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—Aspen Meadows - Collins appeal 1991
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THOINUS FT-T01%; SNUrH
ATTORNEY AT LAW
320 WEST MAIN STREET, SUITE 5
ASPEN, COLORADO 81611
June 24, 1991
Mayor and City Council
City of Aspen
130 So. Galena
Aspen, CO 81611
AREA CODE 303
TELEPHONE $25-5004
TELECOPIER 925.2442
Re: June 24, 19910 Agenda - Appeal of Code Interpretation
(action Item IX(d))
Dear Mayor and City Council Members:
On Thursday, June 20, 1991, Mr. Charles T. Collins received
the City Attorney's memorandum dated June 18, 1991, responding to
his appeal of the request for interpretations of Chapter 24, Land
Use Regulations.
Just today, Mr. Collins asked me to represent him in this
matter, which is now scheduled to be considered by you this
evening.
Inasmuch as neither Mr. Collins nor I have had an adequate
opportunity to review the City Attorney's position on the Code
interpretation appeal, we would request that this matter be tabled
for consideration at the August 8, 1991, City Council meeting.
Thank you for your consideration.
ver trul yours,.
Thomas Fenton Smith
TFS/dd
cc: Jed Caswall, Esq.
Charles T. Collins
Mayor.624
BEFORE THE CITY COUNCIL
FOR
THE CITY OF ASPEN, COLORADO
IN RE THE MATTER OF THE LAND USE CODE INTERPRETATION APPEAL OF
CHARLES COLLINS
THIS MATTER came before the City Council on July 8, 1991,
upon the appeal of Charles Collins pursuant to Section 24-11-101F
of the Municipal Code from a land use code interpretation made by
the Planning Director. Section 24-11-101F provides that any
person who has made a request to the Planning Director for a code
interpretation may appeal the interpretation to the City Council.
Thereafter, City Council shall hear the appeal and affirm or
modify the Planning Director's interpretation.
By letter dated July 8, 1991, and hand -delivered to the City
Council on that date, Mr. Collins, through his legal counsel,
withdrew his prior request to appear and be heard before the City
Council on this matter and asked that Council render its decision
based upon the documents in the record before it.
WHEREFORE, the City Council having reviewed the documents
placed before it concerning the Planning Director's code inter-
pretation as challenged by Mr. Collins and, specifically, Mr.
Collins' letter dated April 16, 1991, and the Planning Director's
written code interpretation in response thereto dated April 17,
1991, and being fully apprised of the circumstances and provi-
sions of the land use code relevant hereto:
CITY COUNCIL FINDS the Planning Director's interpretations
to be consistent with the intent and purposes of the land use
code and does hereby affirm the interpretations entered by the
Planning Director as illustrated in her written opinion dated
April 17, 1991, and the appeal therefrom by Charles Collins is
hereby denied and dismissed.
DONE this 8th day of July, 1991.
ASPEN CITY COUNCIL
By: (a
Mayor
ATTEST:
i
City Clerk
Mailed to: J
Thomas Fenton Smith, Esq.
City Clerk
{{I
THOMAS FENTON SMITH
ATTORNEY AT LAW
320 WEST MAIN STREET, SUITE 5
ASPEN, COLORADO 81611
July 8, 1991
HAND DELIVERY
Mayor John Bennett and City Council
City of Aspen
130 South Galena Street
Aspen, CO 81611
RE: Collins Land Use Code Interpretation Appeal
Dear Mayor and City Council:
AREA CODE 303
TELEPHONE 925-5004
TELECOPIER 925.2442
This letter is being written on behalf of Charles T. Collins
regarding his Land Use Code interpretation appeal, which is
scheduled to be heard before you on July 8, 1991.
Initially, we appreciate your willingness to provide us with
an opportunity for a hearing and for granting an extension of the
hearing date. However, we hereby withdraw our request for a
hearing before you, and ask that you rule on this matter as
submitted to you in writing, including the memorandum from Jed
Caswall dated June 18, 1991, the exhibits thereto, and this letter.
We ask that you consider the following additional information
regarding this appeal:
1. As Section 24-11-101(F) of the Land Use Code does not
specify a standard for review of the Planning Directors'
interpretation, we believe that you should consider the matter, de
novo, i.e., that you review the matter on its merits based upon the
information submitted to you and that the Planning Director's
interpretation should not be given any presumption of validity.
2. With respect to the interpretation of Article 9,
Nonconformities, Section 9-107(A), we request that you consider the
interpretation of this provision in its proper context. The Code
should be read as a whole when making interpretations of individual
provisions, so as to avoid inconsistencies. Accordingly, we
request that you consider the requirements of Section 3-101, which
provides that the conveyance of an easement or right of way divides
a property into two or more separate interests for street use and
constitutes a subdivision, which subdivision approval cannot be
granted for a nonconforming lot.
3. In addition, Section 7-1004 (A) (3) , precludes the
conveyance of an easement or right of way which extends the
existing nonconformity of a nonconforming lot. That occurs where
the lot area of a property for density or FAR purposes is reduced
Mayor John Bennett and City Council
July 8, 1991
Page 2
by the conveyance of an easement or right of way. Accordingly,
Article 9, Section 107(A) should not be interpreted to require in
all cases the creation of an entirely new nonconforming lot. The
interpretation should be that a "new nonconforming lot" exists
where the nonconformity of an existing lot is increased by the
transfer, conveyance, sale or subdivision.
Finally, I am informed by Amy Margerum that your crowded
agenda for tonight's meeting may preclude consideration of this
issue until July 22, 1991. We have no objection to the two -week
delay, but we would request that there be no further delay in
disposition of this appeal beyond July 22.
Thank you for your consideration.
Very truly yours,
gym_
Thomas Fenton Smith
TFS/kl
cc: Charles T. Collins
CITY➢ SPEN
110 South Galena eet
jr
en,Colorado 81 1
300-5055 C' t:` ney
303-920-519 x
MEMORANDUM
DATE: July 3, 1991
TO: Mayor and City Council
FROM: Jed Caswall, City Attorney'�(�
RE: Charles Collins Land Use Code Interpretation Appeal
The above -noted action item was tabled at your last meeting and
continued to July 8th at the request of Mr. Collins so as to
allow his legal counsel adequate time to prepare (see attach-
ment). My previous memo to you adequately explains the issues
involved in this matter (see attachment).
EMC/mc
Attachments
jc73.3
cc: Thomas Fenton Smith, Esq.
ell) recycled paper
THOMAS FENTON SMITH
ATTORNEY AT LAW
320 WEST MAIN STREET, SUITE 5
ASPEN, COLORADO 81611
June 26, 1991
Mayor and City Council
City of Aspen
130 So. Galena
Aspen, CO 81611
Re: Collins Appeal of Code Interpretation
Dear Mayor and City Council Members:
AREA CODE 303
TELEPHONE 925-5004
TELECOPIER 925-2442
Enclosed is my letter dated June 24, 1991, which was faxed to
Jed Caswall on the afternoon of your June 24 meeting.
Jed correctly pointed out that I erroneously requested tabling
for consideration of the August 8, 1991, meeting. The date has
been correctly noted as July 8, 1991, and we should be present to
address the issue at that time.
Thank you for your consideration.
Very truly ours,
Thomas Fenton Smith
TFS/dd
cc: Jed Caswall, Esq.
Charles T. Collins
Mayor.626
,
�r
CITY OFkA,SPEN
130 South Galena Street
Aspen, Colorado 81611
303-920-5055 City Attorney
303-920-5197 Fax
MEMORANDUM
DATE: June 18, 1991
TO: Mayor and City Council
FROM: Jed Caswall, City Attorney
RE: Land Use Code Interpretation Appeal
This matter is on your agenda at the request of Charles T.
Collins pursuant to Section 24-11-101F of the Municipal Code,
which allows a person to pursue an appeal to City Council of a
land use code interpretation as entered by the Planning Director.
PROCEDURAL FRAMEWORK
Section 24-11-101A of the Municipal Code vests the Planning
Director with authority to make all interpretations of the land
use code. A code interpretation may be sought by any interested
person. Upon receipt of a proper request for an interpretation,
the Planning Director shall have fifteen days to render a written
opinion. Section 24-11-101F provides that any person who has
made a request for an interpretation may appeal the interpreta-
tion as made by the Planning Director to the City Council by
filing a petition within thirty days of the Planning Director's
decision. The appeal shall be considered by City Council within
thirty days of its filing. No standard for review is set forth
in the code, hence, I would advise that you apply an "arbitrary
and/or capricious" standard, i.e., the Planning Director's
interpretation shall be affirmed unless there is no competent
evidence supporting the interpretation and the interpretation is
unjust and not in accordance with the code.
On January 28, 1991, Mr
the Planning Director f
formities", and Article
use code. (See Exhibit
written interpretation
February 8, 1991. (See
Mr. Collins followed up
THE COLLINS APPEAL
. Collins submitted a written request to
or an interpretation of Article 9 "Noncon-
7, Division 10 "Subdivision", of the land
1.) The Planning Director rendered a
addressing Mr. Collins' concerns on
Exhibit 2.) On or about March 21, 1991,
on the Planning Director's interpretation
recycledpaper
Memorandum to Mayor and City Council
June 18, 1991
Page 2
of February 8th with aYotner letter seeking additional clarifica-
tion. (See Exhibit 3.) A meeting involving the Planning Direc-
tor, the City Engineer, the City Attorney and Mr. Collins result-
ed at which Mr. Collins' questions were discussed in detail. On
April 16, 1991, Mr. Collins submitted another request for a code
interpretation. (See Exhibit 4.) The Planning Director respond-
ed on April 17th with a written opinion. (See Exhibit 5.) It is
this April 17th written interpretation that Mr. Collins is now
appealing to City Council. (See Exhibit 6.)1
REQUESTED ACTION
Council is to determine whether the Planning Director's code
interpretations as set forth in her April 17, 1991, letter are to
be affirmed or modified. While the code provisions delineating
the appeal process do not call for a hearing, it is my advice to
Council that it afford Mr. Collins the opportunity to argue his
case verbally before you if he so desires, affording the Planning
Director an opportunity to respond as she deems appropriate. Mr.
Collins would then be allowed a final closing statement or
argument. You may then render your decision at the conclusion of
the presentation or take the matter under advisement for further
deliberation. I will be happy to prepare a written document
reflecting your decision should you so direct.
EMC/mc
Attachments
jc618.1
cc: Planning Director
Charles T. Collins
1Mr. Collins' appp.q! is dated May 17, 1991, and while Mr.
Collins states he hand -•delivered the appeal on that date to the
City Manager's office with a copy to the Planning Department, no
record of such delivery has been found. It was not until June
10, 1991, that the staff first became formally aware of Mr.
Collins' appeal when he presented a copy of same directly to City
Council at the conclusion of the proceedings on the Aspen Meadows
development approvals. Staff has no reason to doubt Mr. Collins'
assertion that he originally delivered the appeal to the City on
May 17th, it is just that no record can be found of same.
' '28 -
531 W. Gillespie
Asper., Colorado
January 25, 1991
Ms. Amy Maraerum
Planning Director
City of Aspen
]30 South Galena Street
Aspen, Colorado 81611
Re; Land Use Regulations
Municipal Code of the City of Aspen
Dear Amy:
I am writing to you to request interpretations of Chapter
24, Land Use Regulations, as provided in Article 11,
Article 9: NONCONFORMITIES
Does this article allow the transfer, conveyance or
subdivision of interest in a nonconforming lot that
would create a new nonconformina lot?
If such a transfer, conveyance or subdivision can be
considered, please cite the enabling section(s) and
authorizing procedure(s).
Article 7, Division 10: SUBDIVISION
Does this division allow exemptions -or exceptions from
the terms of this divisio:_ other than the exemptions
listed in Sec. 7-10-03?
If other exemptions or exceptions can be considered,
please cite what thev are and the enabling section(s)
and authorizing procedure(s).
Please let me know if you need additional information to
complete this request.
Thank you very much for your help.
Very truly,,,.)4ours ,
Charles T. Collins
Exhibit 1
Aspen/Pit ing Office
130 treet
Asp 611 FEB i991
(303) 9 920-5197
CITY A]TOr?i�i[Y,S
February 8, 1991 OFFICE
Charles T. Collins
531 W. Gillespie
Aspen, Colorado
Dear Charles:
This is in response to your letter dated
received in this office on January-28th.
January 25, 1991 and
You requested an interpretation of Chapter 24 Land Use .
Regulations as provided in Article 11 (Interpretations of the
Land Use Code). My responses to your questions follow.
Article 9: Nonconformities:
Nonconforming lots may be transferred or conveyed but may not be
subdivided if the nonconformity is increased. -.It is the intent
of the article to permit nonconforming uses to continue to exist,.
but not to allow nonconformities to be enlarged or expanded. If
subdivision resulted in creation of a new nonconforming lot, it
would not be allowed.
If it is an existing non -conforming lot of record, a single
family dwelling may be developed on such lot if the lot is. in
separate ownership and not contiguous to lots* in the same
ownership. All dimensional requirements of the zone district
must be met or a variance must be obtained from the dimensional
requirements pursuant to Article 10.
Section 9-107 (A) states that:'.
No lot or interest therein shall be transferred, conveyed,
sold or subdivided so as to create a new nonconforming lot,
to avoid, circumvent or subvert any provision of this
chapter, or to leave remaining any lot in violation of the
dimensional requirements of this chapter.
Article 7, Division 10: Subdivision:
The exemptions from the full subdivision review are outlined in
Section 7-1003 (Exemptions). These are the only exemptions the
code allows to be considered. There may be specific or unusual
recycled paper Exhibit 2
circumstances associated with your case which I am unable to
answer fully without more.complete information.
Without specifics as to why you are requesting a code
interpretation, it is impossible to give you a complete answer
and may lead to mis-interpretation on your part.' I encourage you
to be more specific with respect to the exact case or property
you are' referring to so I can respond to the specifics of your
case. If you are referring to the Meadows proposal, the
specifics of the SPA overlay and the Master Plan may impact such
-an interpretation.
I hope the. above information is useful. Please contact me if ypu
have any additional questions.
Si7yv/�:
ely,
mArgerum
Planni Director
cc: Jed Caswall
Kim Johnson
531 West Gillespie Aspen, Colorado
March 21, 1991
Ms. Amy L. Margerum
Planning Director
City of Aspen HAND DELIVERED
130 South Galena Street
Aspen, Colorado 81611
Re: Land Use Regulations
Aspen Meadows SPA Submittal
Dear Amy:
Thank you for your letter dated February 8, 1991 in response
to my earlier request for certain interpretations of Chapter 24.
Specifically, my request is directed to several items in the
Aspen Meadows proposal which appear to be in conflict with the
conditions set forth in Chapter 24.
Article 9: NONCONFORMITIES
The proposed new access road from 7th Street and the
access to existing residences are shown cutting across
Lots D, E, F, G, H and I, Block 7 of the original Aspen
Townsite. This is presently a nonconforming lot of 6755
square feet in the R-15 zone. A reduction in its size
would create a new nonconforming lot which is clearly
prohibited. Please confirm that a variance request
following the standards applicable under Article 10 is
the one way to create such a new nonconforming lot.
_Article 7� Division 10: SUBDIVISION
The proposed new access road from 7th Street and
related improvements do not appear to conform 'to a
number of the design standards required for subdiv-
isions in Sec. 7-1004(C)(4)(a), including but not
limited to paragraphs (1), (2), (3), (6), (9), (10),
(12), (13) and (14). Because these standards relate
directly to road safety and public health, I request an
an interpretation as to their immutability to exemp-
tions or exceptions from the subdivision regulations.
I hope this additional information will help you to answer
these questions on code interpretation.
Thant, you for your continued assistance.
Very truly yours,
w
,riU✓
Charles T. Collins
I �
Exhibit 3
531 West Gillespie Street
Aspen, Colorado
April 16, 1991
Ms. Amy Margerum
Planning Director
City of Aspen
130 South Galena Street
Aspen, Colorado 81611
Re: Aspen Meadows
Final SPA Development Plan
Dear Amy:
This is a request for an additional interpretation of
Chapter 24, Land Use Regulations, as provided for in Article 11
of the code. These items were brought forth only recently after
the Final SPA Development Plan had been submitted by the
applicant.
Article9: NONCONFORMITIES (Marqusee)
Clarification regarding the conveyance of a property right
and construction thereon leaving a nonconforming lot in
violation of the dimensional requirements of the code.
Article 7: SUBDIVISION
The code requires R.O.W. dedication for all streets.
Clarification is requested for the authority or source which
permits retaining the new road in private ownership with a
public access easement, as this is not an existing road nor
one planned for the future.
A_rt_icle_7: SUBDIVISION
An interpretation is asked for 'local' vs. 'collector'
streets and the qualified party who will evaluate road
safety and public health concerns when proposed street
designs do not meet the city's design standards. In the West
End, streets running north and south to Main and Hallam
Streets would generally be considered 'collector' streets
feeding into an arterial route, that is, Highway 82.
Thanks for your assistance. Please call me at 925-2089 if
you have questions.
Sincerely
i
Charles T. Collins
Exhibit 4
n lr
si
A.s en/Pik °P4"Anning Office
April 17, 1991 130 ®uth' Galena street
Charles T. Collins A Pori. C'616rad ,8A611
531 West Gillespie (J03) 920-5090 ;,Fax :(303) 920-5197
Aspen, Colorado
Dear Chic:
I am writing in response to your letter dated April 16, 1991
regarding a request for interpretation of the Land Use Code.
First, I want to thank you for your input and interest throughout the
Meadows review process. We have ensured that all valid concerns
raised by you throughout the process are followed through via the
conditions of approval we proposed.
You asked about Article 9 as it relates to nonconforming lots and in
particular the Marquese lot. Section 9-107A of the Land Use Code
states that "no lot or interest therein shall be transferred,
conveyed, sold or subdivided so as to create a new nonconforming lot,
to avoid, circumvent or subvert any provision of this chapter." The
fact that a public road easement will be crossing the Marquese lot
does not "create a new nonconforming lot." The City Attorney agrees
with this interpretation.
Article 7 dealing with Subdivision does require Right of Way
dedication for all streets. The approval is conditioned upon ROW to
be dedicated upon review by the City Engineer and will comply with
this section of the code. The new road will be a public road, not a
private road as your letter states.
The City Engineer will evaluate road safety concerns. The
determination of whether a road is a "local" or a "collector" is made
by the City Engineer based on traffic counts and the number of other
roads feeding into a road. There is no requirement in the code for
making this determination. In addition, the code amendment allowing
for an SPA proposal to vary from Subdivision requirements will allow
this and other SPA projects to vary from the requirements laid out in
the Land Use Code for things such as right-of-way width and maximum
percent grade.
Please feel free to contact me if you have any additional questions
or require clarification on the above items.
nqe �tc�
my Merum
Planningrector
cc: Jed Caswall, City Attorney
Chuck Roth, City Engineer
Kim Johnson, Planner
161)
a recycled paper
Exhibit 5
COPV
531 West Gillespie Street
Aspen, Colorado
May 17, 1991
Honorable Members of the Aspen City Council
130 South Galena Street
Aspen, Colorado 31611
HAND DELIVERED
Re: Land Use Regulations
Aspen Meadows SPA Submittal
Dear Council Members:
Pursuant to the standards and procedures set forth in
Article 11 of Chapter 24, I wish to file this petition to appeal
the decision of the planning director with regard to my requests
for interpretation of Article 9 (Non Confozmities) and Article 7
;Develcp^ert Review Standards) of the code.
Background information fs presented in the attached copies
of our correspondence dated March 21, April 16 and April 17,
1991.
Please advise when a hearing date is set and whether
additional information will help in considering this petition.
:hank you.
Sincerely,
Charles T. Collins
CC: Amy Margerum, Planning Director
Exhibit 6