HomeMy WebLinkAboutcoa.lu.ca.980 gibson 0054.2009 THE CITY OF ASPEN
City of Aspen Community Development Department
CASE NUMBER 0054.2009.ASLU
PARCEL ID NUMBER 273707410001
PROJECTS ADDRESS 980 GIBSON AVE
PLANNER JENNIFER PHELAN
CASE DESCRIPTION CODE INTERPRETATION - APPEAL
REPRESENTATIVE GARFIELD & HECHT
DATE OF FINAL ACTION 12/4/09
CLOSED BY ANGELA SCOREY ON: 03.30.11
RESOLUTION NO. 100
(SERIES OF 2009)
A RESOLUTION OF THE CITY OF ASPEN CITY COUNCIL AFFIRMING AN
INTERPRETATION OF THE LAND USE CODE MADE BY THE COMMUNITY
DEVELOPMENT DIRECTOR REGARDING LOT AREA AND DEVELOPMENT
RIGHTS.
WHEREAS, the Community Development Director received a request for an
interpretation of the Land Use Code regarding Floor Area and development rights from the
owner of an area of land gained through quiet title action (Pitkin County Case No. 06 -CV -165)
and described as the "northerly parcel" represented by Attorney David McConaughy; and,
WHEREAS, pursuant to Chapter 26.306 — Interpretations of Title, the Director rendered
a decision and the owner sought an appeal; and,
WHEREAS, the City Council, pursuant to Chapter 26.316, may affirm the Interpretation
of the Director or modify or reverse the Interpretation upon a finding that there was a denial of
due process, exceeding of jurisdiction, or abuse of authority in rendering the interpretation; and,
WHEREAS, the City Council has taken and considered written and oral argument from
Attorney David McConaughy representing the appellant, and the Community Development
Director, and has found that the Director provided due process and neither exceeded his
jurisdiction or abused his authority in rendering the Interpretation; and,
WHEREAS, the City of Aspen City Council finds that this Resolution furthers and is
necessary for the promotion of public health, safety, and welfare.
NOW, THEREFORE BE IT RESOLVED that the City Council affirms the Community
Development Director's Interpretation of the Land Use Code regarding Floor Area and
development rights associated with the "northerly parcel."
This Resolution shall not affect any existing litigation and shall not operate as an abatement of
any action or proceeding now pending under or by virtue of the ordinances repealed or amended
as herein provided, and the same shall be conducted and concluded under such prior ordinances.
If any section, subsection, sentence, clause, phrase, or portion of this Resolution is for any reason
held invalid or unconstitutional in a court of competent jurisdiction, such portion shall be
deemed a separate, distinct and independent provision and shall not affect the validity of the
remaining portions thereof.
APPROVED by the Aspen City Council at its regular meeting on November 23, 2009.
ATT T:
ar
A .410(10 ,A1 ://f 4
Kathryn S. V, ity Clerk Michael C. Ireland, M.; or
APPROVED AS TO FORM:
7
John' I orcester, City Attorney
Resolution No.--, Series of 2009. Page 1
Regular Meeting Aspen City Council November 23, 2009
Mayor Ireland said it is pretty clear that conceptual does not mean final approval and his
final vote will depend on overcoming the concern that this project not become a large
empty space blocking the views of the mountain.
Roll call vote; Councilmembers Torre, no; Romero, yes; Skadron, yes; Mayor Ireland,
yes. Motion carried.
RESOLUTION #100, SERIES OF 2009 — 980 Gibson Code Interpretation Appeal
Jennifer Phelan, community development department, told Council this is an appeal of a
code interpretation regarding development rights and floor area associated with an area of
land gained through a quiet title action. Ms. Phelan told Council this is bounded by
Matchless Drive and Gibson Avenue; it is the northerly parcel. Ms. Phelan noted the
community development director is required to provide interpretations of the land use
code. The applicant requested an interpretation about this parcel of land, which was
acquired through quiet title action. In the interpretation, staff noted that this 5600 square
foot parcel does not have any floor area nor any development right associated with it.
Ms. Phelan pointed out the appeal asked 3 things; an answer to all of the 5 questions
posed in initial request; reversal of the determination that the northerly parcel has no floor
area; and that the property is considered to have a development right and to be reviewed
through growth management administratively. Ms. Phelan said regarding not answering
questions 1, 2, and 3, staff felt those were hypothetical and interrogatory question rather
than providing clarity around the text in the code. Ms. Phelan said regarding the
determination of no floor area for the northerly parcel, the land use code says that certain
things are deducted from a lot area in calculating floor area. One of those is proposed
dedicated rights -of -way. Ms. Phelan said this area of land gained through quiet title
action was a proposed right -of -way and dedicated by the subdivider of the Alpine Acres
subdivision, which was 5 lots and 2 streets. Ms. Phelan said staff determined this was a
proposed right -of -way and could not be counted toward the definition of lot area and
there is no associated floor area.
Ms. Phelan said there was a request to go through administrative growth management.
Ms Phelan reminded Council all lots within the city are required to go through growth
management review. This has not and staff does not believe this lot meets the criteria to
be reviewed administratively. This area of land was platted as a right of -way and
expected to be a right -of -way. This is part of a 5 lot subdivision; there are other lots in
this subdivision that have gone through additional subdivision review and this property
has not. Ms. Phelan said this is no different than an adverse possession claim where the
beneficiary cannot develop land gained through adverse possession. Ms. Phelan pointed
out there are 3 criteria for overturning a code interpretation; lack of due process, excess
of jurisdiction, or abuse of discretion. Ms. Phelan stated staff met the due process by
notice requirements. The community development director is required by the land use
code to issue interpretations of the title of the code so the jurisdiction was not abused.
Ms. Phelan said in interpreting the land use code, some discretion has to be used;
however, staff does not feel there was an abuse of discretion.
16
Regular Meeting Aspen City Council November 23. 2009
John Worcester, city attorney, noted this is an appeal on the record and Council has to
limit their discussions to the record before them. Council can only reverse the decision of
the community development director if they find a denial of due process, an abuse of
discretion or excess of jurisdiction, that they misapplied the law.
David McConaughy, representing the applicant, said the only stated reason he has found
from community development department about why this parcel does not have floor area
is that it was a proposed right -of -way, not because it was acquired through quiet title or
adverse possession. Mayor Ireland said the land use code 26.575.020(c) that area within
a vacated right -of -way or within an existing or proposed dedication right of way or
surface easement does not control the issue. McConaughy said they can agree this is not
a current right -of -way and agree it is not a vacated right -of -way because it was never
dedicated and the question is, is it a proposed right -of -way. McConaughy stated the
applicant's goal is to redevelop the property and they need to know what the starting
point is. McConaughy said to that end, they asked staff what land use entitlements were
associated with this parcel and were told there were none; it is sterile ground and not a
separate parcel. McConaughy said the first 3 questions go to the issue of whether this is a
separate parcel. McConaughy noted the parcel is shown on the map; the court created it
as a parcel and it is not owned the same way the adjacent parcel is.
Mayor Ireland asked if allowing quiet title creation of separate parcel in a separate entity
opens the door to subdivision by court action and does the city have the right to stand up
against that. McConaughy said the city does not because that parcel was created by an
order of the court and it is what it is; the city was a party to that case. McConaughy said
the question is whether there are development rights associated with that parcel.
McConaughy said if the answer is yes, the applicant would like to come back with a plan
and first they need to know what the floor area would be. McConaughy said the only
stated reason is that this was a proposed right -of -way. McConaughy questioned what
"proposed" means, ever proposed. It was proposed on a plat and approved by the county
in 1964 and annexed into the city in 1976. This was never accepted as a right -of -way by
the county and when it was annexed, it was known it had not been constructed so it is not
currently proposed. McConaughy said this was proposed once; however, it does not
mean the property is sterilized as a right -of -way forever. There has to be some
connection to reality. McConaughy stated their position is if the discussion is a
"proposed right -of- way ", there needs to be an actual proposal. McConaughy stated
nobody thinks this will ever be a right -of -way; the city disclaimed all interest in this
parcel. McConaughy told Council the applicants agree they need a growth management
quota to develop the lot. The issue is whether they are eligible for an administrative
review. McConaughy pointed out the staff memorandum argues that the property has to
be legally existing in the city prior to 1977. McConaughy reiterated this was annexed as
a separate metes and bounds parcel in 1976. Ms. Phelan pointed out the plat shows
Herron drive and Silverking drive, which were the original dedicated right -of -way in the
Alpine Acres subdivision on the annexation plat.
Mayor Ireland asked if the parcels were under common ownership, they were merged.
McConaughy said those parcels were in no man's land until the court determination.
17
Regular Meeting Aspen City Council November 23, 2009
McConaughy said the reason this is ineligible for administrative review because it was
not in the city until 1977 it not right; it was annexed in 1976. McConaughy said the real
point is whether there is floor area associated with the parcel. Mayor Ireland said he
would like to know if the parcels were merged because no matter what the court decrees,
there is not a separate parcel and it cannot get a growth management quota.
McConaughy showed the northerly parcel and the southerly parcel and when it was
annexed, all was shown as one legal parcel and not part of the lot, not part of the common
elements, so there was a parcel. Mayor Ireland asked if there was ownership of the parcel
by the adjoining properties. McConaughy said not by his clients. McConaughy said the
shaded area shown on the plat as a right -of -way was not owned by the city or the county.
Mayor Ireland asked why the adjoining owners did not own this land and if the court was
correct and the adjoining property owners owned it, and then the land was merged as
adjoining parcels. Mayor Ireland said parcels do not have to be owned by the city to
merge with the adjoining lots. Mayor Ireland noted there is not such a thing as a parcel
that does not have ownership.
Ms. Phelan said this property was platted as a right -of -way, not as a developable lot. It
was annexed as Silverking Drive, not as a developable lot. Councilman Romero asked if
Herron Drive had the same conditions. Ms. Phelan said it was platted as a right -of -way.
McConaughy said that was accepted because it was built. Ms. Phelan said the Silverking
Drive was proposed and dedicated as a right -of -way. McConaughy said the language on
the 1964 plat says, "the foregoing plat is accepted for filing and conveyance of roads
thereon and temporarily and conditionally approved by the Board of County
Commissioners and acceptance of said roads is subject to satisfactory construction hereof
by subdivider ", which never happened and the county never accepted the dedication, and
that's why the city agreed that it acquired no ownership when it annexes and that's why
the court found it could be adversely possessed.
Mayor Ireland said if someone owns two adjacent parcel with a condominium on one and
vacate land on the other and there was common ownership prior to 1970's, it becomes
one parcel; it is merged. McConaughy said if they submit a re- subdivision application,
the separate parcel issue is moot. The question is what the allowable floor area is.
Councilman Torre asked if there are any utilities running through this parcel. David
noted there is an underground sewer line. Councilman Torre stated he cannot find that
the development director abused his discretion or went outside his jurisdiction.
Councilman Skadron concurred and stated the community development director's
interpretation was ethical and there was no abuse of authority. Councilman Johnson said
with due process and discretion, he is comfortable with the decision of the community
development director. Councilman Johnson asked if there is any room for negotiation on
the size of the floor area. Worcester answered it is not an issue of whether the applicant
is entitled to 100 square feet or 200 square feet; they are either entitled to FAR or not
based upon the language in the code. Worcester said part of the issue is what does
proposed right -of -way mean. Mayor Ireland said he does not understand how this would
escape merger. Worcester said that was not part of the consideration. Worcester said
18
Regular Meeting Aspen City Council November 23, 2009
there is no doubt there was a proposed right -of -way in the past, it was never dedicated
properly. It was not accepted by the county and when the land was annexed, it was not
accepted by the city. It was a proposed right -of -way at one point. Worcester pointed out
when rights -of -way are vacated; the property can no longer by counted toward the FAR.
McConaughy said they are requesting Council direct staff to answer the questions.
Mayor Ireland stated there is no entitlement to have hypothetical questions answered.
Councilman Romero stated the community development director exercised his discretion
based on the language of proposed right -of -way and there was no over extension of reach
based on the record in front of Council. Mayor Ireland said he feels this revolves around
showing there is a separately owned parcel before one can get development rights.
Mayor Ireland moved to adopt Resolution #100, Series of 2009, affirming the community
development director's interpretation; seconded by Councilman Torre. All in favor,
motion carried.
Councilman Johnson moved to adjourn at 10:30 p.m.; seconded by Councilman Torre.
All in favor, motion carried.
d ij r
Kathryn S. och, City Clerk
19
/�. r
'"' P211
MEMORANDUM
TO: Mayor Ireland and Aspen City Council
COPY: John Worcester, City Attorney /
THROUGH: Chris Bendon, Community Development Director
FROM: Jennifer Phelan, Deputy Planning Director �'�' �' //
RE: Appeal of Land Use Code Interpretation — -Lot Area and Development
Right
DATE: November 23, 2009
APPLICANT /OWNER: the "northerly parcel" be reviewed administratively with regard
MD 1, LLC to growth management.
REPRESENTATIVE: STAFF RECOMMENDATION:
David McConaughy, Staff recommends City Council uphold the Director's
Garfield and Hecht, PC interpretation by adopting the proposed Resolution affirming the
interpretation and not require staff to respond to the 3 questions
LOCATION: posed by the Applicant in the original interpretation request.
Alpine Acres Subdivision,
specifically a former ,: %- s
platted right -of -way within „ / 0
the subdivision that is • „ * 1 ",.. /� '
described as the "northerly issued b � ` `�%� //,
the Community y ° /
Development Director. Q � rk' It 4' in
The Applicant requests -t,. , , ZW24 4 ' � je, et: l � 'P " 4r %/ e . /0 Er
initial interpretation 1 1: = ,� a-:,31\-- ? ` * . ° ° i -r ✓.=
,z � ,,, //A �.�. it � � % / / / / / / / / /G .,
request, 2) reverse staff's Figure I: Vicinity Map of "northerly parcel"
conclusion that the
"northerly parcel" has no
floor area, and 3) permit
1
P 212
SUMMARY:
One of the jobs assigned to the Community Development Director is to provide
interpretations of the text of the City's Land Use Code. This is a formal process in which an
applicant requests a written interpretation and, if they don't agree with the interpretation,
affords the applicant the right to appeal the decision to the City Council.
Section 26.316.030 of the Aspen Land Use Code sets forth the applicable standard of review
that Council should follow in these matters and the actions available to Council following the
hearings on the appeals.
STANDARD OF REVIEW:
Section 26.316.030(E) reads as follows:
Standard of review. Unless otherwise specifically stated in this title, the decision -
making body authorized to hear the appeal [City Council] shall decide the appeal
based solely upon the record established by the body from which the appeal is taken
[Community Development Director]. A decision or determination shall not be
reversed or modified unless there is a finding that there was a denial of due process,
or the administrative body has exceeded its jurisdiction or abused its discretion.
The Land Use Code does not define the terms: "a denial of due process ", "exceeded its
jurisdiction," or "abused its discretion." Court cases, however, have helped define these terms
as follows and may be used by Council in its deliberation of the appeal:
A denial of due process may be found if some procedural irregularity is determined to have
occurred that affected a significant right of the appellant, or the administrative body
otherwise acted in violation of the appellant's constitutional or statutory rights. Ad Hoc
Executive Committee of Medical Staff of Memorial Hospital v Runyan, 716 P. 2d 465 (Colo.
1986.)
A decision may be considered to be an abuse of discretion if the "decision of the
administrative body is so devoid of evidentiary support that it can only be explained as an
arbitrary and capricious exercise of authority." Ross v Fire and Police Pension Ass 'n., 713
P.2d 1304 (Colo. 1986); Marker v Colorado Springs, 336 P.2d 305 (Colo. 1959).
A decision may be considered to be in excess of jurisdiction if the decision being appealed
from "is grounded in a misconstruction or misapplication of the law," City of Colorado
Springs v Givan, 897 P.2d 753 (Colo. 1995); or, the decision being appealed from was not
within the authority of the administrative body to make. City of Colorado Springs v
SecureCare Self Storage, Inc., 10 P.3d 1244 (Colo. 2000).
2
'Vs.- P213
ACTIONS BY COUNCIL FOLLOWING APPEAL HEARING:
Section 26.316.030(F) reads as follows:
Action by the decision - making body hearing the appeal. The decision - making body
hearing the appeal may reverse, affirm, or modify the decision or determination
appealed from, and, if the decision is modified, shall be deemed to have all the
powers of the officer, board or commission from whom the appeal is taken, including
the power to impose reasonable conditions to be complied with by the appellant. The
decision shall be approved by resolution. All appeals shall be public meetings.
BACKGROUND:
In this case, the interpretation rendered by the Director essentially discusses whether there is
floor area or a development right associated with a specific area of land that was gained
through a quiet title action (described as the "northerly parcel" within this memo) and shown
in Figure 2, below. The interpretation request arose after the Applicant met with Community
Development staff and was provided a pre - application conference summary primarily stating
that no floor area or development rights are associated with the subject area of land gained
through the quiet title action. The Applicant disagreed with those two points in the summary
and requested an interpretation, by posing a number of questions, to gain better understanding
of staffs conclusion in the pre - application conference summary.
1 I ' * " 1 1
, €
x .e v /� 6
y // / 11 ta, NN N
W,1' / e � S« ��� / � �� t —
—Ai
b
/ _ 0 ♦ t,
N. 2 <---lie
Sp W
\ \ 9 Vfry `E s . v \// i
n
\ \ /
Figure 2: "Northerly parcel" gained through quiet title action
As noted in the Appeal request (Exhibit B), the Applicant is requesting Council to address
three issues in this Appeal. These issues are listed below and are addressed individually in the
memo:
1) The interpretation did not answer three questions submitted in the interpretation
request — and the Director should be directed to do so; and,
3
P214 _ C
2) The interpretation finds that the land area gained through quiet title is a proposed
right -of way and therefore is excluded from the calculation of Lot Area (resulting in
the "northerly parcel" having no floor area associated with it) — and the Director's
finding should be reversed; and,
3) The "northerly parcel" is not eligible for development because it has never received
a Growth Management Review under Chapter 26.470 of the Land Use Code — and the
Council should amend the interpretation to allow the land area to apply for
administrative growth management review. *
Issue 1) The Interpretation issued did not answer questions 1, 2 and 3.
The purpose of an interpretation is to provide an explanation of the meaning of the text of the
Land Use Code and boundaries of the zone district map. As noted previously, the request for
an interpretation was a result of staff's determination in a pre- application conference
summary that the subject area of land has no associated floor area or a development right.
Although five questions were posed, a number of the questions were essentially interrogatory
questions, seeking legal opinions and posing inappropriate hypotheticals. Staff's role in a
code interpretation is to interpret the actual text of the code, not to respond to hypothetical
questions. As such staff answered the ultimate questions posed in the interpretation request:
whether the "northerly parcel" has a development right or floor area associated with it.
Issue 2) The Interpretation finds that the land area gained through quiet title is a proposed
dedicated right -of way.
The calculation of Allowable Floor Area is based upon the size of the Lot Area. Lot Area can
be a net number rather than gross number due to adopted exclusions from Lot Area within the
Land Use Code. Section 26.575.020(C), Lot Area, of the Land Use Code states, "excluded
from total lot area...is that area within a vacated right -of -way, or within an existing or
proposed dedicated right -of -way (emphasis added) or surface easement."
The "northerly parcel" is part of an unimproved proposed right -of -way originally known as
Silver King Drive (now known as Matchless Drive) that is part of Alpine Acres Subdivision
(Figure 3). The right -of -way was proposed as a public right -of -way by the dedication
certificate on the Alpine Acres subdivision plat. A portion of the dedication reads, "and does
hereby convey to Pitkin County, for public use, Silver King Drive and Herron Drive, as
platted for roadway easements."
4
P215
AaCKr _r. ^�
er -
•
t
. .. _ t _-
\
xr rr. SK xr .. r :.... .�-
u.-
Figure 3: Alpine Acres Subdivision plat
The City's Land Use Code defines "public right -of -way" as, "a dedicated strip or other area
of land on or over which the city and/or public may travel or use for passage and within
which public utilities and/or streets, alleys, trails, sidewalks and other ways may be
installed." Although not improved to standard street improvement requirements and
consequently not accepted by Pitkin County due to the lack of improvement, the subject area
of Silver King Drive was proposed for dedication as a public right -of -way by the original
subdivider of Alpine Acres by the plat's dedication language.
The City's Land Use Code does not define the term "proposed." This requires the Director
use some discretion. Further, the code does not define the timeframe in which the proposal
must occur, whether the proposal needs to be formally accepted, or in whose jurisdiction the
proposal is made. Quite simply, the Alpine Acres Subdivision plat was approved by Pitkin
County with Silver King Drive and Herron Drive proposed as a public- right -of -way. The
County consented, with the signing of the plat, to the creation of both streets. Clearly, the
developer "proposed" or offered both drives as dedicated rights -of -way to the County.
Subsequently, when the entire subdivision was annexed into the City, the annexation plat
accepted by the City shows both Herron Drive and Silver King Drive.
3) The land area is not eligible for development because it has never received a Growth
Management Review under Chapter 26.470 of the Land Use Code.
In the interpretation rendered by the Director, it is noted that the land associated with the
quiet title action has not received a growth management allotment or exemption in order to
have a development right. All development within the City is subject to Chapter 26.470,
Growth Management Quota System, and commonly described as growth management
review. The Applicant states that the "northerly parcel" should be eligible for an
administrative growth management review under Section 26.470.060 (B), Single - Family and
5
P216
Duplex Dwelling Units; however, the "northerly parcel" does not meet any of the necessary
conditions to be reviewed under this subsection.
To be reviewed under this subsection, a vacant lot must meet one of the following conditions:
it was created by a lot split, it was created by a historic lot split, or it was subdivided or
legally described prior to November 14, 1977. This vacant area of land does not meet any of
these criteria and cannot be reviewed administratively.
Alpine Acres Subdivision was originally approved by the County with five (5) lots and two
roads. If the composition of the subdivision is to change, it requires subdivision review to
ensure orderly development such as providing adequate access or public utilities. For
example, Lot 5 has been subdivided through City Council review and approval and is now
two lots instead of one. A subdivision review by the City has not occurred and the quiet title
action was not reviewed under the expectation of development rights being created.
STANDARDS OF REVIEW:
1. Due Process — The applicant has met with staff on a number of occasions to discuss his
rights associated with the subject land area. After the pre - application summary was
provided to him, his representative requested an Interpretation based on clarifying the
basis of staff's conclusions in the pre - application summary (no floor area or a
development right is associated with the subject area of land). An Interpretation provides
the opportunity for a party to appeal the findings.
Certain timeframes affect when interpretations must be provided after a request and when
appeals need to be scheduled. Those timeframes have been met. As required by the Land
Use Code, the appellant was provided notice of tonight's meeting via registered mail and
all other affected parties were noticed by publication in the newspaper, as required.
(Please see Exhibit D). Assuming tonight's meeting does not contain any procedural
flaws, staff believes that proper procedural due process has been provided.
In providing an interpretation, the Director relied on the facts presented and the language
within the Land Use Code. Definitions within the code such as "right -of -way" and "Lot
Area" were used in evaluating the original plat creating Alpine Acres and any rights
associated with the land area gained through quiet title action. Although "proposed" is not
defined in the Land Use Code, staff applied the common definition of the word in
evaluating the code language and rendering an interpretation. Staff's interpretation was
not arbitrary and provided substantive due process.
2. Jurisdiction — The Director's jurisdiction to interpret the Land Use Code is established in
Chapter 26.210 of the City of Aspen Land Use Code. This Chapter outlines the
jurisdiction, authority, and duties allocated to the Community Development Director.
One of the Director's duties outlined in the Chapter reads: "To render interpretations of
this Title or the boundaries of the Official Zone District Map pursuant to Chapter
26.306." Staff believes this language is clear and it does not appear that the applicant is
questioning this provision of the code.
6
P217
3. Discretion — With respect to abuse of the Director's discretion, the Director did need to
use his discretion in rendering the interpretation. The question is whether the Director
abused that discretion. With regard to issue 1, the Director is required to interpret specific
text of the code to provide explanation and clarity. Staff does not believe hypothetical
questions addressing a very specific application of the code to a property are proper
matters for code interpretations. This style of questioning is not typically used to clarify
the meaning of the text of the Land Use Code. These are interrogatory questions,
possibly containing limited facts, aimed at sequentially establishing a property right in a
"gotcha" fashion.
With regard to issue 2, there is no definition of "proposed" outlined in the code and staff
used a literal interpretation, as Silver King Drive was proposed by the subdivider as a
public right -of -way. In looking at issue 3, staff simply noted that all development is
required to go through growth management review and such review has not occurred for
the "northerly parcel" created through quiet title action.
Staff tends to approach these sorts of tasks with a very pragmatic and realistic
administration of development limitations. The Land Use Code does not predict every
type of circumstance. Staff considers the text of the code as well as the effects that would
be expected with different interpretations. The Director believes that his discretion was
applied appropriately and the Interpretation was rendered ethically.
CODE INTERPRETATION AND CODE AMENDMENT:
The question in a code interpretation is what does the code say? On occasion, applicants
seek a code interpretation because they believe the code should say something else. The code
amendment process is the proper venue for the question what should the code say?
Two RESOLUTIONS:
Attached are two Resolutions. One finds that the Director acted correctly and affirms the
interpretation. The second finds that the Director exceeded his jurisdiction, abused his
authority, or failed to provide due process and reverses the interpretation.
RECOMMENDATION:
Staff believes the Director's interpretation was rendered ethically and that no abuse of
authority or exceeding of jurisdiction occurred. Staff recommends City Council uphold
the Director's interpretation by adopting the proposed Resolution affirming the
interpretation.
CITY MANAGER COMMENTS:
7
r
P 218 �..
RECOMMENDED MOTION: (all motions must be made in the positive)
"I move to approve Resolution No. ft) 0 , Series of 2009, [affirming or reversing] the
Community Development Director's interpretation of the Land Use Code regarding Lot Area
and development rights.
ATTACHMENTS:
Exhibit A — Interpretation dated August 19, 2009 and Interpretation request
Exhibit B — Appeal letter from David McConaughy dated September 1, 2009, with exhibits
Exhibit C — Land Use Code Section Regarding Appeals
Exhibit D — Affidavit of notice
Exhibit E — Additional correspondence from David McConaughy dated October 9, 2009,
with exhibits
8
RESOLUTION NO. , ' P 219
(SERIES OF 2009)
A RESOLUTION OF THE CITY OF ASPEN CITY COUNCIL AFFIRMING AN
INTERPRETATION OF THE LAND USE CODE MADE BY THE COMMUNITY
DEVELOPMENT DIRECTOR REGARDING LOT AREA AND DEVELOPMENT
RIGHTS.
WHEREAS, the Community Development Director received a request for an
interpretation of the Land Use Code regarding Floor Area and development rights from the
owner of an area of land gained through quiet title action (Pitkin County Case No. 06 -CV -165)
and described as the "northerly parcel" represented by Attorney David McConaughy; and,
WHEREAS, pursuant to Chapter 26.306 — Interpretations of Title, the Director rendered
a decision and the owner sought an appeal; and,
WHEREAS, the City Council, pursuant to Chapter 26.316, may affirm the Interpretation
of the Director or modify or reverse the Interpretation upon a finding that there was a denial of
due process, exceeding of jurisdiction, or abuse of authority in rendering the interpretation; and,
WHEREAS, the City Council has taken and considered written and oral argument from
Attorney David McConaughy representing the appellant, and the Community Development
Director, and has found that the Director provided due process and neither exceeded his
jurisdiction or abused his authority in rendering the Interpretation; and,
WHEREAS, the City of Aspen City Council finds that this Resolution furthers and is
necessary for the promotion of public health, safety, and welfare.
NOW, THEREFORE BE IT RESOLVED that the City Council affirms the Community
Development Director's Interpretation of the Land Use Code regarding Floor Area and
development rights associated with the "northerly parcel."
This Resolution shall not affect any existing litigation and shall not operate as an abatement of
any action or proceeding now pending under or by virtue of the ordinances repealed or amended
as herein provided, and the same shall be conducted and concluded under such prior ordinances.
If any section, subsection, sentence, clause, phrase, or portion of this Resolution is for any reason
held invalid or unconstitutional in a court of competent jurisdiction, such portion shall be
deemed a separate, distinct and independent provision and shall not affect the validity of the
remaining portions thereof.
APPROVED by the Aspen City Council at its regular meeting on , 2009.
ATTEST:
Kathryn S. Koch, City Clerk Michael C. Ireland, Mayor
APPROVED AS TO FORM:
John Worcester, City Attorney
Resolution No,--, Series of 2009. Page I
P220 �-
RESOLUTION NO. _
(SERIES OF 2009)
A RESOLUTION OF THE CITY OF ASPEN CITY COUNCIL REVERSING AN
INTERPRETATION OF THE LAND USE CODE MADE BY THE COMMUNITY
DEVELOPMENT DIRECTOR REGARDING LOT AREA AND DEVELOPMENT
RIGHTS.
WHEREAS, the Community Development Director received a request for an
interpretation of the Land Use Code regarding Floor Area and development rights from the
owner of an area of land gained through quiet title action (Pitkin County Case No. 06 -CV -165)
and described as the "northerly parcel" represented by Attorney David McConaughy; and,
WHEREAS, pursuant to Chapter 26.306 — Interpretations of Title, the Director rendered
a decision and the applicant sought an appeal; and,
WHEREAS, the City Council, pursuant to Chapter 26.316, may affirm the Interpretation
of the Director or modify or reverse the Interpretation upon a finding that there was a denial of
due process, exceeding of jurisdiction, or abuse of authority in rendering the interpretation; and,
WHEREAS, the City Council has taken and considered written and verbal testimony
from Attorney David McConaughy representing the appellant, the Community Development
Director, and has found that the Director did not provide due process or either exceeded his
jurisdiction or abused his authority in rendering the Interpretation; and,
WHEREAS, the City of Aspen City Council finds that this Resolution furthers and is
necessary for the promotion of public health, safety, and welfare.
NOW, THEREFORE BE IT RESOLVED that the City Council reverses the Community
Development Director's Interpretation of the Land Use Code regarding Lot Area and
development rights associated with the "northerly parcel."
1) The "northerly parcel" cannot be considered a proposed dedicated right -of -way and
therefore should not be excluded from Lot Area.
2) The "northerly parcel" is available for administrative growth management review under
section 26.470.060 (B), Single - family and Duplex Dwelling units of the land use code.
3) Staff is directed to answer questions 1, 2, and 3 of Attorney David McConaughy's
correspondence dated July 20, 2009.
This Resolution shall not affect any existing litigation and shall not operate as an abatement of
any action or proceeding now pending under or by virtue of the ordinances repealed or amended
as herein provided, and the same shall be conducted and concluded under such prior ordinances.
If any section, subsection, sentence, clause, phrase, or portion of this Resolution is for any reason
held invalid or unconstitutional in a court of competent jurisdiction, such portion shall be
deemed a separate, distinct and independent provision and shall not affect the validity of the
remaining portions thereof.
APPROVED by the Aspen City Council at its regular meeting on , 2009.
Resolution No. , Series of 2009. Page I
P221
ATTEST:
Kathryn S. Koch, City Clerk Michael C. Ireland, Mayor
APPROVED AS TO FORM:
John Worcester, City Attorney
Resolution No. , Series of 2009. Page 2
P222 — — t \ `L
CITY OF ASPEN
COMMUNITY DEVELOPMENT DEPARTMENT
LAND USE CODE INTERPRETATION
JURISDICTION: City of Aspen
APPLICABLE CODE SECTIONS: Section 26.104.100, Definitions — Right of
Way
Section 26.470, Growth Management
Section 26.575.020.0 - Calculations and
Measurements, Lot Area
Section 26.710.040, Medium Density
Residential (R -6) Zone District
EFFECTIVE DATE: August 19, 2009
WRITTEN BY: Jennifer Phelan, Community Development
Deputy Director
ihillW Jessica Garrow, Long Range Planner
APPROVED BY• Chris Bendon, Community Development
Director
COPIES TO: City Attorney
City Planning staff
SUMMARY:
This Land Use Code interpretation is being issued in response to an inquiry with regard to the
`parcel' created as a result of MD1 LLC, et al. v. The City of Aspen, et al. Pitkin County Case
No. 06 CV 165. The request was filed by David McConaughy of Garfield and Hecht LLC on
behalf of MD 1 LLC and asks that the Community Development Director indicate if there is a
development right to the "Northerly Parcel" referenced in Pitkin County Case No. 06 -CV -165.
The requester shall have the right to appeal this code interpretation, as outlined below.
BACKGROUND:
The purpose of this interpretation is to explain the development rights, if any, associated with the
"Northerly Parcel ". described in the Amended Quiet Title Decree issued by the Pitkin County
District Court in Case No, 06 -CV -165.
The "Northerly Parcel" was originally platted as right -of -way called Silverking Drive in the
Alpine Acres Subdivision. Silverking Drive was dedicated to Pitkin County for public use when
it was originally approved in 1964. The subdivision was annexed by the City in 1976. The
right -of -way, although dedicated, was never improved upon and MD 1 LLC recently received
possession of the right -of -way through Quiet Title Decree. The area is in the R -6 Zone District.
An ( �� i P 223
The legal case began as an adverse possession claim. The City agreed to disclaim any interest in
the subject property upon certain conditions agreed to by the parties to the lawsuit to ensure that
adequate utilities are available and adequate right -of -way was preserved for access to other
surrounding lots. When the City disclaimed interest in the right -of -way, there was no discussion
or reference by the plaintiffs regarding the creation of separate parcels, floor area, or
development rights. The final Decree did not mention floor area or new development rights.
DISCUSSION
Staff has relied on four (4) sections of' the Land Use Code, to render this interpretation.
Following are the sections, with emphasis added:
A. Section 26.710.040, Medium Density Residential (R -6) Zone District. Allowable Floor Area
in the R -6 Zone District is based on Lot Area.
B. Section 26.575.020.C, Calculations and Measurements — Lot Area.
... Also excluded from total lot area for the purpose of floor area calculations in all zone
districts is that area beneath the high water line of a body of water and that area within a
vacated right -of -way, or within an existing or proposed dedicated right-of-way or surface
easement. ...
C. Section 26.104.100, Definitions — Right -of -Way.
A strip or other area of land specifically designated or reserved for travel, passage, and/or
the installation of utilities or other similar uses by persons other than, or in addition to,
the landowner.
D. Section 26.470, Growth Management.
Section 26,470.020, Applicability — General: This Chapter shall apply to all .
development in the City of Aspen — Residential, Lodging, Commercial, and Community
Facilities.
Citation A states that Floor Area calculations in the R -6 Zone District are based on Lot Area.
Citation B states that any area within a proposed right -of -way is excluded from total Lot Area for
floor area purposes and therefore does not contribute to floor area calculations. Citation C
defines a "right -of- way."
Citation D states that any and all development, regardless of the use type, must undergo a growth
management review and either receive a growth management allotment or an exemption. If a
growth management allotment or exemption is not received development cannot occur.
INTERPRETATION
It is Staff's interpretation that the land area that MD1 LLC received through the Quiet Title
Decree has no associated floor area and does not have a development right.
First, because the land area in question was a proposed right -of way, it is deducted from the
calculation of Lot Area and therefore it has no associated floor area. Second, all development in
/2 2 4 11'- 46\._2
the City of Aspen must receive a growth management allotment or exemption in order to have a
development right. The land associated with the Quiet Title has never received such a review.
This interpretation was provided on August 19, 2009, and shall become effective on August 19,
2009. This interpretation of the land use code shall be valid until such time as the code sections
specified are amended to implement this clarification or for other purposes.
APPEAL OF DECISION
As with any interpretation of the land use code by the Community Development Director, an
applicant has the ability to appeal this decision to the Aspen City Council. This can be done in
conjunction with a land use request before City Council or as a separate agenda item.
26.316.030(A) APPEAL PROCEDURES
Any person with a right to appeal an adverse decision or determination shall initiate an appeal by
filing a notice of appeal on a form prescribed by the Community Development Director. The
notice of appeal shall be filed with the Community Development Director and with the City
office or department rendering the decision or determination within fourteen (14) days of the
date of the decision or determination being appealed. Failure to file such notice of appeal within
the prescribed time shall constitute a waiver of any rights under this Title to appeal any decision
or determination.
5
ASPEN OFFICE (lAnF D Q� H C Tt 1 C AVON OFFICE
"01 East Hyman Avenue
�J n.[' j JJ CX. �.f� 11 1 0070 Benchmark Road
;pen, Colorado 81611 Post Office Box 5450
Telephone (970) 925 -1936 ATTORNEYS AT LAW Avon, Colorado 81620
Facsimile (970) 925 -3008 Since 1975 Telephone (970) 949 -0707
GLENWOOD SPRINGS OFFICE Facsimile (970) 949 -1810
•
The Denver Centre www.garfieldhecht RECEIVED BASALT OFFICE
420 Seventh Street, Suite 100 River View Plaza
Glenwood Springs, Colorado 81601 100 Elk Run Drive, Suite 220
Telephone (970) 947 -1936 JUL 1 1 2 1 2009 Basalt, Colorado 81621
Facsimile (970) 947 -1937 y� L d � 6 Telephone (970) 927 -1936
CITY OF ASPEN Facsimile (970) 927 -1939
(AMENITY DEVELOPMENT
July 20, 2009
David H. McConaughy
• dmcconaugh th a)!arfieidhecht. cans
Chris Bendon •
•
Community Development Director
City of Aspen
Aspen, CO 81611
Re: 980 Gibson Avenue
Dear Mr, Bendon:
•
We represent MD 1, LLC, which is the owner of a condominium unit located at 980
Gibson Avenue known as Unit 1, Lot I, Block 1, Alpine Acres Subdivision. MD 1, LLC is also
the owner • of the "Northerly described in the Amended Quiet Title Decree issued by the
Pitkin County District - Court on lily 10,•2008' in Case 06-CV -165. ! _The purpose of this
letter is to request an interpretation of the Aspen Land Use Code pursuant to. Chapter 26.306 of
the City Code.
The subject property was the topic of a pre - application conference between the owner's
representative, Stan Clauson, and Planner Jessica Garrow in November 2008. A copy of the pre -
application conference summary is enclosed for reference. The applicant respectfully disagrees
with several points in the summary and presents this application for the purpose of obtaining a
better understanding of the City Code and the purported basis for Ms. Garrow's conclusions.
• Questions Presented
Our general request is to provide an explanation and basis under the City Code for the
conclusions set forth in the pre - application conference summary. Additionally, we request
specific answers to the following questions.
1. Where a separate legal parcel of 5,603 square feet was established by Court Decree
in a case where the City was a named defendant, and not through any City subdivision process,
does the parcel satis5' the dimensional requirements for a detached single family home in the R-
6 zone district under Section 26.710.040.'
We believe the answer is `yes." City Code § 26.710.040 provides that the "minimum lot
area per dwelling unit" in the R -6 zone is 4,500 square feet for a detached residential dwelling,
390542 -1
City of Aspen
GARFIELD & HECHT, uly 20, 2009
P.C. C. Page 2 of 3
but the "minimum lot size" is 6,000 square feet. We believe the latter provision applies only
during the subdivision process to create a new lot, but an existing parcel in the R -6 zone would
be eligible for construction of a detached dwelling unit if it meets or exceeds 4,500 square feet
and complies with other requirements of the City Code.
2. Is there any process under the City Code by which a lot line between contiguous
parcels can be dissolved without formal action by the City and notice to the affected property
owners?
We are not aware of any such process and believe the answer is "no."
3. In the case of a condominium plat identjf Eying three adjacent parcels where Parcel A is
owned solely by Party 1,. Parcel B is owned solely by Party 2, and Parcel C is a common element
owned in equal undivided interests by both Party 1 and Party 2, are each of the three parcels "in
separate ownership" or are any two or more parcels in the "same ownership" for purposes of
City Code Section 26.312.050?
We believe that each of the three parcels would be in separate ownership because title is
vested differently for each parcel and that none of them would be in the same ownership.
4. Is there any provision in the City Code providing that a legal parcel established by
Court Decree has no associated floor area for any purpose of the City Code if such parcel was
ever proposed as a potential right of way but was never actually dedicated to the City as a street
or right of way?
We are not aware of any such provision and therefore believe the answer is "no."
5. Under Chapter 26.306 of the City Code, will the City respond to an applicant's
request to interpret the Code by describing or confirming the land use entitlements for a specific
piece of property?
We have been informally advised by the planning department that the Community
Development Director would not provide an opinion regarding entitlements for a specific
property under this Chapter. Therefore, we merely seek to confirm that such a request would be
rejected and/or summarily denied. However, if the Community Development Director would
respond to such a request, then we request a summary of the entitlements for the parcels owned
by our client as described at the beginning of this letter.
* * *
450346 -1
® Printed on recycled paper
__:
r, E kT-A
City of Aspen
GARFIELD & HECHT, P,C. July 20, 2009
Page 3 of 3
If you require any additional information, please let me know. We look forward to your
response. Thank you very much for your time and attention.
Very truly yours,
Garfie t, P.C.
„a
D a d H. cConaugI
DHM:lp P
-ow
Enclosure(s)
Cc: MD 1, LLC
450346 -1
P228 • btklB
ASPEN OFFICE GARFIELD & HECHT P C. 0070 B Benchmark Road
601 East Hyman Avenue f
Aspen, Colorado 81611 Post Office Box 5450
Telephone (970) 925 -1936 ATTORNEYS AT LAW Avon, Colorado 81620
Facsimile (970) 925 -3008 Since 1975 Telephone (970) 949 -0707
GLENWOOD SPRINGS OFFICE Facsimile (970) 949 -1810
The Denver Centre www.garfieldhechtcom BASALT OFFICE
420 Seventh Street, Suite 100 River View Plaza
Glenwood Springs, Colorado 81601 100 Elk Run Drive, Suite 220
Telephone (970) 947 -1936 Basalt, Colorado 81621
Facsimile (970) 9474937 _ Telephone (970) 927 -1936
Facsimile (970) 927 -1939
September 1, 2009
David H. McConaughy
dmeconauph at garfie/dhecht com
Chris B
endon
Community Development Director
City of Aspen
Aspen, CO 81611
Re: 980 Gibson Avenue
Dear Mr. Bendon:
Please accept this letter as an appeal of the City's decision dated August 19, 2009,
regarding this firm's application for a code interpretation dated July 20, 2009, on behalf of MD
1, LLC. For ease of reference, we enclose copies of the November 5, 2008 pre - application
conference summary, this firm's letter of July 20, 2009, and the City's decision dated August 19,
2009. We have also included additional documents identified below that were already in the
City's possession and, based on the decision, appear to have been relied upon by the Community
Development Department. This appeal is submitted pursuant to Section 26.316.030(A) of the
Aspen City Code.
Issues for Appeal
1. The Community Development Department did not answer Questions 1, 2 or 3.
The application presented four questions regarding specific provisions of the City Code
and a fifth, general question regarding the land use entitlements for certain property described in
the application. The response was silent regarding the first three questions.
2. The City Council should reverse the decision of the Community Development
Department regarding Question 4 because Matchless .Drive is not a dedicated, vacated, or
proposed right -of -way.
3. The City Council should clarify the response to Question 5 by confirming that the
property is eligible for administrative review under the Growth Management Quota System
described in Chapter 26.470 of the City Code.
390542 -1
® Printed on recycled paper
P229
City of Aspen
G D &HE CHT n.0 September 1,2of4
tll�P 1 LL n r, R r Page 2 of 4
Law and Argument
Issue No. 1
City Code Section 26.306.010 provides that any real property owner in the City may apply for an
interpretation of any provision of Title 26 of the City Code. Question 1 of the application
included a specific request to interpret Code Section 26.710.040. Question 2 requested an
interpretation of Title 26 regarding the absence of any provision to dissolve a lot line between
contiguous parcels without formal action or notice. Question 3 presented a specific question
regarding Code Section 26.312.050.
The decision of the Community Development Department was silent as to all three questions.
Accordingly, we request that the City Council either answer the questions or direct the
Community Development Department to provide an interpretation as required by Section
26.306.010.
Issue No. 2
In response to Question No. 4, the Community Development Department cited three code
sections in support of its contention that the "Northerly Parcel" has no floor area because the
subject parcel is a "vacated right -of -way" or an "existing or proposed dedicated right -of- way."
As recognized by the City, the subject parcel was created by virtue of the enclosed Amended
Decree Quieting Title dated July 10, 2008. The legal description attached to the decree as
Exhibit A confirms that the parcel was once a portion of Silver King Drive a/k/a Matchless Drive
as shown on the plat approved by Pitkin County before the land was annexed to the City of
Aspen. An excerpt from the recorded plat is also enclosed.
It is undisputed that the portion of Matchless Drive that became the Northerly Parcel was never
actually dedicated to, nor accepted by, either Pitkin County or the City of Aspen. Neither the
City nor the County ever took any formal action to vacate the right -of -way, because it was never
dedicated in the first place. As such, the City cannot rely on the portions of Code Section
26.757.020 referring to a "vacated right -of -way" or a "dedicated right -of- way."
The question, therefore, is whether the portion of Matchless Drive shown on the plat can be
considered a "proposed right -of -way" for purposes of Section 26.757.020. Such an
interpretation defies both law and common sense for a number of reasons.
First, the word "proposed" must be interpreted to apply to the time of the application. Land use
applications typically go through a number of iterations before reaching the stage of final plat.
The location and dimensions of lots and streets will change from sketch plan through final
approval, and lots shown on a final plat may overlap areas that were considered or proposed as
roads early in the process. As a practical matter, a "proposed right -of -way" cannot possibly
include every square foot of land that was ever considered as a road in any context, especially
465447 -1
P230 0 �xI1E,4Tl3
City of Aspen
September 1, 2009
GARFIELD & HECHT, P.C. Page 3 of 4
where the City has explicitly rejected such.a proposal. Instead, this section must be interpreted
to apply to lands that are currently proposed as future rights -of -way so that the public's future
right of access will not be impaired by development.
Second, any proposal for the dedication of Matchless Drive was made prior to the date the plat
was approved by Pitkin County in 1964 and was subject to conditions that were never fulfilled.
The County never accepted any dedication, and any contractual duties of the original developer
to fulfill any such conditions would have become unenforceable due to the statute of limitations
more than 40 years ago. There is no current proposal.
Third, even if there were a "proposal" for dedication, such a proposal would have been made to
Pitkin County, not the City of Aspen. Any such proposal to Pitkin County is not relevant under
the City Code.
Finally, and most importantly, the City affirmatively disclaimed any interest in the subject parcel
by filing the enclosed unconditional Disclaimer in Case No. 06 -CV -165 on July 31, 2006. Even
if there had been a lingering "proposal" for future dedication, it was extinguished as of that date.
Under the doctrines of res judicata and collateral estoppel, the City cannot now take a position
contrary to what was litigated, or what could have been litigated, in the quiet title case.
As of the date of the application, the Northerly Parcel is not a vacated right-of-way, a dedicated
right -of -way, or a proposed right -of -way. Accordingly, the conclusion that the parcel has no
floor area on this basis must be reversed.
Issue No. 3
The Community Development Department determined that the parcel is not eligible for
development because it has never received a Growth Management review under Chapter 26.470
of the City Code.
Pursuant to Section 26.470.060, assuming that the applicant desires to apply for a single - family
home or a duplex, the parcel should be eligible for administrative review subject only to the
construction of an ADU in order to meet affordable housing requirements. We request
confirmation of this interpretation.
Conclusion
The City Council should direct the Community Development Department to respond to
Questions 1, 2 and 3 as presented in the application. The applicant reserves the right to file a
future appeal depending on the outcome of that response.
The City Council should reverse the Community Development Department's conclusion that the
Northerly Parcel has no associated floor area.
465447 -1
ail Printed on recycled nener
11 `$ P231
City of Aspen
September 1, 2009
GARFIELD &HECHT, P.C. Page 4 of 4
The City Council should clarify that an application for Growth Management approval for a
single family home or duplex may be processed on an administrative basis subject only to
affordable housing requirements.
We look forward to presenting this appeal to the City Council. Thank you for your time and
attention.
Very truly yours,
Garfield & Hecht, P.C.
bd." # ,945-a7/
David H. McConaughy
DHM:lp
Enclosure(s)
cc: MD 1, LLC
•
465447 -1
P232 1 F F
City of Aspen
GARFIELD &HECHT, P.C. '° P '? o
but the "minimum lot size" is 6,000 square feet. We believe the latter provision applies only
during the subdivision process to create a new lot, but an existing parcel in the R -6 zone would
be eligible for construction of a detached dwelling unit if it meets or exceeds 4,500 square feet
and complies with other requirements of the City Code.
2. Is there any process under the City Code by which a lot line between contiguous
parcels can be dissolved without formal action by the City and notice to the affected property
owners?
We are not aware of any such process and believe the answer is "no."
3. In the case of a condominium plat identifying three adjacent parcels. where Parcel A is
owned solely by Party 1, Parcel B is owned solely by Party 2, and Parcel C is a common element
owned in equal undivided interests by both Party 1 and Party 2, are each of the three parcels "in
separate ownership" or are any two or more parcels in the "same ownership" for purposes of
City Code Section 26.312.050?
We believe that each of the three parcels would be in separate ownership because title is
vested differently for each parcel and that none of them would be in the same ownership.
4. Is there any provision in the City Code providing that a legal parcel established by
Court Decree has no associated floor area for any purpose of the City Code if such parcel was
ever proposed as a potential right of way but was never actually dedicated to the City as a street
or right of way?
We are not aware of any such provision and therefore believe the answer is "no."
5. Under Chapter 26.306 of the City Code, will the City respond to an applicant's
request to interpret the Code by describing or confirming the land use entitlements for a specific
piece of property?
• We have been informally advised by the planning department that the Community
Development Director would not provide an opinion regarding entitlements for a specific
property under this Chapter. Therefore, we merely seek to confirm that such a request would be
rejected and/or summarily denied. However, if the Community Development Director would
respond to such a request, then we request a summary of the entitlements for the parcels owned
by our client as described at the beginning of this letter. •
* * *
450346-1
® Printed an recycled paper
r .�
\ -Bnl P233
City of Aspen
GARFIELD & HECHT, P.C. July 20, 2009
Page 3 of 3
If you require any additional information, please let me know. We look forward to your
response. Thank you very much for your time and attention.
Very truly yours,
Garfie_. • t, P.C.
a id H. / cConaug
DHM:Ip
Enclosure(s)
Cc: MD 1, LLC
450346 -1
® Printed on recycled paper
P234 r�� �
CITY OF ASPEN
PRE - APPLICATION CONFERENCE SUMMARY
PLANNER: Jessica Garrow, 429 -2780 DATE: November 5, 2008
PROJECT: 980 Gibson
REPRESENTATIVE: Stan Clauson, 925.2323
DESCRIPTION:
The Applicant is interested in better understanding what can be done on the property located at 980 Gibson. 980 Gibson is
a corner lot, adjacent to Gibson Ave and Matchless Drive. The property is designated Historic.
The property was engaged in a Quiet Title action for a platted right of way that was adjacent to the historic property and,
known commonly as Silverking Drive. This is recorded at reception number 550852. The Community Development
Department and the City Attorney's office have examined the quiet title, and believe the following with respect to 980
Gibson:
• The quiet title did not create new developable parcels of land. Rather, the quiet title enlarged 2 existing properties,
one is 980 Gibson.
• Because the area of land was originally platted for a ROW (though never accepted by the City) it cannot be used
for purposes of Floor Area. It can, however, be used for purposes of setbacks.
• The City of Aspen requires adequate ROW for Matchless Drive, which is adjacent to 980 Gibson. This may mean
that a portion of the property that was subject of the quiet title may need to be dedicated to the City.
The City advises the applicant to get a survey completed based on the language in the Quiet Title and agreements with the
City to confirm this understanding.
Land use applications can be found on the Community Development website at:
http : / /www.aspenpitkin.com/depts /41 /main planninq.cfm.
Relevant Land Use Code Section(s): 26.104.100 Definitions, Parcel
• 26.304 Common Development Review Procedures
26.415 Development Involving a Landmark
26.575.020 Calculations and Measurements
26.710.040 R -6 Zone District
http: l/ www. aspenpitkin .comldepts/381citvcode.cfm
Review by: - Staff for compliance with quiet title
Referral Agencies: None.
Planning Fees: none at this time
Referral Agency Fees: None
Total Deposit: none at this time
To apply, submit the following Information:
❑ Proof of ownership with payment.
W-2(kh-fDATIR 5
❑ Signed fee agreement.
❑ Applicant's name, address and telephone number in a letter signed by the applicant which states the name,
address and telephone number of the representative authorized to act on behalf of the applicant.
❑ Street address and legal description of the parcel on which development is proposed to occur, consisting of a
current certificate from a title insurance company, or attomey licensed to practice in the State of Colorado, fisting
the names of all owners of the property, and all mortgages, judgments, liens, easements, contracts and
agreements affecting the parcel, and demonstrating the owners right to apply for the Development Application.
❑ Total deposit for review of the application.
❑ 3 Copies of the complete application packet and maps.
HPC =12; PZ = 10; CC = 7; Referral Agencies = 1 /ea.; Planning Staff =1
❑ An 8 1/2" by 11" vicinity map locating the parcel within the City of Aspen.
❑ Site improvement survey including topography and vegetation showing the current status, including all easements
and vacated rights of way, of the parcel certified by a registered land surveyor, licensed in the state of Colorado.
(This requirement, or any part thereof, may be waived by the Community Development Department if the project is
determined not to warrant a survey document.)
❑ A written description of the proposal and an explanation in written, graphic, or model form of how the proposed
development complies with the review standards relevant to the development application. Please include existing
conditions as well as proposed. List of adjacent property owners within 300' for public hearing
❑ Copies of prior approvals. -
❑ Applications shall be provided in paper formal (number of copies noted above) as well as the text only on either of
the following digital formats. Compact Disk (CD)- preferred, Zip Disk or Floppy Disk. Microsoft Word format is
preferred. Text format easily convertible to Word is acceptable.
❑ Applicants are advised that building plans will be required to meet the International Building Code as adopted by
the City of Aspen, the Federal Fair Housing Act, and CRS 9.5.112. Please make sure that your application
submittal addresses these building - related and accessibility regulations. You may contact the Building Department
at 920.5090 for additional infortnation.
Disclaimer:
The foregoing summary is advisory in nature only and is not binding on the City. The summary is based on current zoning,
which is subject to change in the future, and upon factual representations that may or may not be accurate. The summary
does not create a legal or vested right.
P 2 3 6 W \
CITY OF ASPEN
COMMUNITY DEVELOPMENT DEPARTMENT
LAND USE CODE INTERPRETATION
JURISDICTION: City of Aspen
APPLICABLE CODE SECTIONS: Section 26.104.100, Definitions — Right of
Way
Section 26.470, Growth Management
Section 26.575.020.0 - Calculations and
Measurements, Lot Area
Section 26.710.040, Medium Density
Residential (R -6) Zone District
•
EFFECTIVE DATE: August 19, 2009
WRITTEN BY: Jennifer Phelan, Community Development
Deputy Director
�
I �� Jessica Garrow, Long Range Planner
APPROVED BY: J /,IY Chris Bendon, Community Development
Director
COPIES TO: City Attorney
City Planning staff
SUMMARY:
This Land Use Code interpretation is being issued in response to an inquiry with regard to the
`parcel' created as a result of MD1 LLC, et al. v. The City of Aspen, et al. Pitkin County Case
No. 06 CV 165. The request was filed by David McConaughy of Garfield and Hecht LLC on
behalf of MD 1 LLC and asks that the Community Development Director indicate if ,there is a
development right to the "Northerly Parcel" referenced in Pitkin County Case No. 06 -CV -165.
The requester shall have the right to appeal this code interpretation, as outlined below.
BACKGROUND:
The purpose of this interpretation is to explain the development rights, if any, associated with the
"Northerly Parcel" described in the Amended Quiet Title Decree issued by the Pitkin County
District Court in Case No. 06-CV -165.
The "Northerly Parcel" was originally platted as right -of -way called Silverking Drive in the
Alpine Acres Subdivision. Silverking Drive was dedicated to Pitkin County for public use when
it was originally approved in 1964. The subdivision was annexed by the City in 1976. The
right -of -way, although dedicated, was never improved upon and MD1 LLC recently received
possession of the right -of -way through Quiet Title Decree. The area is in the R-6 Zone District.
`' v3 P237
The legal case began as an adverse possession claim. The City agreed to disclaim any interest in
the subject property upon certain conditions agreed to by the parties to the lawsuit to ensure that
adequate utilities are available and adequate right -of -way was preserved for access to other
surrounding lots. When the City disclaimed interest in the right -of -way, there was no discussion
or reference by the plaintiffs regarding the creation of separate parcels, floor area, or
development rights. The final Decree did not mention floor area or new development rights.
DISCUSSION
Staff has relied on four (4) sections of the Land Use Code, to render this interpretation.
Following are the sections, with emphasis added:
A. Section 26.710.040, Medium Density Residential (R-6) Zone District. Allowable Floor Area
in the R -6 Zone District is based on Lot Area.
B. Section 26.575.0202, Calculations and Measurements — Lot Area.
... Also excluded from total lot area for the purpose of floor area calculations in all zone
districts is that area beneath the high water line of a body of water and that area within a
vacated right -of -way, or within an existinz or proposed dedicated right-of-wav or surface
easement. ...
C. Section 26.104.100, Definitions — Right -of -Way. and/or
A strip or other area of land specifically designated or reserved for travel, p assa a g >
the installation of utilities or other similar uses by persons other than, or in addition to,
the landowner.
D. Section 26.470, Growth Management.
Section 26.470.020, Applicability — General: This Chapter shall apply to all
development in the City of Aspen — Residential, Lodging, Commercial, and Community
Facilities.
Citation A states that Floor Area calculations in the R -6 Zone District are based on Lot Area.
Citation B states that any area within a proposed right -of -way is excluded from total Lot Area for
floor area purposes and therefore does not contribute to floor area calculations. Citation C
defines a "right -of- way."
Citation D states that any and all development, regardless of the use type, must undergo a growth
management review and either receive a growth management allotment or an exemption. If a
growth management allotment or exemption is not received development cannot occur.
INTERPRETATION
It is Staffs interpretation that the land area that MD1 LLC received through the Quiet Title
Decree has no associated floor area and does not have a development right.
First, because the land area in question was a proposed right -of way, it is deducted from the
calculation of Lot Area and therefore it has no associated floor area. Second, all development in
P238
CC
the City of Aspen must receive a growth management allotment or exemption in order to have a
development right. The land associated with the Quiet Title has never received such a review.
This interpretation was provided on August 19, 2009, and shall become effective on August 19,
2009. This interpretation of the land use code shall be valid until such time as the code sections
specified are amended to implement this clarification or for other purposes.
APPEAL OF DECISION
As with any interpretation of the land use code by the Community Development Director, an
applicant has the ability to appeal this decision to the Aspen City Council. This can be done in
conjunction with a land use request before City Council or as a separate agenda item.
26.316.030(A) APPEAL PROCEDURES
Any person with a right to appeal an adverse decision or determination shall initiate an appeal by
filing a notice of appeal on a form prescribed by the Community Development Director. The
notice of appeal shall be filed with the Community Development Director and with the City
office or department rendering the decision or determination within fourteen (14) days of the
date of the decision or determination being appealed. Failure to file such notice of appeal within
the prescribed time shall constitute a waiver of any rights under this Title to appeal any decision
or determination.
•
•
xTI [T3 ` 239
RECEPTION'S: 550853, 07/09/2008 at 02:10:07 PM, 1 OF 5, R $26.00
Janice K. Vos Caudill, Pitkin County, CO
Pitldn CountyDisnict Court
506 East Main Street
Aspen, CD 81611
Plaintiffs:
MD1 LLC, a Colorado limited liability
company, and, VAN METER FAMILY
LIVING TRUST, a California Trust
v
Defendant(s): COURT USE ONLY
The CITY OF ASPEN; LUKE W.
ANTHONY, or his heirs, successors, or
assigns; and all unknown persons who claim Case Number. 06 CV 165
any interest in the subject matter of this action.
The Honorable Denise K. Lynch
On Plaintiffs' Motion for SummaryJudgment Division:
AMENDED DECREE QUIETING TITLE IN PLAINTIFFS and CORRECTING
CLERICAL ERRORS
The matter was before this Court on Plaintiffs' Motion for Summary Judgment. Based upon
the pleadings that have been filed and the affidavits and exhibits admitted into evidence, THIS
COURT FINDS:
THAT service under Rule 4 of the Colorado Rules of Civil Procedure is proper upon all of
the Defendants in this action;
THAT the legal description in the first decree contained clerical errors, which are fixed in
Revised Exhibit A and Revised Exhibit 13, attached hereto, pursuant to the Court's authority
under GRCP. Rule 60(a);
THATMDI LLC and its predecessors in interest have adversely possessed the property
described in Revised ExhlbitA (the `Northerly Parcel), attached hereto, for a time in excess of
the periods of the statutes of limitation, as provided in CRS. 5S 38 -41 -101, s seq.;
THAT the Van Meter Family Living Trust and its predecessors in interest have adversely
possessed the propertydescnbed in Revised ExhibitB (the `Soudredypameh`), attached hereto,
fora time in excess of the periods of the statutes of limitation, as provided in C.R.S. • • -
say. COMBINED '1 •F OARFIEID COUNTY
GLENwpol r r ffk8. COLORADO •
Alternate finding for Plaintiffs' tide derived through re .6dslit add correct coot of the
original . n ti - '
Dated • r_ - - Cie* aW; ,�er
DelautY
r
P240 1
RECEPTIONS: 550853, 07/09/2008 at 02:10:07 PM, 2 OF 5,
Janice K. Voe Caudill, Pitkin County, CO
MD1, et al v. Aspen, et aL
Pirkin CoutayDistnuiu Court, Case No. 06 CV 165
Decree Quoting Tale in Plaintiffs
Page2of5
THAT MD1 LLC is the owner of the Northerly Parcel by reason of that certain bargain and
sale deed from Luke W. Anthony, dated September 14, 2007, and recorded in the real property
records of Pitkin County, Colorado on November 9, 2007, at Reception No. 543962;
THAT the Van Meter Family Living Trust is the owner of the Southerly Parcel by reason of
that certain bargain and sale deed from Luke W. Anthony, dated September 14, 2007, and recorded
in the real property records of Pitldn County, Colorado on November 9, 2007, at Reception No.
543963;
THAT none of the Defendants has responded to the Complaint or entered an appearance in
this action and all the Defendants are therefore in default, with the exception of the City of Aspen
and Juke W. Anthony, both of whom disclaimed all interest in the Northedy Parcel and Southerly
Parch
THAT Daniel D. LeMoine, Esti., has been appointed and appeared for any and all
Defendants who are in, or who may be in, or who may have been ordered to report for induction
into, the military service, as defined by the Soldiers' and Sailors' Civil Relief Act of 1940, as
amended;
THAT this is an action in tanaffecting specific real property,
THAT the Court has jurisdiction over all parties to this action and of the subject matter
thereof;
THAT the allegations in the Complaint are true; and
THAT no Defendant herein has any right, tide, or interest in or to the NorthedyParcel or
Southerly Parcel.
THEREFORE IT IS ADJUDGED AND DECREED THAT:
MD1 LLC was, at the time of the ling of the Motion for Summary Judgment, and is now,
the owner in fee simple absolute with right to possession of the Northerly Parcel;
The Van Meter Family Living Trust was, at the time of the Filing of the Motion for Summary
Judgment, and is now, the owner in fee simple absolute with right to possession of the Southerly
Parcel; and
•
—.ems --
P241
RECEPTIONff: 550853, 07/09/2008 at 02:10:07 PM, 3 OF 5, 1/ �{��CC `��r J,
Janice K. Vos Caudill, Pitkin County, CO [ Vi "i
MD1, et aL v. Aspen, et al
Pitkin CountyDistrict Court, Case No. 06 CV 165
Decree Quieting Title in Plaintiffs
Page 3 of 5
Fee simply title in and to the Northerly Parcel and Southerly Parcel be and the same hereby
quieted in MD1 LLC and the Van Meter Family Living Tout, respectively, and that each of the
Defendants has no right, title, or interest in or to the NortherlyParcel or SonrhrdyParcel, or any
part thereof, and that Defendants an forever enjoined from asserting any claim, right, tide, or
interest in or to the Northerly Parcel or SoutheriyParcel or any part thereof.
Signed this tp day of July, 2008.
By the Court
Denise K. Lynch, District ju
P242 3 1,� B T {� c
RECEPTION #: 550653, 07/09/2008 at 02:10:07 PM, 4 OF 5, l J
Janice K. Vos Caudill, Pitkin County, CO
MD1, et aL v. Aspen, et aL
Pitkin County District Court, Case No. 06 CV 165
Decree Qriedng Title in Plaintiffs
Page 4of5
EXHIBIT A
PROPERTYDESQ WIION OF NORTHERLY PARCEL
A parcel of being a portion of Silver King Drive, Block 1, Alpine Acres Subdivision, City of Aspen,
County of Pitkin, State of Colorado, as shown on the plat thereof recorded at Reception No. 118173
in the offices of the deck and Recorder of Pitkin County, said drive more commonly known as
Matchless Drive in the City of Aspen, said parcel being more particularly descnbed as follows:
Beginning at the westerly roost comer of Lot 3 of said Alpine Acres Subdivision, a No. 5 Rebar
found in place; thence S. 48°50'17" E., along the southwesterlyLine of Lot 3 a distance of 63_02
feet thence S. 65 W. a distance of 66.07 feet to the northeasterly line of Lot 1 of said Alpine
Acres Subdivision; thence N. 48 °50'17" W. a distance of 12375 feet to a No. 5 Rebar, thence
S82 °59'52" E. a distance of 106.85 feet to the point of beginning, said parcel containing 5,603 square
feet, more or less.
•
«� P243
RECEPTION #: 550853, 07/09/2008 at 02:10:07 PM, 5 OF 5, ��
Janice K. Vos Caudill, Pitkin County, CO
MDl, et at v. Aspen. et al
Pitkin County Disnict Court, Case No. 06 CV 165
Decree Quieting Tale in Pla;oriffs
Page 5 of 5
EXHIBIT B
PROPERTY DESCRIPTION OF SOUTHERLY PARCEL
A parcel of being a portion of Silver King Drive, Block 1, Alpine Acres Subdivision, City of Aspen,
County of Pitkin, State of Colorado, as shown on the plat thereof recorded at Reception No. 118173
in the offices of the Clerk and Recorder of Pitldn County, said drive more commonly known as
Matchless Drive in the City of Aspen, said parcel being more particularly described as follows:
Beginning at the southwesterly line of Lot 3 of said Alpine Acres Subdivision, from which the
westerly most corner of said Lot 3 bears N. 48 °50'17" W. a distance of 63.02 feet thence S.
48°50'17` E., along the southwesterly lines of Lot 3 and Lot 2 of said Alpine Acres Subdivision a
distance of 102.04 feet to the centerline of an existing drainage; thence S. 56 °3677" W. along said
drainage a distance of 22.65 feet; thrnre S. 53 °34'06" W. along said drainage a distance of 26.11 feet;
thence S. 17 °52'03" W. along said drainage a distance of 13.79 feet to the northeasterly line of Lot 1
of said Alpine Acres Subdivision; thence N. 48°50'17" W. along said northeasterly line distance of
123.53 feet; thence N. 65 °55'41" E. a distance of 66.07 feet to the point of beginning, said parcel
containing 6,548 square feet, more or less.
P244 3
- l-
B/ocr{ 1, 447>/A1 AG2 ,ES S aRblaIS /OA
• .2737-071- 2'
BK • 3 l 2
7 - a -c
bm wj a,
mg, izeo
J .J • ( � '' f��
r
L • ® a) C1
IMCQU V8
A GO on 1
LE.-7 AYE i
G x
/ o y'Y ., 10
` ef'
R
r
•
P245
•
- . :
BL / i +` ..
•
- ._..__- _- CPINE- 1CRES-SUSD/W/ -S /0Al pL�
.. S./w/H.a m• w'N Me..nrN
s R se F. sadiae r: ewe .r i.sf - 4. •
• • / FJ,�_ ✓LY N /M 6 JJK ern:
T. •
/CJT 00 M/ Na ✓ire J.ed. 4...0., • ✓r L r � I.e. sr... r iser /nL
0/00 ' NEY IY / - 15CYR' N /ti# Mr 44.....0 . Yr. Par re / C • r
_ , i e.r 4 -q L note F . eW.' M// $ . o/ J.�/ ••••• ...nth,' f r rrrrn/L
• Ye.JN ✓ .Gixar Croy lasing, M ....ran d1 - %AI.• /FNaf, /...- 4 �///''� ' ]]]�� �� ` '
; r/rC OF COLaGJOOf xfn....N -Iye.! 4./..-It n_
bat:. h r J M. m/ /rdr2i(iy K , . .., n SuCNY/Ma✓ "r
r StT JeS- H a 4. 4.4444 ',Mo
Fl a.MieJM .vinca _-- 9/LP = --- - { k�/hNC
•
r r.. n. ,,, wy . ar.Gi nr «-ro .as ..+e✓
suevir'ei wrriarvr Je e1e e . e./ .r nv <•e•.rk . ate
F ewer w:G.'n ➢s. /.'esie/ rY ysrb
:. w Sx✓e N /? •••41. en /
- .tsar /LGFS S ✓JO /Y /S/aY wNI 4.7 n74 l Js/it/ • �� dw-w..
j ,
asaa•Y nsf ... a,* re set... -e Ntr ..rd der •• •/. J'6.r)dJ • ,
sr, er. r•n
u••^ra M./ M JI'L. • _5-frafara `✓n /rr NJxr.
I y ..,---0- r.L4 n.LMr
•
Pofr! V m• rY4• n...! zeal) a.•••.••-an ro/J .
,. z.. a...ea
napery ) to': .Main s + • .. r ' N •
M :L w Au' fitly arry .cs = ) _ r. arrr. a
. Arr./ / n. 'ea " i ..e 0`..4.-• .-• r.•4 m.f A..a /:. wwK y .. -JA a/ .�` "J�
• ./ I /. /Lf 44 ..0 /K/ ke 'l A'y4.4 . .aJ+a 1 •
•
.:LY /a0 rir /if-0v rM Ma "We. Cairy Cbt • KCree.! sr
lirJ Iwr/�eeY .
J
• r.:YeCn ra•rCer
ner.r.
P246 OF* 7 1 - ` N Q
Pitldn County District Court
506 East Main Street
Aspen, CO 81611
Plaintiffs:
MD1 LLC, a Colorado limited liability
company; and, VAN METER FAMILY
LIVING TRUST, a California Trust
Ir.
•
Defendant(s):
The CITY OF ASPEN; LUKE W. . A COURT USE ONLY
ANTHONY or his heirs, successors, or assigns;
and all unknown persons who claim any Case Number. 06 CV 165
interest in the subject matter of this action
Attorney for City of Aspen: •
John P. Worcester .
130 S. Galena Street
`..) ra Floor
Aspen, Colorado 81611 - • '-
Tel: 970920.5055
Fa= 970.9205119
Ipeck®brandt- law.com
Atty. Reg. # 20610 Division:
DISCLAIMER UNDER RULE 105
COMES NOW, John Worcester, on behalf of defendant Ciiy of Aspen, disclaiming any and
all interest in the property at issue in this matter and thereby relieving the City of Aspen of any
liability for the costs of this action. CRC.P. 105(c).
Dated 1St 311 UNo
BT
• Worcester, city attorney
I
P 2 4 7
Chapter 26.316
APPEALS
Sections:
26.316.010 Appeals, purpose statement.
26.316.020 Authority.
26.316.030 Appeal procedures.
•
26.316.010 Appeals, purpose statement.
The purpose of this Chapter is to establish the authority of the Board. of Adjustment, Growth
Management Commission, the Planning and Zoning Commission, and City Council to hear and decide
certain appeals and to set forth the procedures for said appeals. (Ord. No. 17 -2002 § 2 (part), 2002)
26.316.020 Authority.
A. Board of Adjustrnent. The Board of Adjustment shall have the authority to hear and decide the
following appeals:
1. The denial of a variance pursuant to Chapter 26.314 by the Planning and Zoning Commission
or Historic Preservation Commission.
B. City Council The City Council shall have the authority to hear and decide the following appeals: -
1. An interpretation to the text of this title or the boundaries of the zone district map by the
Community Development Director in accordance with Chapter 26.306. An appeal of thi s nature
shall be a public meeting.
2. Any action by the Historic Preservation Commission in approving, approving with conditions,
or disapproving a development application for development in an "H, ", Historic Overlay
District pursuant to Chapter 26.415. An appeal of this nature shall be a public meeting.
3. The scoring determination of the Community Development Director pursuant to Chapter
26.470.. An appeal of this nature shall be a public meeting.
4. The allocation of Growth Management Allotments by the Planning and Zoning Commission
pursuant to Chapter 26.470. An appeal of this nature shall be a public meeting.
5. Any other appeal for which specific authority is not granted to another board or commission as
established by this title. An appeal of this nature shall be a public meeting.
C. Planning and Zoning Commssion. The Planning and Zoning Commission shall have the
authority to hear and decide an appeal from an adverse determination by the Community Development
Director on an application for exemption pursuant to the growth management quota system in
accordance with Section 26.470.060(D).
City of Aspen Land Use Code. August, 2007.
Part 300, Page 35
•
P248 .„.J ki C,
D. Administrative Hearing Officer. The Administrative Hearing Officer shall have the authority
to hear an appeal from any decision or determination made by an administrative official unless
otherwise specifically stated in this title.
(Ord. No. 17 -2002 § 2 (part), 2002; Ord. No. 27 -2002 § 23, Ord. No. 12 -2007; 2002)
26.316.030 Appeal procedures.
A. Initiation. Any person with a right to appeal an adverse decision or determination shall initiate an
appeal by filing a notice of appeal on a form prescribed by the Community Development Director. The
notice of appeal shall be filed with the Community Development Director and with the city office or
department rendering the decision or determination within fourteen (14) days of the date of the decision
or determination being appealed. Failure to file such notice of appeal within the prescribed time shall
constitute a waiver of any rights under this title to appeal any decision or determination.
B. Effect of filing an appeal The filing of a notice of appeal shall stay any proceedings in
furtherance of the action appealed from unless the Community Development Director certifies in
writing to the chairperson of the decision- making body authorized to hear the appeal that a stay poses
an imminent peril to life or property, in which case the appeal shall not stay further proceedings. The
chairperson of the decision making body with authority to hear the appeal may review such
certification and grant or deny a stay of the proceedings.
C. Timing of appeal The decision - making body authorized to hear the appeal shall consider the
appeal within thirty (30) days of the date of filing the notice of appeal or as soon thereafter as is
practical under the circumstances.
D. Notice requirements. Notice of the appeal shall be provided by mailing to the appellant and by
publication to all other affected parties. (See section 26.304.060(E)).
E. Standard of review. Unless otherwise specifically stated in this title, the decision- making body
authorized to hear the appeal shall decide the appeal based solely upon the record established by the
body from which the appeal is taken. A decision or determination shall be not be reversed or modified
unless there is a finding that there was a denial of due process, or the administrative body has exceeded
its jurisdiction or abused its discretion.
F. Action by the decision- making body hearing the appeal The decision - making body hearing the
appeal may reverse, affirm, or modify the decision or determination appealed from, and, if the decision
is modified, shall be deemed to have all the powers of the officer, board or commission from whom the
appeal is taken, including the power to impose reasonable conditions to be complied with by the
appellant. The decision = making body may also elect to remand an appeal to the body that originally
heard the matter for further proceedings consistent with that body' s jurisdiction and directions given, if
any, by the body hearing the appeal. The decision shall be approved by written resolution. All appeals
shall be public meetings.
(Ord. No. 55 -2000, §§ 4, 5; Ord. No. 27 -2002 § 24, Ord. No. 12 -2007, 2002)
City of Aspen Land Use Code. August, 2007
Part 300, Page 36
•
October 5, 2009 •
Mr. David McConaughy
and Hecht, P.C.
THE CITY of ASPEN
601 E. Hyman Ave.
Aspen, CO 81611
RE: APPEAL OF AN INTERPRETATION (980 Gibson)
Dear David, . -
As required per Section 26.316.020 D., Notice Requirements, of the land use code notice is
hereby given that a public hearing will be held on Monday, October 26, 2009, to begin at 5:00
p.m. before the Aspen City Council, City Council Chambers, City Hall, 130 S. Galena St.,
Aspen. The purpose of the hearing is to consider an appeal of an Interpretation submitted by you
on behalf of MDI,LLC.
The Interpretation provided information on the development rights associated with land that was
acquired by quiet title, specifically, that the land has no associated floor area. The request of the
applicant is to reverse the Community Development Director's interpretation on floor area and
respond to certain additional questions. The subject land under review is adjacent to 980/990
Gibson and 1040 Matchless Drive and is generally described as a parcel being a portion of Silver
King Drive, Block 1, Alpine Acres Subdivision, City of Aspen, County of Pitkin, State of Colorado as
shown on the plat thereof recorded at Reception No. 118173, said drive more commonly known as
Matchless Drive. For further information, please feel free to contact me at 970.429.2759 or by
email Jennifer .Phelan(cr�,ci.aspen.co.us. A memo will be emailed to you in the near future.
Regards,
Jenifer Phelan
Deputy Director
130 Sorm GALENA STAEEr • ASPEN, COLORADO 81611 -1975 • PHONE 970.920.5000 • FAX 970320.5197
www. aspengov.com
..._ 0.0 - ec___________.
0 l`
8
0 4 y
n
o f * ,
r z
.L
.... C .- --..... \ 1
N
n
J W T
W
W r
S ik t g___.
W #`
•
W
a
i c --- \
9
y .....„ ....________ ,..
ru seam
N
on micsola■
a > O ! •A
_C-.) T V
o x O ; a ° o o o Z l
3 m —1 :5 5 m . � o r » 3 3 0 C
s m i v m 9—
• W 3` 3 C - il n � .. ^o a 37
m c.,, dEt n ° ' ro - m i 7
° a < S .17 mo MD- o.ma 2 .-
< c+- x m w Z F' y 3 ;.-.....1,-,..:.-,.. • -ice' _.
c. . GI ao cmyi
% C ..4eii�' v
70 CL ^s mom ?GJ M1h
lYT mCma3 Z D O N V O s
3 1 m a ?D-
�"rn> v
= 0 m m - O N W
M to
3 N / a v
32 0zr
W n v EA
m W
ir g .` _ N — m ° N 1 i it
0 m 3 £ 2 moff, I
� Er,
c
o m
n N i ❑❑❑ y
O am v n Q._ .
...13 2 E A . . . .
. . . . . .
. . .. . . . -
. .= u $ _ Z1
< m
N AO m O V �. y
Mineral Estate Owner Notice. By the certified mailing of notice, return receipt
requested, to affected mineral estate owners by at least thirty (30) days prior to
the date scheduled for the initial public hearing on the application of
development. The names and addresses of mineral estate owners shall be those
on the current tax records of Pitkin County. At a minimum, Subdivisions that .
create more than one lot, Planned Unit Developments, Specially Planned Areas,
and COWAPs are subject to this notice requirement.
Rezoning or text amendment. Whenever the official zoning district map is in
any way to be changed or amended incidental to or as part of a general revision
of this Title, or whenever the text of this Title is to be amended, whether such
revision be made by repeal of this Title and enactment of a new land use
regulation, or otherwise, the requirement of an accurate survey map or other
sufficient legal description of, and the notice to and listing of names and
addresses of owners of real property in the area of the proposed change shall be
waived. However, the proposed zoning map shall be available for public
inspection in the planning agency during all business hours for fifteen (15) days
prior to the public hearing on such amendments.
Signat . 9
The foreP,oin "Affidavit of Notice" was ac owledged before me this LI clay
of 6 GtO , 200, by oi o SCO.r -� .
R rn NOTICE
1
RE: APP AL OF AN INTERPRETATION g
WITNESS MY HAND AND OFFICIAL SEAL
NOTICE IS HER Y GIVEN that a public hearin
will be held on ontlay. October 26 t0
begin at 5:00 p. .before the Aspen S Galena r
City OOh ns, Clry S My commission expires: 0 �6 �l 0 /aD i
St., C Aapen, neg C t co an appeal 01 an
Devel reta\io .Issuer by the Community
Dave 0pment Director, submidetl by is to MBC.
M c pefl C b on beDall of r t% LLC., 109 AA1C,
A spen. CO 61611. The lnte rip tion pro Wtletl
Inlmma on thetl a npphts IIle ,
with (all that then nc has a q
specifically e that the ther, has no associated floor N Public
area. Community e request of the applicant e p reta ion ��``
aar area an resp d D c Picador's in additional _ � F Rw tb ♦
q on Floor area he respond to certain rev 5 ♦"�
u The 9 0El' b s lantl review': O '• , , .... ,, 6? 1
Drive a u to . 9 Gibson ed u10ar as parcel b ein g
Dnve Drive, Block , Al AAc res Se c., F
S cordon o1 City o Aspen, Runk of P State j 1
e
o Colosbo, 5s purity .' LAURA , I
i
at Reception as shown on 17 plat id drive a more v s'tY5
at commonly n a 1161]es said drive more �1 • c 1 ER
nto a ly known as Matchless Drive. For further 1 . `
nlmmetio unAY OeveIo r n Phalan at the City of A AS APPLICABLE: It 3., Asp Community Development Depertm . (0' by �•
G . Galena SL , Aspen, CO 970.629.27 f by •C'
email J 6 Ph . • °e'' rE PUBLICATION 'ti C r'
ICI t a n 'r `
AaPen 01ry Daan`° PH OF THE POSTED NOTICE (SIGN ,� g o �, .
11 2009. in the Aspen Times Weekly on October E OWNERS AND GOVERNMENTAL AGENCIE,5�11T !'1 Y �110/2410
11 10127335)
BY MAIL
• APPLICANT CERTIFICATION OF MINERAL ESTAE OWNERS NOTICE
AS REQUIRED BY C.R.S. §24- 65.5 -103.3
•
P252
ASPEN OFFICE GARFIELD & HECHT P C
0070 AVON OFFICE
601 East Hyman Avenue . . Benchmark Road
Aspen, Colorado 81611 Post Office Box 5450
Telephone (970) 925 -1936 ATTORNEYS AT LAW Avon, Colorado 81620
Facsimile (970) 925 -3008 Since 1975 Telephone (970) 949 -0707
GLENWOOD SPRINGS OFFICE Facsimile (970) 949 -1810
The Denver Centre www.garfieldhecht.corn BASALT OFFICE
420 Seventh Street, Suite 100 River View Plaza
Glenwood Springs, Colorado 81601 100 Elk Run Drive, Suite 220
Telephone (970) 947 -1936 Basalt, Colorado 81621
Facsimile (970) 947 -1937 Telephone (970) 927 -1936
Facsimile (970) 927 -1939
October 9, 2009
David H. McConaughy
Glenwood Springs Office
dnzcconau¢h1(Earfreldhechtcan
Jenifer Phelan, Deputy Director of Community Development
Jim True, Esq., Assistant City Attorney -
City of Aspen
Aspen, CO 81611
Re: 980 Gibson Avenue •
Dear Ms. Phelan and Mr. True:
Thank you for the recent meeting regarding the pending appeal of the City's Land Use
Code Interpretation regarding property owned by our client, MD 1, LLC.
As we discussed our client's goal is to determine the. development rights and floor area
associated with the "Northerly Parcel" for which title was quieted in , MD .1's name. That
determination will provide guidance to MD 1 prior to submitting any future development
application.
Our client is considering an application to amend the final plat for Lot 1, Block 1 of
Alpine Acres and create a new plat that would encompass all of Lot 1 (which includes two
condominium units in addition to common elements), plus the Northerly Parcel. The owner of
the adjacent "Southerly Parcel" may or may not seek to include that land as well, but we do not
represent that owner and make no representations concerning the Southerly Parcel. This
proposal is only conceptual, and no application is submitted at the current time.
Our original application for a Land Use Code Interpretation presented five separate
questions. The first three questions all related to whether the Northerly Parcel is a separate
buildable lot today in its current state. The City declined to answer those questions and instead
focused on the last two questions, which related to floor area and development rights for the
Northerly Parcel.
During our meeting, you agreed that the Northerly Parcel would, in fact, have associated
floor area unless it is determined to be a "proposed right -of- way." You further suggested that the
City [night be open to reconsidering this issue following research to determine whether there
would be any risk of creating precedent for other undeveloped rights -of -way elsewhere in the
® Printed on recycled paper
City of Aspen
October 9, 2009
GARFIELD & HECHT, P.C. Page 2 of 3
City. Given the unique litigation history of the Northerly Parcel, we hope you now agree that
creating precedent for other parcels should not be a concern.
We continue to maintain that the Northerly Parcel is a separate, developable lot.
However, we acknowledge that the City Staff disagrees with this position and believes that the
Northerly Parcel should somehow be merged into the adjacent Lot 1 as an extension of the back
yard and not be considered as a distinct lot. We, in turn, have asserted arguments as to why
merger cannot have occurred-. Regardless, if our client were to proceed with a subdivision
application that redrew the lot lines for Lot 1 and the Northerly Parcel, this issue would be moot,
and the boundaries and dimensions of any new lots would be defined by a new plat to be
approved by the City.
In the interest of avoiding controversy over a scenario that may never come to pass: MD
1 requests that the City Council consider its appeal of Questions 4 and 5 first. On these issues, I
have enclosed a draft "Amended Interpretation" for your consideration. As you will see, the
Amended Interpretation provides that some floor area would be associated with the Northerly
Parcel, but it acknowledges that the first three questions would be moot if MD 1 pursues an
application for an amended plat.
If the City Council were to make a decision on Questions 4 and 5 that is acceptable to
MD 1, MD 1 would request that the Council hold its appeal in abeyance on Questions 1, 2, and 3
until such time as the property owner processes an application for an amended plat. In order to
preserve the rights of both the City and the Applicant on the first three questions, I propose that
we enter into a simple tolling agreement with respect to any appeal deadlines (covering the
appeal deadlines applicable to appeals that would be heard by the City Council and the District
Court).
MD 1 could then process an application for an amended plat with knowledge of its rights,
and the new final plat could be a benefit for both the City and the Applicant while
simultaneously resolving any ambiguities about future development.
To this end, I enclose the above - referenced draft "Amended Interpretation' for your
consideration. if this document (or something similar) could be approved on a staff level, then
we could avoid an appeal altogether. If that is not an optiotr, then-our be to have the
staff's support at the City Council hearing on October 26, 2009 for both the issuance of the
Amended Interpretation and a tolling agreement for the other 3 questions. I welcome your
comments and any suggested revisions in furtherance of that goal. Otherwise, please submit the
enclosed draft to City Council for its consideration.
Either way, unless we can resolve this issue on a staff level and avoid the appeal hearing,
I request that Council consider the appeal of Questions 4 and 5 before considering Questions 1,
2, or 3.
478395 -1
0 Printed on recycled paper
P254 r-g �3
City of Aspen
October 9, 20D9
GARFIELD & HECHT, P.C. Page 3 of 3
Thank you. I look forward to hearing from you soon.
Very truly yours,
- cht,
P(
D. 1+ H. cConau_ =_
D cl o s u
Encloures)
cc: MD 1, LLC
478395 -1
® Printed on recycled paper
n
CITY OF ASPEN
COMMUNITY DEVELOPMENT DEPARTMENT
AMENDED LAND USE CODE INTERPRETATION
October 9, 2009
SUMMARY:
This Amended Land Use Code Interpretation is being issued in response to an inquiry with
respect to certain real property described in the Amended Quiet Title Decree entered in Pitkin
County District Court Case No. 06 -CV -165. The request was filed by David McConaughy of
Garfield & Hecht, P.C., on behalf of the owner of the "Northerly Parcel" described in such
decree, which is MD 1, LLC. This Amended Interpretation supersedes and replaces the Land
Use Code Interpretation issued on August 19, 2009.
BACKGROUND:
The purpose of this interpretation is to explain the development rights associated with the
"Northerly Parcel" described in the Amended Quiet Title Decree issued by the Pitkin County
District Court in Case No. 06 -CV -165.
The "Northerly Parcel" was originally identified on the plat of Alpine Acres Subdivision as a
right -of -way called Silverking Drive. Silverking Drive was conditionally proposed for
dedication to Pitkin County for public use when the Alpine Acres plat was approved in 1964.
The Alpine Acres Subdivision was annexed by the City in 1976. The right -of -way was never
constructed, and the conditions of dedication were never fulfilled. Neither the County nor the
City ever accepted any dedication of the right -of -way.
MD 1, LLC also owns Unit 1, Lot 1, Block 1 of Alpine Acres, which is a condominium unit.
The property outside the building footprint of the condominium unit is a limited common
element owned jointly by MD 1, LLC and the owner of Unit 2. The Northerly Parcel is adjacent
to the portion of Lot 1 designated as a limited common element on the condominium plat.
Case No. 06 -CV -165 was an adverse possession case in which MD1, LLC and its predecessor
owners of Unit 1 asserted they had used, occupied and possessed the area of the Northerly Parcel
for more than 18 years. On July 31, 2006, the City filed a "Disclaimer" of any interest in the
subject parcel in Case No. 06 -CV -165. Subsequently, the Pitkin County District Court issued its
Decree vesting title in the subject parcel in MD 1, LLC.
The subj ect property is zoned R -6. The Amended Quiet Title Decree is silent as to any
development rights that may be associated with the Northerly Parcel.
By letter from Garfield & Hecht, P.C. dated July 20, 2009, the Applicant presented five requests
for interpretation of the Land Use Code regarding development rights associated with the
Northerly Parcel. The first three questions all related to whether the Northerly Parcel is a distinct
lot or legal parcel that may be sold or developed separately from the adjacent property that is
currently platted as condominium units and common elements. The fourth and fifth questions
related to floor area and development rights associated with the Northerly Parcel.
478386 -2
P256
Since the original Interpretation was issued on August 19, 2009, the Applicant has stated its
desire to amend a portion of the plat for Alpine Acres such that the lot lines between the
condominium units, the common elements, and the Northerly Parcel would all be merged and
reestablished so as to reconfigure the lots and, potentially, to seek City approval of a new plat
depicting three or more new, separate lots. If the Applicant chooses to pursue this approach.,
then the first three questions would become moot, and the remaining issue would be what
development rights are associated with the land currently described as the Northerly Parcel.
Accordingly, this interpretation will address Questions 4 and 5 of the application.
DISCUSSION:
The following sections of the Land Use Code have been considered.
A. Section 26.710.040, Medium Density Residential (R -6) Zone District. Allowable Floor
Area in the R -6 Zone District is based on Lot Area according to the chart set forth at
Section 26.710.040(D)(11).
B. Section 26.575.020(C), Calculations and Measurements — Lot Area.
...Also excluded from total lot area for the purpose of floor area calculations in all zone
districts is that area beneath the high water line of a body of water and that area within a
vacated right -of -way, or within an existing or proposed dedicated right -of- way....
C. Section 26.470.060 — Administrative Applications for Growth Management Review
Citation A provides a table to calculate floor area based on lot size. The Northerly Parcel is
5,603 square feet. Pursuant to the table, this equates to 3,240 square feet of floor area.
Citation B states that any area within a proposed right -of -way is excluded from total Lot Area for
floor area purposes.
Chapter 26.470 of the City Code requires a Growth Management allotment or exemption for all
new development. Citation C provides several options for administrative approval of a Growth
Management allotment for single - family or duplex residences.
INTERPRETATION:
If the Applicant applies for subdivision approval to amend the plat of Alpine Acres for Lot 1 and
the Northerly Parcel, the inclusion of the Northerly Parcel would create development rights for
up to 3,240 square feet of additional floor area. The precise amount of floor area would depend,
in part, on the dimensions of any new lots approved through the subdivision process under the
City Code. Such an application would be subject to all applicable procedures and restrictions set
forth in the City Code.
While the Northerly Parcel may have been identified on the Alpine Acres Subdivision Plat as a
"proposed right -of -way" when the plat was recorded in 1964, there is no current proposal for
right -of -way dedication, and both the City and the District Court have confirmed that title is now
vested in the Applicant as private property. Accordingly, Citation B does not apply.
478386 -2
�'<ft(gl li 6 1 2 7
As part of any subdivision or development application, the Applicant would need to comply with
Chapter 26.470 of the City Code. However, the property would be eligible for administrative
review under Citation C.
478386 -2
r^�
MEMORANDUM
TO: Mayor Ireland and City Council
dvi THRU: Chris Bendon, Community Development Director
FROM: Jennifer Phelan, Community Development Deputy Director
RE: MD1, LLC Appeal (980 Gibson)
MEETING
DATE: October 26, 2009 (continue to 11/23/09)
GENERAL BACKGROUND:
On August 19` of 2009, the Community Development Director issued and administrative
Interpretation (Exhibit 1) with regard to land that was gained by MD1, LLC through a Quiet
Title decree (MDI LLC, et al. v. the City of Aspen). The Applicant is appealing staff's
Interpretation; however, the Applicant has agreed to continue the Appeal to November 23`' in
light of October 26` large agenda.
RECOMMENDATION:
Staff recommends continuing the appeal to November 23rd.
CITY MANAGER COMMENTS:
•
RECOMMENDED MOTION: (all motions must be made in the positive)
"I move to continue the Appeal submitted by MD1, LLC, to November 23, 2009"
3
ASPEN OFFICE AVON OFFICE
601 East Hyman Avenue GARFIELD & HECHT, PC • 0070 Benchmark Road
Aspen, Colorado 81611 Post Office Box 5450
Telephone (970) 925-1936 ATTORNEYS AT LAW Avon, Colorado 81620
Facsimile (970) 925 -3008
Since 1975 Telephone (970) 949 -0707
GLENWOOD SPRINGS OFFICE Facsimile (970) 949 -1810
The Denver Centre www.garfieldhecht.com BASALT OFFICE
420 Seventh Street, Suite 100 River View Plaza
Glenwood Springs, Colorado 81601 100 Elk Run Drive, Suite 220
Telephone (970) 947 -1936 Basalt, Colorado 81621
Facsimile (970) 947 -1937 Telephone (970) 927 -1936
Facsimile (970) 927 -1939
October 9, 2009
David H. McConaughy
Glenwood Springs Office
dmcconaughyrNparfieldhecht. com
.lenifer Phelan. Deputy Director of Community Development
Jim True, Esq., Assistant City Attorney
City of Asper'.
Aspen, CO 81611
Re: 980 Gibson Avenue
Dear Ms. Phelan and Mr. True:
Thank you for the recent meeting regarding the pending appeal of the City's Land Use
Code Interpretation regarding property owned by our client, MD 1, LLC.
As we discussed, our client's goal is to determine the development rights and floor area
associated with the "Northerly Parcel" for which title was quieted in • MD 1's name. That
determination will provide guidance to MD 1 prior to submitting any future development
application.
Our client is considering an application to amend the final plat for Lot 1, Block 1 of
Alpine Acres and create a new plat that would encompass all of Lot 1 (which includes two
condominium units in addition to common elements), plus the Northerly Parcel. The owner of
the adjacent "Southerly Parcel" may or may not seek to include that land as well, but we do not
represent that owner and make no representations concerning the Southerly Parcel. 'This
proposal is only conceptual, and no application is submitted at the current time.
Our original application for a Land Use Code Interpretation presented five separate
questions. The first three questions all related to whether the Northerly Parcel is a separate
buildable lot today in its current state. The City declined to answer those questions and instead
focused on the last two questions, which related to floor area and development rights for the
Northerly Parcel.
During our meeting., you agreed that the Northerly Parcel would, in fact, have associated
floor area unless it is determined to be a "proposed right -of- way." You further suggested that the
City might be open to reconsidering this issue following research to determine whether there
would be any risk of creating precedent for other undeveloped rights -of -way elsewhere in the
® Printed on recycled paper
0
rare
City of Aspen
GARFIELD & HECHT, P.C. October 9, 2009
Page 2 of
City. Given the unique litigation history of the Northerly Parcel, we hope you now agree that
creating precedent for other parcels should not be a concern.
We continue to maintain that the Northerly Parcel is a separate, developable lot.
However, we acknowledge that the City Staff disagrees with this position and believes that the
Northerly Parcel should somehow be merged into the adjacent Lot 1 as an extension of the back
yard and not be considered as a distinct lot. We, in turn, have asserted arguments as to why
merger cannot have occurred. Regardless, if our client were to proceed with a subdivision
application that redrew the lot lines for Lot 1 and the Northerly Parcel, this issue would be moot,
and the boundaries and dimensions of any new lots would be defined by a new plat to be
approved by the City.
In the interest of avoiding controversy over a scenario that may never come to pass, MD
1 requests that the City Council consider its appeal of Questions 4 and 5 first. On these issues, I
have enclosed a draft "Amended Interpretation" for your consideration. As you will see, the
Amended Interpretation provides that some floor area would be associated with the Northerly
Parcel, but it acknowledges that the first three questions would be moot if MD 1 pursues an
application for an amended plat.
If the City Council were to make a decision on Questions 4 and 5 that is acceptable to
MD 1, MD 1 would request that the Council hold its appeal in abeyance on Questions 1, 2, and 3
until such time as the property owner processes an application for an amended plat. In order to
preserve the rights of both the City and the Applicant on the first three questions, I propose that
we enter into a simple tolling agreement with respect to any appeal deadlines (covering the
appeal deadlines applicable to appeals that would be heard by the City Council and the District
Court).
MD 1 could then process an application for an amended plat with knowledge of its rights,
and the new final plat could be a benefit for both the City and the Applicant while
simultaneously resolving any ambiguities about future development.
To this end, I enclose the above - referenced draft "Amended Interpretation" for your
consideration. if this document (or something similar) could be approved on a staff level, then
we could avoid an appeal altogether. If that is not an option, then our goal would be to have the
staff's support at the City Council hearing on October 26, 2009 for both the issuance of the
Amended Interpretation and a tolling agreement for the other 3 questions. I welcome your
comments and any suggested revisions in furtherance of that goal. Otherwise, please submit the
enclosed draft to City Council for its consideration.
Either way, unless we can resolve this issue on a staff level and avoid the appeal hearing,
I request that Council consider the appeal of Questions 4 and 5 before considering Questions 1,
2, or 3.
478395 -1
0 Printed on recycled paper
City of Aspen
GARFIELD & HECHT, P.C. October 9, 2009
Page 3 of 3
Thank you. I look forward to hearing from you soon.
Very truly yours,
G. • - f cht, P.C.
ie 4 0
D. lri H. cConau.
D cl o
Ense
closures)
cc: MD 1, LI,C
478395 -1
0 Printed on recycled paper
' J
CITY OF ASPEN
COMMUNITY DEVELOPMENT DEPARTMENT
AMENDED LAND USE CODE INTERPRETATION
October 9, 2009
SUMMARY:
This Amended Land Use Code Interpretation is being issued in response to an inquiry with
respect to certain real property described in the Amended Quiet Title Decree entered in Pitkin
County District Court Case No. 06 -CV -165. The request was filed by David McConaughy of
Garfield & Hecht, P.C., on behalf of the owner of the "Northerly Parcel" described in such
decree, which is MD 1, LLC. This Amended Interpretation supersedes and replaces the Land
Use Code Interpretation issued on August 19, 2009.
BACKGROUND:
The purpose of this interpretation is to explain the development rights associated with the
"Northerly Parcel" described in the Amended Quiet Title Decree issued by the Pitkin County
District Court in Case No. 06 -CV -165.
The "Northerly Parcel" was originally identified on the plat of Alpine Acres Subdivision as a
right -of -way called Silverking Drive. Silverking Drive was conditionally proposed for
dedication to Pitkin County for public use when the Alpine Acres plat was approved in 1964.
The Alpine Acres Subdivision was annexed by the City in 1976. The right -of -way was never
constructed, and the conditions of dedication were never fulfilled. Neither the County nor the
City ever accepted any dedication of the right -of -way.
MD 1, LLC also owns Unit 1, Lot 1, Block 1 of Alpine Acres, which is a condominium unit.
The property outside the building footprint of the condominium unit is a limited common
element owned jointly by MD 1, LLC and the owner of Unit 2. The Northerly Parcel is adjacent
to the portion of Lot 1 designated as a limited common element on the condominium plat.
Case No. 06 -CV -165 was an adverse possession case in which MD1, LLC and its predecessor
owners of Unit 1 asserted they had used, occupied and possessed the area of the Northerly Parcel
for more than 18 years. On July 31, 2006, the City filed a "Disclaimer" of any interest in the
subject parcel in Case No. 06 -CV -165. Subsequently, the Pitkin County District Court issued its
Decree vesting title in the subject parcel in MD 1, LLC.
The subject property is zoned R -6. The Amended Quiet Title Decree is silent as to any
development rights that may be associated with the Northerly Parcel.
By letter from Garfield & Hecht, P.C. dated July 20, 2009, the Applicant presented five requests
for interpretation of the Land Use Code regarding development rights associated with the
Northerly Parcel. The first three questions all related to whether the Northerly Parcel is a distinct
lot or legal parcel that may be sold or developed separately from the adjacent property that is
currently platted as condominium units and common elements. The fourth and fifth questions
related to floor area and development rights associated with the Northerly Parcel.
478386 -2
Since the original Interpretation was issued on August 19, 2009, the Applicant has stated its
desire to amend a portion of the plat for Alpine Acres such that the lot lines between the
condominium units, the common elements, and the Northerly Parcel would all be merged and
reestablished so as to reconfigure the lots and, potentially, to seek City approval of a new plat
depicting three or more new, separate lots. If the Applicant chooses to pursue this approach,
then the first three questions would become moot, and the remaining issue would be what
development rights are associated with the land currently described as the Northerly Parcel.
Accordingly, this interpretation will address Questions 4 and 5 of the application.
DISCUSSION:
The following sections of the Land Use Code have been considered.
A. Section 26.710.040, Medium Density Residential (R -6) Zone District. Allowable Floor
Area in the R -6 Zone District is based on Lot Area according to the chart set forth at
Section 26.710.040(D)(11).
B. Section 26.575.020(C), Calculations and Measurements — Lot Area.
...Also excluded from total lot area for the purpose of floor area calculations in all zone
districts is that area beneath the high water line of a body of water and that area within a
vacated right -of -way, or within an existing or proposed dedicated right -of- way....
C. Section 26.470.060 — Administrative Applications for Growth Management Review
Citation A provides a table to calculate floor area based on lot size. The Northerly Parcel is
5,603 square feet. Pursuant to the table, this equates to 3,240 square feet of floor area.
Citation B states that any area within a proposed right -of -way is excluded from total Lot Area for
floor area purposes.
Chapter 26.470 of the City Code requires a Growth Management allotment or exemption for all
new development. Citation C provides several options for administrative approval of a Growth
Management allotment for single - family or duplex residences.
INTERPRETATION:
If the Applicant applies for subdivision approval to amend the plat of Alpine Acres for Lot 1 and
the Northerly Parcel, the inclusion of the Northerly Parcel would create development rights for
up to 3,240 square feet of additional floor area. The precise amount of floor area would depend,
in part, on the dimensions of any new lots approved through the subdivision process under the
City Code. Such an application would be subject to all applicable procedures and restrictions set
forth in the City Code.
While the Northerly Parcel may have been identified on the Alpine Acres Subdivision Plat as a
"proposed right -of -way" when the plat was recorded in 1964, there is no current proposal for
right -of -way dedication, and both the City and the District Court have confirmed that title is now
vested in the Applicant as private property. Accordingly, Citation B does not apply.
478386 -2
As part of any subdivision or development application, the Applicant would need to comply with
Chapter 26.470 of the City Code. However, the property would be eligible for administrative
review under Citation C.
478386 -2
r
AFFIDAVIT OF PUBLIC NOTICE
REQUIRED BY SECTION 26.304.060 (E), ASPEN LAND USE CODE
ADDRESS OF PROPERTY:/ 1 A4BG
r P4 , Aspen, CO
SCHEDULED P BLIC HEARING DATE:
L Dct 24e 5: ym , 2009
STATE OF COLORADO )
) ss.
County of Pitkin o
4 401 et a t G40 -1 ' v'1 (name, please print)
being or representing an Applicant to the City of Aspen, Colorado, hereby personally
certify that I have complied with the public notice requirements of Section 26.304.060
(E) of the Aspen Land Use Code in the following manner:
Publication of notice: By the publication in the legal notice section of an official
paper or a paper of general circulation in the City of Aspen at least fifteen (15)
days prior to the public hearing. A copy of the publication is attached hereto.
Posting of notice: By posting of notice, which form was obtained from the
Community Development Department, which was made of suitable, waterproof
materials, which was not less than twenty -two (22) inches wide and twenty -six
(26) inches high, and which was composed of letters not less than one inch in
height. Said notice was posted at least fifteen (15) days prior to the public hearing(
and was continuously visible from the day of , 200 to
and including the date and time of the public hearing. A photograph of the posted
notice (sign) is attached hereto.
Mailing of notice. By the mailing of a notice obtained from the Community
Development Department, which contains the information described in Section
26.304.060(E)(2) of the Aspen Land Use Code. At least fifteen (15) days prior to
the public hearing, notice was hand delivered or mailed by first class postage
prepaid U.S. mail to all owners of property within three hundred (300) feet of the
property subject to the development application. The names and addresses of
property owners shall be those on the current tax records of Pitkin County as they
appeared no more than sixty (60) days prior to the date of the public hearing. A
copy of the owners and governmental agencies so noticed is attached hereto.
(continued on next page)
Mineral Estate Owner Notice. By the certified mailing of notice, return receipt
• requested, to affected mineral estate owners by at least thirty (30) days prior to
the date scheduled for the initial public hearing on the application of
development. The names and addresses of mineral estate owners shall be those
on the current tax records of Pitkin County. At a minimum, Subdivisions that
create more than one lot, Planned Unit Developments, Specially Planned Areas,
and COWAPs are subject to this notice requirement.
Rezoning or text amendment. Whenever the official zoning district map is in
any way to be changed or amended incidental to or as part of a general revision
of this Title, or whenever the text of this Title is to be amended, whether such
revision be made by repeal of this Title and enactment of a new land use
regulation, or otherwise, the requirement of an accurate survey map or other
sufficient legal description of, and the notice to and listing of names and
addresses of owners of real property in the area of the proposed change shall be
waived. However, the proposed zoning map shall be available for public
inspection in the planning agency during all business hours for fifteen (15) days
prior to the public hearing on such amendments.
SG e...-- - 1---)
Signatu e
The foregoing "Affidavit of Notice" was ac o0 dg�d before�ne this day
of 6 C , 200 0 , b -�/wt
P DLIC NOTICE
RE: APP L OF AN INTERPRETATION
NOTICE IS HER y GIVEN that a public hearing, WITNESS MY HAND AND OFFICIAL SEAL
will be held on onday, October 26, 2009, to
be at 5'00 p before the Aspen Cit Council,
Cit Council Ch burs, Cit Hall 130 y. Galena
St., Aspen, 1 consider an appeal of an
Interpretatio issued by the Community My commission expires: D % A ciao I 6
Development Director, submitted by David
McCOnaun 0 on development MgC. ass AA9C, s,
Aspen, CO 8161 1 The Interpre ri tati , on provided `/, / T V_ J /
it information land that the asvaat was acquired rights associated
w title
with land thc by quiet title,
specifically, that the land has no associated floor
e qest of e appcant is reverse the Notary Public
C ommu ea. Th nity reu
Developm Dir int r erpretation
on floor area and respond to certain additional
questions. The subject land under review is .a ..... adjacent to 980/990 Gibson and 1040 Matchless —: c ?V }) y
Dnve and is generally described as a parcel being
a portion of Silver King Drive, Block 1; Alpine Acres ; `0 ° °�•• °° ° •., fff
Subdivision, City of Aspen, County of Pitkin, State
of Colorado as shown on the plat thereof recorded
at Reception No. 118173, said drive more 1 : 'V5
LAURw y
commonly known as Matchless Drive. For fudher
information, contact Jennifer Phelan at the City of 6I • ' • MEYER j
Aspen Community Development Depadment, 130 ATTACHMENTS AS APPLICABLE:
S. Galena St.. Aspen, CO 970.429.2759, (or by ffl ••
email Jennifer. Phelan@ci. asoen.co.us).
aMichael C. Ireland. Chair YE PUBLICATION f 1 ° ! • f • . °
Aspen City council �� r'" CQ�.
lPH OF THE POSTED NOTICE (SIGN '' —
Published in the Aspen Times Weekly on October
1 C
11.2009. (41273351 !E OWNERS AND GOVERNMENTAL AGENC M tfj il0f2Of0
BY MAIL
• APPLICANT CERTIFICATION OF MINERAL ESTAE OWNERS NOTICE
AS REQUIRED BY C.R.S. §24- 65.5 -103.3
v , in
y P� o a -7; -6 0biSp3 o o n rail
c 3 % f .m Qg
T ' .. Dy c g- m N y N y '2,
.$ I a- r, G maOna z
—" 5 A l l • co
2 — C` , a
moo„$ s
"O 3 F . p, a 2 ^ �!
O
ru
r b ., _
9 I � W
3 h -' a P 3 tr W 3 ,
....._
W R. m -4 m \ al
r 3 ❑ O ❑ zz
rU n � r
o = -- ru
1 E ‘ . 11 . 1 o m
1 -5 4 -. t - A >'( 4 9--
Itr Si:` Y.. .
^ � D o N UWTg
/lll/// S
F 2l 7 t c,:,' it O ° ➢
/ N af
N l �
P
m °C11m1
si miii i 1
m G
October 5, 2009
Mr. David McConaughy
Garfield and Hecht, P.C.
THE CITY OF ASPEN
601 E. Hyman Ave.
Aspen, CO 81611
RE: APPEAL OF AN INTERPRETATION (980 Gibson)
Dear David,
•
As required per Section 26.316.020 D., Notice Requirements, of the land use code notice is
hereby given that a public hearing will be held on Monday, October 26, 2009, to begin at 5:00
p.m. before the Aspen City Council, City Council Chambers, City Hall, 130 S. Galena St.,
Aspen. The purpose of the hearing is to consider an appeal of an Interpretation submitted by you
on behalf of MDI,LLC.
The Interpretation provided information on the development rights associated with land that was
acquired by quiet title, specifically, that the land has no associated floor area. The request of the
applicant is to reverse the Community Development Director's interpretation on floor area and
respond to certain additional questions. The subject land under review is adjacent to 980/990
Gibson and 1040 Matchless Drive and is generally described as a parcel being a portion of Silver
King Drive, Block 1, Alpine Acres Subdivision, City of Aspen, County of Pitkin, State of Colorado as
shown on the plat thereof recorded at Reception No. 118173, said drive more commonly known as
Matchless Drive. For further information, please feel free to contact me at 970.429.2759 or by
email Jennifer.Phelan@ci.aspen.co.us. A memo will be emailed to you in the near future.
Regards,
Jenifer Phelan
Deputy Director
130 SOUTH GALENA STREET • ASPEN, COLORADO 81611 -1975 PHONE 970.920.5000 • FAX 970.920.5197
www. aspengov.com
Primed on Recycled Paper
RECEIVED
SEP 0 2 2009
CITY OF ASPEN
ATTACHMENT 2 —LAND USE APPLICATION COMMUNTTY DEVELOPMENT
ROJECT:
Jame: "Nor Paie 1 '' pQr Cou1-
rflec(eP P "+k0 0 ls4.C4.06cv
.ocation: ' {XO ts A-ve., / 4spa - \ 4Ipinf 4Cres C
(Indicate street address, lot & block number, le:al description w ere a, ro.riate
'arceiID #(REQUIRED) jv — Tlti Qoun4M QSSP54 websi4e nines no 5 4-w A
Por Lel tl As 4-Le chyle he reon.
YPPLICANT:
Jame: M9 1 LL C
Address: I O q 44� / A- S e!') `(• 16 I
? hone #: Y
REPRESENTATIVE:
\lame: Qav,d F-. Mc ('onat k�
Address: Gart'C 4 Keck , 601 E. 14 m4 \ f}ve, Aspw\ . CO F76 11
Phone #: g7-0 Qa6 (836,
TYPE OE APPLICATION: (please check all that apply):
❑ GMQS Exemption ❑ Conceptual PUD ❑ Temporary Use
❑ GMQS Allotment ❑ Final PUD (& PUD Amendment) ❑ Text/Map Amendment
❑ Special Review ❑ Subdivision ❑ Conceptual SPA
❑ ESA - 8040 Greenline, Stream ❑ Subdivision Exemption (includes ❑ Final SPA (& SPA
Margin, Hallam Lake Bluff, condominiumization) Amendment)
Mountain View Plane
❑ Commercial Design Review ❑ Lot Split ❑ Small Lodge Conversion/
Expansion
❑ Residential Design Variance ❑ Lot Line Adjustment [T' Other: A ppe4I et 14
❑ Conditional Use U code n i er ce1-a4,bor
EXISTING CONDITIONS: (description of existing buildings, uses, previous approvals, etc.)
PROPOSAL: (description of proposed buildings, uses, modifications, etc.)
[lave you attached the following? FEES DUE: $
] Pre - Application Conference Summary
] Attachment #l, Signed Fee Agreement
] Response to Attachment #3, Dimensional Requirements Form
] Response to Attachment #4, Submittal Requirements- Including Written Responses to Review Standards
] 3 -D Model for large project
All plans that are larger than 8.5" X 11" must be folded. A disk with an electric copy of all written text
'Microsoft Word Format) must be submitted as part of the application. Large scale projects should include an
electronic 3 -1) model. Your pre-application conference summary will indicate if you must submit a 3 -1) model.
% WOO se
RECEIVED
SEP 01 2009
CITY OF ASPEN COMMUNITY DEVELOPMENT DEPARTMENT CITY OFASPEN
COM MUNITYDEVaopNeNT
Azreement for Payment of City of Aspen Development Application Fees
CITY OF ASPEN (hereinafter CITY) and M D 1 L. L. C.
(hereinafter APPLICANT) AGREE AS FOLLOWS:
1. APP ICANT has submitted to CITY an application for
Ao en! o Irk Ad use code evvi- Prprel.-10 0-o •
(hereinafter, THE PROJECT).
2. APPLICANT understands and agrees that the City of Aspen has an adopted fee structure for Land
Use applications and the payment of all processing fees is a condition precedent to a determination of application
completeness.
3. APPLICANT and CITY agree that because of the size, nature or scope of the proposed project, it
is not possible at this time to ascertain the full extent of the costs involved in processing the application.
APPLICANT and CITY further agree that it is in the interest of the parties that APPLICANT make payment of an
initial deposit and to thereafter permit additional costs to be billed to APPLICANT on a monthly basis.
APPLICANT agrees additional costs may accrue following their hearings and /or approvals. APPLICANT agrees he
will be benefited by retaining greater cash liquidity and will make additional payments upon notification by the
CITY when they are necessary as costs are incurred. CITY agrees it will be benefited through the greater certainty
of recovering its full costs to process APPLICANT'S application.
4. CITY and APPLICANT further agree that it is impracticable for CITY staff to complete
processing or present sufficient information to the Historic Preservation Commission, Planning and Zoning
Commission and /or City Council to enable the Historic Preservation Commission, Planning and Zoning
Commission and /or City Council to make legally required findings for project consideration, unless current billings
are paid in full prior to decision.
5. Therefore, APPLICANT agrees that in consideration of the CITY's waiver of its right to collect
full fees prior to a determination of application completeness, APPLICANT shall pay an initial deposit in the
amount of $ 4- 3 S which is for I hours of Community Development staff time, and if actual
recorded costs exceed the initial deposit, APPLICANT shall pay additional monthly billings to CITY to reimburse
the CITY for the processing of the application mentioned above, including post approval review at a rate of $245.00
per planner hour over the initial deposit. Such periodic payments shall be made within 30 days of the billing date.
APPLICANT further agrees that failure to pay such accrued costs shall be grounds for suspension of processing, and
in no case will building permits be issued until all costs associated with case processing have been paid.
CITY OF ASPEN APPLICANT
Mb 1 V . LLC n
B By: Ccr! si
Chris Bendon llMltp tAnnCLS
Community Development Director Date: 1-2.01
Billing Address and Telephone Number:
I q A L
RECEIVED
SEP 01 2009
CITY OF ASPEN
ATTACHMENT 2 -LAND USE APPLICATION COMMUNITY DEVELOPMENT
ROJECr:
Jame: "A1o r+kerl j PArc -e I " pQr Cour4 Qecree ) P;1 -k,. D ts4-.C4..a6cvllr
.ocation: 'iX0 CC lI bServ• A-ve., A sp&'.. .4IpeAt Acres C4(0.
(Indicate street address, lot & block number, legal description where appropriate)
'arcellD #(REQUIRED) (4 — T-t COkS QS Lue ksi4e Danes r01 5htr-s� a
part-el tk As af \LW ct'a4ee hereoo
kPPLICANT:
Jame: MO 1 L L C
kddress: I O C l r4A- / A SPew, ('n cl 16 I
'hone #:
REPRESENTATIVE:
\lame: 'V n
av Cd H .• Mc
Address: GArc t+ t4ecLt-, 601 E. 1.4 ete\ Ave, ASpeNN , CO 2r(( (
Phone #: 9 +0 QaE 1Q
TYPE OF APPLICATION: (please check all that apply):
❑ GMQS Exemption ❑ Conceptual PUD ❑ Temporary Use
❑ GMQS Allotment ❑ Final PUD (& PUD Amendment) ❑ Text/Map Amendment
❑ Special Review ❑ Subdivision ❑ Conceptual SPA
❑ ESA — 8040 Greenline, Stream ❑ Subdivision Exemption (includes ❑ Final SPA (& SPA
Margin, Hallam Lake Bluff, condominiumization) Amendment)
Mountain View Plane
❑ Commercial Design Review ❑ Lot Split ❑ SmallLodge Conversion/
Expansion
❑ Residential Design Variance ❑ Lot Line Adjustment a Other: A ppeed o3' / m a
❑ Conditional Use Use code n 4 - er eef f a+fo ,
•
EXISTING CONDITIONS: (description of existing buildings, uses, previous approvals, etc.)
PROPOSAL: (description of proposed buildings, uses, modifications, etc.)
Have you attached the following? FEES DUE: $
] Pre - Application Conference Summary
] Attachment #1, Signed Fee Agreement
] Response to Attachment #3, Dimensional Requirements Form
] Response to Attachment #4, Submittal Requirements- including Written Responses to Review Standards
] 3 -D Model for large project
All plans that are larger than 8.5" X 11" must be folded. A disk with an electric copy of all written text
'Microsoft Word Format) must be submitted as part of the application. Large scale projects should include an
electronic 3 -D model. Your pre - application conference summary will indicate if you must submit a 3 -1) model.
C 0
ASPEN OFFICE GARl IELD CC P HECHT C AVON OFFICE
601 East Hyman Avenue . . 0070 Benchmark Road
Aspen, Colorado 81611 Post Office Box 5450
Telephone (970) 925 -1936 ATTORNEYS AT LAW Avon, Colorado 81620
Facsimile (970) 925 -3008 Since 1975 Telephone (970) 949 -0707
GLENWOOD SPRINGS OFFICE Facsimile (970) 949 -1810
The Denver Centre www.garfieldhecht.com BASALT OFFICE
420 Seventh Street, Suite 100 River View Plaza
Glenwood Springs, Colorado 81601 100 Elk Run Drive, Suite 220
Telephone (970) 947 -1936 Basalt, Colorado 81621
Facsimile (970) 947 -1937 Telephone (970) 927 -1936
Facsimile (970) 927 -1939
September 1, 2009
David H. McConaughy
dmcconaueh v(mEarreldhecht.com
Chris Bendon
Community Development Director RECEIVED
City of Aspen
Aspen, CO 81611
SEP 01 2009
Re: 980 Gibson Avenue CITY OF ASPEN
Dear Mr. Bendon: « Y a '
Please accept this letter as an appeal of the City's decision dated August 19, 2009,
regarding this firm's application for a code interpretation dated July 20, 2009, on behalf of MD
1, LLC. For ease of reference, we enclose copies of the November 5, 2008 pre - application
conference summary, this firm's letter of July 20, 2009, and the City's decision dated August 19,
2009. We have also included additional documents identified below that were already in the
City's possession and, based on the decision, appear to have been relied upon by the Community
Development Department. This appeal is submitted pursuant to Section 26.316.030(A) of the
Aspen City Code.
Issues for Appeal
1. The Community Development Department did not answer Questions 1, 2 or 3.
The application presented four questions regarding specific provisions of the City Code
and a fifth, general question regarding the land use entitlements for certain property described in
the application. The response was silent regarding the first three questions.
2. The City Council should reverse the decision of the Community Development
Department regarding Question 4 because Matchless Drive is not a dedicated. vacated. or
proposed right -of -way.
3. The City Council should clarify the response to Question 5 by confirming that the
property is eligible for administrative review under the Growth Management Quota System
described in Chapter 26.470 of the City Code.
390542 -1
0 Printed on recycled paper
0 3
City of Aspen
GARFIELD & HECHT, P.C. September 1, 2009
Page 2 of 4
Law and Argument
Issue No. 1
City Code Section 26.306.010 provides that any real property owner in the City may apply for an
interpretation of any provision of Title 26 of the City Code. Question 1 of the application
included a specific request to interpret Code Section 26.710.040. Question 2 requested an
interpretation of Title 26 regarding the absence of any provision to dissolve a lot line between
contiguous parcels without formal action or notice. Question 3 presented a specific question
regarding Code Section 26.312.050.
The decision of the Community Development Department was silent as to all three questions.
Accordingly, we request that the City Council either answer the questions or direct the
Community Development Department to provide an interpretation as required by Section
26.306.010.
Issue No. 2
In response to Question No. 4, the Community Development Department cited three code
sections in support of its contention that the "Northerly Parcel" has no floor area because the
subject parcel is a "vacated right -of -way" or an "existing or proposed dedicated right -of- way."
As recognized by the City, the subject parcel was created by virtue of the enclosed Amended
Decree Quieting Title dated July 10, 2008. The legal description attached to the decree as
Exhibit A confirms that the parcel was once a portion of Silver King Drive a/k/a Matchless Drive
as shown on the plat approved by Pitkin County before the land was annexed to the City of
Aspen. An excerpt from the recorded plat is also enclosed.
It is undisputed that the portion of Matchless Drive that became the Northerly Parcel was never
actually dedicated to, nor accepted by, either Pitkin County or the City of Aspen. Neither the
City nor the County ever took any formal action to vacate the right -of -way, because it was never
dedicated in the first place. As such, the City cannot rely on the portions of Code Section
26.757.020 referring to a "vacated right -of -way" or a "dedicated right -of- way."
The question, therefore, is whether the portion of Matchless Drive shown on the plat can be
considered a "proposed right -of -way" for purposes of Section 26.757.020. Such an
interpretation defies both law and common sense for a number of reasons.
First, the word "proposed" must be interpreted to apply to the time of the application. Land use
applications typically go through a number of iterations before reaching the stage of final plat.
The location and dimensions of lots and streets will change from sketch plan through final
approval, and lots shown on a final plat may overlap areas that were considered or proposed as
roads early in the process. As a practical matter, a "proposed right -of -way" cannot possibly
include every square foot of land that was ever considered as a road in any context, especially
465447 -1
0 Printed on recycled paper
3
City of Aspen
GARFIELD & HECHT, P.C. SeptemP 3 2
of 4
where the City has explicitly rejected such a proposal. Instead, this section must be interpreted
to apply to lands that are currently proposed as future rights -of -way so that the public's future
right of access will not be impaired by development.
Second, any proposal for the dedication of Matchless Drive was made prior to the date the plat
was approved by Pitkin County in 1964 and was subject to conditions that were never fulfilled.
The County never accepted any dedication, and any contractual duties of the original developer
to fulfill any such conditions would have become unenforceable due to the statute of limitations
more than 40 years ago. There is no current proposal.
Third, even if there were a "proposal" for dedication, such a proposal would have been made to
Pitkin County, not the City of Aspen. Any such proposal to Pitkin County is not relevant under
the City Code.
Finally, and most importantly, the City affirmatively disclaimed any interest in the subject parcel
by filing the enclosed unconditional Disclaimer in Case No. 06 -CV -165 on July 31, 2006. Even
if there had been a lingering "proposal" for future dedication, it was extinguished as of that date.
Under the doctrines of res judicata and collateral estoppel, the City cannot now take a position
contrary to what was litigated, or what could have been litigated, in the quiet title case.
As of the date of the application, the Northerly Parcel is not a vacated right -of -way, a dedicated
right -of -way, or a proposed right -of -way. Accordingly, the conclusion that the parcel has no
floor area on this basis must be reversed.
Issue No. 3
The Community Development Department determined that the parcel is not eligible for
development because it has never received a Growth Management review under Chapter 26.470
of the City Code.
Pursuant to Section 26.470.060, assuming that the applicant desires to apply for a single - family
home or a duplex, the parcel should be eligible for administrative review subject only to the
construction of an ADU in order to meet affordable housing requirements. We request
confirmation of this interpretation.
Conclusion
The City Council should direct the Community Development Department to respond to
Questions 1, 2 and 3 as presented in the application. The applicant reserves the right to file a
future appeal depending on the outcome of that response.
The City Council should reverse the Community Development Department's conclusion that the
Northerly Parcel has no associated floor area.
465447 -1
s� Printed on recycled paper
Seer+
City of Aspen
GARFIELD & HECHT, P.C. September 1, 2009 f4
Page 4 of 4
The City Council should clarify that an application for Growth Management approval for a
single family home or duplex may be processed on an administrative basis subject only to
affordable housing requirements.
We look forward to presenting this appeal to the City Council. Thank you for your time and
attention.
Very truly yours,
Garfield & Hecht, P.C.
tekti
David H. McConaughy
DHM:lp
Enclosure(s)
cc: MD 1, LLC
465447 -1
® Printed on recycled paper
r
City of Aspen
GARFIELD &HECHT, P.C. Ji y 20, 2009
Page 2 of 3
but the "minimum lot size" is 6,000 square feet. We believe the latter provision applies only
during the subdivision process to create a new lot, but an existing parcel in the R -6 zone would
be eligible for construction of a detached dwelling unit if it meets or exceeds 4,500 square feet
and complies with other requirements of the City Code.
2. Is there any process under the City Code by which a lot line between contiguous
parcels can be dissolved without formal action by the City and notice to the affected property
owners?
We are not aware of any such process and believe the answer is "no."
3. In the case of a condominium plat identifying three adjacent parcels where Parcel A is
owned solely by Party I, Parcel B is owned solely by Party 2, and Parcel C is a common element
owned in equal undivided interests by both Party 1 and Party 2, are each of the three parcels "in
separate ownership" or are any two or more parcels in the "same ownership" for purposes of
City Code Section 26.312.050?
We believe that each of the three parcels would be in separate ownership because title is
vested differently for each parcel and that none of them would be in the same ownership.
4. Is there any provision in the City Code providing that a legal parcel established by
Court Decree has no associated floor area for any purpose of the City Code if such parcel was
ever proposed as a potential right of way but was never actually dedicated to the City as a street
or right of way?
We are not aware of any such provision and therefore believe the answer is "no."
5. Under Chapter 26.306 of the City Code, will the City respond to an applicant's
request to interpret the Code by describing or confirming the land use entitlements for a specific
piece ofproperty?
We have been informally advised by the planning department that the Community
Development Director would not provide an opinion regarding entitlements for a specific
property under this Chapter. Therefore, we merely seek to confirm that such a request would be
rejected and/or summarily denied. However, if the Community Development Director would
respond to such a request, then we request a summary of the entitlements for the parcels owned
by our client as described at the beginning of this letter.
* *
450346 -1
® Printed an recycled paper
r^
City of Aspen
GARFIELD & HECHT, RC. July 20, 2009
Page 3 of
If you require any additional information, please let me know. We look forward to your
response. Thank you very much for your time and attention.
Very truly yours,
Garfie . . t, P.C.
a id H. i cConaug
DHM:lp
Enclosure(s)
Cc: MD 1, LLC
450346 -1
® Printed on recycled paper
RECEIVED
SEP 01 2009
CITY OF ASPEN GI TY OF ASPEN
PRE - APPLICATION CONFERENCE SUMMARY ;OMMUMTY DEVELOPMENT
PLANNER: Jessica Garrow, 429 -2780 DATE: November 5, 2008
PROJECT: 980 Gibson
REPRESENTATIVE: Stan Clauson, 925.2323
DESCRIPTION:
The Applicant is interested in better understanding what can be done on the property located at 980 Gibson. 980 Gibson is
a corner lot, adjacent to Gibson Ave and Matchless Drive. The property is designated Historic.
The property was engaged in a Quiet Title action for a platted right of way that was adjacent to the historic property and,
known commonly as Silverking Drive. This is recorded at reception number 550852. The Community Development
Department and the City Attorney's office have examined the quiet title, and believe the following with respect to 980
Gibson:
• The quiet title did not create new developable parcels of land. Rather, the quiet title enlarged 2 existing properties,
one is 980 Gibson.
. • Because the area of land was originally platted for a ROW (though never accepted by the City) it cannot be used
for purposes of Floor Area. It can, however, be used for purposes of setbacks.
• The City of Aspen requires adequate ROW for Matchless Drive, which is adjacent to 980 Gibson. This may mean
that a portion of the property that was subject of the quiet title may need to be dedicated to the City.
The City advises the applicant to get a survey completed based on the language in the Quiet Title and agreements with the
City to confirm this understanding.
Land use applications can be found on the Community Development website at:
http : / /www.aspenpitkin.com /depts /41 /main planninq.cfm.
Relevant Land Use Code Section(s): 26.104,100 Definitions, Parcel
26.304 Common Development Review Procedures
26.415 Development Involving a Landmark
26.575.020 Calculations and Measurements
26.710.040 R -6 Zone District
httD:// www. aspenpitkin .comldeptsl38 1citvcode.cfm
Review by: - Staff for compliance with quiet title
Referral Agencies: None.
Planning Fees: none at this time
Referral Agency Fees: None
Total Deposit: none at this time
To apply, submit the following Information:
❑ Proof of ownership with payment.
❑ Signed fee agreement.
❑ Applicant's name, address and telephone number in a letter signed by the applicant which states the name,
address and telephone number of the representative authorized to act on behalf of the applicant.
❑ Street address and legal description of (he parcel on which development is proposed to occur, consisting of a
current certificate from a title insurance company, or attomey licensed to practice in the State of Colorado, listing
the names of all owners of the property, and all mortgages, judgments, liens, easements, contracts and
agreements affecting the parcel, and demonstrating the owner's right to apply for the Development Application.
❑ Total deposit for review of the application.
❑ 3 Copies of the complete application packet and maps,
HPC =12; PZ = 10; CC = 7; Referral Agencies = 1 /ea.; Planning Staff = 1
❑ An 8112" by 11" vicinity map locating the parcel within the City of Aspen,
❑ Site improvement survey including topography and vegetation showing the current status, including all easements
and vacated rights of way, of the parcel certified by a registered land surveyor, licensed in the state of Colorado.
(This requirement, or any part thereof, may be waived by the Community Development Department if the project is
determined not to warrant a survey document.)
❑ A written description of the proposal and an explanation in written, graphic, or model form of how the proposed
development complies with the review standards relevant to the development application. Please include existing
conditions as well as proposed. List of adjacent property owners within 300' for public hearing
❑ Copies of prior approvals.
❑ Applications shall be provided in paper format (number of copies noted above) as well as the text only on either of
the following digital formats. Compact Disk (CD)- preferred, Zip Disk or Floppy Disk. Microsoft Word format is
preferred. Text format easily convertible to Word is acceptable.
❑ Applicants are advised that building plans will be required to meet the International Building Code as adopted by
the City of Aspen, the Federal Fair Housing Act, and CRS 9.5.112. Please make sure that your application
submittal addresses these building - related and accessibility regulations. You may contact the Building Department
at 920-5090 for additional information.
Disclaimer:
The foregoing summary is advisory in nature only and is not binding on the City. The summary is based on current zoning,
which is subject to change in the future, and upon factual representations that may or may not be accurate. The summary
does not create a legal or vested right.
r...
CITY OF ASPEN
COMMUNITY DEVELOPMENT DEPARTMENT
LAND USE CODE INTERPRETATION
JURISDICTION: City of Aspen
APPLICABLE CODE SECTIONS: Section 26.104.100, Definitions — Right of
Way
Section 26.470, Growth Management
Section 26.575.020.0 - Calculations and
Measurements, Lot Area
Section 26.710.040, Medium Density
Residential (R -6) Zone District
EFFECTIVE DATE: August 19, 2009
WRITTEN BY: Jennifer Phelan, Community Development
Deputy Director
Jessica Garrow, Long Range Planner
APPROVED BY: Chris Bendon, Community Development
Director
COPIES TO: City Attorney
City Planning staff
SUMMARY:
This Land Use Code interpretation is being issued in response to an inquiry with regard to the
`parcel' created as a result of MD1 LLC, et al. v. The City of Aspen, et al. Pitkin County Case
No. 06 CV 165. The request was filed by David McConaughy of Garfield and Hecht LLC on
behalf of MD 1 LLC and asks that the Community Development Director indicate if there is a
development right to the "Northerly Parcel" referenced in Pitkin County Case No. 06 -CV -165.
The requester shall have the right to appeal this code interpretation, as outlined below.
BACKGROUND:
The purpose of this interpretation is to explain the development rights, if any, associated with the
"Northerly Parcel" described in the Amended Quiet Title Decree issued by the Pitkin County
District Court in Case No. 06 -CV -165.
The "Northerly Parcel" was originally platted as right -of -way called Silverking Drive in the
Alpine Acres Subdivision. Silverking Drive was dedicated to Pitkin County for public use when
it was originally approved in 1964. The subdivision was annexed by the City in 1976. The
right -of -way, although dedicated, was never improved upon and MD 1 LLC recently received
possession of the right -of -way through Quiet Title Decree. The area is in the R -6 Zone District.
The legal case began as an adverse possession claim. The City agreed to disclaim any interest in
the subject property upon certain conditions agreed to by the parties to the lawsuit to ensure that
adequate utilities are available and adequate right -of -way was preserved for access to other
surrounding Tots. When the City disclaimed interest in the right -of -way, there was no discussion
or reference by the plaintiffs regarding the creation of separate parcels, floor area, or
development rights. The final Decree did not mention floor area or new development rights.
DISCUSSION
Staff has relied on four (4) sections of the Land Use Code, to render this interpretation.
Following are the sections, with emphasis added:
A. Section 26.710.040, Medium Density Residential (R -6) Zone District. Allowable Floor Area
in the R -6 Zone District is based on Lot Area.
B. Section 26,575.020.C, Calculations and Measurements — Lot Area.
... Also excluded from total lot area for the purpose of floor area calculations in all zone
districts is that area beneath the high water line of a body of water and that area within a
vacated right -of -way. or within an existinz or proposed dedicated right-of-wav or surface
easement. ...
•
C. Section 26.104.100, Definitions — Right -of -Way.
A strip or other area of land specifically designated or reserved for travel, passage, and /or
the installation of utilities or other similar uses by persons other than, or in addition to,
the landowner.
D. Section 26.470, Growth Management.
Section 26.470.020, Applicability — General: This Chapter shall apply to all
development in the City of Aspen — Residential, Lodging, Commercial, and Community
Facilities.
Citation A states that Floor Area calculations in the R -6 Zone District are based on Lot Area.
Citation B states that any area within a proposed right -of -way is excluded from total Lot Area for
floor area purposes and therefore does not contribute to floor area calculations. Citation C
defines a "right -of- way."
Citation D states that any and all development, regardless of the use type, must undergo a growth
management review and either receive a growth management allotment or an exemption. If a
growth management allotment or exemption is not received development cannot occur.
INTERPRETATION
It is Staff's interpretation that the land area that MD1 LLC received through the Quiet Title
Decree has no associated floor area and does not have a development right.
First, because the land area in question was a proposed right -of way, it is deducted from the
calculation of Lot Area and therefore it has no associated floor area. Second, all development in
{ r
the City of Aspen must receive a growth management allotment or exemption in order to have a
development right. The land associated with the Quiet Title has never received such a review.
This interpretation was provided on August 19, 2009, and shall become effective on August 19,
2009. This interpretation of the land use code shall be valid until such time as the code sections
specified are amended to implement this clarification or for other purposes.
APPEAL OF DECISION
As with any interpretation of the land use code by the Community Development Director, an
applicant has the ability to appeal this decision to the Aspen City Council. This can be done in
conjunction with a land use request before City Council or as a separate agenda item.
26.316.030(A) APPEAL PROCEDURES
Any person with a right to appeal an adverse decision or determination shall initiate an appeal by
filing a notice of appeal on a form prescribed by the Community Development Director. The
notice of' appeal shall be filed with the Community Development Director and with the City
office or department rendering the decision or determination within fourteen (14) days of the
date of the decision or determination being appealed. Failure to file such notice of appeal within
the prescribed time shall constitute a waiver of any rights under this Title to appeal any decision
or determination.
RECEPTION#: 550853, 07/04:108 at 02:10:07 PM, 1 OF 5, R \46.00
Janice K. Vos Caudill, Pitkin County, CO
Pitkin County District Court
506 East Main Street
Aspen, CO 81611
Plaintiffs:
MD1 LLC, a Colorado limited liability
company, and, VAN METER FAMILY
LIVING TRUST, a California Tnist
V.
Defendant(s):
The QTY OF ASPEN; LUKE W. COURT USE ONLY
ANTHONY, or his heirs, successors, or
assigns; and all unknown persons who claim Case Number. 06 CV 165
any interest in the subject matter of this action.
The Honorable Denise K. Lynch
On Plaintiffs' Motion for Summary Judgment Division:
AMENDED DECREE QUIETING TITLE IN PLAINTIFFS and CORRECTING
CLERICAL ERRORS
The matter was before this Court on Plaintiffs' Motion for Summary Judgment. Based upon
the pleadings that have been filed and the affidavits and exhibits admitted into evidence, THIS
COURT FINDS:
THAT service under Rule 4 of the Colorado Rules of Civil Procedure is proper upon all of
the Defendants in this action;
THAT the legal description in the first decree contained clerical errors, which are fixed in
Revised Exhibit A and Revised Exhibit 13, attached hereto, pursuant to the Court's authority
under CRC.P. Rule 60(a);
THAT MD1 LLC and its predecessors in interest have adversely possessed the property
described in Revised Exhibit (the "Northerly Parcel "), attached hereto, for a time in excess of
the periods of the statutes of limitation, as provided in CRS. SS 38 -41 -101, et sal.;
THAT the Van Meter Family Living Trust and its predecessors in interest have adversely
possessed the property described in Revised Exhibit B (the "SoutheriyPamel "), attached hereto,
fora time in excess of the periods of the statutes of limitation, as provided in C.R.S. ;- - •
sq. COMBINED OW , .•F GARFIELD COUNTY
OLEWNGOI).. GS, COLORADO
Altemate finding for Plaintiffs' title derived through re A and correct copy of the
origin ' 4 %
0
Cried Clerks
,ea9Y'9= Dep4'
RECEPTION#: 550853, 07/097re008 at 02 :10:07 PM, 2 OF 5,
Janice K. Vos Caudill, Pitkin County, CO
MD1, et al. v. Aspen, et al.
Pitkin County District Court, Case No. 06 CV 165
Decree Quieting Tito in Plaintiffs
Page 2 of 5
THAT MD1 LLC is the owner of the Northerly Parcel by reason of that certain bargain and
sale deed from Luke W. Anthony, dated September 14, 2007, and recorded in the real property
records of Pitkin County, Colorado on November 9, 2007, at Reception No. 543962;
THAT the Van Meter Family Living Trust is the owner of the Southerly Parcel by reason of
that certain bargain and sale deed from Luke W. Anthony, dated September 14, 2007, and recorded
in the real property records of Pitkin County, Colorado on November 9, 2007, at Reception No.
543963;
THAT none of the Defendants has responded to the Complaint or entered an appearance in
this action and all the Defendants are therefore in default, with the exception of the City of Aspen
and Luke W. Anthony, both of whom disclaimed all interest in the Northerly Parcel and Southerly
Parcel;
THAT Daniel D. LeMoine, Esq., has been appointed and appeared for any and all
Defendants who are in, or who maybe in, or who may have been ordered to report for induction
into, the military service, as defined by the Soldiers' and Sailors' Cavil Relief Act of 1940, as
amended;
THAT this is an action in remaffecting specific real property;
THAT the Court has jurisdiction over all patties to this action and of the subject matter
thereof;
THAT the allegations in the Complaint are tree; and
THAT no Defendant herein has any right, tide, or interest in or to the Northerly Parcel or
Southerly ParceL
THEREFORE IT IS ADJUDGED AND DECREED THAT:
MD1 LLC was, at the time of the filing of the Motion for Summary Judgment, and is now,
the owner in fee simple absolute with right to possession of the Northerly Parcel;
The Van Meter Family Living Trust was, at the time of the filing of the Motion for Summary
Judgment, and is now, the owner in fee simple absolute with right to possession of the Smithery
Parcel; and
RECEPTION#: 550853, 07/008 at 02:10:07 PM, 3 OF 5,
Janice K. Vos Caudill, Pitkin County, CO
MD1, et al. v. Aspen, et aL
Pitkin CountyDistrict Court, Case No. 06 CV 165
Decree Quieting Title in Plaintiffs
Page 3 of 5
Fee simply tide in and to the NortherlyParcel and Southerly Parcel be and the same hereby
quieted in MD1 LLC and the Van Meter Family Living Trust, respectively, and that each of the
Defendants has no right, title, or interest in or to the Northerly Parcel or SoutherlyParcel, or any
pan thereof, and that Defendants are forever enjoined from asserting any claim, right, title, or
interest in or to the NortherlyParcel or SoutherlyParcel or any part thereof.
Signed this LD day of July, 2008.
By the Court:
1)..1
Denise K. Lynch, District J
RECEPTION#: 550853, 07/008 at 02:10:07 PM, 4 OF 5,
Janice K. Vos Caudill, Pitkin County, CO
MD1, et aL v. Aspen, et aL
Pitkin CountyDistrict Court, Case No. 06 CV 165
Decree Quieting Tide in Plaintiffs
Page 4 of 5
EXHIBIT A
PROPERTY DESCRIPTION OP NOR RLY PARCEL
A parcel of being a portion of Silver King Drive, Block 1, Alpine Acres Subdivision, City of Aspen,
County of Pitkin, State of Colorado, as shown on the plat thereof recorded at Reception No. 118173
in the offices of the Clerk and Recorder of Pitkin County, said drive more commonly lmown as
Matchless Drive in the City of Aspen, said parcel being more particularly described as follows:
Beginning at the westeri}Fmost comer of Lot 3 of said Alpine Acres Subdivision, a No. 5 Reba"
found in place; thence S. 48 °50'17" E., along the southwesterly Line of Lot 3 a distance of 63.02
feet; thence S. 65 °55'41" W. a distance of 56.07 feet to the northeasterly line of Lot 1 of said Alpine
Acres Subdivision; thence N. 48 °50'17" W. a distance of 123,75 feet to a No. 5 Rebar, thence
S82 °59'52" E. a distance of 106.85 feet to the point of beginning, said parcel containing 5,603 square
feet, more or less.
m t.-., -..._ .- .,. -,re t,
RECEPTION#: 550853, 07/0",.008 at 02:10:07 PM, 5 OF 5,
Janice K. Vos Caudill, Pitkin County, CO
MD1, et aL v. Aspen, et al.
Pitkin CountyDistrict Court, Case No. 06 CV 165
Decree Quieting Tale in Plaintiffs
Page 5 of 5
EXHIBIT B
PROPERTY DESCRIPTION OF SOUTHERLY PARCEL
A parcel of being a portion of Silver King Drive, Block 1, Alpine Acres Subdivision, City of Aspen,
County of Pitkin, State of Colorado, as shown on the plat thereof recorded at Reception No. 118173
in the offices of the Clerk and Recorder of Pitkin County, said drive more commonly known as
Matchless Drive in the City of Aspen, said parcel being more particularly described as follows:
Beginning at the southwesterly line of Lot 3 of said Alpine Acres Subdivision, from which the
westerly-most comer of said Lot 3 bears N. 48 °50'17" W. a distance of 63.02 feet; thence S.
48 °50'17" E., along the southwesterly lines of Lot 3 and Lot 2 of said Alpine Acres Subdivision a
distance of 102.04 feet to the centerline of an existing drainage; thence S. 56°36'27" W. along said
drainage a distance of 22.65 feet; thence S. 53 °34'06" W. along said drainage a distance of 26.11 feet;
thence S. 17 °52'03" W. along said drainage a distance of 13.79 feet to the northeasterly line of Lot 1
of said Alpine Acres Subdivision; thence N. 48 °50'17" W. along said northeasterly line distance of
123.53 feet; thence N. 65 5541" E a distance of 66.07 feet to the point of beginning, said parcel
containing 6,548 square feet, more or less.
or%
B 1, ,44.7>/4) ,4cR £USbk)i&io.V
- 737 - 07t- a.
BK. PG.Z
7- 6 —4. '/
$ Y K} by drspe
�1 x y 6uyP j tr
t 4 4-A 0 2, QI X
Q
. „sue o
�' Z 1 4000. Cum 91> fr.
r
LESS Die;
r
• 2 4 " ,a - er�� rr� s 44 1 1 •414 ,[ S COND p. ..
�. ion wo /wn G x
v.
•
•
•
•
•
ffSe$c 3 5
w Ir i w re.
.. 6
BLOCK / - • ,w . .. • ;rPr i
Jehoh sae .4 the _._ ..__ . ALPINE A CRES-- SUBD /!r/S /ON - .
Sy, SL A. See/ 4 t' 4. . M .O a.mir A' NaM an IN . 4...ir/Q
RNM . a,.... ....Y... 0 .....r .. i.
saw. Jn
L,ca/L,Prate ... , rM r./.9. /. .. Me ...re sr r/.^4.' ^ ma ...nail asN !Se 7: lha ./r s defer Se
..'MOM 4. MLN "ace .A I #keirIM rw` .s _ •'e. nt/n /..r./r. e awe
ran ems' r`.a J� {-slew e a / w.. /N r ✓5' aearS nee /N/I✓ JN Woes aserSe Tao. a
w .. stoat we l l dLers s ✓ /o.✓/J tN.../ ....
rrirs ^r Ca.00APO /. - .... +. a 4a/re J•-
nowo<r. ./ /4K•^ ...014/I wcera Jwwraa ad r.. Nr .. yr
• we /noels s "res /. w srocc r an r c • w a..w..✓ on r/r arr..r/. .l T n w /.u.a.../
r✓e✓troe J Jrno.eoT avA// .U.r /M ~as. nee /a'a •/
1 ale/ et Sett /,.a' .Y. /..rn4 v Stela
al Cans* Ow ni as- 4. e/ At. ••77/ .r / are o .Y. diode ent
/Gale 4 at/nor /C4KS J✓/r/✓ia/a✓ .ea N I/ ha at rM
rod 44444 2,e2Ge
• Samna". snd.. ✓I es flea/. .w. nom :CO N /./ ✓✓ /Y. I -• /1.I.
Aft. Can./sedan ••4 047: #7<e74.7 y/ aJ/.O /r.L4..rr • W :
,rra00.044- l ,. m✓ v, du I.1 ...
haver y
rw. 4,,,b4 M1 +% Lr/n1 Cr/riss.N M /JJA
24... a 1../.......
4/ .4 / 4444/ M l/. /.1 w wr..v. ✓ r, aH.wm / • .•Y.••r • M 1 .... r. ......
4 o.rri sisases � r M .s
l
s ..
r s ear J 'S •d e / .. s44 /NN'r ....M'[ /i.t IN/nett W.
./ sear estate r IwYN/ . 1 S1///
'�}- Y.
44444 /44 M "/"Pf .a .w. Mbo, Awry cast. a .-s. /a .mist .w.�d.Y.r -�--T
f
�� ANi ta../.nn✓L' /Lr7r .
•
Pitkin County District Court
506 East Main Street
Aspen, CO 81611
Plaintiffs:
MDI ITC, a Colorado limited liability
company; and, VAN METER FAMILY
LIVING TRUST, a California Trust
v .
Defendant(s):
The CITY OF ASPEN; LUKE W. • COURT USE ONLY
ANTHONY or his heirs, successors, or assigns;
and all unknown persons who claim any Case Number: 06 CV 165
interest in the subject matter of this action
Attorney for City of Aspen:
John P. Worcester
130 S. Galena Street
) 2n Floor
Aspen, Colorado 81611
Tel: 970.920.5055
Fax: 970.920.5119
1peck ®braodt- 1aw.com
Atty. Reg. # 20610 Division:
DISCLAIMER UNDER RULE 105
COMES NOW, John Worcester, on behalf of defendant City of Aspen, disclaiming any and
all interest in the property at issue in this matter and thereby relieving the City of Aspen of any
liability for the costs of this action. C.R.C.P. 105(c).
Dated: IrmAixt 7y!, 2,601.;
By: `/ L _��•
Worcester, city attorney
�i{ ,
� ,, °..
No Qcwca-�
T i
VOA 1 ; 1 ? - OoS Zoaq• <j 4
..
Eile Edit Record Navigate Fgm Reports For➢ at lab tielb 0
i Q � 0x ►° ►# l t i iJ e: S' $ f S4 1 D W1 fl i Ids lump 1 :*10101
i''A tel ad a M .0 • I III ciil G Lb 0
vi
ifilelnlyalustion ICustaio Reads Ieuwa I Peet 1Parcels IFee Summery ISUbeermits IAttedments'Routing status IRoutng 4 1
Permit Type Laski JAspen Land Use Permit ♦ 10054.2009.ASLU
Address 1980 GIBSON AVE J Apt/Suite I
1
Cory (AS State ICO J Zip '81611 J
- Permit Information PEN
Master Permit I J Routing Queue aslu07 Applied 09/0312009 j
Project' J Status 'pending Approved 1 J
Description ( APPEAL OF LAND USE CODE INTERPRETATION Issued 1 ----- . _ j
Final I J
Submitted IDAVID MCCONAUGHV 925 1936 Clock (Running Days F Expires 108/29/2010 J
' Owner
Last Name IMDI, LLC J First Name I 980 GIBSON AVE
ASPEN CO 81611
Phone 1(970) 948-0007
r Owner Is Applicant? 1
— Applicant
Last Name 'GARFIELD & HECHT J First Name I 601 IT E H VMAN
UN
Phone 1(970) 925 -1936 Cust *125185 L d ASPEN CO 81611
I Lender - � I
Last Name I J First Name I
I Phon I
Permit lenders full address AspenGold(b) Record: 1 of 1
GUI illMOVIAil 4 - 7 3Sm
cv ko2AlpV 26335
N s---> •.\,:°\ ',
..„ g
d