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HomeMy WebLinkAboutCUP 139Ax1; St. Elizabeth Seton Catholic Church; Conditional Use Permit (CUP) (3)05/05/2004 17: 28 619-294-4442 LINTVEDT MCCOLL ASOC T PAGE 02 - 8 17 3 s 0 c I A T PLANNING CIVIL ENGtNEERlNG . LAND SURVEYING May 5,2004 Joel King Catholic Diocese of San Diego 3888 Paducah Drive San Diego, CA 921 17 RE: CUP 139fAX11 Elizabeth Seton Catholic Church Dear Mr. Klng: P-4493 We have reviewed the proposed conditions of approval for the extension of your Conditional Use Permit (CUP). We have also field reviewed the existing site at St. Elizabeth Seton Catholic Church. The conditions of approval as written will impose current requirements for implementation of long term Best Management Practices (BMPs) on the existing site, This typically would include Site Design BMPs, Source Control BMPs and Structural Treatment Control BMPs to treat storm water run off to the maximum extent practicable (MEP). The church site is 100 percent developed. Parking lots are constructed to sheet flow to the existing public street or to limited onsite storm inlets. Due to elevation differences, parking lot drainage can not be diverted to landscape filter areas as is possible in new construction, Existlng systems can be retrofit to provide partial treatment of storm water run-off, however complete interception and treatment is not possible without major reconstruction. The regulations require treatment to the maximum extent "practicable", however 'practicabte" is not defined. In our opinion site design and structural treatment BMPs should be limited to retrofitting existing systems. The focus should be placed on source control BMPs to limit the discharge of pollutants through improved maintenance and education programs for staff and users. We suggest the following clarifications to be added to the conditions of approval. Addition of structural BMPs shall be limited to reirofitting existing facilities within the existing surface improvements. Structural BMPs that would necessitate the reconstruction of the existing parking lot or existing improvements will not be required. The conditions also specify a time frame of 6 months for approval to new BMPs and a construction time frame of 12 months. Based on our experience with designing and processing approvals of BMPs, these time frames are much too short for the complexity of this site. We suggest the time frame references be changed as follows: Design and approvals of new BMPs shall be completed within 12 months of the CUP exfension. Construction and implementation of new BMPs shall be completed within 24 months of the CUP extension. Please give ma a call if you have any questions regarding our recommendations Patricia M~COII, P.E. Cc Melissa White - Planning Commission Chairperson Cc Don Neu -Assistant Planning Director Cc Jeremy Riddle - Staff Engineer - 2810 Camino del Ria South, Suite 200 .Son Diego, CA 92108 m(6f9) 29494440 .FAX (619) 294-4442 -