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Permit Number: T06OT02735
Parcel: 130010050

Review Status: Completed

Review Details: FLOODPLAIN

Permit Number - T06OT02735
Review Name: FLOODPLAIN
Review Status: Completed
Review Date Reviewer's Name Type of Review Description Status Comments
11/16/2006 ELIZABETH EBERBACH ENGINEERING REVIEW Denied DATE: November 16, 2006
TO: Patricia Gehlen; CDRC Manager
SUBJECT: Railroad W.A.S.H. Overlay, Grading, Floodplain Use Permit Submittal Engineering Review
REVIEWER: Elizabeth Eberbach
ACTIVITY NUMBER: T06SA00260, T06OT02735, T06CM05565, T06BU02535

SUMMARY: The W.A.SH. Report package was received on October 27, 2006. Development Services Department Engineering Division has done a review of the received items. The subject watercourse adjacent to this site, Railroad Wash, is designated as a Watercourse Amenities Safety and Habitat (W.A.S.H.) Ordinance wash and was disturbed June 2006 without review/permits. This submittal represents part of the mitigation to resolve the disturbance at the site. Engineering does not recommend approval of the overlay package at this time. The earliest it can go to SAC is December. If it is going to go in December, the comments from Landscaping, Zoning and Engineering will need to be addressed and returned to use early next week 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 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 comments:
a) Entitle report as Environmental Resource / W.A.S.H. Report.
b) 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.
c) Tucson Code Sec.23A-50.(2): Address the following:
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 vegetation will be replaced and show on a mitigation exhibit.
d) Tucson Code Sec.29-15(b)(1): Address the following element comments:
i) Element b - provide discussion of existing and pre-disturbed erosion impacts, especially downstream of disturbed area.
ii) Element c -clarify existing Fairland Stravenue right-of-way along the wash in section 5.3 of report and whether the south 50-foot Study Area overlaps the railroad and Fairland Stravenue. Clarify right of way on W.A.S.H. exhibit.
iii) Element e - 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.
iv) 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 and how any mitigation supports reestablishing pre-disturbed conditions.
v) 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 or clarify using larger scale or differentiated linetypes.
vi) Element i- Address the following geotechnical evaluation comments:
(1) Regarding the geotechnical assessment for the gantry supports, provide 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.
(2) Explain how safety factors are recommended to be used for proposed design in W.A.S.H. Report.
vii) Tucson Code 29-12 (a-d): Add conclusion/summary as to how the proposed project meets the intent of the ordinance. The introductory or closing statement in the W.A.S.H. Report should state whether the proposed development and mitigation, whether in the study area but not in the resource area, or within the resource area, is compatible with the purpose and intent of the W.A.S.H. Ordinance regulations.
e) On W.A.S.H. exhibit and grading planview, clarify W.A.S.H. Ordinance limits. Provide the following delineations for clarification:
i) a top of bank delineations,
ii) a 50-ft offsets for the 50-ft Study Areas for both sides of the wash,
iii) any delineation for the remaining resource area found within that study area,
iv) delineation of East Fairland Stravenue.
f) Tucson Code 29-16(b): Provide additional cross sections in W.A.S.H. Report and grading plan, that clarifies location of:
i) the stravenue,
ii) railroad property limits,
iii) grading limits, mitigation area,
iv) wash,
v) top of banks,
vi) setbacks, gantry,
vii) cut and fill widths & depths,
viii) and limits of disturbance.
2) Address the following additional specific grading comments:
a) Address the following comments for sheet GD-1:
i) List area of disturbance in square feet and acreage on grading plan.
ii) Provide an estimate for cut/fill quantities on cover sheet.
iii) Revise general grading note 8 to reflect City of Tucson, not Pima County.
iv) Update general grading notes 2 and 12 to revise Chapter 36 to 'City of Tucson Development Standard 11-01'.
v) Reference the project's geotechnical evaluation document, firm name, job number, and date on general grading note 14.
b) Label limits of grading/disturbance limits on planviews.
c) For SWPPP report:
i) Provide a SWPP exhibit that addresses the following:
(1) Interim erosion control measures shall be placed within the grading limits that match grading plan. On the SWPPP exhibit, address the following:
(a) Depict disturbance limits,
(b) Label grading limits.
(c) Place controls within the grading limit.
(d) Provide locations where contractor is to install specific interim erosion/sediment/pollution controls (wattles, logs, sediment berms, and silt fence) within the grading/disturbance limits.
(2) Designated concrete washout locations are required; show location of concrete wash-out area on plan view of SWPP exhibit. Delineate limits of designated concrete washout area such that it is not located in the wash or outside of the grading/disturbance limits area.
(3) Show limits, dimensions, and designated location of any temporary stockpile area(s) with appropriate controls.
(4) Provide a general location map on an exhibit that identifies the receiving waters.
ii) Add a note to the SWPP exhibit and/or front of SWPP report stating that the operator shall report to ADEQ any noncompliance (including spills) which may endanger human health or the environment. The operator shall orally notify the office listed below within 24 hours:
(1) Arizona Department of Environmental Quality
1110 W. Washington, 5th floor (5515B-1)
Phoenix, AZ 85007
Office: 602-771-4466; Fax 602-771-4505
iii) Revise detail E6 to clarify that there will be no obstruction of flow by removing earth material above grade on upper left detail.
iv) Provide copy of the General Permit within report.

Once you have addressed the comments, you are welcome to set up a meeting to go over the comments. Submit a revised submittals for both the grading plan, revised SWPPP, and revised W.A.S.H. Report with 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, let me or Joe Linville know. Call me at 791-5550, extension 2204.

Elizabeth Eberbach, P.E., CPM, CFM
Civil Engineer
Engineering Division
Development Services

Final Status

Task End Date Reviewer's Name Type of Review Description
11/30/2006 DELMA ROBEY OUT TO CUSTOMER Completed
11/30/2006 SUE REEVES REJECT SHELF Completed