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HomeMy WebLinkAboutordinance.council.042-13 ORDINANCE No. 42 (Series of 2013) AN ORDINANCE OF THE ASPEN CITY COUNCIL ADOPTING TITLE 29— ENGINEERING DESIGN STANDARDS. WHEREAS, The Engineering Design Standards provide policies and design guidelines to city agencies, design professionals, private developers, and community groups for residential and commercial development that ensure the public welfare, preserve the community aesthetic, and promote efficient development within the City limits of Aspen; and, WHEREAS, the City Engineer has recommended approval of the proposed Title 29 — Engineering Design Standards; and, WHEREAS,the Aspen City Council finds that this Ordinance furthers and is necessary for the promotion of public health, safety,and welfare;and NOW, THEREFORE BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF ASPEN,COLORADO THAT: Section 1: Title 29—Engineering Design Standards, shall read as follows: TITLE 29. ENGINEERING DESIGN STANDARDS Chapter 29.01 Sections: 29.01.010 Purpose and Intent 29.01.020 Adoption of Engineering Design Standards. 29.01.030 Applicability 29.01.040 Review Authority 29.01.050 Review Procedure 29.01.060 Variations 29.01.070 Appeals Page 1 of 6 29.01.010 Purpose and Intent The purpose of this Chapter is to ensure development in the City of Aspen meets minimum engineering standards. It is the City's intent to establish Engineering Design Standards that will ensure the public health, safety and welfare, preserve the community aesthetic, and promote efficient development within the City limits of Aspen. The Engineering Design Standards, as adopted pursuant to Section 29.01.020, shall apply to all construction, development, redevelopment, any work within the right of way, and Title 26 development applications and plats, annexations and vacations. 29.01.020 Adoption of Engineering Design Standards. Pursuant to the powers and authority conferred by the Charter of the City, there is hereby adopted and incorporated herein by reference as if fully set forth those standards contained in the Engineering Design Standards, as may be amended from time to time by City Council Resolution. At least one (1) copy of the Engineering Design Standards shall be available for public inspection at the Community Development Department and Engineering Department. 29.01.030 Applicability This Chapter applies to all construction, development, redevelopment, modifications and additions to existing developments, any work within the right of way, and Title 26 development applications and plats, annexations and vacations. Unless specifically exempted, the provisions of this Chapter shall supplement any and all existing laws and shall apply to all persons, without restriction, and to conditions arising after the adoption thereof, to conditions not legally in existence at the time of adoption of this title, and to conditions which, in the opinion of the city engineer or designee, constitute a distinct hazard to life or property. The Design Standards provide policies and design guidelines to city agencies, design professionals, private developers, and community groups for residential and commercial development that ensure the public welfare, preserve the community aesthetic, and promote efficient development within the City limits of Aspen. The City of Aspen shall use the policies, criteria and information including specifications and standards in the latest edition of the Engineering Design Standards for the proper implementation of the requirements of this Title. The Engineering Design Standards may be periodically amended as necessary to provide additional clarity or to reflect procedural revisions or changes in construction or engineering practices. Such revisions to these Standards may consist of either "procedural"revisions or"technical"revisions. Any other amendments to the Engineering Design Standards shall be adopted by City Council Resolution. Examples include revisions that are considered major changes, changes in law and changes that will cause significant increased cost or controversy. Page 2of6 29.01.040 Review Authority The City Engineer, or designee, is authorized to make and enforce the rules and regulations contained in the Engineering Design Standards in order to carry out the intent of the standards and this Chapter. Where no specific or applicable rules, regulations, or standards appear to be set forth in the Engineering Design Standards, other rules, regulations, standards, guidelines, and recommended practices, as published by professional associations, technical organizations, model code groups,. and similar entities, may be used by the City for guidance. 29.01.050 Review Procedure A. Review Process. The City Engineer shall have the authority on behalf of the City of Aspen to determine that all design and construction is completed to a level that is equal to or exceeds the requirements set forth in this Chapter and the Engineering Design Standards. 29.01.060 Variances A. Authority. The City Engineer may grant variances to the design standards. Variances are deviations from the terms of this Chapter which would not be contrary to the public interest. B. Standards. In order to authorize a variance from the design standards the following standards shall be met: 1. There exist practical difficulties and unnecessary hardships inconsistent with the purpose and intent of the design standards. 2. The issuance of a variance shall not compromise the safety of a site or structure. C. Application. Requests for variances from the standards, policies or submittal requirements of this document shall be submitted in writing with appropriate documentation and justification to the City Engineer. An application for a variance from the design standards shall include, at a minimum, the following information: I. The criteria from which the applicant seeks a variance. 2. A written justification outlining why the criterion cannot be met. 3. An alternate criteria or standard that is proposed to comply with the intent of the criteria from which the variance is sought. 4. Supporting documentation, including necessary calculations, etc. 5. An explanation of any potential adverse impacts of the proposed variance to adjacent landowners. 6. An analysis of the variance request must be signed and stamped by a Professional Engineer licensed in the state of Colorado. Upon receipt of a complete application for a variance, the City Engineer shall prepare a statement, approving, approving with conditions, or denying the variance. During the course of reviewing the requested variance, the City Engineer may request additional information needed to make a decision. The City Engineer may also request modifications of the proposed variance. Page 3 of 6 D. Expiration. Except as otherwise established in this Title or through vesting of a site specific development plan pursuant to Title 26, a variance granted under this Chapter shall automatically expire after twelve (12) months from the date of approval unless a building permit application submittal is accepted by the Chief Building Official. The City Engineer may grant an extension to an approved variance. All requests for extensions must be submitted prior to the expiration of the variance, must demonstrate good cause showing the extension is necessary, and must demonstrate that the circumstances for granting the variance are still applicable. E. Appeals An_applicant may appeal a variance decision pursuant to Section 29.01.070, Appeals. 29.01.070 Appeals A. Initiation. An applicant aggrieved by an order, requirement, decision, or determination of the City Engineer may be appealed to the Administrative Hearing Officer, pursuant to the procedures set out in Chapter 26.108 of this Code except to the extent set forth herein. The notice of appeal shall be filed with the City Engineer within fifteen (15) days following the date of such order, requirement, decision, or determination. The notice of appeal shall state in detail the action appealed,the grounds for the appeal, and the relief sought. Failure to file such a notice of appeal within the prescribed time shall constitute a waiver of any rights under this Chapter to appeal any order, requirement, decision, or determination. B. Effect of filing an appeal. The filing of a notice of appeal shall stay any proceedings in furtherance of the action appealed from unless the City Engineer certifies in writing to the Administrative Hearing Officer that a stay poses an imminent peril to life or property, in which case the appeal shall not stay further proceedings. The Administrative Hearing Officer may review such certification and grant or deny a stay of proceedings. C. Timing of appeal. The Administrative Hearing Officer shall consider the appeal within thirty (30) days following the date of filing the notice of appeal, or as soon thereafter as is practical under the circumstances. D. Action by Administrative Hearing Officer. The Administrative Hearing Officer shall review the record of the action taken by the City Engineer, and provide a decision to the Applicant in writing. The Administrative Hearing Officer may reverse or affirm wholly or partly the order, requirement, decision or determination appealed from and shall enter such order, as they deems appropriate under the circumstance. Section 2: Chapter 26.580 Engineering Department Regulations is here by repealed in its entirety. All citations to 26.580 within the municipal code shall be amended to cite Title 29. Section 3: Effect Upon Existing Litigation. This ordinance shall not affect any existing litigation and shall not operate as an abatement of Page 4 of 6 any action or proceeding now pending under or by virtue of the ordinances repealed or amended as herein provided, and the same shall be conducted and concluded under such prior ordinances. Section 4: Severability. If any section, subsection, sentence,clause,phrase,or portion of this ordinance is for any reason held invalid or unconstitutional in a court of competent jurisdiction, such portion shall be deemed a separate, distinct and independent provision and shall not affect the validity of the remaining portions thereof. Section 5: Effective Date. In accordance with Section 4.9 of the City of Aspen Home Rule Charter,this ordinance shall become effective thirty(30) days following final passage. Page 5 of 6 Section 6• A public hearing on this ordinance shall be held on the�'day of J,2013, at a meeting of the Aspen City Council commencing at 5:00 p.m. in the City Council Chambers,Aspen City Hall, Aspen, Colorado,a minimum of fifteen days prior to which hearing a public notice of the same shall be published in a newspaper of general circulation within the City of Aspen. INTRODUCED,READ AND ORDERED PUBLISHED as provided by law, by the City Council of the City of Aspen on the E/ day of t£'- ,2013. Attest: Kathryn S.Koch,City Clerk Ail Steven Skadro ,Mayor FINALLY,adopted,passed and approved this��day of ,2013. Attest: ( ' Kathryn S.Koch,City Clerk Steven Skadro ,Mayor Approved as to form: x Attorney Page 6 of 6 Exhibit C - Public Outreach Comments Section Number(note section numbering has been updated from the orginal comment version) Item Specifics Comment COA Response Would be good to include the 3-part system of reducing impact which is not just Conventional development and construction renewable,but reduce,reuse and recycle. Seems good to use those as BMPs,and processes are increasingly identified as potentially the'green'building I have seen at trade shows does focus on this.Very similar to adverse to the environment.Sustainable IPM which uses biological,cultural,physical/mechanical controls,and lastly, development is generally understood to mean chemical controls. An example in engineering might be: rain garden—less water Text added:This includes the encouragement of development that occurs with the goal of meeting to the rain garden—grading to prevent water from entering a paved public area— use of reducing,reusing and recycling materials as Introduction human needs while ensuring efficient use of.... and ice melting chemicals. part of the building process. Using the environmentally sensitive site design Seems as if a primary design technique in the list should include"protecting, techniques outlined in these Design Standards, improving,maintaining water quality in streams and rivers,and drinking supply"- The text was modified as follows:Improve water Introduction the following will be achieved.... something to that effect. There is no statement of water quality in that list. and air quality and reduce heat island effect The text was modified as follows:Under the direct First bullet'direct supervision of AN engineer...'so as not to be confused with supervision of an Engineer(not to be confused 1.1.1 General Requirements Under the direct supervision of an Engineer THE city engineer. with the City Engineer) Abbreviations are the last page of Appendix B,the rest are details. Should they be Abbreviations are described through out the General considered separate appendices?ppendices. document as they are referred to. Recommended scale is 1 inch equals 5,10,or 20 Engineering scales do not use 8 feet rather they Drawing Layout feet. Scale of drawings is more standard 8,10,and 20 than 5,10 and 20 use 5 feet. Are you expecting every development proposal,no matter how small,to list all The text was modified as follows:3 Utility Utility information is required according to the sub-surface details of existing utilities? How can we possible know the pipe information is required according to following(for Drawing Layout following..... size,angle,borings,etc. proposed unless otherwise noted): Overall,the detail in the list appears to be specifically geared toward projects that Yes the list is geared toward City ROW however include City ROW. Perhaps there could be a lesser standard for private there are circumstances(ie private roads)that the Drawing Layout General development. list would apply outside of the ROW Text was modified to read:j Permanent traffic Traffic control devices,including striping, "Traffic control devices"have been part of a separate"traffic control plan"do control devices,including striping,markings, Drawing Layout markings,signage,and signals. you really want them on the main sheet? signage,and signals. The profile view is to be located directly below the plan view along a matching survey line and stationing and is to be drawn at a horizontal scale For profile drawings,yes 1-5 foot scale is typical, that matches the plan view and a vertical scale of however we will consider other scales so long as Drawing Layout 1 inch equals 5 feet. Is a vertical scale of 1—Sfeet typical? they are legible. Cross-sectional drawings are required with all construction plans that include varying or transitional features,such as street sections,fill slopes,and drainage channels.Cross-sectional Yes we do want cross sections other than the drawings reflect dimensions,elevations, public ROW,especially for private driveways.This stationing,and any other detailed information Do you want cross sectional dwgs of other than public row? This does not require helps us during review to ensure that the Drawing Layout necessary to ensure accurate construction.... for private driveways for example. driveway ties into the ROW. Yes we will work with the Building Dept,and Com dev to see if we can lessen the survey burden on Projects must submit a property survey based on consider standards for homeowners that do not trigger a formal surveyor one smaller projects.Until that time you may ask for a Survey Plan Chapter 2 of these standards. made within 1 year,due to the cost burden. variance from the requirment. Section Number(note section numbering has been updated from the orginal comment version) Item Specifics Comment COA Response The disturbance area was established by the URMP.We plan on reviewing the URMP Consider increasing the disturbance area to at LEAST 500 feet before triggering requirements later this year this includes the 200 Any proposed construction project that disturbs review. Perhaps qualify with a depth calc as well?Volumetric? Also by"grading sf disturbance trigger.As far as cross sections more than 200 square feet of exterior area must plan for building permits,landscape permits....Must be in compliance with every 10 feet,that requirment is specifically comply with the grading plan requirements engineering desing standards"do you mean grading plans for landscape areas geared toward the curb and gutter,alleys and Site Grading Plan outlined in the URMP. must show cross sections etc.every 30 feet etc?that seem cumbersome if so. driveways. All development and redevelopment projects in the City of Aspen must submit a soils report stamped by a Colorado Professional Engineer,as Again,a soils report for EVERY development and redevelopment project seems required by the URMP.Please refer to Section too constrictive for many smaller projects or those that do not involve soil work A soils report is required for major driange 1.3.9 of the URMP for the soils report under 3 feet. This will cost a fortune for many smaller developers including projects.The requirement is not intended for Soils Report requirements. homeowners,landscapers,remodelers etc. minor projects that do not involve soil work. This idea has been vetted with the Parks Dept. They have determined that they do not require a stamp of a landcape architect.The triggers for referral reviews(ie Engineering,Parks,etc...)will City should require the stamp of a Licensed Landscape Architect,just as it does a be determined by our permit process Professional Engineer,licensed Architect,structural engineer etc. Also you might improvement project and will be incorporated Landscaping Plan General state that the plan will be reviewed by specific City personnel.(if it will be into our new business process web site. Text was modified to read:All existing and All existing and proposed streets and alleys, bullet 2—requires CL of existing roadways. Often in a survey we get Edge of proposed streets and alleys,including widths, including widths,centerline of roadway pavement Pavement,and that seems sufficient doesn't it?Also providing existing ROW centerline of roadway pavement(if project Transportation curve data seems excessive and not necessary. impacts centerline of street), Text modified to read:Compliant COA survey Compliant COA survey(refer to engineering dept. (refer to engineering dept.survey checklist 1.3.4 Other survey checklist) COA survey is undefined thus far located in Appendix A). Text modified to read:Unless already submitted as part of the approved plan set,a Final a Final Landscaping Plan must be submitted that landscape plan is not usually on a recorded subdivision plat. Is this your Landscaping Plan must be submitted that includes 1.3.4 Other includes.... intention? Where the proposed subdivision covers only a part of the applicant's adjacent holdings,a sketch plan for such other lands shall be submitted and the proposed streets,utilities,easements,and other improvements of the tract under review Requiring a sketch plan for an applicant's adjacent but undeveloped holdings Understood however,the City is interested in the shall be considered with reference to the seems a waste of time. Who can know? Conditions change often in the market Applicant's adjacent holdings and their plans for 1.3.4 Other proposed development of the adjacent holdings. and funding. them. Tracking pads and dust control is one of the larger_ impacts of a project,however we do not require Although a complete construction mitigation plan the details of these requirements during land use. is not required for land use,the project must CMP should you add to this tracking pads and dust control,etc?Seems the Instead we require complete mitigation of these 1.3.6 Construction Management Plan identify impacts during construction. biggest public burden. impacts during building permit process. Section Number(note section numbering has been updated from the orginal comment version) Item Specifics Comment COA Response Text modified to read:Base map and survey Base map and survey control monuments are to control monuments are to be tied to the City of 2.1.1 Survey Control be tied to the City's control network and... Survey control monument—do you mean tied to City's or Cities? Not sure Aspen's control network and..... A minimum of two(2)sets of mylars and one(1) this is first reference to providing data specifically on CDs,not just'electronically'. 2.3.1 Condominium Subdivision Plat compact disc(CD)shall be submitted Is this a special case? Requirement was removed. Trees planted in public utility easements shall be located at least 10 feet away from existing or Trees in utility easements required 10. 1 don't believe the City itself complies with This is a current requirement(not a new one)and 2.5 Easements future utilities. this. yes the City does try to comply. Text was modified to read:Storm drainage Where applicable,projects shall provide for public Longitudinal placement of public utilites: what about storm drainage that might systems and associated infrastructure are also 2.5 Easements utility easements. be necessary through a subdivision? considered as a public utility. No the 20 foot width requirement is not new however a variance may be considered if the setbacks for a property conflict with the above easement dimensions and the applicant can Water and sewer easements shall be a minimum Is the requirement for 20'width in water and sewer easements new?Seems like demonstrate how the easements will be 2.5 Easements of twenty(20)feet in width. it should be evaluated case by case? alternatively accommodated. Driveway dimentions are either 10 or 18 feet Can you check with driveway standards because my recollection is city required depending on the frontage a property has and driveways no more than 16'or 14'at intersection with public street,this does not how the garage or parking is oriented.If a accommodate 20 emergency access. I think driveway standard should be driveway is used for emergency access then the 2.5 Easements Emergency access dimentions increased to 20'. width is widened to 20 feet. The City does not use underground transformers due to access limitations during an emergency. All utilities shall be placed underground,except For example if the underground transformer has transformers,switching boxes,terminal boxes, Would it be in the best interests of the public and the utilities to require snow on top of it,it will take longer to locate and 3.2 Location meter cabinets,pedestals,and ventilation ducts underground transformers? Seems like that's the trend. longer to"dig"out. Instead of requiring a specific turrning radius, refer to driveway throats and curb cuts,so if Planning will agree to 20'for res, overhang heights and turn around,we just require Adequacy of the project site design to fully satisfy that might be better. I think you should also include sufficient turning radius, the site to demonstrate that they can ratify the Chapter 4 Transportation Design on-site truck-loading demand. overhang heights and turnaround for delivery vehicles such as Fed Ex,UPS. onsite truck loading demand. In the case of a large multi use subdivision or PUD for example,a through cut or subdivisions are required to have access to the Chapter 4 Transportation Design General access from the ROW may be desirable. ROW(refer to plat requirements A 3:1 slope is too steep for a vehicle to recover(ie come back to the driveway if they drive off) Regardless,the requirement was revised to read: Guardrails,retaining walls,curbing or equivalent Guardrails,retaining walls,or curbing must be errant vehicle protection must be provided for provided for driveways that have steep(i.e.3:1 or Guardrails—3:1 is not considered steep and requiring guard rails for residential driveways that have steep(i.e.3:1 or greater)side Chapter 4 Transportation Design greater)side slopes. drives that have them will be an excessive cost burden and unnecessary. slopes. Section Number(note section numbering has been updated from the orginal comment version) Item Specifics Comment COA Response The following text was added:If it is determined that the cross section needs to accommodate a The streets in the City of Aspen are classified into bike lane,the typical cross section provided will alleys,local,commercial,and collector streets. Should you add provision for bike lanes in these requirements somewhere,say not apply.Instead a new cross section will be 4.2.1 Classification of Streets Typical cross sections are shown in Appendix B. residential collector and commercial? developed to accommodate this additional use. Horizontal design standards for all city streets For now we do not require development to install shall comply with Table 3—Horizontal Alignment bike lanes instead they are installed by the City as 4.2.4 Horizontal Alignment Standards. Include spec for bike lane? part of an overal plan. Parking lanes shall not be located within twenty feet of a crosswalk at an intersection or within Currently parking spaces/lanes are 15'from crosswalk,intersection etc.,in the The parking lane requiement is not new,it was 4.2.4 Horizontal Alignment thirty feet of any signal,stop sign,or yield sign. City I think,although Parking dept keeps taking them away. taken directly from the City's Model Traffic Code. Having a detached sidewalk not only improves the Sidewalk layout 5''landscape buffer'between back of curb and sidewalk. This has pedestrian experience it also allows for a planting been a concern of mine for some time. It makes no sense for a person to exist the strip along the street.This space(as you Sidewalks shall be placed so that there is a car,cross muddy or snow-filled'buffer'to access sidewalk! They won't!this mentioned)is also used for snow storage.For minimum buffer of 5 feet between the back of causes peds to walk in the street to get to a doorway,or compacts and ruins the projects that are concerned about people walking the curb and the sidewalk;this is to allow for 'buffer'over time. This is key to snow removal particularly. We can't climb over over the landscape area,the projects typically use adequate landscaping and snow storage buffer the snow banks in the'buffer'zone. Sidewalks in the core especially,should be pervious pavers or provide for pedestrian paths 4.5.2 Sidewalk Layout and Design behind the curb gutters and travel paths. attached accross the lanscape strip. When there exist site constraints,and minimum widths cannot be achieved,the sidewalk width may be accomplished in landscape areas with the use of approved materials(i.e.,pavers)as approved by the City Engineer and Parks Department.This includes the use of alternate materials in place of tree grates.However,the alternate materials for the landscape area must be consistent with the same materials for the sidewalk area.For example if there is an available width of 12 ft.(usually within a commercial area) it will have a 7 ft.sidewalk made of pavers and The example shows how to allow sidewalk in the additional 1ft.pavers in the landscape area to makes no sense to have concrete with a 1 foot paver border to accommodate a lanscape buffer area.As it is described there will create an 8 ft.walk width and the remaining landscape buffer. The 1 foot paver zone just heaves and is unstable,becomes a not be a 1 foot paver buffer,rather the sidewalk 4.5.2 Sidewalk Layout and Design width of 4'will be dedicated to landscaping. hazard and unsightly. Impossible to maintain. will encroach 1 foot in the landscape buffer area. Pedestrian ramps for streets with curbs and Diagnal ramps direct pedestrians into the middle gutters must be constructed at all intersections Ramps should be the full distance of radius for snow removal.The design of two of the intersection instead of the cross walk.This with sidewalk and curb returns in accordance ramps and a tiny curb section in between,is silly and just gets hammered by is of particular concern for those pedestrians who 4.5.5 Pedestrian Ramps with the details in Appendix B. snowplows. are vision impared. The folowing text was added:On street bike lanes are installed by the City as part of an overall bike 4.6 Bike Path General Could include reference to bike lanes on appropriate streets lconnectivity plan. Section Number(note section numbering has been updated from the orginal comment version) Item Specifics Comment COA Response Finished grades of 1:1 and 2:1 will not support Text was revised to read:Finished grades of 1:1 vegetation growth and is subject to erosion.The and 2:1 are subject to severe erosion as a result maximum finished grade is 3:1 How about"Max finished grade without slope stabilization methods shall be 3:1. the maximum finished grade permitted is 3:1 (horizontal:vertical)unless otherwise approved by Slopes in excess of 3:1,up to and including 2:1 may be stabilized with vegetation (horizontal:vertical)unless otherwise approved by the City Engineer with surface stabilization and by a method approved by the City Forester,or by mechanical retaining systems. the City Engineer with surface stabilization and providing that no grading exceeds one to one Slopes 2:1 or greater that are longer than 4'may require mechanical stabilization. provided that no grading exceeds a one to one 5.2 Grading Standards (1:1). Any mechanical retaining over 6'in height shall require the stamp of a PE or LLA" (1:1)ratio. For walls located in the City Right-of-Way,the plans,profiles,sections,details,interference drawings,and engineering analyses and calculations for each wall type shall be stamped by a licensed Colorado Professional Engineer if Requirements should perhaps only be so specific for walls over 6'in height or the wall height exceeds 4 feet,as measured from something. Safety factor calcs,parameters etc.are typically not necessary for Sumbittal requirements are only for walls greater 5.3.3 Submittal Requirements finish grade. walls under 4',and if stamped by PE or LLA,assume liability of the designer than 4 feet. Allowed Projections into Setbacks.Setback areas shall be unobstructed above and below ground except for the following allowed projections:Uncovered porches,landscape terraces,slabs,patios,walks,landscape walls, earthen berms,retaining walls,steps and similar structures,which do not exceed thirty(30)inches vertically above or below natural grade or finished grade,whichever is more restrictive.(Also see Chapter 26.410—Residential Design Standards for limits on the location of berms.) Improvements may be up to thirty (30)inches above and below grade simultaneously,for up to a sixty(60)inch total. Improvements may exceed thirty(30)inches below grade if determined to be Within a property,retaining walls shall not exceed necessary for the structural integrity of the 5.3.3 Submittal Requirements the height limitations set forth in 26.575.020 Please clarify whether footers for walls must be in setback and PL or not. improvement. No snowmelt is not allowed to drain to the City 5.6 Snowmelt Systems General Pvt snowmelt not allowed to drain into ROW----Unless fee in lieu is paid? ROW because of ice claming issues. Instead of refering to a separate landscape document,this section has been written so that it gives specific guidance on landscape requirements.Additionally Aspen are not Entire landscape section is too specific and should be included in the Parks docs, permitted in the ROW,instead large shade trees 5.7 Landscaping General maybe not in here.If included here,Aspen should be allowed in the ROW are preferred. The City is putting a lot of emphasis on Silva cells because we are interested in growing a healthly and strong urban forest.We think this can be 5.4 Silva Cells General Too much emphasis on the product"Silva Cells". achieved with the use of Silva Cells Section Number(note section numbering has been updated from the orginal comment version) Item Specifics Comment COA Response The following text is included in the parking section:All required parking and access areas shall I think Snow storage should be given more emphasis and should be contained in be designed to accommodate on-site snow 5.8 Snow Storage General the Parking design section,not grading. storage per Section 5.8.