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HomeMy WebLinkAbout1041 - FCLWD TRILBY WATER TANK FEEDER LINE PRE-APPLICATION - - SUBMITTAL DOCUMENTS - ROUND 1 - Project Narrative Project Information and Design Narrative - FCLWD 30” Trilby Tank Feeder Water Line Connection City of Fort Collins 1041 FONSI Request August 7, 2024 Ally Utility Consulting 1 | Page Request for Finding of No Significant Impact (FONSI) The Fort Collins – Loveland Water District submits this narrative and the supporting application materials for consideration in the City of Fort Collins’ 1041 regulations process. After significant alternative evaluation, and conducting an Ecological Characterization Study, FCLWD respectfully requests a ‘Finding of No Significant Impact’, or FONSI, from the City of Fort Collins based on those portions of the project that are subject to City review. Purpose of Project In previous engineering studies, critical treated water infrastructure investments for the Fort Collins – Loveland Water District (FCLWD) were identified to increase resilience and redundancy. These investment recommendations included construction of additional water lines and finished water storage, including the proposed construction of a 6 Million Gallon (MG) tank and 30” Feeder Waterline. These facilities increase the reliability of the District’s existing facilities in the same location. The Fort Collins - Loveland Water District needs to increase reliability and resilience to its customers by constructing a treated water storage tank, just north of the existing District Trilby 4 MG water tank. The proposed new tank will be located on the County’s landfill property, near the County’s proposed Solid Waste Transfer Station (see attached Exhibit 1). The location of this project spans the land planning areas of both the County and the City, and therefore require coordination with each entity for those components within their respective jurisdictions. Reliable water and water infrastructure is critically important to society, and is supported in the Larimer County Comprehensive Plan by ensuring that Larimer County “facilitates the provision of utility and communication services to keep pace with demand and meet the needs of residents” and will “collaborate with and promote coordination of utility providers to deliver affordable and reliable services, share resources, and increase efficiency.” The County further supports water infrastructure planning in the County’s 2019-2023 Strategic Plan’s #1 Goal: “Larimer County works collaboratively to ensure adequate public infrastructure is available to support the needs of our growing community.” The cooperative nature of the proposed FCLWD facilities and the infrastructure needs of County residents has been established in a recently-signed Memorandum of Understanding. Similarly, these proposed facilities are congruent with the current version of the City of Fort Collins’ “City Plan” (Comprehensive Plan): » Addressing infrastructure priorities: City Plan supports collaboration with local and regional partners as development occurs to address infrastructure and service needs in areas not currently served by City utilities. (Vision/Values) » Policy LIV 1.3 - COMMUNITY EDGES Collaborate with Larimer County and adjacent communities to plan the edges of the Fort Collins GMA. Provide joint guidance on factors including, but not limited to, future land use, development referrals, infrastructure planning, development standards, Transfer of Development Rights (TDR) programs, fees, community separators and the preservation of open lands. (Principles and Policies) Stored potable water ensures that the FCLWD can serve approximately 60,000 existing customers (including City of Fort Collins residents) with water during high demand periods of the summer. Water Ally Utility Consulting 2 | Page tanks also ensure this stored water is sufficient to provide a buffer of emergency water during these crucial periods of hot, dry weather. Emergencies can include unanticipated disruptions in water supply, disruptions to water treatment processes, water transmission line bursts, and fire-fighting needs. FCLWD territory spans portions of the City of Fort Collins, the City of Loveland, Larimer County, Timnath, and Windsor. Accordingly, the fire protection agencies of these areas depend on the District’s ability to construct this stored water. Hospitals, schools, and other primary social services also depend on this water service reliability. The District’s Mission is to respond to growth within these jurisdictions and ensure that necessary water service is reliable and uninterrupted. FCLWD is not an agency that governs land-use, and therefore can only respond to the growth of the region through responsible planning and construction of infrastructure. With sustained population growth over past decades, the District must increase its stored water tanks and the waterlines connecting them to the Distribution piping system. Without this increased storage and waterline connectedness, District customers will suffer a reduction in their potable water reliability that becomes apparent during unplanned emergencies. The proposed 6 MG Trilby Tank and most of the proposed 30” Feeder Waterline are predominantly located outside of the City of Fort Collins, on land owned by Larimer County. FCLWD is coordinating closely with Larimer County Planning for these portions of the project to satisfy the County’s review requirements. While much of the project is not subject to review under City of Fort Collins 1041 regulations, a small portion of the proposed waterline facilities are: the connection to an existing 36” FCLWD waterline and approximately 100 linear feet of 30” waterline. This portion of the project is proposed for construction on lands owned by the City of Fort Collins. After coordinating with City of Fort Collins staff (Kirk Longstein) in January of 2024, FCLWD was notified that this portion of the project was subject to 1041 Review, and possibly eligible for a Finding of No Significant Impact (FONSI). In addition, CFC developed a Submittal Checklist and Guide, specific to this project and submitted with this narrative report which outlines ‘Required’ and ‘Waived’ 1041 submittal requirements. Alternatives Two alternatives were developed to evaluate the optimum connection for the proposed 30” waterline to connect to the existing 36” FCLWD waterline, as illustrated in Exhibit 2 (Appendix). Both of these alternatives are also illustrated with a ½ mile buffer as illustrated in Exhibit 2, and used to perform the Ecological Characterization Study. Exhibit 2 and the Study are also included in the Appendix. Primary Design Alternative This option connects the proposed 30” Tank Feeder Line to the existing FCLWD 36” waterline in the northeast quadrant of the intersection of Taft Hill Road and W. Trilby Road. This connection will occur in the easement for the existing 36” District waterline. From this location, new 30” waterline will be to the west, and under Taft Hill Road via a bore and casing pipe. To accommodate this new pipe, and the excavation required for the bore pit, additional permanent easement will be required (Appendix Exhibit 3). This approach will also ensure that vehicular traffic is not disrupted in either Taft Hill Road, nor W. Trilby Road. In addition, traffic to the Larimer County Behavioral Health facility and the Larimer County Landfill will also be maintained at all times. Ally Utility Consulting 3 | Page From this intersection, the pipeline will continue to the west to the Proposed 6 MG Trilby Tank. This portion of pipeline is not subject to City of Fort Collins 1041 Review, but rather will be under the review of Larimer County. Advantages, Disadvantages, and Unknowns for this option are outlined in the following table: Benefits Impacts Unknowns Alternate Design This option, as illustrated in Exhibit 2, would include connection to the FCLWD 36” waterline in W. Trilby Road, west of the intersection with Taft Hill Road. Due to the depth of the District waterline in the intersection (greater than 12’), this alternative would require significant excavation to connect the waterline and lay pipe to the west within the asphalt paving of W. Trilby Road. Benefits Impacts Unknowns regulations are triggered bicycle traffic due to deep, open-cut nature to CFC traffic signal facilities waterline will be significant and likely impact new W. Trilby Asphalt (Behavioral Health Ally Utility Consulting 4 | Page Based on the above analysis, the Primary Design Alternate has been selected by the District and proposed for City of Fort Collins review in this process. Detailed design has been performed and is illustrated in the relevant design sheet included in the Appendix. This alternate also requires additional permanent easement to be granted to the District for installation and maintenance of the proposed 30” pipeline. This proposed easement description is included in the Appendix. Ecological Characterization Study Summary, Cumulative Impacts, and Potential for Significant Impacts As illustrated in the prior tables, the Primary Design Alternative offers the greatest number of benefits, and the fewest number of potential impacts and is proposed for the City’s approval in the FONSI finding as discussed below: Primary Design Alternative Since the proposed (preferred) Primary Design Alternative occurs outside of the road rights-of-way, temporary construction impacts to a small area of the Fort Collins property will occur. This will be limited to connecting to the existing 36” waterline, and digging a deep and compact ‘trench box’ excavation for the drilling and boring equipment. As a result of this proposed excavation, an Ecological Characterization Study was conducted for this alternate. As outlined in the attached Ecological Characterization Study (Appendix), no concerns were raised regarding this Alternate. This includes threatened or endangered species; no waters of the US or wetlands were identified; no migratory bird nests were observed; and not recorded cultural resources were identified within the requested radius of analysis. The Ecological Characterization Study also recommends avoiding excavation activities during certain times of the year to minimize potential impacts to Western Meadowlarks and song sparrows. Based on conversations with City staff as a condition of any potential FONSI approval, FCLWD will ensure this work occurs between September 1 and March 31 to avoid impacts to foraging migratory birds. Construction field activities to perform work for this alternative are anticipated to last approximately 8 weeks. Temporary impacts are anticipated to be minor, and limited to construction and revegetation activities. These impacts include surface water runoff during precipitation events, potential groundwater discharge during construction, prairie dog and avian habitat disruption, and revegetation of the area to ensure restoration of the City’s natural areas land to preconstruction activities. Permanent impacts are not anticipated. This alternative is proposed within the City’s existing Cathy Fromme Natural Area. The proposed easements associated with this Alternative are approximately 0.21 acres, to be located adjacent to an existing FCLWD 7.3 acre (approximate) pipeline easement. This existing 30 foot-wide pipeline easement is parallel to the Taft Hill Road, from the Trilby Road intersection to a point approximately 2 miles north. While this design will increase the FCLWD’s easement within the Cathy Fromme Natural Area, the net increase in easement is small: approximately 2.9%. Furthermore, this ‘new’ easement is primarily located between the existing FCLWD pipeline easement, and the existing Taft Hill and Trilby Road rights-of-way. This area offers lower value of open space than uninterrupted open space to the northeast of this LOD. Any future Taft Hill Right of Way widening would similarly reduce the impact of this proposed pipeline easement to the overall value of the Cathy Fromme open space, and any Ecological impacts associated with this alternative. This alternate does not significant impact a natural feature, nor have the potential to significantly impact natural habitat corridors. Ally Utility Consulting 5 | Page This Alternative also features a drilled boring under Taft Hill Road, which ensures that vehicular traffic is not impacted during the anticipated 3-week construction window of this work. This is particularly important given that: • This traffic signal is the ‘first’ traffic signal that northbound vehicles experience in nearly three miles of high-speed travel from Loveland. This mitigates potential risk to construction workers and other vehicles posed by inattentive, or distracted drivers travelling northbound on Taft. This is especially important at night, with increased potential for impaired drivers encountering traffic control, lane shifting, barriers and cones, etc. • No detours are necessary for this alternate. This eliminates public frustration associated with multi-mile detours. This is also important to large vehicles, and vehicles pulling trailers to the landfill. Under the Alternate Design, west-bound Trilby drivers attempting to turn north to the landfill would be frustrated to discover that this movement is prohibited. Drivers with trailers would be doubly-frustrated then, when being forced to drive further west on Trilby (a dead-end road) to find a spot to turn around. Likely, drivers would elect to use Behavioral Health entrances and parking lot to turnaround, frustrating everyone involved. • This intersection is important for bicycle travel, which would be unaffected with the proposed Primary Design Alternative. • Since there are fewer existing ‘other’ facilities (pipes, traffic signal communication and sensing loops, gas lines, fiber optic lines, etc.) associated with this Alternative, this option offers significantly less risk than the Alternate Design, which features deep, open-cut excavation in an area with known groundwater and numerous other facilities. • Due to the shallower depth of excavation and shorter windows of construction, groundwater risks are lower with this alternative. This reduces the risk and cost associated with any groundwater treatment that is required through CDPHE groundwater dewatering and discharge permits if naturally-occurring or landfill contaminants are encountered. • While these proposed pipe facilities have a design life projected to be 70 years or greater, eventually repairs or replacement will be required. This alternative offers the greatest flexibility and least impact to future residents and vehicular traffic. This will become increasingly important as area population grows, and roadway templates and traffic loads correspondingly increase. After construction is completed, areas impacted by construction activities will be returned to preconstruction condition. Therefore no cumulative impacts to this area have been identified. While the location of this alternate is within existing City natural areas, the additional increase to an already-existing FCLWD pipeline easement is small. As a result, no potential for temporary or permanent Significant Impacts have been identified for this Primary Alternate. Alternate Design The Alternate Design would occur within the road rights-of-way. Due to the depth of the exiting 36” waterline to which the proposed 30” waterline must connect, this excavation would likely exceed 15’ in depth. In addition, groundwater is known to exist at this depth, further complicating the excavation and stabilization plans. This would result in significant excavation footprint that would significantly impact the Trilby roadway, east of the intersection. This Alternate also includes similar impacts to the intersection, with significantly increased potential complications due to the congested nature of below-grade facilities Ally Utility Consulting 6 | Page at this intersection. Lastly, the complicated nature of this Alternate would extend the construction window, and therefore extend and increase the risks and traffic control frustrations associated with the project. Since this Alternate occurs within road right of way, it does not trigger 1041 review regulations. Therefore no Ecological Characterization Study was conducted for this Alternate. Construction field activities to perform work for this alternative are anticipated to last approximately 12 weeks. Temporary impacts include significant disruption to traffic and bicycle patterns, increased risk to existing utilities, surface water runoff during precipitation events, potential groundwater discharge during construction, removal and replacement of City of Fort Collins Trilby Road asphalt paving, removal and replacement of Larimer County Trilby Road asphalt paving, and disruption in traffic patterns to Larimer County’s Landfill and Behavioral Health facilities. Permanent impacts would include repeating these temporary impacts under repair and replacement activities by the FCLWD on the proposed facilities. This Alternate has significant impacts: • As the ‘first’ traffic signal that northbound vehicles experience in three miles of high-speed travel from Loveland, there is increased potential risk to construction workers and other vehicles posed by inattentive or distracted drivers travelling northbound on Taft. This is especially important at night, with increased potential for impaired drivers encountering traffic control, lane shifting, barriers and cones, etc. • Significant multi-mile detours would be necessary, frustrating large vehicles, and landfill- bound vehicles pulling trailers. West-bound Trilby drivers would be doubly frustrated when being forced to drive further west through the intersection and finding that Behavioral Health entrances and parking lot are the best options to turnaround. This would also lead to frustrations experienced by Behavioral Health customers and employees. • Bicycle travel would be affected during construction. Potential multi-mile detours could be extra burdensome to cyclists. • Significant ‘other’ facilities (pipes, traffic signal communication and sensing loops, gas lines, fiber optic lines, etc.) associated with this Alternative could be impacted or inadvertently disrupted during construction due deep, open-cut excavation in an area with known groundwater and numerous other facilities. • Deeper excavation and longer windows of construction in groundwater increases the risks associated with this alternative. This is compounded by any groundwater treatment that is required through CDPHE groundwater dewatering and discharge permits if naturally- occurring or landfill contaminants are encountered. • In the future, repairs or replacement will replicate these impacts to future residents and vehicular traffic. This will become increasingly important as area population grows, and roadway templates and traffic loads correspondingly increase. • This Alternate requires impacting new Trilby Road asphalt that was recently installed with the Behavioral Health project. Larimer County staff and Commissioners have expressed a desire to avoid impacting this new road way with this project. Cutting this asphalt and intersection to construct this pipeline would likely draw public criticism and ire. Since impacts of this Alternate do not extend beyond the road right of way, no cumulative impacts to this natural area are identified. Given the above analysis, Significant Impacts are expected with the Alternate Design. Ally Utility Consulting 7 | Page Permits For either alternate, the additional permits will include a City of Fort Collins “Permit for Excavation on Public Property in the Right-of-Way”; a CDPHE Construction Stormwater Discharge permit; and a CDPHE dewatering permit (if groundwater is encountered). These permit applications will be initiated after the City’s 1041 evaluation, and therefore have not been started. No federal permits are associated with this work. Conceptual Mitigation Plans As stipulated in the 1041 checklist, mitigation plans for this review are limited to the LOD or “Limits of Disturbance”. This area is defined as those construction areas within the existing and proposed permanent and temporary easements overlaid on the Cathy Fromme Natural Areas land for the preferred Alternate. This is illustrated in Exhibit 2 in the Northeast quadrant of the Trilby / Taft Hill Road intersection. City of Fort Collins Land Use Code Section 6.27.6.5 lists criteria to be used for determination by the Director of a finding of No Significant Impact. As discussed previously, additional easement and construction activities would be associated with the preferred Alternate, however the scale of these impacts is small and temporary. In addition, the impacts associated with the preferred alternate are less significant that those associated with the Alternate Design. The following mitigation plans are proposed for the preferred alternate: Traffic Disruption, Impacts to Landfill Customers, and Reduced Risk for Construction Workers and Nearby Utilities As discussed previously, this project will significantly increase reliability for FCLWD water customers through the installation of additional buried water infrastructure. The proposed approach mitigates temporary and permanent impacts by limiting the impact to vehicular traffic, bicyclists, landfill customers, Larimer County Behavioral Health and other adjacent neighborhoods that would otherwise be frustrated by construction within the Trilby and Taft Hill roadways. This approach also mitigates the concern and expense of cutting the newly installed Trilby asphalt, west of the intersection. Safety, for both the public as well as construction workers, is also mitigated by this proposal. These mitigations will be realized during the proposed installation of this infrastructure (temporary) as well as future repair and replacement activities (permanent). Additionally, the proposed approach reduces the potential (negative) impact of existing utilities within the intersection, including City of Fort Collins traffic signal communications systems. Topsoil Handling, Stockpiling, and Vegetation Reseeding To ensure that the area is returned to its preconstruction condition, the top 18” of topsoil will be scraped and stockpiled separately from excavated underlying soils. Silt fencing will be placed to limite runoff impacts and soil migration during construction activities. After construction activities, the topsoil will be replaced to the top 18” of the ground. The disturbed areas will be reseeded with native seed mix per the City of Fort Collins Natural Areas specifications. This includes the City’s preferred mix for prairie dog and bird habitat. After germination and establishment of the seed, silt fencing will be removed from the site. Ally Utility Consulting 8 | Page Groundwater Mitigation All construction activities that encounter groundwater are under the jurisdiction of the Colorado Department of Health and Environment (CDPHE) groundwater discharge permit system. Groundwater encountered and pumped from the excavation on this project will be governed under this State of Colorado system of notification, permitting, and monitoring. Groundwater with contaminants will be discharged to the surface only through this permit system, which has controls to ensure contamination is removed through onsite treatment techniques prior to discharging to the environment. Disproportionately Impacted Community Analysis Colorado Enviroscreen (an Environmental Justice Mapping Tool) was utilized to determine whether this project was within an area that has been identified as a Disproportionately Impacted Community (DIC). This tool was developed for Colorado Department of Public Health and Environment (CDPHE) by a team from Colorado State University. As illustrated in the in Appendix, this project is not located within an identified community, using the latest database (May 2023). Therefore no mitigation techniques are required for this project related to DIC designations. Avian Resource Mitigation Plan As outlined in a future permit, construction activities will be limited to between September 1 and March 31 to limit impacts to avian resources in the area. Prairie Dog Management Plan As outlined in the prairie dog management plan in the Appendix, prairie dogs will be eradicated only within the LOD immediately before and during construction activities. Based on conversation with City Staff, relocation is not a viable option for temporary or permanent conditions. Given the existing prairie dog populations in the immediately surrounding area, City staff is not requiring permanent prairie dog extermination from the FCLWD for this area, after construction activities have concluded. Allowing prairie dogs to reestablish habitat in this area after construction is also a mitigation technique. Avian Impacts Mitigation Construction activities will be limited to between September 1 and March 31 to avoid impacts to foraging migratory birds. No additional conceptual mitigation plans, beyond returning disturbed areas to preconstruction condition, are envisioned. In addition, City-specified seeding mixes will be used to benefit both prairie dog and avian habitat. Conclusion Two alternatives have been analyzed for this project. While the Alternate Design is burdened with many disadvantages and impacts, the proposed Primary Alternate offers many advantages. Mitigation plans have been developed to address the minor temporary and permanent impacts that have been identified in collaboration with City Staff. No significant impacts have been identified and therefore, the FCLWD respectfully requests a FONSI for this 1041 application.