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HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 01/13/2004 - CITYWIDE FLOODPLAIN REGULATIONS (EXCEPT FOR THE PO DATE: January 13, 2004 STUDY SESSION ITEM STAFF: Jim Hibbard, Bob Smith, FORT COLLINS CITY COUNCIL Marsha Hilmes-Robinson SUBJECT FOR DISCUSSION Citywide Floodplain Regulations (except for the Poudre River). GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED • Does City Council need any additional information before they can consider adoption of the proposed changes? • Does City Council agree with staff's approach of balancing risk with regulation? o More restrictive in floodway, less restrictive in flood fringe o More restrictive for new development, less restrictive for existing development o More restrictive for residential, less restrictive for non-residential • Are there any specific regulations Council would like to see other alternatives on? • Is it OK to have three regulations less than FEMA minimums and move to a Class 5 CRS rating? Executive Summary In 1999, Council adopted a higher rainfall standard based upon a technical analysis of rainfall statistics. Higher rainfall results in higher runoff and larger floodplains. In 2001, City Council gave the Utilities General Manager the authority to remap floodplains using the higher rainfall. Also in 2001, Council adopted interim floodplain regulations for the changing floodplains and instructed staff to review the City's floodplain regulations (except for the Poudre River) with the goal of balancing risk with regulation. The mapping is complete and a map of the revised citywide floodplains is attached. In September of 2002, a staff memo outlined three basic themes for balancing risk with regulation as follows: • Stricter regulations in the higher risk floodway areas and less restrictive regulations in the remaining 100-year floodplain. • Stricter regulations for new development and less strict regulations for existing structures. • Stricter regulations for residential development and less strict regulations for commercial development. Using these themes, staff reviewed floodplain regulations and formulated recommendations. A "Quick Guide" to the proposed floodplain regulations is attached. The quick guide is designed for the general public and includes definitions of floodplain terms and a summary of the proposed January 13, 2004 Page 2 regulations. Summaries of the major provisions for the floodway and flood fringe are on pages 7 and 8 respectively. Also attached is a more in depth and detailed matrix of the proposed floodplain regulations. It shows whether a proposed regulation is more restrictive, less restrictive,or remains the same when compared to the current regulation. The matrix also compares the proposed regulations to the Federal Emergency Management Agency(FEMA) minimum requirements. The matrix is divided into three sections, one each for the floodway, flood fringe, and moderate risk zones. There are three provisions of the proposed regulations shown on the matrix that are less than the FEMA minimum. Effectively, this means that City designated floodplains would be regulated at a lower level than FEMA floodplains on these three criteria. The Community Rating System (CRS) is a voluntary incentive program that encourages communities to go beyond FEMA minimum requirements for floodplain management. The City's current rating is a Class 4, which means residents and businesses of Fort Collins receive a 30%discount on flood insurance premiums. The proposed regulations would result in Fort Collins moving to Class 5. This would cause the City's discount rate to drop to 25%, raising the average annual flood insurance premium by $18. There are 346 flood insurance policies in Fort Collins. Background and Past Council Direction The City of Fort Collins has participated in the National Flood Insurance Program since 1979,which enables property owners to purchase flood insurance through this federal program. Part of that participation includes the City's enforcement of floodplain regulations on existing and new development in the various floodplains across the city. Undeveloped properties located in a floodplain can develop as long as they comply with the floodplain regulations. The Fort Collins Utilities is charged with the administration of these regulations. The purpose of the enforcement of the regulations is to reduce the potential for loss of life and damage to properties located in or near these floodplains. Periodically the City has revised or updated these floodplain regulations. Floodplain regulations were first adopted in the City in the mid 1970's for the Poudre River. In 1979 the City of Fort Collins entered the National Flood Insurance Program with the adoption of floodplain regulations for the Poudre River,Spring Creek,and Dry Creek basins. Between 1979 and 2001 enforcement of floodplain regulations was expanded to other basins within the City when the master plan for that basin was adopted. Several of the floodplains in the City have not been submitted to or approved by FEMA. In these floodplains the City has the option to establish floodplain criteria below the FEMA minimum. City designated floodplains are located in the Old Town, West Vine, McClellands/Mail Creek, Canal Importation, Foothills and Fossil Creek basins. FEMA designated floodplains are located in the Spring Creek, Dry Creek, Cooper Slough and Boxelder Creek basins. In the FEMA floodplains there are minimum standards set by FEMA that must be met in order to participate in the National Flood Insurance Program. However, FEMA encourages and supports communities that go beyond the minimum FEMA regulations in both FEMA and locally designated floodplains. January 13, 2004 Page 3 After the 1997 flood, questions were raised concerning the adequacy of the City's floodplain regulations. City Council directed City staff to review the floodplains across the city and make recommendations on changes. In 2000, the floodplain regulations for the Poudre River were reviewed and changes to the regulations were adopted. Regulations for the other basins were to be reviewed as the City remapped the 100-year floodplains during the development of the basin master plans using the updated rainfall standard. In 2001, the Canal Importation Basin Master Plan and floodplain were adopted by City Council. Floodplain regulations were initially adopted for both existing and new development. However, several months later, City Council suspended regulations for platted and existing development on an interim basis until the citywide review could be completed. However, City Council determined that new development and critical facilities must continue to comply with the floodplain regulations as contained in city code. At that time, staff was instructed to review the City's floodplain regulations for all basins other than the Poudre River with the goal of balancing risk with regulation. In September of 2001, the Utilities General Manager was given the authority to remap the floodplains using the higher rainfall. The new mapping was completed in 2002 and 2003. Floodplain Maps and Property Statistics A map of the revised citywide floodplains is attached. The floodplains on this map are the maximum extent of the existing (FEMA) mapping and the new City mapping. The 100-year floodways (areas of greatest risk with high depths and velocities)are shown in dark blue. The 100- year flood fringe is shown in light blue. The moderate risk areas, shown in green, are either the existing FEMA 500-year floodplains or areas of sheet flow in the 100-year floodplain with less than 1-foot of depth. The 500-year floodplains for the FEMA-designated floodplains will be updated and remapped when FEMA adopts the new City mapping. A 500-year floodplain will not be mapped for the City-designated floodplains. Citywide statistics for the 100-year floodplain are shown in the following table. Floodplain Statistics Floodway Flood Fringe Moderate Risk Area (acres) 1,900 1,300 400 Number of Structures 700 1,700 900 Over the next several years, revised mapping will be submitted to FEMA for the basins that have FEMA designated floodplains. This will result in only one regulatory map per basin. Floodplain maps are also revised after each capital improvement project to reflect areas that are no longer in a mapped floodplain. Since 1997, over 900 structures were removed from the floodplain in the Old town basin due to the construction of stormwater capital projects. Proposed Floodplain Regulations As staff began review of the floodplain regulations, the purpose of floodplain regulations as contained in Chapter 10 of the City Code was reviewed and paraphrased into the following statement of purpose. January 13, 2004 Page 4 "Strive to promote public safety, raise awareness of flooding risks, and reduce public and private losses from floods through enforcement of floodplain criteria that balance risk with regulation." To carry out this purpose, three underlying themes were identified: 1. Floodway vs. Flood Fringe Map a floodway (areas of greatest depths and highest velocity) in all of the City's floodplains where practical. This allows the higher risk areas to be distinguished from the floodplain areas of lower risk. Staff is recommending stricter regulations in the higher risk floodway areas and less restrictive regulations in the remaining 100-year floodplain. 2. New Development vs. Existing Development It is important that we not create future problems that will place people at risk and require those who come after us to spend more money fixing new problems. On the other hand, there are many existing homes and businesses currently in floodplains where owners have normal expectations of being able to remodel, repair and add to their structures. Staff is recommending stricter regulations for new development and less strict regulations for existing structures. 3. Residential Development vs. Non-Residential Development From a health and human safety perspective, residential structures represent a higher risk than commercial structures. Staff is recommending stricter regulations for residential development and less strict regulations for commercial development. Compared to the City's current regulations, some of the proposed regulations are more restrictive, while others are less restrictive. The attached floodplain regulation matrix identifies the proposed regulation changes. It is color coded to show which changes are more restrictive, less restrictive,or remain the same when compared to existing regulations. This matrix also compares the proposed regulations to the FEMA minimum requirements. To help illustrate these regulations with less complexity, the attached "Proposed Floodplain Regulations Quick Guide" was prepared. Key Changes to Floodway Areas • More Restrictive than Current Regulations - New residential structures would not be allowed. Currently they are allowed if they show no-rise. - New residential additions would be not allowed.Currently they are allowed if they show no-rise. - Basements in non-residential new structures and additions would not be allowed. Currently they are allowed if flood proofed. • Less Restrictive than Current Regulations - Substantial Improvement time period changed from the life of the structure to 1-year. - Freeboard requirement changed from 18-inches to 6-inches on substantial improvements and non-residential additions. - Utilities General Manager can waive floodplain regulations in a City floodplain if a capital project is under construction. Currently, completion of the project is required. January 13, 2004 Page 5 - Sub-grade crawl spaces would be allowed per new FEMA guidelines. Currently sub- grade crawl spaces are not allowed. Key Changes to Floodplain Fringe Areas • More Restrictive than Current Regulations - New mobile homes or modular offices would not be allowed except in existing parks. Currently the development of new mobile home and modular offices parks are allowed. • Less Restrictive than Current Regulations - Substantial Improvement time period changed from the life of the structure to 1-year. - Improvements on a floor above the flood elevation would not count toward the substantial improvement amount (50% of current market value)for structures in a City floodplain. Currently all improvements in the structure count toward the substantial improvement amount. - Pop-top additions on residential structures in City floodplains are required to flood proof the lower floors if they exceed substantial improvement. Currently a pop-top addition that is a substantial improvement would require the house to be elevated. - Freeboard requirement would be changed from 18-inches to 6-inches on substantial improvements and additions. - Utilities General Manager would be able to waive floodplain regulations in a City floodplain if a capital project is under construction. Currently,completion of the project is required. - Sub-grade crawl spaces would be allowed per new FEMA guidelines. Currently sub- grade crawl spaces are not allowed. Key Changes to Moderate Risk Floodplain Areas • Less Restrictive than Current Regulations Allow new critical facilities in the 500-year floodplain and in the 100-year sheet flow areas of less than 1-foot. Currently new critical facilities are not allowed in the moderate risk areas. New structures or additions in the 100-year sheet flow areas do not have to be elevated or flood proofed. Currently they are required to be protected. In addition, there will be some minor"clean-up"items that will be included when the ordinance is considered by City Council for adoption. These items are considered house keeping items that are needed to enable city code to be compatible with FEMA terminology and current administration of the regulations. Proposed Regulations Below FEMA Minimums In the past, the City designated floodplains have been regulated the same as the FEMA floodplains with some criteria above the FEMA minimum. However, in the proposed regulations,three of the criteria are less restrictive than the FEMA minimum. These are: 1. Improvements on a floor above the flood elevation would not count toward the substantial improvement amount (50% of current market value). January 13, 2004 Page 6 2. Pop-top additions on residential structures in City floodplains are only required to flood proof the lower floors instead of elevate if they exceed substantial improvement. 3. The Utilities General Manager would be able to waive floodplain regulations once a stormwater capital project is under construction that will remove the structure from the floodplain. Effectively, this means that City designated floodplains would be regulated at a lower level than FEMA floodplains on the above three issues. Community Rating System and Flood Insurance Considerations Fort Collins currently has one of the highest rated stormwater management programs in the country based on the FEMA Community Rating System(CRS). The CRS is a voluntary incentive program that encourages communities to go beyond FEMA minimum requirements for floodplain management. Based on a rating of numerous stormwater management activities (public outreach, higher regulatory standards, drainage system maintenance, flood warning, etc.) residents and businesses of a community receive a discount on their flood insurance premiums. Fort Collins currently has a Class 4 rating (on a scale of 1 to 10 with 1 being the best) which results in a 30% discount on flood insurance premiums. All structures in Fort Collins are eligible for flood insurance regardless of whether they are located in a floodplain or not. Lenders must require flood insurance for any structure in a FEMA-designated floodplain. Lenders may require flood insurance for structures in City-designated floodplains or areas not even mapped in a floodplain, although this is not a common practice. The cost of flood insurance depends on many variables including amount of coverage, deductibles, type of structure, and how high the structure is elevated above the flood level. As of November 2003, there are 346 flood insurance policies in Fort Collins. Of the 346 policies, 72% are residential and 28% are non-residential. Changes in regulations as proposed would result in Fort Collins moving from Class 4 to Class 5. This will result in the City's discount rate dropping to 25%. The impact of this change is shown in the following table. Impact of CRS Class Chan a on Annual Flood Insurance Premiums Average Annual Average Premium Annual Community Before Percent Premium After Wide Annual CRS Class Discount Discount Discount Premium Cost 5 (proposed) $364 25% $273 $94,458 4 current $364 30% $255 $88,161 Difference 5% $18 $6,297 Fort Collins obtained the Class 4 rating in 2000, having had a Class 6 rating since 1995. As of October 2003, there were 994 communities nationwide participating in the CRS program. The following graph shows the distribution of communities by CRS class: January 13, 2004 Page 7 CRS Communities by Class (994 participating as of 10/01/03) 450 393 a400 --346 __.._ .. ... _..... _ .. -... -........__... 350 300 - .. E 250 P $ , c°i 200 --- ,°= - -- 177 - --- ° 150 - a 100 52 .. ... _ ..._._......._ .... .. E ° y'?" 23 0 50 ... ----- . . ..... _....._ _.... 3- 1...... c O i ... - mom Class 9 Class 8 Class 7 Class 6 Class 5 Class 4 Class 2 In addition to offering discounts on flood insurance premiums, the community's CRS rating is also used as a factor in evaluating annual pre-disaster mitigation grant applications to FEMA. The City has currently applied for$3 million for capital projects on Spring Creek. How much weight is given the CRS rating and effect of the proposed CRS class change on future grant applications is unknown. There are two specific regulations staff is proposing to become less restrictive that will effectively result in Fort Collins moving to a Class 5. If Council wants to maintain the Class 4 rating, the following regulations would have to be adopted in lieu of the staff recommendation: • require no new critical facilities in the moderate risk areas, and • require the time period for calculation of substantial improvement be cumulative for 10 years in the FEMA floodplains. Public Outreach The process of informing property owners in the City's 12 stormwater basins of upcoming changes to both the master plan and floodplain regulations began in early 2002 and continued until late 2003. A variety of communication tools such as customer mailings, web pages, press releases and media interviews, public meetings and open houses, and outreach to both internal and external groups potentially affected were used. In 2002, customers most affected by floodplain boundaries and proposed regulations were identified as the primary focus of initial outreach. Because a significant number of those within the mapped floodplains are Larimer County residents, City and County staff collaborated on public outreach. January 13, 2004 Page 8 These customers received a packet that included comprehensive information about: • floodplain mapping, • the review process for floodplain regulations, and • the impacts on property mapped within the floodplains. Each property owner/renter also received: • an individualized floodplain map showing their property relative to the floodplain, • a flood history for their basin, and • property protection information. Eight public open houses were held to provide an opportunity for customers and staff to discuss the information included in the mailings as well as the master planning process. Customers received mailed invitations and open houses were advertised in the Fort Collins Coloradoan and North Forty News. At the same time, web pages were developed on the Utilities Web site to provide additional information. Over 4,000 packets were mailed, and 250 people attended the 8 open houses held during the year. In 2003, public outreach was expanded to include all property owners and renters in the City's stormwater drainage basins, not just those within the mapped floodplains. At a kickoff open house held in February, property owners and renters were invited to learn more about the City's stormwater drainage basins, floodplains and regulations, safety and flood protections, and the regional weather patterns that can result in flash flooding. Following the kickoff, nine additional public open houses were held. Information presented at the open houses consisted of basin-specific information as well as information about the citywide planning process, including: • flooding histories for each basin, • maps showing identified basin problems, • maps showing proposed solutions, • proposed floodplain regulations, • stormwater project funding, and • the process for adoption of master planning and floodplain regulations. Over 62,000 pieces of mail were sent, including informational packets, basin-wide kickoff invitations, open house invitations and letters to 24 community organizations. Publicity for the outreach campaign included media releases and briefings, and advertising in local media. The nine open houses were attended by 470 people. Of the 24 community organizations contacted, seven asked for presentations or more information. Presentations were made to six City Boards, including the Water Board,the Natural Resources Advisory Board,the Planning and Zoning Board, the Affordable Housing Board,Landmark Preservation Board and Parks and Recreation Board. Comment forms were available at the open houses and on the Utilities Web site. Thirty-three comment forms were submitted. Although most of those who attended open houses did not January 13, 2004 Page 9 comment formally on either the proposed master plan or floodplain regulations, almost everyone got a chance to express their views to staff. Comments received on floodplain issues can generally be summarized as follows: • questions about the rainfall standard, never seen that much water, even in 1997, • agreed with the themes used to balance risk with regulation, • questions about the accuracy of the mapping, offered data for review, • regulations have a financial impact on property owners, • regulations are too strict, • regulations are not strict enough, • would like different regulations in each basin, • properties in floodplains pay for flood insurance in addition to stormwater rates, and • benefited from remapping, would like City to submit to FEMA soon. ATTACHMENTS City of Fort Collins Flood Risk Map Proposed Floodplain Regulations Quick Guide Floodplain Regulation Review Table ® CITY OF FORT COLLINS FLOOD RISK MAP wE Mwa a 0.5 1 z i\Y •4- 1 npY3�"� I.fi'•t» { 1 MPunp.NV—oR \' 1 a. 1 `a J Z A� r•-•1 s r l 9 �- r% 1 r-,j f` 1 1 loodplain Legend Hl Legend oa a1Fk MOMrvb W.x Poad.R-w 50'.hyev PRcuct Co 1pr(Oph x Vebiy>=6) ® May lndHa: -A .dFEMA sooyearfipotlpbin(FEMA Zone XaOaletl). (� . FbMr oay-Nwa M 100.year MOJd reas ain with grealeat doWiRs am -A d FEMA w CMy lMymr0oo0gaRw(seat flow)with "---- City Limits MbAvekMtlea. Groups delAs d ass tM 1fM Low al. -/ .w adaa ay Issas marina two-year fora. UGA® may isms -AwADwaa d FEMA 106year600lainad in,Inds aaaa AO.aD AH) /veal MS. dFEMA aM Naaamsaw ,awsarflomplain ndWiy poming aeasam aMel i� fbcaPigna.Local Grain �Ubma ma l�exHtyear am SWYear flnw kM1ave�ageaedM1ad 1-3 asead. a0•Pre Ys Water Features mare u a 1%annwi maDnathx lMe areas will m moaea. Major Streets '100 Year Pood lain is shown as the maximum extent of FEMA and City Bootl lairs combined. ` N " y O :� o w ._ CD o ow V o � CL CD A+ T W N N n o .� y.., co CD il� CM OD O cooO _ � U C LL fl. LL i N LL. 3 x 0 i , a Y 1` ! C o l LL E 1 T p �•�, ,1 U a o C , a N� ai O i( O �C w o AD r � u aoi © yry yr fr m��)�<y"yr��yarr � p O o m �rrArnr xds.rss � ' '� �. E s o p. o vim ; o o N o d o O iO O V O D O O 4� sy� cC v N O N O 1 V 0 O N CO T c .c c c c c '� UaJ \.Y '4'F• � �SY (C O �. IC O T T T T T T ~ cz cu aj bbA ,CL L T 36' rr Qr iV-i co W d 0 a` m U tC z rA d = N r. >_ O > > co `c° O d C -0 N 'O ;� a O G� p p O O w -10o a j t Nca v Z Q ���1�� fG (/6. L (D L y 4 N t' 1„ .��' cb v bA L O 9 O O N � .x � •� r c o .c m Y3 v . y• v G a=i as Q c �n- O ,� U > > -0 N -O — O W O Y O � O 0 N +. m f.. bbc v C CD O � O Y 01 E 6 Z i.. v i cd O_ C O 0 t > tz v d 0) •E -- 0- iO N �" �" O O E O 4 f6 07 -0 w �+ U L o N -0 d C y Y C O O O .a C O C N A? 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Floodway-Area of 100-year floodplain with greatests depths and fastest Mayin Jude:velocities. City Flood Risk Map Ames o lF i -Areas FEM A 700•year flootlplein(FE MA Zonas A,AE,AO,and AH) -Amasof City 100-year lloodplaln including ponding areas and sheet This hformeuon is bared on the Federal energancyMalagemera flow areas wdth average depths of 1-3 feet. Poenoyf(FEMA)Rood lnwranoe Raw Mq(FIR4 and the Ciryof There Is a 1%annual chance that these areas will be flooded. Fort colllnsMasrer Rainagewag Plans. lhls later does not Imply Moderate,Risk drrtthe rablenoed propemywlll orwill notbe tee from flooding or damage. 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Qj j v / � F f \ 7 ° / \ � � & d � \ k < / 2 ) / � \ k @ E \ § @ ] § \ ° ? s \y � 2. v CAA v ¢, •p, ,.Cti m Je v EM v A Ja z C o E o bo v v � w w � •6, cu .� ItCA a 0 3 Lp ca CA �+ o w o w u a, o p € ,z � •� w c'+"C �' 0 U > •E..' Vie. � O �C > C 5 \ � ƒ � 6 § } § d © < / ( ] ¥ j d \ ( • ] \ \§ j W \ = \ \ \ & ) } \ \ j to \ ƒ � § , � f ) ) ± < j / \ 5 e ! / m to k � \ U \ \ ) , 00 � 22 ) ] / m ! g . 0 ƒ \ ) Co ) \ \ ( § g z \ » t 2 \ = 2 / \ � \ \ \ \ � ] ) } ® 2 e � \ \ / t / \ to / » ) \ \ \ \ \ \ { c � \ ® = r k { } \ \ ( E & @ G ƒ 2 \ & \ \ ƒ \ } ƒ ; / \ t \ -x _ E k / m , to = 2 co { ƒ ] / \ \ 3 ƒ E / : $ 2 A ± a 5 a ` & . \ rr \ / / / / § \ / ( \ Proposed Floodplain Regulations Comment Form Floodplain regulations are intended to regulate development in areas with a high risk of flooding. These regulations help provide a reasonable level of protection for personal safety and minimize flood damage to structures. The proposed floodplain regulations attempt to balance the level of risk with the level of regulation—and to balance individual responsibility with government authority. Please complete the following information. (This information helps us track and compile comments for review by City Council.) Name Address Phone (optional) E-mail (optional) Would you like someone to contact you to answer questions about the proposed regulations? Yes—No Do you live or own property in the floodplain within City limits? Yes _ No_ Don't Know If yes, address of property If yes, is the property? Residential Non-residential _ Vacant Ground If yes, name of basin You are encouraged to review the Floodplain Regulation Quick Guide before answering these questions.Your answers will help us to understand your ideas and opinions concerning the general philosophies used to develop floodplain regulations. 1. By identifying the portion of the floodplain with the greatest depths and fastest moving water (floodway), regulations can be tailored to the level of risk. This approach provides the option to allow new development and additions to existing structures along the less hazardous edge of the floodplain (flood fringe), but not in the most hazardous portion (floodway). Which of the following statements do you most agree with? A. Regulations for the edge of the floodplain (flood fringe) should be less restrictive than regulations for the more hazardous center of the floodplain (floodway). B. Regulations for the edge of the floodplain (flood fringe) should be the same as regulations for the more hazardous center of the floodplain (floodway). 2. A significant number of structures currently exist in the City's floodplains.Which of the following statements do you most agree with? A. Regulations for existing structures should generally be less restrictive than regulations for new development. B. Regulations for existing structures should be the same as the regulations for new development. "Id 11,01W 3. When the property owner of an existing structure in a floodplain remodels or repairs the building, regulations may require protection from flood damage. Which of the following statements do you most agree with? A. There should be no regulations concerning remodeling or repairing existing structures in floodplains. B. There should be regulations concerning remodeling or repairing existing structures in floodplains if the dollar amount of the improvement is significant(50% of the value of the structure or greater). 4. From a health and human safety perspective, residential buildings represent a higher risk than commercial buildings.Which of the following statements do you most agree with? A. Regulations for residential buildings should be the same as regulations for non-residential buildings. B. Regulations for residential buildings should be more restrictive than regulations for non-residential buildings. General Comments Please provide us with any additional comments you have on the proposed floodplain regulations. If commenting on a specific proposed regulation, please list the page number in the Quick Guide where the regulation is found. Thank you for your comments. Return to: Fort Collins Utilities 700 Wood Street P.O. Box 580 Fort Collins, CO 80522-0580 FAX: (970) 221-6619 Ci of Fort Collins ry Utilities a9 ° $ $ aE Ca � Qg E L _ $ o. ?t z w ° � z o � 7tl CrJ a N o rn ° ay •: w 3 ay � o a o a »oo m , a. m o 4 4 m o . $. » m � ' w •3 d a a, co 7 '0 � aE ° E ° a ^p < �. rro C K' �-I OR m � 5' a m S Y z z z y. N ° C C ° O^ O^ a ^• _. .a. �. 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