HomeMy WebLinkAbout1986-08-12 RecommendationCity of Iowa City
MEMORANDUM
Date: July 10, 1986
To: Planning and Zoning Commission
From: Barry Beagle, Associate Planner
Re: CZ -8614. Rezoning from A-1 to RS
Mr. Steve Bright of Bright Realty Company has submitted an application to
the Johnson County Zoning Commission to rezone three (3) separate 1.9 acre
parcels from A-1, Agricultural to RS, Residential Suburban. The proper-
ties are located 1.6 miles northeast of Iowa City, accessible by a private
drive extending south of Rapid Creek Road.
Each of the three (3) sites are located within Area 4 of the Fringe Area
Policy Agreement. As the Commission is aware, a new policy for Area 4 is
under consideration which permits limited development in the Rapid Creek
Study Area. However, at the present time, it is the policy of Area 4 to
discourage residential development in lieu of continued agricultural use.
STAFF RECOMMENDATION
Staff recommends that the Commission find the proposed rezoning from A-1
to RS, for three (3) separate 1.9 acre parcels, to be inconsistent with
the existing Area 4 policy.
ATTACHMENTS
Location Map.
Approved byY
on c e ser, Director
Department of Planning &
Program Development
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PHELAN, TUOMR, BOYLE & MULLEN
ATTORNEYS AT LAW
WIL11AM V. PHELAN 321 MARKET LOUIS SHULMAN (1906-1982)
WILLIAM M. TUCKER P.O. BOX 2150
DANIEL W. BOYLE
CHARLES A. MULLEN IOWA QTY, IOWA 52244
SITPHEN P. BRIGHT (319) 354-1104
BRUCE L WALKER
RICHARD M. TUCKBE nLCEIVr-0 ---
THOMAS H. GEIZAAN
STEVEN R. REGEISIWEITUER August 5, 1986 AUG 0 6 (jnv
MARY ELIZABETH PHELAN
P.P.D. DEPAIi1AIENT
Ben Johnson
Zoning Administrator
Johnson county Zoning commission
United States Post Office Building
Iowa City, Iowa 52240
Barry Beagle
Associate Planner
City of Iowa City
Department of Planning & Program Development
Civic Center
Iowa
City, Iowa 52240
Re: Rezoning Application - Graham Township
Bright Development Company
Gentlemen:
As YOU know on July 31 the Hoard of Supervisors approved the
change of the density in the Rapid Creek area to a 3 to I
ratio. I will be redoing my application on the basis of
this new policy and will submit a revised application.
Therefore, I request that you take no further action but
hold my application as a Pending matter until we are able to
redo this in compliance with the new Policy adopted by the
Johnson County Board of Supervisors.
Yours very truly,
- 4XV,
Stephen F. Bright
SFB: jh
cc: Dick Breazeale
Robert Mickelson
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City of Iowa City
MEMORANDUM
DATE: flay 12, 1306
T0: Planning & Zoning Commission
FROM: Karin Franklin-yC(
RE: Environmental Regulations
The attached documents were sent to the City Council in April.
The Council referred the question to the Planning and Zoning
Commission. You are asked to review the recommendations of
the Urban Environment Ad Hoc Committee and make a recommendation
to the Council on the appropriate scope of new regulations
pertaining to grading and site development as it relates to
environmentally sensitive areas. At this time specific ordinances
are not under consideration. Your recommendation should relate
to the extent to which you feel regulation is necessary; for
example, should any new ordinance apply to all building permits
or just to large scale developments. ' At the informal meeting
Monday 1 will go over the UEAHC recommendations and the possible
areas of applicability. I would suggest that the Commission plan
to discuss this item during at least two informal sessions.
Your recommendation on the scope of the regulations will be
forwarded to the Council who will then reach consensus on the extent
Of applicabilitybefore the staff prepares specific ordinances.
The ordinances will then be referred.back to the Commission.
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City of Iowa City
MEMORANDUM
Date: March 14, 1986
To: City Counci
From: Karin n I . n, - Senior Planner
Re: Environmental Regulations
Last summer the Urban Environment Ad Hoc Committee recommended to the City
Council that ordinances be developed which would require grading plans for
all earth moving exceeding 50 cubic yards and site development plans for
the development of natural areas worthy of protection. Single family and
duplex construction would be exempt under the Committee recommendation.
The recommendation documents are attached. The Council referred these
items to the Planning and Zoning Commission.
The staff began to draft the ordinances and found that considerable work
could be done to generate a comprehensive ordinance which the Council
would ultimately find unacceptable. In the interest of efficient use of
staff time, it was decided to come before the Council to discuss the scope
of applicability of these regulations. Enclosed is a document which
attempts to set forth a range of possible regulations. It is the staff's
hope that the Council will be able to reach consensus on a focus for these
new regulations, be it a comprehensive ordinance or an ordinance with very
limited applicability.
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1/9/85
RECOMMENDATIONS TO THE CITY COUNCIL
CONCERNING LAND DISTURBING ACTIVITIES
\ On April 9, 1985, the City Council of Iowa City adopted the policy recommen-
dations of the Urban Environment Ad Hoc Committee for the preservation and
protection of Iowa City's urban environment. These policies address several
important elements integral to the character of Iowa City which need to be
protected and preserved.
Among these elements of concern are environmentally sensitive areas which are
defined as follows:
Environmentally sensitive areas' are geographical areas containing
natural, ecologic, archeological or aesthetic resources or features
which are of value to the public and the destruction of which might
result in the permanent or long-term loss of important public
resources (such as mature woodlands), in economic loss, in hazards
such as landslides or flooding, and in the long-term degradation of
the environment. Examples of such environmentally sensitive areas
include, but are not limited to, uncommon or unique geologic
formations , natural stream corridors including floodplains,
floodways and greenbelts of the Iowa River and associated creeks,
natural stormwater detention areas, bottom land and upland woods,
steep slopes, areas of high recreational value for bird watching
and observation of flowers and other plants and animals, and areas
containing a high concentration of ecologic and aesthetic features.
The Urban Environment Ad Hoc Committee recommends that the City Council of
Iowa City consider the following means of implementation for the preservation
and protection of environmentally sensitive areas. The Committee is recom-
mending general concepts it wishes to see included in future regulations; it
is not setting forth specific ordinances to be considered.
I. 'Regulation of Land Disturbing Activities
Goal
The goal of regulating land disturbing activities is to insure develop-
ment that is sensitive to the underlying topography and to control excess
erosion, hazardous rock and soil slippage, sediment production, and
drainage and water management problems associated with grading and
removal of vegetative cover.
Objectives
Objectives of 'such regulations are to address and minimize the effects of
the following:
1. Development affecting the stability of steep slopes.
2. Severe alterations (excavation or fill) to the natural topography.
3. Clearance of vegetation or destruction of vegetation by means other
than Clearance.
4. Alterations to the natural/existing drainageways.
I
2
S. The creation of erosion and runoff onto adjacent and/or downstream
I properties.
1 6. The effect of land disturbing activities in ravines.
lThe Committee suggests the following definitions:
I
I' 1. Grading shall mean excavation or fill or any combination thereof and
shall include the conditions resulting from any excavation or fill.
2. Land disturbing activit shall mean any disturbance to land in excess
o cu tc yares wilt may result in erosion, including, but not
limited to, tilling, removal of vegetative cover, stockpiling of
soil, and grading, except that the term shall not include minor land
disturbing activities.
3. Minor land disturbin activities shall mean any disturbance to land
not exceed ng cubic yards including, but not 'limited to, home
gardening, landscaping and normal repair of private drives and
lanes.
4. Ravine shall mean a long, deep gully in the earth's surface with side
sT of at least 50 feet but not greater than 500 feet, all or part
of which have a slope of 15 percent or greater.
5. Steep slope .shall mean a slope any part of which contains a grade of
15 percent or greater.
Recommendations
1
The Urban Environment Ad Hoc Committee recommends that the following be J
included in the implementation of regulations addressing land disturbing
activities:
1. All land disturbing activities shall be subject to the approval of a
grading plan and/or permit.
2. All land disturbing activities shall be subject to the approval of an
erosion control plan..
3. All land disturbing activity on slopes of 15 percent or greater shall
require the submission of detailed grading and erosion control plans
certified by a professional, registered soil engineer, or equiva-
lent.
4. For steeper slopes, e.g. 25 percent or greater, additional require-
ments be adopted, such as percentage of land to be left in its
f natural state.
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Exemptions
The Committee recommends that the following be exempted from these regu-
lations:
1. The construction of individual single-family dwelling units except on
steep slopes (15 percent or greater) shall be exempt frau gracing
plan/permit requirements but shall be required to file erosion 1
control plans:
2. Minor land disturbing activities as defined, including home garden-
ing, landscaping, patio construction, etc.
3. Minor land leveling associated with normal agricultural activities
which does not require grading below the top soil, or land disturbing
activities for the construction of access roads to support agricul-
tural production.
4. Cemetery graves, sanitary landfill sites (subject to other regula-
tions), emergency grading and other similar activities.
Prohibitions
Any land disturbing activity shall be prohibited in the lower portion of
a ravine to preserve and protect its natural water carrying capacity.
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Environmentally Sens
emulating Land Disturbing Activities
The basic goals in regulating grading (excavation and fill) activities
are to minimize the effects of development on the stability of steep
slodrapes, to mnagewaysand mtooreduce osevee alterations n and runoff lto the tna uralet pography.
The regulation of grading goes hand in hand with erosion control, and no
grading permit should be issued without an erosion control plan for the
site to be graded if these basic goals are to be met.
Clearly, the steeper the slope and the larger the development, the
greater the potential adverse impact of land disturbing activities.
Thus, regulations can be applied at various levels relating to both the
steepness of slopes and the size of development.
Council is requested to provide the staff with some direction as to the
level at which it wishes to have controls applied. The explanation
below and Table I identify a number of levels at which regulations might
btions e triggered. These levels range from very comprehensive (i.e. regula-
strictivel(i e. regulations wouall
ld apply tovonl inalargetscal to least ne-
ments
on steep slopes). Since the levels relate to both steepness YeOfpslope
and size of development, these factors can be combined in a variety of
ways; the table below provides only a sampling.
In order to provide you with some idea of where these regulations might
apply, the attached map shows the general areas of Iowa City with slopes
Of 15 percent or more. This 15 percent figure is used by many communi-
ties, but there is a considerable range (from 8% to 25%) in some commu-
nities before a variety of regulations become applicable.
Grading and Erosion Control Plans
Under existing regulations the City requires plans and proposed methods
for the prevention and control of soil erosion and sedimentation for
subdivisions, Large Scale Residential Developments (LSRO) of 2 acres or
more, and for any commercial/industrial development or redevelopment of
one acre or more. These plans are reviewed and approved by the Depart-
ment of Public Works prior to final approval of subdivision plats or
Large Scale Development (LSD) plans or prior to the issuance of a build-
ing permit. Erosion control plans address the goal of minimizing
erosion and runoff problems. However, they do not speak to the issues of
the stability of steep slopes, severe alterations to the natural topog-
raphy, or to the effect of land disturbing activities in ravines.
A grading plan, which would provide information directly related to the
Issues outlined above, could be required as part of the erosion control
Plan. Additional information required for the plan would include 1)
existing and proposed contours (existing contours are already required
for site plans for subdivisions and LSDs), 2) the approximate amount of
material to be excavated and/or filled, and 3) the extent and slope of
all grading. Details Of drainage patterns are already required by
existing erosion control regulations. On steep slopes (15% or greater)
additional information on soil types and soil borings could be
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required. Grading and erosion control plans would then be evaluated
according to certain criteria or performance standards which would
address the goals of the plan requirements.
Some of the information required for grading plans is already provided
for LSDs and subdivisions. The Council may choose to require addi-
tional information to meet the goals of a grading plan. The other
question to be answered is whether grading and erosion control plans
should be required for small developments(which require only building
permit approval) and for any grading activity whether immediately asso-
ciated with development or not. Currently grading can be done without
any City permit.
Levels at which grading and erosion control plans could be required
1. For all movement of earth in excess of 50 cubic yards. (UEAHC recom-
mendation)
This would permit gardening, construction of patios or home addi-
tions, repairs, etc. without a plan. (Certain types of land dis-
turbing activities such as the digging of cemetery graves, the use
of sanitary landfill sites, and agricultural activities should
probably be exempt.)
2. For all movement of earth in excess of 500 cubic yards, except where
the maximum grade between property lines exceeds 10 percent, gradin
plans would be required for movement of earth in excess of 50 cubic
yards.
This would permit construction of most single-family homes and many
small commercial buildings without submission of a grading and
erosion control plan except on steep slopes.
3. Certified grading and erosion control plan required for all movement
OF—earth earth on slopes of 15 percent or more.
Certification by a registered engineer would be required to insure
the adequate control of erosion and other adverse impacts on steep
slopes.
4. Certified grading and erosion control plan required for all building
permii applications for new construction or expansion on slopes 15
percent or greater.
This means grading and erosion control plans would only be required
if construction was going to take place. Grading of a property
prior to application for a building permit would therefore not be
required to have grading and erosion control plans.
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5. Grading and erosion control plan required for all subdivisions, PDH
plans and large scale developments (two acres or more).
Development requiring a building permit only (e.g. "the Cliffs")
would not be subject to the requirements. On slopes 15% and greater
certification of plans could be required. Implementation at this
level would mean adding requirements for information to existing
regulations.
6. Certified grading and erosion control plan required for all large
sca a evelopments on slopes of 15 percent or more.
This would be the least restrictive regulation applying only to
large developments on steep slopes.
Table I shows how each of the levels described would affect different
types of developments which require the movement of earth.
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TABLE 1: LEVELS OF GRADING AND EROSION CONTROL REQUIREMENTS
Extent of Element '
X • Required
0 • Not required
s. an 9raaing
in excess of 50
over 500 cu.yds.;
on slopes 1St'
4. All building
S. All subdivi-
6, pp
Type of Oevelopnent
cu.vds.
except on slopes
10% or more.
or more certi —
fled plans.
pemdts on slopes
1st
Bions, LSDs/
LSOs on
slopes 15i or
1.
Single family on
Slopes -15%
or more.
POHs.
more
individual lots
Slopes -15%
x
p
%
X
0
t
0
0
X
0
0
0
0
2. Multi -family 3-29
units
a
X
0
0
0
3.
Multi -family
Slopes -15%xA
X
t
%
D
30 or more units
na
%
4.
Subdivisions/PDN
Slopes -15%
%
t
%
%
%
(less than 2 acres
MIN%
Slopes -15%
%
X
%
%
0
5. •LSNRDs
(2 acres or more)
ij;{
Slopes -
X
%
%
i
%
%
X
6. •LSRD/PDH -
(2 acres or more)
Xis%
%%
%
X
%
7.
•
Slopes -15%
%
%
Industrial/
Industrial
X
0
0
%
0
1-1.99 acres
X
X
%
X
0
0.
Commercial/
Slopes -15%
%
X
Industrial
�5
%
0
0
%
under 1 acre
%
x
0
9.
Grading only
Slopes -15%
(m fmnedlate
♦15
development)
%
%
%
—
0
0
0
X • Required
0 • Not required
W,
7/9/85
RECOMMENDATIONS TO THE CITY COUNCIL
CONCERNING SITE DEVELOPMENT PLANS
In order to implement the policy recommendations of the Urban Environment Ad
Hoc Committee which were adopted by the City Council of Iowa City on April 9,
1985, the Committee recommends that the Council consider the site development i
plan process as a means to preserve and enhance Iowa City's environmentally
sensitive areas. As with the Committee's recommendations concerning land
disturbing activities, the purpose here is to recommend general concepts the
Committee wishes to see included in future regulations. .Specific ordinances
are not being presented for consideration at this time.
I. Regulations of Development Through a Site Development Plan Process
Goal
The goal of the site development plan process is to identify environmental-
ly sensitive natural features located on land proposed for development so
that those features may be protected and enhanced through sensitive and
innovative development.
Objectives
The objectives of site development plans include:
1. The preservation of natural topographic features including steep
slopes.
2. The preservation of natural ecosystems and vegetative cover (such as
woodlands) which contribute to the climatic and aesthetic nature of the
City.
3. The preservation of natural drainageways and floodplains.
4. The encouragement of innovative and alternative approaches to conven-
tional flatland practices in order to minimize grading, cut and fill
operations, as well as the amount of impervious surface.
IIRecommendation - The Urban Environment Ad Hoc Committee recommends that the
following procedure be included in regulations designed to protect and
enhance environmentally sensitive areas.
Site Development Plan Process
A. Protected Natural Features
The first step in the site development plan process is to define the
natural features that are to be protected. These Will include:
1) Steep slopes (15% or greater).
2) Ravines.
3) Drainageways.
4) Floodways and floodplains.
5) Certain trees, groves of trees and woodlands as defined in Attach-
ment A.
61 Unusual geologic features, e.g. exposed limestone bluffs.
7 Prairie (to be further defined)
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B. Natural Features Checklist
I IThe next step is the requirement that a natural features checklist be
submitted with all preliminary subdivision, LSRD, and LSNRD plans and
with building permit applications for all development other than single
family or duplex development on individual lots. The checklist shall
include a list and/or site plan of natural features present and an ap-
proximate percentage of land occupied by each one.
It will be the responsibility of the developer to submit the checklist
and the responsibility of City staff to perform inspections of sites as
it deems necessary to ensure the integrity of the checklist. If
possible, the City shall maintain an inventory of undeveloped environ-
mentally sensitive lands to assist developers and City staff with such
checklists.
C. Site Development Plan Required
The protected natural features will be assigned a numerical value
dependent upon the extent and need for protection. If this point total
reaches a certain limit, or where 25% or more of the site is occupied
by protected natural features, a detailed site development plan must be
submitted for review.
D, General Standards for Site Development Plan Review
The site development plan will be reviewed to make sure that it
complies with the following general standards:
1) The development will promote the goals and objectives of the site
development plan process.
2) The development will not cause a serious and lasting degradation of
the environment.
3) The development will guarantee the conservation and protection of
irreplaceable natural resources from pollution, impairment or
destruction by minimizing alteration of the natural site features
to be preserved.
4) The development will blend into the natural setting of the land-
scape for orderly growth and development,
5) The development shall strive for diversity and originality in lot
layout and siting of buildings in order to achieve the best
possible relationship between the development and the land.
E. Specific Advantages of a Site Development Pian
1) It provides a mechanism for identifying natural features to be
protected.
2) It can strongly influence the redirection of development away from
natural features.
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3) It can give the City some control over development on land that
does not require a grading permit.
4) It can deal directly with the issue of preservation of 'trees and
other natural vegetative cover in subdivisions, LSRUs, LSURDs, and
on individual lots.
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3) It can give the City some control over development on land that
does not require a grading permit.
4) It can deal directly with the issue of preservation of 'trees and
other natural vegetative cover in subdivisions, LSRUs, LSURDs, and
on individual lots.
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Attachment A
Protected Trees, Groves of Trees and Woodlands
A. Trees
The following trees, full-grown and maturing, which are native to the Iowa
City area, are considered important examples of their species as defined by
trunk diameter and, once damaged or destroyed, could not be irmediately
replaced, or, in some cases, may be impossible to replace.
Species Trunk Diameter at 4 Feet
Aspen (Quaking) 3"
Aspen (Big Tooth) 10"
Ash (Green/White) 10"
Basswood/Linden (American) 6„
Birch (River) ,
'Butternut 6„
Cedar, Red „
"Cherry (Wild Black) 3„
Oogwood (Pagoda) 10"
Elm (American) 10"
Hackberry
'Hickory (Shagbark, Butternut, Mockernut) 6"
'Hop Hornbeam 4"
*Hornbeam 10"
Locust (Black) to..
Locust (Honey) 10"
Kentucky Coffee Tree 10"
Maple (Black, Sugar) 6"
*Oak (White, Burr)
Oak (Northern Red, Pin, Northern Pin, Swamp White, 10"
Shingle, Chinkapin, Black) B"
Pine (Eastern, White) 10"
Plain (American) 4„
Redbud 41
Serviceberry B„
*Walnut (Black)
Trees marked with * have a high priority for protection because of their
stature, relative rarity or the difficulty of reestablishing them if damaged
or composite destroyed. unk size willswith be calculatedlaccording'touanhas acceptedees, a
formula
2. Grove of Trees - Any stand of trees an an area of 1/4 acre or more consisting
o e g t or more trees with a 10" or greater caliper which are on the list of
protected trees.
3. Woodlands - An area of one-half acre or more containing at least 100 growing
trees which are on the list of protected trees.
Recommended Performance Standards
1. Such standards should require that the maximum number of trees possible be
preserved. pp
agel
2. ofrtheoves groveftrees and or woodlandshouldbe required to remaior some n in appropriate
ralestate.
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II. Regulations requiring Site Development Plans for Environmentallv Send_
•f,u
The basic goal in regulating development through review of site develop-
ment plans, is to protect and enhance environmentally sensitive areas
such as woodlands, floodplains and hillsides, and to provide a tool for
innovative development that is sensitive to these features. As is the
case for land disturbing activities, these regulations could be trig-
gered at various levels.
The regulations would require submission of a natural features checklist
with applications for development at whatever level the Council deter-
mines to be appropriate (e.g. for all building permits or only for large
scale developments). The natural features checklist would be reviewed
to determine if a site development plan is required. Please consult the
recommendation concerning site development plans dated 7/9/85 included
I in this packet for an explanation of the natural features checklist. If
no such plan is required, building permit or development/subdivision
plan review would proceed normally. If protected natural features are
present beyond a certain threshold (e.g. more than 15% of a site is in
the floodplain) the developer would be required to submit a site devel-
opment plan and to comply with certain performance standards. Site plan
review for LSD/PDH plans would continue in accordance with current
procedures.
III. Additinnal
- - - � �� oiw uevelo mens Ions.
The extent of additional activities, and thereforecosts, will depend on
the level at which Council determines that these regulations should
apply. The list below assumes that regulations will apply to all devel-
opment from the building permit process up and to grading for which no
permit is currently required.
A. Developer
I. Grading plan
- For excavation, fill and small developments, there would be an
added cost of providing contours, slopes and drainage patterns.
- For large developments there would be little added cost,
because information is already required for detailed construc-
tion plans.
2. Erosion control plan
- For small developments, there would be little added cost since
plans can be very simple, for development on steep slopes
there would be some additional cost since more complex plans
i would be required,
d
- For large developments, there would be no added cost.
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3. Certified grading and erosion control plan
- Considerable cost would be added. Estimates by local engi-
neering firms range from $200 to $5000 depending on the size
of the development and the severity of conditions (slope and
soils).
4. Natural features checklist
Additional information on site plans wot(�1) be required. In_ I
most cases information is readily available and does not
require a professional; a small added cost would result.
5. Site development plan
i
- These plans are already required for LSDs. There would be
some extra cost for small developments.
B. City f
1. Grading and erosion control plans
i
Public Works Department:
a. Additional review of plans would be required for excavation
and fill and small developments on steep slopes. LSD erosion
control plans are already reviewed.
b. Inspection: Additional costs would be incurred in inspect -
Ing grading since currently only erosion control measures
are inspected.
Cost: Approximately $15 per hour.
Housing and Inspection Services Department:
If the Public Works Department does not carry out the inspection
for instance at the building permit level), an additional site
inspection at time of grading could be required. Cost: Minimum
$15 per inspection.
2. Natural features checklist
PPD/Public Works:
a. A review of the checklist and determination of need for a
site development plan would be required. Evaluation of the
checklist would be potentially the most time-consuming
element. However, an inventory of most environmentally
sensitive areas in Iowa City already exists and would speed
up the process.
b. Review of site development plan: There would be some in-
crease in staff time required depending on how many addi-
tional site development plans are processed and the extent
of the performance standards.
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This cursory review of the cost of the most ccmprehensive regulation
assumes that the City will absorb some of the cost of the regulatory
process. This burden may be shifted to the developer by requiring that
all plans and inspections be certified by a professional hired by the
developer, a review and inspection done by the city staff would be
minimal. The sharing of costs of compliance is another area in which
the staff would like guidance from the Council.
IV. Applicability
In order to provide some idea of how many building permits/LSOs/subdivi-
sions might fall under these regulations, the 1984 applications have
been reviewed.
Assuming that all slopes of 15% or more would be regulated and natural
features as listed in the UEAHC recommendations are protected, the
attached table shows the total number of applications and approximately
how many of these would be affected by the proposed regulations. This
table does not include the impact of the most comprehensive regulation,
i.e, grading plans for all movement of earth in excess of 50 cubic
yards; the City has no record of such activities.
1301
I
Number of Plans Submitted for Approval and Building
Permit Applications for 1984
# with steep
slopes and # with pro -
Total # protected natural tected natural
Tvoe of Development Applications features * features only **
8 3 2
Subdivision 5 2 1
9 1 2
LSNRD 84 3 7
Building permits
(multi -family & commercial) 137 13 18
Building permits
(single-family & duplex)
I *Most areas with steep slopes also have other protected natural features such as
woodlands, drainage ways, ravines. These areas are all in First & Rochester Subdi-
visions or Buresh Avenue area.
**For almost all developments the protected natural features were floodplains and
drainage ways.
/3�9
I
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