Attachment 1- Pervious Pavers (062617 cc ws pp KFS) w
CITY OF ClIANIIASSEN
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MEMORANDUM
TO: Todd Gerhardt, City Manager
FROM: Paul Oehme, Director of Public Works/City Engineer
DATE: September 25, 2017
SUBJ: KFS: Research Policies and Potential Consequences for the Allowance of
Permeable Pavers in the Equation for Hard Cover Allowance
DISCUSSION
Annually,the city receives requests from residents that wish to install a patio or other hard cover
on their property but the hard surface coverage threshold is sometimes already at the maximum
allowed by code. Patios are considered hard surface and would add to the total hard surface
coverage of the property.
Hard Surface/Lot Coverage Percentage as PUD
City Code (Chapter 20 - Zoning/Article VIII. Planned Unit Development District. Division 1.-
Generally. Sec. 20-505 - Required general standards, (e)) illustrates by table the following:
Hard surface coverage shall be limited as follows:
Comprehensive Plan Designation Hard Surface Coverage (%)
Low or medium density residential 30
High density residential 50
Office 70
Commercial (neighborhood or community) 70
Commercial (regional) 70
Industrial 70
Mixed use 70
According to Code, individual lots within PUD's may exceed these standards if the average
meets these standards.
Hard Surface/Lot Coverage Percentage by Land Use Classification
Most directly related to the policy implications of addressing PICP, "maximum lot coverage" as
a percent of the lot.
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Todd Gerhardt
KFS: Allowance of Permeable Pavers
September 25, 2017
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Maximum Lot Coverage by Land Use Classification
Land Use Classification by District Maximum Lot Coverage by Percentage
"A-2" Agricultural Estate* 20
"RR" Rural Residential* 20
"RSF" Single-Family Residential* 25
"R-4"Mixed Low Density Residential* 30
"RLM" Residential Low and Medium Density* single-family dwelling, 35
two-family dwelling, 40
townhouse or multi-family dwelling 50
"R-8" Mixed Medium Density Residential* 35
"R-12"High Density Residential* 35
"R-16" High Density Residential* 50
"BN"Neighborhood Business 65
"BH" Highway and Business Services 65
"CBD" Central Business No maximum
"CC" Community Commercial 70
"BG" General Business 70
"BF" Fringe Business 40
"OI" Office and Institutional 65
"IOP" Industrial Office Park 70
day care facilities 65
Shoreland Management District single-family residential 25
medium/high density residential 35
industrial zones within Lake Susan
Shoreland District 70
*Please be apprised that City Code (Chapter 20-Zoning, Article IV. - Conditional Uses. Division
3. -Standards for Agricultural and Residential Districts. Sec 20-254. - Churches (4). states, "No
more than 70 percent of the site is to be covered with impervious surface and the
remainder is to be suitability landscaped in conformance with Article XXV."
To get around the hard cover coverage requirement, property owners have asked to use patio
systems that allow water to infiltrate into the soil to reduce runoff. Permeable pavers are the
most previlent system that property owners have asked to be used. The City Code does not
recognize these systems as permeable. Property owners would have to go through a variance
process to have these systems approved.
Todd Gerhardt
KFS: Allowance of Permeable Pavers
September 25,2017
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Staff has researched how other communites handle pervioius pavers for residental use in hard
cover surface considerations. The attached spreadsheet shows the findings.
Staff has been concerned that if allowed in residential areas, the systems may not be installed
properly and not be maintained as needed. Staff does not have the resources to check back to see
if the permeable pavers are working as intended. If they are not working as intended, what
should the recourse be? The city does allow these systems in special situations for commercial
or industrial areas however,plans have to be submitted and approved and a maintenance
agreement signed.
There were three main potential options to consider for residential areas:
A Continue to define pervious pavers as impervious surface, with engineering and literature
to support that policy.
A Allow the conditional use of pervious pavers with engineering and literature to detail the
conditions of use (e.g., engineering and maintenance standards, alternative management
standards).
• Allow the use unconditionally.
There are several purposes for regulating and limiting impervious surfaces. Traditional city
planning, zoning and code requirements set limits of impervious surfaces by land use
classification to encourage infiltration and natural groundwater recharge,reduce urban flooding
and solar heat gain, limit overall hardscape, and provide green space.
Federal, state, and regional regulations have been enacted to manage stormwater in urbanized
communities including but not limited to the requirements of the EPA Clean Water Act,National
Pollution Discharge Elimination Systems (NPDES), and specifically Municipal Separate Storm
Sewer Systems (MS4)requirements.
In Minnesota,watershed districts (WD) and watershed management organizations were created
to manage and protect the water resources within their defined hydrologic boundary. The
Minnesota Legislature authorized the creation of watershed districts in 1955, through the
Watershed Act, for the statutory purposes to conserve the natural resources of the state by land
use planning, flood control, and other conservation projects for the protection of public health
and welfare and the prudent use of natural resources. Further, in 1982,the Minnesota
Legislature approved the Metropolitan Area Surface Water Management Act, which requires
local units of government in the Seven-County Metro Area to prepare and implement
comprehensive surface water management plans. Both the WD and the city have an interest in
water quantity and quality and have adopted plans and rules that address a variety of water
management concerns.
More discussion with the WD would be need to see if allowing permeable pavers would be
acceptable and comply with their rules.
Todd Gerhardt
KFS: Allowance of Permeable Pavers
September 25,2017
Page 4 of 8
Pervious Pavers Defined
The MPCA Stormwater Manual defines the more encompassing definition of permeable
pavement as follows: Permeable pavements allow stormwater runoff to filter through surface
voids into an underlying stone reservoir where it is temporarily stored and/or infiltrated. The
most commonly used permeable pavement surfaces are pervious concrete,porous asphalt, and
permeable interlocking concrete pavers (PICP).
The Interlocking Concrete Pavement Institute(ICPI) describes permeable interlocking concrete
pavements (PICP) as: PICP consists of solid concrete units molded with joints and/or openings
that create an open area across the pavement surface. The openings allow water from storm
events to flow freely through the surface into an open-graded base where it is collected and
stored before it infiltrates into the underlying soils. For low-infiltration rate soils, drain pipes
are often placed in the subbase to drain excess water, thereby functioning as a detention facility
with some infiltration.
Uses and Limitations of Permeable Interlocking Concrete Pavements (PICP)
PICP has become the preferred permeable pavement option over pervious concrete and asphalt
applications in recent years due in part to the use in smaller residential or retrofit applications,
and lower material and installation costs and maintenance. Research has demonstrated that PICP
is an effective method for reducing stormwater runoff and pollutants from urbanized areas.
Properly designed, installed, and maintained PICP can have design life surface infiltration rates
exceeding 100 in./hour according to industry literature.
PICP are typically used in areas with light traffic at commercial and residential sites such as low-
speed roads,parking lots, driveways, sidewalks,plazas, and patios. Stringent design, installation
and maintenance is imperative to ensure proper performance.
All the WD's recognize permeable pavement as a viable BMP to reduce volume and pollution.
Many offer cost-share opportunities for their installation. However, complicating factors in the
blanket use of PICP in the city are the varying rules and standards across the WDs pertaining to
the design, installation, and maintenance of permeable pavement and PICP specifically. Each
WD has its own specific rules, standards, and exemptions. Developing a city-wide one-size-fits-
all set of engineering and maintenance standards for PICP is problematic. Therefore, the first
step is to address the use of PICP in City Code if PICP are approved.
Current City Code Definitions that Influence the Use of PICP
A key issue that influences the use of PICP in the City Code is the varying definitions and
regulations of impervious surface,hard surface coverage and lot coverage.
City Code (Chapter 1- GENERAL PROVISIONS/Sec. 1-2. Rules of construction and
definitions) defines impervious surface as: any material that substantially reduces or prevents
Todd Gerhardt
KFS: Allowance of Permeable Pavers
September 25,2017
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the infiltration of stormwater. It shall include, but not be limited to, gravel driveways,parking
area, buildings, and structures.
City Code defines:
A Hardcover as: the definition of impervious surface.
A Lot coverage as: that portion or percentage of a lot that is covered by impervious
surfaces.
A Structures as: anything manufactured, built, constructed, erected, or a portion thereof
which is normally attached to or positioned on land, whether temporary or permanent in
character, including, but not limited to, buildings,fences, sheds, advertising signs, dog
kennels, hard surface parking areas, boardwalks,playground equipment or concrete
slabs.
The terms "hard surface" and"hard surface coverage" are not defined within Sec. 102 Rules of
construction and definitions,however the terms are interspersed throughout the Code.
Watershed District Definitions that Influence the Use of PICP
The following are definitions of impervious,pervious and structure for WDs within the
jurisdiction of the city. In instances where definitions are not provided, the specific entity has
not defined the term.
The Minnehaha Creek WD defines impervious as: surfaces that are compacted or covered with
a layer of material such that it is highly resistant to infiltration of runoff including but not limited
to gravel, rock, asphalt, concrete, and non pervious paver systems.
The Riley Purgatory Bluff Creek WD defines impervious surface as: any exposed surface that
has been compacted or covered with a layer of material, or is likely to become compacted from
expected, use, such that it is highly resistant to infiltration.
The Carver County WMO defines impervious as: a constructed hard surface that either
prevents or retards the entry of water into the soil and causes water to run off the surface in
greater quantities and at an increased rate of flow than prior to development. Examples include
rooftops, sidewalks,patios, driveways,parking lots, storage areas, and concrete, asphalt, or
gravel roads.
The Minnehaha Creek WD defines pervious as: surfaces that are readily penetrated or
permeated by rainfall or runoff resulting in infiltration and reduced runoff.
The Carver County WMO defines pervious as: a surface that is readily penetrated or
permeated by rainfall or runoff resulting in infiltration and reduced runoff.
The Riley Purgatory Bluff Creek WD defines structure as: any impervious building or other
object that is constructed or placed on the ground and that is, or is intended, to remain in place
for longer than a temporary period.
Todd Gerhardt
KFS: Allowance of Permeable Pavers
September 25,2017
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The Carver County WMO defines structure as: anything constructed or erected on or
connected to the ground.
Current City Code that Influences the Use of PICP
Relevant"hard surface" or"impervious surface"references and standards by zoning
classification are cited here and in the Appendix. To ensure code changes are made to
accommodate the use of PICP in the city, City Code sections should be thoroughly reviewed.
City Code (Chapter 18 - Subdivisions,Article III. - Design Standards. Sec. 18-60. - Lots (j)
states, Proposed house sizes shall be shown on the subdivision plan and shall be designed to
accommodate residents' future house expansion(e.g.,porches) and accessory structures (e.g.,
decks and patios) as well as the driveway and sidewalks to building entrances. If house plans are
not known, then a 60-foot by 60-foot building pad and a 30-foot wide access driveway shall
be used. The maximum permitted impervious surface shall be calculated for each lot and
the permitted houses and structures shall be limited to those sizes.
Design, installation, and maintenance standards would be at the discretion of appropriate city
staff and/or input or deferment to the corresponding WD or WMO. The MPCA Stormwater
Manual suggests using the design, installation, and maintenance guidance for PICP as referenced
by the Interlocking Concrete Pavement Institute(ICPI). The ICPI's website is www.icpi.org. It
includes information for design professionals and installers regarding industry standards and
specifications, installation guidelines and maintenance. Staff would recommend that if
permeable pavers are allowed a certified installer shall be required to pull the permit. Many
certified installers are available in the metro area.
Shoreland Management and Bluff Creek Overlay Districts would need to be addressed in a
different manner if ICPI are allowed. Staff recommends that as a permit requirement, a
recordable easement or maintenance agreement be required that assures the owner of the
property in which PICP was installed as a permitted accessory use is properly maintained as a
pervious surface.
Planning Department Review
Planning staff has reviewed the findings from the research that has been completed. A brief
discussion of these issues and Planning staff's recommendations are presented below.
Issue 1: Lot Coverage and Impervious Surface
Unlike the terms "hardcover" and "impervious surface", "lot coverage" and "impervious
surface" should not be seen as interchangeable. When the City Code uses the terms hardcover
and impervious surface, it is primarily in a context of stormwater management; however, the
term lot coverage is has impacts on the intensity of land use, viewscape, and greenspace, as well
as on stormwater runoff. Treating impervious surface and lot coverage as synonyms would
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KFS: Allowance of Permeable Pavers
September 25,2017
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mean that setbacks would be the only limit on the intensity of land use.
In the case of industrial and commercial districts, this would allow for larger parking lots and
buildings. Staff examined a site within the Southwest Corporate Center that is limited to 70%lot
coverage. If lot coverage was defined solely as impervious surface and pavers were not
considered impervious surface, the owner could increase the parcel's maximim building size
from about 268,000 square feet to approximately 329,000 square feet and reduce the greenspace
on site from 30 percent to about 10.5 percent. This would create a substantially different visual
impact for surrounding land users and increase the development's traffic impact.
In residential areas,this would mean that by substituting traditional impervious surfaces with
pervious pavers, a builder could construct a house where only roofed structures counted towards
lot coverage. This would allow for the construction of homes with a substantially larger
footprint, as lot coverage currently used for driveways and patios could all be allotted to the
house, and would also make it easier for large sheds to be constructed on small residential lots.
Staff examined a property on W. 65th Street zoned Residential-Single Family and determined
that if lot coverage was defined solely as impervious surface,the owner could reduce the
property from having 75% greenspace to approximately 40% greenspace. Staff conducted the
same exercise for a property zoned Residential Low and Medium Density on Strawberry Lane
and discovered that the lot's greenspace could be reduced from 65%to around 31%. In both
cases,the owners would be able to add 320 plus square foot sheds in their rear yards. The size of
these accessory structures, overall intensity of property use, and visual impression of these
residences would be very different from what is currently typical for the city's small lot
residential neighborhoods.
Since the city uses lot coverage as a major tool for limiting the intensity of development and
preserving onsite greenspace, any change that completely exempts a category of materials from
counting towards lot coverage will have many unintended consequences.
Issue 2: Regulating through Conditional Use Permits
Conditional Use Permits need to go before both the Planning Commission and City Council.
Additionally, staff performs annual inspections of all conditional use permits in order to ensure
that properties are complying with the conditions placed upon the permits. Categorizing
pervious pavers as conditional uses would result in a significantly increased workload for both
the Planning Commission and City Council, and performing the required inspections would
exceed the capacity of the city's staff.
Properties located in commercial and industrial districts can already utilize pervious pavers as
part of a stormwater mitigation strategy. These systems are evaluated as part of a development's
site plan review, and several projects incorporating these systems, for example Total Wine,have
already been approved.
Todd Gerhardt
KFS: Allowance of Permeable Pavers
September 25,2017
Page 8 of 8
Issue 3: Definitions
Planning staff is concerned that by narrowly defining pervious systems as those made up of
permeable interlocking concrete pavers,the city will not be able to take advantage of new
technologies. Adopting a broader definition of pervious would allow the city to evaluate
proposed systems based on their demonstrated capacity to facilitate stormwater infiltration,
rather than the materials used in their construction.
Summary
Planning staff agrees that pervious pavers and other similar systems are proven technologies that
are well suited for use in low traffic areas. Staff recognizes that the current lot coverage limits
on residential properties were drafted partially with the intent of limiting the stormwater runoff
generated in those zoning districts; however,the lot coverage standards were also created to
create a certain neighborhood aesthetic. Staff desires to balance these two considerations to
accommodate technologies that allow homeowners to created stormwater neutral structures,
without comprising the character of the city's residential neighborhoods.
Recommendation
Planning staff recommends that the following changes be made to the City Code if permeable
pavers are approved:
1) Residential properties should be allowed a total lot coverage of X+5%* where X is the
currently established maximum impervious lot coverage, and the 5%is pervious lot
coverage. To qualify as pervious,the system must be designed in compliance with
standards established by the Interlocking Concrete Pavement Institute(ICPI) and
installed by an ICPI certified installer.**
a. Possible phrasing: "The maximum lot coverage for all structures and paved
surfaces is 30%, of which no more than 25%may be impervious surfaces."
2) The use of permeable paver systems on industrial and commercial properties should
continue to be addressed through the site plan review process.
3) The term"pervious/permeable"be defined in the City Code.
4) The usage of the terms "impervious" and"hardcover" should be standardized throughout
the Code.
*To provide context that would allow a 15,000 square foot lot(minimum RSF lot size)to
construct a 750 square foot(25' x 30')pervious paver patio in addition to the currently permitted
3,750 square feet(25%) of impervious lot coverage.
**For other types of pervious surface technologies, a similarly credible organization's guidelines
and appropriately certified installer could be substituted.
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