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Home My WebLink AboutRIDGEWOOD HILLS RESIDENCES (4TH FILING) - PDP - 33-10 - CORRESPONDENCE - ENVIRONMENTAL REPORT (5)t /- Ridgewood Hills/Shenandoah Neighbornood Council Response to Ridgewood Hills Development Proposal development site. However, we do recommend radon abatement, as listed later in this section (see Requested Actions). 2.5 Requested Actions Given the lack of a formal written analysis submitted with the development proposal or an examination by the City (at least there are no documents in the public record for a judgment on the need for an environmental review), the Council respectfully submits that the following actions be taken by the City regarding potential environmental impacts associated with the proposed development: • Natural Habitats and Features: A suitable evaluation should be conducted of the natural resource impacts of the proposed development, especially a survey of the Preble's Meadow Jumping Mouse. When performing the evaluation, the entire disturbed area should be reviewed, including areas that will encompass work needed to modify storm water drainage Pond 2. If sensitive species or habitats are found or could potentially be impacted, a detailed mitigation plan should be required in the development proposal. • Air Quality: Compliance with the general requirements, emission limitation guidelines, control measures and operating procedures listed in Regulation 1, Section III.D.2.b should be required. • Noise and Vibration: The requirements set forth in Section 3.4.4 of the Code should be enforced by requiring the developer to deploy an ambient noise monitoring network around the perimeter of the site at adjacent residences (including those across Triangle Avenue), to ensure noise levels do not exceed the City's Noise Control Ordinance. Vibration monitoring equipment during grading and other structural construction activities should also be deployed at the perimeter at adjacent residences to limit the developer's liability should excessive vibration result in property damage at existing residences. • Health Risks: Due to the presence of radon gas in the community, the City should require the developer to install radon mitigation systems in all structures at the proposed development. Ridgewood Hills/Shenandoah Neighbornood Council Response to Ridgewood Hills Development Proposal Kestrel, Coopers Hawk, Northern Harrier, American goldfinch, house finch, song sparrow, western meadowlark, and numerous unidentified swallows that feed on insects there. 2.1.3 Mammals Observations of mammals include red fox, ground squirrels, other burrowing rodents (probably pocket gopher), mice, rabbits, and coyotes. 2.1.4 Habitat Several small parcels, including the one proposed for development, provide a continuous open space with the Long View Farm Open Space. Though the parcel in question has been disturbed and graded nearly a decade ago, it provides unplowed upland habitat and compliments the more mesic drainages and tree stringers that are found immediately southeast. Water runoff from lawns, natural water drainage, and water captured by nearby detention ponds have provided habitat diversity for species tolerant of adjacent suburban areas. 2.2 Section 3.4.2: Air Quality The United States Environmental Protection Agency has promulgated 24-hour ambient air quality standards for particulate matter (PM,o and PM2.5). Excessive particulate matter exposures over this relatively short period of time can be dangerous to not only sensitive populations (including children) but also healthy adults. The duration of construction is not relevant but rather the maximum potential short-term emissions and subsequent public exposure are important. Based on the acreage to be disturbed, it does not appear that a permit is required by CDPHE APCD, Regulation 3. However, we do believe that the general requirements, emission limitation guidelines, control measures and operating procedures listed in Regulation 1, Section III.D.2.b should be required for this project. The distance between grading activities and full-time residences is very short. As such, and given the fact that there are many young children living in these homes, the developer should be required by the City to incorporate the requirements in Regulation 1, Section III.D.2.b in order to protect the public from excessive exposure to particulate matter generated as fugitive dust from grading activities. 2.3 Section 3.4.4: Noise and Vibration Since the distance between grading and construction activities, and full-time residences is very short, the community is concerned about noise and vibration impacts during construction of the proposed development. Requested monitoring requirements are listed later in this section (see Requested Actions). 2.4 Section 3.4.9: Health Risks Radon gas is present in many areas of the country, and Fort Collins is no different. Several residences in the Ridgewood Hills and Shenandoah communities have conducted radon testing and determined the need for radon mitigation monitoring systems. Since radon is highly transient, we do not recommend performing pre -construction radon monitoring at the proposed Ridgewood i s/Shenandoah Neighbornood Council Response to Ridgewood Hills Development Proposal 2.0 Environmental and Natural Area Protection Standards The Ridgewood Hills/Shenandoah Neighborhood Council (Council) believes that several subsections of Division 3.4 of the Fort Collins Land Use Code (Code) require evaluation for the following topics: Natural Habitats and Features (Section 3.4.1), Air Quality (Section 3.4.2), Noise and Vibration (Section 3.4.4), and Health Risks (Section 3.4.9). Each subsection of the Code is discussed below. The development proposal did not contain an analysis of environmental and natural area impacts, and there was no statement of basis for not requiring such analysis in the City's review of the developer's conceptual design document submitted in June 2010. Without a judgment by City staff regarding the need for such assessment, and without an analysis conducted by the developer, the Council has no information to review on these important topics. As such, the Council has made the following observations in the field, and reviewed the Code and Colorado Department of Public Health and Environment (CDPHE) Air Pollution Control Division (APCD) regulations. Requested actions by the City are presented in Section 2.5 2.1 Section 3.4.1: Natural Habitats and Features We understand that the footprint of final development (i.e., where the new structures will actually be located) is likely to be outside the buffer zone of sensitive areas identified in the City's Natural Habitats and Features Inventory Map. We believe this map may be outdated for this specific area, and that the following species and habitats are present not only in and near the development itself, but also within the natural storm water drainage pond (known as Pond 2 in the drainage study submitted with the development proposal). We are concerned about the lack of current survey data for these habitats/species and also believe the City should consider the impact of proposed modifications to Pond 2 (see drainage report), as well as all areas of land disturbances associated with the construction and mitigation measures submitted with the development proposal. 2.1.1 Preble's Meadow Jumping Mouse Though habitat appears marginal for this threatened species, observations of a jumping mouse fitting the description of a Preble's (Zapus hudsonius preblei) have been made within the last year. Susan Champion who lives on Triangle Avenue, which backs up against the property, has twice observed a live jumping mouse (described as having an upright and hunched stance, large feet, with darker coloration on the back and behavior of high jumping). She suspects that her cat brought them to her property from Tract C behind her house. It is very possible that these mice are foraging .beyond riparian vegetation to the disturbed uplands of the proposed development site. 2.1.2 Migrating Birds and Avifauna The proposed development site is utilized for foraging, perching, and roosting of several avian species. Observations by residents include Great Horned Owl, Red Tailed Hawk, American Page 1 0 Steve Olt From: McKean, Patrick [Patrick. McKean@aecom.com] Sent: Thursday, December 16, 2010 8:14 AM To: Lindsay Ex; Steve Olt Cc: Chris Bruno; JShort; Chad Moore Subject: Ridgewood Hills development proposal - draft environmental eval request Attachments: Draft Environmental —Natural Areas Impacts.docx Good morning Lindsay — attached is our DRAFT environmental and natural habitat review section from our forthcoming report. This section is still in draft form but covers the topics we feel are important for considering during your review of the development proposal. What time will you be doing your site walk tomorrow? We're trying to round up a member of our Council to accompany you so having your time window would be very helpful We plan to submit our full report Steve by Monday morning at the latest, which will include discussions regarding traffic, school, and property value impacts associated with the proposed development. Thank you for taking the time to speak with me on Tuesday to explain the City's review process for development proposals. Please call me either on my cell or weekdays (work) number below if you have any questions on this draft report. Patrick McKean 530-3461(weekdays) 223-5678 (evenings and weekends) 219-6601 (cell) 12/16/2010