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HomeMy WebLinkAboutSALUD FAMILY HEALTH CENTER LOT 4 - FDP200011 - SUBMITTAL DOCUMENTS - ROUND 5 - Responses Page 1 of 21 Community Development and Neighborhood Services 281 North College Avenue PO Box 580 Fort Collins, CO 80522 970.221.6689 970.224.6134 - fax fcgov.com/developmentreview December 15, 2023 RE: Salud Family Health Center Lot 4, FDP200011, Round Number 4 Please see the following summary of comments from City staff and outside reviewing agencies for your submittal of Salud Family Health Center Lot 4. If you have questions about any comments, you may contact the individual commenter or direct your questions through your Development Review Coordinator, Todd Sullivan via email at tsullivan@fcgov.com. Ripley Responses in Green EPS Group Responses in Blue TW Beck Responses in Red JA Environmental Consulting Responses in Orange Salud Responses in Purple ICON Responses in Dark Orange Salud Family Health Center_FDP_RD4 Session ID: 406-165-582 Session URL: https://studio.bluebeam.com/hyperlink.html?link=studio.bluebeam.com/sessions/406-165-582 Comment Summary: Department: Development Review Coordinator Contact: Todd Sullivan tsullivan@fcgov.com 970-221-6695 Topic: General Comment Number: 1 07/17/2020: INFORMATION ONLY: 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! Comment Number: 2 Page 2 of 21 07/17/2020: INFORMATION ONLY: As part of your resubmittal 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. Comment Number: 3 07/17/2020: INFORMATION ONLY: When you are ready to resubmit, please make an appointment with me at least 24 hours in advance. Submittals are accepted any day of the week, with Wednesday at noon being the cut off for routing the same week. Comment Number: 5 FOR FINAL APPROVAL: All "For Final Approval / For Approval" comments need to be addressed and resolved prior to moving forward with the final documents and recording of this project. I will provide a recording checklist and process information when we are closer to this step. Response: Understood Comment Number: 6 INFORMATION: LUC 2.211 Lapse, Term of Vested Right: Within a maximum of three (3) years following the approval of a final plan or other site-specific development plan, the applicant must undertake, install and complete all engineering improvements (water, sewer, streets, curb, gutter, streetlights, fire hydrants and storm drainage) in accordance with city codes, rules and regulations. The period of time shall constitute the "term of the vested property right." Failure to undertake and complete such engineering improvements within the term of the vested property right shall cause a forfeiture of the vested property right and shall require resubmission of all materials and reapproval of the same to be processed as required by this Code. All dedications as contained on the final plat shall remain valid unless vacated in accordance with law. The project status can be reviewed at any time and, at the City's discretion, the expiration date can be extended as additional "diligent pursuit" efforts are made on this project. Department: Planning Services Contact: Katelyn Puga kpuga@fcgov.com Topic: General Comment Number: 13 12/11/2023: FOR FINAL APPROVAL Planning recognizes the executed Environmental Use Restrictions imposed by the Colorado Department of Public Health and Environment (CDPHE) that outlines the requirement that the site needs to be approved by CDPHE prior to the recordation of the FDP. Please continue to work with Environmental Planning and Environmental Regulatory Affairs. Page 3 of 21 Response: The Site does not require prior approval from CDPHE to record the FDP, only that the Site development comply with the Environmental Use Restrictions (EURs)(Record No. 20210035465, 4/7/2021, Larimer County). Salud has worked closely with the Colorado Department of Public Health and the Environment (CDPHE) to address the historical environmental conditions and to place the EURs on the Property as part of a completed Voluntary Cleanup Program (VCP) cleanup that was implemented from about 2015 through 2020. (The VCP Completion Report for the former Forney Site, 1830 Laporte Ave. has been previously provided to the City with our original submittals) CDPHE approved the completion of the cleanup and the closure of the environmental conditions in 2021 with the issuance of a No Action Determination (NAD letter). The NAD stipulates that the CDPHE approves the land for commercial use and the planned development fits this land use. There are currently no known environmental conditions on the property that require investigation or remediation. The EURs were placed on the property to: 1) address any residual environmental contamination; 2) provide environmental oversite of intrusive activities in the event that an unknown environmental condition is encountered; and 3) to assure full protection of human health and the environment during the redevelopment process and future use of the Property. On January 23, 2024, Salud and the City held a meeting to discuss the City’s environmental comments and questions. Mr. Fonda Apostolopoulos, P.E., Environmental Engineer at the State of Colorado Division of Hazardous Materials, CDPHE joined the meeting by phone and confirmed that the development of the Property could proceed as a long as the EURS were followed. Mr. Apostolopoulos leads the Colorado VCP program at CDPHE. He is knowledgeable of the conditions and issues at this Site as he was involved with the former Forney Industries VCP Site completion. He provided the EC and EURs for the Site and is responsible for hundreds of VCP projects statewide. The meeting with Mr. Apostolopoulos and the City environmental staff was arranged to address concerns outlined in the City comments and was followed up by an additional meeting in March 13,2024 (Zoom meeting). Comment Number: 14 12/12/2023: FOR FINAL APPROVAL To acknowledge the Environmental Use Restrictions that applies to the property add the following notes to the site plan cover sheet: 1) No structures intended for human occupancy (including residences, offices, or other workplaces, etc.) may be built on the Property without a properly designed and constructed vapor mitigation system approved by the City of Fort Collins and by CDPHE as required in the Environmental Use Restrictions. 2) All land use approvals and associated permits are subject to the approval of CDPHE, prior to recordation of the final plans. Response: Bullet 1: The EURs placed by Salud Family Health Centers(Salud), the property owner, and CDPHE on the property as part of the completion of the VCP cleanup activities requires vapor mitigation systems (VMS) in all new construction. The VMS will be included in the design plans and drawings as an element of the building construction. The VMS system design will be provided to CDPHE for approval as part of the design process to assure that the VMS meets CDPHE requirements for this site. The VMS will also meet the City of Fort Collins requirements for radon resistant construction. Proposed language for the site plan cover sheet taken directly from the NAD: “As per the Notice of Environmental Use Restrictions placed on the property, any new building will have to have an approved vapor mitigation system installed and certified. As part of the certification process, the owners will have to apply to the Voluntary Cleanup Program and have the state approve a No Action Determination for the installed system. “ Bullet No. 2: No land use approvals and associated permits are subject to the approval of CDPHE at this time. All CDPHE approvals regarding the environmental conditions at the Property have been completed with the NAD and the EURs as long as the land use is for Commercial purposes. If residential was being proposed, CDPHE would need to approve that change in land use. Page 4 of 21 The EURs do require future CDPHE approval of the VMS as discussed above. In addition, if any CDPHE stormwater or other permitting is needed, that permitting will be part of the construction requirements of the project and will be addressed with CDPHE when conditions require such permits. Appropriate comments have been added to the Site Plan cover sheet to address this comment. Department: Engineering Development Review Contact: John Gerwel jgerwel@fcgov.com Topic: General Comment Number: 2 11/20/2023: INFORMATION: Our Capital Improvements department has confirmed payment of Laporte frontage improvements. Per applicant response, work within recently constructed ROW improvements are subject to increased pavement impact fees. More information on that can be found here: https://www.fcgov.com/engineering/excavation (Previous comments from Marc Virata) 08/11/2022: for approval: In the time since the development project was last reviewed, the City's capital project to improve Laporte Avenue adjacent to the site has progressed such that it is approaching a 90% design this month and construction anticipated later this year. The current design along the frontage does not take into account Salud Drive and addresses only existing accesses in the current condition before the proposed development. There may be options that would have the capital project accommodate as part of the design and build the opening for the future Salud Drive, but that window is diminishing as the capital project design is furthered along towards approval. Additionally, with the Laporte project, there could be the option to extend the water service off of Laporte into the site to avoid future street cuts into Laporte Avenue that could be subject to triple impact penalty fees. Also, in looking at the phasing plan that was included that didn't take into account the capital project now moving forward, it is suggested that a check in occur with the applicant on vision towards the timing of their development to understand how to approach finalizing the capital project design. Note that to the extent that the City is building the local portion frontage of Laporte Avenue abutting the property, there would be a repay from the development to the City for the local street improvements specified in the development agreement. Additionally, as part of the development agreement we would document that the landscaping and irrigation along Laporte Avenue as part of the capital project would be required to be maintained by the developer. 04/27/2021: for approval: The plans have been forwarded to Dan for his input and verification. The preliminary design plans for Laporte don't appear to coincide with what is shown on the plans as an elevated bike lane along Laporte behind the curb and gutter is shown. After Dan's review, we may want to have a meeting to discuss design and timing considerations. 07/14/2020: for approval: Page 5 of 21 The City has an improvement project for Laporte Avenue that involves this development's Laporte Avenue frontage. Discussion with Dan Woodward in Engineering Capital Projects should occur to explore how the plans should reflect the frontage along Laporte and also whether the construction of this frontage might be better served to be done by the City (with a payment provided in-lieu of construction). The timing of the development's anticipated construction start in comparison to the City is part of the consideration for this. Comment Number: 7 11/21/2023: FOR FINAL APPROVAL - UNRESOLVED: The culvert design has been routed to our structural engineer. Comments from them will be coordinated. The railing shown in the plans does not have the minimum 54 inches of protection. Please revise. Response: The railing was revised to provide 54” of protection. (Previous comments from Marc Virata) 08/11/2022: for approval: The response indicated that new box culvert designs have been included. These have been route to Jin for his review. 04/27/2021: for approval: The revised design with the more standard box culvert is appreciated. The review of the box culvert design is with Jin Wang and updated comments will be coordinated and provided. One concern I do see is that there doesn't appear to be a railing over the bridge. A bicycle railing is required with the roadway having an adjacent bikelane and would need to be a minimum of 54 inches (11.3.4 of LCUASS). 07/14/2020: for approval: The design of the ditch crossing under the new roadway was provided for initial review to Jin Wang, City Engineering's staff structural engineer and the overall design is problematic and would need to be redesigned. AAASHTO Load and Resistance Factor Design should be the design specifications and the use of an aluminum box culvert would not be allowed as only reinforced concrete and steel are acceptable per 11.2.3 of LCUASS. A complete design with presumed structural rebar with a concrete box and wingwalls is needed. Attached sidewalks are required to be 8 feet. The design engineer should perhaps reach out to Jin Wang for further details and discussion. Comment Number: 16 11/20/2023: FOR FINAL APPROVAL - UNRESOLVED: The sheet referenced in the response to this comment does not address the concerns laid out below. Please address these concerns. Response: We added sheet E-2 to the title sheet, which previously was missing. (Previous comments from Marc Virata) 08/11/2022: for approval: Carried over as unresolved. The response indicates E2 has been added to the sheet index, but I'm not seeing this, or understand if it intended to address the comment. 04/27/2021: for approval: The environmental status and previous contamination of the property was not something I was aware of having inherited the project, and I'm looking for more Page 6 of 21 information on from the perspective that the City would become the owner of land (right-of-way) for public street purposes. Additional information is needed for review with the information provided in the November 2020 report that City staff was recently made are of and still processing and should be identified in the most recent Site Characterization Report : 1) Identify with the proposed development what are the areas of City owned right-of-way and also City maintained infrastructure (utilities, trees, public street) that coincide with areas of contamination identified in the environmental compliance completion reports (such as an overlay of the proposed site development with areas identified in Page 28 of the November 2020 completion report). We don't believe we have all the known information at this time to make this determination. 2) How will the proposed development potentially impact any ongoing compliance efforts (such as Page 28 of the 11/2020 report delineates a "photoremediation" zone, which appears to potentially be in proximity to the new City right-of-way/street. Is this a "phytoremediation zone", and if so, what is it still ongoing and what is the implication on the loss of vegetation with the development?) 3) A soils report wasn't found in the electronic documents, it should be provided for review to understand the recommendations for the construction of the public street system and whether the report considered the environmental condition. Response: The property has been the subject of extensive environmental investigations and remediation activities under a CDPHE- approved VCP, including soil and groundwater assessment and cleanup. There are currently no known environmental conditions on the property that require further investigation or remediation. The Property is cleared and approved by CDPHE for commercial redevelopment as long as the EURs are implemented as part of the redevelopment program. The closure was done with the placement of EURs due to low concentrations of residual chlorinated solvents in groundwater. CDPHE determined that the concentrations of chlorinated solvent remaining at the Site were not migrating and do not represent a risk to human health and the environment as long as any redevelopment of the Property follows the EURs. Salud met with the City of Fort Collins staff on January 23, 2024 to review the historical soil and groundwater investigation and remediation information and to provide assurance that the EURs will be followed during redevelopment. Mr. Fonda Apostolopoulos of the CDPHE VCP Program participated in that meeting confirming: 1) the site conditions are acceptable to the State of Colorado; 2) that migration of the residual contaminants is not an issue of concern to the CDPHE based on the remediation and monitoring previously performed; 3) there was no need or requirement for additional investigation or remediation activities; and ) 4 the proposed development plans are consistent with the EC as long as the project follows the EURS. In addition, Salud held a subsequent follow-up meeting with the City to further discuss the environmental conditions and to provide additional information requested during the January meeting. A Power Point presentation referenced during the March 13, 2024 follow up meeting outlines the meeting topics and is attached as Attachment 1 (March 13, 2024 Meeting Outline). As part of that meeting, Northern Engineering prepared a figure that overlays key environmental sampling locations and data with the planned street and utilities and shows the depth to groundwater with respect to utilities in the work areas. This figure should help with understanding the Site conditions and shows a compilation of post remediation monitoring data and some data from the initial 2014 and 2015 groundwater investigations at the Site. The figure shows that only limited sections of the planned street are in areas of possible environmental concern. However, consistent with the MMP, environmental oversight is needed during installation of utilities and road construction for the entire street in accordance with the MMP. The new figure is included as Attachment 2 (New Figure). Page 7 of 21 Comment Number: 17 11/29/2023: FOR FINAL APPROVAL: The soils report that is referenced in the utility plans has not been found in any previous submittals. Given the amount of time that has elapsed in these project submittals, we need a new soils report, unless the one referenced explicitly has a warranty/expiration date that has not been exceeded. Either way, we need a soils report and that report should be accurately referenced on the title sheet of the utility plans. Response: Please see attached signed and stamped letter from EEC, the GEOR indicating the GEO-Report 2016 is valid for the current plan concept. Comment Number: 18 11/29/2023: FOR FINAL APPROVAL: Has a ditch crossing agreement been established with the ditch company? We will want to see that that has been executed prior to approving these plans. Response: We are establishing crossing agreements with the ditch company for the box culvert, electric/fiber, water, sewer, and gas. The ditch company has requested a 3-way agreement for the street/box culvert between the developer and city. We will continue to coordinate with the ditch company and city as needed. Comment Number: 19 11/29/2023: FOR FINAL APPROVAL: Please provide more complete labeling for existing contours in the grading sheets. Response: Updated contour labels and checked all grading plans to ensure labeling. Comment Number: 20 11/29/2023: FOR FINAL APPROVAL: Please include the statement found in LCUASS App E, section E-4.II.E in the notes on the grading sheets. Response: Included FFE statement on grading sheets. Comment Number: 21 11/29/2023: FOR FINAL APPROVAL: Will there be any speed limit sign postings? I'm not seeing any. Response: A 25mph speed limit sign has been added northbound along Maple Street Comment Number: 22 11/29/2023: FOR FINAL APPROVAL: The signing and striping of the bike lane and buffer appear to be backwards from current LCUASS standards. The buffer should be between the travel lane and the bike lane, not between parking and the bike lane. Response: Updated striping of bike buffer lanes to correct orientation and location. Comment Number: 23 11/29/2023: FOR FINAL APPROVAL: The water main linework does not match what is indicated in the legend of the utility plans. Please correct the plan linework to match the legend. Response: Updated the water linework in the legend to make plan sheets. Comment Number: 24 11/29/2023: FOR FINAL APPROVAL: Adding on to Water/Wastewater's- comment 7, we will need an offsite utility easement and an offsite temporary construction easement for that water line. Both need to be recorded with the County Clerk and need to be depicted on the plans and plat with reception numbers in the plat. Response: We are showing an offsite utility easement for the water crossing on Maple Street. We do not believe a temporary Page 8 of 21 construction easement is necessary. The Offsite Utility Easement and General Deed language has been submitted to the city for review. Comment Number: 25 11/29/2023: FOR FINAL APPROVAL: LCUASS standard detail drawings 1401 and 1411 are not current. Please use the updated drawings. Additionally, the LCUASS trenching detail (Drawing 2201) is missing from the plans. Please include that as well. Response: Updated details to most recent version and checked remaining details. Added detail 2201 on sheet D1. Comment Number: 26 11/29/2023: FOR FINAL APPROVAL: This project will require a development agreement. Please fill out the DA form found in the following link. Please include this in the next submittal. https://www.fcgov.com/engineering/devrev Response: DA For has been included with this submittal Comment Number: 27 11/30/2023: FOR FINAL APPROVAL: Please coordinate with our Parks department to determine who will be responsible for maintenance of the parkway along Laporte. Response: Noted project team has reached out to the parks department to better understand maintenance obligations and will continue to coordinate with City staff. Comment Number: 28 12/11/2023: INFORMATION: Third party inspectors should be in communication with City inspectors. Having all inspectors on the same page could help out quite a bit with the approval process. Our ROW inspector is Ken Zetye (kzeye@fcgov.com) and our chief building inspector is Marcus Coldiron (mcoldiron@fcgov.com) Comment Number: 29 12/12/2023: FOR FINAL APPROVAL: The City does not wish to assume responsibility for land that is subject to an environmental use restriction. Maple Street should be private. If the EUR is successfully removed, then the City would consider accepting the street as public ROW. The street would also need to be designed to LCUASS standards if the City is to accept the ROW in the future. This can be further solidified in the development agreement. Response: Salud recognizes the City’s concerns regarding the City’s acceptance of the street as a public ROW based on potential environmental considerations. The meetings that were held on January 23, 2024 and March 13, 2024 resulted in significant progress in addressing the City’s issues to accept the street as a public ROW. To be clear, Salud is in the business of providing medical care to underprivileged and underserved people. Salud is not however structured to maintain and manage roadways, and certainly not capable of maintaining a through street with significant public use like the planned Maple extension. The City is concerned with possible environmental liability stemming from accepting the roadway. The conversations on this subject include the facts that: 1) based on the new figure that was provided at the March meeting (Attachment 2), the portion of the street that is in an area where there was environmental contamination is very small. While the entire planned street is in the area that is subject to environmental covenant, the area where there is the potential for an environmental discovery is minimal; 2) Salud is required by the MMP to provide environmental oversite and possible testing during the installation of all utilities for the entire street (not just the area of potential environmental concern). All excavation activities associated with the construction of the roadway are subject to the MMP. If any potential environmental concerns are encountered, Salud is responsible under the MMP and Page 9 of 21 covenant to address the concerns, collect confirmation samples indicating that the concern has been addressed, and documenting the activity in a completion report that will be provided to CDPHE; 3) The concentrations of residual chlorinated solvent in the groundwater are extremely low, are well below the planned excavation depth, and do not represent an issue for future maintenance workers (see response to Comment 10); and 4) Mr. Fonda Apostolopoulos of the CDPHE indicated in the January meeting that once oversight of the utility installation and the roadway installation has been completed that there is no reason for additional oversight associated with utility or street maintenance; CDPHE has since agreed to provide a letter indicating to the City that once the City accepts the street as a public ROW (following Salud’s oversight of environmental conditions and reporting the oversight efforts to the CDPHE), that implementation of the MMP as part of the environmental use restrictions no longer applies to the ROW. Salud is working with CDPHE to provide written assurance of this MMP modification for the ROW to the City. Comment Number: 30 12/12/2023: FOR FINAL APPROVAL: We will want some approval by CDPHE documented in the final submittal documents. That may be through a memo documented in the development agreement. This will depend on what CDPHE is willing to provide. Updates will come when we hear from CDPHE. Ultimately, we feel that having something like that documented in association with this project will be beneficial for all parties. Response: Since this comment was provided, Salud has facilitated a meeting between the City and the CDPHE on January 23, 2024 and we have communicated with CDPHE based on discussions that were held during our March 13, 2024 meeting (see Response to Comment 29). Department: Environmental Regulatory Compliance Contact: Jesse Schlam jschlam@fcgov.com 970-218-2932 Topic: Erosion Control Comment Number: 29 12/11/2023: FOR FINAL APPROVAL: All underground utilities (water, wastewater, stormwater, electric, etc.), foundations, sump pits, and their bedding material should be located outside of the groundwater plume. (estimated at 7 feet down). This project will need to prevent contaminates from infiltrating utility pipes (causing groundwater pollutants to be directed off site into the drainage system or sanitary treatment system) or use the bedding to redirect flow and "shortcut" the groundwater off site. Response: Planned underground utilities will be mostly located outside areas of known and suspected groundwater contamination based on the VCP sampling and investigations. Groundwater at the site was remediated and monitored for about five years during the groundwater cleanup portion of the VCP at the Site. The groundwater level at the site is generally at or around 12 feet below ground surface (bgs) near the irrigation ditch and runs about 20 feet bgs in the area where most of the utilities will be installed. See the Figure presented in Attachment 2 for depths to groundwater. The groundwater plume was remediated using a reductive dehalogenation technology approach and only limited areas of low levels of chlorinated solvent remained on the Site when the NAD was issued. It is unlikely that any residual solvent will be encountered or caused to move off-site due to construction activities. Where there is the potential for installation of utilities in areas of potential environmental impacts, environmental oversight performed in accordance with the CDPHE approved MMP for the Site will provide for protection of human health and the environment. The above discussion of the groundwater conditions was confirmed by Mr. Fonda Apostolopoulos of CDPHE during our January 2, 2024 meeting on environmental conditions. Additional information on the environmental conditions is presented in Attachment 1 (outline from Salud’s March 13, 2024 meeting with the City). Page 10 of 21 Comment Number: 30 12/11/2023: FOR FINAL APPROVAL: All LID treatment should either be relocated outside of the plume footprint or prevent the addition of water into the groundwater, promoting higher groundwater levels and furthering the spread of contaminants. Response: This comment suggests a misunderstanding of current Site conditions including the contaminant levels and aerial extent. The groundwater plume has been remediated at the Property. Most of the former plume was reduced to concentrations that are below the Colorado Basic Groundwater Standards. There were residual concentration of chlorinated solvents in some areas of the former groundwater plume that remained when the NAD was issued, but these contaminants were at low concentrations, the areas do not have enough contaminant mass to cause significant migration, and the residual concentrations were acceptable to CDPHE with the placement of the EURs for the Site. It is highly unlikely that any LID treatment will cause migration of the residuals, in fact it is likely that any input to groundwater will serve to dilute concentrations of any residuals that may be present. Comment Number: 31 12/11/2023: FOR FINAL APPROVAL: Per the Materials Management Plan/Notice of Environmental Use Restrictions and the Fort Collins Drainage Criteria Manual, any Erosion Control Report needs to be updated to provide description of the known contaminants on this project and develop a list of Control Measure or Best Management Practices to address encountering contamination in soil and how those materials will be handled during demo, site grading, and construction. Any soil disturbance will require trained oversight and monitoring. Response: The Material Management Plan (MMP) that was approved by CDPHE will be followed, including oversight of intrusive activities by a trained Environmental Professional (EP). The MMP describes site conditions. All known contaminated soils at the project Site have been remediated as part of the VCP cleanup, however, any impacted soils that are discovered will be handled in a manner that is compliant with State and local requirements. The MMP provides procedures that should be followed for addressing contamination in the soil and groundwater during demolition, site grading, and construction. The MMP will be referenced in the erosion control report. Comment Number: 32 12/11/2023: FOR FINAL APPROVAL: Per the Materials Management Plan/Notice of Environmental Use Restrictions and the Fort Collins Drainage Criteria Manual the erosion control report must include Construction Dewatering and the anticipated controls to hand pollutants in the groundwater. Response: Salud does not anticipate that dewatering activities will be associated with the planned slab-on-grade building or the utilities that will be installed. Since the groundwater table is generally 12 to 20 feet deep, the only area where we may encounter groundwater is potentially during installation of the foundation of the bridge over the irrigation ditch. This construction activity will take place in an area that is not near the footprint of the historic groundwater plume. Any water that is removed during construction will be assessed by the EP for the site and will be managed appropriately in accordance with the CDPHE approved MMP and applicable regulations. Comment Number: 33 Page 11 of 21 12/11/2023: INFORMATION ONLY: The groundwater on this site would not meet the State's low risk discharge and could not be land applied on site. That said, a construction dewatering permit will likely result in a remediation permit which will require collecting samples getting tests and possible institute treatment before any discharges off site. This site may require any groundwater to be collected and properly disposed of rather than dewatering. Any of these dewatering options will result in higher than typical costs related to construction. Any sump pumps or foundations would also likely result in a long-term remediation permit which would require ongoing permitting with CDPHE. Response: Remediation of groundwater at the site resulted in most of the monitoring wells being at or below the Colorado Basic Groundwater Standards. A few of the wells had levels of chlorinated solvents that were slightly above the Standards but were at concentrations that CDPHE determined were protective of human health and the environment with the placement of EURs. Attachment 2 provides a new map of the locations where concentrations of solvents were above the standards when the NAD was issued is being prepared. Construction dewatering, sump pumps, or foundation dewatering is not anticipated for the slab-on-grade building that is planned, but any dewatering that is necessary in these areas will be done in a manner that is compliant with state and local requirements as dictated in the CDPHE approved MMP. The EP for the site will be responsible for identifying and properly handling of any environmental conditions including extracted groundwater. Comment Number: 34 12/11/2023: INFORMATION ONLY: Based upon the complication to this unique site and the amount of permits and environmental remediation the City recommends that a dedicated and knowledgable environmental compliance staff be employed for this sites' design, development, and construction. Response: Historically, there were environmental conditions of concern on this Property; however, the VCP cleanup has addressed all known environmental conditions as discussed in other comment responses. Salud will follow the EURs for the Site including the implementation of the CDPHE approved MMP. Salud is prepared to work with the City to address any concerns regarding past or existing environmental conditions. During our January 23, 2024 and March 13, 2024 meetings, JAEC contrasted the conditions at the former Forney Industries Site with the environmental contamination that is present in the downtown Fort Collins area of the Willow Street and the Northside Aztlan Community Center to set perspective on the magnitude of environmental conditions at the two properties. In the Willow Street area, the City is a party to an environmental covenant that is the result of historical landfilling and the presence of a historical manufactured gas plant (MGP) in the area. The residuals present as a result of the MGP operations and landfilling are relatively high, with the presence of highly contaminated groundwater and free product residuals that required a remediation barrier to prevent discharge of the free product coal tar into the Poudre River. The extremely low concentrations of residual chlorinated solvents at the former Forney site are significantly lower than the concentration of compounds such as benzene and naphthalene that are beneath the highly developed Willow Street area. The City also operates a VMS in the Azlan Center to control vapor intrusion from the contamination into the building. The vapors include benzene, naphthalene, and other compounds. Despite the presence of the serious contamination in the area, the environmental conditions and the environmental covenant did not prevent redevelopment in this area; for example, the construction of a major apartment project was done under a Colorado VCP without major issues due to environmental concerns. Mr. Joseph Aiken of JAEC managed the environmental oversight during construction, and the installation of the VMS system for this project. The removal of impacted soils and a sump associated with the former MGP operations, the extraction and proper disposal of groundwater countered during the installation of caissons, and the installation and testing (with CDPHE approval) of a VMS in the buildings all occurred in accordance with the CDPHE approved MMP for that site. In addition, the installation of major new utilities in Willow Street required environmental oversight and Mr. Aiken managed that oversight for the City during the project. No contaminated groundwater or soils were encountered during that utility installation project and conditions that may have caused a Page 12 of 21 health and safety concern were not found during the project. While the very low concentrations of residual chlorinated solvents at the former Forney Industries Property represent a much lower risk than a construction project in the Willow Street area, the planned project at the Site has the same restrictions as the Willow Street projects and will have the same level of oversight as the work that was done in the Willow Street area. Salud plans to provide the necessary oversight by an EP as required by the MMP and we are committed to working with the City and CDPHE on addressing any environmental conditions that are encountered. Department: Environmental Planning Contact: Kirk Longstein klongstein@fcgov.com 970-416-4325 Topic: General Comment Number: 5 12/11/2023: INFORMATION ONLY A development agreement will be required prior to issuance of a DCP. The DA will likely include language regarding the environmental contamination issues, which will be determined when all the requested information is available. Response: The EC and EUR language address environmental concerns associated with the site and property development. The EURs generally prohibit the use of groundwater, dictates the implementation of a CDPHE-approved VMS in all new construction, and requires the use of the CDPHE-approved MMP for all construction activities. Since the time this comment was provided Salud has met with the City Staff to review the EC’s and the MMP providing additional background and supporting information. Salud appreciates the opportunity to participate in additional discussions if Staff has further questions. Comment Number: 6 12/11/2023: FOR FINAL APPROVAL: The current plans do not show the contaminated groundwater plume as it related to the designed structure. Please add a sheet to the plans delineating the extent of the plume and the proposed improvements. Response: A map showing the groundwater contamination and proposed project is included as Attachment 2. The groundwater at the Site was historically contaminated with chlorinated solvents but has been remediated to concentrations that are considered by CDPHE to be protective of human health and the environment as long as the EURs are adhered to. The groundwater plume was remediated and closed with a VCP NAD in 2020. The closure allowed for some residual solvent at concentrations that were low enough to not be migrating and are contained in limited areas of the Property. A new map was prepared and discussed at the March meeting. The groundwater map shows the site areas where residual solvents exceeded the Colorado Basic Groundwater Standards as known when the NAD was issued. Comment Number: 7 12/11/2023: FOR FINAL APPROVAL: Written approval from CDPHE that the Notice of Environmental Use Restrictions and the accompanying Material Maintenance Plan for this property have been reviewed and meet the State's Criteria for all work in and around the contaminated groundwater plume along with the vapor mitigation system. Page 13 of 21 Response: CDPHE has approved the notice of EURs and the MMP. The approved documents are posted on the CDPHE website under the “Sites with Environmental Covenants and Use Restriction” section. During our January 23, 2024 meeting on the environmental concerns presented in the City’s comments, Mr. Fonda Apostolopoulos of CDPHE confirmed that no additional approvals are required to proceed with the development as long as the EURs are followed and the MMP is implemented. The MMP does require Salud to obtain CDPHE approval of our VMS design when that design is available. CDPHE will approve confirmation sampling that shows that the VMS is working properly. Comment Number: 8 12/11/2023: FOR FINAL APPROVAL: Please provide a Remediation and monitoring Plan including specific actions to treat groundwater contaminates: TCE, cis-DCE, and Vinyl Chloride to meet Colorado groundwater standards. Planning staff would like the most recent data from the remediation monitoring wells to see how the site has been progressing over the last 3 years. In addition, we would like an environmental remediation professional to provide a written estimate of how long following natural attenuation verses active remediation would take for all the contaminates to meet the groundwater standards. Response: There are no known environmental conditions that require investigation or remediation at the Site. CDPHE has issued a NAD and EURs for the Site. The site was assessed, remediated, and closed through the Colorado VCP. The latest data was collected as part of the VCP closure in 2020 and is included in the Completion Report for the VCP project. As stated in the above comments, Salud and JAEC met with the City regarding the environmental conditions on January 23, 2024 and March 13, 2024. The Salud project team is available to meet with City staff again if requested to discuss the closure documentation including discussion of the Colorado’s Conditional Closure Policy and Guidance for Low Threat Sites. This guidance document was used to address and close the groundwater issue providing assurance to the CDPHE that the source materials were removed and that the residual chlorinated solvents do not represent a threat to human health and the environment. Comment Number: 9 12/11/2023: FOR FINAL APPROVAL: Provide progressive monitoring reports that show groundwater contamination of TCE, cis-DCE, and Vinyl Chloride levels meet CDPHE groundwater standards for four (4) consecutive quarters. Response: All monitoring data is presented in the VCP Completion report for the Property. The site was closed with an EC and EURs to address any chlorinated solvents that were above the Standards at the time of closure. See response to Comment 8. Comment Number: 10 12/11/2023: INFORMATION ONLY: The City recommends that the property owner work with the State to lift the Environmental Use Restrictions once groundwater contamination of TCE, cis-DCE, and Vinyl Chloride levels meet CDPHE groundwater standards for four (4) consecutive quarters. Response: In compliance with the NAD there are no plans to sample groundwater at this time. The NAD indicates that the groundwater was remediated to the satisfaction of CDPHE, and no additional monitoring or remediation is necessary. Based on our conversations with CDPHE, once the street has been installed and any observed environmental conditions are addressed, the CDPHE will issue a written statement that future implementation of the MMP is not required in areas of the roadway right-of-way Page 14 of 21 where utilities have been installed as deemed cleared by the Environmental Professional (EP (See response to Comment 29) Groundwater use restrictions and the requirement for vapor mitigation in on-site structures will remain. These restrictions will not apply to the roadway. JAEC has also communicated with CDPHE regarding the potential for worker exposure in utility trenches in the roadway. This concern was raised during Salud’s conversations with the City. While the part of the street that may be in an area of residual groundwater impact is very small, JAEC modelled hypothetical worker exposure to contaminated air in excavated area with the US EPA Vapor Intrusion Screening Level (VISL). The calculation was based on groundwater concentrations found at the site and assumed that the worker was in a basement or closed vault with an annual exposure of 8-hours per day. We believe this approach is a conservative representation of the potential exposure. The VISL results indicated a very low risk of exposure (1 x 10 -9 range of risk). US EPA considers the 1 x 10 -6 range to be protective of human health and the environment so our calculation indicated a risk that was three orders of magnitude below the protective range. Keep in mind that the actual exposure scenario where a worker is in an open trench is more protective than the indoor air exposure that we calculated because the trench is open to the atmosphere and not a confined space such as a basement. The result of this analysis is that virtually no exposure risk to a worker in a trench at the Site exist. CDPHE stated in our January 2024 meeting that there was a very low probability of a worker issue based on the site data and was satisfied with this assessment. Department: Stormwater Engineering Contact: Wes Lamarque wlamarque@fcgov.com 970-416-2418 Topic: General Comment Number: 27 12/07/2023: FOR FINAL APPROVAL: Please replace Bioretention Detail with updated version. Response: Updated bioretention detail to most recent version. Comment Number: 28 12/07/2023: FOR FINAL APPROVAL: Rain Garden 2 elevations are not correct. It looks like the bottom of the pond is at 41.00, not 41.7. Please revise. Also, please label grate elevation for the rain garden spill. Response: Fixed spot elevation locations to display correct top and bottom elevations. Department: Stormwater Engineering - Floodplain Contact: Kevin Meyer kmeyer@fcgov.com Topic: General Comment Number: 24 12/08/2021: FOR APPROVAL: Please see floodplain CLOMR comment letter from ICON Engineering that was sent to Aaron Cvar. Please address the listed comments and resubmit for review. Update:12/6/2023: CLOMR resubmittal is currently under review. No construction may take place prior to approved CLOMR. Please coordinate with Ted Bender at tbender@fcgov.com for any questions regarding CLOMR review or timelines. Response: Noted, the project team will continue to work with and coordinate with City staff once CLOMR review is completed. Comment Number: 25 Page 15 of 21 12/08/2021: FOR APPROVAL: There is concern regarding removal of the existing bridge and placement of the new bridge across the irrigation canal and the impact of those changes may have on the spills from the canal (location and discharge). This will need to be analyzed to show that the spills are not changing. If there is a change, the modeling must be revised to reflect the proposed condition. Update:12/6/2023: CLOMR resubmittal is currently under review. No construction may take place prior to approved CLOMR. Please coordinate with Ted Bender at tbender@fcgov.com for any questions regarding CLOMR review or timelines. Response: Noted, the project team will continue to work with and coordinate with City staff once CLOMR review is completed. Department: Water-Wastewater Engineering Contact: Wes Lamarque wlamarque@fcgov.com 970-416-2418 Topic: General Comment Number: 7 12/07/2023: FOR FINAL APPROVAL - UNRESOLVED: 11/16/2021: FOR FINAL APPROVAL: 04/28/2021: FOR APPROVAL: Please submit utility easement documents once completed and these will be required before the signing of recording documents. 07/10/2020: Have locates and survey been completed for the water main to the east? The connection point shown does not appear to line up with the existing water main and it does not appear the existing water main has been stubbed to the property line. An easement may be needed to connect across the adjacent parcel in order to make the connection to the existing water main. Response: The Offsite Utility Easement and General Deed language has been submitted to the city for review. Comment Number: 17 12/07/2023: FOR FINAL APPROVAL - UPDATED: Please provide specs for maintenance road. Road needs to be able to support HS20 loading. Also, we need to revisit the offsite access to the manhole on the City property to the north. It has been a while and I am not sure the City's stance on this. 11/16/2021: FOR FINAL APPROVAL - UPDATED: The comment response indicated a maintenance road is being provided. Please provide documentation within the Utility Plan Set. 04/28/2021: FOR APPROVAL: City Utilities will get back with the Applicant regarding if any maintenance access will be required for the new offsite public sanitary main. Response: A maintenance road detail has been added to the detail sheets (D8). Per the email on 7/25 we will extend the maintenance road to manhole A2 Page 16 of 21 Comment Number: 20 12/07/2023: FOR FINAL APPROVAL - UPDATED: The fire service to the new building needs additional separation from a couple trees. 11/16/2021: FOR FINAL APPROVAL - UPDATED: There is a tree too close to the water service right before the service enters the building. 04/28/2021: FOR APPROVAL: Please show the water and sewer services all the way to the building on the Utility Plan and the Landscape Plan to ensure separation requirements from other utilities and trees/landscaping. Response: Water and Sewer Service lines have been updated to show connecting all the way to the building. Landscaping has been updated to provide required 6’min separation from trees and utility lines. Department: Light And Power Contact: Cody Snowdon csnowdon@fcgov.com 970-416-2306 Topic: General Comment Number: 4 12/12/2023: FOR APPROVAL: On the C-1 Form, please add the meter/service required for the stormwater outfall pump. The pump will need to be a metered service until the time that the regional outfall is constructed. Please also provide a one-line diagram showing this service for review. Response: C1 form has been updated to include the meter/service required for the pump 07/13/2020: FOR APPROVAL: A commercial service information form (C-1 form) and a one-line diagram for all commercial meters will need to be completed and submitted to Light & Power Engineering for review prior to Final Plan. A link to the C-1 form is below: http://zeus.fcgov.com/utils-procedures/files/EngWiki/WikiPdfs/C/C-1Form.pdf Comment Number: 6 12/12/2023: FOR APPROVAL: Please dedicate an easement around the existing facilities running along the western edge of the property. These facilities will be required to provide redundant power through the project. Response: We have added utility easement around electric line along west property line. Responses have been added to redlines. 07/13/2020: FOR APPROVAL: All existing electrical facilities located onsite need to be located and shown on the plans. All existing electrical facilities need to be within public Right-of-Way or an Utility Easement will need to be dedicated on the Plat. : Comment Number: 9 07/13/2020: FOR INFORMATION: 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: Page 17 of 21 http://www.fcgov.com/utilities/business/builders-anddevelopers/-plant-investment-development-fees Comment Number: 13 12/12/2023: FOR APPROVAL: Please add an electrical vault on the north side of the private drive to provide redundant power to the property. Please see markups. Response: Added electric vault along private drive. Responses have been added to redlines. Department: Forestry Contact: Freddie Haberecht fhaberecht@fcgov.com Topic: General Comment Number: 21 08/09/2022: FOR FINAL APPROVAL- UPDATED Redlines from last round have not been resolved. See comment below. 11/16/2021: FOR FINAL APPROVAL – UPDATED Continued: Thank you for adjusting tree and utilities. Forestry identified a few more conflicts which are highlighted on an updated redlined set. 12/11/2023: FOR FINAL APPROVAL UPDATED Please review Forestry’s redlines. There are a handful of tree-utility conflicts that need to be resolved either by shifting utilities or slightly shifting tree locations. Response: Landscape has been updated to avoid tree/utility conflicts mentioned in Forestry Redlines. Comment Number: 25 12/11/2023: FOR FINAL APPROVAL This project does not currently meet City of Fort Collins streetscape standards in that it only provides a 5.5' parkway strip as opposed to the current standard of 8'. This width of parkway leads to conflicts with the trees in the future. Response: The site plan was entitled at Planning and Zoning Board and the parkway width shown was entitled with it. The new parkway width is a standard that was enacted after the projects entitlement. Department: Park Planning Contact: Missy Nelson mnelson@fcgov.com Topic: General Comment Number: 1 12/12/2023: INFORMATION: Both Park Planning & Development and Parks department comments will be provided by Missy Nelson | mnelson@fcgov.com | 970.416.8077 Comment Number: 2 12/12/2023: Please add the following note to the General Note section of the Landscape Plans: The Developer, or its successor(s) in interest, shall be responsible for the ongoing irrigation and maintenance of the landscaping located within the public right-of-way along the portion- of Laporte Avenue that abuts the Property. Page 18 of 21 Response: The above note has been added to the General Notes section of the landscape plans. Comment Number: 3 12/12/2023: Thank you for providing a spur trail heading north. Please provide an exhibit of the trail connections in the area. Response: An exhibit of the trail connections in the area has been provided with this submittal Comment Number: 4 12/12/2023: Please see redlines on site plan and plat. Add public access easement to cover all portions of the trail. Response: Redlines have been addressed on the site plan Response: Responses have been added to redlines Comment Number: 5 12/12/2023: Please see redlines on site plan and add note on site plan that the trail is privately owned and maintained within a public access easement. Response: The above note has been added to the site plan. Department: Internal Services Contact: Lauren Wade lwade@fcgov.com 970-302-5962 Topic: GIS Comment Number: 3 11/16/2021: FOR FINAL APPROVAL: Maple St will continue to W Laporte Ave per the Master Street Plans. Salud Dr will be Maple St. Contact: Todd Reidenbach treidenbach@fcgov.com 970-416-2483 Topic: General Comment Number: 2 07/24/2020: This street is Maple St, per the Master Street Plan's future Maple St extension. Contact: Russell Hovland rhovland@fcgov.com 970-416-2341 Topic: Building Insp Plan Review Comment Number: 1 07/13/2020: A change of occupancy for these existing buildings will require a building permit and full review by Building Services. Comment Number: 4 12/11/2023: Commercial Construction shall comply with adopted codes as amended. Current adopted codes are: 2021 International Building Code (IBC) with local amendments 2021 International Existing Building Code (IEBC) with local amendments 2021 International Energy Conservation Code (IECC) with local amendments 2021 International Mechanical Code (IMC) with local amendments 2021 International Fuel Gas Code (IFGC) with local amendments 2021 International Swimming Pool and Spa Code (ISPSC) with local amendments Colorado Plumbing Code & state amendments (currently 2021 IPC) 2023 National Electrical Code (NEC) as amended by the State of Colorado Projects shall comply with the current adopted building codes, local Page 19 of 21 amendments and structural design criteria can be found here: https://www.fcgov.com/building/codes Accessibility: State Law CRS 9-5 & ICC/ANSI A117.1-2017. Snow Live Load: Ground Snow Load 35 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 Colorado Seismic Design: Category B. Climate Zone: Zone 5 Energy Code: 2021 IECC commercial chapter. Response: We understand we will need to comply with all current codes at the time of the building permit submittal. INFORMATIONAL ITEMS: Commercial occupancies must provide 10ft to 30ft of fire separation (setback) from property lines and 20 feet between other buildings or provide fire rated walls and openings per chapter 6 and 7 of the IBC. City of Fort Collins adopted International Fire Code (IFC) and amendments to the 2018/2021 IFC require a full NFPA-13 sprinkler system per IBC chapter 9 or when building exceeds 5000 sq.ft. (or meet fire containment requirements). Buildings using electric heat, must use heat pump equipment. A City licensed commercial general contractor is required to construct any new commercial structure.Plans must be signed and stamped by a Colorado licensed architect or engineer and must be included in the permit application.Electric vehicle parking spaces are now required per local amendment to the IBC. See section 3604. For projects located in Metro Districts, there are special additional code requirements for new buildings. Please contact the plan review team to obtain the requirements for each district. Building Permit Pre-Submittal Meeting: For new buildings, please schedule a pre-submittal meeting for any new commercial or multi-family building with Building Services for this project. Pre-Submittal meetings assist the designer/builder by assuring, early on in the design, that the new projects are on track to complying with all of the adopted City codes and Standards. Please work with your Development Review Coordinator to schedulethis meeting. Department: Technical Services Contact: Jeff County jcounty@fcgov.com 970-221-6588 Topic: Building Elevations Comment Number: 18 12/06/2023: FOR FINAL APPROVAL: Please change the titles to "Salud Family Health Center - Lot 4" in the sheet title blocks. See markups. Response: Utility Plans have been updated to include “Lot 4”. However, the Plat was not updated because we are platting more than Lot 4. Response: The title of this project has been updated to include “Lot 4.” Topic: Construction Drawings Comment Number: 11 12/06/2023: FOR FINAL APPROVAL-UPDATED: There are line over text issues. See markups Page 20 of 21 08/09/2022: FOR FINAL APPROVAL-UPDATED: There are line over text issues. See redlines. 04/29/2021: FOR FINAL APPROVAL-UPDATED: There are line over text issues. See redlines. 07/10/2020: FOR FINAL APPROVAL: There are line over text issues. See redlines. Response: Responses have been added to redlines. Topic: Landscape Plans Comment Number: 15 12/06/2023: FOR FINAL APPROVAL-UPDATED: There is text that needs to be masked. Mask all text in hatched areas. See redlines. 08/05/2022: FOR FINAL APPROVAL: There is text that needs to be masked. Mask all text in hatched areas. See redlines. Response: A text mask has been added to the text in the landscape sheets to avoid line over text issues and provide more clarity. Comment Number: 17 12/06/2023: FOR FINAL APPROVAL: There are line over text issues. See markups. Response: Redlines provided have been responded to and the applicable texts have been adjusted to avoid L.O.T. legibility. Topic: Plat Comment Number: 1 12/12/2023: FOR FINAL APPROVAL-UPDATED: Please make changes as marked. If changes are not made or you disagree with comments, please provide written response of why corrections were not made. Please provide any responses on redlined sheets and/or in response letter. If you have any specific questions about the redlines, please contact John Von Nieda at 970-221-6565 or jvonnieda@fcgov.com Response: Responses have been added to redlines 08/05/2022: FOR FINAL APPROVAL-UPDATED: Please make changes as marked. If changes are not made or you disagree with comments, please provide written response of why corrections were not made. Please provide any responses on redlined sheets and/or in response letter. If you have any specific questions about the markups, please contact John Von Nieda at 970-221-6565 or jvonnieda@fcgov.com 04/29/2021: FOR FINAL APPROVAL: Please make changes as marked. If changes are not made or you disagree with comments, please provide written response of why corrections were not made. Please provide any responses on redlined sheets and/or in response letter. 07/10/2020: FOR FINAL APPROVAL: Please make changes as marked. If changes are not made or you disagree with comments, please provide written response of why corrections were not made. Please provide any responses on redlined sheets and/or in response letter. Page 21 of 21 Department: Outside Agencies Contact: Todd Sullivan tsullivan@fcgov.com 970-221-6695 Topic: General Comment Number: 1 07/17/2020: LARIMER COUNTY CANAL NO. 2 - Melissa Buick melissahbuick@gmail.com 970.686.7126 FOR APPROVAL: Larimer County Canal No. 2 Irrigating Company requests the plans show the ditch easement as being 25 feet from the top of the bank on both sides of the ditch for the continued ongoing cleaning, maintenance, and repair and/or replacement of the ditch. Additional comments are that the developer will need to have crossing agreements in place for the construction/installation of the vehicular bridge, utility or other crossings of the ditch an/or any historical discharge into the ditch. The Company requests additional plans showing the detail for each of the proposed ditch crossings for review and approval. Response: The ditch easement is shown 25-feet from the top of bank. We are coordinating crossing agreements with ditch company and city. Comment Number: 2 11/19/2021: LARIMER COUNTY CANAL NO. 2 - Melissa Buick melissahbuick@gmail.com 970.686.7126 FOR APPROVAL: Larimer County Canal No. 2 Irrigating Company will require agreements to be completed for any crossing of, or discharge into the ditch prior to work beginning and requests the developer provide a list of items impacting the ditch and ditch easement, including plans for each individual crossing. The ditch easement should be shown on the plat and access to the ditch and ditch easement throughout the property may not be obstructed. Response: We are coordinating crossing agreements with ditch company and city. Department: Water Conservation Contact: Eric Olson eolson@fcgov.com 970-221-6704 Topic: General Comment Number: 1 07/01/2020: BUILDING PERMIT: Irrigation plans are required no later than at the time of building permit. The irrigation plans must comply with the provisions outlined in Section 3.2.1(J) of the Land Use Code. Direct questions concerning irrigation requirements to Eric Olson, at 221-6704 or eolson@fcgov.com