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HomeMy WebLinkAboutcoa.lu.ca.Square Foot Limitation 534 E Hyman Ave.A15-91 ~. r'I .^ CASELOAD SUMMARY SHEET city of Aspen DATE RECEIVED: 37;l4~1 PARCEL ID AND CASE NO. DATE COMPLETE: 4 v~ I 2737-182-13-005 A15-91 LL Ir L I .L \ STAFF MEMBER: -"'=" 1-1- -~U.Me-~"TA(,.oE" vll^t!l;i(.:fto,^ PROJECT NAME: r lLldn . ____.. i1I.RJi Code Amendment Application Project Address: 534 East Hvman. Aspen. CO Legal Address: APPLICANT: Aspen Bank Shares. Ltd. Applicant Address: 534 East Hvman Ave..Aspen. CO REPRESENTATIVE: Vann Associates. Inc.. Sunnv Vann Representative Address/Phone: 230 East Hopkins Avenue Aspen. CO 81611 ;~iD~=~;;=~~;;;~==~~===;~~=~;=~~;~;;=;;~;~;;;===;=== . TYPE OF ApPLICATION: 1 STEP: .. . 2 STEP: K 0.Lz..- P&Z Meeting Date b I~~ CC Meeting Date G/;1G?B1v PUBLIC HEARING: VESTED RIGHTS: PUBLIC HEARING: ~ YES ~ OR..J). ~/n_ . 7A/)) f ~ NO ~;;, YES NO NO VESTED RIGHTS: Planning Director Approval: Insubstantial Amendment or Exemption: Paid: Date: --------------------------------------------------------------- --------------------------------------------------------------- RE5lRRALS: City Attorney Mtn Bell School District City Engineer Parks Dept. Rocky Mtn NatGas Housing Dir. Holy Cross State HwyDept(GW) Aspen Water Fire Marshall State HwyDept(GJ) City Electric Building Inspecto)( Envir.Hlth. Roaring Fork Other ~~NI~6- Aspen Con. S.D. Energy Center . DATE REFERRED: ;3 / d- 7 ! '1 / INITIALS:.j)-f- ================================d============1~r================ FINAL ROUTING: DATE ROUTED: II 6?jq r INITIAL:a?---- ___ City Atty~ City Engineer ___Zoning ___Env. ___ Housing ~other: FILE 'TATU' AND LOCATIO"' l~ C~ Health "../ .-"" .-, ORDINANCE NO. 22 (Series of 1991) .~. ORDINANCE OF THE ASPEN CITY COUNCIL AMENDING CHAPTER 24 SECTION 5..50.;\ OF THE MUNICIPAL CODE TO CHANGE THE TERM "GROSS FLOOR AREA" "!'f);'NET LEASABLE COMMERCIAL AND OFFICE SPACE" WHEREAS, the Pitkin County Bank has proposed to amend section 5,,504 of Chapter 24 to change the term "gross floor area" to "net leasable commercial and office space"; and WHEREAS, the term "gross floor area" is not defined within the Code and the term "net leasable commercial and office space" .is defined in the Code and is typically used for mitigation purposes; and WHEREAS, staff believes that when the zoning regulations were amended to include the term "net leasable" that the terminology was not reviewed for consistency with the rest of the Code and therefore "gross floor area" was not changed; and WHEREAS, pursuant to section 7-1103 review an amendment to the text of Chapter making a recommendation to council; and the commission shall 24 at a pUblic hearing WHEREAS, the Planning and Zoning commission reviewed the proposed amendment at their May 71 1991 meeting and recommends to Council approval of the amendment; and NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF ASPEN, COLORADO: section 1: section 5-504, "Use square footage limitations", of Division 5 "Supplementary Regulations", of Article 5 of Chapter 24 of the Municipal Code of the City of Aspen, Colorado, is hereby amended to read as follows: within section 24-5-404. Use Square Footage Limitations, the Commercial Core (CC), Commercial (C-1), and Service/Commercial/ Industrial (S/C/I) zone districts I all permitted and conditional commercial business shall be restricted to the following maximum net leasable commercial and. office space. A. 3.000 Sq. ft. The following and similar uses shall be limited to three thousand (3,000) square feet in net leasable commercial and office space: antique shop; art supply; bakery; bookstore; camera shop; candy, tobacco or cigarette shop; catalogue store; drug store; florist shop; gift shop; hobby shop; jewelry shop; key shop; liquor store; pet shop; photography shop; stationery store; dry cleaning; pickup station; barber and beauty shop; small J ~. .-, appliance store; art gallery; decorator shop; seamstress; laundromat; tailor; shoe repair shop; radio and TV broadcasting stations; rental, repair and wholesalingl provided they are accessory uses; electrical and plumbing service shops; automobile washing facility; pharmacies; art studio; and catering service. B. 6.000 sa.ft. The following and similar uses shall be limited to six thousand (6,000) square feet in net leasable commercial and office space: drugstore (including pharmacy); equipment rental, storage and repair; shop craft industry; fabrication and repair and building materials; sporting goods store; variety shop; professional offices; and major appliance stores. C. 9.000 sa. ft. The following and similar uses shall be limited to nine thousand (9,000) square feet in net leasable commercial and office space: service station and restaurant. D. 12.000 sq.ft. The following and similar uses shall be limited to twelve thousand (12,000) square feet in net leasable commercial and office space: vehicle sales; builder supply yard; lumber yard; dry cleaning plant and laundry; manufacture and repair of sporting goods; printing and publishing plant; furniture store; carpet and floor covering store; financial institutions; and food market. J E. 20.000 sa.ft. The following and similar uses shall be limited to twenty thousand (20,000) square feet in net leasable commercial and office space: warehousing and storage. F. Retail sales areas. All of the square footage limitations on use shall not restrict the square footage of the total retail sales areas in these Zone Districts, or any buildings occupied by any combination of more than one (1) of the. above uses; provided, however, that any business enumerated above I of the same type which occur individually or jointly in a single structure or combination of structures situated upon a single tract of land under the same ownership, shall be considered one (1) business and together restricted to the maximum net leasable commercial and office space provided in this section. section 2: -) That the city Clerk be and hereby is directed, upon the adoption of this ordinance, to record a copy of this ordinance in the office ./ ""') f........ \, .,.' . - '\ J . ;-,. 1""-.. of the Pitkin County Clerk and Recorder. section 3: If any section, subsection, sentence, clause, phrase or portion of this ordinance is for any reason held invalid or unconstitutional by any court of competent jurisdiction I such provision and such holding shall not affect the validity of the remaining portions thereof. section 4: This Ordinance shall not effect 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 I and the same shall be conducted and concluded under such prior ordinances. section 5: A public hearing on the Ordinance shall be held on the ~~day of ~ ' 1991 at 5:00 P.M. in the city council Chambers, Aspen ity Halll Aspen Colorado I fifteen (15) days prior to which a hearing of public notice of the same shall be published in a newspap~r of general circulation within the city of Aspen. INTRODUCED, READ AND t~ Council of the , 1991. ORDERED PUBLISHED as provided by law, by C'ty of Aspen ~the 10""-> dey. of ('3~'- John ennettl Mayor AT EST: Kathryn FINALLY ADOPTED this 22nd day of July 1991. /3~ John B 'nnett, Mayor ATTEST: Kathryn c , ,-." ,-, MEMORANDUM TO: Mayor and Council THRU: FROM: Carol O'Dowdl City Manager Amy Margerum, Planning Directo~ Leslie Lamont, Planner THRU: RE: Square Footage Limitation Code Amendment - section 5- 504, Second Reading Ordinance 22 DATE: July 22, 1991 ----------------------------------------------------------------- ----------------------------------------------------------------- SUMMARY: The applicant, Pitkin County Bank, seeks to amend Section 5-504 of the Aspen Land Use Code. The amendment would change the term "gross floor area" to "net leasable commercial and office space." This section of the COde restricts the size of individual commerical business only within the CC, C-1, and S/C/I zone districts. A text amendment is a two step review process requiring review by the Commission and Ordinance adoption procedures at Council. The Commission reviewed the amendment at their May 7 meeting and recommends approval of the text amendment for section 5-504. During first reading of Ordinance 22, the Council asked staff to more clearly illustrate the impact of the amendment. Staff has included a sketch defining gross floor area, net leasable and floor area. Staff has also sampled some buildings and estimated the affect the change in the language would have upon those particular buildings. COUNCIL GOALS: The proposed amendment is consistent with Goal #14: to develop a consistent and fair government so that citizens know what to expect... BACKGROUND: Pitkin County Bank received a 1990 commercialGMQS allocation for 2/240 square feet of net leasable square footage to enlarge the existing bank building. Commercial GMQS allotments are allocated on a net leasable sauare foot basis. Because net leasable does only refers to useable space the additional net leasable pushes the Bank over the allowable "gross floor area" for a financial institution. Pursuant to Section 5-504, financial institutions are limited to a maximum of 12/000 square feet of "gross floor area." The Zoning Department has interpreted "gross floor area," although not defined in the Land Use Code, to mean a building's gross square footage everything contained within the four walls above and below grade. 1"""\. .,-" Note: floor area, as defined in the code, generally does not include below grade space and net leasable is generally defined as all commercial or office space that is meant to be leased and occupied above or below grade space excluding bathrooms, stairs, corridors, mechanical and storage areas. Please see attached illustration. The effect of this language upon the applicant is to preclude the Pitkin County Bank and Trust Company the ability to occupy all of the additional square footage that they received with their 1990 GMQS allocation. The Bank could build the space but would have to lease it to another business (as the total exceeds, "gross floor area") and lease space elsewhere for their expanded needs. The proposed floor area is below the allowable floor area for the site in that CC zone district. Additionally, GMQS requires only competition for "net leasable" space. Supporting space (closets I storage etc.) may represent floor area but is not considered net leasable and does not require competition or mitigation. Please see attachment B for Pitkin County Bank calculations. PROBLEM DISCUSSION: A. Although the Planning Department has confirmed Zoning's interpretation regarding "gross floor area," staff does agree with the applicant that the language is problematic for the following reasons: 1) "Gross floor area" is not defined within the Code and is not typically used throughout the Code as a guideline for development. 2) "Floor area" is the term used within the Code to regulate the bulk and mass for a proposed development. 3) within the CCI C-l, and S/C/I zone districts maximum allowable floor area and other dimensional requirements are used to limit the bulk of commercial and office buildings. 4) "Net leasable" commercial and office space is the term used for growth impact mitigation for employee housing and parking impacts, which is a limitation to the size of a business. 5) The Land Use Code requires mitigation for the expansion of net leasable space within an existing building. For example, if an existing business seeks to convert basement storage area into net leasable space any expansion less than 500 square feet must be reviewed by the Planning and Zoning Commission and greater than 500 square feet must compete in Growth Management. 6) Staff has reviewed four buildings to help determine the affect this amendment would have on existing businesses. Staff will present those findings at the Council meeting. 2 /""', '-"', 7) Staff considers this request reasonable and appropriate lending better consistency to the Land Use Code. B. The applicant offers three other ideas regarding the continued use of the term "gross floor area" such as: 1) The limitation was designed to limit the size of businesses rather than a building's bulk. The community was probably concerned about the development of a large commercial structure such as a K-Mart. This would support the fact that a large building can contain numerous small commercial uses. 2) The applicant also believes that at the time this zoning regulation was promulgated that "gross floor area" really referred to "floor area." 3) Discussions with Alan Richman (please see attached letter, C) have also revealed that when the new regulations were being inserted into the Code, the terminology for the limitations of size was not reviewed for consistency with the rest of the code. A review probably would have amended this section of the code. C. Proposal 1. The applicant purposes to substitute the term "net leasable commercial and office space" for "gross floor area" in this section of the Code. 2. The applicant also suggests reducing the net leasable square footage allowed in this section. The term net leasable could result in slightly larger structures because "net leasable" does not include storage, closets I etc. This problem arose when the Code was amended to use "net leasable" instead of "floor area" as a measurement for commercial GMQS quotas. Research showed that approximately 85% of a building's floor area typically constitutes net leasable space therefore the quotas were reduced by 15% so the total floor area of the commercial building did not drastically increase in size but remained consistent to past acceptable sizes as defined within the Code. This memo does not include a 15% reduction in allowable square footage for several reasons: a) mitigation is required on net leasable square footage which potentially limits size; b) a reduction in maximum allowable may create non-conforming conditions for existing businesses or structures; and c) other dimensional requirements are used to limit the bulk of commerical and office building's. However, staff is interested in the Council's comments regarding this element of the Code Amendment. 3. Allowances for storage and underground parking can be excluded 3 ~ '-'. from this section because the definition of "net leasable" excludes storage and underground parking. C. Amendment: Section 5-504 is proposed to be amended as follows: with the Commercial Core (CC), commercial (C-1), and Service/Commercial/Industrial (S/C/I) zone districts, all permitted and conditional commercial business shall be restricted to the fOllowing maximum ~res5 fleer areal exeludiB~ aayhaacmcnt, fer steragc (except eemmcreial sterafJo pa.rpeses er \illder~rel:lfld par~tin~ net leasable commercial and office space. A. 3.000 sa. ft. The following and similar uses shall be limited to three thousand (3,000) square feet in ~ress fleer area net leasable commercial and office space: antique shop; art supply; bakery; book- store; camera shop; candy, tobacco or cigarette shop; catalogue store; drug store; florist shop; gift shop; hobby shop; jewelry shop; key shop; liquor store; pet shop; photography shop; stationery store; dry cleaning; pickup station; barber and beauty shop; small appliance store; art, gallery; decorator shop; seamstress; laundromat; tailor; shoe repair shop; radio and TV broadcasting stations; rental, repair and wholesaling, provided they are accessory uses; electrical and plumbing service shops; automobile washing facility; pharmacies; art studio; and catering service. B. 6.000 sa. ft. The following and similar uses shall be limited to six thousand (6,000) square feet in ~resa fleer area net leasable commercial and office space: drugstore (including pharmacy); equipment rental, storage and repair ; shop craft industry; fabrication and repair and building materials (l.rith an adaitiel'tal three thellSal'td (3, BJl8) sqtiare feet permitted fer stera~e); sporting goods store; variety shop; professional offices; and major appliance stores. C. 9.000 sa. ft. The following and similar uses shall be limited to nine thousand (9,000) square feet in ~ress fleer area net leasable commercial and office space: service station and restaurant. D. 12.000 sa.ft. The following and similar uses shall be limited to twelve thousand (12/000) square feet in ~ress fleer area net leasable commercial and office space: vehicle sales (.lith aR additieRal six theuaaRd (6,888) sqtiare feet permitted fer elltaeer tltera~e); buflder supply yard; lumber yard; dry 4 r"\ r"\ cleaning plant and laundry; manufacture and repair of sporting goods; printing and publishing plant; furniture store; carpet and floor covering store; financial institutions; and food market (wit.h aR nddi$ienal ~rcc theuaand (J,00B) square feet permitted fer a~era;c andaeecooery aaes). E. 20.000 sa. ft. The following and similar uses shall be limited to twenty thousand (20/000) square feet in ljJresa fleer area net leasable commercial and offiQe space: warehousing and storage. F. Retail sales areas. All of the square footage limitations on use shall not restrict the square footage of the total retail sales areas in these Zone Districts, or any buildings occupied by any combination of more than one (1) of the above uses; provided, however, that any business enUlllerated above, of the same type which occur individually or jointly in a single structure or combination of structures situated upon a single tract of land under the same ownerShip, shall be considered one (1) business and together restricted to the maximum ljJreas fleer area net leasable commercial and office space provided in this section. D. summary: within the development. In summary, the proposed Change insures consistency Code and is the most appropriate guideline for staff recommends the following changes to Section 5-504: 1) changing the term "gross floor area" to "net leasable commercial and office space"; 2) eliminating the exclusion language for storage, basement and underground parking; and PLANNING AND ZONING COMMISSION VOTE 5 FOR 0 AGAINST Key Issues: The commission agreed with staff that a reduction in the a.llowable square footage was unnecessary. The Commission also requested staff to consider minimum sizes to try and prevent the "cubiclization" of retail space in the downtown. RECOMMENDATION: The Commission recommends to Council approval of the text amendment for Section 5-504. PROPOSED MOTION: I move to read Ordinance 221 Series of 1991. I move to approve Ordinance 22 on second reading amending Chapter 5 r-,. t""'"'\ 24 of the Municipal Code section 5-504. CITY MANAGER COMMENTS: ATTACHMENTS: A. Sketch B. Bank Calculation C. Richman Letter D. Ordinance 22 6 ,-.." ,-.." ATTACHMENT A y------.---- i , I closet non net- leaseable Znd,Floor "connnercial/retail" net leaseable I 1st Floor ! "connnercial/retail" ! I net leaseable I I i ! i I [ i I i \ I ! Gross Floor Area" garage non net- leaseable bathroom non net- leaseable basement I' ,., commercial/retail" net-leasE!able '\ I I I I Floor \ Area \ \ , \ \ ; \ \ ! , " i f j I I I i f ! I j r'\ r-, Attachment B ~.~q Existina Proposed Total Allowable Gross Building Area 9,240 4,190 13,430 12/000 Floor Area 4,700 4,150 8,850 9,030 Net Leasable Area 5/460 2,240 7,700 12,000 ~ .~ EXHIBIT 3 ATTACHMENT C. ALAN M. RICHMAN PlANNING SERVICES 1015 East Hyman Avenue Sulte 5 Aspen, Colocado 81611-4122 303-925-7634 , October 25, 1990 Mr. Sunny Vann Vann Associates 230 E. Hopkins Avenue Aspen, Colorado 81611 Dear Sunny, You have asked me to examine Section 5-503 of the Aspen Land Use Regulations, Use .' Square Footage Umitations, so that I might recall the changes made to this provision during the re-codification of the former zoning and subdivision regulations. In reviewing this section of the Code, it is my recollection that the only change which was made was to eliminate the Planning and Zoning Commission's ability to grant variations from these standards. The consultant felt that granting variances was not within P&z's . powers, which, conveniently, allowed us to eliminate one of Aspen's many review procedures. It is my recollection that no consideration at all was given to the term "gross floor area". It was never brought to our attention that the term was not defined. Moreover, had we thought about the term, we might have instead used "net leasable floor area", a term which is already used in connection with other provisions regulating commercial uses. I would suggest that if the term "net leasable floor area" were ever to replace the term gross floor area in this section, then the square footage limitations themselves might need to be re-calculated. Based on research we conducted during the Code revision process, the limitations should be reduced by a factor of 0.85, to reflect net leasable versus total floor area of a commercial building. . I hope this information clarifies your understanding of the actions taken with respect to this provision. Very truly yours, ALAN M. RICHMAN PLANNING SERVICES . ;h~V\ Alan M. Richman, AICP ~ ~. " MEMORANDUM FROM: Mayor and Council Carol O'Dowd, city Manager "A/ Amy Margerum, Planning Director~\NV Leslie Lamont, Planner TO: THRU: THRU: RE: Square Footage Limitation Code Amendment - Sec.tion 5- 504, First Reading Ordinance DATE: May 28, 1991 SOHMARY: The applicant, pitkin County Bank, seeks to amend Section 5-504 of the Aspen Land .Use Code changing the language that limits the maximum size of a financial institution. "Gross floor area" is the term used to restrict the size of an individual commercial business within the CC, C-l, and S/C/I Zone Districts. The applicant proposes to change the term to "net' leasable commercial and office space." A tex1;: amendment is a two step review process requiring review by the Commission and Ordinance adoption procedures at Council~ The Commission reviewed the amendment at their May 7 meeting and recommends approval of the text amendment for Section 5-504. COUHCILGOALS: The proposed amendment is consistent with Goal #14: to develop a consistent and fair government so that citizens know what to expect... BACKGROUND: pitkin county Bank received a 1990 commercial GMQS allocation for 2,240 square feet of net leasable square footage to enlarge the existing bank building. As you know, commercial GMQS allotments are allocated on a net leasable square foot basis. However, the Bank's allocation pushes them over the allowable "gross floor area" for a financial institution. Pursuant to Section 5-504, financial institutions are limited to a maximum of 12,000 square feet of "gross floor area." The Zoning Department .has interpreted "gross floor area," although not defined in the Land Use Code, to mean a building's gross square footage - everything contained within the four walls above and below grade. Note: floor area as defined in the code generally does not include below grade space and net leasable is generally defined as al~ commercial or office space that is meant to be leased and occupied excluding bathrooms, stairs, corridors, mechanical and storage areas. .,-.., ~. The effect of this language upon the applicant is to preclude the Pitkin county Bank and Trust Company the ability to occupy all of the additional square footage that they received with their 1990 GMQS allocation: Existina Increase ProDosed Gross Building Area 9,240 4,190 13,430 Floor Area 4/700 4,150 8,850 Net Leasable Area 5/460 2,240 7,700 Note: The proposed floor area is below the allowable floor area for the site in that CC zone district. PROBLEM DISCUSSION: A. Although the Planning Department has confirmed Zoning's interpretation regarding "gross floor area," staff does agree with the applicant that the language is problematic for the following reaSOns: 1) "Gross floor typically used development. 2) "Floor area" and "net leasable" are the terms used within the Code to define the parameters of a development. area" is not defined within the Code and is not throughout the Code as a guideline for . 3) "Net leasable" commercial and office space is the term used for growth impact mitigation whic~a~ ~Il~~~~ limiting factor. 4) Within the CC, C-l, and S/C/I z6~~futricts maximum allowable floor area and other dimensional requirements are used to limit the bulk of commercial and office buildings. 5) Since the time of the original zoning regulations the term "net leasable commercial and office space" has been included in the Code to be used for growth impact mitigation purposes and floor area is used for bulk control. Thus, this change insures consistency within theCQde and is the .most appropriate guideline for development. The applicant offers two other ideas regarding the continued use of the term "gross floor area"such as: 1) The limitation was designed to limit the size of businesses rather than a building'S bulk. The community was probably concerned about the development of a large commercial structure such as a K-Mart. This would support the fact that a large building can contain numerous small commercial uses. 2 ,r-... . ~. . 2) The applicant also believes that at the time this zoning regulation was promulgated that "gross floor area" really referred to "floor area." 3) Discussions with Alan Richman, please see attached letter, have also revealed that when the new regulations were being inserted into the code that the terminology for the limitations of size was not reviewed for consistency with the rest of the code. A review probably would have amended this section of the code. B. Proposal 1. The applicant purposes to substitute the term "net leasable commercial and office space" for "gross floor area" in this section of the Code. 2. The applicant also suggests reducing the square footage allowed in this Section. The term net leasable could result in slightly larger structures because "net leasable" is more permissive than "gross floor area." This problem arose when the Code was amended to use "net leasable" instead of "floor area" as a measurement for commercial GMQS quotas. Research shewed that approximately 85% of a building'S floor area typically constitutes net leasable space therefore the quotas were reduced by 15% so the total floor area of the cOllllllercial building did not drastically increase in size but remained consistent to past acceptable sizes as defined within the Code. ' This memo does not include a 15% reduction in allowable square footage for several reasons: a) mitigation is required on net leasable Iilquare footage which potentially limits size; and b) a reduction in maximum allowable may create non-conforming conditions for existing businesses or structures. However, staff ilil interested in the Council's cOllllllents regarding thilil element of the Code Amendment. 3. Allowances for Iiltorage excluded from this Section lealilable" excludes Iiltorage and and underground parking can be because the definition of "net underground parking. C. Amendment: follows: Section 5-504 is proposed to be amended as With the Commercial Core (CC), COllllllercial (C-l) , and Service/Commercial/Industrial (S/C/I) zone districts, all permitted and conditional commercial business shall be restricted to the following maximum C!fZ'e8'!t-~-:leer- area r-e-:lfel-tidi:-I'lg'-e.!'lY- be.1gelOOft'b,-~~:l"~ te:lfeeP-e---eeiIlIIleJ!'e~1---lt-ee:l"ag'e'--~li':l"l'e5C5 --e:l"--ttl'tde~~li'M ~a-:l"~i:-I'lg'-net leasable COlIIlIIercial and office space. 3 ,~ .-, A. 3.000 sa. ft. The following and similar uses shall be limited to three thousand (3,000) square feet in ~reMI :Hee~-6rea net leasable commercial and office space: antique shop; art supply; bakery; bookstore; camera shop; candy, tobacco or cigarette shop; catalogue store; drug store; florist shop; gift shop; hobby shop; jewelry shop; key shop; liquor store; pet shop; photography shop; stationery store; dry cleaning; pickup station; barber and beauty shop; small appliance ,store; art gallery; decorator shop ; seam.stress; laundromat; tailor; shoe repair shop; radio and TV broadcasting stations; rental, repair and wholesalinq, provided they are accessory uses; electrical and plumbing service shops; automobile washing facility; pharmacies; art studio; and catering service. B. 6.000 sa.ft. The following and similar uses shall be limited to six thousand (6,000) square feet in ~Z'e81!! ~%eo~--a-l!'ea net leasable commercial and. office space: drugstore (including pharmacy); equipment rental, storage and repair; shop craft industry; fabrication and repair and building materials tw~--aft--add-i~-iefte.~--~hret.--bboueend t"7e~---eq1!"a-re---f~"'-pa'!lli~-~--s~~)-t sporting goods store; variety shop; professional offices; and major appliance stores. c. 9.000 sa.ft. The following and similar uses shall be limited to nine thousand (9,000) square feet in ~ ~%eo~--a-l!'ea net leasable commercia1 and office space: service station and restaurant. D. 12.000 sa. ft. The following and similar uses shall be limited to twelve thousand (12,000) square feet in ~~ f.%eo~- area net leasable commercial and office space: vehicle sales tw~ a-ft-~al ->5-iiC--tl1al:\sa-M--f6;~->5~are--~ pe_i-~-~-~-~e); builder supply yard; lumber yard; dry cleaning plant and laundry; manufacture and repair of sporting qoods; printing and publishing plant; furniture store; carpet and floor covering store; financial institutions; and food market twi--eft--en--add.-i~-iet'le:i--'ehl!'ee--bboueend t3-;-&&&)--~- fee~--~'m:i~~-ed---f~--8i!erafJe--a-ftti aeecase~y uac3~ E. 20.000 sa. ft. The following and similar uses shall be limited to twenty thousand (20,000) square feet in ~~ f.%eo~- area net leasable commercial and office space: warehousing and 4 ~ r--. , F. storage. Retai1 sa1es areas. All of the square footage limitations on use shall not restrict the square footage of the total retail sales areas in these Zone Districts, or any buildings occupied by any combination of more than one (1) of the above uses; provided, however, that any business enumerated above, of the same type which occur individually or jointly in a single structure or combination of structures situated upon a single tract of land under the same ownership, shall be considered one (1) business and together restricted' to the maximum ~rel!tl!I f-%eo~- ~ea net 1easab1e comm.ercia1 and office space provided in this section. D. Sonmn<try: In summary staff recommends the following changes to Section 5-504: 1) changing the term "gross floor area" to "net 1easable commercial and office space"; 2) eliminating the exclusion language for storage, basement and underground parkingiand PLAHNIHG AND ZORING COMMISSION VOTE 5 FOR 0 AGAINST Key Issues: The Commission agreed with staff that a reduction in the allowable square footage was unnecessary. The Commission also requested staff to consider minimum sizes to try and prevent the "cubiclization" of retail space in the downtown. RECOMMENDATJ:ON: The commission recommends to Council approval of the text amendment for Section 5-504. PROPOSED lIOTl:oN: I move to read and approve Ordinance , Series of 1991 on first reading amending Chapter 24 of the Municipal Code Section 5-504. , CITY MANAGER COMMENTS: ATTACBM:ERTS: A. Richman Letter B. Ordinance 5 - r--.. ,,-,, , , MEMORANDUM TO: FROM~ Aspen Planning and Zoning Commission Leslie Lamont I ,Planning Square Footage Limitation Code Amendment - section 5- 504 RE: DATE: May 7, 1991 ----------------------------------------------------------------- ----------------------------------------------------------------- SUMMARY: The applicant seeks to amend section 5-504 of the Aspen Land U~~.cod!Ochanging the language that limits the maximum size of "financial'institution. "Gross floor area" is the term used restrict of an individual commercial business within e , 1, and S/C/IZon Districts. The a~ Plicant. pr o~s . ~o ange the term to "net le sable a:rea." . _ ~ ~~. . ~ A tex is a two step review process requiring n icing . in the newspapers at the Commission and qrdinance adopt~on procedures at councir. staff recommends approval of the text amendment for section 5- 504. APPLICANT: Vann. Aspen Bank Shares, Ltd., as represented by Sunny APPLICANT'S REQUEST: Amend Secti;.o n1J-:!)5 c{f1a i.ng "gross floo.r area" to "net leasable tll'"'9:i. " "', G5Y'fvvv\.QX/CZ C-f:::y ~ -' STAFF COMMENT'S: U (.. ~ A. Background: Pitkin county Bank received a 1990 commercial GMQS allocation for 2,240 square feet of net leasable square footage to enlarge the existing bank building. Pursuant to Section 5-504, financial institutions are limited to a maximum of 12,000 square feet of "gross floor area. II The Zoning Department has interpreted "gross floor areal" although not defined in the Land Use Code, to mean a building t s gross square footage as everything contained within the four walls above and below grade. Note: floor area as defined in the code generally does not include below grade space and net leasable is generally defined as all commercial or office space that is meant to be leased and occupied excluding bathrooms, stairs I corridors, mechanical and storage areas. The effect of this language upon the applicant is to preclude the Pitkin County Bank and Trust Company the ability to occupy all of --. ,--.' the additional square footage that they received with the,ir 1990 GMQS allocation: Existinq Increase Proposed Gross Building Area 9,240 4/190 13,430 : Floor Area 4,700 4,150 8,850 Net Leasable Area 5,460 2,240 7,700 Note: The proposed floor area is below the allowable floor area for the site. Although the Planning Department has confirmed interpretation, staff does agree with the applicant language is problematic for the following reasons: Zoning's that the 1) "Gross floor typically used development. area" is not defined within the code and is not throughout the Code as a guideline for 2) "Floor area" and "net leasable" are the terms used within the, Code to define the parameters of a development. 3) "Net leasable" square footage is the term used for growth impact mitigation which can be a size limiting factor. 4) within the CC, C-1, and S/C/I zone districts maximum allowable floor area and other dimensional requirements are used to limit the bulk of commercial buildings. 5) Since the time of the original zoning regulations the term "net leasable" has been included in the Code to be used for growth impact mitigation purposes and floor area is used for bulk control. Thus I this 'change insures consistency within the Code and is the most appropriate guideline for development. ' The applicant offers two other ideas regarding the continued use of the term "gross floor area" such as: 1) The limitation was designed to limit the size of businesses rather than a building's bulk. The community was probably concerned about the deve'lopment of a large commercial structure such as a K-Mart. This would support the fact that a large building can contain numerous small commercial uses. 2) The applicant also believes that at regulation was promulgated that "gross referred to "floor area." the time this zoning floor area" really 2 ~ .-, . 3) Discussions with Alan Richm~n I please see attached letter, have also revealed that when the new regulations were being ,inserted into the code that the terminology for the limitations of size was not reviewed for consistency with the rest of the code. A review probably would have amended this section of the code. ' B. Proposal: C'~">The applicant purposes to substitute th~ term "net leasable /--"--~ea" for "gross floor area" in this' Section of the Code. \~ .. 2. "'\ The applicant alfio suggests reducing the square footage .... allowed' in this section. The term net le.asable could result in slightly larger structures becCiuse "net leasable area" is more permissive than "gross floor area." This problem arose when the Code was amended to use "net leasable" instead of "floor area" as a measurement for commercial GMQS quotas. Research showed that approximately 85% of a building's floor area typically constitutes net leasable space therefore the quotas were reduced by 15% so the total floor area of the commercial building did not drastically increase in size but remained consistent to past acceptable sizes as defined within the Code. This memo does not include a 15% reduction in allowable squa.re footage, for several reasons: a) mitigation is required on' net leasable square footage which potentially limits ,size; and b) a reduction in maximum allowable may affect existing bu.sinesses perhaps creating a non~ccinforming condition with existing usinesses or structures. ~ ~- However, staff is interested in the Commission's comments regarding this element of the Code Amendment. 3. Allowances for storage excluded from this Section leasable" excludes storage and and underground parking can because the definition of underground parking. be "net C. Amendment: follows: Section 5-504 is proposed to be amended as with the Commercial Core (CC) I Commercial (C-1), and Service/Commercial/Industrial (S/C/I) zone districts I all permitted and conditional commercial business shall be restricted to the following maximum <!r~:t:t--f.:!. e~-~,--elfer1:td-i-I't€!-t1f\Y- ~ascmel'l-t-;--:f~-s-~l'lt<!re fe:lfeell'~--ee-lltllte~i-1t r --:t~t'-It<!re --ll'l:tl'll'e-se:t--el'--l:t!'lcl-el'<f~l:tMi ll'1t1'~i-~ A. 3.000 sq.ft. The following and similar uses shall be limite~~o ree thousand (3,000) square feet in <!rl'~~~-~~~Q: antique shop; art --~~~ ,....--.., ~ supply; bakery; bookstoFe; camera shop; candy, tobacco or cigarette shop; catalogue store; drug store; florist shop; gift shop; hobby shop; jewelry shop; key shop; liquor store; pet shop; photography shop; stationery store; dry cleaning; pickup station; barber and beauty shop; small appliance store; art gallery; decorator shop; seamstress; laundromat; tailor; shoe repair shop; radio and TV broadcasting stations; rental, repair and wholesaling, provided they are accessory uses; electrical and plumbing service shops; automobile washing facility; pharmacies; art studio; and catering service. B. 6.000 so. ft. The following and similar uses shall be .~.. to six thousand (6,000) square feet in ~~ rea :.drugstore (including pharmacy); equipmen rental. storage and repair; shop craft industry; fabrication and repair and building ,ma ter ials fwl,-e-ft--al'l--&dd4.'t4.~&~---t.-ffl:'ee--~ t-3-,ee-f)i ---gq1f'a-re - --f-eet---pei:'fll-it-t-ed---~--a--e-~r~h sporting goods store;' variety shop; professional offices; and major appliance stores. C. 9.000 so.ft. The following and similar uses shall b~~~ nine thou~and (Q,.?OO) square feet in ~-~~ rea: serv~ce stat~on and restaurant. D. 12.000 so. ft. The following and similar. uses shall be limited t~.twe e. thousand (12,000) square feet in ~~ero ~oa: vehicle sales fwl,-e-ft--Ml--a:ddH;::j,el'\"ar-~ - a-al'let--(-6-;~--eql:ta-re ~ee~--~~m4.'t'ted---f~-~-~t~ra~~); builder supply yard; lumber yard; dry cleaning plant and laundry; manufacture and repair of sporting goods; printing and publishing plant; furniture store; carpet and floor covering store; financial institutions; and food market tWl,-e-ft-al'l-&dd4.'t4.~fte~ -eftree-"'ft~ti5eftd--{-3-,~--eqtta-re--fee"'-~it-t-ed--rer a-"l:-er~e-a-I'let-a-eeea-~ry-tta-ea-r~ E. 20.000 so.ft. shall be limite square feet in ~ storage. and similar uses thousand (20,000) : warehousing and F. Retail. sales areas. All of the square footage limitations on use shall not restrict the square footage of the total retail sales areas in these Zone Districts, or any buildings occupied by any combination of more than one (1) of the above uses; providedl however, that any business 4 t~, .-, enumerated above, of the same type which occur individually or jointly in a single structure or combination of structures situated upon a ,single tract of lanQ unQer the same ownership, shall be considered one ,(1) business anQ together restricted to the maximum ~~e floor" area provided in this section. Amended language is proposed to read as follows: With the Commercial Core (CC), Commercial (C-l), and service/Commercial/Industrial (S/C/I) zone districts, all permitted and conditional commercial business shall be restricted to the following maximum net leasable leeF aFea'~n~'~ O"""'-""'<lrOu~6~ A. 3.000 Sq. ft. The owing and, similar uses' , shall be limited to e ousand (3,000) square feet in net leasabW OQ,r area: antique shop; art supply; bakery; booksio e; camera shop; candy I tobacco or cigarette shop; catalogue store; drug store; florist shop; gift shop; hobby shop; jewelry shop; key shop; liquor store; pet shop; photography shop; stationery store; dry cleaning; pickup station; barber and beauty shop; small appliance store; art gallery; decorator shop; seamstress'; laundromat; tailor; shoe repair shop; 'radio and TV broadcasting stations; ,rental, repair and wholesalingl provided they are accessory uses; electrical and plumbing service shops; automobile washing facility; pharmacies; art studio; and catering service. B. 6.000 sa. ft. following and similar uses shall be limitedt '.six ousand (6 1000) square feet in net leasable' 'f oor rea: drugstore (including pharmacy); equip n rental I storage and repair; shop craft industry; fabrication and repair and building materials; sporting goods store; variety shop; professional offices; and; major appliance stores. ,.. v. 9.000 Sq. ft. The following be limited t06>;ne ousand net leasable 'fl rea: restaurant. and similar uses shall (9,000) square feet in service station and D. 12.000 sq.ft. The fol1 and similar uses shall be limited to tw usand (12/000) square feet in net leasable rea: vehicle sales; builder supply yard; er yard; dry cleaning plant and laundry; manufacture and repa~r of sporting goods; printing and publishing plant; 5 .~. furniture. store; carpet and floor covering store;' fin~ncial ins~itutions; and food market. E. 20.000 so.ft. The following and .s' 'lar uses shall be limited to twenty thou nd 20 I 000) square feet in net' leasable loor area: warehousing and storage. F. Retail sales areas. Afl of the square footage limitations on use ~hall not re$trict the square footage of the total retail sales areas in these Zone Districts, or any buildings occupied by any combination of more than one (1) of the above uses; provided, however I that any busi~ess enumerated above, of the same type which occur individually or jointly in a single structure or combination of structures situated upon a single tract of land under the same ownership all be considered one (1) business an tog 'ther restricted to the maximum net leasable floor rea provided in this section. SUMMARY: In summary staff recommends the fOllowing changes to section 5-504: 1) changing the term "gross floor area" to "net leasable area"; 2) eliminating the exclusion language for storage f" basement and underground parking; and RECOMMENDATION: Staff recommends that the Commission recommend to Council approval of the text amendment for section 5-504. -d ~..~ ~ C?~, (~ '\ ~ \ ,'-" .-, PUBLIC NOTICE RE: PROPOSED TEXT AMENDMENT TO SECTION 5-503 OF THE ASPEN LAND USE REGULATIONS NOTICE IS HEREBY GIVEN that a p~blic hearing will be held on Tuesday, May 7, 1991 at a meeting to begin at 4:30 pm before,the Aspen Planning and Zoning commission, 2nd Floor Meeting Room, 130 South Galena street, Aspen, Colorado to consider an application submitted by Aspen Bank Shares, Ltd. as owner of the Pitkin County Bank'and Trust Company requesting an amendment to the text of section 5-503 of the Aspen Land Use Regulations. The proposed text amendment would replace the term "gross floor area" with the term "net leasable area". For further information, contact the Aspen/Pitkin Planning Office, 130 S. Galena st., Aspen I CO 920-5090. sIC. Welton Anderson. Chairman planning and Zoning Commission ----------------------------------------------------------------- ----------------------------------------------------------------- Published in The Aspen Times on April 16, 1991. City of Aspen Account. -,0; r-., r-., MEMORANDUM TO: city Attorney FROM: Leslie Lamont, Planning Office Text Amendment, Section 5-510, Use Square Footage RE: DATE: March 26, 1991 ======:========================================================= Attached for your review and comments is an application from Aspen Bank Shares, Ltd. (Pitkin County Bank & Trust) requesting a text amendment. Please return your comments to me no later than April 15, 1991. Thank you. r-., .-, ASPEN/P~~'Kil\l PLANNING OFFICE 130 S. Galena street Aspen, Colorado 81611 (303) 920-5090 March 261 1991 sunny Vann Vann Associates 230 East Hopkins Avenue Aspen I CO 81611 Re: Text Amendment, section 5-503, Use Square Footage Dear Sunny, The Planning Office has completed its preliminary review of the captioned application. We have determined that this application is complete. Please submit the application fee of $780.00. We have scheduled this application for review at a pUblic hearing by the Aspen Planning and Zoning Commission on May 7, 1991 at a meeting to begin at 4:30 pm. The Friday before the meeting datel we will call to inform you that a copy of the memo pertaining to the application is available at the Planning Office. If you have any questions, please call Leslie Lamont, the planner assigned to your case. sincerelYI Debbie Skehan I Office Manager r--. .~ VANN ASSOCIATES, INC. :::2.'''~:1g Cor',sultants March 14, 1991 HAND DELIVERED Ms. Kim Johnson Aspen/Pitkin Planning Office l30 South Galena Street Aspen I Colorado 81611 Re: Pitkin County Bank & Trust Company/Use Square Footage Limitation Code Amendment Dear Kim: Please consider this letter an application for an amendment to the language of section 5-503, the Use Square Footage Limi tat ions of the Aspen Land Use Regulations (see Pre- Application Conference Summary attached hereto as Exhibit 1). The application is submitted pursuant to section 7-1103 of the Regulations by Aspen Bank Shares, Ltd. (dba, the Pitkin County Bank & Trust Company). The Applicant's representative is Sunny Vann of Vann Associates, Inc., Planning Consultants (see Exhibit 2, Permission to Represent). Background On December 17, 1990, the city Council awarded the Applicant a commercial GMQS allotment for the expansion of the Pitkin County Bank & Trust company building. The allotment consist- ed of two thousand two hundred and forty (2,240) square feet of net leasable area which is to be used to add a partial second floor to the existing bank building. The addition is to be occupied solely by bank personnel, and is necessary to alleviate existing overcrowded conditions within the bank. Pursuant to section 5-503.D. of the Regulations, financial institutions are limited to a maximum of twelve thousand (12,000) square feet of "gross floor area". Al though the Regulations contain a definition of the term "floor area", and provide direction as to how floor area is to be measured for "floor area ratio" and "allowable floor area" purposes I the Zoning Department has taken the position that the term "gross floor area" I as used in section 5-503, refers to a building's gross square footage as opposed to its floor area. 230 East HOPKins Avenue' Aspen, Coiorado 81611 . 303/925'6958 ~. , . ~.. Ms. Kim Johnson March 14, 1991 page 2 While the staff's interpretation is arguably debatable~ if sustained, it would preClude the Pitkin County Bank & Trust Company from occupying all of the additional square footage which is to be constructed pursuant to their GMQS allotment. As Table 1 below illustrates, the gross square footage (i.e'l the "gross floor area") of the expanded building will be approximately thirteen thousand four hundred and thirty (13,430) square feetl or one thousand four hundred and thirty (1,430) square feet greater than the twelve (12,000) square foot maximum limitation. The building's expanded "floor area", however, will be significantly less than the maximum allowed. Table 1 Development Data' Existing Proposed Increase Gross Building Area2 9,240 13,430 4,190 Floor Area3 4,700 8,850 4,150 Net Leasable Area4 5,460 7,700 2,240 , All numbers rounded to nearest ten (10) square feet. 2 The sum of the gross horizontal areas of each story of the building. 3 The building's basement has been excluded as it is located one hundred (100) percent below grade. 4 Excludes areas dedicated to bathrooms, stairways, corridors, mechanical areas and storage areas. As you know, the Applicant requested a formal interpretation of the relevant provisions of the Regulations from the Planning Office. While the staff agreed with the Zoning Department's interpretation, they indicated that the language was indeed problematic, and suggested that the Applicant apply for an amendment to the Regulations. proposed Amendment While I believe that the use square footage limitations of Section 5-503 predate the current staff's tenure in the t"'" ,-, Ms. Kim Johnson March 14, 1991 Page 3 planning Office, it is my understanding that the limitations were conceived as a means of regulating the relative size of commercial businesses rather than as a bulk control. At the time they were adopted, the community was apparently con- cerned about the possibility of someone developing an unusually large commercial structure (e.g., a K-Mart or a large grocery store). This understanding would appear to be supported by the fact that it is possible to maximize a structure's floor area while not exceeding the various use square footage limitations. In other words, a large building could contain multiple small commercial uses. Unfortunately, little if any public record exists regarding the adoption of the zoning regulations in which the use limitations originally appeared. The zoning regulations in question were adopted, I believe, concurrent with the city- wide rezoning which occurred in the early seventies. As "floor area" was the standard measure of building size at the time, I believe that the term "gross floor area" as used in section 5-503 referred to floor area and not gross building square footage, the Zoning Department's interpretation notwithstanding. Since the adoption of the original zoning regulations, numerous changes have occurred in the way floor area is measured. In addition, the new Aspen Land Use Regulations have introduced the term "net leasable area"l which is the standard for measuring impact for growth management and affordable housing purposes. Floor area is now used solely as a bulk control. If in fact the intent of the use limita- tions was to control the relative size of commercial busi- nesses, as opposed to building bulk, I believe that the substitution of "net leasable area" for "gross floor area" in the current regulations would more appropriately achieve this obj ecti ve. The use of net leasable area would, in my opinion, permit a more accurate comparison of business size. In discussing the adoption of the new Aspen Land Use Regula- tions with Alan Richman, he indicated that the use limita- tions of the' old code were simply transferred to the new regulations. Little, if any, discussion as to their contin- ued applicability apparently occurred during the adoption process. Alan also indicated that the terminology (i.e., "gross floor area") of the limitations was not reviewed for consistency with the language and definitions contained in the new regulations. In hindsight, I believe he would agree that this issue should have been addressed in connection with the adoption of the new Regulations. A letter from Alan addressing this issue is attached as Exhibit 3. ,I'""'-, I'""'-, Ms. Kim Johnson March 14, 1991 Page 4 Based on the above, the Applicant requests that Section 5-503 be amended to replace the term "gross floor area" with the term "net leasable area". To the best of my knowledge, the Regulations contain no other reference to gross floor area. As a result, no definition of this term need be drafted. The term net leasable area was defined in connection with the 1988 adoption of the Aspen Land Use Regulations. The introductory paragraph to Section 5-503 would, therefore, read as follows. "Within the Commercial Core (CC), commercial (c-l), and Service/Commercial/Industrial (S/C/I) Zone Districts, all permitted and conditional commercial business shall be restricted to the following maximum net leasable area". As the definition of net leasable area excludes storage areas used exclusively by the tenants of the building, I believe that the language in Section 5-503 which refers to the exclusion of basements used for storage and underground parking can be eliminated. It should be noted that the use of "net leasable area" to limit the relative size of commercial structures will result in slightly larger buildings as this term is more permissive than "gross floor area". This potential problem also arose when the unit of measure for the commercial GMQS quotas was changed from "floor area" to "net leasable area". The problem was resolved, however, by reducing the quotas by fifteen (15) percent. This reduction was based on the theory that approximately eighty-five (85) percent of a commercial building's floor area typically constitutes net leasable space. Should the staff have a similar problem regarding the Applicant's proposed amendment, the same approach could be utilized to reduce the size of the various existing use square footage limitations. In other words I the existing limitations could be reduced by fifteen (15) percent to ensure the maximum size of the community's commercial structures remains unchanged. For example, the existing twelve thousand (l2,OOO) square foot gross floor area limitation on the size of financial institutions would become a ten thousand two hundred (10,200) square foot limitation on net leasable area. As the Applicant ability to proceed with the construction of the proposed bank addition is dependent on obtaining the proposed regulatory amendment, any assistance you may be able . l ,.--..- , , . --.---:--.,." ~~~-r:""'::;:. '- 1"""'\ 1"""'\ Ms. Kim Johnson March 14, 1991 Page 5 to provide in the timely scheduling of our application would be sincerely appreciated. Should you have any questions, or require additional information, please do not hesitate to call. Very truly yours, VANN ASSOCIATES, INC. SV:cwv Attachments EXHIBIT 12//7 .l;'>{E-APPLICATION CONFERENCE SUMMARY PROJECT: Cdb~f)J.AIOcl--~.fo ~~~ ~cd-. <" ' fitCO. f;.q.. j APPLICANT'S REPRESENTATIVE: /UMM.O REPRESENTATIVE'S PHONE: ,5. (//rc::J6 .1"""\ CITY OF ASPEN ~ OWNER'S NAME: 1. Type of Application: ~Sa;Y Describe action/typ~ of development ~ing requested: , ~ uM 1/ drP d:d~t1A,~ (~:!.a~~ch APpli=t has been requested to respond. types of reports requested: , 2. Policy Areal , Referral Aaent ~M{J.Nt 'C. g Comments ~ :he~ ~ 4. Review is: (P&Z 5. Public Hearing: Only) (CC Only) ~+r- (NO) of the application 3 6. Number of copies 7. What fee was applicant requested to submit: 8. Anticipated date of submission: 9. COMMENTS/UNIQUE CONCERNS: frm.pre_app ,......, .-, EXHIBIT 2 ' VANN ASSOCIATES, INC. PIRnnlng CO:lsultants september 12, 1990 HAND DELIVERED Ms. Leslie Lamont Aspen/Pitkin planning Office 130 South Galena street Aspen, Colorado 81611 Re: Permission to Represent Dear Ms. Lamont: Please consider this letter authorization for Sunny Vann of Vann Associates, Inc., planning Consultants, to represent Aspen Bank Shares, Ltd. in the processing of our application for a commercial growth management allocation for an addition to the Pitkin County Bank & Trust Company building located at 534 East Hyman Avenue. Mr. Vann is hereby authorized to act on our behalf with respect to all matters reasonably pertain- ing to the aforementioned application. Should you have any questions, or if we can be of any further assistance, please do not hesitate to call. Sincerely, Aspen Bank Shares, Ltd. ~I~ Charles B. Israel, President Pitkin County Bank & Trust Company (303) 925-6700 SV:cwv 230 East Hopkin~; Avnr~I:". /I.,snml. C,J!'Ir'rldo .',1611. ]03,'Q2:).f\95B