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MEMORANDUM
To: Suzanne Wolff, Community Development Department
From: Warren Rider, Environmental Health & Natural Resources
Department
Date: April 10, 2008
Re: Aspen Valley Ranch Special Review, Designation to Historic
Register, Minor Amendment to Development Permit, GMQS
Exemption (PID 2643-053-02-001; Case P166-07)
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SUMMARY OF RELEVANT PARTS OF APPLICATION: The applicant is seeking
approval for streambank restoration and enhancement, pond development, and
encroachment into the established setbacks to river and stream corridors and
wetlands.
DISCUSSION: A site visit was conducted on June 26, 2007 by Warren Rider and
Suzanne Wolff from the Community Development Department.
The Pitkin County Environmental Health & Natural Resources Department
("EH/NR") has reviewed the details of the Aspen Valley Ranch application under
the authority of the Pitkin County Land Use Code and has the following
comments.
1-60-220 Erosion
Applicant has stated that the owners of individual lots will submit erosion control
plans as part of the construction management process. Applicant currently holds
a State of Colorado Stormwater Discharge Permit for Construction. This permit
should cover activities for the individual lots until permits are transferred to
individual lot owners. Subdivisions are viewed as a "Common Plan of
Development" under CDPHE stormwater rules:
'A common plan of development or sale' is a site where multiple separate and
distinct construction activities may be taking place at different times on different
schedules. Examples include: 1) phased projects and projects with multiple filings
or lots, even if the separate phases or filings/lots will be constructed under
separate contracts or by separate owners (e.g., a project where developed lots are
sold to separate builders); 2) a development plan that may be phased over multiple
years, but is still under a consistent plan for long-term development; and 3)
projects in a contiguous area that may be unrelated but still under the same
contract, such as construction of a building extension and a new parking lot at the
same facility. If the project is part of a common plan of development or sale, the
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disturbed area of the entire plan must be used in determining permit
requirements.
CDPHE website, accessed January 4, 2008, Stormwater Fact Sheet -
Construction, emphasis added.
Applicant shall provide for all lots to be included within its Stormwater
Management Plan until its permit(s) can be officially transferred to individual lot
owners through CDPHE.
7-20-30 Water Courses and Drainage
Applicant proposes streambank restoration and channel enhancements on Red
Canyon Creek as well as diversions and potential pond and wetland creation.
Sections 7-20-30(c)(1)(a) and (b) require "[m]aintenance of historical flow
patterns and runoff amounts to reasonably preserve the natural character of an
area" and the "unimpeded flow of natural water courses." Applicant has not
provided details on the specific methods to be employed in those areas proposed
for enhancement. Recommendations from a restoration hydrologist have been
provided but again, design details have not been provided for review.
Proposed actions have not adequately addressed how maintenance of historical
flow patterns will be achieved, nor has the applicant addressed how the natural
character of the area (stream corridor) will be preserved given the potential
diversions of water out of the natural channel. Diversions, in and of themselves,
could be viewed as impediments to the flow of natural water courses on the
property by generating reductions in natural flows through Red Canyon Creek.
Applicant shall show that the proposed actions do not adversely impact the
natural character and function of Red Canyon Creek. Generation of man-made
wetlands, ponds, and trout fisheries should not be approved at the expense of
the natural systems of Red Canyon and Dry Woody Creeks and in the name of
"habitat improvements."
7-20-40 Floodplain Hazards
Applicant represents that no improvements will be located within the floodplain
with the exception of one homestead driveway and stream enhancements.
Applicant was not specific as to which homestead this driveway applies to.
However, if no other alignment is possible for the driveway and the applicant
applies for and receives a Floodplain Development Permit the proposed driveway
could be allowed within the floodplain. Stream enhancements would also be
allowed within the floodplain if a Floodplain Development Permit is applied for
and issued.
In reviewing the application, staff observed that the ISDS easement on
Homestead 4 appears to encroach into the floodplain of Red Canyon Creek.
Section 7-20-40(b)(2)(g) states that "no use, fill, construction, excavation,
embankment, or alteration on or over any portion of the floodplain shall be
permitted that would result in ... [t]he infiltration of floodwaters into on-site
wastewater disposal systems that would impair their functioning or pollute the
stream." Applicant was required to address this issue before approval of the
application and remove the ISDS easement from the floodplain of Red Canyon
Creek on Homestead 4. This requirement has not been completed by applicant.
7-20-80 River and Stream Corridors and Wetlands
Applicant does not propose extensive encroachment into the setbacks as
established in Section 7-20-80. However, applicant has vested rights allowing for
encroachment into the current setbacks on Homesteads 4, 8, and 9. Additional
proposed actions within the established setbacks include stream restoration and
enhancement actions, as described in Attachment 6 to the application. Per
Section 7-20-80(c)(2), "[b]ank stabilization and riparian restoration work may also
be permitted in riparian wetland buffer areas upon a finding that any adverse
impacts will be adequately mitigated as required by subsection (d)."
As noted above, applicant has provided a narrative description of activities that
are being contemplated. No details, design specifications, or channel restoration
techniques have been provided to adequately determine whether or not the
proposed (or contemplated) activities meet the requirements of Section 7-20-80.
Applicant should provide more detailed description and details of the proposed
actions prior to approval of those portions of the application.
Summary of Conditions of Approval:
Applicant must provide details on the specific methods to be employed in
those areas proposed for stream enhancement.
Applicant shall show that the proposed stream enhancement actions and
water diversions do not adversely impact the natural character and
function of Red Canyon Creek.
Applicant must remove the ISDS easement from the floodplain of Red
Canyon Creek on Homestead 4.
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