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HomeMy WebLinkAboutBLOOM - PHASE 1 - PDP210014 - SUBMITTAL DOCUMENTS - ROUND 1 - CORRESPONDENCE-CONCEPTUAL REVIEW 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com August 18, 2021 City of Fort Collins Ms. Brandy Bethurem Harras 281 North College Avenue P.O. Box 580 Fort Collins, CO 80012 Re: Response to Bloom Phase 1 – Concept Review Comments Dear Ms. Bethurem Harras Thank you for your Bloom – Phase 1 Concept Review comments which we received on July 8, 2021. The development team has reviewed all the comments and have addressed them in the following pages. Please feel free to contact me directly should you have any other comments, questions and/or special requests for additional information. We look forward to continuing to work with you and your colleagues at the City of Fort Collins. Sincerely, Norris Design Ryan F. McBreen Principal 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Development Review Coordinator – Brandy Bethurem Harras Comment #1 I will be your primary point of contact throughout the development review and permitting process. If you have any questions, need additional meetings with the project reviewers, or need assistance throughout the process, please let me know and I can assist you and your team. Please include me in all email correspondence with other reviewers and keep me informed of any phone conversations. Thank you! Response: Noted. Thank you. Comment #2 The proposed development project is subject to a Type 2 (Planning and Zoning Board) review and public hearing. The applicant for this development request is required to hold a neighborhood information meeting prior to formal submittal of the proposal. Neighborhood meetings offer an informal way to get feedback from your surrounding neighbors and discover any potential hiccups prior to the formal hearing. Please contact me, at 221-6750, to assist you in setting a date, time, and location. I and possibly other City staff would be present to facilitate the meeting. Response: Per discussions with Staff, it has been determined that this application will go through a Type 1 review process. Comment #3 I will provide you a roadmap specific to your development review project, helping to identify each step of the process. For more detailed process information, see the Development Review Guide at www.fcgov.com/drg This online guide features a color-coded flowchart with comprehensive, easy to read information on each step in the process. This guide includes links to just about every resource you need during development review. Response: Noted. Thank you. Comment #4 I will provide a Project Submittal Checklist to assist in your submittal preparation. Please use the checklist in conjunction with the Submittal Requirements located at: http://www.fcgov.com/developmentreview/applications.php. The checklist provided is specific to this Conceptual project; if there are any significant changes to this project, please let me know so we can adjust the checklist accordingly. I can send an updated copy of the Submittal Checklist to ensure you are submitting the correct materials. Response: Noted. Thank you. Comment #5 As part of your submittal, you will respond to the comments provided in this letter. This letter is provided to you in Microsoft Word format. Please use this document to insert responses to each comment for your submittal, using a different font color. When replying to the comment letter please be detailed in your responses, as all comments should be thoroughly addressed. Provide reference to specific project plans or explanations of why comments have not been addressed, when applicable. Response: Noted. Thank you. Comment #6 The request will be subject to the Development Review Fee Schedule: https://www.fcgov.com/developmentreview/fees.php. I will provide estimated fees, which are due at time of project submittal for formal review. This is an estimate of the initial fees to begin the development review process based on your Conceptual Review Application. As noted in the comments, there are additional fees required by other departments, and additional fees at the time of building permit. The City of Fort Collins fee schedule is subject to change - please confirm these estimates before submitting. If you have any questions about fees, please reach out to me. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Response: Noted. Thank you. Comment #7 Submittals are accepted any day of the week, with Wednesday at noon being the cut-off for routing the same week. Upon initial submittal, your project will be subject to a completeness review. Staff has until noon that Friday to determine if the project contains all required checklist items and is sufficient for a round of review. If complete, a formal Letter of Acceptance will be emailed to you and the project would be officially routed with a three-week round of review, followed by a formal meeting. Response: Noted. Thank you. Comment #8 When you are ready to submit your formal plans, please make an appointment with me at least 24 hours in advance. Applications and plans are submitted electronically in person with initial fees. Pre-submittal meetings can be beneficial to ensure you have everything for a complete submittal. Please reach out and I will assist in those arrangements. Response: Noted. Thank you. Planning Services – Pete Wray 970-221-6754 pwray@fcgov.com Comment #1 FOR HEARING: - Mulberry & Greenfields PUD  The Mulberry & Greenfields PUD hearing and approval will need to be completed before the Bloom Filing 1 PDP can go to hearing. Response: Comment noted.  The residential densities, housing types, let sizes, street network and drainage areas should be consistent with proposed PDP plans. Response: We assume this comment references the PUD, and this PDP is consistent with the Mulberry & Greenfields PUD Master Plan that has been resubmitted concurrently with this application.  Please identify community benefit facilities not associated with development requirements. Response: This information has been included as part of the project narrative. Comment #2 FOR HEARING: - Plat, Bloom Filing One Plat.  The proposed Bloom Filing One incudes four parcels for the entire property, so the plat will include these. I just want to make sure the future development tracts north of the RR and Future Commercial/Retail tract north of Mulberry frontage road are included in this overall plat map. Response: While the Bloom – Phase 1 PDP area is only a portion of the overall area, the Plat does include the entire property, as requested.  Known or planed street names should be identified. The naming of Greenfields north of Mulberry should be “Drive” not “Court” since this portion extending to Vine is a through street. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Response: Known street names have been included and the Greenfields suffix has been updated accordingly as well. We plan to work through other street names through the PDP approval process.  Please provide enough context along edges of plat off-site to show connections and adjacent uses. Response: We believe we have shown this information on the included Plat.  Please identify future land uses in the proposed future development parcels to be consistent with the PUD Districts and LUC zoning. Response: Land uses within Phase 1 are identified within this PDP. Future land uses for future phases are not known and will defer to the Mulberry & Greenfields PUD Master Plan. Future PDP applications will determine those ultimate land uses in the other areas. Comment #3 FOR HEARING: - LMN  PUD identifies LMN density for District One between 4 – 12 DU/ac. The proposed PDP is within this range, also per LUC density range of 4 - 9. Response: Correct, the proposed density falls within this range.  The PUD identifies single-family detached dwelling use as a type I review, which is consistent with LUC review. Response: The PUD has revised this review to a BDR. Further discuss as this and PUD are reviewed will likely be necessary.  For project over 30 acres, a minimum of 4 housing types are required. Staff discussed this in coordination with the PUD and encourage proposed mix of housing types in PUD to be distributed throughout each phase. This would include incorporating other types than single-family detached products such as two family, single-family attached and multifamily dwellings. Response: The PUD has laid housing type requirements for each district. With this project including multiple phases it is not required to have a certain amount of housing types with each application, rather each District (per the PUD Master Plan) is required a minimum number of housing types. This submittal meets the required number of housing types and is providing 4 types with this initial application; SFD front load, SFD rear/alley load, cottage, and accessory dwelling unit.  Please identify which housing types meet LUC standards and ones that are a new type. The alley loaded duplex garage type will need to include parking for primary residence and potential ADU if added above garage. Response: Understood, the Mulberry & Greenfields PUD Master Plan further defines housing type variety requirements that apply holistically to each District. This PDP application is proposing at least 4 housing types (per our PUD), with front load, cottage homes, small alley-load, and accessory dwelling units.  District 1 and 2 and part of 3 that includes LMN may need to include a neighborhood center to serve the residential neighborhoods east of Mosaic if this site is greater than ¾ miles from commercial district or Mosaic NC. It is not clear if the future amenity or development parcel adjacent to the planned neighborhood park are part of a neighborhood center. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Response: Neighborhood center standards have been revised as part of the Mulberry & Greenfields PUD Master Plan. This project is in conformance with those standards. Generally speaking, we believe that the development within District 3 will meet the needs of the community and this standard.  The block size that is bounded by streets cannot exceed 12 acres. If any block face exceeds 700’ a mid- block pedestrian connection between streets should be included. Response: This application meets this standard.  The maximum residential building height for single-family dwellings is 2 ½ stories unless the PUD identifies 3-stories. Response: The Mulberry & Greenfield PUD Master Plan permits buildings up to 3 stories in height. Development within this phase will meet this standard. Comment #4 FOR HEARING: - Parking Residential parking requirements will be based on lot size/width resulting in 1-2 spaces per DU. Depending on PUD standards, a modification of standards may be needed for on-street parking. Additional guest parking should be provided off-street for each block. Response: Parking meets the standards of the proposed Mulberry & Greenfields PUD Master Plan. Comment #5  The street system should be designed to comply with the 660’ connectivity standards in LUC Section 3.6.3 this will include connections to existing development off site and within Phase 1. This network of streets, or bike and pedestrian connections in lieu of streets should also include connections along the RR tracks on either side of Greenfields Drive. Staff recognizes the unique conditions of the RR spur and stacking constraints, and requests stub-outs that reserve the ROW and space for a future RR crossing. Response: The plan as included meets the intention of these standards. The ability to provide future connections across the RR has been memorialized within the Mulberry & Greenfields PUD Master Plan and the currently layout can accommodate this potential future condition.  The proposed north/south local street that parallels Delozier Drive should be removed and extend the three east/west streets to Delozier to create an improved block pattern. The proposed single row of lots between these streets is not a sustainable block pattern. Response: The block pattern has been revised to create a better block pattern and extend streets as appropriate.  International Blvd. (or local street classification) should be extended east of Greenfields Drive to provide 660’ connections to Peakview to the south. Response: No development is proposed east of Greenfields as part of this filing. An intersection at Greenfields Drive and International Boulevard has been established. We believe that it would be most appropriate to locate a road in this area at the time development occurs east of this intersection. Any road placement would be a guess at this type and could adversely impact development patterns in areas where development has not yet been fully contemplated.  The regional trail alignment should include crossing Vine Drive to the north, and cross Greenfields south of RR tracks, then extend to Cooper Slough to the east. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Response: The regional trail alignment has been indicated within the PUD. The design of the regional trail is not included as part of Phase 1. Comment #6 FOR HEARING: - Community Gateway  Staff will need to coordinate the gateway feature adjacent to Mulberry/Frontage Road to assess design, signage etc. with the applicant for implementation and funding.  It is not clear if a sign that includes “welcome to Fort Collins” is appropriate for this location, or if it is aligned with the Mulberry Corridor Plan direction. Response: Comment noted. The Applicant has identified a location for this community monument and understands the continued discussions with Staff will need to occur on this item. Comment #7 This development proposal will be subject to all applicable standards of the Fort Collins Land Use Code (LUC), including Article 3 General Development Standards. The entire LUC is available for your review on the web at http://www.colocode.com/ftcollins/landuse/begin.htm. Response: Noted. Thank you. Comment #8 If this proposal is unable to satisfy any of the requirements set forth in the LUC, a Modification of Standard Request will need to be submitted with your formal development proposal. Please see Section 2.8.2 of the LUC for more information on criteria to apply for a Modification of Standard. Response: Thank you. We believe this application, meets all applicable standards within Fort Collins Land Use Code as well as the Mulberry & Greenfields PUD. Engineering Development Review – Marc Virata 970.221.6567 mvirata@fcgov.com Comment #1 Because of the ongoing review and coordination with the PUD Master Plan that relates to this phase, standardize conceptual review comments were not provided, and instead responses to specific questions in the application, or generalized comments to the application are provided. I'm unable to attend the conceptual review as it coincides with a planned vacation but can look to follow up with the applicant accordingly. Response: Noted. Thank you Comment #2 The application provided a premise that as a way to mitigate allowing on-street parking to count towards parking requirements, a connector local street would be built. The connector street better facilitates two-way traffic from a road width perspective, but it doesn't inherently create more parking spaces if the intent is to deviate from typical parking requirements for developments under the Land Use Code. We will want to better understand the implications behind this proposal and coordinate this discussion with Planning and Traffic. Perhaps a parking impact study, or other tools would need to be considered before the City can formulate an overall position on this request. Response: The Mulberry & Greenfield PUD further defines parking requirements and provides a parking diagram to indicate parking availability. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Comment #3 The LCUASS updates that modifies the cross sections of some streets can be found here: https://www.larimer.org/sites/default/files/uploads/2021/chapter_7_figures.pdf. Note that this was approved on second reading by City Council on 7/6/2021 as provided here: https://citydocs.fcgov.com/?cmd=convert&vid=72&docid=3524478&dt=AGENDA+ ITEM&doc_download_date=JUL - 06-2021&ITEM_NUMBER=07 Response: The proposed PDP and PUD are adhering to the new LCUASS updates. Comment #4 The Delozier and International curve shown on the PDF would need additional design information by the applicant's CIVIL engineer for review and consideration by the city. Any element of this design that doesn't meet LCUASS requirements would require a variance request for consideration as part of the PDP review. Response: The Radius does not meet LCUASS – this is intended to be an interim condition until such a time as International Blvd. is built. A variance request is part of this application. Comment #5 There are elements of the PDP that would not appear to meet the intent of either the LUC on standards such as extending existing street stubs as provided in 3.6.3, or the Master Street Plan in not depicting the extension of Delozier south of International. It's understood that this will perhaps be more formally vetted through the PUD Master Plan already under review. This comment is provided perhaps more on the overall premise that there would appear to need to be approval of the PUD Master Plan in a manner that addresses elements of not meeting requirements before the PDP could be approved. Response: Bloom – Phase 1 has made every effort to make these connections as noted. We believe the PDP road network provided with this application meets these standards. Comment #6 There appears to be the creation of double frontage lots for the lots between Sykes and International along the east side of Delozier Road with the creation of the new street running parallel to Delozier Drive. This would typically not be allowed under 3.3.1(B)(1) of the Land Use Code. Response: This condition has been revised, we believe the revised layout meets the referenced code section. Comment #7 The overall understanding of what is intended to be built from a transportation/street perspective with the initial phase 1 of the PDP will need additional review and discussion, along with support of its suitability through a traffic study. If A Drive is intended to be built at this time, it would be required to be built with temporary turnaround at its western termination (under the assumption that an extension of Delozier Drive south of International Drive is not ultimately not incorporated through an acceptance of this under the PUD Master Plan.) Response: The Master TIS provides analysis of proposed improvements with phase 1 PDP. These elements are highlighted in the accompanying memo for phase 1 PDP. Comment #8 Under the premise that the extension of Greenfields Court north of Sykes Drive occurs in a future phase, to the extent that a portion of Greenfields is still abutting what would be construed as part of this development, we would need to ensure that there is a manner in which it is viewed that the "Future Phase" north of the railroad isn't burdened with the financial aspect of constructing the roadway and crossing south of the railroad. Response: The complete Greenfields Drive ROW is platted as part of this application, though the actual construction of Greenfields crossing the railroad ROW will occur during a future TBD phase. The permitting of the crossing is subject to review by the Public Utilities Commission and the application is working with the City on a separate design package for the crossing itself. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Traffic Operations – Steve Gilchrist 970.224.6175 sgilchrist@fcgov.com Comment #1 TRAFFIC IMPACT STUDY: A Traffic Impact Study will be required with the submittal of this project to demonstrate how this phase fits within the PUD Traffic Study for this site. The level of study may depend on the approval of the PUD. This will also need to include clarification on the proposed improvements planned within this first submittal. (Will Greenfields and the connection to Mulberry be constructed in the first phase?) Please contact Traffic Operations to scope the study. Response: A memo and updated analysis will be provided per a conversation with the City held on August 16th, 2021, at 1 pm. Comment #2 Could you clarify how a wider street would allow for more parking, when the amount of on street parking is really determined by the linear curb length and number of access points/driveways/fire hydrants, etc. Response: The wider street does not permit more parking, but rather, as Staff as stated previously, alley or rear loaded product tends to park more on adjoining streets than a typical front load. On previous projects Staff has asked that non-front load homes front on to local connector level streets. Comment #3 More information will be required with regard to the bike and pedestrian accessibility/connectivity through this project. Response: The included plans include an extensive trail network as well as road network and we believe this project goes above and beyond when it comes trail/bike/pedestrian connectivity. Stormwater Engineering – Chandler Arellano 970.420.6963 carellano@fcgov.com Comment #1 This project is located within the City's MS4 boundaries and is subject to the erosion control requirements located in the Stormwater Design Criteria, Chapter 2, Section 6.0. A copy of those requirements can be found at www.fcgov.com/erosion Based upon the supplied materials, site disturbs more than 10,000 sq. ft. and/or meets one of the other triggering criteria (sensitive area, steep slopes, or larger common development) that would require Erosion and Sediment Control Materials to be submitted. Response: Comment noted, to comply with the City MS4 permitting process. Comment #2 Please submit an Erosion Control Plans to meet City Criteria (FCDCM Ch 2 Section 6.1.3) Please ensure that the Erosion Control Plans provided include an individual sequence sheets in accordance with (FCDCM Ch 2 Section 6.1.3.2) Please ensure that the Erosion Control Plans, Escrows, and Reports include phasing requirements (FCDCM Ch 2 Section 6.1.3, 6.1.4, & 6.1.5) Response: Erosion Control plans are to be provided with the FDP submittal. Comment #3 As this is a City project, no Erosion Control Erosion Control Escrow / Security Calculation will be needed. Response: Acknowledged. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Comment #4 Please submit an Erosion Control Report to meet City Criteria. (FCDCM Ch 2 Section 6.1.4) Response: This will be provided with the FDP document process. Comment #5 Based upon the area of disturbance or this project is part of a larger common development, State permits for stormwater will be required since the site is over an acre and should be pulled before Construction Activities begin. Response: Acknowledged, State Permits to be submitted prior to construction activities Comment #6 The City Manager’s development review fee schedule under City Code 7.5-2 was updated to include fees for Erosion Control and Stormwater Inspections. As of January 1st, 2021, these fees will be collected on all projects for such inspections. The Erosion Control fees are based on; the number of lots, the total site disturbance, the estimated number of years the project will be active and the Stormwater Inspection. Fees are based on the number of LID/WQ Features that are designed for on this project. Based on the proposed site construction associated with this project we are assuming 273 lots, 63.98 acres of disturbance, 2.5 years from demo through build out of construction and an additional 3 years till full vegetative stabilization due to seeding. Which results in an Erosion Control Fee estimate of $10995.79. Based on 0 number of porous pavers, 0 number of bioretention/level spreaders, 3 number of extended detention basins, and 0 number of underground treatments, results in an estimate of the Stormwater LID/WQ Inspection fee to be $750. Please note that as the plans and any subsequent review modifications of the above-mentioned values change the fees may need to be modified. As additional phases come through development review, additional fees will be calculated and assessed for Parcel C, D, E, F, Future Commercial Retail and Future Phases NE of Great Western Railway. I have provided a copy of the spreadsheet used to arrive at these estimates for you to review. Please respond to this comment with any changes to these assumed estimates and why, so that we may have a final fee estimate ready for this project. The fee will need to be provided at the time of erosion control escrow. Response: Please note there are 15 bioretention facilities located throughout the site to meet LID requirements. Stormwater Floodplain – Claudia Quezada (970)416-2494, cquezada@fcgov.com Comment #7 INFORMATION ONLY: A portion of this property is currently located in the FEMA-regulated, 100-year Cooper Slough floodplain and must comply with the safety regulations of Chapter 10 of City Municipal Code. A FEMA Flood Risk map is attached. Response: Acknowledged, site development will comply with the Safety Regulations of Chapter 10 of City Municipal Code. Comment #8 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com INFORMATION ONLY: Any construction activities in the floodplain (e.g., grading, structures, sidewalk or curb & gutter installation/replacement, roads, utility work, landscaping, etc.) must be preceded by an approved floodplain use permit, the appropriate permit application fees, and approved plans. Response: Acknowledged – prior to any work being done within the floodplain, floodplain use permits/fees will be submitted. Comment #9 INFORMATION ONLY: In the City of Fort Collins Construction of residential and nonresidential structures is allowed in the Cooper Slough 100-year floodplain, as long as the lowest finished floor of the building, and all duct work, heating, ventilation, electrical systems, etc. are elevated 18-inches above the Base Flood Elevation (BFE). This elevation is known as the Regulatory Flood Protection Elevation (RFPE). RFPE = BFE + 18-inches. No basements are allowed in the 100-year floodplain. An approved FEMA Elevation Certificate, completed by a licensed surveyor or CIVIL engineer and showing that the addition is constructed to the required elevation, is required prior to a Certificate of Occupancy (CO) being issued. Response: Acknowledged – will provide the necessary clearance to be at or above the RFPE elevation. Comment #10 INFORMATION ONLY: Critical facilities as defined in Chapter 10 of City Code, are prohibited in the 100-year floodplain. Critical facilities include essential services facilities, hazardous materials facilities, at-risk population facilities, and government services facilities. Response: Acknowledged. Comment #11 Please utilize development review checklist for floodplain requirements when preparing your plans for submittal. https://www.fcgov.com/utilities/img/site_specific/uploads/fp-checklist100-2018-update.pdf?1522697905 Response: Acknowledged. Comment #12 INFORMATION ONLY: Please show the boundaries of the floodplain and floodway on site drawings as applicable. Contact Beck Anderson of Stormwater Master Planning at banderson@fcgov.com for floodplain CAD line work. Response: Floodway and floodplain boundary linework have been added to the set. Stormwater Engineering – Wes Lamarque (970)416-2418 wlamarque@fcgov.com Comment # 13 Master plan and criteria compliance (site specific comment): The design of this site must conform to the drainage basin design of the Lower Cooper Slough Master Drainage Plan as well the Fort Collins Stormwater Criteria Manual (FCSCM). The stormwater criteria manual is available on our website here: https://www.fcgov.com/utilities/business/builders-and-developers/development-forms-guidelines- regulations/stormwater-criteria Response: Site is to comply with the Master Plan and City Criteria. We have requested a variance per our discussion with release rates for the Cooper Slough. Comment #14 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Documentation requirements (site specific comment): A drainage report and construction plans are required and must be prepared by a Professional Engineer registered in the State of Colorado. The drainage report must address the four-step process for selecting structural BMPs. Response: Acknowledged – to provide a drainage report and construction plans prepared by a Colorado PE. Comment #15 Stormwater outfall (site specific comment): The stormwater outfall options for this site are multiple locations depending on the location within this development boundary. The northwest area would outfall to the west into the storm sewer in Delozier Road at the southeast corner of the East Ridge development. The southern section would outfall into the cooper slough via a new storm sewer system. Also, it is not exactly clear where the northeast area will outfall and the drainage study will need to investigate what outfall options exist. If this area were to outfall to the cooper slough, an offsite drainage easement would be required from the east property line to the cooper slough. Response: The design is taking all drainage north of International Blvd. and outfalling directly int the Cooper Slough via one pond outfall. The applicant is evaluating if they can obtain an easement to allow for another outfall location further upstream of the Cooper Slough. A portion of the drainage south of International Blvd will enter the proposed storm sewer provided by Peak View development. The other portion will outfall directly into the Lake Canal. Comment #16 Offsite Stormwater Flows (site specific comment): As part of design of this site, an offsite flow analysis will need to be performed. The development will need to accept and pass any existing offsite flows. The results of the offsite analysis and the developments plan to handle offsite flows should be discussed with Water Utilities early in the design of this site. Please note that Stormwater Master Planning has already identified drainage flows entering the northwest corner of the site. Response: Acknowledged – to analyze offsite flows. Should offsite flows enter the site, infrastructure will accept and pass the flows. Comment #17 Detention requirements (site specific comment): Onsite detention is required for the runoff volume difference between the 100-year developed inflow rate and the 2-year historic release rate. Please note that the city has landscaping requirements for stormwater detention ponds. These requirements can be found in the Fort Collins Stormwater Criteria Manual, Chapter 8, Section 3.0 and in Appendix B (Landscape Design Standards and Guidelines for Stormwater and Detention Facilities). Response: Acknowledged – please note we are requesting a variance to provide 0.2 cfs / acre as the release rate per our discussion with the City on August 05, 2021. Comment #18 Development Drainage Master Plan (site specific comment): It is recommended that a drainage master plan for the overall development is performed. This will help with project phasing, approvals, and logical development for the overall site. This plan should determine the sizing and location of storm detention, water quality, and LID facilities. Response: Provided with the first filing. Comment #19 Stormwater Master Planning Requirements (site specific comment): Fort Collins Stormwater Master Planning is in the process of updating the ‘Selected Plan’ for this drainage basin. Currently, there is an identified master-planned stormwater improvement at the southern boundary just north of Mulberry Street which. This improvement is a planned conveyance of Lake Canal drainage spills to the Cooper Slough. Please contact Dan Evans (daevans@fcgov.com), Stormwater Master Planning Manager, for any additional information. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Response: Acknowledged – will coordinate with Dan Evans about the conveyance improvements at the southern boundary north of Mulberry St. Comment #20 Water Quality and Low Impact Development requirements (standard comment): All new or modified impervious areas require stormwater quality treatment. In addition, the City requires the use of Low Impact Development (LID) methods to treat stormwater quality on all new or redeveloping property, including sites required to be brought into compliance with the Land Use Code. There are two (2) categories of LID requirements; the development will need to meet one of the two following options: 1. LID with Permeable Pavers: When using the permeable pavers option, 50% of the new or modified impervious areas must be treated by LID methods. Of the new or modified paved areas, 25% must be pervious. 2. LID - without Pavers: 75% of all new or modified impervious areas must be treated by LID methods. This typically consists of a rain garden or bioretention system, but other options are allowed. The remainder of the water quality treatment can be accomplished ‘standard’ or LID water quality methods. Accepted methods are described in the Fort Collins Stormwater Criteria Manual (FCSCM), Chapter 7: http://www.fcgov.com/utilities/business/builders-and-developers/development-forms-guidelines- regulations/stormwater-criteria Response: WQ and LID requirements have been considered and are to meet criteria. Exhibit has been included to show locations of LID’s and amount of treatment for each LID. Comment #21 Detention drain times (standard comment): Per Colorado Revised Statute §37-92-602 (8) that became effective August 5, 2015, criteria regarding detention drain time will apply to this project. As part of the drainage design, the engineer will be required to show compliance with this statute using a standard spreadsheet (available on request) that will need to be included in the drainage report. Upon completion of the project, the engineer will also be required to upload the approved spreadsheet onto the Statewide Compliance Portal. This will apply to any volume-based stormwater storage, including extended detention basins. Response: Provided SDI spreadsheet to show drain times and compliance with Colorado Statute within the Drainage Report. To upload approved spreadsheet once project has been completed. Comment #22 Inspection and maintenance (standard comment): There will be a final site inspection of the stormwater facilities when the project is complete and the maintenance is handed over to an HOA or another maintenance organization. Standard operating procedures (SOPs) for on-going maintenance of all onsite drainage facilities will be included as part of the Development Agreement. More information and links can be found at: http://www.fcgov.com/utilities/what-we-do/stormwater/stormwater-quality/low-impact-development Response: Noted. Thank you. Comment #23 Fees (standard comment): The 2021 city wide Stormwater development fee (PIF) is $9,730/acre of new impervious area over 350 square feet and there is a $1,045/acre of site review fee. No fee is charged for existing impervious area. These fees are to be paid at the time each building permit is issued. Information on fees can be found at: http://www.fcgov.com/utilities/business/builders-and-developers/plant-investment-development-fees or contact our Utility Fee and Rate Specialists at (970) 416-4252 for questions on fees. There is also an erosion control escrow required before the Development Construction permit is issued. The amount of the escrow is determined by the design engineer, and is based on the site disturbance area, cost of the measures, or a minimum amount in accordance with the Fort Collins Stormwater Manual. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Monthly fees - http://www.fcgov.com/utilities/business/rates Response: Comment noted. Fees will be paid as required at the appropriate time. Electric Engineering – Cody Snowdon 970-416-2306 csnowdon@fcgov.com Comment #1 City of Fort Collins Lights and Power currently does not have any facilities in the area of this project and the project a r e a i s c u r r e n t l y s e r v e d b y P V R E A . C o o r d i n a t i o n a n d t i m i n g w i l l b e c r i t i c a l t o b e a b l e t o s e r v e t his site. This project will require a dedicated circuit and Capital funding to get power to the property. Response: Comment noted. The Applicant will continue to work with Staff on this item. Comment #2 Streetlights and infrastructure will need to be installed at the time A Drive and Greenfields Court is constructed. In constructing those streets before Tracts B - F are developed, our design cannot account for future designs of those Tracts. To avoid relocations in the future at the cost of the future projects, it would be good to look at some conceptual design layouts and work with Light and Power to place facilities accordingly. Response: Comment noted. We will work with Staff on this item through the development process. Comment #3 If the private drives/alleys are proposed to be illuminated, the streetlights are considered private and will need to be privately metered. Please show all private streetlights and private meters on the plans. Response: Comment noted. This information has been provided. Comment #4 In having private alleys, we would encourage a Utility Coordination meeting very early in the process to ensure the widths will provide adequate separation for all utilities required for this project. Response: Utility coordination meetings have occurred. Comment #5 In having alley within this project, Light and Power will require the primary lines to be shown on the Preliminary Development Plans and secondary and service lines, as well as structures to be shown on the Final Plans. Response: Preliminary lines shown. Comment #6 All utility easement and crossing permits (railroad, ditch, floodplain, etc.) needed for the development will need to be obtained by the developer. Response: Noted. Comment #7 All proposed Light and Power electric facilities that are within the limits of the project must be located within a utility easement or public right-of-way. Response: Noted. Comment #8 Transformer location will need to be coordinated with Light & Power and needs to be shown on the Utility Plans. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Transformers must be placed within 10 ft of a drivable surface for installation and maintenance purposes. The transformer must also have a front clearance of 10 ft and side/rear clearance of 3 ft minimum. When located close to a building, please provide required separation from building openings as defined in Figures ESS4 - ESS7 within the Electric Service Standards. Please show all proposed transformer locations on the Utility Plans. Response: These are shown on the PDP materials. Comment #9 During utility infrastructure design, please provide adequate space of all service and main lines internal to the site to ensure proper utility installation and to meet minimum utility spacing requirements. A minimum of 10 ft separation is required between water, sewer and storm water facilities, and a minimum of 3 ft separation is required between Natural Gas. Please show all electrical routing on the Utility Plans. Response: These are shown on the PDP materials. Comment #10 Streetlights will need to be installed along all public rights-of-way. A 40 feet separation on both sides of the light is required between canopy trees and streetlights. A 15 feet separation on both sides of the light is required between ornamental trees and streetlights. Please coordinate the light placement with Light & Power. A link to the City of Fort Collins Street lighting requirements can be found below: https://www.larimer.org/sites/default/files/ch15_2007.pdf Response: Comment noted. Standards will be met. Comment #11 All residential service requests above 200 amps are considered a customer owned service; therefore, the applicant is responsible for installing the secondary service from the first point of attachment to the meter and will own and maintain that service. Response: Comment noted and understood. Thank you. Comment #12 Per Light and Power’s Electric Service Standards: 8.1.10. The builder is required to install the electric meter socket(s) on the same side as the electric service ‘stub’. 8.1.11. Builders are also encouraged to install the natural gas meter(s) on the opposite side of the house from the electric service. 8.1.12. The electric service trench must be a minimum of 3 feet from the natural gas service trench, and the electric and gas services shall not cross each other. Response: Comment noted and understood. Thank you. Comment #13 The City of Fort Collins now offers gig-speed fiber internet, video and phone service. Contact Brad Ward with Fort Collins Connexion at (970) 224-6003 or bward@fcgov.com for commercial grade account support, RFPs and bulk agreements. Response: Thank you for this information. Comment #14 For additional information on our renewal energy programs please visit the website below or contact John Phelan (jphelan@fcgov.com). https://www.fcgov.com/utilities/business/go-renewable Response: Thank you for this information. We will review and implement as appropriate. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Comment #15 Light & Power will require AutoCAD files of the Site Plan, Utility Plans, and Landscape Plans prior to the Entitlement Process approval. Response: Comment noted. This information will be provided at the appropriate time in the process, as requested. Comment #16 Electric capacity fees, development fees, building site charges and any system modification charges necessary to feed the site will apply to this development. Please contact me or visit the following website for an estimate of charges and fees related to this project: http://www.fcgov.com/utilities/business/builders-and-developers/plant- investment-development-fees Response: Comment noted and understood. Thank you for this information. Comment #17 Please reference our policies, construction practices, development charge processes, electric services standards, and fee estimator at http://www.fcgov.com/utilities/business/builders-and-developers. Response: Comment noted. Thank you for this information, we will review. Fire Authority – Marcus Glasgow 970-416-2869 marcus.glasgow@poudre-fire.org Comment #1 FIRE LANES Fire access is required to within 150 feet of all exterior portions of any building, or facility ground floor as measured by an approved route around the perimeter. For the purposes of this section, fire access cannot be measured from an arterial road. Any private alley, private road, or private drive serving as a fire lane shall be dedicated as an Emergency Access Easement (EAE) and be designed to standard fire lane specifications. In addition, aerial apparatus access requirements are triggered for buildings in excess of 30' in height. Code language and fire lane specifications provided below. - IFC 503.1.1: Approved fire Lanes shall be provided for every facility, building or portion of a building hereafter constructed or moved into or within the jurisdiction. The fire apparatus access road shall comply with the requirements of this section and shall extend to within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility. When any portion of the facility or any portion of an exterior wall of the first story of the building is located more than 150 feet from fire apparatus access, the fire code official is authorized to increase the dimension if the building is equipped throughout with an approved, automatic fire-sprinkler system. Response: Comments noted. We believe this application meets these standards. Comment #2 FIRE LANE SPECIFICATIONS A fire lane plan shall be submitted for approval prior to installation. In addition to the design criteria already contained in relevant standards and policies, any new fire lane must meet the following general requirements: 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com  Fire lanes established on private property shall be dedicated by plat or separate document as an Emergency Access Easement.  Maintain the required 20-foot minimum unobstructed width & 14-foot minimum overhead clearance. Where road widths exceed 20 feet in width, the full width shall be dedicated unless otherwise approved by the AHJ.  Additional fire lane requirements are triggered for buildings greater than 30' in height. Refer to Appendix D105 of the International Fire Code.  Be designed as a flat, hard, all-weather driving surface capable of supporting 40 tons.  Dead-end fire access roads in excess of 150 feet in length shall be provided with an approved turnaround area for fire apparatus.  Dead-end roads shall not exceed 660 feet in length without providing for a second point of access. Dead- end access roads in excess of 1320 feet in length require a third point.  of access. Dead-end access roads in excess of 2640 feet in length require a fourth point of access.  The required turning radii of a fire apparatus access road shall be a minimum of 25 feet inside and 50 feet outside. Turning radii shall be detailed on submitted plans.  Dedicated fire lanes are required to connect to the Public Way unless otherwise approved by the AHJ.  Fire lane to be identified by red curb and/or signage and maintained unobstructed at all times.  Fire lane sign locations or red curbing should be labeled and detailed on final plans. Refer to LCUASS detail #1418 & #1419 for sign type, placement, and spacing.  Appropriate directional arrows required on all signs.  In remote rural applications, fire lane standards may be modified with the approval of the fire marshal; examples might include reduction in road width or road surface.  International Fire Code 503.2.3, 503.2.4, 503.2.5, 503.3, 503.4 and Appendix D; FCLUC 3.6.2(B)2006 and Local Amendments. Response: Comments noted. We believe this application meets these standards. Comment #3 IFC D107.2 - S-F RESIDENTIAL DEVELOPMENTS - REMOTENESS Where two fire apparatus access roads are required, they shall be placed a distance apart equal to not less than one- half of the length of the maximum overall diagonal dimension of the property or area to be served, measured in a straight line between accesses. Response: Comments noted. We believe this application meets these standards. Comment #4 WATER SUPPLY Hydrant spacing and flow must meet minimum requirements based on type of occupancy. A fire hydrant capable of providing 1500 (1000) gpm at 20 psi residual pressure is required within 300 (400) feet of any commercial (residential) building as measured along an approved path of vehicle travel. For the purposes of this code, hydrants on the opposite side of arterial roadways are not considered accessible to the site. Response: Comments noted. We believe this application meets these standards. Comment #5 PREMISE IDENTIFICATION: ADDRESS POSTING & WAYFINDING Where possible, the naming of private drives is usually recommended to aid in wayfinding. Addresses shall be posted on each structure and where otherwise needed to aid in wayfinding. Code language provided below. IFC 505.1: New and existing buildings shall have approved address numbers, building numbers or approved building identification placed in a position that is plainly legible, visible from the street or road fronting the property, and posted with a minimum of eight-inch (four-inch for residential) numerals on a contrasting background. Where access is by means of a private road and the building cannot be viewed from the public way, a monument, pole or other sign or means shall be used to identify the structure and best route. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com Response: Comments noted. We will address as required. Environmental Planning – Scott Benton, 970-416-4290 sbenton@fcgov.com Comment #1 FOR SUBMITTAL: The primary consideration from Environmental Planning’s perspective is the relationship of this development to the ODP/PUD and metro district requirements. Namely, clarification is needed on what is being implemented in Phase 1 in regard to stormwater facilities and outflows. If outflows to the Cooper Slough and construction/disturbance in the Natural Habitat Buffer Zones are required for this submittal, then substantial plans (restoration plans that address soil handling, weed management, etc.) will be required. Response: This information has been included as part of this application. Comment #2 FOR SUBMITTAL: The proposed Phase 1 encompasses drainage basins D and E. Environmental Planning’s request from the PUD process in order to meet the elevated PUD requirements was to connect basins D and E to basins B and C, thus increasing flows to the Cooper Slough as far north as possible. Is that what is planned for Phase 1? Response: This is being considered and will be confirmed with the hydraulic/storm drain vertical analysis in FDP. Comment #3 FOR SUBMITTAL: Has the offsite easement/permission been explored to outflow to the Slough from basin B? Response: An outfall easement is being worked on. One from pond A is being looked at but have not been able to obtain. Comment #4 FOR SUBMITTAL: Contact the assigned Development Review Coordinator (DRC) prior to PDP submittal if trees will be impacted. A review of trees shall be conducted by City Environmental staff to determine the status of existing trees and any mitigation requirements that could result from the proposed development. The site visit can be conducted in tandem with Forestry’s site visit. Please contact assigned Development Review Coordinator directly at 970-221-6689 or email DRCoord@fcgov.com to schedule a tree inventory site visit. Please plan for at least two weeks to get an onsite meeting scheduled, especially during April - October. Response: This review has been conducted and this application reflects that review. Comment #5 FOR SUBMITTAL: If tree removal is necessary, please include the following note on the tree mitigation plan and landscape plan, as appropriate: "NO TREES SHALL BE REMOVED DURING THE SONGBIRD NESTING SEASON (FEBRUARY 1 TO JULY 31) WITHOUT FIRST HAVING A PROFESSIONAL ECOLOGIST OR WILDLIFE BIOLOGIST COMPLETE A NESTING SURVEY TO IDENTIFY ANY ACTIVE NESTS EXISTING ON THE PROJECT SITE. THE SURVEY SHALL BE SENT TO THE CITY ENVIRONMENTAL PLANNER. IF ACTIVE NESTS ARE FOUND, THE CITY WILL COORDINATE WITH RELEVANT STATE AND FEDERAL REPRESENTATIVES TO DETERMINE WHETHER ADDITIONAL RESTRICTIONS ON TREE REMOVAL AND CONSTRUCTION APPLY." Response: This note has been added as required. Comment #6 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com INFORMATION ONLY: City of Fort Collins Land Use Code [Section 3.2.1 (E)(3)], requires that to the extent reasonably feasible, all plans be designed to incorporate water conservation materials and techniques. This includes use of low-water-use plants and grasses in landscaping or re-landscaping and reducing bluegrass lawns as much as possible. Native plants and wildlife-friendly (ex: pollinators, butterflies, songbirds) landscaping and maintenance are also encouraged. Please refer to the Fort Collins Vegetation Database at https://www.fcgov.com/vegetation/ and the Natural Areas Department’s Native Plants document for guidance on native plants: http://www.fcgov.com/naturalareas/pdf/nativeplants2013.pdf. Response: Water conservation techniques and plant materials are being utilized as part of this application. Additionally, the heavy use of plants that are native, adapted to our climate, and wildlife friendly have been utilized. Comment #7 INFORMATION ONLY: Please be sure to review standards and submittal requirements carefully prior to submitting a Project Development Plan to ensure Lighting Plans meet the City’s newly updated lighting code, Section 3.2.4. Response: We believe this application meets these standards. Comment #8 INFORMATION ONLY: The City of Fort Collins has many sustainability programs and goals that may benefit this project. Of particular interest may be: 1) Zero Waste Plan and the Waste Reduction and Recycling Assistance Program (WRAP) provides communication materials and on-site assessments to support recycling program. Also provides rebates for new compost programs: http://fcgov.com/recycling/wrap.php 2) Solar Rebate Program offers up to $50,000 in rebates to Fort Collins Utility customers for the installation of solar PV: www.fcgov.com/solar, contact Rhonda Gatzke at 970-416-2312 or rgatzke@fcgov.com 3) Integrated Design Assistance Program offers financial incentives and technical support for new construction and major renovation projects. Must apply early in the design phase: http://fcgov.com/idap, contact David Suckling at 970-416-4251 or dsuckling@fcgov.com Response: Thank you for this information. We will continue to explore this opportunity. Forestry – Nils Saha nsaha@fcgov.com Comment #1 PRE-SUBMITTAL - Forestry Tree Inventory: If there are existing trees on site, please schedule an onsite inventory with City Forestry (nsaha@fcgov.com) to obtain inventory and mitigation information. This meeting should occur prior to the first round of PDP. Existing significant trees should be retained to the extent reasonably feasible. Response: This has meeting and walk has occurred with Staff and this application reflects the outcome of this onsite inventory. Comment #2 Please provide a landscape plan that meets the Land Use Code 3.2.1 requirements. This should include the existing tree inventory, any proposed tree removals with their locations clearly noted and any proposed tree plantings (including species, size, quantity, and method of transplant). The plans should also include the following City of Fort Collins notes: General Landscape Notes Tree Protection Notes Street Tree Permit Note, when applicable. 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com These notes are available from the City Planner or by following the link below and clicking on Standard Plan Set Notes: https://www.fcgov.com/developmentreview/applications.php Required tree sizes and method of transplant: Canopy Shade Tree: 2.0” caliper balled and burlapped Evergreen tree: 6.0’ height balled and burlapped Ornamental tree: 1.5” caliper balled and burlapped Required mitigation tree sizes: Canopy Shade Tree: 2.0” caliper balled and burlapped Evergreen tree: 8.0’ height balled and burlapped Ornamental tree: 2.0” caliper balled and burlapped Response: The included landscape plans meet these standards. Comment #3 If applicable, please provide an “Existing Tree Removal Feasibility Letter” for City Forestry staff to review. Proposals to remove significant existing trees must provide a justification letter detailing the reason for tree removal. This is required for all development projects proposing significant tree removal regardless of the scale of the project. The purpose of this letter is to provide a document of record with the project’s approval and for the City to maintain a record of all proposed significant tree removals and justifications. Existing significant trees within the project’s Limits of Disturbance (LOD) and within natural area buffer zones shall be preserved to the extent reasonably feasible. Streets, buildings and lot layouts shall be designed to minimize the disturbance to significant existing trees. (Extent reasonably feasible shall mean that, under the circumstances, reasonable efforts have been undertaken to comply with the regulation, that the costs of compliance clearly outweigh the potential benefits to the public or would unreasonably burden the proposed project, and reasonable steps have been undertaken to minimize any potential harm or adverse impacts resulting from noncompliance with the regulation.) Where it is not feasible to protect and retain significant existing tree(s) or to transplant them to another on-site location, the applicant shall replace such tree(s) according to City mitigation requirements. Response: This is to be determined, the Applicant wants to continue coordinating with Staff to determine the viability of the some of these trees. Comment #4 As noted on the application, the city is currently reviewing proposed revisions to the LUCASS standards that would require a minimum 8’ parkway on local streets. It is anticipated that these revisions will be adopted in July. Please adhere to these newer standards for parkway width in your design. City staff has discussed potential modifications to setback requirements where feasible. Please continue to coordinate with city staff on subsequent designs proposals. Response: The plan reflects the updated LCUASS standards. Comment #5 Standard LUC standard for Tree Species Diversity states that in order to prevent insect or disease susceptibility and eventual uniform senescence on a development site or in the adjacent area or the district, species diversity is required and extensive monocultures are prohibited. The following minimum requirements shall apply to any development plan: Number of trees on site Maximum percentage of any one species 10-19 50% 20-39 33% 40-59 25% 60 or more 15% 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com The City of Fort Collins’ urban forest has reached the maximum percentage of the following species. Ash (Fraxinus), Honeylocust (Gleditsia triacanthose: ‘Shademaster’, ‘Skyline’, etc.), Bur Oak (Quercus macrocarpa), and Chanticleer Pear (Pyrus calleryana). Please note that additional species might join this list as we work through the review process. Response: The included landscape plans meet these standards. Comment #6 Please include locations of utilities on the landscape plan including but not limited to water service/mains, sewer service/mains, gas, electric, streetlights, and stop signs. Please adjust tree locations to provide for proper tree/utility separation. Street Light/Tree Separation: Canopy shade tree: 40 feet Ornamental tree: 15 feet Stop Sign/Tree Separation: Based on feedback from Traffic Operations, it is preferred that trees be planted at least 50 feet from the nearest stop sign in order to minimize conflicts with regulatory traffic signs. Driveway/Tree Separation: At least 8 feet from edges of driveways and alleys. Utility/Tree Separation: 10’ between trees and public water, sanitary, and storm sewer main lines 6’ between trees and water or sewer service lines 4’ between trees and gas lines 10’ between trees and electric vaults Response: The included landscape plans meet these standards. Comment #7 Per Land Use Code 3.2.1.(D)(c), canopy shade trees shall constitute at least 50 percent of all tree plantings. Response: The included landscape plans meet these standards. Comment #8 Canopy shade trees should be planted at 30-40’ spacing (LUC 3.2.1 (D)©) along street frontages. Response: The included landscape plans meet these standards to the extent feasible. Comment #9 Each landscape island should be 8’ in its smallest dimensions to allow for tree root growth (LUC 3.2.1 5©). Response: The included landscape plans meet these standards. Building Code Review - Russell Hovland 970-416-2341 rhovland@fcgov.com Comment #1 A permit is required for this project and construction shall comply with adopted codes as amended. Current adopted codes are: 2018 International Residential Code (IRC) with local amendments 244 North College Ave, #130 I Fort Collins, CO 80524 www.norris-design.com 2018 International Plumbing Code (IPC) as amended by the State of Colorado 2020 National Electrical Code (NEC) as amended by the State of Colorado Copies of current City of Fort Collins code amendments can be found at fcgov.com/building. Please read the residential permit application submittal checklist for complete requirements. Snow Load Live Load: 30 PSF / Ground Snow Load 30 PSF. Frost Depth: 30 inches. Wind Loads: Risk Category II (most structures): · 140mph (Ultimate) exposure B or · Front Range Gust Map published by The Structural Engineer's Association of Seismic Design: Category B. Climate Zone: Zone 5 Energy Code: 2018 IRC chapter 11. INFORMATIONAL ITEMS: · 5ft setback required from property line or provide fire rated walls & openings for non-fire sprinkled houses per chap 3 of the IRC. 3ft setback is required for fire sprinkled houses. · Bedroom egress windows (emergency escape openings) required in all bedrooms. · Prescriptive energy compliance with increased insulation values is required for buildings using electric heat. · A passing building air tightness (blower door) test is required for certificate of occupancy. Stock Plans: When the same residential buildings will be built at least three times, a stock plan design or master plan can be submitted for a single review and then built multiple times with site specific permits. More information can be found in our Stock Plan Guide at fcgov.com/building/res-requirements.php. Response: Comments noted. Thank you for this information. Technical Services - Jeff County 970-221-6588 jcounty@fcgov.com Comment #1 As of January 1, 2015, all development plans are required to be on the NAVD88 vertical datum. Please make your consultants aware of this, prior to any surveying and/or design work. Please contact our office for up-to-date Benchmark Statement format and City Vertical Control Network information. Response: Comment noted. Plans meet this standard. Comment #2 When submitting a Subdivision Plat for this property/project, addresses are not acceptable in the Plat title/name. Numbers in numeral form may not begin the title/name. Please contact our office with any questions. Response: Comment noted. Plans meet this standard.