Loading...
HomeMy WebLinkAboutminutes.boa.19911122 CITY OF ASPEN BOARD OF ADJUSTMENT NOVEMBER 22, 1991 CITY COUNCIL CHAMBERS 4:30 PM. A G E N D A I. CASE #91-8 L'OPERA APPEAL RECORD OF PROCEEDINGS BOARD OF ADJUSTMENT NOVEMBER 22, 1991 Meeting was called to order by Chairman Remo Lavagnino at 4 : 30pm. Answering roll call were Remo Lavagnino, Rick Head Josephine Mann, Charlie Paterson, and Bill Martin. Anne Austin and Ron Erickson were excused. L'OPERA APPEAL CASE #91-8 Jed Caswall, City Attorney: Basically as I understand the appeal the applicant is not asking for an interpretation of any provision of the code. What they are asking and what they wish to challenge is an application of specific provisions of the code made by the Zoning Enforcement Officer through the particular facts surrounding his client's desire to put a restaurant in the Wheeler Square Bldg. What you are being asked to do is to apply staff's interpretation of the code to the facts as will be presented before you. Based upon my understanding of the facts as set forth in the appellant's appeal that this Board has the authority to effectively make a judgement as to whether or not the Zoning Enforcement Officer is correctly applying the code to the facts of this case. Bill Drueding, Zoning Officer: When the building permit application came in from the appellant it indicated it was going to be a restaurant. That indication was determined by the seating plans, warming facilities, cooking facilities. I told the applicant that this was not permitted because of the definition of the code that says you must have alley access. And I determined they did not have alley access. They went to the Planning Director to see whether my determination was correct. The Planning Director wrote a letter and she upheld my determination that direct alley access was not correct and therefore could not be permitted. Remo: Could you tell us what you mean by direct alley access? Drueding: That this the interpretation of mine. Diane Moore, Planning Dept: The definition of restaurant is "A restaurant shall be required to have service delivery access from an alley or other off-street service in the delivery area. The restaurant is located on (she read very fast here and I could not understand what she was saying) elevator for dumb waiters and service access" . As I had outlined for you in my memo--the reason this particular section was placed in the code was because there were obviously a BAM11.22 . 91 lot of concerns within the City of delivery trucks and service trucks impeding the movement of traffic and creating unsafe conditions. So this particular section was placed in the definition of the restaurant. It was specifically for that and that is why they have addressed it and requires that alley or other off street service areas be required in terms of service delivery for restaurants. Part of the philosophy behind that was that restaurant establish- ments have increased deliveries and they felt that this was very important. CCLC and the City are trying to address this issue. When I did this interpretation after looking at the plans and doing on-site inspection and visit they don't have the kind of access that was contemplated by this particular section in the definition. They don't even actually if you look at the alley which is right behind the Wheeler Square Bldg it is not even designated for service deliveries now. And even if that were you wouldn't go through a corridor which is down past several offices through courtyard open space and then make a delivery into this restaurant. And it is based on the way we have reviewed other applications. Remo: Are you telling me that if the alley were open to traffic then direct access-- Diane: No. Remo: So then you still haven't answered my question. What is direct access? Drueding: The definition does not state "direct access" . Remo: But you used that word. Drueding: I tried to back off from that word. I didn't mean to use it. Remo: I think in the kinds of buildings restaurants that are around in the same vicinity and zone, none of them meet that requirement. That one across the street doesn't have any access. The Grille does not have any access to an alley according to your definition. So that part of our guidelines or a subsection to our guidelines is that if someone else is enjoying a property right in the same vicinity and zone and is denied the subject property then that is a hardship. So that is considered a hardship under our guidelines. . Rick: We are not being asked to determine a hardship or practical difficulty. 2 BAM11.22 .91 David Myler, representative for Wheeler Square Assoc: Gerard Philippon who is proposing to open what Gerard will describe for you as a European style bakery where food will be prepared and served. And because food will be prepared and served it is a restaurant under the 1988 definition. There is really no dispute about that. This is a very serious problem from our perspective. This is the old Baskin Robbins space in the Wheeler Square Bldg. As we see it there are 2 principal issues that we are asking you to review. Those issues are first of all whether the proposed use that we have in mind is subject to the 1988 definition of a restaurant which requires service delivery -access from an alley or- other off-site service area. It is our position that we are not subject to that regulation--at least on a technical basis. And that we should be exempt from having to demonstrate compliance with that regulation. If we are subject to it the second question is--can we comply? There we think we can as well. The fact that we don't believe that the alley access requirement is applicable in this case doesn't mean that we aren't concerned about deliveries--that we aren't willing and indeed prepared to work with the City, to work with CCLC, to work with our neighbors to minimize the impacts of deliveries, to be a good neighbor, to be part of the solution rather than the problem. We have discussed some of those solutions with the staff concerning loading zones and deliveries and where we can park trucks off street, etc. We do wish to work within the spirit and the intent of that regulation and mitigate the delivery impacts. Background: The prior use of the property. In late 1986 Baskin Robbins began operation. In 1988 the code was amended to add the definition of a restaurant with the language that has been sited requiring delivery access. It also defined the restaurant as an eating and drinking establishment where food is prepared and served. Those are 4 very important concepts. And if under the 1988 amendment you met those 4 tests then you were required to have delivery access from off street. I am also assuming that you are familiar with the non-conforming use regulations in the codes. If the Baskin Robbins operation was a restaurant--an eating, drinking establishment that prepared and served food then the space would be grandfathered. The use of that space would be a non-conforming use and we would not be subject to the provisions of the 1988 amendment as long as the continued use of that space was not enlarged or expanded or abandoned for a period of 12 months. We meet all of those tests. Remo: Does that include a new ownership? A new activity as long as it is a restaurant. 3 BAM11.22 . 91 Myler: It is the use that is grandfathered. Not the particular tenant. The use existed prior to the 1988 regulation and therefore it is not subject to it. In discussing this with staff what it really boils down to is the term "prepared"--food preparation. It is staff's position that there was no food preparation taking place in the Baskin Robbins operation. Therefore it was not a restaurant. Therefore there was no non-conforming use. Gerard is the first restaurant to be in the space -scy they have -to comply with the 188 regulation. We disagree. There was preparation going on there. I have asked Barbara Umbreit of the Environmental Health Dept and Ken Shriver who operated the Baskin Robbins restaurant for 5 years to come here and share with you their thoughts regarding this rather esoteric but very important distinction and that is was food being prepared there. Because if it was, clearly Baskin Robbins was a restaurant and clearly they were grandfathered. The question I asked Barbara Umbreit and the answer that I got from her in evaluating this was that the fact that food was prepared and served on the premises. This is the primary if not the soul reason that a food service license was required. And a food service license was obtained in 1986 and was renewed every year up until 1991. Barbara Umbreit, Environmental Dept: I want to state that our definition of what was served at this establishment comes from the Colorado revised statutes and differs from Bill ' s interpretation of a restaurant per the City code. Our definition certainly required Baskin Robbins to have a food service license and we inspected them regularly. They did prepare food according to our definition. Even something as simple as a milk shake can be a public health concern. Myler: In my discussions with the Shrivers they were preparing cakes and ice cream cakes which took hours to prepare. Fruit was being prepared for use in various of the mixtures and sundaes that were prepared. Other condiments had to be prepared for toppings on food. And an interesting point that Barbara made, dairy products are probably one of the most dangerous food products that we have to deal with from a health standpoint. There is probably more risk of contamination there than anywhere else. So the simple fact that refrigeration was required and care was required to be taken in preparing this product for service to a customer I think is an element of preparation. I don't see any real basis for distinguishing between the preparation of food in the zoning and landuse context and the 4 BAM11.22 . 91 health context. To me preparation is preparation. And I don't think that I can read anything in the definition of a restaurant which simply says "Where food is prepared and served indoors" . That would lead to an inference that you can distinguish between different degrees of preparation. If you are preparing food you are a restaurant. It doesn't matter how much preparation is actually involved. The conclusion that we have come to I think is inescapable. Baskin Robbins was a restaurant and we should be exempt. Drueding: It is a criteria of a food license--does Clark's Market require a food license? Barbara: It has a food service license. Drueding: Does a bakery require one? Barbara: If they have perishable food, yes. Drueding: Does a catering license require one? Barbara: Yes. Drueding: They are all different areas of the code. You will see "Restaurant" in your packet and right below it says a bakery. The point is the zoning code differentiates a restaurant differently than the Health Dept. Remo: Could a bakery than serve other things other than a bakery? Could they serve coffee and maybe soup as part of their bakery operation? Drueding: Now we are getting into that gray area. We don't have a definition of a bakery. Remo: So then how can we-- Drueding: Because we--we don't know what a bakery is. Part of this reason--I know some history here. The bakery is--Little Cliff' s--that was a bakery. Let's go to Godiva. They served ice cream. But they were not considered a restaurant. Remo: What about Main Street Bakery? The Main Street Bakery serves lunches, dinners, soups. Drueding: That has been an area addressed by Planning & Zoning Commission about how far you could go with this preparation. We just can't make all the definitions that has the correct words. That' s why we have interpretation and history and common sense-- intent. Rick: What do you call Mezzaluna? Is that a bakery? It 's in the Mill Street Plaza that serves food outside. They have tables 5 BAM11.22 . 91 outside. It is a bakery but they are serving lunch and sandwiches and food. They don't have alley access. They don't have an elevator. They have been there one year. They just opened 6 months ago. Now how did they get away with this? Drueding: They are not a restaurant. They are a bakery. Remo: Ah! But they are serving food. Drueding: I don't know that. And this is a full blown restaurant we have here. This is a matter of degree here. And I am saying this is a full blown restaurant vs this gray area of bakery. Myler: The question is not what we are doing because we can say that under the current definition we are a restaurant. It is what Baskin Robbins was doing. And really the only issue is preparation. Is preparation any different from a land use standpoint than it is from a health standpoint. Remo: So you are saying that once you establish that Baskin Robbins was a restaurant that you would have the same right to utilize that space as a restaurant just because it was already established as a restaurant. So they are not denying that they are a restaurant. Drueding: Correct. But Baskin Robbins was not a restaurant. I say it was not a restaurant. Rick: We have to determine whether it was a restaurant. Drueding: The reason for this code was the intensity and the amount of delivery per day. I feel as Zoning Officer that a restaurant requires much more service during the day and that is the impact associated. That is why we have differentiation between restaurant and bakery and catering service. That is what the code is trying to address--this impact. Remo: So if they could mitigate that and have the spirit of the intent of what the code wanted and they could convey that to you- -would that be all right? Drueding: No. That is why we have a Board of Adjustment. We are not prepared to the decisions of who has more impact and who has less impact. Remo: What we want from you is if you want to go along with the intent of the code, are you comfortable with that? 6 BAM11. 22 .91 Drueding: I am comfortable with the decision that Baskin Robbins was not a restaurant. This particular operation is a restaurant. Charlie: Why was Baskin Robbins named a restaurant on their license and at the same time they had to have a bathroom which is something you don't need if you just have an ice cream parlor? Drueding: That is the Health Dept rules. And this is pre 1988 with approval as restaurant. Rick: Bill, could you live with the applicant combining all of their deliveries with the other restaurant that is in the premise? Drueding: I can't make that decision. I am saying it is a restaurant so I have to stay by the code. Rick: They are talking about all deliveries being made before 6: OOAM in the morning. Diane: What Dave is proposing is a solution to-but and it is something like patrol days. There was a section in here that said "In the alternative dadadadadada within this definition of the code that provided that we consider it. It doesn't have that. And that is why today perhaps we should look at making an amendment to the code. My interpretation is I don't feel that gives us that ability to do that. Rick: Could we give the applicant some relief subject to the City amending or looking into amending that code? There were several "no" answers to this. Jed: That is not your function here. Charlie: But we can certainly make a determination on our findings that has nothing to do with changing the code. And that is probably better. Jed: We are all rather new at this type of procedure before the Board of Adjustment and I think it is important to focus in on what I believe the issue is basically a factual determination that you have to make. Was Baskin Robbins a restaurant? The appellant is not debating or disputing that he is a restaurant. If you make a determination that Baskin Robbins was in fact a restaurant, you need I don't believe go any further in any of these other issues. I think the staff has said that the definition of a restaurant under the health code in their mind is different than a definition of a restaurant under the Landuse Code. And you will have to decide whether you think that is correct and then use your best 7 BAM11. 22 . 91 judgement as to whether or not Baskin Robbins was a restaurant. They have said if Baskin Robbins was a restaurant his client's operation as a restaurant would be grandfathered from the prohibitions that the staff claims prohibits him from having a restaurant in that location. Myler: Mr. Chairman, Rick Head is right. If you determine that the other issues are mute. But I wish to assure you again that they aren't mute in our mind. That we are committed to working with the City-- Remo asked for public comment at this point. Connie Shriver: I have sales tax, tourism tax, dates declaring that we were a restaurant. We had the IRS declaring that we were a restaurant. Every Baskin Robbins in the country is classified as a restaurant. I don't know why this one would not be. Philippon: I am new in this area here. I moved in April. Prior to that I had 5 different businesses in Key West, Florida which is a very similar type resort. I am familiar with the historical district and all of that because of Key West. When I moved here after negotiating with Mr. Fleischer the first thing I did was go to City Hall and find out all the different rules of the City. At that time I met with the Health Dept. That was back in mid August. At that time I met with Mr. Drueding. I met also with the Historical lady. And I think I have done pretty much what was in my--I did my homework. I was told by everybody that it was an OK location. At this point I didn't have too elaborate a plan on the business. This is what I showed my landlord and this is what I showed Mr. Drueding on the concept of what I wanted to do which is a very European, French bakery, cafe. Mr. Drueding took a copy of this paper here and told me that that the zoning was fine for this type of operation. Based on this I went ahead and signed a lease and made large investments towards that project. I am new here in town but this is my new home town here. I brought my life savings with me. I am not an out-of-town investor here. This is something very serious for me. Remo: Unfortunately this Board can't right the wrongs of what City Hall does. They do it all the time. I think your recourse is to sue the City. Myler: We recognize that the preliminary meetings are infor- mational only. We are not here to criticize Bill or to point fingers or anything else. I think that there was probably a misunderstanding and we are not here to try to rely on anything. 8 BAM11. 22 .91 Remo: What we are dealing with is basically whether City of Aspen's definition of a restaurant is greater than the State definition. Jed: It definitely would be. You are bound by the City code. Myler: We don't disagree with that. The City has defined restaurant. It says "If you prepare and serve food, you are a restaurant" . Baskin Robbins prepared and served food. It was a restaurant. Drueding: I don't believe I misdirected Gerard one bit. And I just want to show you why. He did not talk about a restaurant. He talked about a French Bakery. This shows a bakery. I agree. That would be a bakery. That is what it looks like--a bakery. This shows 4 tables, ovens, pastry proofer, waitress station, customer seating--this is a whole different thing than this. And this I considered a bakery. I did not deceive him. A restaurant is different than a bakery. This was OK. And I still make that decision. It shows as a bakery and that would have been OK. Philippon: But a bakery as an ice cream place is a restaurant. An ice cream parlor is an ice cream parlor. A bakery is a bakery. Remo: Is there any definition in the code that speaks to an ice cream parlor? Drueding: No. Remo: Nothing specific as that. So if it is not covered under ice cream parlor, it is relegated to some other--But why would the City say it was a restaurant then? Why would the City put it under that designation? Drueding: This particular plan? Remo: Baskin Robbins. Drueding: I didn't. Remo: No. I mean why would the City-- Drueding: The Planning Dept, who is the City, did not call it a restaurant. The Health Dept--they used their terminology as the City. They called it a restaurant. Remo: So what did the City call it? Drueding: The Planning Dept of the City said it was not a restaurant. 9 BAM11.22 .91 Remo: What was it? What was it classified under? What use was it classified under? I mean it has to be put under something don't you think? Whether it is an office or--what is it? And you don't have a definition of an ice cream parlor. It has got to be put somewhere. It is an establishment. They do serve foods. Drueding: That distinction between restaurants and other food establishments was not established until 1988. Remo: In 1988 how would you classify Baskin Robbins? Drueding: Not a restaurant. Remo: What would you classify it as? Drueding: And there other pre-existing ice cream parlors in the City that we would go on. Remo: What are they classified as? Diane: How I would classify it as a retail commercial establishment such as bakeries and other types of uses. Remo: But it is not under that. Specifically it is not. Diane: It is a gray area. Remo then asked if there were any comments from the public. There were none and he closed the public portion of the meeting. Josephine: Here we are again with this kind of a problem. This gray area in the code that causes us all sorts of problems. So this time it is the use or the definition of the term "restaurant" and how we have used it. It is not really the definition. It is how we have used or misused that word. So to my way of thinking this is a gray area and that is what we must deal with as a Board. To my way of thinking that word "restaurant" applies more than just an establishment that serves food that requires a license from the Health Dept etc. It is also an establishment that has service deliveries. And so the code has made restrictions about that. Therefore in my way of thinking I would say that Baskin Robbins was not a restaurant but that doesn't mean to me that we as a Board should go on and worry about what is going to happen there because that would be an interpretation and we are not to do that today. We are not to interpret. Remo: Joe, all we need to know is was Baskin Robbins a restaurant and why you think it was or was not a restaurant. 10 BAM11.22 .91 Josephine: I think Basin Robbins was not a restaurant in the full use of the term. That is why this is such a gray area. A restaurant has--if we call Basin Robbins a restaurant that is the same as calling an ice cream parlor a restaurant. Remo: But you have to remember the definition that they placed on what a restaurant is, is preparation. Rick: Eating, drinking, preparation and serving. And they said that they prepared food. And of course we know people ate and drank and were served there. So why wouldn't it be considered a restaurant if they prepared food? Those are the 4 criteria to be a restaurant. Josephine: I think an ice cream parlor is different from a restaurant. They may do some preparing of food. But it is a limited amount. Rick: What is the distinction between the grades of preparation? Whether you are making ice cream sodas or rolls and dough. How can you use variations of preparation. It is either prepared or it isn't. And was ice cream prepared there? And cakes and fruit chopped up for the ice cream sodas and what have you? Clearly it was. So it should be considered a restaurant. Remo: That is their definition of a restaurant. Josephine: That is their definition. Remo: No. That is the City's definition. That is how it is written. Josephine: But I say that I think the definition includes more than that which is the servicing of the--the bringing in of food and trucks and deliveries and all of that sort of thing. Rick: Baskin Robbins had trucks bringing big tubes of ice cream. They had to get that stuff out of the truck and into the restaurant. Josephine: I don't know how they did it. Rick: They did it the same way they do it for the restaurant that is downstairs. Milan's used to be there and they had deliveries made. And the applicant has said that they agree to piggy back all the deliveries with that restaurant. They will be coming out of the same truck. They are making an attempt to accommodate the concerns that Bill has of obstruction to traffic and congestion. 11 BAM11.22 .91 Josephine: But I think we need to make the point that there is a gray area about this. Rick: I don't think there is. I think it is black and white. I think very clearly that Baskin Robbins under these guidelines is clearly a restaurant. And if that is the case then they have the right to grandfather that use right along. Charlie: I take a little different approach. Right in front of me I have a business sales tax license dated December 22, 1990 from the City of Aspen that says it is a restaurant. That is one thing besides the argument that is being made. That other consideration I have is that I can see a distinct-- there is a distinction between a place that has tables where you sit down and eat the food and a place where you just walk in and get your bakery goods or your ice cream and you walk right out and there is no place to sit. So if there was a sitting area where people were eating food and drinking some prepared type of food, I consider that more likely to be a restaurant. Another thing too that we haven't talked about is--things are different now than they were 10 or 20 years ago when some of these codes were written. The question is, is a book store a restaurant? People 20 years ago would have said "No. A book store is not a restaurant" . And yet here in Aspen we know a book store that is a very good restaurant. OK? So we have to modernize our thinking. I would consider Baskin Robbins a restaurant. Bill: I won't repeat Charlie' s and Rick's comments. I agree with both of them. I think Baskin Robbins was a restaurant. And just because ice cream--Baskin Robbins, if they had changed their product could have served sandwiches. They could have served cookies. They could have prepared food right on the spot. But they elected, in their restaurant to just serve ice cream. And prepare the condiments that go with serving ice cream which is preparation of food. Remo: It is difficult. I think the arguments that have been presented are valid. And since the City has established a slot for ice cream parlors and have historically relegated it to a restaurant in print. Whether it is for lack of not knowing where to put it or whether they thought about the ramifications of what relegating it to a restaurant might mean in the future, we don't know. I would go along with the arguments that were presented here and I would put it in the category of a restaurant and would make the determination that the application of the building enforcement officer was correct. 12 BAM11. 22 .91 Jed: I think the appropriate action would be to firm the application of the code in this case as made by the Zoning Enforcement Officer or to reverse the application of the Zoning Enforcement' s application of the code in this particular case based upon the facts as presented. Basically the issue was the Zoning Enforcement Officer did not apply the term "restaurant" to Baskin Robbins. That the Zoning Officer' s application of the term "restaurant" not applied to Baskin Robbins was incorrect and you are reversing -that determination. Remo then re-opened the hearing to the public for any further comments. Philippon: I just want to say that I will comply with--I want to be a good citizen and good neighbor. And being a bakery we--like me being French--a bakery cafe is different from a restaurant as your ice cream parlor is different from a restaurant. We won't have the delivery of meats and fish and things like that daily. I will probably be happy with 2 deliveries a week of flour and eggs and butter and other canned goods and some fresh fruits. Remo: Well, if we grant you this variance you can do what you want but we will watch you. MOTION Rick: I move to reverse the Zoning Officer's application of the term "restaurant" as expanded on by the City Attorney. Charlie seconded the motion. Roll call vote: Remo, yes, Rick, yes, Josephine, yes, Charlie, yes, Bill, yes. Rick moved to adjourn the meeting. Charlie seconded the motion with all in favor. Time was 5:20pm. Jan e M. Carney, ity eputy Cle 13 CITY , iney PEN 1 et 1 � 30 Z MEMORANDUM DATE: November 19, 1991 TO: _ Board of Adjustment _ FROM: Jed Caswall, City Attorney RE: L'Opera Appeal Gerard Philippon, as lessee of the premises at Space 301, Wheeler Square Building, 315 East Hyman Avenue, Aspen, Colorado, has submitted a written request to the Planning Director pursuant to Section 24-12-101 of the Municipal Code seeking an appeal from an administrative decision denying Mr. Philippon permission to utilize the subject premises for the operation of a restaurant. In that a question has arisen regarding the jurisdiction of the Board of Adjustment to hear Mr. Philippon's appeal, I am forward- ing you this opinion addressing the issue. Section 24-4-301 of the Municipal Code sets forth and defines the parameters of the Board of Adjustment's general jurisdiction: That provision states as follows: In addition to any authority granted the Board of Adjustment by state law and the Municipal Code of the City of Aspen, Colorado, the Board of Adjustment shall have the following powers and duties: A. To hear, review and approve variances to the terms of these regulations under Article 10; B. To hear and decide appeals from, and review any order, requirement, decision, or determination made by any administrative official charged with the enforcement of this Chapter under Article 12, except for appeals of interpretation of the text of this Chapter or the boundaries of the zone district map which shall be heard and decided by the city council. Article 12 "Appeals From Administrative Action", provides at Section 24-12-101 as follows: --rckd Pop- Memorandum to Board of Adjustment November 19, 1991 Page 2 Sec. 12-101. Appeals from the (sic) administrative action. A. Authority. The Board of Adjustment shall have the authority to hear and decide appeals from any decision or determination by any administrative official pursu- ant to the standards and procedures hereinafter set forth, except for interpretation to the text of this Chapter or the boundaries of the zone district map, which shall be decided pursuant to the terms of Article 11. B. Initiation. An appeal may be initiated by any person who received a decision or determination by any admin- istrative official with respect to this -Chapter, except an interpretation to the text of this Chapter or the boundaries of the zone district map. E. Action of the Board of Adjustment. The Board of Ad- justment shall consider the appeal within thirty (30) days following receipt of all records concerning the subject matter of the appeal. The Board of Adjustment may reverse, affirm, or modify the decision or deter- mination appealed from and, if the decision is modi- fied, shall be deemed to have all the powers of the officer from whom the appeal is taken, including the power to impose reasonable conditions to be complied with by the appellant. The decision shall be in writ- ing and shall be sent to the appellee (sic) by certi- fied mail. [Note: "appellee" should be "appellant" . ] Any notice of appeal must be filed with the Planning Director within ten (10) working days of the date of the decision being appealed. (See, Section 24-12-101(C) . ) As identified in the notice of appeal, Mr. Philippon wishes to appeal a zoning enforcement determination that Space 301 of the Wheeler Square Building may not be remodeled and utilized as a "restaurant" under the terms of the Municipal Code. The core issue before the Board of Adjustment is the application of the definition of the term "restaurant" as set forth in the Municipal Code to the facts pertinent to Mr. Philippon's request to use Space 301 as a restaurant. Memorandum to Board of Adjustment November 19, 1991 Page 3 As described above, the Board of Adjustment is without jurisdic- tion to make interpretations of the Municipal Code. Similarly, the Board of Adjustment is without jurisdiction to entertain appeals from administrative interpretations of the Code. On the other hand, the appeal being requested by Mr. Philippon in the case before you does not challenge an administrative interpreta- tion of any provision of the Code, but, rather, seeks a review of a zoning enforcement officer's application of the Code to a given set of facts as presented by Mr. Philippon. Based upon the nature of the appeal as defined by Mr. Philippon in his notice of appeal, and in consideration of the Municipal Code provisions noted above, it is my opinion as City Attorney that Article 12 of Chapter 24 of the Municipal Code authorizes and properly vests the Board of Adjustment with jurisdiction to hear and determine Mr. Philippon's appeal from the zoning en- forcement officer's administrative decision in the application of the term "restaurant" to Mr. Philippon's request to remodel and utilize Space 301 of the Wheeler Square Building as a restaurant. I will be available to the Board at the hearing scheduled to decide Mr. Philippon's appeal should you have any questions concerning the matters set froth above. EMC/mc jc1119.5 cc: Planning Director Zoning Enforcement City Manager Oity Clerk Dave Myler (for appellant) Aspen/Pi1t * ning Office 130 treet Asp 1611 (303) 9 920-5197 O ux TO: Board of Adjustment PROM: Diane Moore, City Planning Directo RE: L'Opera Appeal DATE: November 20, 1991 In accordance with Section 24-12-101 of the Municipal Code, I have Sttached for your review information and records concerning the L'Opera appeal. Mr. Philippon is seeking an appeal from an administrative decision denying Mr. Philippon permission to utilize Space 301 of the Wheeler Square Building for the operation of a restaurant. The attached information is in chronological order with the most recent correspondence placed first in your packet. I have identified the material by referring to it as exhibits and the following is included: Exhibit I - Letter from Dave Mylar (representing L'Opera) to Diane Moore and Bill Drueding, dated November 20, 1991. Exhibit II - Letter from Dave Mylar to Diane Moore, dated November 81 1991, Notice of Appeal for L'Opera. Exhibit III - Letter from Diane Moore to Dave Mylar, dated November 61 1991, Code Interpretation. Exhibit IV - Letter from Dave Mylar to Diane Moore, dated October 23, 1991, Delivery Access Requirements for Restaurants. Exhibit V - Section 24-3-101 -of Municipal Code, Definition of Restaurant. Exhibit VI - Section 24-5-209 of Municipal Code, Permitted Uses within the Commercial Core zone district. Exhibit VII - Aspen/Pitkin Regional Building Department Building Permit Application for Wheeler Square Associates. Exhibit VIII - City of .Aspen Plumbing Permit Application for won•► Fleisher i Co. I will be available to the Board at the hearing should you have any questions concerning the tatters set forth above. NOU 2 0 MYLER, STULLER & SCHWARTZ ATTORNEYS AT LAW - - DAVID J. MYLER 106 S. MILL STREET,SUITE 202 SANDRA M. STULLER ASPEN,COLORADO 81611 ALAN E. SCHWARTZ (303)920-1018 FAX 9204259 November 20, 1991 Bill Drueding and Diane Moore Aspen/Pitkin County Planning Department 130 South Galena Aspen, CO 81611 RE: L'Opera Dear Bill and Diane: Probably the most significant issue affecting your deter- mination that L'Opera must comply with the off-street access requirements is whether or not its predecessor, Baskin-Robbins, was a restaurant. If it was , then the proposed use of the space by Mr. Phillipon would not be subject to the 1988 access require- ments, since Baskin-Robbins commenced its operations in 1986 . I ask you to consider the following as new evidence in that inquiry: 1 . On each business license application and renewal for Baskin-Robbins from 1986 through 1991 (copies of 1986 and 1991 attached) , the City designated the nature of the business as either eating place or restaurant. 2 . A Food Service Establishment License was issued to Baskin-Robbins in each year from 1986 to 1991 (copy of 1991 renewal attached) . Food Service Licenses are only required of businesses that prepare and serve food. 3 . When the space in question was remodelled to accom- modate Baskin-Robbins in 1986 , a public bathroom was required to be installed solely because Baskin-Robbins was considered by the Building Department to be a restaurant with seating. I am advised by the Building Department that public bathrooms are not required of any retail establishments with the exception of restaurants. Thus, according to the standards and definitions by which the City regulates business , building and occupancy, and environmental health, Baskin-Robbins was considered to be a restaurant and was required to adhere to the operational, health, access and safety requirements of a restaurant. I fail to see how the City can now claim that the business was not a restaurant from a zoning standpoint. 4 . I have also reviewed the plans and the building permit issued for the Swiss Bakery located on the Mill Street Mall. This business is considered to be a restaurant by Environmental Health, the Water Department and the Building Department. It has MYLER, STULLER & SCHWARTZ Bill Drueding and Diane Moore November 20 , 1991 Page Two no direct access to an alley. Deliveries can and probably will be made from the alley to the south of the Ute Mountaineer across the mall. Ironically, the space was previously occupied by an ice cream parlor. The Swiss Bakery was not considered to be a restaurant by Bill , since most of the items to be served would be baked (prepared) elsewhere. We believe that this distinction between preparation and serving is insignificant in the circumstances, particularly with respect to deliveries. The fact that many items to be served are baked off premises does not mean that no food preparation will take place on premises. Sandwiches will be made , food items will be assembled, coffee will be brewed, salads and soups will be made, and many items will be warmed or melted for service . More importantly, since all baking will take place at another location, and given the necessity that baked goods be fresh, it would seem obvious that the Swiss Bakery will require at least daily deliveries of baked goods, perhaps even several times a day. Also, those deliveries will be made by using a vehicle which would not normally be in the area making deliveries , thereby adding to congestion. We believe that the better position is that the Swiss Bakery is a restaurant and it is either grandfathered on the basis of prior use of the space or complies with the off-street requirements since the delivery truck can park in the alley to the north. The fallacy of the distinction between a business which only prepares food and one that only serves it is further illustrated by the fact that Mr. Phillipon could avoid the delivery access requirement simply by physically dividing his space into a bakery and a retail outlet, with separate entrances and leases . Separately, neither space would be a restaurant according to Bill ' s approach and, thus , would not require alley access . My reason for providing you with this information now is in the hope that you might reconsider your position, approve the remodel plans , and thus avoid the necessity for an appeal. Please call if you have any questions . Very truly yours, MYLER, L R & S Z By: David J. b9fler DJM:caw Enclosures cc: Edward M. Caswall, Esq. 0 SOUTH GALENA ST. • ASPEN,COLORADO 81611 BUSINESS/SALES TAX LICENSE p1gaif review this form for accuracy and completeness: cared any errors or omissions and/or note any changes which have occvrred. PLEASE TYPE OR PRINT CLEARLY 1. NAME OF BUSINESS: B A S K I N S R O B B I N S 4 LOCATION ADDRESS: 2 CORPORATE NAME: ICE CREAM IN ASPEN 3. MAIUNG ADDRESS: 315 E H Y M A N, S T E 301 315 E H Y M A N #301 ASPEN.CO 81611 ASPEN, CO 81611 ) I PHONE NUMBER: 92S-8234 6. DATE BUSINESS BEGAN IN ASPEN: 4/01/81 7. ENTER BUSINESS TERMINATION DATE(IF KNOWN): 8. NATURE OF BUSINESS: 5 812 RESTAURANTS 9. TYPE OF BUSINESS: ® RETAIL Q SERVICE 0 WHOLESALE D OTHER 10. TYPE OF OWNERSHIP: ® INDIVIDUAL Q PARTNERSHIP Q CORPORATION 0 ASSOCIATION OR CLUB 0 OTHER 11 OWNERS,PARTNERS, AND/OR SOCIAL SECURITY 12 LOCAL PERSO)t)TO Ct.1t;IT, fQgT IN EMEICANCY: ='S OF BUSINESS: NUMBER: NAME B - _ __ ADDRESS) C 11 ENT CITY DENTiFICATION NUMBER: 2228 14. ENT STATE SALES TAX LICENSE NUMBER: 458069000 15, FREQUENCY OF FILING SALES/USE RETURNS: B MONTHLY Q QUARTERLY Q SEASONAL Q ANNUAL 16. 94M NQ OF BUSINESS OUTLETS OPERATING UNDER THIS APPLICATION: NOTE-A SEPARATE OCCUPATION TAX MUST BE PAID FOR EACH BUSINESS LOCATION. 17. ENTER AVERAGE NQ OF EMPLOYEES CompuTATON OF OCCUPATION TAX DUE TO THE CITY OF ASPEN FOR THE CALENDAR YEAR )APL 1 THRU DEC 31: OCCUPATION TAX DUE 0-9 EMPLOYEES................................................................... 150.00 10-49 EMPLOYEES .............$300.00 ................................................... 50 OR MORE EMPLOYEES........................................................$600-00 �v�G APP TION DUE DATE ! 1/01/91 �O APPLICANT'S SIGNATURE TITLE DATE :ASE RETURN THIS APPLICATION ALONG WITH YOUR REMITTANCE,PAYABLE TO THE CIT Y OF ASPEN. WA2 RIP APPLICATION FOR RENEWAL OF '� 130 GALENA sr. r ® . ASPEN,COLORADO 81611 BUSINESS/SALES TAX LICENSE Please review this form for accuracy and completeness; correct any errors or omissions and/or note any changes which have occurred. PLEASE TYPE OR PRINT CLEARLY 1. NAME OF BUSINESS: b A S K I N S R U B B I N S 4. LOCATION ADDRESS: -1 2. CORPORATE NAME: ICE CREAM IN ASPEN +� rm') 5. rt� 30 3. MAILING ADDRESS: A S P E f V s C 0 8161 1 £ CU `-- S. PHONE NUMBER: 925-8234 6. DATE BUSINESS BEGAN IN ASPEN: '11117'6 1 '�' 7. ENTER BUSINESS TERMINATION DATE (IF KNOWN): T 8. NATURE OF BUSINESS: 5812 EATING PACE/CATERERS 9. TYPE OF BUSINESS: ® RETAIL 0 SERVICE 0 WHOLESALE 0 OTHER 10. TYPE OF OWNERSHIP: INDIVIDUAL 0 PARTNERSHIP 0 CORPORATION 0 ASSOCIATION OR CLUB 0 OTHER 11. OWNERS, PARTNERS, AND/OR 12. LOCAL PERSON TO CONTACT IN EMERGENCY: OFFICERS OF BUSINESS_:_ NAME: A. PHONE: B. HOME C. ADDRESS: 13. CURRENT CITY IDENTIFICATION NUMBER: 222b 14. CURRENT STATE SALES TAX LICENSE NUMBER: 45P,069000 15. FREQUENCY OF FILING SALES/USE RETURNS: O< MONTHLY 0 QUARTERLY 0 SEASONAL 0 ANNUAL 16. ENTER NO. OF BUSINESS OUTLETS OPERATING UNDER THIS APPLICATION: NOTE-A SEPARATE OCCUPATION TAX MUST BE PAID FOR EACH BUSINESS LOCATION. 17. ENTER AVERAGE NO. OF EMPLOYEES COMPUTATION OF OCCUPATION TAX DUE TO THE CITY OF ASPEN FOR THE CALENDAR YEAR JAN. 1 THRU DEC. 31: OCCUPATION TAX DUE F 10 OR LESS EMPLOYEES. . . .. . . . . . .. . .. . .. ... .. ..... .. ... . . ..... $100.00 F 10 OR MORE,BUT LESS THAN 50 EMPLOYEES. . . . . . . .... ... . . .. .. .. . $200.00 l F 50 OR MORE EMPLOYEES. .. ... . ... .. ... . ... . . . . ..... . . .. .. ..... $400.00 �J APPLICATION DUE DATE 1/01/87 gaza . 6&4k( au9-n� APPLICANT'S SIGNATURE TITLE DATE I I ASE RETURN THIS APPLICATION ALONG WITH YOUR REMITTANCE. PAYABLE TO THE CITY OF ASPEN. U2 .T :7 s, Z 3S' 3. ti� .. .... .mow..... ... .. .. ,• a a a .� TAXPAYER NAME: S H R I V E R KEN DBA; B A S K I N R O B B I N S RENEWAL DUE APPLICATION DATE LIABILITY INFORMATION FOR LICENSE ACCOUNT NUMBER FOR THE YEAR U"IN W Idww" COUNTY CITY INDUST TYPE LIABILITY DATE MO CAY YEAR 04-66701 57 001 5812 S t110183 1991 01 02 91 LOCATION 315 E HYMAN AVE 301 RETURN THIS COPY ADDRESS ASPEN CO 81611 In consideration thereol,l do hereby certify that I have complied with all the items of sanitation as listed In the Colorado 7) 71-9 State Food Service Establishment Code,and that I have complied with all orders given me by authorized inspectors of the State Department otPubfic Health. I do h9rebYsgrOG thatin the event that the itemi of sanitation are notcompfied (8) FEE with, I will discontinue serving food until such time as requirements are met. Aulho pnatun =5/, , TW _ Da /� S 100.00 '179/ ' ®� MAIL ONE COPY O �16 APPLICATION WITH A CHECK OR MONEY ORDER PAYABLE TO: Nr ASPEN-PITKIN COUNTY Lo CP�' , v' ENVIRONMENTAL HEALTH 130 S. GALENA ASPEN, CO. 81611 101911291 046670100009717 MYLER, STULLER & SCHWARTZ ATTORNEYS AT LAW DAVID J.MYLER 106 S.MILL STRUT,SUITE 202 SANDRA M.SIULLER ��I_ ' Q ASPF ,COLOLADO 81611 ALAN E.SCHWART2 1 V OW)920-1018 FAX 920-CS9 November Or 1991 WV -8 y1 Diane Moore City Planning Director Aspen/Pitkin County Planning Office 130 South Galena Aspen, CO 81611 RE: Notice of Appeal - L'Opera Dear Diane: In accordance with the provisions of Article XII, Section 12 - JO1.C, of the City of Aspen Land Use Code, please accept this letter as a notice of appeal on behalf of Wheeler Square Associates, Inc. and Gerard Philippon, d/b/a L'Opera, from the determination by Bill Drueding, Zoning Enforcement Officer, that Space 301 of the Wheeler Square Building cannot be remodeled and occupied for the use intended by Mr. Philippon (Bakery/Cafe) as a result of the application of the definition of a restaurant as set forth in Section 3-101 of the Land Use Code. Wheeler Square Associates, Inc. , as the owner of the space in question, and Mr. Philippon, as the current tenant, respect- fully disagree with Mr. Drueding's determination, as well as the "Code interpretation" rendered on November 6, 199-4 which supports that determination. Wheeler Square Associates, Inc. and Mr. Philippon are not by this -letter seeking to appeal the November 6 Code interpretation, but rather, to appeal from the application of the definition in question to the facts of this case. Certainly, any application of a regulation may, and. often does, involve elements of Code interpretation. And, in this case, an interpretation of the intent of the service delivery requirement in the definition of a restaurant was relied upon to disqualify the off-street delivery access which does exist. Nevertheless, we believe that the issues for appeal are more a matter of the applicability of Code provisions, rather than interpretation of the text. It is for that reason that we have chosen to appeal pursuant to Article XII rather than Article XI. We are, in fact, appealing from the decision or determination by an administrative official rather than the interpretation of Code text by the Planning Director. i • MYLER, STULLER & SCHWARTZ Diane Moore November 8, 1991 Page Two On the basis of the foregoing, we request that our appeal be scheduled for a hearing before the Board of Adjustment at the earliest possible time. It is my understanding that the Board meets "on demand" and usually on Thursdays . We are prepared to meet with the Board on November 14th if that can be arranged. Time is of the essence, and I would greatly appreciate whatever effort can be made to expedite this appeal. If you have any questions or need any additional information, please do not hesitate to contact me immediately. Very truly yours, MYLER, STULLER & SCHWARTZ By: David J yler Attorneys for Wheeler Square Associates, Inc. and Gerard Philippon, d/b/a L'Opera DJM:caw cc: Edward M. Caswall, Esq. Bill Drueding Wheeler Square Associates, Inc. Gerard Philippon 4 Aspen/Pit ing Office 130 treet Ap 611 (303) 9 920-5197 November 6, 1991 Mr. Dave Myler Myler, Stuller & Schwartz 106 S. Mill Street Suite 202 Aspen, CO 81611 RE: -Delivery Access Requirements for Restaurants Dear Dave: I have attached a copy of the code interpretation of Section 3- 101 of the Aspen Municipal Code regarding your client, L'Opera. I would like to refer you to Chapter 24, Section 11-101 (F) of the Code which states that "any person who has made a request for interpretation may appeal the interpretation of the planning director to the city council by filing a petition within thirty/ (30) days of the planning director's decision". As we had discussed previously, if you appeal the decision to the city council by November 18, 1991 we could schedule the item for the November 25, 1991 Council meeting. If you have any questions, please give me a call. Sincerely, Diane Moore 1 City Planning Director CC: Bill Drueding Jed Caswall `bd mcyckd paper ASPEN/PITRIN COUNTY PLANNING AND ZONING OPPICE CODE INTERPRETATION JURISDICTION: City of Aspen APPLICABLE CODE SECTION(S) : Chapter 24,, . Section 3-101 of the Aspen Municipal Code, which refers to the definition subject section off the cc ode The particular definition interpretation is the definition for "restaurant". EFFECTIVE DATE: November 6, 1991. WRITTEN BY: Diane Moore, City Planning Director BACKGROUND: Gerard Philippon has entered into a lease of Space 301 of the Wheeler Square Building at 315 East Hymn Avenue. Mr. Philippon intends to operate a bakery/restaurant usiness with that space which as defined in Section 3-101 of the Land considered to be a restaurant Code. The definition of a restaurant is as follows: Restaurant means a commercial eating and drinking establishment where food is prepared and served indoors, for consumption on or off premises. A restaurant shall only be permitted to prepare or serve food outdoors, in required open space, when approved by the commission pursuant to Section 3- 101, Open Space. A restaurant shall be required to have service delivery access from an alley or other off-street service delivery area. if the restaurant is located off ground level, it shall have use of an elevator or dumbwaiter for service access. A grocery store or similar establishment which prepares and serves food but which principally sells packaged or nonperishable food and drink shall not be considered a restaurant. The City's Zoning Enforcement Officer, Bill Drueding, has not signed off on the building permit to remodel the space in question because there is no service delivery access from an alley or other off-street service delivery area as stated in the definition of a restuarant. Space 301 of the Wheeler Square Building (formerly Baskin-Robbins) does not have the required service delivery access from an alley or other off-street service delivery area. Space 301 could be accessed from the alley which is located immediately to the south of the Wheeler Square Building but currently this alley is not opened to allow delivery trucks to exit onto Monarch Street. If service deliveries were to utilize this alley, deliveries would have to go through the hallway separating several offices and then through the courtyard and up the stairs for the delivery. Hence, if this alley were opened to delivery trucks, this access would not meet the intent of the language contained within the restaurant definition as service deliveries would not have the required access to the restaurant. The definition of a restaurant was amended in April of 1988 to specifically include the sentence which states that " a restaurant shall be required to have service delivery access from an alley or other off-street service delivery areas. If the restaurant is located off ground level, it shall have use of an elevator or dumbwaiter for service access". The reason for the amendment of the definition was that service delivery trucks were impeding the movement of traffic and parking on city streets and potentially creating unsafe conditions. This has been the topic and concern of previous discussions by the Planning and Zoning Commission, CCLC and Council. INTERPRETATION: The Planning Director's interpretation and application of Section 3-101 of the Aspen Municipal Code to the case at hand is that Space 301 of the Wheeler Square Building cannot be used as a restaurant because there is no service delivery access from an alley or other off-street service delivery area. Since the restaurant definition has been revised, owners of proposed restaurants have been required to have access to an alley -for delivery of goods/services. Additionally, restaurants that are located off ground level have been required to install elevators or a dumbwaiter for service access. This code interpretation and application is consistent with the past zoning enforcement activities. code.int.wheeler. ,r"x V)11011 —IJ- MYLER, STULLER & SCHWARTZ ATTORNEYS AT LAW DAVID J. MYLER 106 S.MILL STREET, SUITE 202 SANDRA M. STULLER ASPEN,COLORADO 81611 ALAN E. SCHWARTZ (303)920-1018 FAX 920-1259 October 23, 1991 Aspen/Pitkin County Planning Director 2 3 ' c/o Diane Moore City of Aspen 130 South Galena Aspen, CO 81611 RE: Delivery Access Requirements for Restaurants Dear Diane: Gerard Philippon has entered into a lease of Space 301 of the Wheeler Square Building at 315 East Hyman Avenue. Mr. Philippon intends to operate a bakery business within that space which will be called L'Opera. The business is considered to be a restaurant as defined in Section 3-101 at page 1590 of the Land Use Code. As such, the following provision applies: A restaurant shall be required to have service delivery access from an alley or other off-street service delivery area. Mr. Drueding has taken the position that Space 301 cannot be used as a restaurant because there is no service delivery access from an alley or other off-street service delivery area. As a result, Mr. Philippon' s application for a building permit to remodel the space is stalled. We disagree with Mr. Drueding' s conclusion and, in addition, believe that there is precedent for allowing the use even if direct alley access is in question. Because the resolution of this issue may involve the interpretation of the definition of a restaurant, it was suggested by Mr. Drueding that I submit this letter on behalf of Mr. Philippon and Wheeler Square Associates, Inc. , the owner of the building, for your review under Article 11 of the Land Use Code. A. Space 301 Has Delivery Service Access From an Alley or Other Off-Street Service Delivery Area. As shown in the plans and maps submitted herewith, Space 301 can be accessed from the dedicated alley immediately to the south of the Wheeler Square Building. Delivery vehicles can and do park in the alley to the south of the Ute Mountaineer and, MYLER, STULLER & SCHWARTZ Aspen/Pitkin County Planning Director October 23, 1991 Page Two from that location, can make deliveries by crossing the mall to the open hallway leading through the Wheeler Square Building to Space 301 . The mall, the alley adjacent to Ute Mountaineer, and the alley behind the Wheeler Square Building are all "off-street" and thus there does exist an off-street delivery area which can be used to provide delivery service to Space 301. In fact, the "delivery area" adjacent to the Ute Mountaineer is now utilized on a regular basis for delivery to other merchants in the vicini- ty. B. Space 301 Has Been Used as a Restaurant Since 1986 . Prior to being leased to Mr. Philippon, the space was occupied by Baskin-Robbins. Baskin-Robbins was "a commercial eating and drinking establishment where food was prepared and served indoors, for consumption on and off premises" . Thus, Baskin-Robbins was a restaurant as that term is defined in Section 3-101 . Admittedly, the extent of food "preparation" was not as extensive as other restaurants. However, the finished product did require on-site preparation and did not consist of pre-packaged or non-perishable food items which are the charac- teristics of a food store exempt from the definition of a restaurant. It is our understanding that where a space has been utilized as a restaurant since before the adoption of the alley access requirement, that that requirement has not been enforced. In effect, the space is grandfathered. We believe that Space 301 is entitled to similar treatment, particularly where the delivery impacts will be minimal, as described below. C. Even if the Direct Alley Access is Not Utilized, the Incremental Impact of Service Deliveries to Space 301 Will Be Minimal. Virtually all products requiring delivery at L'Opera will be provided by Shamrock Foods and Nobel/Sysco. These vendors already make numerous and extensive deliveries to several food-oriented businesses in the vicinity of and within the Wheeler Square Building. Mr. Philippon estimates that he will require no more than one delivery per week from each supplier. Deliveries to L'Opera from the parking location customarily used by these suppliers will result in no more than 10-15 minutes per week of additional delivery time. Most importantly, deliveries will be made from a vehicle which will be parked in the vicinity in any event to serve existing businesses. MYLER, STULLER & SCHWARTZ Aspen/Pitkin County Planning Director October 23, 1991 Page Three Both Mr. Philippon and the landlord understand the need to minimize the use of streets for deliveries, particularly at those times of the day when such use interferes with parking and traffic movement. They will agree, as a condition of building permit and certificate of occupancy approval, to utilize their best efforts to require of purveyors that deliveries be made in the mornings, before 6 a.m. , and that, where vehicles are able to utili�:; the alley to the south of the Ute Mountaineer, that that serve as the staging location for deliveries to L'Opera. In conclusion, I believe that the facts and circumstances of this case warrant an interpretation of the service access re- quirements which will allow the continued use of Space 301 as a restaurant. . If you disagree, Mr. Philippon and Wheeler Square Associates expressly reserve the right to seek a review of the decision by the Zoning Enforcement Officer in applying the definition of a restaurant and the service access requirements set forth therein by the Board of Adjustment pursuant to Article 12 of the Land Use Code. If you have any questions or need additional information, please do not hesitate to contact me. Time is of the essence in this matter, and I would appreciate a response at your earliest opportunity. Very truly yours, MYLER, STUL & SC TZ By: David J. Xyler DJM:caw Enclosures ALL f 41 l V 6-A k-I ko Fl- to 4v • p'_o• D'-O' D�o" 3-.&1` 7-4" V--Of B',_' _A'-6!I' I�'� •i'b' :sl'�• ,d` a�Y � '•d .r,a• �irdi .re 510'; �'_a- _ •,=1d r6 4=8' and 4C — ---�. —�-�-r-- -- ;.' ►a.o. M:.-� N.O. T M-0 I I . �r�e of Mew tvlwawh� ?j i i S'+' Q �L*4g or' mospi GquMb or v44— ° c tJ�u� IQ b a OFFICE cR E�rnw avwJ�1DF�•C-V#LW9" ' tLt-�.-rw a ny+a suoFL.=c-�ask b } a/-.->O off.! 7U ._K C._..._--fJTa-.MrE o u y %. JWL. 0i✓6 GaWMN�sJ I (,&eg s�Ruc'tu►t++7 I ",y � TJ (..e �rlcucrua�v� ��� MiKf� ,.4�. •E�`T ar.,°•fro -Ar,G��oo¢.rw'b)a T m m o ® ® p a ! ® %V4 W.4 b.l \� �� ° I I 4'&W y Lr'11 �►s.Ir' �' 2�' O ;rug �° • so , �. ►t. ,/ntf« I}�+ EAJr 1Yvv `s 3 su+� u �s�w�, �6 g'L•F G` UP Ito — ,' � �~'• � ..gyp. ,Y •0' � _�,'0_ _4•C + ® _ I , 3 n ® p Am pool I scE 41rig 7 - t + V > - a 1 . t ( ..`° 1 iu rleal�rim ��E � i tom"d� i �� t.�bs(•i'1'!.'' t i 1 - 13S 6- _ - '. '•s'�f�r And � cFc:•.s � LINE.: pLo.J1H el�,cv` �( ' or � 1 4• 524" -- _... I -4. �''� G-O, b.p, a�_p. �_.p• _� end >� J' �'" - f — fir I'$' SW °' • t 10" / 4%4141 /r• •4•D' \ / 41-e 4'•9 rb b• 4' 1 M.o. M.O. �aa •e Q i FGIs:'1 1�N[ Cr m�cF rwo ME �1 -rQ1►y+ nRas� i � ' APr GoLUMNai� (4.EC IRi21IC'(lt�� � i � � (•it! v'TR11G"(Il • 0 tJo-t"t L vLwv IudW ; 'er_ _O a4" I O.44 W L 1 rQ•rH1z. Sri¢do AWMI _ I lie lO�• .e•—�i. �14.. �F"��" y}4�: y16 s' ti'i! 4'�. f '`O' K`9• r i 10'-G• I� -- r � ,F I:y�J.TOr�LV<•/✓ 6F�.•('101" ® ? ,_ O W-. 1 1 i p -- �eLLUr•w•x�,•.a•s�iC t 1 o � I � Va,0rlx �a6MUV � •r � -` e.1tt1Cz. (.y OL& Act('J �1•Y:.l,+l a 1�a- Vii, J t �!' - c t t a I ! I t.AJ IKiwfC� / O OFPWM7 AFL.�N1O'-0" I I t r t � 1 CO) � �t� 4..a.n +-1 ,.i. hie 4=e Led r 4•e r4 id 4'•a° d '�'°" — «e qap rn��J 4..e. a rd n e ,b� i .. r - i•io I -r10-� MA — {• �p- ��Il II'�fi111 19 ���� I ,ffl 1 Il� : �. G��Ea�'� 111111111 1111 �E�� ' - '����► ,�.. jj NIIII 1011111c 1111 X11 ppOp 11111`�l'!E P PARK Ar 0 III��111 {�!�ID . � Illl�mul Ilil " IIIl��. 1 Ilhn' � VIAGNER pARK IIP�1•:'!1 u.. �_., nil 11111 11 11� ■ .. d leee @ �el1 -maim �l�1 a mm o in m 3-101 ASPEN CODE exercise room,playground and playfield activity center or club house. A recreation club may include kitchen facilities,bathing and toilet facilities,locker facilities and halls for assembly. Remodeling means any act which changes one or more of the exterior architectural features of a structure,designated as a H,Historic Overlay District. Residential use means used or intended for use exclusively fqr dwelling purposes,but not including hotel or lodge rooms. Resident occupied unit means any dwelling unit which is limited, by deed restriction or other guarantee running with the land,to occupancy(but not to price or income limitations) by qualified employees in Pitkin County,meeting the guidelines or approval of the city coun- cil's housing designee. When considering granting approval to an individual not meeting the guidelines as a qualffied employee,the housing designee shall take into account the length of residence of the individual in the community and the place where he or she votes and pays personal income taxes. Restaurant means a commercial eating and drinking establishment where food is pre- pared and served indoors, for consumption on or off premises. A restaurant shall only be permitted to prepare or serve food outdoors, in required open space, when approved by the commission pursuant to Section 3-101, Open Space. A restaurant shall be required to have service delivery access from an alley or other off-street service delivery area.If the restaurant is located off ground level,it shall have use of an elevator or dumbwaiter for service access. A grocery store or similar establishment which prepares and serves food but which principally sells packaged or nonperishable food and drink shall not be considered a restaurant. Reversed corner lot means a corner lot which is bounded on three(3)sides by streets. Right-of-way means the land on which facilities such as roads,railroads,canals,utilities, and other similar uses exist or may be constructed. Roominghouse means the same as boardinghouse. Satellite dish antenna or satellite radio frequency signal reception and/or transmission device means a dish-shaped or parabolic-shaped reception or transmission device, whose antenna is more than two(2)feet in height and/or"dish"component is more than two(2)feet in diameter,which is used for the reception and/or transmission of satellite signals,including but not limited to television signals, AM radio signals, FM radio signals, telemetry signals, data communications signals or any other reception or transmission signals using free air space as a medium,whether for commercial or private use;provided; A. Area and bulk requirements. The installation of a satellite dish antenna shall not cause a violation of area and bulk requirements within the zone district in which it is located, unless a variance is granted by the board of adjustment. B. Right-of-way. A satellite dish antenna shall not be placed on an easement or in the city right-of-way,unless an encroachment permit is secured. C. Increased danger. The installation of a satellite dish antenna shall not cause any increased danger to neighboring property in the event of collapse or other failure of the antenna structure. Supp.No. 1 1590 5-209 ASPEN CODE S. Public building for administration; S. Restaurant,cabaret and night club,tea groom; 10. Retail commercial establishment limited to the following,and similar uses: Antique sto re, appliance store, art supply store, art gallery,bakery,bookstom, camera shop, candy,tobacco or cigarette store,clothes store,computer sales store,florist shop,food market, furniture store, gift shop, hardware store, hobby shop, jewelry shop, job printing shop,key shop, liquor store,music store,office supply store,pet shop,paint and wallpaper store,photography shop,record store,shoe store.,.sporting goods store, stationery store,variety store,video sales and rental store; 11. Service commercial establishments limited to the following and similar uses: Cater- ing service,financial institution,personal service including barber and beauty shop, custom sewing, dry cleaning pickup station, laundromat, ski repair and rental, shop-craft industry, tailoring and shoe repair shop, parking lot or parking garage, studio for instruction in the arts,radio or television broadcasting facility; 12. Rental,repair and wholesaling facilities in conjunction with any of the uses provided in Section 5-209.B.1-11,provided all such activity is clearly incidental and accessory to the permitted use and conducted within a building; 13. Storage of materials accessory to any of the uses provided in Section 5-209.B.1. through 1.2.,provided all such storage is located within s strwdure; 14. Residential dwelling units which are located above street level commercial uses in historic landmarks, provided that the residential dwelling unit is restricted to six- month minimum leases; 15. Accessory residential dwellings restricted to affordable housing guidelines; 16. Detached residential dwellings designated as historic landmarks; 17. Newspaper publishing office; 18. Home occupations;and 19. Accessory buildings and uses. C. Conditional cow& fke follteYing uses are permitted as conditional ufts in the Commer- cial Core(CC)zone district, subject to the standards and procedures established in Article 7, Dingion 3. 1. Recreational and entertainment establishments limited to the following and similar uses. Business,fraternal or social club or hall;ice or roller-skating rink; 2. Gasoline service station; 3. Hotel; 4. Newspaper and magazine printing; 5.- Day care center; Supp.No. 1 1638 x ti bI`� Y r� 130 S.Galena 13UILDING PERMIT APPLICATION General 008/1611 A :!V*PITKIN REGIONAL BLXLOING OEPiAR ENT Construction Permit PITKIN COUNTY 0 CITY OF ASPEN AWicard to complete numbered spaces or.:y. No. (� BLOCK LEGAL I LOT N0_-, O TRACT OR SUBDIVISION 1 SEE ATTACHED SHEET)2 DESC. ss � � ��•, 21P PHONE 1 0"AcTOR _F " nEC,T R MAILADORESS PHONE LICENSE NO. ENOINEER`� MNL ADDRESS UIDEPISE NO. 6. CLASS of WORK: 7 O NEW O ADDITION ALTERATION O REPAIR O MOVE O WRECK cNSUS CODE TOTAL FEE DMX n PLAN CHECK FEE PERMIT FEE !%USE TAX DER. 8. a ��_ VALUATION OF WORK �-� 10. Remarks �• $g11w�FL) No.of Swrms OOC.Load ' �ft� 11 n NO.OF BEDROOMS u"Tana Fin Spri d ors Regiwed: EXISTING ADDED \�" C ❑Vag D No jNo.of Dw"N units OFFSTREET PARKING SPACES: covww utloowrw aPECU►L APPROVALS REOIRREG AUTHORIZED NY DATE ZONING D L*m H.P.C. FUCture Count: fjt, r , PARK DEDICATION HEALTH DEPARTMENT FIREPLACE PPESUMMrTAI TACCC� er amr vnwDlOW FIRE MARSH AL -A SPRINKLER Jq fj O10E °m O1°E WATER TAPy G 7 3 o v G'ri; f �E OTHER AT P RMITS ARE RE FOR�ELE�CTR�ICAL,PL�BING, HEATIN ,VENTILATING OR AIR CONDITIOIlf�IG: SELECTION OF METHOD FOR PAYMENT OF USE TAX THIS PERMITBECOMES NUUJWD VOID IFWORK OR CONSTRUCTION O MONTHLY USE OF QUARTERLY RETURNS WILL BE SUBMITTED. AUTHORIZED IS NOT COMMENCED WITHIN 120/180 DAYS,OR IF CON- STRUCTION OR WORK IS SUSPENDED OR ABANDONED FOR A p DEPOSIT METHOD:3%OF 25%OF PERMIT VALUATION PAID NOW PERIOD OF 120/180 DAYS ATANYTIME AFTER WORK IS COMMENCED. AT ISSUANCE. FINAL REPORT ON TOTAL ACTUAL MATERIALS I HEREBY CERTIFY THAT 1 HAVE READ AND EXAMINED THIS APPLICATION AND COST MUST BE FILED WITHIN 60 DAYS AFTER COMPLETION OF KNOW THE SAME TO BE TRUE AND CORRECT.ALL PROVISIONS OF LAWS AND WORK. GENERAL CONTRACTORS CHOOSING THIS METHOD ORDINANCES GOVERN " 1N?E OF WORK WILL BE COMPLIED WITH RSPECIFIED EREIN T.THE GRANTING OF A PERMIT DOES NOT MUST REPORT AND REMIT TAX FOR ALL SUBCONTRACTORS GIVE A HORITY VIOLATE OR CANCEL THE PROVISIONS OF THAT DO NOT OBTAIN THEIR OWN PERMIT.ATE REGULATING CONSTRUCTION OR THE PER-U 1 Q EXEMPT: STATE 8 PITKIN COUNTY RESALE NO. EXEMPT ORGANIZATION THIS FORMA IS A PERMIT ONLY WHEN VALIDATED. WORK STARTED WITHOUT PERMIT WILL BE DOUBLE FEE Plan Check VWklation Pw *Valuation 7%Use Tax Deposh VNldation �r Al WHITE-FILE COPY GREEN-F*"NCE DEPT PINK-43UNDING DEPARTMENT YELLOW-ASSESSOR GOLD-CUSTOMER PLUMBING PERMIT APP ICATION ° PITKIN COUNTY O CITY OF ASPE 542. 4 i [IADO�:O. TRACT (OSEE ATTACHED SHEET) OWNER r I I � MAIL ADDRESS ZIP PHONE L ADDRESS PHONE LICENSE NO. DUd =4 OR N MAIL AO PHONE LICENSE NO. {I{ i ENGINEER MAIL ADDRESS PHONE LICENSE NO, LENDER MAIL ADDRESS BRANCH UK OF OU1LDING Class o6 work: O.NEW O ADDITION ALTERATION O REPAIR OsaCribB work f I — SPECIAL CONDITIONS: PERMIT FEES t8Y: Type of Fixture or Item Fe IZAAZ5 � Water Closet(Toilet) O , Bathtub Lavatory(Wash Basin) APPLICATION ACCEPTED BY: NS CHECKED Y: APPROVED FOR Shower / Kitchen Sink S Disp. Dishwasher 7 Laundry Tray OTICE Clothes washer ER IT BECOMES NULL AND VOID IF WORK OR CONSTRUCTION AUTHORIZED IS NOT COMMENCED WITHIN 120DAYS OR IFCONSTRUC- Water Heater M/BTU ea TON OR WORK IS SUSPENDED OR ABANDONED FOR A PERIOD OF 120 Urinal DAYS AT ANY TIME AFTER WORK IS COMMENCED. Drinking Fountain I tM ERE9YCERTIFYTHATI HAVE READ AND EXAMINED THIS APPLICATIONAND KNOW TNESAMETOBETRUE AND CORRECT.ALL PROVISIONS OFLAWSANDORDINANCES Floor Sink or Drain QMRtMQ THIS TYPE OF WORK WILL BE COMPLIED WITH WHETHER SPECIFIED "ERREIN OR NOT.THE GRANTING OF A PERMIT DOES NOT PRESUME TO ONE ,*Iep Sink AUT"Daw TO VIOLATE OR CANCEL THE PROVISIONS OF ANY OTHER STATE OR Gas Systems: Outlets LOCAL LAW REGULATING CONSTRUCTION OR THE PERFORMANCE OF CONSTRUCTION. Water Piping d Treating Equip. Waste Interceptor vacuum Breakers Fan Coil Units) lo OR AUTHORIZED AGENT (DATE) y TORE LA- OWNER(IF OWNER BUILDER) (DATq ;PERMIT> _ TOTAL FEE t WHEN PROPERLY VALIDATED(IN THIS SPACE)THIS IS YOUR PERMIT PLAN CHECK VALIDATION CK- M.O. CASH PERMIT VALIDATION CK "^ CASH COPIES:WHITE—INSPECTOR YELLOW—APPLICANT PINK—FILE Rev.7/8 3 4 6 8 "IT I *ail J t__ , - 4- ! i 7 14__._ 18 ' i i i i � ' fit+� '� ' �� � _ ..�_ I-I i i ! i _ �.=L��1 i - - '- � a �-•�_- r-- - - i- -r- .rL _ - TI Ain 13 8 9=door urdax-C,axt�eX 14 t6iAcr CPj: 5 2 muy}► �so . . _ ei'r_i9era�oY' it area .3. � •�fu �'., r � g ur.&r au,,�.r sard11 kh Ycf r. '15 ` Ad C�is&-I Cc se, 4 marble�o!p -fir refr i ac�r' _10 Cxe mach 16 Cdd d'►sy cam' - 5 17 Exiei b?c�fi m Brcad os,d�� mixer 91 Pass�oY wagons wf GD�t�er{ 18 CvOawr Se�fit� 12 CrtPe _ -}oP