Public Comments re: City of Tucson Aug 2021 Utility Manual

See latest version of the document:

This item is good, as far is it can have effect. Unfortunately it precedes any vote of elected council and is therefore void. The backward processes should not be forced upon the public. The best thing the City can do is to combine it with the TWTFO. Much of the contents of this manual would be unnecessary if there were no premise for new poles. We do that by requiring co-location, and antennas are to be so tiny, about the size of a WiFi router, so they can fit on anything so there’s no need for any new or replacement poles.

-“Utility company” discusses the project with residents and reaches an agreement,
-If no agreement can be reached, another location may be compelled.
-66 pages of regulation, many of which were previously claimed to be preempted by state law.

Contains no direction to staff to ensure compliance with federal law
Does not remove any premise for new pole.
Language is full of holes

TDLR (Too Ling Didn’t Read): An Overview

City of Tucson
Public Utility Administrative Manual
Department of Transportation and Mobility
May 7, 2021
Table of Contents
  1. Authority
  2. References
  3. Purpose
  4. Work Restrictions and ROW Management
  5. Design Coordination
  6. Utility Locations
  7. Utility Corridor Approved Locations
  8. Submittal Requirements
  9. Construction and Material Replacement
  10. SWF Guidelines and Standards
  11. Design Review Steps
  12. Construction Procedures
  13. Inspection Expectations

List of Figures

Figure 1: Small Wireless Pole (SWF)
Figure 2: Arterial Street Utility Location (per City of Tucson Technical Standards)
Figure 3: Residential Street Utility Location (per City of Tucson Technical Standards)
Figure 4: Conceptual Tree Placement Locations
Figure 5: Aerial Heights
Figure 6: Overlashing
Figure 7: Barricades
Figure 8: Erosion Exposure
Figure 9: Local Floodplain
Figure 10: Modern Streetcar
Figure 11: Sight Visibility Triangle (SVT)
Figure 12: Screening
Figure 13: Low Profile Utility Marker
Figure 14: Solid Waste Equipment Clearance
Figure 15: Type 1 Utility Pole
Figure 16: Type 2 Pole
Figure 17: Type 3 Pole
Figure 18: Type 3A Pole
Figure 19: Type 3B Pole
Figure 20: Accessory Screening
Figure 21: SWF Poles in Amenity Zone
Figure 22: Separation for Driveways and Trees
Figure 23: Pole Location at Corner Property Line
List of Exhibits
Exhibit A T-Top Modified PAG Standard Detail 216 Detail
Exhibit B Pothole Patch
Exhibit C Moratorium Patch Limits
Exhibit D Holiday Restrictions
Exhibit E Utility Waiver


The Constitution of the State of Arizona, The Tucson City Charter, Chapters 7a-D, Chapter 23, Chapter 25, and Chapter 30 of the Tucson City Code, and the Arizona Revised Statutes (ARS) Title 9, Chapters 4, 5, all other applicable federal, state and local laws, codes, rules and regulations, and the City’s police powers and authority over the public Right-of-way.

wt: and the recent ordinance this manual is pursuant to? 


All construction shall be performed in accordance with the requirements of the following
separate documents:

• Current Edition: PAG Standard Specifications for Public Improvements, and Standard Details for Public Improvements,
• Current Edition: Tucson Water Design Standards Manual,
• Current Edition: Tucson Water, Standard Specifications and Details,
• Current Edition: Pima County Regional Wastewater Reclamation Department Standard Specifications and Details for Construction
• Current Edition: Manual on Uniform Traffic Control Devices for Streets and Highways, and Amendments.
• Current Edition: Arizona Supplement to the Manual on Uniform Traffic Control Devices (MUTCD),
• Current Edition: Additions by the City of Tucson to the Manual on Uniform Traffic Control Devices, for Temporary Traffic Control
• Current Edition: Pima County and City of Tucson Department of Transportation Signing Manual,
• Arizona Department of Environmental Quality (ADEQ), Waste Programs Divisions, Solid Waste Management, Petroleum-Contaminated Soils, Arizona Revised Statutes ARS § 49-851.A.3, and ARS § 49-152.
• Current Edition: Pima County and City of Tucson Department of Transportation Pavement Marking Design Manual, October 2002 .
Additions By The City of Tucson To The Manual On Uniform Traffic Control Devices For Temporary Traffic Control
• City of Tucson Uniform Development Code Technical Standards Manual

wt: and which new ordinance to demand such a manual?


For the purposes of this City of Tucson Public Utility Administrative Manual (the “Manual”):

Utility Company” means a public or private entity seeking to construct, manage, operate or maintain infrastructure and/or facilities within, on, across, above or beneath the public right-of-way for public or private use and includes, but is not limited to, public service corporations, telecommunications corporations, wireless service providers, wireless infrastructure providers, video service providers, common carriers, sewer corporations, fiber companies and gas and water utilities.

wt: Defining "Utility Company" is deceptive, making it easy to present the network as something needed by the public, such as gas, water, or power. It is not. 

Right-of-way” (ROW) means the area on, below or above a public roadway, highway, street, sidewalk, alley, or utility easement. Right-of-way does not include a Federal Interstate Highway, a state highway or state route under the jurisdiction of the Department of Transportation, a private easement, or property that is owned by a special taxing district.

UCC” means Utility (Planning) and Coordination Committee and established by ordinance 4465 for the planning and coordination of the construction and modification of existing and proposed infrastructure within the public right-of-way.

MITZ” means major impact traffic zone and refers to arterials or collectors that provide
transportation corridors throughout the City of Tucson. It also includes the downtown city center and its immediate surroundings. It is generally bounded by Toole Ave/4th Avenue, 6th St, Granada Avenue, and Cushing Street.

TNE” means temporary noise exemption and is required for work done at night.

Annual Permit” means a right of way permit that allows applicants to do temporary work not requiring excavation, inspection, and lasting no longer than two hours. This permit does not allow impact to street capacity for arterials and collectors and daily activity must be reported to the Permit Center for information and permit assignment planning.

MCP” means mobility control plan and was previously known as a traffic control plan. All barricades shown on plans must also consider all forms of mobility including pedestrians, bicyclists, and transit riders when planning a construction activity that may restrict a mobility function for the safety of the users of various mobility categories.

DTM” means Department of Transportation and Mobility.

CSA” means cost sharing agreement between the utility and DTM for expectations and assignment of costs related to utility removal from a City street made as part of a capital project improvement.

PUE” means public utility easement and describes the allowance of designated land for the use and installation of utilities in compliance with the City’s construction requirements.

Professional” means a person who is knowledgeable in a recognized area or specialty, trained, and performs the design of respective work as a livelihood.

Antenna” – communications equipment that transmits or receives electromagnetic radio frequency signals used to provide wireless service.

Stealth Design Techniques” – The use of materials, colors, screening, undergrounding, or other concealment elements intended to blend the new equipment and existing pole into the surrounding setting.

Cantenna” – that part of a small cell facility typically located at the top of small cell poles, that covers, shrouds, or otherwise conceals that part of the facility used for the purpose of housing the antenna(s), antenna mount(s), cable connections, radio equipment and other hardware.

Collocate or collocation” – to install, mount, maintain, modify, operate or replace wireless facilities on, within or adjacent to a wireless support structure or utility pole.

FCC – The Federal Communications Commission.

Owner” – A person with a legal or equitable interest in ownership of real or personal property.

Public rights-of-way or ROW” – Public roads, access ways, sidewalks, or similar facilities.

Small wireless facility” – a wireless facility that meets both of the following qualifications:

  • All antennas are located inside an enclosure of not more than six cubic feet in volume or, in the case of an antenna that has exposed elements, the antenna and all of the antenna’s exposed elements could fit within an imaginary enclosure of not more than six cubic feet in volume.
  • All other wireless equipment associated with the facility is cumulatively not more than twenty-eight cubic feet in volume, or fifty cubic feet in volume if the equipment was ground mounted before August 9, 2017. The following types of associated ancillary equipment are not included in the calculation of equipment volume pursuant to this subdivision:
    o An electric meter.
    o Concealment elements.
    o A telecommunications demarcation box.
    o Grounding equipment.
    o A power transfer switch.
    o A cutoff switch.
    o Vertical cable runs for the connection of power and other services.

Utility pole” – a pole or similar structure that is used in whole or in part for communications services, electric distribution, lighting or traffic signals. Utility pole does not include a monopole.


The purpose for this manual is to

  • Inform Utility Companies of the requirements and expectations for processing a request to construct and install utility infrastructure within the City of Tucson right of way (ROW).
  • Advise Utility Companies of shared space and approved utility locations to coexist within a limited space.
  • Advise Utility Companies of what must be considered* when designing, coordinating, and constructing public utility main infrastructure within City of Tucson ROW and maintaining existing mobility, landscaping, access, safety, and street materials as deemed to be in the public’s interest.
  • Inform the Utility Companies of the permit communication expectations* for the City and its residents.
  • Provide City Staff with direction for review, approval, and inspection of work within the ROW. The Utility Companies shall acknowledge and understand* the steps the City of Tucson will need to follow for the City to assess the complexity of the project presented as it pertains to the public, the ROW limitations, and needs and uses. Mobility concerns, communication, and construction quality expectations* will be addressed by the conditions of this manual as discussed herein.
wt: this should also serve the following purposes:

*Advise Utility Companies of what is required when designing, coordinating, and constructing
*Inform Utility Companies of the REQUIREMENTS for use of the ROW
*Utility Companies shall acknowledge, understand, agree and comply with... in order to use the public ROW * quality REQUIREMENTS...

-Inform Utility Companies where WTFs in the ROW will be allowed and where they will not. I.E. not allowed in residential zones. OR how they will be permitted to operate in certain zones. 
-Inform City staff direction to ensure facilities comply with ALL federal standards and any other applicable law [or local ordinance]. 


This document applies to any new utility infrastructure installation in the public ROW. It also applies to maintenance of current facilities and infrastructure when this maintenance activity impacts the use of the ROW by others.

New fiber companies to the City of Tucson shall make application and ** receive approval for a license agreement, provide proof of operating area approval, and must be current in annual fee payments. Utility Companies having franchise agreements must be in compliance with the current agreement..

wt:**shall make complete an application and MAY receive approval for a license agreement if the City finds it appropriate...
By codifying that the fiber "company shall make an application and receive approval"  it means two things:
The company creates their own application and
the application will be approved

Yes, we know what was meant but vague language establishes loopholes. 


The requirements of work allowed will vary based upon the type of utility and its location in relation to other utilities in the same right-of-way. Varying requirements may be imposed upon the Utility Company such as work hours, seasonal restrictions, events, other work scheduled, and possible differing restoration methods and materials to address the concerns* of businesses, City events, capital projects, commuters, pedestrians, bicyclists, bus riders, and other stakeholder needs. Approval of permits and work dates or work hours may be delayed to account for and accommodate the users of the ROW for transportation, other requests, and activities.

wt: *specifications
  • Deviation from a standard utility placement location may be approved in advance through a waiver request that includes: the reason for the request and evidence that all possible locations meeting the intent of the initial approved location placement have been explored and found infeasible. Guidelines for alternate locations included herein may be used to demonstrate this intent should a waiver be necessary. Waivers will be granted or denied at City’s sole discretion.
wt: There should be no deviation from the standard, with a strong ordinance that requires co-location and tiny units (the size of a WiFi router) there is no premise for either new placements or deviation from the standard. The City must demonstrate resolve and stamina and just say no. Telecommunications will not be impeded by this.

Design and construction within Major Traffic Impact Zones (MITZ) shall have special design considerations, utility location changes, work hour restrictions, and other specialized considerations applied to the review and approval that may not be standard to a normal approval.

Design and construction in residential areas will also have special design considerations, utility location changes, work hour restrictions, and other specialized considerations applied to address the needs and the concerns* of the resident. This may include landscape and tree planting opportunities, off-street parking, mail and package delivery, pedestrian access, and placement of above ground equipment.

Work done at night will require a temporary noise exemption (TNE) and special inspection fees. Work done on the weekends or after hours may have special inspection fee rates associated with the overtime request.

wt: *specifications of residentS

4.2.1 Row Permit Required

Any activity in the ROW requires a ROW permit. This advises the City of Tucson of the activity and if there is a need to follow up with an inspection for safety or quality; and to let the residents or business know of activity and who to contact to address their specific concerns.

If maintenance is required, an Annual Permit exists for the expediency of this work. A 2-hour maximum, no excavation, or lane restrictions on arterials or collector streets are covered by an Annual Permit; otherwise, a standard ROW permit is required. Utility Companies should determine if it is right for them. If work on an arterial or collector street is necessary, mobility and business impacts must be addressed. A Mobility Control Plan (A.K.A Barricade Plan) will need to be submitted for review and approval before work begins.

Work that begins (other than for emergency reasons) without a ROW permit being issued or has expired is subject to a $2,500 citation per City Code Chapter 25- 45.1. , in addition to any additional remedies available to the City by law, including a Stop-Work Order.

wt: and may result in a hearing and ultimate removal of the site

4.2.2 Public Notification Program

Businesses, residents, and affected stakeholders shall be allowed to view and comment on all new infrastructure proposed in the planning/design stage.* The Utility Company shall reach out to the affected areas and address concerns** before designs have completed their review for approval. Proof of public outreach will need to be provided as part of the review submittal in the design stage.

wt: *How and where?  Where will notice be posted pursuant this section? 
**residents' specifications... The Utility Company appears to be the applicant, but it's an odd way to rename and define the entity. 

4.2.3 Road Appearance

It is the desire of the City of Tucson to keep all roads looking uniform in appearance. The
contractor shall add additional surfacing material over disturbed pavement areas to keep the road looking uniform in appearance to its surroundings as described herein. Discussion of the limits and expectation details is contained herein. Opportunities to partner with the Department of Transportation and Mobility (DTM) for roads scheduled to be resurfaced may be available to help coordinate the timing and reduce the costs for pavement restoration. It is in the best interest of the Utility and the City to minimize impacts, disruption, and costs associated with any activity where possible with advanced planning and continued communications.

wt: no wishy washy language. COT wants roads to be uniform, then it's a requirement not a desire. 

4.2.4 Support Drawings

All infrastructure to be installed shall require engineered drawings that accurately depict the exiting rights-of-way, street infrastructure improvements, existing, underground, and overhead utilities, relevant elevations, existing landscaping, driveways, and private improvements. Design shall be prepared by design professionals as allowed by the Arizona State Board of Technical Registration or as required by respective government agencies owning the infrastructure. Record drawings shall be required upon completion showing the complete as-built infrastructure, including all horizontal runs of power, communications, or other facilities necessary to the installed infrastructure. A certification line must be included as part of the formatting attesting to the accuracy and quality of the work. The Utility Company shall be responsible for any below ground damage caused by their work
and bears the responsibility to pay for and make any repairs or replacement to infrastructure or services found damaged by this work.

wt: surely the author means existing? Include a before and after photo simulation.

4.2.5 No Abandoned Facilities

Infrastructure that is to be replaced or relocated shall not leave remnants in place unless first approved be the City and only under special circumstances. The cost to the company shall not be a reason for not removing the abandoned infrastructure. Work may be coordinated with capital projects or other activity that exposes the material to reduce the costs associated with the removals. The cost to remove the abandoned material shall be borne by the owner of the infrastructure and if made in conjunction and cooperation with a capital project, the payment amount and details for collecting or assisting with its removal shall be captured by a Cost Sharing Agreement (CSA).

wt: we're not sure what a CSA is or who does the sharing.  Sounds like taxpayers? This should be re-written to reflect that the COT retains the right to set precedence to capital projects over this infrastructure, and if the pole happens to be in the way of such a necessary project, the item is relocated at the Utility Company's expense. They don't pay rent, they pay for the site once, for the low price of less than $1K. 


Work is evaluated based upon other ROW activity and events. Restrictions and scheduling of work will be made a condition of the permit. Here are some things to consider:

wt: These are restrictions and requirements, no considerations, thus:


Holiday Moratorium- During the period of November 1st to January 2nd . Issuance of new permits is reduced to work affecting certain arterials and collectors due to the increased number of winter visitors during the referenced time of year. Construction sites in progress along these routes shall cooperate by minimizing impact to street capacity and business access during this time. A list of streets affected can be found in Exhibit . New work may be approved to be
done at night provided it meets the intent of this restriction and the requirements described herein are followed.

Street Capacity Restored- lanes that are restricted shall be strongly encouraged* to be restored for use by the community including drivers, pedestrians, and bicyclists at the end of shift each day.

wt: *precise language is needed. encourage, strongly or otherwise is meaningless. 

Events- the Utility Company will consider and account for work restrictions during temporary events. Most events occur downtown. Traffic congestion shall be minimized by complying with scheduling and ROW work hourly coordination.

Other Construction- capital projects, emergency repairs, and other types of work may impact the work proposed by the Utility Company’s permit request. The Utility Company shall be aware of these occurrences and cooperate with emergency or planned work requests.

Development- Utility Companies shall be aware and consider other business operations and access, capital project schedules, noise restrictions, peak traffic hour times, and holiday or events. Communication with all affected including commuters through message boards and public service announcement updates is desired.*

wt: is required

Night Work- construction Downtown, in congested areas, residential areas, and MITZ may not be allowed during normal business hours in some areas. A Temporary Noise Exemption (TNE) pursuant to Tucson Code section 16-31(d), may be necessary if the construction zone impacts the normal use of the street and business access when working at night. The link to request and submit one can be found at

Street or Intersection Closing- Closing of streets or intersections will not be allowed in
residential areas without written permission, neighborhood awareness, and a TNE unless it is an emergency, as determined in City’s sole discretion.
Closing of arterial or collector intersections may be considered on a case-by-case basis if work is done at night to minimize impacts to businesses, commuters, and emergency services. Advanced message board notifications are required in addition to a TNE as discussed above.

wt: They're going to be closing our streets? All over town for the next few years while they build up a network we don't want? Just say NO, COT. 

Weather- Utility Companies should account for seasonal weather delays when considering and scheduling. Permittees should consider work on weekends and longer shifts to meet the ROW Permit expiration date. Applicable overtime fees may apply.


It is important that the City of Tucson is made aware of upcoming utility projects that may impact planned capital projects and other event activities within the City limits. A monthly Utility Coordination Meeting will be held virtually or physically where all utility companies may be able to present proposed projects so that potential issues may be coordinated and resolved before proceeding. The City’s Utility Coordinator will chair the Utility Coordination Committee (UCC). All utility companies shall have an opportunity to attend and present proposed projects.

wt: then it should be open to the public

Daily and scheduled maintenance activity shall be reported to the Utility Coordination Section through the following link: for the City of Tucson. Annual Permit reporting shall have a heading stating it is “Annual Permit Work Activity”. Impacts to commuter traffic is important to know and report on. This includes flushing of fire hydrants, power outages, pole removals, and other related routine maintenance activities that may affect street capacity with trucks, equipment, water, materials, or debris.


Mobility, property and business access, safety, pavement damage, interruption of services, * and the public awareness **are areas of concern expressed by the City’s inhabitants. The City of Tucson has adopted public involvement requirements for all City capital projects and similar information and opportunities for public comment will be afforded to residents, business owners, and users of the public ROW for utility infrastructure construction in the public ROW.

wt: *property values, privacy, landscape, views and the quiet enjoyment of streets...
**specifications required

6.1.1 Public Notification Process (Design)

All NEW or major utility installations, major repair, or capital infrastructure replacement shall follow this process. This requirement does not apply to regular maintenance, emergency repairs or individual business and new house service connections. This requirement shall occur during the design stage- concurrently with plans that are submitted for permit review and approval. Notifications during construction follow a different protocol. Here are the steps to follow:*

  1. Prepare an Informational Letter describing the work planned and the benefits provided by this improvement. Describe when the design is expected to be completed and the expected construction start date and duration. Notifications shall be sent out to residents and businesses within a minimum ¼ mile radius of the propose project limits, the City’s Utility Coordinator, the affected Ward office, and one to the Neighborhood representative (if one exists). The respective Ward office will have the contact information for the neighborhood affected.
  2. Meet with the DTM staff to discuss where the infrastructure will go in relation to current
    utility locations.
    For arterial and collector streets, discuss how business access, pedestrians, and bus service will be maintained. For residential locations, describe how access and typical operations like mail/ package delivery will be made; how garbage pickup will be managed; and how on street parking will be accommodated during construction.
    For above ground equipment, identify the potential site for placement of the above ground
    equipment within the project area or neighborhood. The site should be selected based on
    technical/engineering restrictions and may include PUE and/or ROW areas.
    Identify several alternate locations– if possible. Above ground equipment does not include
    manhole rims, water box valves, pullboxes, or other accessories that are flush with the
    pavement or ground.
  3. For above-ground infrastructure in residential areas, the packet will include a “before” and “after” (with the new structure superimposed and all accessory equipment) picture * plus a diagram showing all work considered to be performed, including trenching or boring in the area. A 15-business day citizen response period will begin upon DTM advising the Applicant the Application is complete. A list of residents to whom a packet was sent must be provided to DTM during the plan review. Residents who have been notified of the improvements may send their responses to
  4. If the infrastructure is to be in a public utility easement (PUE) or less than *50-ft from a residence, a utility company customer service representative will make personal contact with the property owner either by phone, virtual meeting, or in person to discuss any concerns the property owner might have. Document conversation to include time, date, person spoken with, and result of conversation. Share response with the DTM Utility Coordination team during the review period.
  5. When a project is identified and the logistics discussed with the City’s Utility Coordination team, the utility company shall post a 2’x1.5’ wire frame sign at all locations where above ground equipment or accessory equipment will be located. The sign shall contain information as to where details can be found, the contact person for the utility company, and where comments can be emailed to. If the concerns expressed cannot be resolved through the design, a UTILITY WAIVER may be submitted for review and approval justifying the site location based upon the criteria described in this manual. *
  6. The City places a great emphasis on transparency and public engagement and strongly encourages* Utility Companies to show a willingness to work with residents and select alternate locations if there is a strong resistance to an initial placement .

Any use of a PUE shall be consistent with the terms of the easement and applicable law, code and regulation.

If the Utility Company already has a proactive and comprehensive public information program, they implement in advance of new infrastructure projects that meet the intent of this requirement, they may continue to follow it in lieu of these steps subject to approval from the City’s Utility Coordinator. The information gathered should be made available to the City’s Utility Coordinator as part of this submittal process.

Figure 1 – Small Wireless Facility
1. In the former version of this draft there was contained a written notice describing the impacts... that would have been interesting, let's put it back in. 
3. * Before and After photo simulation. In the original draft there was a before and after here... it should remain. 
4. *1,500 ft
5. * Record Plans shall be posted at the site. 
6. *Requires

If the Utility Company has an even more inclusive... program


The location of the work is a key element in the assessment of impacts to the community. The duration of the permit, the time when work can be done, and construction details that must be followed are described herein. The Utility Company must make sure that the location of all infrastructure installed is carefully documented for future reference. Considerations to move a utility location to another location may be approved provided the location is compatible with other utilities, their service lines, and approved by the City. The following items will be reviewed for compatibility, use, and any special requirements associated with the utility installation:
• Utility corridor approved locations
• Utility separation requirements
• Depths and Heights
• Proximity to Modern Streetcar
• Downtown

Figure 2- Arterial Street Utility Location

Figure 3- Residential Street Utility Location


The City of Tucson is committed to planting 1,000,000 trees in the right-of-way for shade to pedestrian paths between the curb and the property line. All Utility companies shall keep this in mind when planning, designing, or modifying their infrastructure within City of Tucson rights-of-way.

Figure 4- Conceptual Tree Placement Location
wt: ...and? "OK we'll 'keep that in mind' when we cut them down and bore through their roots and water lines"

How about this:
No WTF shall be constructed, maintained or OPERATED in a way that would endanger the City's trees.


WET Utilities
All wet utilities shall generally be located under the street pavement for ALL streets and street classifications unless they exist in a pre-existing utility easement. Wet utilities are liquid or gas, conveyed in conduits or pipes that could be under pressure.

WET utilities may be located outside of the pavement area provided they do not conflict with proposed tree or water harvest basin locations; do not cause sight visibility issues for drivers using intersections or driveways; and are compatible with the utilities already in the vicinity located. WET utilities may be in dedicated utility easements or in prior rights easement locations.

DRY Utilities
Dry utilities include power, cable, or fiberoptic communication lines and their supporting
equipment. These may be located on existing power poles or below ground. SWF equipment shall be screened in accordance with this manual.

If dry utility infrastructure is above ground, the poles, pedestals, equipment cabinets, or other supporting equipment should not interfere with the sight visibility of drivers at intersections, alleys, or driveways. Also, placement of new equipment shall not be positioned to interfere with pedestrian paths or landscape amenities- future or present.

Support poles *** are approved to be positioned near the right of way /property line. All dry utility lines must be coordinated in height so to not be a danger to those who must do maintenance to the equipment under or attached to poles and their lines. For communication/fiberoptic or cable lines that are currently aerial, a 10-ft vertical separation (or as allowed by the power company) is typically required between overhead power and communication or street lighting lines or equipment.

wt: support poles may be approved. This is the kind of language is trouble. It says here that support poles -whatever that means- ARE APPROVED near the ROW AND OR YOUR PROPERTY LINE. 
No, they MAY be approved. They aren't just approved.
Considering a tiny size and co-location requirement, the City will not need to approve any new poles.

If dry utilities are located below ground, the conduits constructed under the pavement shall
maintain the designated separation requirements described herein. If this is not possible, a joint trench with compatible utilities can be made.

Communication, fiber, cable, or electric conduits installed between the curb and the property line shall be constructed with special protection such as a concrete cap unless installed with jack and bore methods.

Approval to install utilities in alignments other than an approved location shall require confirmation by the reviewer and formal approval by the City Engineer as part of a UTILITY WAIVER request.

wt: how about "no"? 
Add a line or section: Residential zones are not an approved location for sWTFs.

Aerial installation shall be located on approved pole locations with permission by the pole owner. No new aerial attachments shall be made on wooden poles scheduled to be removed. These poles are generally “cut off” and have no electrical lines on them.


• A 5-ft minimum horizontal separation from any dry underground utility shall be provided for water mains, sanitary sewer mains, and other utilities. The minimum horizontal separation is measured from outside of water/sewer main to the outside of the underground utility.
• A-10-ft horizontal separation between wet utilities shall be provided where possible.
• A-minimum 4-ft vertical separation between wet utilities shall be provided unless additional pipe material modifications are made to the system at the crossing per agency requirements.
• A 5-ft minimum horizontal separation from any dry underground utility shall be provided for water services and sewer services. The minimum horizontal separation is measured from outside of water/sewer services to the outside of the underground utility.
• A 2-ft minimum vertical separation from any dry underground utility crossing for water mains, water services, sewer mains, and sewer services. The minimum vertical separation is measured from the top of water/sewer main/service to outside of the underground utility.
• A 4-ft minimum vertical clearance underneath existing trees or vegetation for wet and dry utilities.
• A 5-ft minimum vertical and horizontal clearance near or underneath Modern Streetcar tracks for all utilities.
Any and all, more stringent separation requirements required by Federal, State, or Local Codes agencies, or ordinances shall take precedence.

A utility company requesting a variance from the above minimum clearances must do so in writing in the form of a Waiver Request to the Engineering Division, Utility Coordination Section as part of the permit application. The request shall identify each utility clearance requirement for which a variance is requested and the reasons why a variance should be granted. The Utility Coordinator will decide whether a variance should be granted. When utility conflicts are found during construction, all changes and variances must be preceded by an approved plan revision.


Aerial electric, cable, or fiber optic lines shall be a minimum of 18-ft high when crossing signalized street intersections, pavement, or alleys. The height above ground, outside of paved areas and all other intersections shall be no less that 16-ft at lowest sag locations. Adding of additional poles shall not be considered if the height cannot be maintained at the sag between pole spacing. The lines in violation shall be raised or moved to an underground location per the requirements of this manual.



The Utility Company must provide design drawings prepared by professionals in their respective field that depict the utilities and street infrastructure correctly including driveways, bus stops, landscaping, existing trees or vegetation, and sidewalks *. The professional assigned by the utility company to prepare the drawings, will be responsible, on behalf of the utility company to ensure that all work is done in accordance with the latest PAG Standard Specifications and City of Tucson requirements. Here are some general design coordination items to address:**

wt: *sidewalks and a before and after photo simulation

  1. Work to be done in street corridors planned for expansion shall be coordinated with pending capital project plan designs for horizontal and vertical locations of proposed relocations.
  2. Barricade plans shall be prepared by an ATSSA certified specialist and include all mobility impacts planning for safe travel through the construction zone.
  3. Existing utility locations shall be investigated for depth at crossings through pothole or record drawing information in advance to avoid conflicts and delays during construction.
  4. Existing plants and trees to be impacted shall be evaluated for protection or replacement.*
  5. All existing conditions shall be replaced to at least the original condition or better as described herein.
wt: * exaction of which to be paid for by____

Plans and supporting documents may be submitted to the following address for review:


9.1.1 Plan View Requirements (all utilities above or below ground)

The plan view shall include, but not be limited to, the following:

  1. Provide a scale or dimension adequate to accurately depict relationships among the physical features within the construction area and to identify potential conflicts. Scale should be no smaller than 1” = 40’.
  2. Make sure the existing and proposed rights-of-way and adjacent easements clearly labeled and dimensioned. Right-of-way lines shall be labeled “R/W” or “ROW.”
  3. Show the location and size of all existing and proposed facilities and street improvements that the proposed utility construction would either cross or run parallel within the limits of the right-of-way corridor and the adjacent easement. The lip of gutter and/or edge of pavement shall be indicated when proposed construction is located within the asphalt surface and in relation to the right-of-way.
  4. Show all existing or proposed improvements including landscaping, above and underground structures, lip-of-gutter, curb, back of sidewalk, and front of sidewalk if not adjacent to the curb when proposed construction is located within an alley or behind curb and gutter.
  5. Show all existing and proposed paving improvements when proposed work is in areas with new development.
  6. Storm drains, sanitary sewer lines, and water lines over 12-inchesin diameter shall be drawn to scale. Vertical poles over 12-inches in diameter shall be drawn to scale.
  7. All conduits or conduit systems over 12-inches in diameter or wide shall be shown to scale if proposed construction is within 2-feet of existing conduit system.
  8. Provide a dimension that accurately describes all proposed utility crossings (underground and overhead) when measured at a 90-degree angle with the road monument line.
  9. Show the locations and limits of the proposed construction and their relation between other agencies or right-of-way owners. Add the jurisdiction name (ie. City of Tucson, ADOT, etc.).
  10. For infrastructure requiring new utility service, horizontal and/or vertical runs of electric power, fiber optic cable or conduit from the closest splice or interchange. If additional permits are contemplated for electric or fiber optic cable installation, said permits shall be referenced on the plan set, even if only proposed at the time of application.
  11. Provide dimensions for survey ties to nearest cross street. Dimension ties to monument lines (not centerline of asphalt) in streets and to property lines in alleys and easements.
  12. Show all existing topography affected by the proposed construction. Vertical changes in elevation adjacent to vertical or exposed infrastructure may require retaining structures.
  13. Provide a completed title block.
  14. Provide a vicinity map indicating major cross streets.
  15. Include a North arrow on each plan sheet. Orient the layout so North is either at the top or the left on the page.
  16. Label all street names.
  17. Provide a legend showing all symbology used on plans.
  18. Show approximate floodplain or local flood limits.
  19. Include a note stating, “Notify Arizona 811 two working days before construction”. Call 811 or 1-800-782-5348.
  20. All minor revisions to approved plans must be made distinctive on the revised plans by crossing out the original note, symbol, or value and replacing it with the revised information. Major revisions shall be indicated by “Clouded” symbol containing the new design information.

wt: distance to the nearest building

9.1.2 Profile Requirements (when utilities are underground)

The profile shall include, but not be limited to, the following:

  1. Existing and proposed grades should be at intervals of 100’ or less in the same alignment as the proposed construction. The profile shall be shown as a continuous line on the plans throughout the project.
  2. Show all existing and proposed facilities that the proposed utility will cross (storm drains, sanitary sewer lines, waterlines, and conduit systems).
  3. Storm drains, sanitary sewer lines, and water lines over 12” in diameter shall be drawn to scale. NOTE: All conduit systems over 12” in diameter or high shall be shown to scale if proposed construction is within 2’ of another existing conduit system.
  4. Provide a vertical scale that adequately depicts installation of existing facilities. Please specify scale (i.e. 1” = 2’, 1” = 5’, etc.)
  5. Elevations shall be City of Tucson datum and indicated on the plans.

NOTE: Complete profile drawings showing all intersections return curve to return curve for
Major Street to Major Street, or Major Street to Collector Street shall be provided when
proposed construction crosses existing or proposed facilities. Profiles may also be required when clarity of a proposed crossing is necessary.


  1. Minimum overhead clearance shall be 18 feet over street pavement and alleys. Overhead lines shall not obstruct or interfere with traffic signal visibility. Indicate the heights on the plans.
  2. Existing underground facilities need not be shown on plans for overhead installations or maintenance (including overlashing) unless excavations are also included in the work. Overlashing expectations are described in the License Agreement for each respective utility.
  3. Permits for overhead lines must comply with any License Agreement with licensed and franchised companies.
  4. When plans are submitted for utility pole relocation (s) and/or removal (s), all utility owners that may be attached to the pole (s) will be issued a joint use utility permit. All pole occupants must relocate their facilities within 90 days of pole relocation. Utility Company acknowledges that City may remove attachments from poles within the ROW that are not removed within the permitted timeframe. City will bill holdovers for the cost of removal plus 15% administrative costs. When all attachments are clear, the pole (s) shall be removed immediately before the permit is
    closed out.
  5. Guy wires must be out of the pedestrian path.
Figure 6 – Excess Overlashing
wt: Fig. 6: is this is not allowed?


The City of Tucson governs all street, sidewalk, and alley restrictions. Traffic control devices
utilized in the right-of-way must include provisions for all modes of transportation and
accessibility. All work must comply with the requirements of the Manual of Uniform Traffic

Control Devices (MUTCD) and current Additions By The City Of Tucson To The Manual On Uniform Traffic Control Devices For Temporary Traffic Control supplement. Please follow the CHECKLIST below when preparing and planning all work within the ROW. Lack of consideration for the different modes of transportation may affect the amount of time needed to review and respond to permit applications. Blue “Business Access” signs shall be required for construction affecting business access.

9.3.1 Mobility Control Plan Information Required

A plan view of the area to be barricaded. The plan should be situated so that North is up.

  1. Must have a north arrow.
  2. All streets must be labeled.
  3. All intersections shown.
  4. All side streets and alleys must be shown and labeled by name and if an alley as “alley.”
  5. All driveways must be shown.
  6. Dimension current lane widths
  7. Show all bus stops.
  8. Label or depict barricades, devices, and signs to be used respectively.
  9. Indicate respective spacing of signs and barricades.
  10. Show face of barricade direction.
  11. Dimension width of area to be reserved/used for the work and restrictions.
  12. Show all tapers and lengths.
  13. Provide double sided blue “business access” signs at all business driveways.
  14. Depict provisions for pedestrians.
  15. Depict provisions for bicyclists.
  16. Depict provisions for bus riders.
  17. Provide barricade setup and takedown hours if it is not a 24-hr set up hours.

NOTE: Pedestrian provisions must be made through the construction site for all arterial and
collector streets. Provisions for transit riders must be made and shown on the MCP. Bicycles can be directed to travel lanes provided the appropriate speed limit reductions are included and share road signs provided. If the barricade plan is for multiple location set up, the entire project must be submitted for analysis and review. Staff will work with the Utility Company to modify the proposed plan provided it meets the minimum requirements set forth by this checklist and the MUTCD.


The permittee is responsible for ensuring the natural drainage is not impeded during and after construction.

City streets are used to convey stormwater drainage. Many local streets are jurisdictional floodways in nature and carrying at least 100-cfs in the right-of-way during the 100-year storm event. All infrastructure, above ground or below ground, proposed in a regulated floodplain shall require a floodplain-use permit. The Applicant is referred to Chapter 26 Floodplain and Stormwater of the Tucson
City Code.

Design calculations for scour depth and a description of measures to be taken during and as part of the improvements must be provided for review and approval when crossing washes and crossings. Impacts to major wash bank protection shall require Pima County Flood Control approval and inspection.

wt: just say no COT
This image has an empty alt attribute; its file name is image-18.png
Figure 9- Sample Local Floodplain Layer (Map Tucson)


The designer shall contact the neighboring utilities affected for depth and location. Conflict
resolution will be made before submitting to DTM for review and processing. Utilities to review include:
• Electric Lines (Tucson Electric Power)
• Potable and Reclaimed Water (Tucson Water)
• Sanitary sewer (Pima County Regional Wastewater Reclamation Department)
• Natural gas (Southwest Gas)
• Telecommunications (various fiber and cable)
• Traffic Signal and Street Lighting (City of Tucson)
• Drainage (Pima County Flood Control District and City of Tucson)
• Landscape irrigation (City of Tucson)
• Storm drain (City of Tucson)
Plans shall indicate the degree of accuracy and provide confirmation that other utilities have been consulted with and agree with the prosed placement of the new infrastructure.

9.5.1 Protection of Utility Service Connections Required

The designer shall also identify all business and private services to buildings and properties. The plans shall include notes to advise the contractor to locate all house or business utility service connections along the property frontages affected. All house or business service connections shall be identified before new installation of utility lines are installed whether it be by trenching or jack and bore methods. The record drawings shall identify the locations confirmed or found in the field.

Repair of the pavement, replacement of the landscape shall be included as part of the work
description on the ROW Permit Application.


9.6.1 State Historical Preservation Office( SHPO)

Historic review, archeological review, and monitoring requirements may be required as part of the application. Check for location at the Historic Preservation layer on Map Tucson

The Utility Company must provide confirmation of any monitoring requirements needed for the work to be done in an archeological sensitive area. This MUST be discussed with the Inspector at the Preconstruction meeting if it is a requirement of the ROW Permit or in a known archeologically sensitive area.

wt: current historic review process has not proven sufficient. Visual aspects must not be changed. A 35ft microwave factory changes the appearance of things. 
9.6.2 ADOT or Other Agencies Impacted

Work being done near a railroad (UPRR), the freeway, or other State regulated roadways may need their own separate permit. The designer will need to determine if any work will enter the jurisdiction’s ROW including the barricade footprint. A separate ADOT, UPRR, Pima County, or other agency ROW Permit will be required if there is encroachment, and the permit must be secured by the Applicant’s contractor.


All plans must depict any trees or bushes growing in the construction zone, consistent with UDC Section 7.7.4. Impacts to the vegetation must be addressed before, during, and after construction in accordance with these requirements and current City Ordinances. No damage to said trees shall occur without provisions for mitigation or replacement.

wt: high powered microwaves impact trees


Storm water management within the construction site is the responsibility of the permittee. Where required, the permittee shall obtain all necessary National Pollution Discharge Elimination System (NPDES) permits and comply with all applicable requirements therein. The need to obtain this permit is dependent on the use of ROW area for equipment staging, materials staging, disturbance to ground areas by equipment routes in the construction zone. A Notice of Termination (NOT) will be necessary before the project is closed out.

For project sites less that one acre occupied and disturbed by construction or maintenance
activity, work shall follow best management practices for site housekeeping.


All utility company work located within the Modern Streetcar corridor that is in the public rights-of-way, must also be reviewed and approved and a Track Access Permit issued by Sun Link for any street having MSC track and overhead power. The Modern Streetcar corridor within the public rights-of-way is defined as 5-feet from the outside of guideway curbs over which this transit route operates.

Work near or around the overhead power lines may require a de-energizing of the MSC
powerlines and work will need to be done at night. Coordination of this requirement will be
included in the ROW Permit application.

Figure 10 Modern Streetcar


9.10.1 Downtown

Special consideration should be given when planning the upgrade and installation of wet or dry utilities downtown. Many of the downtown streets contain a concrete layer under the pavement. Special patching requirements and limits shall apply to improve the appearance of downtown streets to like new condition regardless of the street’s age or appearance.

9.10.2 Sight Visibility Triangle (SVT)

Poles, equipment, or other above ground infrastructure shall be placed so as not to obscure any portion of any Sight Visibility Triangle (SVT), consistent with the City of Tucson Unified
Development Code (UDC) Sections 10-01.5.0 – 10-01.5.4 (Sight Visibility)

Figure 11 Sight Visibility Triangle

9.10.3 Vaults

It may be necessary to construct a vault within the street ROW at locations where major
intersection of power or communication systems occur. Vaults may be used at these locations provided there are no other locations possible. They will be allowed to be under the paved section of the road, and made compatible with other utilities that are present. A vault constructed under pavement must be traffic rated to withstand the expected traffic volume loadings. The vault must be design and constructed to be watertight and able to sustain H20 loading (minimum) as defined by the Federal Highway Administration.

The utility company will be responsible to adjust the vault elevation in the pavement should the City of Tucson add a pavement overlay or modify the street profile that causes an elevation change at this location.

9.10.4 Pole Placement

New electrical or communication poles shall be placed within 1’-3’ of the ROW/property line. Additionally, new poles shall not be placed within five (5) feet of the perpendicular extension of the ROW-facing façade of any single or multifamily dwelling unit. The perpendicular extension shall be derived by drawing a straight line following the roofline on each side of the façade to and through the ROW. Service poles for private use shall be on private property only. Individual service poles shall be reduced and eliminated where possible by moving overhead service lines to compatible underground locations.

New utility poles, streetlights, or wireless support structures (each a “Utility Pole”) shall be a minimum of 150 feet radially from any other existing verticality in the ROW. Existing verticality shall include: Utility Poles, traffic signs/signals and street signs.

Streetlight poles or dusk to dawn poles shall additionally be spaced based upon safety lighting design requirements. All lighting must be LED and must meet City of Tucson and Pima County Outdoor Lighting Code and UDC standards.

9.10.5 Meters, Services, and Pedestals

Meters, controllers, and meter pedestals shall not be in the SVT where possible in arterial or collector rights-of-way. Meters, controllers, and meter pedestals shall be located on power poles in residential locations or may be located to alley or drainageway locations; but, must be protected and screened to assist with screening concerns in a residential area.

Power to a streetlight or SWF may be extended within the ROW from the nearest available power source for poles having streetlights.

Underground electrical services for irrigation for private use shall not exceed 100-ft in the public ROW without a temporary revocable easement from the City of Tucson and special protective design requirements prescribed by the department. Electric services for public equipment shall be designed and conductors sized in accordance with applicable codes.

9.10.6 Pullboxes

Pullboxes should be placed outside of existing or future pedestrian paths where possible. If the existing ROW is not wide enough or there are other obstructions that may prevent this, the pullbox may be in the pedestrian path provided it is flush with the ground and is within a concrete collar that will help support it from settling.

All pullboxes located in alleys or streets shall use a traffic rated design and made of materials to withstand H20 traffic loading.

9.10.7 Specialized Location Markers

Markers identifying the location of underground infrastructure
shall be limited to low profile style markers that are flush with
the ground. The use of location markers must be shown on the
plans and approved.

Use of vertical markers might be considered in rural locations
where utilities are difficult to identify as being present.

Figure 13- Low Profile Utility Marker

9.10.8 Alley Clearance

Meters or above ground splice closures shall be screened where possible in residential areas. Placement of screens, poles, meters, or pedestals in alleys shall be placed with clearance in mind so to allow for Solid Waste Collection equipment and vehicles.
Residential alleys are typically 20-ft across but may be as little at 16-ft wide. Trucks vary in width and may be as much as 8-feet wide at the wheels. Containers vary in diameter but are

Figure 14- Solid Waste Equipment Clearance

as wide as 4-ft across the top. Above ground accessory structures that are installed or extend into the alley must be checked to ensure their location can provide passage of refuse collection trucks and utility equipment traffic.


Communication or electric power facilities may be installed as attachments to bridges or roadway structures only where the utility company has demonstrated that all other means of installation is not practicable. Other means shall include, but are not limited to, underground and independent poles and only if made aesthetically pleasing. Most new bridge designs include empty conduits for this purpose. Special negotiations and lease of the conduit may be necessary.

wt: Just say no COT... and what is aesthetically pleasing? What of those that are very unsightly that already exist?

If an attachment must be made, submittals shall include sealed plans, profiles, and details on the proposed attachment to the structure and method of attachment, along with sealed structural calculations for all brackets and connection devices into the structure. An Arizona Registered Structural Engineer must seal the plans and calculations.

WET utilities carry a significant added weight and will be discouraged from attaching to a bridge or structure unless the requesting Utility Company is willing to pay for the added costs necessary to support the loading; make the installation aesthetically pleasing; and address access requirements necessary to do maintenance to its own respective infrastructure without significantly affecting traffic capacity. Requests will be considered on a case-by-case basis.

Facility installations conveying commodities that are volatile, flammable, corrosive, or present high degrees of risk to persons and property in the event of damage to or failure of that facility *is highly discouraged but may be reviewed and approved on a case-by-case basis.

wt: is not permissible


The City of Tucson must coordinate new work and manage the use of the ROW to protect its own infrastructure. This may include but not be limited to paving, sidewalk, curb, traffic signals, street lighting, signage, landscaping, and storm drainage. The condition of the City’s infrastructure must be maintained, replaced, or improved as part of any activity within the public ROW.

The standards and requirements for street pavements are described in the City of Tucson Unified Development Code Technical Standards Manual per Ordinance 11025 and Ordinance 8727. The requirements in Section 10- Transportation provide direction to reviewers and give expectations to utility companies for the repair of pavements caused by the installation of utility infrastructure in street rights of way. The two documents shall serve to complement one another. Should differences exist between them, the more stringent requirement shall be required and enforced.


Shading shall extend to one foot above the top of the highest projection of the facility being
installed and conform to the parent organization ’s specifications.


10.2.1 Non-Paved Areas

Backfill in non-paved areas may be replaced with native material compacted to a minimum 85- percent of the material’s maximum density.

10.2.2 Under Pavement

Backfill under pavement is important to the integrity of a pavement patch. The City of Tucson has determined that the failure of most patches begins with poor workmanship and the type of backfill material used to backfill trenches or other excavations. Regardless of the age and condition of the pavement, the following will be required of all disturbance to existing pavement in streets or bike path areas:

Trenches and excavations shall be void of native soils and the backfill of trenches for utility mains or services under asphalt concrete (AC) shall be made with aggregate base (AB) material that meets current Pima Association of Governments (PAG) Standards and specifications. The aggregate base AB must be compacted to 100-percent of the respective material maximum density. Density tests shall be made by a certified material testing laboratory. A minimum of one test per day is required and depending on the length of work, more tests may be necessary. A density test shall be taken for each day and for every 100-CY of material compacted. The results shall be reported to the City’s Inspector.

10.2.3 Concrete Caps or Encasement Required

A 6-inch concrete cap or concrete encasement of the conduit shall be used over or around any fiberoptic or electrical line installation installed in the parkway space between the property line and the back face of curb. The concrete used shall be an approved controlled low strength material (CLSM) concrete mix per the current PAG Specifications as a minimum.

Jack and bore installation do not require concrete encasement or concrete caps. Backfill and patching requirements described herein shall apply for potholes.


10.3.1 Moratorium

The City of Tucson has established a no cut pavement moratorium for new pavements and
pavement rehabilitation projects. Information as to which streets and their locations that
special restrictions apply may be found at
or at

10.3.2 Emergencies or New Service Lines

Service line repairs may be made in new pavements without a moratorium patch requirement provided the backfill and pavement repair includes NO native backfill and the pavement area affected is less than 4-ft wide to complete the T-Top Patch Detail. If the width exceeds the 4-ft maximum width, the area of patch must comply with moratorium patch requirements.

10.3.3 Moratorium Pavement Repair

Pavement patch limits for pavements under moratorium is a T-Top Pavement patch, 50-ft beyond the limits of the trench on both sides of the excavation and for the width of the lane affected.
See Exhibit C.

10.3.4 Non-moratorium Pavement Repair

Pavement patch limits for pavements not under moratorium shall follow a T-Top Detail, see
Exhibit A. The contractor shall apply an approved microsurface treatment to the affected patch area for 50-ft beyond the trench limits and for the width of the lane affected for the street affected.

10.3.5 Multiple cuts

If multiple cuts and patches are made to the same street and within the existing pavement, the entire street surface shall be milled 2-inches and overlaid with 2-inches of an approved asphalt mix on arterial and collector streets.

For residential streets, a microsurface treatment shall be added to the surface of the patched area for the entire width of lane affected between cuts upon completion of the pavement patch in lieu of a mill and overlay. In residential areas, the treatment shall extend to the center of the street. If both sides of the street have been cut, the entire street shall be covered over between the limits of the first cut to the last cut on the same street.


All downtown streets affected by a pavement cut shall be resurfaced by milling and replacing the pavement in the lane affected. The depth of the mill and pavement replacement shall be 2-inches thick and 50-ft in both directions of the edge of the pavement patch method used.


Potholes are required to locate existing utilities, irrigation lines, and house service connection locations. Most utility line locations may be determined with electronic measuring devices. House service connection information might not be available. Vacuum extraction is often used, but the pavement must be disturbed to extract the soil. Pavements shall be patched upon determining or verifying the desired utility service connection information or status.

New pavement (under moratorium) may be cored for potholes and replaced per Exhibit B
provided a flat, vertical surface is maintained and left in place upon completion of its repair.
Pavements older than 5-years shall be treated as a patch and resurfaced with the materials and the areas described herein.


Bore pits in the pavement and potholes made on older pavement shall be repaired per the
pavement patching direction described herein. The location of all services and utility lines that are expected to be encountered as part of the operation, must be identified and located in the field to meet AZ 811 requirement. The Applicant must show them on the plans and this work described in the scope of work for the ROW Permit. Repair of damaged pavement for bore pits or potholes shall be made as described herein for pavement patches.


Any excavation into Portland Cement (PC) concrete or asphaltic concrete (AC) pavement shall either be cored or sawcut to provide a face to join the new PC concrete or asphaltic concrete material together. For pavement replacements that require milling, the edges shall be sawcut and the edge made smooth to tack and join the old to the new material.


Concrete curbs that are damaged by truck tires or other heavy equipment shall be replaced by first saw cutting the curb at the nearest joint. The contractor shall be careful to not remove beyond 2- inches of the pavement adjacent to the curb. Broken pavement or a sawcut beyond 2-inches shall follow the pavement patching direction described herein.


Concrete Sidewalks that must be removed, damaged by the utility installation or for maintenance shall first be sawcut at the nearest joint. The sidewalk shall have a minimum thickness of 4-inches and a minimum thickness of 6-inches is required in driveway areas. Construction expansion joint material shall be provided on both sides of the sidewalk match and extend vertically the entire depth of the sidewalk face.

Where concrete tint or integral color are necessary, the contractor shall match the current color as closely as possible for the area impacted.


Painted AZ 811 utility location markings for the work performed shall be removed from all
pavement, concrete sidewalk, and curb within 30-days of completing work requiring said marking information. The site shall not be deemed complete and restored until the requested markings for the project have been removed to the Inspector’s satisfaction.


All striping that is interrupted by pavement patching shall be replaced in kind.


Landscaping within the public ROW may have some additional requirements and coordination. Irrigation lines under new or modified driveways will be required to be sleeved before rebuilding the existing improvements.

Groundcover shall be replaced in kind to match. Decomposed granite (DG) used for ground cover, and rock plating shall be replaced to its original thickness and DG shall be no less than 2-inces over the top of newly excavated and compacted area. Rock plating shall have a thickness of at least 1.5 times the average diameter of the rock disturbed.

DO NOT replace the cover material with contaminated, blended, material set aside before
construction unless it can be kept from blending with the soil underneath. Protected DG, new DG, or other decorative rock cover will need to be used that matches most closely in color. The ROW Inspector will determine if it is too contaminated to reuse.


Trees and shrubs that are removed shall be replaced in kind and watered for a period of 6-
months. Trees that need to be pruned to allow room for equipment or to allow installation of infrastructure construction, shall be performed by a worker that is an arborist, certified by the International Society of Arboriculture. Certified Tree Workers under the supervision of an ISA Certified Arborist, may also perform the pruning.


The contractor shall modify all curb access ramps disturbed by the construction. Paving of the street disturbed may trigger curb access ramp modification. Pedestrian access during
construction will need to be provided during construction.

No redirection of pedestrians on an arterial or collector street shall be allowed by the MCP. A traffic lane may need to be reserved/restricted to provide pedestrian access or temporary paved path (2-inch thick by 5-ft wide min). Pavement detours shall be constructed through the construction zone.


All excavations shall be secured for safety and to provide pedestrian access after shift. Where pedestrian access is not possible, a separate pedestrian path shall be provided with the use of concrete or water barrier in the street and signed to allow safe use of the road. A temporary pavement ramp may be necessary to provide pedestrians the opportunity for a safe transition to the new path elevation from the curb.

All open trenches shall be covered by steel plates or approve materials in accordance with the City’s Supplement to the MUTCD at the end of shift.



Small wirelessfacilities shall be designed and located to minimize the impact to homeowners and business owners and to maintain the character and appearance of the surrounding neighborhood. This will include lot line location, pole appearance/aesthetics, safety, pedestrian access, and compatibility with existing utility infrastructure. To that end, support equipment shall be minimized above ground and electric meters shall be included within the pole makeup.


SWF Companies installing small cell facilities are encouraged to use existing power pole locations or replace existing streetlights with a dual-use (combination of small cell and street lighting) pole. Should this not be possible, freestanding poles, equipped with a mast arm and luminaire for potential street lighting shall be located to meet the ends described herein.

SWF poles shall not be spaced closer than 150-ft radially from one another. Different or competing communication providers shall not space separate SWF poles within150-ft of one another.

New SWF poles may not be closer than 150-ft from an existing utility pole.


It is the intent to reduce the number of poles on a street and above ground equipment from view. To that end, four different types of small cell installations may be permitted in the rights-of-way. These types include the following concepts:

  • Attachments to existing wooden power poles- Type 1,
  • Attachments to wooden streetlight poles- Type 2
  • Replacement of existing wood poles or metal streetlight poles Type 3, 3A, 3B
  • New freestanding metal pole installations Type 4.


Colocation requires permission from the pole owner. The pole must be able to withstand the extra weight of colocation equipment, fiber installations, and wind loading. A structural analysis will be required.

New steel and painted poles are desired to be used and will be required at locations where streetlights currently exist.

Existing dusk to dawn or steel street light poles already have power and their auxiliary equipment in place. Power sharing agreements can be established more easily. Providers are strongly encouraged to use these locations first.

New pole locations will have a lower acceptance by the community and may need some advanced outreach strategies.

All street lighting to be added or replaced must be 3000K LED and must meet all other requirements of the City of Tucson and Pima County Outdoor Lighting Code and UDC Standards.


11.5.1 Type 1 Utility Pole Attachment

A Type 1 Utility Pole attachment is a collocation of SWF equipment on an existing power pole. The separation between power and any equipment shall meet the Power Company’s separation guidelines to allow safe maintenance to all users.


  • Pole Mounted Equipment Shroud- 49”H x 19”W x 13”D maximum. One equipment shroud, containing all required small cell equipment, shall be installed per pole. Exception: one additional equipment shroud may be allowed per pole if the antenna is located within the second equipment shroud.
  • Strand Mounted Equipment Shroud- 9.0 cubic feet maximum strand mount equipment shroud. Only one equipment shroud shall be installed per permit location.
  • Any meter housing shall be located outside of the pedestrian path to address pedestrian or vehicle accessibility requirements.

FIGURE 15 Type 1 Pole

11.5.2 Type 2- Attachment to Wooden Streetlight Pole

To maximize the use of existing pole conditions, a cellular provider might consider the use of pre-existing streetlights on wooden poles (such as a dusk to dawn light) as a viable location. The location will need to be reviewed for spacing and position consistency requirements described herein before proceeding.

Wooden poles having overhead fiberoptic lines and that are designated to be removed/relocated shall not be considered as a viable candidate for adding streetlights and SWF equipment.

If the wood pole needs to be lengthened, the pole shall be replaced with a painted steel pole, Type 3 with accessory equipment placed at strategic locations to meet the intent of this manual or a Type 3 with equipment internal to the pole .

An existing meter pedestal may remain. New meter pedestals will require location approval. Power sharing shall be in accordance with established power sharing contract arrangements established with the City of Tucson.

New meter pedestals will require prior approval, at the City’s sole discretion, upon a showing of necessity.

Power sharing, where available, may be requested by executing a Power Sharing Rider to the Wireless Right-of-Way and submitting with an approved Site License Agreement (SLA). Power sharing is permitted at the sole discretion of the City and must be approved by Tucson Electric Power (TEP).

FIGURE 16 Type 2 Pole

11.5.3 Type 3 Combination Steel Pole (SWF and Light Pole)

A Type 3 Combination pole either replaces a streetlight pole or has the potential to provide street lighting capability in the future. Power sharing agreements apply in this instance.

A Type 3 small cell and streetlight pole may be located where an existing wooden or metal streetlight pole exists or at a new location strategically determined to provide the best cellular service. If a streetlight does not exist at a new, proposed location, the pole will be equipped and wired for a streetlight for potential future use of the light.

The Type 3 pole typically includes a concrete pole foundation, equipment cabinet, riser pole, luminaire, mast arm, luminaire control node, cantenna or antenna enclosure, and all hardware and electrical equipment necessary for a complete assembly.

The metered pedestal location may be separate from the pole in arterial and collector locations unless these street classifications pas through a residential area. Accessory equipment should avoid landscape, pedestrian pathway, or sight triangle, as much as possible. All small cell carrier equipment shall be screened and hidden behind an exterior shroud to maintain the best look of the neighborhood it is located within.

FIGURE 17 Type 3 Pole

11.5.4 TYPE 3A Steel Pole with Enclosed Meter

The Type 3A Pole is desired to meet the intent of reducing above ground equipment or obstructions. The feature of this pole is all small cell carrier equipment shall be housed internal to the pole or visibly screened / hidden behind an exterior shroud.

The Type 3A pole components shall be shaped to be visually pleasing and proportional to each other. They shall be painted to provide the best aesthetics to match the area they are located within. Directions on the color choices shall be given to the Utility Company during the pre-submittal process.

In locations where historical lighting architecture is required to be matched, the Utility Company shall match the architectural elements in style and color to the satisfaction of the community.

Type 3 combination poles should include a decorative transition over the base equipment cabinet upper bolts, hidden hardware connections, and a restriction of horizontal flat spaces greater than 1.5- inches to prevent cups, trash, and other objects from being placed on the pole components. Each pole component shall be architecturally compatible to create a cohesive aesthetic.

FIGURE 18 Type 3A Pole

11.5.5 Type 3B Steel Combination Pole (with Additional Providers)

The Type 3 pole will be allowed when the equipment for two (2) separate providers is proposed to be installed on a single pole. To qualify for this permit, the Utility Company must demonstrate that proposed deployment(s) cannot be integrated into the equipment cabinet or the cantenna.

This pole must be composed of a single equipment cabinet, riser pole, optional internal RF transparent section in the riser pole, streetlight, cantenna, and a single externally mounted equipment shroud. The exterior mounted equipment shroud shall match the pole aesthetics. Care should be taken to integrate the mounting attachments into the enclosure design.

The enclosure shall be securely strapped to the pole. Wires and cabling shall be hidden from view. Cables and wires shall be located internal to the pole until they reach a cable grommet.

Weatherproof grommets shall be installed at all cable entry points. All pole openings shall be weatherproofed to prevent interior rusting of the pole.

FIGURE 19 Type 3B Pole


All accessory equipment is desired to be contained within the SWF pole so to not add to the number of above ground obstructions that must be placed within the available right-of-way in support. If there is available space and screening is approved, the small cell accessory equipment shall be placed in proximity to a common property line between adjoining residential properties, utility easement/alleys, alleys, or drainageway access roads. The intent is to hide or minimize visual impacts equitably among adjacent and nearby properties. Screening may be necessary if the locations do not meet the intent and screen color shall meet the neighborhood approval.

Accessory equipment is allowed on arterial and collector streets. Accessory equipment may be placed adjacent to a residential property located on a corner lot provided it is not in the SVT. If accessory equipment is restricted to midblock locations, the small cell facility shall be placed away from it so that a cluster of obstructions is not formed. A SWF pole may replace existing street signposts.

If these placement requirements are not technically feasible, the applicant may submit a SWF Waiver to the City’s Utility Coordinator requesting the small cell facility be exempt from these requirements and offer alternative locations reasonably meeting the intent of these standards and minimizing impacts among residential properties.

The location of replacement poles, new poles, and supporting equipment must comply with the Americans with Disabilities Act, city construction and sidewalk clearance standards, city ordinances, and state and federal laws and regulations to provide a clear and safe passage within the rights-of-way.

Figure 20- Accessory Screening


Various colors have been selected by affected neighborhoods. New colors may be added based upon input received during the Public Interaction Meeting.

Here are the colors to date:

No Color- Galvanized (standard)

Tucson Auto Mall:
• Vendor: Benjamin Moore & Co.
• Color: Bronzetone #163-60 also known as “Ironclad Retardo”

Central Business District (Gucci Pole):
• Vendor: Sherwin Williams (Envirolastic 940 DTM)
• Color: “Tempe Brown”

Concrete Pole:
• Vendor: Powder Technology Inc.
• Color: Concrete Gray PB, Lab Number XTA1913, known by COT as “Concrete Aggregate”
(painted concrete color with specks in the paint simulating an exposed aggregate look of a
concrete pole)

Downtown Streetcar:
• Vendor: Valmont
• Color: RAL 7013-Valmont, #350318 also known as Product: B13294TM15K

Historic Flat Black & Silver:
• Vendor: Dunn-Edwards
• Color: DEA 187, EVSH10 also known as “Black”
(The flat black is applied from the pole base to a horizontal or transverse line across the diameter of the pole 6-ft above the base)
• Vendor: Dunn-Edwards
• Color: DE 6367 also known as “Covered in Platinum”
(The silver is applied from a horizontal or transverse line across the diameter of the pole, 6ft above the base, and up to the top of the pole)

*Galvanized Poles: Silver paint is not required above the black portion.

Mountain Avenue:
• Vendor: Valmont
• Color: Columbia Cascade Caspax -7, Evergreen, Product Number DS-50-59A220 – 6S Finish known by COT as “Forest Green”

Scott Avenue:
• Vendor: TIGER Drylac
• Color: RAL7013

Wood Pole:
• Vendor: Dunn-Edwards
• Color: DE6112 also known as “Cedar Chest”

Meter Cabinet:
• Vendor: Dunn-Edwards
• Color: DE6137 also known as “Tan Plan”
Pink/Salmon Pole:
• Vendor: Powder Technology Inc.
• Color: Desert Storm C.B., Product Number PT-US52-NS06 known by COT as “Desert

11.8 TREES

SWF poles shall not be placed in water harvesting areas without proper precautions and care to protect and maintain trees and shrubs that could be impacted by the construction activity. SWF poles shall be separated from existing trees and their canopy along property frontages. A separation of 25-ft is desirable.

Figure 21 SWF Poles in Amenity Zone


SWF poles proposed along arterials streets or collectors must be set back from the curb and be located behind an existing sidewalk or future 6-ft to 8-ft sidewalk area. The pole may not be located closer than the nearest streetlight pole at street corner having a traffic signal. If less than the desired pedestrian path separation is available, the provider may install a curb access ramp with a reduced dimension having no less than 5-ft in width.

SWF poles proposed in residential neighborhoods may place the pole behind the curb at existing street sign locations provided there are no additional support communications equipment above ground such as a metered pedestal cabinet. Placement of the SWF pole must consider pedestrian access to meet current or future ADA compliance setbacks.

A SWF pole may replace an existing signpost at a local street intersection in a residential neighborhood provided the following criteria are met:

  1. It is physically separated to provide the pedestrian access is provided for and no other above ground equipment is included,
  2. The curb access ramp at the street corner is modified as part of this construction to meet ADA regulations, and confirmation that any other existing utility apparatus-such as the use of a fire hydrant will not be affected.
  3. The pole may not block existing fire hydrants.

If other types of utility poles (wood or steel) exist in the vicinity of the proposed SWF pole location, the cellular provider should collocate to this pole unless there is sufficient separation (150-ft min) between the existing utility pole and the proposed SWF pole as described herein.

11.10 Property Frontages and Common Property Lines

SWF poles may not be placed anywhere along a residential frontage except for at property

In some cases where driveways are at locations that are in nonconformance with current driveway approve locations per the City Code, Chapter 25, poles may be placed to meet the intent of separation between driveways and clos to the property line. A distance no less than 5-ft from existing driveways should be maintained without additional protection such as post barricades.

Figure 22 Separations from Driveways and Trees

Figure 23 Pole Location at Common Property Line


Should the installation vary from the location approvals provided by these guidelines a written request for waiver of the specific deviation shall be forwarded for review and approved by the Utility Coordinator.

A waiver must be part of the review application and proof that all other design options have been explored to meet the intent of these guidelines. The waiver shall contain:

  • DESCRIPTION: the description of the infrastructure proposed and the public review interaction.
  • LOCATION: The location of proposed facility and list of accessory equipment shall be provided.
  • REASON: Provide the reason why a waiver is requested.
  • IMPACTS: List the impacts to other utilities and to citizens or businesses.
  • DESIGN OPTIONS CONSIDERED: Describe what other considerations were made before moving to the waiver request and why they do not work here.
  • CONCESSION: Describe what will be done as a concession if this waiver is approved. This may include screening, protection, pavement replacement, additional landscape or other
  • improvements that are beyond the scope of this improvement. The City of Tucson will review and provide a response within five business days.


These are the steps that will generally be followed. The status will be provided online. Plans and review requests can be made at

The number of people needed to complete the review is based upon the complexity, the impacts, and whether accurate information provided by the Utility Company’s consultant is contained in the ROW application.

  • DTM Staff receive plans and ROW Permit from Applicant.
  • DTM Staff verify License Agreement/ Franchise Agreement Status (if applicable).
  • Staff review for completeness (Y/N). If complete, assigned for review. If not complete, send notice to applicant.
  • Applicant provides missing information. DTM notifies Applicant of acceptance if complete.
  • Administration fees paid by Applicant.
  • Applicant sends notification out to public, copies Utility Coordinator, Ward Offices, and
  • neighborhood. Public comment period: 15-business days applies to NEW infrastructure only. (Emergency or maintenance requests do not go through this design notification process.)
  • DTM Utility Coordinator distributes to review staff.
  • Staff reviews and comments. Comments available online.
  • Utility Company is notified of status. Approved or disapproved.
  • If disapproved, re-review (if needed) _____business days upon receiving modifications and depending on the complexity. Re-review may be necessary if modifications are not made completely. Resubmittal made by Applicant.
  • Official approval given by City of Tucson. Permit fees paid by Applicant.
  • Permit issued. NTP meeting scheduled.
  • Construction expectation (NTP) meeting held with Inspection Coordinator. Dates, description, and contact info on resident notification confirmed.
  • Resident Notifications made by contractor when work is scheduled and ready to start (5- days in advance).
  • On Site inspection meeting held before work begins. Proof of notifications provided. (Work cannot start until this meeting held.)
  • Work Begins
  • Milestone inspections scheduled and made live or virtually.
  • Project completed, inspected, site restored. Live walk through scheduled.
  • Record drawing and materials testing support information provided to inspector at walk through.
  • ROW Permit closed out.



Upon receiving confirmation that a permit has been approved, the Applicant or Applicant’s
contractor shall take steps to do the following:


Before a preconstruction meeting is scheduled, the contractor shall distribute door-hangars five (5) days in advance of the start of construction to homes within 300-feet of the proposed site explaining what will occur.

Door hangars shall include:

  • A description of the work to be done;
  • The start and expected end dates;
  • The expected work hours;
  • A description of coordination measures to be taken during construction for parking, pedestrian access, mail delivery, garbage pickup, and miscellaneous needs;
  • The contractor and inspection contact information.

A sample containing the information to include is provided at

Provide a listing of the properties that resident notifications were issued to and a copy of the actual notification issued. The notification must contain the appropriate information described in the steps listed to be acceptable. Provide this information to the Inspector at the Preconstruction Meeting. If the notification is incomplete, it will need to be reissued to the residents. No work may commence until the Inspector confirms the notifications have been issued.

For new major infrastructure in the right-of-way, the utility company will establish a dedicated customer point of contact (project manager) to serve the citizens of the City of Tucson for construction issues.

NOTE: Weekly meetings will be held to assess effectiveness of the cooperation with the residents. The contractor will make alterations as necessary to protect the needs of the residents.


A preconstruction meeting must be held before construction may begin to outline the
expectations to be followed during construction. The availability of the inspector for a
preconstruction meeting and various progress inspections shall be accomplished using phone, email, and video conferences.

At a minimum, the topics to be covered at the preconstruction meeting between Contractor and Inspector shall include the following topics:

  • Resident/Business Notification verification
  • Work hours
  • Material Submittal documentation
  • Communication and expectations
  • Site Safety expectations
  • Mobility considerations
  • Required inspections (for SWF: add foundation, pole delivery, installation, connections)
  • Design changes
  • Final inspection (for SWF: add testing)
  • Close out (for SWF: add power approval)

Every day the permit is open necessitates maintenance of the site and inspection of the site. The Utility Company is encouraged to complete work as soon as possible. Work on weekends is not permitted without advance notification and inspection overtime fees.


Permits will be posted online. The contractor will be required to have a hard copy of the permit and plans with him when on site. Construction may not begin until the notifications and a preconstruction meeting have been scheduled.


A hard copy of the mobility control plan shall be with the contractor when on site. Plans must address all mobility impacts and provisions to allow users to pass through the site and not redirect them across the street where practicable.


Open excavations shall be secured with steel plates and shall be secured in place per the latest PAG Detail. All steel plates must be secured with either a cold mix wedge per PAG Standard Detail 217 or recessed into the existing pavement as follows:

  • Steel plates shall be recessed into the pavement on streets where posted traffic speeds exceed 25-mph and all downtown streets or MITZ.
  • Construction locations where steel plates are used, and where work is to take longer than 5- days shall be recessed into the pavement regardless of if it is in a residential location.

The number of inspections will vary based upon the activity and milestones. Site safety will be checked regularly, and good housekeeping measures always enforced. Inspections might be made on site, virtually, and in case of emergency sufficient notification and documentation required by the ROW Permit process made in a reasonable and prudent time.


No work may be done unless a permit is active, resident notification made, and a preconstruction conference has been held.

Preconstruction meetings may be on site or virtual depending on the scheduling and availability of the Inspector.


The DTM Inspector shall make regular scheduled or nonscheduled progress inspections. The construction site must be safe, clean, and all work in compliance with the PAG Standard Specifications and Details. Failure to meet these requirements are grounds to stop work.


Field design changes may be necessary when incorrect plan information is discovered that conflicts with actual filed information. Design changes must be submitted to the department for review and approval. The decision to make changes in the field shall be guided by the following:

  • Minor change
    A change in alignment of no more than 5-ft horizontally and 1-ft vertically is considered minor. The infrastructure must remain in the same specified, approved, utility corridor and the approved depth must be maintained.
  • Major change
    An alignment, or location change exceeding the description for a minor change. A major change shall require a plan revision that will need to be submitted for review and approval for location and/or depth.

14.2.1 Field Change Approval

Minor field change approval can be authorized by the Inspector assigned to the permit. Major changes to the design as described above require a resubmittal of the plans to the department. The design professional for the work shall make the changes to the plans and submit for review to the department.


At a minimum, the following checklist shall be considered and followed during the planning,
design, and construction of new, modified, or maintained utility infrastructure:

  • Off-site construction support activities.
  • Spill prevention and response.
  • Vehicle and equipment entrances.
  • Chemical and materials storage.
  • Solid waste management.
  • Dust control.
  • Soil stabilization.
  • Erosion control.
  • Any non-stormwater discharges.

The contractor should refer to the ADOT Erosion and Pollution Control Manual to determine the best management practices (BMP) for each item listed above.


The contractor shall provide the inspector with records of material delivery tickets for materials used on site to backfill and patch the street. Materials used must meet current City of Tucson mix designs on file with the DTM Testing laboratory. Material density test results shall also be provided at the frequency required for the respective type and quantity of the material as discussed at the preconstruction conference. The records shall reflect the date, time, and company providing the material or tests.

These delivery tickets and testing results may be a pdf or jpeg format. Copies shall be emailed, or text messaged with attachments for record proof of the quality of work performed at the respective construction site.


A final inspection will need to be made so that the permit can be closed out. If the site is
unacceptable, the permit will not be closed out. Renewal of the permit will need to be made if the contractor is out of time and work is not completed.

14.5.1 Record Drawings

The contractor is required to keep the construction documents with him and make all necessary changes to the plans. A final document shall be provided to the City Inspector at the completion of the work along with bore logs, elevations, dimensions that were confirmed during construction. A certification of correct information will need to be made by the Utility Company or Utility Company’s agent/designer.

Record drawings shall require a certification statement that all information depicted is accurate and correct.

Delivery tickets and testing results shall be provided and made part of the permit record.


A permit shall not be considered closed out until the site is restored to its original condition or better; the site is cleaned up; barricades are removed; and record drawings are provided to the City in electronic format (PDF).

The final information shall be made a part of the permit record.


The permit duration shall be as applied for unless renewals have occurred. Work that is done under an expired permit may warrant a citation for work without a permit.

ALL Work must be completed within this time. Additional permits may require a delay in completing the work per the contractor’s schedule and make availability of materials difficult. In some cases, other work and activities will compete for space and restriction consequences. The costs to all who are responsible for the site safety and compliance add up each day that work is not completed. Additional fees may be assessed if work is done after the permit expiration and if not renewed.

14.7.1 Number of Permits Allowed to Remain Open at One Time

It is the intent to make any utility installation less impactful to the City of Tucson residents. Quick prosecution of the work is expected and will help develop better public relations with the City of Tucson residents. Work is encouraged to be completed as soon as possible and within the approved permit duration. Regulation of permit approval and issuance will be employed to ensure that this intent is met.

Utility work is either new, maintenance, or emergency. The direction in this section applies to new utility infrastructure work only.

  • No more than 10 permits where minor work is required to close out the final requirements will be allowed to be renewed. This may affect the ability of the applicant or their agent to receive future permits. Renewals must be made in anticipation and work started within 30- days of the renewal date.
  • No more than 5 construction sites per general contractor will be allowed to remain open and under construction. Sites must be completed, inspected, and finalized before consideration of future requests will be given. As sites are closed out, new sites will be advanced. Demonstration of cooperation and consistency may allow sites to be constructed at one time.


The ROW permit will not be extended beyond the approved duration. Should follow up work be required, a new permit will need to be obtained. This shall be followed for temporary patching that may be installed and scheduling of the permanent patch is delayed due to unavailability of materials only. Proof of unavailability shall be required.


Abatement for violations of this standard shall consist of paving/overlaying a substantial portion of the affected roadway. The extent of the paving/overlaying shall be determined by the City Engineer, or designated representative.


14.10.1 Modifications

Emergency situations and other conditions not specifically addressed by this standard shall be judged on a case-by-case basis by the City Engineer, or designated representative, without setting precedent.

14.10.2 Appeals

Appeals to rulings made under this standard shall be to the Director of Transportation, whose decision shall be final.


EXHIBIT A T-TOP Modified PAG Standard Detail 216 Detail

EXHIBIT B Pothole Patch

EXHIBIT C Moratorium Patch Limits

EXHIBIT D Holiday Restrictions


(This applies to new utility infrastructure only)


Where is this infrastructure proposed?


Provide a description of the infrastructure to be installed or constructed:

Has there been any opposition from the general public to the project or the location of above ground equipment? Describe the nature of the objection if it exists and where objections have been expressed:


Describe if this is above ground, below ground; will impact access; affect street capacity; etc.


What is the reason for this waiver request?


Describe what has been considered during the design to address public concern and minimize impacts to residents and businesses.


What is your company willing to do differently that will make this acceptable to all affected?
Thank you. The City of Tucson will review and provide a response within five business days.

Thank you. The City of Tucson will review and provide a response within five business days.


Utility Waiver Form