Memorandum
City of Lawrence
Public Works
TO:
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Dave Corliss
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FROM:
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Matt Bond, P.E. - City Stormwater Engineer
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Date:
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January 11, 2008
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RE:
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Chad Voigt
letter – Airport
Business Park
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The following letter was received
from a Lawrence
resident. It was written by the former
City Stormwater Engineer Chad Voigt
concerning the proposed Airport Business Park,
North Lawrence development in general and the North
Lawrence Drainage Study. Although staff
does not disagree with the technical analysis provided by Mr. Voigt, the letter
expresses opinions regarding several policy issues. City staff has not addressed the opinions
expressed but has tried to provide information to clarify points of concern
mentioned in the letter. Staff
recognizes the unique characteristics of the watershed and how the
corresponding stormwater drainage affects North Lawrence. After each point expressed in the letter is an
expansion and clarification relating to the referenced topic. Excerpts from Mr. Voigt's letter are in
italics.
November 18,
2007
To: Bob
Lominska
From: Chad
Voigt
Bob,
These are my thoughts on the proposed Airport
Business Park,
and North Lawrence development in general. The
North Lawrence Drainage Study identifies huge
flood control projects that will be needed if the watershed develops as shown
in conceptual land use plans. Developers
will not be able to pay for these projects, so the development potential of
this land should be reevaluated. The City’s Comprehensive Plan should be
updated to minimize the need for flood control projects. Land uses should be
downgraded to minimize runoff, preserve soils and reduce public expense.
The Airport Business Park
would be a leap toward the conditions forecast in the North
Lawrence Drainage Study. If the development proceeds, these are
the points that need more in-depth review and discussion:
Code
Requirements
It seems there is a lack of understanding of the regulatory
weight of the North Lawrence Drainage Study.
All developments in the City are required (stormwater code and floodplain regulations)
to provide studies and plans to prevent downstream stormwater impacts. For North Lawrence landowners, the scale of the floodplain
and lack of viable management options mean that the required studies are beyond
the resources of isolated developments. The
North Lawrence Drainage Study, paid for by the
public, gives developers the technical material needed to complete a valid
development proposal. Developers can use the North
Lawrence drainage Study, or provide an equivalent independent
study. Either way, each development is required by code to prevent downstream
impacts.
The submittal for the Airport
Business Park
conforms to both the City’s Stormwater Management Criteria as well as current
floodplain regulations. It should be
noted that only the northwest portion of the proposed development lies within
the 100 year floodplain. This area is
being slated as an open tract and will not be developed. This open tract as well as three other
locations (see the attached map) will also be platted as floodplain overlay
district. The applicant for the Airport Business Park
utilized the option of using the North Lawrence Drainage Study for the required
Hydrologic & Hydraulic Study. As the
letter points out the drainage study was paid for by the public and provides not
only a cost effective guideline for development but also provides a consistent guideline. The entire watershed was modeled in the North
Lawrence Drainage Study (NLDS). Separate
drainage studies by individual developments would not necessarily look at the effect
on the entire watershed.
The North Lawrence Drainage
Study identified $16.2 million in reconstruction projects that are needed to
provide a minimal level of service to existing residents. At an average of
$14,000 per acre, many of these projects will likely never be completed. (The
City is still burdened with over $40 million in stormwater projects needed
elsewhere, at a cost of roughly $6,000 per benefiting acre.)
The study also identified $24.8 million in flood control projects
that will be needed if the watershed develops as shown in conceptual land use
plans. With this in mind, it’s critical that new developments add to the
solution rather than adding to the problem. New developments in North Lawrence should fully fund their internal drainage
systems, as well as the additional projects needed to offset downstream
impacts. Public funds should be directed at correcting existing drainage
problems, and should not be directed at managing conditions created by new development.
The 1996 Stormwater Master Plan identified 41 projects that would
reduce or eliminate flooding. The 1996
plan split these projects into three groups with group one projects being the
highest priority. Of the eleven group
one projects listed seven have been completed.
There are still approximately $40 million worth of potential uncompleted
projects listed in the plan. It should
be noted that five of the projects listed in the 1996 Plan are in North Lawrence.
The Airport Business Park
proposal references the North Lawrence
Drainage Study; however I could not find any discussion of downstream impacts
or proposed flood control measures. In
lieu of a discussion of actual impacts, the development should be expected to
pay some share of the $24.8 million grand total. Based on a proportion of the
undeveloped watershed area, this development would need to contribute $449,000.
It appears that this amount would be lower if actual impacts are taken into
account.
The Airport
Business Park
does in fact require $385,050 worth of improvements. The development will require that two of the
channel improvements listed in the NLDS be constructed. These two channel improvements will increase
the capacity of the Maple Grove
drainage channel. In addition to the channel improvements a
cross road pipe under E. 1500 Road/ 7th
Street will also be required.
Maple Grove Drainage
58 acres of the proposed business park currently drains to the Maple Grove drainage
channel; which flows south to the City’s pump station on 2nd Street. This system is already
overloaded, and additional runoff would increase flooding of surrounding
properties. The business park development proposes to minimize this impact by
diverting developed runoff east to the airport property. This will require significant
fill along the west edge of the development, and construction of a drainage
system to deliver flow to the east.
This intent should be clearly identified on the preliminary
plat, including easements and proposed pipe layouts. The development should
fully fund the drainage system needed within the platted area. The development
should also fully fund the system needed to divert runoff to the east, to an
acceptable point of discharge on the airport property. If there will be any discharge
of developed runoff to the west, this should be specifically quantified so that
impacts to the south can be determined and addressed by the developer.
Under existing conditions there are actually 105 acres that drain directly
as well as indirectly to the Maple Grove
drainage channel and then south to the pump station on 2nd Street. Existing topography drains 58 acres of the
proposed development directly into the Maple
Grove drainage channel. Present conditions also enable an additional
47 acres to drain south along the west side of E. 1500 Road/7th Street and
eventually into the Maple Grove
drainage channel. The 47 acres of
drainage that currently run south into North Lawrence will be rerouted through
a pipe under E. 1500 Road and eastward into a slough that drains into Mud
Creek. The pipe along with channel
improvements along the Maple Grove
drainage channel will minimize the overall effects to the 2nd Street Pump Station.
Tributary A Impacts
Most of the proposed business park drains east to the airport,
specifically to Tributary A which flows under Airport Road and East 1600 Road
before flowing south under Highway 24/40 and Interstate 70. As with most North Lawrence drainage systems, Tributary A is very
flat. Runoff from the business park development will increase the depth and
duration of standing water adjacent to the airport runway. Further downstream,
easements will eventually be needed where runoff increases standing water on
existing farm land.
The North Lawrence Drainage
Study identifies two bridge replacement needs on Tributary A, one at East 1600
Road and one at Highway 24/40. Flooding of East 1600 Road has been a concern in
the past because it affects access to Grant School.
Based on land area, the proposed business park will generate 19%
of the need for the $477,000 bridge at E 1600 Rd, and 13% of the need for the
$326,000 culvert at Highway 24/40 (2005 cost estimates). The development should
pay for its proportional share of these downstream improvements. If the
business park is built prior to these improvements, the increased runoff will
lead to more frequent flooding of both roads. The City should identify the
intended schedule for completion of these projects.
The Airport
Business Park
proposes to drain 86 acres to Tributary A.
Under existing conditions 39 acres currently drain to Tributary A. An additional 47 acres of drainage would in
fact be added to the tributary.
Implementing the proposed improvements as noted above would be a
challenge considering both structures are located in the County, one of which
is on a KDOT maintained highway. Douglas
Co. and KDOT would need to participate in decisions relative to these
structures.
Land Use
Planning
In addition to the high cost of managing the North
Lawrence watershed, landowners and the City should recognize the
cost of a future catastrophic river flood. The Corp of Engineers designed the Kansas River levee and reservoir system in the 1960’s to
control a specific major flood, with the explicit warning that larger floods
will eventually occur. Eventually the river will top the levee, and the impacts
in North Lawrence will be similar to the
aftermath of the 1951 flood. The reservoir system was never fully completed,
and climate change will likely increase the magnitude of possible flood events.
These facts should be recognized in the decision to invest public or private
funds in the area.
It has always been a possibility that the Kansas
River could overtop the levee in the event flooding exceeded the
design criteria for the levee. It is
also possible for the upper reach of the Maple
Grove drainage channel to experience an intense amount
of rainfall. Both of these scenarios
would cause severe flooding, but the chances of these events happening are
statistically low. The 1993 flood resulted
from a series of events including saturated soil conditions, higher water
surface elevations on streams and rivers culminating shortly thereafter with an
intense period of precipitation. In
other words it was the “perfect storm” immediately following the perfect
conditions for flooding. Similar
conditions were seen on the Kansas River just this past May of 2007; however
the lower reaches of the Kansas River did not
receive high amounts of rain at the exact same time.
Since the 1951 flood several flood control structures have been
constructed on the upper reaches of the Kansas River. The US Army Corps of Engineers constructed
the following dams in the early 1960’s: Wilson, Tuttle Creek, Milford and Perry. The Bureau of Reclamation constructed the
following dams: Norton(Keith Sebelius), Kirwin, Lovewell, Glen Elder and
Webster. Cedar Bluff was nearing
construction completion in 1951. Based
on research and the best information available all indications point to a
completed reservoir system.
Native soils are an asset to landowners in North
Lawrence. The sandy-loam, high-infiltration soils reduce runoff
and relieve flooding. Covering these soils with impervious surface increases the
volume of runoff more dramatically than in heavy upland soils. Building on
these soils also permanently eliminates their agricultural value. The Eudora
silt loam and Rossville silt loam soil units are both identified by the USDA as
crop capability class 1, prime farmland. These factors are not considered in
current land use plans. The City should plan for the conservation of these natural
resources wherever possible.
The City has taken steps to preserve the high-infiltration soils of North Lawrence by the adoption of Ordinance 7100. City Code Section 20-1204(e)(2)ii limits the
amount of fill placed upon developed lots within the floodplain. Prior to its implementation land owners would
bring enough fill to cover the entire lot and raise it out of the floodplain. The new policy outlines how much fill can be
placed on the lot by setting guidelines for setbacks and corresponding side
slopes. This policy allows for
preservation of high-infiltration soils and as well as floodplain storage
capacity.