21-0512 Establishment Period for Plants at Mill Creek

Question

As a result of the unique conditions of Moab's high desert climate, the design team for the Projects at Mill Creek would like to seek an exception for irrigation water usage under the Water & Ecology of Place Petal requirements.
What we would like Allowed:
Allow the Community Rebuilds team to supplement our harvested rainwater supply with municipal water for the singular purpose of establishing a xeriscaped landscape plan that is compliant with the requirements of the Ecology of Place due to the unique hydrology and municipal code in the city of Moab.
Why the Exception is needed:
The design team seeks this exception with the understanding that there are several areas of considerations that have created the circumstances necessitating this specific ask. Foremost is an advanced comprehension of the local hydrological cycles and plant establishment needs that are unique not only to the Colorado Plateau but Moab itself. While in many other climates, even those in other desert climates such as the Sonoran desert in Arizona, rainwater harvesting is a viable strategy for collecting non-potable water for plant usage, Moab exists as habitable for human civilization largely through the snow-melt run-off from the nearby La Sal Mountains. This is the primary source of irrigation for the farming that has taken place in the greater Moab valley for hundreds of years. Unfortunately, due to local code, we are not able to directly pump water from the adjacent Mill Creek to use for landscape establishment. With these parameters in mind, the landscape on site was designed to be entirely xeriscaped - needing no additional irrigation after establishment. However, due to the nature of the soils in the area, site specific soils, and needs of the native plants we are attempting to re-establish as per our good faith efforts to meet Ecology of Place requirements in a small highly dense housing subdivision, the amount of water needed to establish these plants to eventually become irrigation independent will likely exceed the amount of water we can reasonably harvest through rain during the first performance period. We plan to use all harvested rainwater we can spare for establishment irrigation, but we cannot also provide enough water for urban agriculture and native plant establishment during the performance period that is starting at the same time plants are being established. Our essential ask is that we may be allowed to use municipal irrigation water (harvested from the aforementioned snowmelt) to supplement our harvested rainwater ONLY in the establishment period of the Ecology of place compliant landscape. This is only an issue largely due to the extenuating circumstances created by the planting occurring at the onset of the performance period for reasons continued below.
Our status as an affordable housing non-profit operating under the confines of USDA loan frameworks requires Community Rebuilds to build our homes in a timely and efficient manner. The dense nature of our small subdivision project and the general lack of large storage space for materials and earthen materials required to build this project prohibited us from establishing landscape elements and plants prior to the finished construction of the houses. Peripheral space and other areas around the homes designed for plantings and Ecology of Place re establishment zones were needed for storage of materials until the homes were completed and active construction/disturbance was finished. Sensitivity to the needs of our homeowners who qualified for the affordable housing prohibits us from being comfortable extending the performance period any longer than necessary on the behalf of water requirements for planting. It is our hope that the ILFI Affordable Housing team finds this request reasonable and understands our shared consideration for the goals of the Ecology of Place & Water Petals while taking into account the unique hydrology, climate and even code concerns of Moab as a site for Living Buildings in the future.
Additional Info Provided by team:
We do have a greywater system installed. Due to Utah's code regarding greywater systems, we are not allowed to store/retain any greywater, it must go directly to the in-ground infiltration units. As such, we've placed them in proximity to the homes for their use for annual vegetable/fruit tree gardens. The plantings we are proposing an exception to supplement harvested rainwater for are native, xeriscape plant species in peripheral areas on the site that will not require additional irrigation after establishment. These plants are helping us meet Ecology of Place requirements. The Greywater system on site is being used to meet Urban Agriculture requirements. The greywater system is located near enough to some of the native plantings to allow them to flourish in later years but not enough to establish them due to unique requirements during this first growing season. The plan for establishment irrigation is to exhaust any harvested rainwater on site first, before using potable water, and then fill up buckets from the frost free spigots located on site to provide the additional irrigation needed.
Hopefully this is a sufficient explanation, please let me know if I can provide additional documentation, I have some diagrams/planting plans already submitted in the google drive folders that can provide some clarification.

Answer

Due to construction and Performance Period timeline constraints unique to the project's affordable housing status, ILFI is issuing a project-specific exception to allow the project team to supplement harvested rainwater with municipal water supply in order to establish the xeriscape plantings during the Performance Period. The performance period must extend a minimum of 3 months past the establishment period or the last use of municipal water; these 3 months must reflect a typical season in which irrigation might be needed. The project team must also provide documentation from a landscape architect, landscape designer, or other professional showing that the plants are drought tolerant and will not need supplementary irrigation after their establishment.

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