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AGENDA
DESIGN REVIEW APPEALS COMMITTEE
May 14, 1998
4:30 p.m.
Thursday
Special Meeting
Sister Cities Meeting Room, City Hall
4:30
1.
Roll Call
II. Minutes - 10/9/97 & 03/12/98
III. Comments (Committee, Staff and Public)
4:30 IV.A. SilverLode Lot 8
CD Building Orientation - garage placement
@ Volume Standard - glazing 9'- 12' above floor
IY.E. SilverLode Lot 9
CD Building Orientation - garage placement
@ Volume Standard - glazing 9'- 12' above floor
IV.C. Bell Mountain Townhomes - East Cooper Street -
CD Volume Standard - glazing 9'- 12' above floor
@ Building Elements Standard - one story element
along 20% of street frontage
IY.D. 1240 Riverside Drive
CD Volume Standard - glazing 9'- 12' above floor
@ Building Orientation parallel to street
5:30 V. Adjourn
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MEMORANDUM
TO:
The Design Review Appeal Committee
THRU:
Stan Clauson, Community Development Director ~
Julie Ann Woods, Community Development Deputy Director r-
Mitch Haas, Planner ~~
Bell Mountain Townhomes request for Variances to the "Building Elements"
(Section 26.58.040(B)(I)) and "Volume" (Section 26.58.040(F)(12))
provisions of the Residential Design Standards
FROM:
RE:
DATE:
May 14, 1998
SUMMARY: Pursuant to Chapter 26.58, Residential Design Standards, Section
26.58.020(B), of the Aspen Municipal Code, "an applicant shall prepare an application for
review and approval by staff. In order to proceed with additional land use reviews or obtain
a Development Order, staff shall find the submitted development application consistent with
the Residential Design Guidelines." This Section goes on to state that "if an application is
found to be inconsistent with any item of the Residential Design Guidelines the applicant
may either amend the application or appeal staff's findings to the Design Review Appeal
Board [DRAC] pursuant to Chapter 26.22, Design Review Appeal Board. "
Community Development Department staff reviewed the application to construct a multi-
family structure on the site of the Bell Mountain Lodge for compliance with the "Residential
Design Standards," (see Exhibit A). In staff's review, it was determined that the proposed
designs violate both the "Building Elements" standard and the "Volume" standard. Thus, the
applicant is requesting variances from the "Building Elements" and "Volume" standards
(described below) in order to allow for approval of the architectural designs as proposed.
See Exhibit A, letter from Gibson-Reno Architects requesting variances from the
requirements of Ordinance 30.
Pursuant to Section 26.22.010 of the code, an appeal for exemption from the Residential
Design Standards may be granted if the exception would: (1) yield greater compliance with
the Aspen Area Community Plan; (2) more effectively address the issue or problem a given
standard or provision responds to; or, (3) be clearly necessary for reasons of fairness related
to unusual site specific constraints.
APPLICANT: David F. Gibson of Gibson Reno Architects on behalf of the Bell
Mountain Limited Liability Company.
LOCATION: The site in question is located on the northeast comer of Spring Street and
Cooper Avenue in downtown Aspen. Surrounding structures include the Buckhorn Lodge to
the east, the Chateau Aspen to the west, the Aspen Square building to the southwest, City
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Market and the Durant Mall to the south, the Hannah Dustin building and an A-frame
structure to the north, and the Benedict Commons to the northeast.
STAFF COMMENTS:
Section 26.58.040(B)(1), Building Elements
The "Building Elements" standard mandates that "all residential buildings must have a one-
story street facing element the width of which comprises at least twenty (20) percent of the
building's overall width." According to the pending revisions to the Residential Design
Standards, the intent of the "Building Elements" provisions "is to ensure that each
residential building has street-facing architectural details and elements which provide
human scale to the facade, enhance the walking experience, and reiriforce local building
traditions."
The above described intent of the "Building Elements" provision explains the issue or
problem to which the standard is a response. Since the proposed design does not yield
greater compliance with the Aspen Area Community Plan, if the requested variance is to be
justified, it would need to be on the grounds that the proposed design is necessary for reasons
of fairness related to unusual site specific constraints, or that, the proposed design more
effectively provides street-facing architectural details and elements which provide human
scale to the facade, enhance the walking experience, and reinforce local building traditions
than would a design that meets the exact letter of the "Building Elements" standard.
Given the fact that the proposed design attempts to make the most efficient utilization of the
space available by incorporating garden level living areas, the exact letter of the standard
becomes very difficult to apply. For instance, the Cooper Avenue elevation is 200 feet long
and includes 159 lineal feet (approximately 80% of the front elevation) which is two and
one-half (2.5) stories above grade, and 41 lineal feet (approximately 20% of the front
elevation) which is garden level only. Therefore, there are no purely one story sections in
the proposed buildings; thus, a one-story element would have to, in reality, be a one and a
half story element and, as such, would not comply with the exact letter of the "Building
Elements" standard. In order to meet the letter of the standard, the one story street facing
element on a building with 200 feet of street frontage would have to be at least forty (40) feet
long.
Staff feels that the proposed design, with its garden level, one-story entrances, human-scale
doors and first floor decks (above garden level) combined with the proposed landscape plan
and walkways more effectively provide street-facing architectural details and elements
which provide human scale to the facade, enhance the walking experience, and reinforce
local building traditions than would a design that meets the exact letter of the "Building
Elements" standard. In addition, staff feels that the site's location on the edge of the
commercial core is more conducive to greater vertical massing than are the traditional
residential areas, and that this location represents a site specific condition that would render
the variance appropriate for reasons of fairness. In accordance with this asseSSment, staff
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finds sufficient justification to recommend approval of the requested variance from the
"Building Elements" provision ofthe Residential Design Standards.
Section 26.58.040(F)(12), Volume
The proposed design contains multiple violations of the "Volume" standard (please refer to
the letter and graphic from Gibson-Reno Architects, included with Exhibit A). The standard
reads as follows:
For the purpose of calculating floor area ratio and allowable floor area for a
building or portion thereof whose principal use is residential, a determination
shall be made as to its interior plate heights. All areas with an exterior
expression of a plate height of greater than ten (10) feet, shall be counted as two
(2) square feet for each one (1) square foot of floor area. Exterior expression
shall be deflned as facade penetrations between nine (9) and twelve (12) feet
above the level of the flnished floor, and circular. semi-circular or non-
orthogonal fenestration between nine (9) and fifteen (15) feet above the level of '
the flnished floor.
Simply put, as it relates to the subject case, this standard requires that there be no windows
(facade penetrations/fenestration) in any areas that lie between nine (9) and twelve (12) feet
above the height of the first or second story floors (plate height). As proposed, each of the
four elevations contain at least one violation ofthe "volume" standard (for exact locations of
these violations, please refer to the letter and graphic from Gibson-Reno Architects, included
with Exhibit A).
Given the lack of compliance with the "volume" standard, the applicant is left with the
choice of pursuing one of the following three (3) options. First, the applicant could accept
the two-to-one (2:1) floor area penalty while ensuring that the entire building, including FAR
penalties, would fall within set FAR limitations. Second, they could redesign the proposed
structure such that the new form would comply with the "volume" standard, as well as the
rest ofthe residential design standards. Lastly, the applicant could appeal staff s findings to
the Design Review Appeal Board.
Rather than accept the floor area penalty (the design utilizes all but twenty square feet of the
allowable floor area for the site) or redesign the proposed residence, the applicant has chosen
to seek a variance from the "volume" standard. Consequently, if variances are not granted,
the applicant would have to create new designs that would comply with the volume standard.
If a variance is to be granted, it must be justified according to one of the three variance
criteria outlined above (on page one of this memo).
According to the pending revisions to the Residential Design Standards, the purpose of the
"Volume" standard, like the "Building Elements" standard, "is to ensure that each
residential building has street-facing architectural details and elements which provide
human scale to the facade, enhance the walking experience, and reinforce local building
traditions." Although pending code , amendments do not hold any force in the review of
current applications, it may be informative to note that the pending revisions to the
Residential Design Standards recommend changing the "Volume" standard to read as
3
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follows: "Street facing windows shall not span through the area where a secondjloor level
would typically exist. which is between nine (9) and twelve (12) feet above the finished first
jloor." This proposed language is intended to implement the above-stated purpose of the
standard.
The above described intent of the "Volume" standard explains the issue or problem to which
the standard is a response. Since the proposed design does not yield greater compliance with
the Aspen Area Community Plan and is not necessary for reasons of fairness related to
unusual site specific constraints, if the requested variance is to be justified, it would need to
be on the grounds that the proposed design more effectively provides street-facing
architectural details and elements which provide human scale to the facade, enhance the
walking experience, and reinforce local building traditions than would a design that meets
the exact letter of the "Volume" standard.
Staff does not feel that the proposed glazing interferes with the ability of the architecture to
accomplish the intent of the "Volume" standard. Furthermore, staff finds that many, or
indeed most, of the windows for which a variance is required, would not violate the proposed
revision to the "Volume" standard since most of the violating windows are not on the first
story and none of the violating windows found on the lower levels appear to span through the
area where a second floor would typically exist. Staff feels that the proposed design, with its
garden level, one-story entranCeS, human-scale doors and first floor decks (above garden
level) combined with the proposed landscape plan and walkways effectively provides street-
facing architectural details and elements which provide human scale to the facade, enhance
the walking experience, and reinforce local building traditions. In accordance with this
assessment, staff finds sufficient justification to recommend approval of the requested
variance from the "Volume" provision of the Residential Design Standards.
RECOMMENDATION: Staff recommends that the DRAC approve: (1) a variance from
Section 26.58.040(B)(I), Building Elements, of the Residential Design Standards based on a
finding that the proposed design more effectively addresses the issue or problem the given
standard or provision responds to, and is necessary for reasons of fairness related to site
specific considerations; and, (2) a variance from Section 26.58.040(F)(I2), Volume, of the
Residential Design Standards based on a finding that the proposed design more effectively
addresses the issue or problem the given standard or provision responds to.
ATTACHMENTS:
Exhibit "A" - Submitted application package
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HOLLAND & HARTLLP
ATrORNEYS AT LAW
,
DENVER' ASPEN' .
BOULDER . COLO~AOO SPRINGS
DENVER TECH CENTER
BILLINGS. BOISE
CHEYENNE. JACKSON HOLE
SALT LAKE CITY" .
SUITE 3200
555 SeVENTeENTH STREET
DENVER, COLORADO 80202.3979
MAILING ADDRESS
P.O. BOX 874"
DENVER, COLORADO 80201-87<48"
TELEPHONE (303) 285-8000
FACSIMilE (303) 295-8281
HARRy SHULMAN
970.925.3476
hshulmanCDhollandhart.com
April 3, 1998
VIA HAND DELIVERY
John Worcester, Esq.
Aspen City Attorney
130 S. Galena Street
Aspen, CO 81611
Re: . Bell Mountain Townhome Appeal Rights
Dear John:.
Bell Mountain LLC ("Bell Mountain") was scheduled to go before the Design Review,
Appeal Board on March 12, to appeal staff's finding that Bell Mountain's townhome land use
applicatiOll' was'inconsistent with two provisions in the Residential Design GUidelines;-
Inunediately prior to that appearance, Mitch Haas removed Bell Mountain from the Design
Review Appeal Board agenda, apparently on grounds of advice from you. We have reviewed the .
applicable code provisions; and do not understand whatthe basis of such advice could.be.c We
therefore request clarification from you.
As far as We can See, there are only two land uSe provisions which could apply to this
issue, and both permit the appeal Bell Mountain seeks. Section 26.58.020 B.l of the Aspen Land
Use Regulations is the first of these, and is particularly clear. It provides: "If an application is
found to be inconsistent with any item of the Residential Design Guidelines the applicant may
either amend the application or appeal staff's finding to the Design Review Appeal Board
pursuantto Chapter 26.22, Design Review Appeal Board". Staff found thatBell Mountain's
application is inconsistent with two items in the Residential Design Guidelines. Bell Mountain
wishes to exercise its right to appeal that finding to the Design ReviewAppeal Board. Such
appeal is clearly and explicitly authorized by Section 26.58.020 B.l.
The other applicable code section, 26.58.10 B., states: "All residential development in the
City of Aspen requiring a building permit from the City of Aspen, except for residential
development in the R-15B zone district, shall comply with the residential design standards as
specified in the Administrative Checklist, unless otherwise granted a variance by the Design
Review Appeal Board as established in Chapter 26.22, or unless granted a variance through some
other required review process by the Historic Preservation Commission, the Board of Adjustment
or the Planning and Zoning Commission." Again, Bell Mountain has elected to seek the variance
from the Design Review Appeal Board, as expressly authorized by the ordinance.
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HOlLAND & HARTLLP
ATIORNEYSATLAW
John Worcester, Esq.
April 3, 1998
Page 2
The only potential basis we can think of for your ruling on the issue is that you want the
issue to proceed in only one forum, and you have determined that forum is P&Z. We can
understand why you might rule this way. We believe, however, that there are certain facts which
you may not have known in deciding how to treat Bell Mountain. First, Bell Mountain did not
request to be heard by P&Z. The City unilaterally consolidated the variance issue with Bell
Mountain's other applications before P&Z. Second, during the hearing on Bell Mountain's
applicatiens,P&Z decided to take 110 actioll.on the variancC'.issue. This is reflected. in Reselution .
98-3. Thus, Bell Mountain's variance request was (a) involuntarily consolidated with other
matters before P&Z, and (b) then sidestepped. P&Z cannot be the forum for resolving the
variance issue when it has expressly determined not to do so. Bell Mountain objects to going
back before P&Z on the variance issue, and asserts its right to proceed before the Design Review
Appeal Board, in accordance with 26.58.020 B.l.
Importantly, it cannot be denied that proceeding before the Design Review Appeal Board
is Bell Mountain's right. There is no provision in the City's Common Development Review
Procedures (Chapter 26.52 of the Land Use Regulations) which requires consolidated processing
of an application. Throughout Chapter 26.52, the procedures provide that applications "may" be
consolidated. If Bell Mountain chooses not to consolidate and to proceed on the variance issue
before the-Design Review Appeal Board, it is permitted to do so. Bell Mountain made exactly
this choice. David Gibson, Bell Mountain's architect, submitted the variance request to Mitch
Haas on February 4. In this submission, Mr. Gibson did not request hearing by P&Z. Assignment
to P&Z was an administrative decision made by the staff, and not a request by Bell Mountain.
Bell Mountain should not be required to proceed in a forum which it did not choose, and which
has already indicated it will not decide the variance issue.
We therefore request that you issue a written statement as to the basis of the
determination to preclude Bell Mountain from appealing staff's inconsistency findings to the
Design Review Appeal Board. Alternatively, We request that you instruct Mitch Haas to
reschedule Bell Mountain on their agenda.
Thank you.
cc: Jim Valerio
Alan Riclunan
Stan Clauson
Mitch Haas
Nick McGrath
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MEMORANDUM
TO:
The Design Review Appeal Committee ~/
Stan Clauson, Community Development Direc r cr
Julie Ann Woods, Community Development De ty Directo, . .
Mitch Haas, Planner.~
Bell Mountain Townhomes request for Variances to the "Building Elements"
(Section 26.58.040(B)(I)) and "Volume" (Section 26.58.040(F)(l2))
provisions of the Residential Design Standards
THRU:
FROM:
RE:
DATE:
March 12, 1998
SUMMARY: Pursuant to Chapter 26.58, Residential Design Standards, Section
26.58.020(B), of the Aspen Municipal Code, "an applicant shall prepare an application for
review and approval by staff In order to proceed with additional land use reviews or obtain
a Development Order, staff shall.find the submitted development application consistent with
the Residential Design Guidelines." This Section goes on to state that "if an application is
found to be inconsistent with any item of the Residential Design Guidelines the applicant
may either amend the application or appeal staff's findings to the Design Review Appeal
Board [DRAC] pursuant to Chapter 26.22, Design Review Appeal Board. "
Community Development Department staff reviewed the application to construct a multi-
family structure on the site ofthe Bell Mountain Lodge for compliance with the "Residential
Design Standards," (see Exhibit A). In staffs review, it was determined that the proposed
designs violate both the "Building Elements" standard and the "Volume" standard. Thus, the
applicant is requesting variances from the "Building Elements" and "Volume" standards
(described below) in order to allow for approval of the architectural designs as proposed.
See Exhibit A, letter from Gibson-Reno Architects requesting variances from the
requirements of Ordinance 30.
Pursuant to Section 26.22.010 of the code, an appeal for exemption from the Residential
Design Standards may be granted if the exception would: (I) yield greater compliance with
the Aspen Area Community Plan; (2) more effectively address the issue or problem a given
standard or provision responds to; or, (3) be clearly necessary for reasons of fairness related
to unusual site specific constraints.
APPLICANT: David F. Gibson of Gibson Reno Architects on behalf of the Bell
Mountain Limited Liability Company.
LOCATION: The site in question is located on the n,9rtheast comer of Spring Street and
Cooper Avenue in downtown Aspe!).. Surroundinll: structure" include th" RIl~khnm T nngp tn
the east. the Chateau Aspen to the west. the Aspen Square building to the southwest, City_
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Market and the Durant Mall to the south, the Hannah Dustin building and an A-frame
. structure to the north, and the Benedict Commons to the northeast.
STAFF,fR~l\l.EJS'TS: /~ t.Je tf8l1~ 71j6S,.C:
~ TuJeJ V~I.fl-lC8l he2tU~--rs" <- o;.fe ffT -4 7(fitG; S1l(I!;T7;J(j ~
Section 26.58. 040(B) (1), Building Elements '
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.The "Building Elements" standard mandates that "all residential buildings must have a one-
<tory street facinf! element the width of which comprises at lemt twpnl;V (7.~), vercent qf the
buildinf!'s overall width." According to the pending revisions to the Residential Design
- .
Standards, the intent of the "Building Elements" provisions' "is to ensure that each
residential building has street-jacing architectural details and elements which provide
human scale to the facade, enhance the walking experience, and reinforce local building
traditions."
The above described intent of the "Building Elements" provision explains the issue or
problem to which the standard is a response. Since the proposed design does not vield
greater compliance with the Aspen Area Community Plan, if the requested variance is to be
- justified. it would need to be on the grounds that the proposed design is necessary for reasons
of fairness related to' unusual site specific constraints. or thM th" proposed design more
effectivel ....r~vides str e -' 'tectural details and elements which rovide human
scale to tl\. facade, enhance the walking experience, and reinforce local building traditions
than would a design that meets the exact letter of the "Building Elements" standard.
Staff feels that the proposed design. witj)..;~"""@'"l i.;::',,_<~'V" C"l,~ 'bI;l'_,ll~,jfn.1e-
~~~ 1\4;<ff~ combined with the proposed landscape plan
and walkways more effectively provide street-facin architectural details and elements
which rovide uman scale to the facade, enhance the walkin ex erience and reinforce
local building traditions than wou a eSl~n that meets the exact letter of the "Building
elements" standard. In addition, staff feels that the site's location on the edge of the
90mmercial core is more conducive to Ilreater vertical massing than are the traditional
residential areas, and that this location represents'ltsite specific condition that would render
the variance appropriate for reasons of fairness. In accordance with this assessment, staff
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finds sufficient justification to recommend approval of the requested variance from the
"Building Elements"provision of the Residential Design Standard.
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Section 26.58.040(F)(J2), 0 ume
The proposed design contains multiple violations of the "Volume" standard lease refer to
the etter and graphic from Gibson-Reno Architects, included with Exhibit A). The standar
reads as follows:
For the purpose of calculating floor area ratio and allowable floor area for a
building or portion thereof whose principal use is residential, a determination
shall be made as to its interior plate heights. All areas with an exterior
expression of a plate height of greater than ten (JO) feet, shall be counted as two
(2) square feet for each one (1) square foot of floor area. Exterior expression
shall be deflned as facade penetrations between nine (9) and twelve (J 2) feet
above the level of the finished fioor, and circular, semi-circular or non-
orthogonal fenestration between nine (9) and fifteen (15) feet above the level of
the flnished floor.
Simply put, as it relates to the subject case, tbis standard requires that there be no windows
(facade penetrations/fenestration) jn any areas that lie between nine (9) and twelve (12) feet ,
above the height of the first or second stOry floors (plate height). As proposed, each Ofthe~'
four elevations contain at least one violation of the "volume" standard (for exact locations 0
these violations, please refer to the letter and graphic from Gibson-Reno Architects, included
with Exhibit A).
Given the lack of compliance with the "volume" standard, the applicant is left with the
choice of pursuing one of the following three (3) options. First, the applicant could accept
the two-to-one (2: 1) floor area penalty while ensuring that the entire building, including FAR
penalties, would faU within set FAR limitations. Second, they could redesign the proposed
structure such that the new form would comply with the "volume" standard, as well as the
rest of the residential design standards. Lastly, the applicant could appeal staff s findings to
the Design Review Appeal Board.
Rather than accept the floor area penalty (the design utilizes all but twenty square feet of the
aUowable floor area for the site) or redesign the proposed residence, the applicant has chosen
to seek a variance from the "volume" standard. Consequently, if variances are not granted,
the applicant would have to create new designs that would comply with the volutne standard.
If a variance is to be granted, it must be justified according to one of the three variance
criteria outlined above (on page one ofthis memo).
According to the pending revisions to the Residential Design Standards, the purpose of the
"Volume" standard, like the "Building Elements" standard, "is to ensure that each
residential building has street-jacing architectural details and elements which provide
human scale to the facade, enhance the walking experience, and reiriforce local building
traditions." Although pending code amendments do not hold any forCe in the review of
current applications, it may be informative to note that the pending revisions to the
Residential Design Standards recommend changing the "Volume" standard to read as
3
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follows: "Street facing windows shall not span through the area where a second floor level
would typically exist, which is between nine (9) and twelve (12) feet above the finished first
floor." This proposed language is intended to implement the above-stated purpose of the
standard.
~
The above described, intent ofthe "Volume" standard explains the issue or problem to which
the standard is a response. ~ince the proposed design does not yield greater compliance with
the Aspen Area Community Plan and is not necessary for reasons of fairness related to
unusual site s ecific constraints, if the re uested variance is to be justItJed, It would need to
be on the rounds that the proposed design more e ectIvely vides street- acmg
a c s w VI an s t e
~ng e~{;perienc"", a.lld F\~infnrr.e harrwould aJ~;:)ign tlli:lllUeets.
e e s
Staff does not feel that the proposed glazing interferes with the ability of the architecture to
accomplish the intent of the "Volume" standard. Furthermore, staff finds that many, or
indeed most, of the windows for which a variance is required, would not violate the proposed
revision to the "Volume" standard since most of the violating windows are not on the first
story and none of the violating- windows f~ appear to SPa.n through the
area where-a second floor would typic.llv exist. Sta els that the ro osed design, with its
'garden level, one-story entrances, human-scale' doors and first floor decks (above gar en
level) c()mbined with the proposed landscape plan and walkways effectivel rovides street-
facin . ectural details an e ements w IC provide human scale to the facade, enhance
the w.lking: experience, and reinforce local building traditions. In accordance wi is
assessment, staff finds sufficient justification to recommend approval of the requested
variance from the "Volume" provision of the Residential Design Standards.
RECOMMENDATION: Staffrecommends that the DRAC approve: (1) a variance from
Section 26.58.040(B)(1), Building Elements, of the Residential Design Standards based on a
finding that the proposed design more effectively addresses the issue or problem the given
standard or provision responds to, and is necessary for reasons of fairness related to site
specific considerations; and, (2) a variance from Section 26.58.040(F)(l2), Volume, of the
Residential Design Standards based on a finding that the proposed design more effectively
addresses the issue or problem the given standard or provision responds to.
ATTACHMENTS:
Exhibit "A"- Submitted application package
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February 23, 1998
Mr. Mitch Haas
Community Development Department
130 S. Galena Street
Aspen, Colorado 81611
RE: Bell Mountain Townhomes
Dear Mitch:
We wish to present the design of the Project to the Design Review
Architectural Commission.
We seek relief from two requirements of the Ordinance 30 design
guidelines, to which We do not presently conform: I.) The "Volume"
requirement, which proscribes glazing between 9' and 12' above the
floor, and, 2.) The "inflection" requirement which requires a one-story
element along 20% of the street frontage.
We feel that the mass and scale of the design on this central core site
addresses these issues in the overall design, and we wish to have the
opportunity for the Commission to review the design with us.
P;K~
David F. Gibson, AIA
attachments
cc: A. Richman
haas223.1tr
~,
DAVID
GIBSON
AlA
AUGUST
RENO
AlA
SCOTT
SMITH
AlA
GIBSON. RENO
-ARCHITECTS, L.L.C,'
III
210 E, HYMAN
NO 202
ASPEN
COLORADO
81611
970.925.5968
fACSIMILE
970.925.5993
P.O. BOX 278
117 N. WILLOW
N"2
TELLURIDE
COLORADO
, 81435
970,728.6607
fACSIMILE
970.728,6658
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