HomeMy WebLinkAboutMinutes 01/31/17 PUBLIC HEARING
January 31, 2017
Present: Jillian Ryan Chairman
Kathy Chandler-Henry Commissioner
Jeanne McQueeney Commissioner
Brent McFall County Manager
Bryan Treu County Attorney
Beth Oliver Deputy County Attorney
Kathy Scriver Deputy Clerk to the Board
This being a scheduled Public Hearing,the following items were presented to the Board of County
Commissioners for their consideration:
Commissioner Updates
Commissioner McQueeney shared information from the Northwest Colorado Council of Governments
(NWCOG)meeting she attended. The NWCOG approved nine loans in 2016 with the requirement that the small
businesses generated jobs. She wanted people to be aware that these loans were available and there was more
money to lend.
Commissioner Chandler-Henry stated that last week she attended Colorado Counties Inc. (CCI)and Eagle
County was able to get an appointment as Vice Chair of the Tourism Recreation and Economic Development
Committee as well as the CDOT Public Lands Traveling Committee.
Chairman Ryan spoke about a story in the Vail Daily that had to do with I-70 infrastructure. The 1-70
mountain corridor and 1-25 made President Trump's top 50 projects for infrastructure improvement money. CDOT
was excited and she was thought this might be a great way to get some of the needs met to continue the efforts of
reducing the congestion on I-70.
Consent Agenda
1. Second Amendment to Agreement between Eagle County and Can Pro Rodeo
Tanya Dahlseid,Fair and Rodeo
2. First Amendment to Agreement for Professional Services between Eagle County and Community Health
Services,Inc. for Family Planning Services
Jennie Wahrer,Public Health and Environment
3. Colorado Department of Transportation; Eagle County Signature Sheet for Highway User Tax Fund for
Mileage Revenue Certification
Nicole Trujillo and John Harris,Road&Bridge
4. Approval of the Minutes of the Board of County Commissioner Meeting for November 1,
November 10 and November 15
Kathy Scriver, Clerk and Recorder
5. Intergovernmental Agreement(IGA)between Eagle County and the Colorado Department of Natural
Resources for Cooperative Wildfire Protection
Barry Smith,Emergency Management
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6. Animal Shelter and Services Intergovernmental Agreement(IGA)with the Town of Eagle
Nathan Lehnert,Animal Shelter and Services
Ms.Dahlseid spoke about Item 1,the agreement between Eagle County and Can Pro Rodeo.
Commissioner McQueeney moved to approve the Consent Agenda for January 31, 2017, as presented.
Commissioner Chandler-Henry seconded the motion. The vote was declared unanimous.
Citizen Input
Chairman Ryan opened and closed citizen input,as there was none.
Business Item
Commissioner Chandler-Henry moved to adjourn as the Eagle County Board of County Commissioners
and re-convene as the Eagle County Housing and Development Authority.
Commissioner McQueeney seconded the motion. The vote was declared unanimous.
Eagle County Housing and Development Authority
7. AIA Form B 108-2009 Standard Form of Agreement between Architect and Owner between Lake Creek
Village LLC and Tab Associates,Inc. for Lake Creek Village Apartments Improvements
Jill Klosterman,Housing
Ms.Klosterman explained that the agreement was simply a replacement to an agreement they did in March
of 2016 with Tab Associates, a local architect that helped with design work for replacing the exterior siding, adding
insulation, and replacing windows. Lake Creek Village was applying to Housing and Urban Development(HUD)
for additional funding to complete the work and HUD required a specific form. The contract had not changed and
the project would commence in the spring.
Chairman Ryan explained that the county owned the apartments and took over management a couple years
ago.
Commissioner Chandler-Henry wondered how many more projects were needed at Lake Creek
Apartments.
Ms.Klosterman stated that they would continue replacing boilers and such but this was the last of the major
improvements. The buildings would be different colors so people could identify the separate units.
Commissioner McQueeney moved to approve the agreement between Lake Creek Village LLC and Tab
Associates, Inc. for Lake Creek Village Apartments improvements.
Commissioner Chandler-Henry seconded the motion. The vote was declared unanimous.
Commissioner Chandler-Henry moved to adjourn as the Eagle County Housing Authority and re-convene
as the Eagle County Board of County Commissioners.
Commissioner McQueeney seconded the motion. The vote was declared unanimous.
Brent McFall Retirement Celebration
Chairman Ryan spoke about the celebration for Brent McFall's retirement. In 2017,Mr. McFall started his
42°a year in public service. She spoke about his work in local government. Since coming to Eagle County,he had
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made certain that there was an actionable strategic plan and promoted process improvements. She thanked Mr.
McFall for spending his last two years with Eagle County and wished him all the time in the world to play golf,ride
his bike, and enjoy his family.
Commissioner McQueeney added her thanks and appreciation for the work Mr.McFall had done for Eagle
County. The Strategic Plan was a key component. He had lead by example in terms of customer service.
Commissioner Chandler-Henry added her thanks and pointed out the work he'd done with the
municipalities.
Aric Otzelberger spoke about his relationship with Brent McFall over the years and his 42 years of
dedication to public service and professionalism in local government management. He set a powerful example for
everyone.
Mr. McFall thanked everyone for the recognition.He was drawn into public service because it felt like a
challenge and there were exciting opportunities. He got hooked on the notion of making a difference in people's
lives. He'd had the opportunity over the years to work with thousands of dedicated professional staff and dedicated
community citizens who took the time and interest to be involved. It had been a thrill. He looked forward to the
next phase in his life.
Chairman Ryan presented him with a gift on behalf of the county and wished him the best.
Planning Files
8. PDP-4986 The Tree Farm PUD **TABLING TO 2/21**
Scot Hunn,Planning
Commissioner McQueeney moved to table file PDP-4986,Tree Farm PUD until February 21, 2017.
Commissioner Chandler-Henry seconded the motion. Of the two voting Commissioners,the vote was
declared unanimous.
9. PDA-5941 Frost Creek Salt Creek PUD Amendment
Kris Valdez, Community Development
FILE NO./PROCESS: PDA-5941,Amendment of a Planned Unit Development
PROJECT NAME: Frost Creek and Salt Creek PUD Amendment
LOCATION: Brush Creek Road
OWNER: BCP-ARR, LLC
APPLICANT: BCP-ARR, LLC
REPRESENTATIVE: Dominic Mauriello,Mauriello Planning Group
STAFF PLANNER: Kris Valdez, MURP,AICP
STAFF ENGINEER: Taylor Ryan,PE
STRATEGIC PLAN GOAL: "Eagle County is a Great Place to Live for All"and"Eagle County
Protects the Natural Environment"
POLICY ISSUE: The policy question is whether or not the Eagle County Permit Authority
should approve this application.
I. Project Update Since December 13,2016 Hearing:
Please be aware this is the update memo documenting changes proposed by the Applicant since the December
13,2016 hearing with the Board of County Commissioners. For the full report,please see the staff memo from
the December 13,2016 hearing.
Update and Revisions by the Applicant
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The Adams Rib Planned Unit Development(PUD),proposed to be named Frost Creek and Salt Creek PUD,
currently allows for 97 dwelling units (not including the Salt Creek portion of the ranch), 25 accessory dwelling
units, and 5 cabins which is equivalent to 127 units.
In December,the proposal before the Board of County Commissioners would have allowed 142 dwelling units,
with 15 accessory dwelling units, and 20 cabins (including the 5 already constructed next to the clubhouse)which is
equivalent to 177 units or 45 new dwelling units.
The Update and Revisions submitted on January 13, 2017, included a reduction in the requested density as
discussed in December 2016. The new proposal is to allow for 137 dwelling units,removing the 25 accessory
dwelling units currently allowed in the PUD,and reducing the number of requested guest cabins down to 8 cabins
which means a total of 13 guest cabins with the 5 cabins already constructed.This would mean a total of 150 units
or 23 new dwelling units which is an 18%increase in overall density.
In summary,the proposed density in the Squires Lane area is being eliminated,the number of proposed cabins is
being reduced from 20 to 13 and accessory dwelling units are being eliminated completely.
With this reduction in density,the Affordable Housing Guidelines obligation created by the amendment is reduced
to 10 local resident housing units which is 25%of the proposed new dwelling units. The previous proposal was for
12 local resident housing units. The Housing Department has reviewed this new calculation and agrees with the
amount of affordable units being proposed.
Brush Creek Road
The Applicant is proposing the following improvements to Brush Creek Road:
1. Roadway Striping: The roadway today contains only a center stripe dividing the two lanes. One of the
safety related concerns on this roadway is the lack of lane edge striping on both sides of the roadway. The
lack of the side stripe is most notable at night when it becomes very difficult to see the edge of the roadway
on this largely unlighted roadway. The Applicant proposes to complete or fund the initial striping of the
lane edge in both directions from Sylvan Lane Road to the second entrance into Frost Creek. This is about
13.5 miles of striping. We believe this alone will have a significant impact on roadway safety and also act
to reduce the speeds of vehicles on the roadway by making the roadway appear or feel more narrow.
Narrowing lane widths has proven to reduce vehicle speed. It's been documented that the level of speed,
nearly 10 mph beyond the posted speed limit,is high on this roadway.
2. Vehicular Pullouts: One of the safety complaints of this roadway is the inability for a slow moving
vehicle to move off of the road safely to allow others to pass. You see these types of pullouts throughout
the State and especially in areas where there are vehicles pulling trailers on their way to a State Park or
Federal Lands(campers). The Applicant is proposing to construct two pullout areas (one in each direction)
within 3 years of obtaining PUD approval. The pullout areas would be located approximately 1,000' east
of Hardscrabble property on land owned by the Applicant. The pullouts are generally 350' in length each
per AASHTO requirements. The pullout areas would be paved to County standards(8"base and 4"
asphalt). The Applicant would dedicate the right-of-way for these pull-outs immediately as there is
currently no right-of-way along this portion of Brush Creek Road.
3. Advance Warning Signs: It's notable along this roadway the lack of signs warning motorists of the
presence of bicyclists or sharp curves. The Applicant is proposing$6,000 towards the purchase and
installation of approximately 6 advance warning signs.
II. Staff Analysis of Revised Proposal
Revised Traffic Study:
Following the hearing on December 13, 2016, staff and the Applicant held a series of meetings and discussions,
focused on reaching an agreement on the assumptions and methodology for the project's traffic study. Along with
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the project updates, a revised Traffic Impact Study was also received based on the agreed upon methodology. At
the time of the writing of this staff report update,discussions continue between staff and the Applicant regarding
the findings of the revised study to ensure we have a full understanding.
The revised study did not re-analyze the results of the original study with respect to the impact to intersections
within the Town of Eagle but focused on the impacts to Brush Creek Road. As described in the December hearing,
a number of the intersections within the Town will deteriorate as growth proceeds over the next 20 years to the
point at which improvements will be necessary. It is staff's goal to highlight that both the Town and the County
should consider and plan for these improvements especially when considering developments which will add traffic
to the roadway system within the Town of Eagle.
With the revised traffic study,we are gaining a better picture of the impacts to Brush Creek Road. One aspect
which remains unchanged is that the Level of Service for Brush Creek Road will not deteriorate below a level of B
by the year 2035. Also of note is that the trip generation from this project remains almost unchanged despite the
reduction in density due to the changes in the methodology. The trip generation in the original analysis was 243
vehicles per day,and in the revised study,the trip generation is 234 vehicles per day(a difference of 9 vehicles).
The ongoing discussion is focused on gaining a complete understanding of the actual impact to Brush Creek Road
from this development.
Adequacy of Brush Creek Road:
Also unchanged from the information presented in the December hearing is the staff finding that Brush Creek Road
does not meet the standards to be deemed adequate for either the current traffic or the anticipated traffic in the
future. The concern regarding Brush Creek Road arises from the existing condition and the current traffic load.
The roadway as exists does not meet the applicable standards for a Rural Major Collector which is the classification
of Brush Creek Road as defined by the Eagle County Land Use Regulations. Looking at the forecasted traffic in 20
years,the traffic on Brush Creek is anticipated to exceed all roadway standards as defined in the Land Use
Regulations.
In the letter provided with the Update and Revisions,the Applicant proposed three(3)improvements to Brush
Creek Road as previously described. It is staff's opinion that the proposed improvements do not adequately address
the concerns related to the adequacy of the roadway; however the proposed items may be an improvement over the
existing condition. The items proposed appear to respond to some of the key concerns expressed during review of
this application by staff as well as by the public.
The proposal to add edge lines along Brush Creek Road from the intersection with Sylvan Lake Road to the second
entrance to Frost Creek was originally suggested by the Applicant in hearings as a method to provide traffic
calming in response to concerns raised about speeding. This is a generally accepted method for trying to reduce
speeds although it is unclear how much of a reduction this would accomplish. The Applicant also suggests that the
edge lines will help to identify the edge of the roadway especially at night, and one could infer that this would help
to prevent accidents caused by people driving off the roadway.
Staff has the following concerns with this proposal. The first is that any roadway striping requires ongoing
maintenance. The current maintenance schedule by the County requires re-striping once or twice per year. As
proposed,the cost of maintenance would fall to the County after the initial striping. The striping proposal would
also narrow the already narrow travel lanes. If adding edge lines,one goal would be to maintain the appearance of
a consistent lane width. Due to the varying width of the roadway and without an effort to add width,this would
mean bringing the striping in a short distance from the edge of the asphalt thus narrowing the lanes. This would
have the effect of either pushing vehicles closer to the center of the roadway and oncoming traffic or traffic would
travel on the lines negating the benefit and increasing maintenance. Finally, it is not certain that this would
significantly improve the visibility of the edge of the roadway. While one might expect increased visibility,that
would not be the case if the lines are obscured by debris or snow. Various people have stated that vehicles running
off the road is an issue especially in the winter due to the lack of shoulders and the edge of the road being obscured
by snow. White edge lines would do little to rectify this concern.
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The second proposal is to add two (2)vehicular pullouts on Brush Creek Road to provide room for slow-moving
vehicles to pullover allowing traffic to pass. The pullouts are proposed to be on both sides of Brush Creek Road at
a location about 2-miles from town. The Applicant owns the property on both sides of the road in this location and
is committing to dedicate the right-of-way necessary for the pullouts. The pullouts will be designed and
constructed to meet the applicable County and national standards. The main benefit of the vehicular pullouts is to
provide space for slower vehicles such as recreational vehicles or vehicles pulling trailers to pull over allowing for
following traffic to continue along the roadway unimpeded.
While adding width to the roadway at the location of the pullouts,this proposal does not address the concerns
raised about the narrowness of Brush Creek Road. It is also not clear that this is a beneficial location for this
improvement. Vehicle pullouts are generally recommended on roads with a significant number of trucks or
recreational vehicles and with difficult, steep terrain. This area of Brush Creek Road does not exhibit steep grades,
and slow-moving vehicles have not been discussed as a significant concern. Considering the cyclists known to use
Brush Creek Road,vehicular pullouts could also create additional car/cyclists conflicts in those locations.
The final roadway enhancement proposed by the Applicant is to contribute$6,000 towards the purchase and
installation of additional signage along Brush Creek Road. The proposal cites a lack of signage along the roadway
for advance warning of cyclists or sharp curves. Installation of advanced warning can be beneficial for roadway
users and further review is necessary to determine if additional signage is warranted along Brush Creek Road.
When considering installation of signage along a roadway, it is important to consider the existing signage and
review that proposed locations meet warrants for installation of a new signage. Installing excess signs or signs in
locations where it is not warranted reduces the efficacy of the signage along a roadway. At this time, a review has
not been completed to determine if additional signage is warranted.
Conclusion:
As discussed in the hearing on December 13th,nearly all of the standards for a PUD Amendment are satisfied with
this proposal except for the standards relating to the adequacy of infrastructure because of concerns regarding the
adequacy of Brush Creek Road. Largely due to the existing condition of Brush Creek Road not meeting standards
staff recommended denial of this application. Staff determined that Brush Creek Road does not meet the applicable
standards for the current traffic load, and the traffic is expected to more than double as Frost Creek continues to
build out under the current approval and as background traffic increases. With that in mind, staff was not able to
recommend approval of this application which will add additional traffic to the roadway.
In the interim following the December hearing, staff and the Applicant continued to discuss the project and the
traffic study to reach an agreement about the project's impact. Following those discussions,the update to the plan
proposed measures intended to decrease the impact from the application through reducing the requested units and
by providing improvements to Brush Creek Road.
While the update does decrease the scope of the request,this proposal will still increase the traffic generated by
Frost Creek beyond what can be expected under the current approval. From the revised traffic study provided by
the Applicant,the anticipated traffic is an additional 234 vehicle trips per day, and the total traffic load on Brush
Creek Road in 20 years was calculated to be about 4,000 trips per day(current traffic is about 1,300 trips per day).
The Applicant also proposed three improvements to address some of the concerns raised about Brush Creek Road.
Those improvements are edge line striping,vehicular pullouts, and additional signage. If properly implemented,
the improvements could improve the existing condition of the roadway; however,the roadway would remain
substandard according to the County Regulations and national standards.
DISCUSSION:
Ms.Valdez summarized the revised request. The applicant was requesting an additional 40 single family
residential lots, 8 quest cabins, a reduction in lot sizes on Red Bluffs Way from 3-acres to 0.75 acres, and reduced
lot sizes on Hunters Way from 3-acres to .40 acres. Staff supported the smaller home sizes and the increased safety
measures incorporating the comments of the Great Eagle Fire Protection District.
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Mr.Narracci spoke about the 1041 Permit. At the end of the last meeting in December there were two
issues out of 32 standards. The first was that the State Water Engineer could not confirm that the water to be served
by the Town of Eagle would not injure the water rights of others. Since that time the applicant had succeeded in
getting a letter from the State Engineer indicating that water rights would not be damaged. The remaining item was
the state of Brush Creek Road.
Garett Simon spoke about the time spent on the application and explained that they were trying to mirror
what was happing in resort community demographics. They worked hard on bridging the gap between staff's
concerns and the concerns expressed by the Board.
Dominic Mauriello stated that the applicant had made significant changes and worked closely with staff on
the traffic study. They reduced cabins and eliminated all the density on Squires Lane. The applicant offered a
reasonable amount of improvements to the road for all users which included 13 miles of striping that would result
in slower speeds,pullout areas to prevent unsafe passing, and$6000 for safety signage. If the PUD were approved,
a bike path easement would go into place.The applicant would give$125,000 to the Town of Eagle for future
construction of the bike path. Other benefits included a 40-acre open space parcel. The applicant proposed a real
estate transfer fee with the money going towards wildlife habitat. The applicant was proposing 12 local residents
dwelling units or credits to be purchased. The applicant put in stringent wildfire and fire safety measures. There
was a new traffic impact fee proposed. There was a water plant investment fee proposed to the town as part of the
water agreement; $613,000 would go to the Town of Eagle in order to develop a water plant, 60%paid upfront
upon approval of the PUD. The only issue at this point was Brush Creek Road. The applicant believed that the
level of road improvements that they were proposing along with the traffic impact fees was in balance with what
they were proposing
Ty Ryan, Eagle County Engineer, discussed staff's review of the proposed improvements. The edge line
striping would be about a four inch white line delineating edge of road for Sylvan Lake Road. The striping would
narrow the travel lanes and could be obscured by debris or snow. It was not clear how much the speed would be
reduced. The vehicular pullouts located about two miles from the town would allow for slow moving vehicles to
pull over and provide additional right of way for construction. The improvement would not address overall
concerns and were typically used in areas with steep terrain. The warning signs would warn of possible hazards but
may be ignored if there were too many signs.An analysis would be useful. He spoke about the traffic study and the
trip generation. The daily trip generation was originally calculated at 243 vehicle trips.The impacts to the town
would be minimal. Many intersections would deteriorate and require improvements. Growth was anticipated at
3%per year. Traffic by 2035 could be as over 4,200 trips per day. Staff believed that Brush Creek Road could not
accommodate the additional traffic. Traffic impacts to the Town of Eagle had not been reconciled.The future
improvements still need to be addressed.
Ms.Valdez reviewed the PUD amendment standards and preliminary plan standards. Staff believed the
project was compatible with surrounding uses. Common open space was satisfactory. The applicant complied with
landscaping, signage, off street parking and loading. She presented the boards options.
Commissioner Chandler-Henry clarified that any amendment had to comply with the original PUD
guidelines.
Commissioner McQueeney asked about the trail maintenance.
Mr.Mauriello stated that the applicant would maintain the trial and the language was build into the PUD
guide.
Commissioner McQueeney asked for an explanation of the affordable housing calculation.
Mr.Mauriello stated that under the current regulations the residential use of the property generated the
higher requirement.
Tori Frank with the Eagle County Housing Department explained that if the guest cabins were converted to
residential units the applicant would owe an additional two affordable housing units.
Commissioner Chandler-Henry asked the applicant to explain the guiding principal behind the proposal.
Mr. Simon stated that a significant portion of Frost Creek users were non-residential members which had
driven the demand for the cabin component. From a financial standpoint,they needed a variety of product to be
successful and needed to offer a wider array of opportunities to a greater number of people.
Commissioner Chandler-Henry asked about the total increased density and wondered how people would
live in the Accessory Dwelling Units(ADUs).
Mr.Mauriello explained the concept behind the(ADUs).
Commissioner Chandler-Henry asked when the affordable housing when would be built.
Mr. Simon stated that they would comply with the affordable housing guidelines.
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Commissioner Chandler-Henry wondered if the clubhouse traffic was included in the traffic numbers.
Mr.Ryan stated that the numbers did include clubhouse trips.
Kari Schroeder stated that their numbers were based on weekday traffic. They figured in 40 single family
homes at a weekday rate of 9.52,which equaled 381. They removed 25 ADUs,which subtracted 147 trips per day
and then added 8 rental cabins at the rate of 5.86 trips per day, adding 47, equaled a total of 281.
Commissioner Chandler-Henry asked if the water service agreement with the Town of Eagle was executed.
Mr.Mauriello confirmed that the agreement was fully executed.The agreement was contingent upon the
PUD being approved.
Mr. Garrett stated that if the application was not approved then the agreement would expire.
Chairman Pro-Chandler-Henry opened public comment.
Jeff Brausch,Frost Creek member and regular user of Brush Creek Road, expressed support for the
proposal and supported the road improvements.
Aubrey Carson spoke. Her main concern was the condition of Brush Creek Road. There were safety issues
with the road and the community would be losing safety.
Frank Trevor spoke. He used the road frequently. He supported the road improvements. Frost Creek
members don't drive up and down the road,rather they stay for a few days. He supported the proposal.
Chris Adams expressed concerns for the road and traffic. The road was not safe. He showed pictures of
the road in its current state. He wondered if the 400 club members were included in the total numbers. Just
recently there were cars run off the road. He showed measurements of the road and the emergency vehicles. The
roads were to narrow and the cost to improve the road would be in the millions. He asked the board to deny the
request.
Shirley Zupancic spoke. She lived on Brush Creek and believed there was no way to make the road safe
for more traffic. The proposed improvements were a waste of time and money. She wasn't necessarily opposed to
the Frost Creek PUD amendment but was concerned with the traffic on Brush Creek in the event of emergencies.
Mick Daly spoke. He believed that Frost Creek wasn't what Adam's Rib was for the elite. He believed
that the success of Frost Creek was for everyone. The smaller lots and smaller homes meant increased diversity. He
supported the PUD amendment and the construction of homes, and asked the board to approve the request.
John Shipp spoke. He supported the changes at Frost Creek and believed it was a positive change. As a
resident,population growth was inevitable. The future and proper growth of Eagle and Eagle County relied on
good development and people like Frost Creek.
Kent Meyers spoke. He endorsed the fact that road striping worked and had made positive improvements
to the roads in Cordillera.
James Gilbert,Moser Lane resident spoke. He believed Brush Creek Road was a problem.
Amy Cassidy spoke. She rides her road bike on Brush Creek Road. She believed that some of the safety
issues were exaggerated. The changes being proposed by the applicant would make the road safer for everyone.
She encouraged the board to approve the proposal and encouraged that more cabins be added back in.
Michael Bradshaw spoke. He had no financial interest in Frost Creek but supported environmental friendly
housing. He believed there was poor planning on the county roads. He believed the road was already unsafe; any
temporary improvement would be helpful. The review of this application only exposed an underlining problem that
Eagle County was not owning up to their responsibilities.
Rick Beverage spoke. He supported the applicant's proposal. This was a good opportunity to acquire an
easement for a bike path. He believed the change in the PUD would have minimal impact. The summer traffic was
due to tourism. He believed that safe public roads were the responsibility of the town and county. He supported
the success of Frost Creek.
Kim Bradly,member of Frost Creek and local realtor spoke. She represented two developments now.
Their active inventory now was at an all-time low. She supported the proposal.
Brett Donaldson with Cycle Affect spoke. He supported the road improvements.
Jeff Lutz spoke. He was pro development but Brush Creek Road was dangerous and had always been
substandard.
Rosie Shearwood spoke. She believed that Frost Creek was doing well. The road was the main issue. She
expected that logging would be gearing up in the next few years. She appreciated the efforts on Frost Creek's part
but safety should be considered.
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Scott Turnipseed spoke about the water agreement. The proposal had a lot of great financial implications
to the town.The Town of Eagle could see$350,000 in upfront water tap fees. The bike path was a huge benefit.
Joette Gilbert spoke. The road did not meet adequate traffic safety. The safety of the residents and guests
of Eagle County should be the board's primary goal.
Jack Cornell,Moser Lane resident spoke. He suggested that shoulders be added to Brush Creek Road
rather than building a bike path.
Scott Turnipseed also spoke about the benefits of the 0.2 real estate transfer fee.
Chairman Pro-Chandler-Henry closed public input.
Randy Cohen, Greater Eagle Fire Marshal spoke. Up to this point they had not had any issues with the
road. There was potential and risk but it was difficult to say at this point.
Doug Cupp, Greater Eagle Fire Chief stated that the Fire Marshal had worked closely with the developer.
Commissioner Chandler-Henry asked how the PUD amendment may or may not affect the level of service.
Kari Schroeder stated that Brush Creek Road was a level of service"A". In 2035 the level of service could
be at a level of service`B". Level of service was determined based on lane width, shoulder width,number of
access points and travel speeds. The capacity of Brush Creek Road was in the range of 7200-7500 trips per day.
Mr. Ryan believed the road may be acceptable in 2035 but the infrastructure was in adequate.
Commissioner Chandler-Henry asked about buildout and phasing.
Mr. Simon stated that build out at Frost Creek was unknown but their goal was to accelerate the growth.He
believed buildout was going to be years down the road.
Commissioner McQueeney when the bike path would be built.
Mr. Simon stated that the bike path easement would be granted with the final approval of the PUD.The
road improvements and dedication of the right of way would be immediate and the pull outs would be constructed
within three years. The Town of Eagle was constructing the bike path.Mr. Simon reiterated that their analysis of
traffic was conservative. It assumed that every home built at Frost Creek was a full time resident. Frost Creek
provided a lot of services in house. As businesses owners and homeowners,they understood the concerns of the
neighbors on Brush Creek.
Mr. Ryan stated that staff's concern remained with Brush Creek Road.
Ray Merry,Eagle County Environmental Health Director spoke about the 1041 permit. The water service
agreement and water plan were intact. It was important to take action on the 1041 permit first. There was also a
extensive water monitoring mitigation plan that existed at Frost Creek.
Commissioner McQueeney stated that the public comments were important but the board had to weigh
their decision on where the proposal met the standards. There were 90 units still to be built without the approval so
there was still going to be significant changes to the traffic. Adding 23 more additional homes,was very
incremental and so were the proposed improvements to the road.
Commissioner Chandler-Henry liked the environmental protection efforts. Brush Creek was a
compromised road and the incremental growth probably won't affect it very much and there may be a slight
improvement from the proposed improvements.
Commissioner McQueeney reminded everyone that the county would end up with 10 units of affordable
housing whether on or off the property. The only way to chip away at the road improvement would be to collect
road improvement fees.
Mr.Merry stated that there was a provision in the Land Use Regulations that addressed the need for a
Special Use Permit in the event there was not a 1040. As a matter of routine nature,the applicant requested a
waiver of the Special Use Permit.
Ms. Valdez stated that there were 10 conditions of approval. The 1041 had the standard condition.
Ms. Oliver stated that the resolution would be on the agenda in a couple weeks. At that time the conditions
could be reviewed if there any questions.
Commissioner McQueeney moved that the Eagle County Permit Authority approve File No. 1041-5943,
waiving the requirement for Special Use Review Permit in accordance with Eagle County Land Use Regulations 3-
310 (I.), and incorporating the following condition:
1. That except as otherwise modified by the Permit, all material representations of the Applicant in this
permit application, correspondence, and at all public meetings shall be adhered to and considered
conditions of approval,unless otherwise amended by other conditions.
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Commissioner Chandler-Henry seconded the motion. Of the two voting Commissioners,the vote was
declared unanimous.
Commissioner McQueeney moved to approve File No.PDA-5941, incorporating staff's findings and
staff's conditions,because the applicant, as conditioned,meets all of the standards for approval of an amendment to
a planned unit development.
Commissioner Chandler-Henry seconded the motion. Of the two voting Commissioners,the vote was
declared unanimous.
10. 1041-5943 Frost Creek and Salt Creek Planned Unit Development 1041 Permit
Bob Narracci,Planning
BCP-ARR,LLC,Applicant
Dominic Mauriello,Representative
Note: Tabled from July 26,August 2,August 23,October 16,and December 13,2016
Action: This 1041 Permit, in support of the companion PUD Amendment application,
proposes to amend the water service agreements with the town to shift more
water taps from the Upper and Lower Ranch properties to the Frost Creek
property. If the town approves this shift of water taps,then the total EQR
remaining on the Upper and Lower Ranch property will be 64 EQR.
Location: Brush Creek Road, Eagle area
FILE NO.: 1041-5943
TITLE: Frost Creek Planned Unit Development 1041 Permit
LOCATION: Seven(7)miles southeast of the Town of Eagle on Brush Creek Road
APPLICANT: BCP-ARR,LLC
REPRESENTATIVE: Dominic Mauriello,Mauriello Planning Group
STAFF CONTACT: Bob Narracci,Community Development Director
Ray Merry,Director of Environmental Health
REQUEST: 1041 Permit to allow
RECOMMENDATION: Denial
1. EXECUTIVE SUMMARY
The existing Adam's Rib Frost Creek& Salt Creek Planned Unit Development and 1041 approvals allow 98 single-
family residences, 26 accessory dwelling units, 5 guest cabins including a golf course,clubhouse and ancillary
support facilities. On the Salt Creek portion of the property, equestrian facilities and one single family residence
are presently approved.
Through the companion Planned Unit Development Amendment application(PDA-5941)the applicant is seeking
approval to add 45 additional single-family residential lots to the 98 already allowed. The proposal also includes
increasing the number of allowable guest cabins by 15 cabins,thereby bringing the total from five that are presently
allowed and existing,to a total of 20. The applicant is proposing restrictions on maximum residence size
throughout the PUD; and most restrictive on the 45 newly proposed lots. The proposed 15 new guest cabins are to
be 2,500 square feet each. The existing, approved guest cabins are limited to 1,000 square feet each per the existing
PUD.
Wastewater is provided through on-site wastewater treatment systems(OWTS)designed to accomplish nitrogen
removal with the responsibility of installation,monitoring repair or replacement bestowed upon the HOA,as
specified in the PUD Guide for residential uses with a state-approved central wastewater treatment system serving
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the clubhouse and existing guest cabins. No changes are proposed to the current program involving wastewater
treatment systems except for the technology being used to accomplish nitrogen removal.
Water service to the Frost Creek and Salt Creek property is provided by the Town of Eagle. The Town is to also
provide water service to additional property in the Brush Creek Valley owned by the applicant, and commonly
known as the Adam's Rib Upper and Lower Ranch properties. There are two separate agreements with the Town,
one for the Upper and Lower Ranch property and another for the Frost Creek/Salt Creek properties. In 2004,
when the PUD was amended to shift residential density from Salt Creek to Frost Creek to accommodate increases
to the overall allowable density on the Frost Creek property,the owner of the subject property at the time(Kummer
Development)and the Town amended the current agreements.
The result of the water service agreements in 2004 was that the Frost Creek property, excluding Salt Creek,was
entitled to 121 EQR(Equivalent Residential Units)to be utilized on 97 single family residential lots(97 EQR), 5
guest cabins(4 EQR), and 25 accessory dwelling units(20 EQR). The Upper and Lower Ranch properties,
including Salt Creek,will consist of a total of 114 EQR served by the Town. The agreement contains a provision
that the Upper and Lower Ranch properties can be annexed into the Town and developed at that density.
Through this proposed 1041 Permit, in support of the companion PUD Amendment application,the Applicant
proposes to amend the water service agreements with the Town to shift more water taps from the Upper and Lower
Ranch properties to the Frost Creek property. If the Town approves this shift of water taps,then the total EQR
remaining on the Upper and Lower Ranch property will be 64 EQR.
Since the water service agreement is solely between the Town and the Applicant, the agreement could be modified
at any time in the future to award additional water service taps to the Upper and Lower Ranch Properties,
including Salt Creek and as such, voiding an argument that no new density is being created via the companion
PUD Amendment application by shifting water taps from one area in the Brush Creek Valley to another.
It is important to note that when this report was originally prepared, the water service agreement between the
Town and the Applicant had not been been agreed upon by either the Town or the Developer, thereby making it
inappropriate and unusual to satisfy the associated 1041 Permit approval criteria. As such, this was one of the
reasons Staff could not support approval of this application. A copy of the agreed upon, but not yet ratified by the
Town, amended water service agreement was received by County Staff on Friday, December 2nd at approximately
12:00 p.m. Receipt of this information necessitated immediate update of the staff reports, in order to achieve the
deadline for the paperless, BoCC Agenda system; which was the same day. We did not have time available to re-
refer the Water Service Agreement back to the State Engineer for determination of injury to property(water)rights.
The Eagle County Permit Authority may use whatever evidence it has received during the public hearing process to
render approval criterion satisfied or not. As stated in Chapter 6, Eagle County Guidelines and Regulations for
Matters of State Interest, Section 6.04.01 of the Eagle County Land Use Regulations, "If a project does not comply
with any one or more of the approval criteria, the permit shall be denied or approved with conditions." It is
inappropriate to condition an approval criterion without sufficient supporting evidence having been received by the
Permit Authority to make the approval criterion positive.
2. CHRONOLOGY
2003: The original Adam's Rib Frost Creek& Salt Creek PUD was approved, allowing a gated, 18-hole,
residential golf course community with 60 single family lots and up to 30 ADU's on approximately
1,106.97 acre Frost Creek property and 21 additional single family residential lots on the 520.348 acre Salt Creek
property.
2005: The Board of County Commissioners approved an amendment of the PUD Guided to: 1) Transfer of 20
out of the 21 previously approved Salt Creek Single-Family Residential Lots to the Frost Creek property; 2)Added
16 additional Single-Family Residential Lots for total of 97 Lots; 3) Encompassed an existing home and property,
located at 6902 Brush Creek Road,within the PUD boundary; 4) Utilized five of the previously approved 30
Accessory Dwelling Units as 'Guest Cottages'located near the clubhouse; 5) Added one Accessory Dwelling Unit
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to the Single-Family Residential Lot on the Salt Creek property; 6) Allowed Equestrian Facilities, Shooting Club
and Training Center on the Salt Creek property.
2008: Special Use Permit was approved,to memorialize the Salt Creek equestrian facilities and associated
residences.
December 2015: Application for this proposed 1041 Permit received by Eagle County. Applicant notified that
absent the approved water service agreement it is unworkable to satisfy the 1041 Permit criteria.
April 2016: Letter dated April 19,2016(attached)received from Garfield&Hecht, legal counsel for the Town
of Eagle, indicating that the Water Service Agreements will not be done until the later part of May or into June,but
to not hold up the land use application review and hearing process because of this.
July 2016: Eagle County Planning Commission unanimously recommended denial of the PUD Amendment
application.
3. REFERRAL RESPONSES
This 1041 Permit application was referred to the following departments and agencies with request for comment:
• Eagle County Engineering Department
• Eagle County Attorney's Office
• Eagle County Planning Commission
• Eagle County Sheriff's Office
• Colorado State Department of Environmental Health(Air Quality and Water Quality Divisions)
• Colorado Parks and Wildlife
• Colorado Geological Survey
• Colorado Historical Society
• Colorado Division of Water Resources
• Colorado River District
• Colorado Water Conservation Board
• United States Forest Service
• Army Corps of Engineers
• Natural Resource Conservation Service
• Northwest Colorado Council of Governments
• Roaring Fork Transportation Authority
• Town of Eagle
As of this writing,the following responses have been received:
Engineering Department: Please reference the attached letter dated May 4,2016,which sets forth all Engineering
comments regarding the entire Project proposal; both the PUD Amendment and the 1041 Permit. The Engineering
focus is primarily on the PUD Amendment; however includes comments pertaining to the 1041 Permit as well;
namely potential impacts upon riparian/wetland areas due to road/drive crossings.
Town of Eagle: In the attached letter dated February 19, 2016,the Town set forth the following concerns:
1. The preparation of an Amended Frost Creek Water Service Contract to serve this additional density and
perhaps more density in the future-the Town is currently working on drafts but has not even entered into
negotiations with the Applicant at this time. Therefore,there currently is no agreement in place for potable
water service for the proposed additional units;
2. Improvements required to the Town's current water system infrastructure serving the Frost Creek PUD to
serve the additional density. The Town has engaged a consultant to provide an analysis of what may be
required to ensure adequate pressure and water service for this increased density but has not yet received
this report and,related to item 1 above, cannot finalize an amended water service agreement without it;
3. Bike path connection to the Town of Eagle;
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4. Traffic Impacts -the only access to this PUD is through the Town and on its roads.
5. The Town does not object to the commencement of public review of this application provided that no final
action of approval is provided by Eagle County until the Town and the Applicant have executed a Second
Amendment to the Frost Creek Water Service Agreement.
Town of Eagle: In the attached letter dated April 19,2016 from Garfield&Hecht,P.C., legal counsel for the
Town,prepared by Mary Elizabeth Geiger,"This office represents the Town of Eagle for water matters. As you are
aware,the Town is the domestic water service provider for the Frost Creek/Salt Creek PUD pursuant to various
agreements with BCP-ARR's predecessors (which were then acquired by BCP-ARR). BCP-ARR approached the
Town with regard to its application to the County to amend the PUD to increase density, and we have been working
closely with the representatives of BCP-ARR,LLC with regard to the amendments to the Town's Water Service
Agreements to provide domestic water service for the amended Frost Creek/Salt Creek PUD and adjacent property.
However, since the Town can only negotiate and act through the Town Board, and since we are amending and
restating the existing Water Service Agreements because many provisions are no longer applicable,these
negotiations will likely not be completed and new agreements signed until the later part of May or into June.
Therefore,rather than hold up the land use application review process for BCP-ARR,the Town would support the
County commencing its review and processing of this PUD Amendment application while these water service
negotiations are ongoing, and then condition any County approval thereof upon the successful execution of an
Amended and Restated Water Service Agreement to serve the amended Frost Creek/Salt Creek PUD".
Town of Eagle: In the attached letter dated December 1,2016 from Garfield&Hecht,P.C., legal counsel for the
Town,prepared by Mary Elizabeth Geiger,"This office represents the Town of Eagle for water matters. As you are
aware,the Town is the domestic water service provider for the Frost Creek/Salt Creek PUD pursuant to various
agreements with BCP-ARR's predecessors (which were then acquired by BCP-ARR). It is my understanding that
the above applications will be considered by the Board of County Commissioners("BOCC") on December 13,
2016.
BCP-ARR and the Town have been working together for nearly a year to amend the existing Water Service
Agreement by which the Town provides domestic water service to the Frost Creek/Salt Creek PUD in order to
allow for the Town to provide service to the proposed amended PUD. The Town and BCP-ARR have reached an
agreement which has been fully executed and will be ratified by the Town at its meeting on December 13, 2016 (the
Board of Trustees had previously authorized the Mayor to execute this agreement on behalf of the Town). A copy
of this agreement is attached hereto for your review."
Eagle River Watershed Council: The following comments have been provided for consideration during the
review process:
"Generally,the Watershed Council staff found no concerns with the application. The Applicant references the
existing water quality monitoring network and sampling and analysis plan implemented annually in the PUD in
coordination with Eagle County. The Watershed Council appreciates the Applicant's continued commitment to
assessing the impact of development activities on local surface and groundwater quality. Nonetheless,the County
should work with the Applicant to revisit specific details of the water quality monitoring program to ensure that the
sampling locations,parameter lists, and sampling frequency are sufficient and likely to capture any water quality
changes associated with the amended development plan. Eagle River Watershed Council is available to work with
County staff and the Applicant in this regard.
While limited development at this location has not previously indicated significant impact to downstream water
quality,the Watershed Council suggest that ongoing development and redevelopment activities adjacent to streams
and rivers throughout the County can contribute to the incremental degradation of downstream water quality.
Therefore,the Watershed Council believes that the Frost/Salt Creek water quality monitoring program represents
an important model for future PUD approval processes. Such monitoring programs can greatly assist the County in
understanding how certain patterns of development may assist or obstruct meeting environmental stewardship
goals.
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As water conservation is a growing concern,Eagle River Watershed Council also sees an opportunity for the
County to work with the Applicant to incorporate conservation measures into the plan. This would support Eagle
County's objective to `protect surface and groundwater quality and quantity'.
Eagle River Watershed Council appreciates the opportunity to provide Eagle County with comments on this
proposal and hopes to remain involved in the process to ensure that proposed activities do not negatively impact the
character, condition, or function of local waterways."
Colorado Division of Water Resources: In the attached letter dated February 19,2016,the State Engineer
indicated that, "Water use estimates were not provided. A water service agreement was made between the
developer(Kummer Development), and the Town in 2002 for the Brush Creek properties also referred to as Salt
Creek,Upper Ranch and Lower Ranch and Ridgeway properties. A second water service agreement was made in
2004 for the Frost Creek property and the agreements were amended in 2004 to transfer 21 EQR's from the Brush
Creek properties to Frost Creek. The 2004 agreements currently allow for 121 EQR's in the Frost Creek
development which translates to 97 single family dwellings, 5 guest cabins and 25 ADU's,based on 1 EQR per
single family dwelling an 0.8 EQR per both a guest cabin and an ADU. The applicant indicated that they are
pursuing an amendment to the agreements with the Town to reduce the number of EQR's for the Brush Creek
properties from 114 to 55 and transfer the 59 EQR's to Frost Creek to allow for the increase in single family
dwellings and guest cabins. As of the date of this referral,it does not appear that the amended agreements have
been signed.
Furthermore,pursuant to CRS 30-28-136(1)(h)(II), a municipality or quasi-municipality is required to file a report
with the county and the State Engineer documenting the amount of water which can be supplied to the proposed
development without causing injury to existing water rights. A report of this nature was not included. See the
Guidelines for Subdivision Water Supply Plan Reports(online at
http://water.state.co.us/DWRIPub/Documents/memo subdivisions.pdf) for the necessary information. In addition,
since this proposal also depends on the transfer of EQR's from Brush Creek properties to Frost Creek,the report
should also include the number of lots(if any)that are currently being served in the Brush Creek properties as well
as any future commitments for platted lots within these properties.
Since insufficient information was provided,we cannot comment on the potential for injury to existing water rights
under the provisions of CRS 30-28-136(1)(h)(II). If you or the applicant has any questions concerning this matter,
please contact me for assistance".
Colorado Parks and Wildlife: In the attached letter dated February 16, 2016,offered the following comments:
"The Colorado Division of Parks and Wildlife(CPW)appreciate the opportunity to review and provide
recommendations and comments on this proposal. The proposal requests an increase in density of homes from 98
to 142, a 44%increase and guest cabins from 5 to 20, a 300%increase. This increase in numbers of units will have
a direct, on ground impact with increased disturbance to wildlife habitat. More impactful disturbances to wildlife
will occur with the associated increase in human habitation and activity on the PUD and adjacent federal lands with
the increase in homes and cabins being proposed,the indirect impacts. The application offers few management or
mitigation strategies to offset or minimize disturbance to wildlife or wildlife habitat from either the direct or
indirect influences.
This proposal is designated to occur partially within and adjacent to deer and elk winter range. The area also
encompasses wetlands and riparian area habitat types. This habitat type supports a greater diversity and number of
wildlife species than any other habitat type found in Colorado.
Both deer and elk use the native hillsides adjacent to the area designated for increased density. Hillsides and low
bench areas adjacent to the proposal are recommended to be left in a native vegetative state. The deer and elk use
the hillside for feeding,resting and thermal cover. These hillsides also are areas that produce large mast crops,
berries and acorns that black bears will use and seek out.
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The protection and enhancement of the existing riparian/wetland areas will provide for a diversity of wildlife
species including birds, small mammals,reptiles and amphibians. The existing fishery would also benefit from this
type of management. The creation of more designated open space in and around this habitat type may or may not
be beneficial to wildlife. This will depend on how the open space is managed and what uses are or are not allowed.
Open space that receives high human use has a relatively low value to wildlife. Current PUD guidelines, setbacks
from riparian and wetland areas,and designations by other regulatory agencies already protect this habitat, so the
mitigation of more open space in and along riparian and wetlands areas that is being offered already probably
exists.
The Project does not appear to completely meet the intent of Eagle County's Comprehensive Plan:
3.73. Development Impacts
Policies:
a. Where disturbances to wildlife habitat cannot be avoided, development should be required to fully mitigate
potential negative impacts.
The Comprehensive Plan recognizes that impacts to wildlife from development and human activity cannot always
be fully mitigated. Existing critical wildlife habitats in Eagle County should be identified and preserved, and
residential,commercial and recreational development that removes critical habitat,or diminished the use by
wildlife of these habitats, should not be allowed. While the direct impacts from this proposed density increase are
fairly limited the indirect impacts are substantially increased. The proposal fails to offer mitigation strategies to
address these impacts.
Strategies that would help offset the increase in human activity and loss of habitat in the area include:
Seasonal use restriction in and around sensitive habitats need to be implemented. The use of important seasonal
habitats by humans can create a negative impact to wildlife. Areas that require seasonal closures to human activity
include wither range,migration corridors,production areas,nesting areas or other critical habitats. Regulating or
restricting access to the adjacent federal lands becomes paramount during critical time periods,winter. Active
signage and enforcement of these closures is critical and must be assumed by the HOA.
• Winter range closures should be closed to human activity from December 1 until April 30th.
• Riparian and wetland areas should be closed to human activity from March 1 to July 1 for the breeding,
nesting, and rearing of the wildlife species associated with this habitat.
In addition,new management of the PUD has an opportunity to implement a mitigation strategy that will provide
for enhancement projects in perpetuity. A Wildlife Mitigation Fund could be established and managed on a
cooperative basis by the developers,the HOA, interested homeowners and the CPW. This fund would then be
managed,with money staying under the developer's control and being stipulated specifically for wildlife projects.
These projects could be diverse including projects for improving upland habitat,riparian and wetlands, or the
fishery. Current models exist with Eagle Ranch being the prototype that has generated over$1 million dollars and
has reinvested this money into wildlife projects and enhancement for the PUD.
Originally, mitigation monies around$13,000 were paid for the treatment of adjacent habitat on federal lands for
mitigation for the proposed direct impacts,actual acreage impacted. This amount was determined from an accepted
formula based on habitat. This money was only enough for a single treatment. The impacts from the original PUD
and this project will continue into perpetuity. Negative impacts to wildlife and wildlife habitat have not been fully
mitigated and a mitigation strategy has not been proposed. Eagle County's Comprehensive Plan designates that full
mitigation of potential impacts be addressed. The proposal with increase in density of homes and the associated
human activity will exacerbate these impacts.
The potential exists for this proposal to benefit local wildlife and wildlife habitat with new management strategies.
Without the creation and adoption of new strategies to offset impacts,local wildlife populations will be impacted
by this proposal."
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(The applicant is proposing to implement a real estate transfer fee on the sale of lots within Frost and Salt Creek
for the purpose of providing wildlife habitat improvements within the PUD, in perpetuity. At the Eagle County
Planning Commission hearing, Craig Wescoatt, with CPW, testified in support of the proposed real estate transfer
fee as long as it is in perpetuity and includes resales as well- i.e.: an ongoing funding stream for wildlife and
wildlife habitat improvement both in the Frost Creek PUD and adjacent federal lands.)
Colorado Department of Public Health and Environment: In the attached email dated February 3, 2016,the
CDPHE notes that land development construction activities(earth moving)that are greater than 25 acres or more
than six months in duration require an Air Pollutant Emissions Notice(APEN) from the Air Pollution Control
Division and may be required to obtain an air permit depending on estimated emissions. In addition, a start-up
notice must be submitted thirty days prior to beginning a land development project. Also,CDPHE recommends
that the applicant comply with all state and federal environmental rules and regulations. This may require obtaining
a permit for certain regulated activities before emitting or discharging a pollutant into the air or water, dispose of
hazardous waste or engaging in certain regulated activities.
U.S.Army Corps of Engineers: In the attached email dated March 14, 2016,the following was provided,"The
Corps of Engineers'jurisdiction within the study area is under the authority of Section 404 of the Clean Water Act
for the discharge of dredged or fill material into waters of the United States. Waters of the United States include,
but are not limited to,rivers,perennial or intermittent streams, lakes,ponds,wetlands,vernal pools,marshes,wet
meadows, and seeps. Project features that result in the discharge of dredged or fill material into waters of the
United States will require Department of the Army authorization prior to starting work.
To ascertain the extent of waters on the project site,the applicant should prepare a wetland delineation, in
accordance with the"Minimum Standards for Acceptance of Preliminary Wetlands Delineations"on our website at
the address below, and submit it to this office for verification. A list of consultants that prepare wetland
delineations and permit application documents is also available on our website at the same location.
The range of alternatives considered for this project should include alternatives that avoid impacts to wetlands or
other waters of the United States. Every effort should be made to avoid project features which require the
discharge of dredged or fill material into waters of the United States. In the event it can be clearly demonstrated
there are no practicable alternative to filling waters of the United States,mitigation plans should be developed to
compensate for the unavoidable losses resulting from project implementation".
(Watershed Environmental Consultants, Inc. conducted a wetland delineation of the four development areas
(Southern Parcels, Red Bluffs Way, Hunters Way, Squires Lane) in accordance with the USACE standards. All
impacts to wetlands and other waters of the United States have been avoided with one potential exception for a
single driveway access in the Hunters Way area (between proposed Lots 42 and 43). No engineered details for this
driveway access are available at this time for review. If the driveway can be accommodated without impacting
wetlands, such as in the case of a span, no 404 permit is required for the project. If impacts to wetlands are
anticipated, a 404 permit will be obtained prior to construction.)
Eagle County Planning Commission: Following the public hearing before the Eagle County Planning
Commission for the companion PUD Amendment application on July 6,2016,the Eagle County Planning
Commissioners indicated that:
• The proposal is inconsistent with the Master Plan;
• Land use patterns in Brush Creek should not be changing,
• No current or future sector of the local economy would be significantly degraded as a result of the project;
• The project will have additional traffic impacts compromising access to public recreational areas accessed
via Brush Creek Road.
• The proposal does reflect principles of resource conservation, energy efficiency and recycling/reuse.
• The proposed project's impacts would be no greater than any other similar project; however,will introduce
more traffic and smaller homes will impact the local economy less.
• This is leapfrog development; it's not meeting demand, it is creating it.
• The Golf Course is visual open space.
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• Overall this 1041 Permit application is not ripe because there is no formalized water service agreement.
• ECPC's concerns are primarily with the companion PUD Amendment proposal to increase density.
4. FINDINGS AND RECOMMENDATIONS
A. Pursuant to Eagle County Land Use Regulations, Chapter VI,Section 6.04.01,Permit Application
Approval Criteria for Matters of State Interest, and as more specifically described in the application
materials,the following analysis is provided. The Approval Criteria is numbered and indicated in bold
font. A summary response is provided with the recommendation indicated in the findings box.
A Permit to conduct a designated activity of state interest or to engage in development in a designated area
of state interest shall be approved if the Project complies with the following general criteria and any
additional applicable criteria in Sections 6.04.02 or 6.04.03. If the Project does not comply with any one or
more of these criteria,the Permit shall be denied or approved with conditions. In determining whether the
Project complies with these criteria, or if conditions should be imposed,the Permit Authority may utilize
the considerations set forth in Chapter VI,Appendix `A' of the Eagle County Land Use Regulations.
(1) Documentation that prior to site disturbance for the Project the applicant will have obtained all
necessary property rights,permits and approvals. The Board may, at its discretion,defer
making a final decision on the application until outstanding property rights,permits and
approvals are obtained.
Per the application, "All permits and approvals will be obtained by final plat for the amendment areas
including the following to implement the proposed amendments."
Federal Permits:
• Army Corps of Engineers 404 Permit as necessary for two minor ditch crossings.
State Permits and Approvals:
• Stormwater Discharge Permit
Eagle County Permits and Approvals:
• Approval of this 1041 Permit application.
• Approval of the companion PUD Amendment application.
• Final Plat approval.
• Grading Permit(s).
• Building Permit(s).
Town of Eagle:
• Approved, executed Water Service Agreement allotting the additional water service taps to serve
the proposed additional development density.
Staff concurs that the above itemized list of permits and approvals are required prior to site
disturbance.
(2) The Project will not impair property rights held by others.
Per the application: "The project will not impair the property rights held by others as all property being
amended is within the control of the owners or the Homeowner's Association. The replatting is
occurring within current platted lots held in the same ownership. The proposed changes have no
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impact upon the water rights held by the applicant. All new units will be served by the Town of Eagle
for water,which taps or EQR are already held by the applicant. The Water Service Agreement
includes copies of all water rights and agreements for water service. Any ditches that convey water to
other parties are not being altered by the proposal."
The Town and the Developer have come to agreement regarding the Water Service Agreement. This
Agreement is scheduled to be formalized(ratified) by the Town on December 13, 2016. However,per
the State Engineer's original referral response, the Town of Eagle has not filed a report with the
county and the State Engineer documenting the amount of water which can be supplied to the proposed
development without causing injury to existing water rights; therefore it is not feasible for Staff to make
a determination that the proposed development can occur without causing injury to existing property
(water)rights.
(3) The Project is consistent with relevant provisions of applicable land use and water quality plans.
Per the application: "A complete review of the project's compliance with applicable land use plans is
provided in the PUD submittal. The project is consistent with the relevant provisions of the applicable
land use and water quality plans as follows:
Eagle River Watershed Plan
Water Quantity Goal: Streams, rivers, lakes and reservoirs in the watershed are managed and cared
for in a manner that insures adequate amounts of water for domestic, agricultural, recreational and
ecological needs at all times of the year.
Objective 2.1: Manage water storage, water diversions and water releases within the Eagle River
Watershed in a manner that sustains or enhances stream health and recreational uses.
Applicant's Response-The project has adequate water rights commensurate with the amended PUD
development proposed to ensure that Brush Creek is managed in a manner consistent with demands for
domestic, irrigation and other needs created by the development. Municipal water is provided for
through an existing agreement with the Town of Eagle; depletions to Brush Creek were contemplated
as part of that agreement and legal adjudication.
Objective 2.2: Minimize and/or mitigate adverse impacts to aquatic habitat and stream health from
existing development and future growth.
Water Quality Goal: Water in the Eagle River and its tributary streams is of the highest quality,
providing excellent drinking source water and supporting healthy and self-sustaining trout populations
as indicators of a healthy watershed.
Land Use Goal: Land uses in Eagle County are located, designed, occupied and operated in a manner
that minimizes impacts to water quality and quantity in the Eagle River and its tributary streams.
Applicant's Response: The project does not propose new development within the floodplain,and the
only new impact to wetlands or waters of the US includes a single driveway in the Hunters Way area.
No other impacts to wetlands or waters of the U.S. are proposed. Wetlands monitoring was included
as part of the Water Quality Monitoring and Mitigation Plan approved with the original PUD project.
No new development is proposed within the existing riparian area setback,which in most cases is more
restrictive than the 50-foot wetlands setback. Additionally, approximately 88%of Brush Creek
riparian habitat and 75%of Frost Creek riparian habitat is within designated open space,thereby
ensuring development resulting from approval of the PUD Amendment minimizes impacts to both
tributary streams.
Eagle County Comprehensive Plan
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3.6 Water Resources Goal: Source water in Eagle County is protected, and contributors of surface and
groundwater pollution are identified and eliminated to the fullest extent possible.
3.6.2.Water Quantity Policies:
a. The long-term viability of both ground and surface water sources should be protected.
b. Water conservation efforts by all water users in Eagle County should be implemented.
Applicant's Response-As a result of concerns regarding potential water quality impacts to surface and
groundwater, a Water Quality Monitoring and Management Plan for the Frost Creek PUD was
developed by Wright Water Engineers. The Plan addresses water quality monitoring pre,during and
post construction phases of the project.
As detailed in the Environmental Impact Summary Report, approval of the PUD Amendment will
continue to be subject to the periodic monitoring, and potential amendments to the Plan might include
additional sampling locations to reflect the four new development areas to ensure that water resources
remain protected.
2012 Regional Water Quality Management Plan(the 208 Plan)
Policy 1: Protect and Enhance Water Quality. The surface and groundwaters of the region shall be
protected to minimize degradation of existing water quality and maintain existing and designated uses
of those waters; waters not currently supporting designated uses shall be restored as soon as possible.
Policy 2: Water Use and Development. The project developer shall mitigate the impacts to water
quality and the aquatic environment caused by water supply projects.
Policy 3: Land Use and Disturbance. Water quality, including wetlands,floodplains, shorelines and
riparian areas must be protected from impacts of land use and development so that significant
degradation of water quality is prevented.
Policy 4: Domestic, Municipal and Industrial Water and Wastewater Treatment Facilities. Decisions
to locate water supplies, wastewater treatment systems and other water and wastewater facilities shall
be made in a manner that protects water quality and the aquatic environment. Where growth and
development requires the need for additional facilities capacity, existing facilities should be expanded
instead of developing new facilities, unless expansion is not feasible because of technical, legal or
political reasons.
Applicant's Response-As outlined herein,the project will continue to protect water quality of Brush
Creek through the Water Quality Monitoring and Management Plan and implementation of water
quality best management practices to ensure that existing designated uses are not affected. Wetlands
and floodplains have been identified and will be delineated in the field with fencing prior to any
construction in order to protect these areas from development impacts so that significant degradation of
water quality is prevented.
Water supply is already provided for by the Town of Eagle so that no duplication of services will be
required. On-site wastewater treatment systems will be located and designed to County permitting
standards to ensure that the highest level of treatment is required for any additional development
resulting from this proposal."
Staff concurs that the project addresses a preponderance of master plan goals,policies, objectives and
implementing strategies, while adhering to Future Land Use Map designations and prescribed uses.
Staff also concurs with the 208 Plan analysis.
(4) The applicant has the necessary expertise and financial capability to develop and operate the
Project consistent with all requirements and conditions.
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Per the application: "The Town of Eagle has the financial capability to operate the water system and
the consultants hired to manage the OWTS onsite are qualified to operate and maintain these systems.
The consultants overseeing the operation and maintenance of the OWTS are licensed engineers and
who carry the proper certifications to manage these facilities. The HOA funds the oversight and
activities of the OWTS facilities gaining these funds through charges to homeowners up-front during
construction and annually in the form of dues to ensure continuous inspection and maintenance.
Changes in management and oversight may occur from time to time but the qualifications of the
consultants will remain those that are licensed engineers who hold proper certifications. OWTS
systems are designed with the oversight of the HOA's consultant all the way through final inspection.
The homeowner pays for the design and installation and the HOA is responsible for long term
operation and maintenance. All new common infrastructure such as roadway extensions and water
mains will be funded entirely by the developer."
Inasmuch as the applicant comments on the Town of Eagle's financial capabilities, staff concurs that
the applicant has the necessary expertise and financial capability to develop and operate the Project
consistent with all requirements and conditions.
(5) The Project is technically and financially feasible.
Per the application: "There is additional capacity in the Town's water system and therefore the project
is technically and financially feasible. An amended water service agreement has been submitted with
this application. Each OWTS is being funded by the homeowner and maintained by the HOA with
funding through fees and dues."
A copy of the agreed upon, but not yet ratified by the Town, amended water service agreement was
received by County Staff on Friday, December 2nd at approximately 12:00 p.m. Receipt of this
information necessitated immediate update of the staff reports, in order to achieve the deadline for the
paperless, BoCC Agenda system; which was the same day. We did not have time available to re-refer
the Water Service Agreement back to the State Engineer for determination of injury to property (water)
rights. The Colorado Division of Water Resources initial referral response states that,
"We have reviewed the above referenced proposed amendment to the Frost Creek
(formerly known as Adam's Rib) and Salt Creek PUD to develop a total of 142 single
family dwellings, 26 accessory dwelling units(ADU), and 20 guest cabins.With this
proposed amendment, in Frost Creek,the number of single family dwellings will
increase from 97 to 141 and the number of guest cabins will increase from 5 to 20.
There appears to be no changes to the number of ADUs in Frost Creek and to the
number of structures for Salt Creek(1 single family dwelling and 1 ADU).The water
supply is to be provided through the Town of Eagle(Town)and sewage disposal is to
be through individual systems. Water use estimates were not provided.
A water service agreement was made between the developer(Kummer Development),
and the Town in 2002 for the Brush Creek properties also referred to as Salt Creek,
Upper Ranch and Lower Ranch and Ridgeway properties. A second water service
agreement was made in 2004 for the Frost Creek property and the agreements were
amended in 2004 to transfer 21 EQRs from the Brush Creek properties to Frost Creek.
The 2004 agreements currently allow for 121 EQRs in the Frost Creek development
which translates to 97 single family dwellings, 5 guest cabins and 25 ADUs,based on 1
EQR per single family dwelling and 0.8 EQR per both a guest cabin and an ADU.The
applicant indicated that they are pursuing an amendment to the agreements with the
Town to reduce the number of EQRs for the Brush Creek properties from 114 to 55 and
transfer the 59 EQRs to Frost Creek to allow for the increase in single family dwellings
and guest cabins. As of the date of this referral, it does not appear that the amended
agreements have been signed.
Furthermore,pursuant to CRS 30-28-136(1)(h)(II), a municipality or quasi-
municipality is required to file a report with the county and the State Engineer
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documenting the amount of water which can be supplied to the proposed development
without causing injury to existing water rights. A report of this nature was not
included. See the Guidelines for Subdivision Water Supply Plan Reports(online at
http://water.state.co.us/DWRIPub/Documents/memo_subdivisions.pdf) for the
necessary information.
In addition, since this proposal also depends on the transfer of EQRs from Brush Creek
properties to Frost Creek,the report should also include the number of lots(if any)that
are currently being served in the Brush Creek properties as well as any future
commitments for platted lots within those properties.
Since insufficient information was provided,we cannot comment on the potential
for injury to existing water rights under the provisions of CRS 30-28-136(1)(h)(II).
If you or the applicant has any questions concerning this matter,please contact me
for assistance".
The Town and the Developer have reached agreement on the provisions of the Water Service
Agreement, and this Agreement is to be executed by the Town on December 13, 2016. However; per
the State Engineer, the Town of Eagle has not filed a report with the county and the State Engineer
documenting the amount of water which can be supplied to the proposed development without causing
injury to existing property (water)rights. As such, it is not feasible for Staff to make a determination
that the proposed development can occur without causing injury to existing property(water)rights, in
turn, the Project may also be technically infeasible.
(6) The Project is not subject to significant risk from natural hazards.
Per the application: "As provided in the original development application,Frost Creek is underlain by
the Eagle Valley evaporite formation,which can be soluble under the correct hydrologic conditions.
As the original Geologic Site Assessment prepared by HP Geotech states: `The potential sinkhole
hazard on this parcel does not appear to be any greater than that present in the Town of Eagle, or most
parts of Eagle County where the Eagle Valley evaporite is present. Additionally, since the OWTS are
all located below grade they are generally protected from most hazards. All improvements lie outside
of the 100 year floodplain and therefore are protected from a 100 year flood event'. The applicant has
agreed to additional measures recommended to address fire and wildfire. New homes have square
footage triggers established to make them more fire resistant. These standards are included in the PUD
Guide and the Design Guidelines. Both the Greater Eagle Fire Protection District and the County
Wildfire Mitigation Manager have been satisfied with the proposed amendments."
Staff concurs with the Applicant's assessment. The Colorado Geological Survey did not respond to the
referral for this application or the companion PUD Amendment application; however, the property is
not located in any geologic hazard areas as delineated within the Eagle County Geologic Hazard Maps
and based on a preliminary analysis for planning purposes there are no geologic conditions that would
preclude development of the proposed PUD area.
(7) The Project will not have a significant adverse effect on land use patterns.
Per the application: "The proposed increase in density is to occur within already platted lots within the
subdivision. The development potential(residential square footage)of the lots has been decreased over
what was previously allowed. Additional open space parcels have been created from what was
previously residentially platted lands. The general pattern of development will remain unchanged but
the number of structures will increase in number while decreasing in overall mass. As a result,the
project will not have an adverse effect on land use patterns."
Staff concurs that the Project will not have a significant adverse effect on land use patterns. The Eagle
County Planning Commission indicated that the proposal is leapfrog development in that it is not
meeting demand, it is creating it.
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(8) The Project will not have a significant adverse effect on the capability of local governments
affected by the Project to provide services,or exceed the capacity of service delivery systems.
Per the application: "The project is within an already developed subdivision,with existing homes
nearby. The project will not adversely affect the capability of local governments to provide services as
the project still remains very low density. Further,the Town of Eagle and the Greater Eagle FPD are
provided with significant revenues to help offset the expense of providing services. As evidenced by
the traffic report provided,there is very limited new traffic generated by the amendment. All traffic
generated by Frost Creek is less than 2%of the traffic on Brush Creek Road at buildout. Further,the
original developer made roadway improvements an overlaid 6-miles of the roadway after major
development work was completed. This extended the life of this roadway significantly and in the 10
years since,there has been little traffic from Frost Creek impacting the roadway. Additionally, each
home developed is required to pay road impact fees. Impact fees offset the financial impacts to the
government and the community. Additional density typically generates the need for more County
services such as law enforcement,health and human services, and school impacts. Certainly there will
be some impact but these services are generally offset by taxes paid by the owners. In the case of this
project and given the likely composition of homeowners being second homeowners,the impact on
these types of local government services will be very low and the property tax rates will be relatively
high,thus resulting in an overall positive impact(i.e.paying for services not being used)"
Staff concurs that the Project will not have a significant adverse effect on the capability of local
governments affected by the Project to provide most services. The capacity of Brush Creek Road;
however, will be exceeded.
(9) The Project will not create an undue financial burden on existing or future residents of the
County.
Per the application: "There is no financial burden being placed on the residents for this project as the
water facilities are already in place and no debt is being sought to fund improvements. Additionally,
Plant Improvement Fees and connection charges will be collected from each lot owner. These fees are
a type of impact fee that ensures the cost to the community is being offset with up front fees. The
OWTS systems create no burden for the community at large and due to the state of the art technology
being employed and the monitoring of ground and surface water,there is no downstream impact to the
community at large. The purchasers of these lots will fund the OWTS facilities themselves through
upfront payments and dues paid to the HOA. No existing or future residents of the County,outside of
the project limits,will have any financial burden to serve the development."
Staff concurs that the Project will not create an undue financial burden on existing or future residents
of the County.
(10) The Project will not significantly degrade any current or foreseeable future sector of the local
economy.
Per the application: "There is no financial burden being placed on the residents of this project and no
debt is being sought to fund such improvements. The changes will help to improve the local economy
with additional revenues in the form of taxes and spending by owners and members."
Staff concurs that the Project will not significantly degrade any current or foreseeable future sector of
the local economy. The Eagle County Planning Commission indicated that this criterion is debatable,
without providing explanation of the debate.
(11) The Project will not have a significant adverse effect on the quality or quantity of recreational
opportunities and experience.
Per the application: "The PUD will have little impact on the overall recreational opportunities
within the immediate area or within Eagle County. The proposed PUD Amendment is located
entirely within existing platted developable lots,with no impact on existing open space and
recreational tracts. There are significant,high quality recreational opportunities being provided
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onsite for owners and members including trails, open space areas,the golf course, fitness facilities,
tennis courts, and a community swimming pool. Other recreational activities include fishing and
paddle boarding. This PUD includes more recreational opportunities than most residential projects in
the region and with the costs of operating and maintaining the facilities borne entirely by the private
sector."
Staff concurs that the Project will not have a significant adverse effect on the quality or quantity of
recreational opportunities and experience. The Eagle County Planning Commission believes that the
additional traffic impacts upon Brush Creek Road, as a result of the proposed project will indeed
compromise public access to public lands accessed via Brush Creek Road.
(12) The planning, design and operation of the Project shall reflect principles of resource
conservation,energy efficiency and recycling or reuse.
Per the application: "Best management practices will be implemented in the construction and
operations of the project and will be reflected on construction plans,including but not limited to dust
suppression, erosion control,runoff mitigation and protection of vegetation impacts through practices
outlined in the Environmental Impact Report summary. The project uses raw water for its irrigation
on the residential lots, golf course and open spaces. The use of raw water is limited by agreement
with the Town as documented in the Water Service Agreement. Additionally,the design guidelines
limit the amount of irrigation area on each lot to 7,500 square feet and does not allow irrigation of
native areas. The project will adhere to the Town's Water Conservation Plan as required by the
Water Service Agreement. The Town has a tiered rate for water usage and provides standards for
low flow devices. The project does not provide a drop point for recycled materials but homeowners
are provided with the opportunity to recycle like other developments in Eagle County. The
commercial facilities adhere to a recycling program that insures recycled materials are appropriately
eliminated from the waste stream. The project will comply with all Eagle County regulations for
resource conservation, energy efficiency, and recycling or reuse."
Staff concurs that the planning, design and operation of the Project shall reflect principles of
resource conservation, energy efficiency and recycling or reuse.
(13) The Project will not significantly degrade air quality.
Per the application: "In context of the new proposal adding 47 new dwelling units,project-related
emissions are not anticipated to cause violation of ambient air quality standards or be in violation of
air quality related regulations. During construction there will be minor impacts to air quality
however, all home development and infrastructure installation will use dust suppression and the
stormwater runoff BMP's. Project activities are not anticipated to lead to or cause visibility problems
for the nearby wilderness areas and views of distant mountains."
Staff concurs that the Project will not significantly degrade air quality.
(14) The Project will not significantly degrade existing visual quality.
Per the application: "The design and landscape standards associated with the Frost Creek
development area incorporate the highest visual quality standards. The proposed amended Frost
Creek PUD will only include development in areas already designated for development and will
follow the established design standards for the Frost Creek PUD. No ridgeline development is
proposed with this amended submittal."
Staff concurs with the applicant's assessment that the Project will not significantly degrade visual
quality.
(15) The Project will not significantly degrade surface water quality.
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Per the application: "Impacts to surface water are not anticipated as a result of the new development.
However,the protocol outlined in the Water Quality Monitoring and Management Plan(WQMMP)
and associated documents have provided for advanced mitigation measures and will allow the
determination of whether development of the amended PUD using BMP's adversely affects surface
water quality and if so provides for responses to activation of applicable triggers to be enacted.
Documents associated with the WQMMP which have been reviewed include:
• Guidelines for the Implementation of the Adam's Rib Frost Creek Water Quality Monitoring and
Mitigation Plan(2006),
• Interim Guidelines for the Implementation of the Adam's Rib Frost Creek Water Quality
Monitoring and Mitigation Plan(2009),
• Addendum to the April 2009 Interim Guidelines for the Implementation of the Adam's Rib Frost
Creek and Salt Creek Water Quality Monitoring and Mitigation Plan(2012)
The primary potential impacts to surface water from the Frost Creek PUD have been mitigated by
adherence to local(Eagle County), state(Colorado),and federal permitting requirements, established
guidelines, and high standards of design,construction and maintenance. Mitigation measures
include:
• Strict adherence to site-specific Stormwater Management Plans(SWMP's),a Colorado Department
of Public Health and Environment(CDPHE)Construction Dewatering Discharge Permit, and a
site-specific Spill Prevention, Control,and Countermeasures Plan(SPCC). The Developer will
monitor the BMP's within the SWMP throughout the construction process. Changes to the
BMP's will be made to accommodate any problems that may cause impacts to surface water.
• Roadway runoff for the Frost Creek PUD was mitigated by adherence to the October 29,2004
Final Drainage Analysis prepared by Johnson Kunkel&Associates,Inc. Stormwater drainage or
overland sheet flow is treated in grass-lined swales. Stormwater is directed from the grass-lined
swales to sedimentation ponds, lakes, and protected wetlands and riparian buffer zones prior to
discharge into Brush Creek.
• Potential impacts from pesticide and fertilizer use at the golf course in the Frost Creek PUD are
currently mitigated by adherence to the Integrated Pest Management and Operating Procedures.
• The homeowner's association through their Codes,Covenants, and Regulations will mitigate
potential impacts from activities at individual home sites in the Frost Creek PUD.
• Potential impacts from the Frost Creek PUD golf course maintenance facility may include vehicle
wash water and small quantity chemical discharges. These potential impacts are currently
mitigated by: a)routing all vehicle wash water to floor drains,which are discharged to a grass-
lined swale for treatment,and b)a chemical fertilizer and storage area which has been created
with appropriate spill containment separate from the maintenance facility to prevent impacts
from chemical discharge.
• Potential impacts from the swimming pool at the Frost Creek PUD golf course clubhouse are
mitigated by discharging pool overflow and drain water only after dechlorination to a grass-lined
swale in small quantities with no discharge to surface water.
The Guidelines for the Implementation of the Adam's Rib Frost Creek Water Quality Monitoring
and Mitigation Plan has established trigger limits, a measurable limit on monitored surface water
quality parameters including Total Suspended Solids(TSS),Total Dissolved Solids(TDS),total
phosphorous, and total nitrogen whose exceedances will cause mitigation measures to be enacted.
Three assessment methods are used conjunctively as trigger limits for TSS,TDS, or total
phosphorous. The three assessment methods include: 1)Detections of concentrations of the
parameters in excess of the 85th percentile historic concentration for the given parameter, and 2)
Comparison between upstream and downstream concentrations, and 3)Graphical analysis to assess
temporal changes in the parameters will consist of visual examination of time series graphs,which
may show general long-term changes in parameter concentrations.
The trigger limit for TSS,TDS, or total phosphorous will be activated only when all three of the
assessment tools show abnormal results or rises in concentrations.
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Not enough historical data regarding total nitrogen is available to establish a trigger limit as
described above. Therefore,the established water quality standard for nitrate,a component of total
nitrogen of 10 mg/L is used instead. If the downstream concentration of total nitrogen exceeds 10
mg/L, and is greater that the upstream concentration,then the trigger has been activated.
Bio assessment triggers will be activated if the bio assessment indicates that there is a significant
decline in any of the applicable bioassessment metrics at either of the downstream stations from one
sampling activity to the next, and that the decline may be attributable to contamination of surface
water or other aspects of the development.
Responses to activation of applicable triggers have been clearly outlined. If any of the triggers
listed above are activated,the following steps will occur:
• (Step 1)Confirmation of sample collection.
• (Step 2)Assuming that the confirmation sample shows that trigger was activated, inform the
Environmental Health Department and schedule a meeting to take place after steps three and
four occur.
• (Step 3)Inspection of suspected pollutant sources.
• (Step 4)Inspection of relevant BMP's,to assure that they are properly functioning.
• (Step 5)Meet with the Environmental Health Department. Review available data and results of
the inspections. The responsible party will propose an action plan for review and approval by
the Environmental Health Department.
• (Step 6)Implement action plan.
• (Step 7)Conduct follow-up monitoring to determine if actions are effective."
Staff concurs that the Project will not significantly degrade surface water quality
(16) The Project will not significantly degrade groundwater quality.
Per the application: Per the application: "Impacts to groundwater are not anticipated as a result of
the new development. However,the protocol outlined in the Water Quality Monitoring and
Management Plan(WQMMP)and associated documents have provided for advanced mitigation
measures and will allow the determination of whether development of the amended PUD using
BMP's adversely affects groundwater quality and if so provides for responses to activation of
applicable triggers to be enacted. Documents associated with the WQMMP which have been
reviewed include:
• Guidelines for the Implementation of the Adam's Rib Frost Creek Water Quality Monitoring and
Mitigation Plan(2006),
• Interim Guidelines for the Implementation of the Adam's Rib Frost Creek Water Quality
Monitoring and Mitigation Plan(2009),
• Addendum to the April 2009 Interim Guidelines for the Implementation of the Adam's Rib Frost
Creek and Salt Creek Water Quality Monitoring and Mitigation Plan(2012)
The primary potential impacts to groundwater from the Frost Creek PUD have been mitigated by
established guidelines, and high standards of design, construction and maintenance. Mitigation
measures include:
• All onsite wastewater treatment systems at the clubhouse, golf course maintenance facility,
individual home sites will be designed by a licensed professional engineer and shall include
denitrification at a minimum. The licensed professional engineer will design the wastewater
treatment systems to minimize their potential to impact groundwater.
• Potential impacts from pesticide and fertilizer use at the golf course in the Frost Creek PUD are
currently mitigated by adherence to the Integrated Pest Management and Operating Procedures.
• The homeowner's association through their Codes, Covenants, and Regulations will mitigate
potential impacts from activities at individual home sites in the Frost Creek PUD.
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• Potential impacts from the Frost Creek PUD golf course maintenance facility may include vehicle
wash water and small quantity chemical discharges. These potential impacts are currently
mitigated by: a)routing all vehicle wash water to floor drains,which are discharged to a grass-
lined swale for treatment, and b)a,chemical fertilizer and storage area which has been created
with appropriate spill containment separate from the maintenance facility to prevent impacts
from chemical discharge.
• Potential impacts from the swimming pool at the Frost Creek PUD golf course clubhouse are
mitigated by discharging pool overflow and drain water only after dechlorination to a grass-lined
swale in small quantities with no discharge to surface water.
The Guidelines for the Implementation of the Adam's Rib Frost Creek Water Quality Monitoring
and Mitigation Plan has established trigger limits, a measurable limit on monitored groundwater
quality parameters including total phosphorous,total nitrogen,and the target pesticide whose
exceedances will cause mitigation measures to be enacted. Three assessment methods are used
conjunctively as trigger limits for total phosphorous. The three assessment methods include: 1)
Detections of concentrations of the parameters in excess of the 85th percentile historic concentration
for total phosphorous, and 2) Comparison between upgradient and downgradient background
groundwater monitoring wells, and 3)Graphical analysis to assess temporal changes in the
parameters will consist of visual examination of time series graphs,which may show general long-
term changes in parameter concentrations.
The trigger limit for total nitrogen is 10 mg/L. If the downgradient concentration of total nitrogen
exceeds 10 mg/L, and is greater that the upgradient concentration,then the trigger has been
activated. Any detection of the target pesticide at a concentration in excess of the applicable water
quality standard(if available)for that chemical will activate the trigger limit.
Responses to activation of applicable triggers have been clearly outlined. If any of the triggers
listed above are activated,the following steps will occur:
• (Step 1)Confirmation of sample collection.
• (Step 2)Assuming that the confirmation sample shows that trigger was activated, inform the
Environmental Health Department and schedule a meeting to take place after steps three and
four occur.
• (Step 3)Inspection of suspected pollutant sources.
• (Step 4)Inspection of relevant BMP's,to assure that they are properly functioning.
• (Step 5)Meet with the Environmental Health Department. Review available data and results of
the inspections. The responsible party will propose an action plan for review and approval by
the Environmental Health Department.
• (Step 6)Implement action plan.
• (Step 7)Conduct follow-up monitoring to determine if actions are effective." ."
Staff concurs that the Project will not significantly degrade groundwater quality.
(17) The Project will not significantly degrade wetlands, and riparian areas.
Per the application: "The original lot configuration in the three amended areas contain delineated
wetland and riparian areas(i.e., actual wetlands and riparian areas on lots in private ownership). The
proposed amendments resolve this conflict except in a couple very limited areas where access to two
lots must cross a ditch,which is the existing condition today, as well. The new open space areas
were created to pull wetlands and riparian areas into HOA controlled tracts to further enhance their
protection. The proposal will adhere to the 50-foot setback in three of the new development areas
(Hunters Way,Red Bluffs Way and Squires Lane)with limited disturbance in the Hunters Way area
for driveway access in two locations where a ditch crossing may be required. Water quality impacts
to wetlands are not anticipated as a result of the new development. However,the protocol outlined in
the WQMMP will allow the determination of whether development of the amended PUD using
BMP's adversely affects wetlands and if so provides for mitigation measures to be enacted."
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•
Staff concurs that with the reconfigured access to the reduced number of lots in the Hunters Way
area the Project will not significantly degrade wetlands, and riparian areas.
(18) The Project will not significantly degrade terrestrial or aquatic animal life or its habitats.
Per the application: "The proposal will not result in any significantly differing impacts beyond
increased human activity due to higher density residential uses,which will only take place in areas
already identified for development as part of the original Frost Creek PUD. A Wildlife Mitigation
and Enhancement Plan was adopted for the Frost Creek PUD in order to avoid or minimize impacts
to the extent practicable and mitigate unavoidable impacts to wildlife. Colorado Parks and Wildlife
comments include the request for seasonal closures of open space areas and that a mitigation fund be
developed to mitigate for wildlife impacts. The current PUD Guide already provides for seasonal
closures which CPW staff has acknowledged and the applicant is proposing a 0.2%transfer fee of the
sale of any lot that will be used by the HOA for wildlife habitat enhancing activities.
Staff concurs that with the proposed wildlife mitigation real estate transfer fee approach in
perpetuity, the Project will not significantly degrade terrestrial or aquatic animal life or its habitats.
(19) The Project will not significantly deteriorate terrestrial plant life or plant habitat.
Per the application: "All of the proposed site improvements are on areas identified as dry meadows,
which previously supported upland irrigated pasture prior to the establishment of the Frost Creek
development. The most sensitive vegetative habitat includes riparian habitats,no new impact are
proposed to these areas."
Staff concurs that the Project will not significantly deteriorate terrestrial plant life or plant habitat
and that the previously mapped riparian/wetland areas will be preserved, as well the additional 50
foot setback from the outer edge of mapped wetland areas.
(20) The Project will not significantly deteriorate soils and geologic conditions.
Per the application: "Extensive geologic site assessments for the original Frost Creek PUD were
conducted. The development areas of the original PUD took into account geologic constraints and
produced a plan following specific recommendations for pavement design, roadway alignments,
drainage, site grading,maintenance, and bridge design.
No new areas are being contemplated for development with the proposal; the four development areas
for review in the amended Frost Creek PUD only include changes in density,not areas affected.
However,because compressible soils may still exist on any lot, geologic conditions should be
evaluated on a lot specific basis prior to building."
The Colorado Geological Survey did not respond to the referral for this application; however, staff
does concur that the subject property was extensively evaluated at the time of the original PUD
approval, and during subsequent improvement of the golf course, infrastructure and existing vertical
development on the site. A site specific geologic assessment is to occur prior to issuance of any
building permits for permanent structures.
(21) The Project will not cause a nuisance.
Per the application: "Minimal nuisance factors will be encountered and dealt with during the
construction phase of the project. Factors that are common during the construction of new homes,
including noise,dust and construction traffic will be the most noticeable."
Staff concurs that upon completion of the construction phase, the Project will not cause a nuisance.
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(22) The Project will not significantly degrade areas of paleontological,historic,or archaeological
importance.
Per the application: "A cultural resource study was performed by Western Cultural Resource that
found only one historic structure,which was preserved as part of the original PUD approval. The
project will not significantly degrade areas of paleontological,historic, or archeological importance."
Staff concurs that the Project will not significantly degrade areas of paleontological, historic, or
archaeological importance.
(23) The Project will not result in unreasonable risk of releases of hazardous materials.
Per the application: "The project will not result in an unreasonable risk of releases of hazardous
materials. The project will have normal construction activities and will use the approved methods of
disposing of any construction materials so as not to cause a release of hazardous materials. These
amendments to the PUD have no impact upon the location, storage, containment procedures, spill
countermeasures plan with regard to fertilizers,pesticides,herbicides,lubricants,and fuel. There are
no changes proposed to the previous plans to address these issues. Fueling of golf course equipment
will be from fueling pumps developed at the maintenance facility. All golf related storage of
potentially hazardous materials is within the Golf Maintenance Facility which has containment
facilities built-in. All potential spill runoff is funneled to a catch basin on the north side of the
structure, if a spill is not addressed and contained within the facility first by staff. Therefore all spills
will be prevented from entering the environment, surface waters, or groundwater. Onsite fuel pumps
have spill well containment. Pesticides and herbicides are also stored in the golf maintenance
facility."
Staff concurs that the Project will not result in unreasonable risk of releases of hazardous materials.
(24) The benefits accruing to the County and its citizens from the Project outweigh the losses of any
natural,agricultural,recreational,grazing,commercial or industrial resources within the
County,or the losses of opportunities to develop such resources.
Per the application: "All proposed development to occur as a result of the proposed PUD amendment
occurs within existing platted developable area,with no loss of natural, agricultural,recreational,
grazing, commercial or industrial resources within Eagle County."
Staff concurs that the benefits accruing to the County and its citizens from the Project outweigh the
losses of any natural, agricultural, recreational, grazing, commercial or industrial resources within
the County, or the losses of opportunities to develop such resources.
B. 6.04.02 Additional Criteria Applicable to Municipal and Industrial Water Projects.
In addition to the general criteria set forth in Section 6.04.01,the following additional criteria apply
to municipal and industrial water projects:
1. The Project shall emphasize the most efficient use of water,including the recycling,reuse and
conservation of water.
Per the application: "The project provides efficiency and conservation by utilizing senior water rights
decreed for irrigation that have been historically used on the Frost Creek lands. The lands projected to
be irrigated in the Frost Creek PUD will be irrigated with these senior water rights through a raw water
irrigation system consistent with the approvals for the PUD and the Water Service Agreement-Frost
Creek, dated February 26, 2002, as amended September 7,2004(Holland&Hart,LLP, 7/15/05). The
water being used on the project is very near the point of diversion. As part of the 2002 Water Service
Agreement and a contribution to the Brush Creek Management Plan, an Irrigation Management Plan
was drafted to help maintain streamflow levels immediately downstream of the Town's point of
diversion,the installation and operation of a streamflow gage station just downstream on Brush Creek
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and certain limits on the amount of water the project diverts from various Brush Creek diversion
structures were all agreed to. The lowered diversions are less than historic diversion, and are made
possible by increased irrigation efficiencies associated with the golf course and residential development
as planned.
Best management practices will be implemented in the construction and operation of the project and
will be reflected on construction plans, including but not limited to dust suppression, erosion control,
runoff mitigation and protection of vegetation impacts through practices outlined in the EIR summary.
The project uses raw water for its irrigation on the residential lots, golf course,and open spaces. The
use of raw water is limited by agreement with the Town as documented in the Water Service
Agreement. Additionally,the design guidelines limit the amount of irrigation area on each lot to 7,500
square feet and does not allow irrigation of native areas. The project will adhere to the Town's Water
Conservation Plan as required by the Water Service Agreement. The Town has a tiered rate for water
usage and provides standards for low flow devices. The project does not provide a drop point for
recycled materials but homeowners are provided with the opportunity to recycle curbside like other
developments in Eagle County. The commercial facilities adhere to a recycling program that insures
recycled materials are appropriately eliminated from the waste stream. The project will comply with
all Eagle County regulations for resource conservation, energy efficiency, and recycling or reuse."
Staff concurs that the Project shall emphasize the most efficient use of water, including the recycling,
reuse and conservation of water. It is important to note that the amended water service agreement
provided on December 2, 2016, did not include the Exhibits referenced in the water service agreement.
As such, it is not feasible to determine whether or not the above discussed water service agreement
provisions related to irrigation have changed, or remain the same.
2. The Project will not result in excess capacity in existing water or wastewater treatment services or
create duplicate services.
Per the application: "The project will not result in excess capacity in existing water or wastewater
treatment services or create duplicate services. The Town of Eagle will provide domestic water for the
project. The project will redistribute EQR density per Water Service Agreements from lower Brush
Creek properties to an area with existing approved density and significant infrastructure. The Town
has the current capacity to serve the project. While there is some chance that a future Town Board
could choose to allow more EQR's, or taps, in the future on the Brush Creek properties,under the
terms of the amended Annexation and Water Service Agreement,the density of these properties is
being restricted to reflect the transfer of EQR's(taps). Said differently,the number of total EQR's
available to all of these properties,Frost Creek and the Brush Creek properties does not change as a
result of this amendment. So addressing this criterion No. 2,there is no excess capacity of water or
wastewater facilities being proposed.
Senior agricultural water rights from Frost Creek(Adam's Rib)were transferred to the Town of Eagle
prior to the dedication of the EQR's for Frost Creek and associated properties. The transfer provided
for municipal diversion that meet or exceed the anticipated demands and historic monthly consumptive
water uses. Water depletions associated with the Adam's Rib projects have been augmented.
Engineering reports by Resource Engineering,Inc. and Wright Water Engineers, Inc. determined that a
sufficient and reliable source of supply to irrigate the lands designated for irrigation in the Frost Creek
portion of the PUD.
Wastewater will be serviced through Onsite Wastewater Treatment Systems(OWTS). Each OWTS
system must have denitrification capabilities,equipped with an(centralized)alarm system and
inspected every two years(by the HOA)."
Staff concurs that the Project will not result in excess capacity in existing water or wastewater
treatment services or create duplicate services.
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3. The Project shall be necessary to meet community development and population demands in the areas
to be served by the Project.
Per the application: "According to the Colorado State Demographer estimates,the population of Eagle
County was 43,288 in the year 2000; 47,278 by the year 2005, and projected to be 53,303 in the year
2015. By 2020,the Colorado State Demographer projects Eagle County's population to increase to
57,226. The Colorado State Demographer estimates the 2014 Town of Eagle population to be 6,750,
and the 2014 unincorporated area of Eagle County to be 23,395.
In 2010,the Town of Eagle and Eagle County adopted the Eagle Area Community Plan,which
indicated that the population of Eagle County will double by the year 2030,with much of that growth
anticipated to occur in communities and towns in western Eagle County, like Eagle and Gypsum. The
project is necessary to meet community development and population demands."
Staff concurs that the Project shall be necessary to meet community development and population
demands in the areas to be served by the Project. The Eagle County Housing Department has
indicated its support of the Affordable Housing Plan, as submitted.
4. Urban development,population densities, and site layout and design of storm water and sanitation
systems shall be accomplished in a manner that will prevent the pollution of aquifer recharge areas.
Per the application: "The surrounding privately owned property has generally been subdivided into
five to ten acre lots. The proposed development is compatible with this pattern of urban development,
population density, and site layout.
Additionally, as specifically outlined in the Environmental Impact Summary Report provided in the
Compendium of Technical Reports,a Water Quality Monitoring and Management Plan(WQMMP)
was developed for the Frost Creek PUD in order to establish baseline(predevelopment)water quality
information and ensure that the development would not adversely affect water quality of aquatic life,or
pollution of aquifer recharge areas."
Staff concurs that urban development,population densities, site layout and design of storm water and
sanitation systems shall be accomplished in a manner that will prevent the pollution of aquifer
recharge areas.
C. 6.04.03 Additional Criteria Applicable to Major New Domestic Water and Wastewater Treatment
Systems and Major Extensions of Existing Domestic Water and Wastewater Treatment Systems.
In addition to the general criteria set forth in section 6.04.01,the following additional criteria apply
to any development of major new domestic water and wastewater treatment systems or major
extensions of existing domestic water and wastewater treatment systems:
1. The Project shall be reasonably necessary to meet projected community development and
population demands in the areas to be served by the Project,or to comply with regulatory or
technological requirements.
Per the application: "The PUD Amendment adds new density to the Frost Creek PUD. No changes are
proposed to the water treatment facilities to accommodate the proposed density especially given that
the new density in Frost Creek is simply a transfer of density already contracted for in the Brush Creek
valley. There is new demand for OWTS generated by the new lots proposed in Frost Creek. There is a
direct relationship between the new density and the proposed number of OWTS,thus meeting the
demands for wastewater treatment which reflects the new population in Frost Creek. Therefore,the
project(water and wastewater facilities)are reasonably necessary to meet the specific development and
population demand being created by the PUD Amendment."
Staff concurs that the Project shall be reasonably necessary to meet projected community development
and population demands in the areas to be served by the Project, or to comply with regulatory or
technological requirements.
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(2) To the extent feasible,wastewater and water treatment facilities shall be consolidated with
existing facilities within the area.
Per the application: "The project's water facilities are owned and operated by the Town of Eagle and
the OWTS are managed by a single entity, a consolidated approach to management and operations."
Staff concurs that to the extent feasible, wastewater and water treatment facilities are being and will
continue to be managed by the appropriate entities. No further-opportunity for consolidation exists.
(3) New domestic water and sewage treatment systems shall be constructed in areas which will result
in the proper utilization of existing treatment plants and the orderly development of domestic
water and sewage treatment systems of adjacent communities.
Per the application: "The water system is utilizing the existing Town of Eagle's Water Treatment Plant
and ties into the Town of Eagle's Water System. The Town of Eagle is the only water provider in this
location. Wastewater is being treated on each lot with an OWTS of the strictest standards."
Staff concurs that no new domestic water and sewage treatment systems are proposed as part of this
Project.
(4) The Project shall be permitted in those areas in which the anticipated growth and development
that may occur as a result of such extension can be accommodated within the financial and
environmental capacity of the area to sustain such growth and development.
Per the application: "The water treatment facilities already exist in the area and serve the entire Town
of Eagle. The additional density and growth being proposed with the amendments will be within the
environmental capacity of the area given the attention to ground and surface water quality built into the
PUD. The proposed changes will not generate new growth in the region as new water and wastewater
treatment capacities are not being created.
The Town of Eagle's Water Treatment Plant is located adjacent to the Frost Creek property(on land
dedicated by the original developer for its construction), and the other utilities are located near the
project."
Staff concurs that the Project shall be permitted in those areas in which the anticipated growth and
development that may occur as a result of such extension can be accommodated within the financial
and environmental capacity of the area to sustain such growth and development.
D. Special Use Permit Waiver: In accordance with Chapter II,Article 3, Section 3.310.I.2, Waiver
Provision, of the Eagle County Land Use Regulations,the Special Review Use Permit application for water
and sewer projects may be waived in whole or in part by the Board of County Commissioners upon a
written petition by the applicant showing that:
3.310.2.a. A permit application pursuant to Chapter 6, Sections one through five of the Eagle County
Guidelines and Regulations for Matters of State Interest has been submitted to the Eagle
County Permit Authority relative to this land use which would be the subject of a special
use permit application.
3.310.2.b. Compliance with the Special Use Review Permit requirements would be unreasonably
burdensome for the applicant.
The applicant has requested a waiver of the Special Use Review Permit requirements as such application
would be redundant with this 1041 Permit process and would serve no further legitimate planning, zoning
or other land use objective.
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o
There being no further bus• = . f??�,'- ,? :oard,the meeting was adjournedruary 7,2017.
Attest:_ _ IAi_ Of R'
Allif1611'
C
-r�(4 the Board C ir .n
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