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PUBLIC RESPONSE
ITEM I DATE I SUBMITTED BY
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June 24, 1998
Attn: Chairman & Commission Members
CALDWELL P & Z COMMISSICIN
Caldwell City Hail
621 Cleveland Blvd.
Caldwel3F ID 83605
Rf:.: Proposed Stornwater Management Policy
Case No. OA-17-98
Hearing Date: June 25, 1998
Dear Chairman & Commission Members:
Per the noLlce received on the above case regarding adoption
of the Proposed Stormwater Management Policy for the City of
Caldwell, we are pleased to offer the following comments as
part of the public record.
These comments reference page number and/or section number:
Page 7
• Sec. 101.1, GENERAL RULES.
In several sections, this proposed policy refers to the
Idaho Standards for Public Works Construction (ISPWC)
commonly adopted and used throughout the State of Idaho,
however the City of Caldwell has never officially adopted
ISPWC. We recommend the City adopt ISPWC before any new
stornwater policy.
• Sec. 101.1.1 GRANDFATHER CLAUSE.
We suggest revising the last sentence to read: "The
setting of storm drainage practices for City sponsored
street projects within the confines of the City owned
right-of-way shall be directed by the City Engineer and
will also be designed and constructed in accoxdanoe with
this policy."
j
Page B
• Sec. 101.1.6, ENGINEER'S RULE.
Because single -lot developments less than 1 acre could
include a commercial building with considerable
surrounding hard surface parking areas that collectively
contribute significantly to runoff, there should be no
minimum size of development requiring professional
engineering or design.
Paz 11
• Sec. 102.2.2. EASEMENTS.
Second sentence excludes landscaping over these
facilities. Since they are difficult to conceal, we
recommend that developers and homeowner's be allowed to
landscape in these easements to enhance overall
attractiveness and visual appeal of developments.
Page 14
• Sec. 102.8 GUTTER CAPACITY.
The design and construction standards for Canyon County,
local Highway DISLricLs, and surrounding municipalities
all provide for and permit gutter grades less than or
flatter than 0.4%. We recommend Caldwell provide for
and adopt 0.3% minimum gutter grade.
Page 16
• Section 103.2.1, SITE RUNOFF.
It appears that a great deal of this policy manual
has been taken and/or abridged from the Ada County
Highway District, or ACHD manual. Our comparison with
this manual has not found any reference or basis for a
maximum discharge rate of 1 miner's inch per acre. What
is the basis or foundation for this rate's Why haven't
other jurisdictions adopted this discharge rate criteria?
• Sec. 103.2.4, LOCATION OF STORAGE FACILITIES.
This section specifies that stormwater retention and
detention facilities be located on private property or on
common lots in larger developments. If so who is the
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responsible party?
Page 17
Homeowner's Association or the City?
• Sec. 103.2.7, IDAHO STATE CODE REQUIREMENTS.
How will the Southwest District Health Department or IDWR
handle this in regards to fee assessment and
administration? Have they been consulted about this
function?
• Sec. 103.4, OPERATIONAL RESPONSIBILITY.
If the City is not to have primary operation and
maintenance responsibility, who will have it?
If this is to fall to the Homeowner or Property Owner, do
they really understand their associated liabilities and
maintenance responsibilities? How will they understand
the technical design and operational functions of these
systems in the future?
Page 22
• Table 4 - INFILTRATION RATES.
We suggest attaching the applicable SCS Soil Type table
for cross-referencing. In addition, because the State of
Idaho Division of Environmental Quality (DEQ) has
extensively addressed this subject in their Technical
Guidance Manual, who not incorporate the same
Infiltration/ Percolation Rates and data?
Page 25
• Sec. 105.3.2, TESTING.
This is seems to be an arbitrary provision. Why are
requirements in excess of ISPWC required? Also, see our
first :.omment in this letter regarding ISPWC.
Conclusion
This proposed policy is very complex, far-reaching, and will
substantially increase all development casts including
planning, engineering, construction, and administrative
costs to all involved parties. Have the overall costs and
impacts of this policy on landowners, developers, taxpayers
and the City been fully evaluated?
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We lock forward to your respOn8e Lo the above and we thank
you for your consideration of our comments and concerns.
Sincerely,
William J. Mason,
EARL & ASSOCIATES, INC.
EARL & ASSOCIATES, INC.
IERL
ald L. rl, President
& ASSOCIATES, INC.
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IN REPLY REFER TO-
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United States Department of the Interior
BUREAU OF RECLAMATION
Snake River Area Office
214 Broadway Avenue
Boise, Idaho 83702-7298
SRAOW-6113 June 3, 1998
Legislation Review
Mr. Gordon Law
Caldwell City Engineer
City of Caldwell
621 Cleveland Blvd.
Caldwell ID 83605
Subject: Review of Draft Storm Water Management Policy
Dear Gordon:
Enclosed for your consideration are staff comments regarding this
proposed ordinance.
We wholeheartedly support this policy and sincerely appreciate
its sound engineering and practical utility.
Call John Caywood (ph. 334-1463) if we can be of any assistance.
Sincerely,
Enclosure
100.2.1.2. Accommodate storm water and other flows from upstream
lands and developments by providing adequate WROMOOcM
conveyance facilities through development sites.
100.2.2.2•Control the quantity of water '# contaminants '
eathrough construction of facilities to treat storm
runoff.
11 • •1 ,ra-P UMe 4, MOM@V44•
Design and implement a control system to Tile mailageLuellt
erosion from new developments and resulting sediment load in
receiving waters'
contrw± System;--- The sources of sediment may be controlled
through the use of diversions, ground cover, lined channels,
sediment basins, sediment control structures, filtering and
screening membranes or other approved methods,
1 / .. 1 . • 1 m
The City has constitutional authority as a municipal corporation
to promulgate regulations governing the discharge of storm water
onto the {public -way }
-of ri ht y
g ;c
or into the City's storm water system.# x,
100.3.5 Other
There '� may- other legal authorities, which the City may
assert from time to time.
101.1.1 Grandfather ClausQ
Line 11: The setting of storm drainage practices for City
sponsored street projects within the confines of City owned
right-of-way shall be directed by the City Engineers
AI
101.1.2 Downstream Rule
Line 6:("reasonable") ATM rY %OIC N• ���+M../ !v• Y'yS ��yy^',:,.y..{.•{,....Ky.
parr...... s•,a:e?+n!nPf!' .liinw..:c. , y a •na . a x•x .s rY:C£9`n.,c w.w,.S n
101.1.4 rrr`gation Rule
Line 1- ( irrigation entity) �'e�M "rIM `° ��, 'urisdiction
rr. ,yaa' a�rr�:es:a:•a:•w:y .o-•:ay, �4",v,£ur r s<+:s. fair rc' �{.ELY .rr.r run• Y
• =emu' Lrr �'" � � n* ' �°" ?,�''.,ar' a' :r .,,
. ���`o�, ' 4�.. a ' ✓r,�;A' a��:�'i�'��'C+� ���orY,. • � r +err •�', �'•.c.3k. o�..�.:. S7: r! .i,..� .ro��' '¢rcyifin'!l: who-. s.0ir, .4; (sX C Yl'rl
101.1.5 Discharge Rule
Line 5: (entity operating or maintaining the ditch, drain or
and :z �, •:.: •4C. x.v
Paragraph 2: The rate of discharge shall be calculated using
the proper methodology. The peak rate for areas up to eighty
acres shall be calculated using the Rational Method or approved
derivatives. The Soil Conservation Service (SCS) method TR No.
55 shall be used for areas larger than eighty acres.
i�:i�F11tl,e.: rIM,r Z.V-1Y rxr:•.O::f.' . 4r:.i4.+i•:i rr: is r: Af"
102.2 LOCATION �`'"'''�'
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Storm water conveyance components may be located in public right -
of -wa :AafY..h. :
Y :�•� or on private property in
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easements.
102.2.2 Easements
Last sentence: Easements running along
situated such that the centerline of t'
105.2 IRRIGATION AND DRAINAGE FACILITIES
lines shall be
05/21/98 11:48 '$ PIONEER IRRG DIS U 001/001
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Pioneer
Irrig1tion
District
R a ecx 426 • CALDWELL, IDAHO 63' M6
LONNIE a FREEMAN
Sup@dmmnd@W
NAM E. KMAAMER
sepemry / Trwsuraf
May 20, 1998
Mr. Gordon Law, City Engineer
City of Caldwell
FAX: 455-3003
Dear Mr. Law
f a
andum
Pioneer 998from LiAndaJ=esiregarding thereceipt oDrafteOfrStormwaterd
May 6, 1998 from L
management Policy --April, 1998, inviting responses to the same.
to
Pioneer Basedsupooned thisrreecommendati.ons, we , Scott would,likerto1submit
the
Draft. Base p
the following comments.
On. Page 8, under 101.1.5 Di.schar a Rule, we would like to request
a couple of additions, so t at t e p aragr aph reads as ows:
in
'Any development proposing to discharge off -site, in cotmli ce
with this policy, shall notify in writing, and obtain'the written
approvals of the owner and the entity which'maintains or o eraCes
t e ditch, rain or pond into w is lsc arge s 3 1 occur- n
addition, -
Please be further advised Pioneer Irrigation District desires to
continue to participate in the development of this stormwater manage-
ment policy, and woul�heike to rforlreview•notices l'hank you for1keepng
subsequent drafts of policy
us informed.
Sincerely,
Naida E. Kelleher
Secretary -Treasurer