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HomeMy WebLinkAbout10/15/1991 MEMO TO: Honorable Mayor and City Council FROM: Dennis R. Kraft, City Administrator RE: Non-Agenda Informational Items DATE: October 11, 1991 1 . Attached is memorandum from the City Attorney regarding NBZ Brief. 2 . Attached are the September 18, 1991 minutes of the Scott County Economic Development Coalition. 3 . Attached is the Police Newsletter for Council review. 4 . Attached are the unapproved minutes of the September 18, 1991 Community Development Commission meeting. 5. Attached are the September 9th, 16th and 30th, 1991 minutes of the Shakopee Public Utilities Commission meetings. 6. Attached is correspondence from the Minnesota Department of Health regarding the results of water samples collected on June 5, 1991 from city wells. 7 . Attached is the Building Activity Report for September. 8 . Attached is a memorandum from the Finance Director regarding Riva Ridge Industrial Revenue Bonds. 9 . Attached is the Program Costs by Department Report as of October 8 , 1991 . 10 . Attached is the Revenue and Expenditure Reports as of September 30, 1991 . 11 . Attached are the recommendations for 1992 Legislative Policy from the committees of the AMM and Board of Directors. Please review. 1 MEMORANDUM TO: Mayor and Members of the City Council FROM: Karen Marty, City Attorney DATE: October 9 , 1991 RE: NBZ Brief Per your request, I am sending you copies of the NBZ brief and the City' s brief. These have been sent to the trial judge to assist him in reaching his decision. You will notice a significant difference in the way NBZ and I approach a brief. NBZ seems to think the best defense is a strong offense, and has adopted what I privately call the "foaming at the mouth" approach. Much of their brief is devoted to criticizing and belittling the City. My approach is aimed at providing the calm voice in the wilderness, and to reflect the professional attitude of the City. I deal with the issues, the law, and the facts. After all, this is a matter in court, and not a shouting match between children. I believe our position is legally correct, and I believe that our professional, legalistic approach is more persuasive than an emotional approach. This letter is protected by the attorney-client privilege, and should not be distributed to the public. The briefs, however, are public documents, and you should feel free to deal with them as you like. If you have any questions, please let me know. Signed = Y (7%/e/ Karen Marty, City Attorney KEM:bjm [NBZMEMO] Attachments cc: Dennis Kraft 10 - OTHER CIVIL STATE OF MINNESOTA DISTRICT COURT COUNTY OF SCOTT FIRST JUDICIAL DISTRICT NBZ Enterprises, Inc., the successor in interest of Scott County Lumber Company and Bert Noterman; Moon Valley Aggregate, Inc., a/k/a G & T Trucking, Inc., Plaintiffs, PLAINTIFFS' POST-TRIAL BRIEF vs. Court File No. 91-09739 City of Shakopee, Defendant. INTRODUCTION On April 5, 1988 under court order, the Shakopee City Council issued Conditional Use Permit No. 376 ("CUP") on the property owned by NBZ Enterprises, Inc. ("NBZ"), the successor in interest of Scott County Lumber and Bert Noterman. (Plaintiffs' Exhibit 1). The property is located on the west side of Scott County Road 83 and 1-1/4 mile south of its intersection with Scott County State Aid Highway 16 ("Property"). The City of Shakopee ("City") admits that, consistent with this Court's finding, "processing" is a permitted use on the Property. [Testimony of City Administrator,Dennis R.Kraft("no doubt"that processing is permitted on the Property); Testimony of City Planner, Lindbergh S. Ekola ("no dispute that some processing allowed")]. Therefore, as previously determined by this Court,the sale 419664 1 issue in this proceeding is 'whether or not a ready-mix plant is in fact a processor of materials." (Order and Memorandums dated August 21, 1991). In their Trial Brief plaintiffs extensively addressed the issues in this case and analyzed the applicable law. All of that argument will not be repeated here. Instead the Court is referred to the Trial Brief as an introduction to the discussion in this Brief. STATEMENT OF FACTS A. Plaintiffs' Ready-Mix Operation Constitutes "Processing". Plaintiffs presented the uncontroverted testimony of three experts of unparalleled distinction and experience in the ready-mix, aggregate processing industry. Each testified that a ready-mix operation was in his opinion a processor of aggregate. Joseph L. Shiely III has spent his lifetime in the aggregate business. Shiely was an owner and chief officer of the prominent Twin Cities metropolitan aggregate and concrete operation, the J. L. Shiely Company. Shiely was the third generation of his family to own and manage the gravel and ready-mix business. Shiely testified regarding a sand and gravel extraction and processing operations. He explained that ready-mix is "part of the same processing." Shiely described the ready-mix operation as a"continuum" from the sand and gravel extraction process. Additionally, Shiely opined that the greatest intensity of use in this continuum is the mining and crushing of the rock; these steps in the process impart the "preponderance of effect on [the] minerals." Shiely reinforced his point by noting the significantly greater time allocated to the mining and crushing operation compared with the time allocated to the ready-mix operation. Moreover, the mining of gravel forever changes the land surface. Shiely further 419664 2 distinguished manufacturing of concrete products, i.e. cinder block, from ready-mix as "not as closely affiliated" with washed aggregate. Finally, Shiely established that there were no adverse environmental impacts associated with ready-mix processing in the gravel mine. In fact, such a processing operation would have a beneficial effect on traffic by reducing its volume. Mathias Fischer owns and operates the Twin Cities' second largest ready-mix operation. Fischer has 46 years of experience in the aggregate mining and processing business. At trial, Fischer repeated his expert testimony previously given at the City Council hearing of August 20th. In Fischer's unrefuted expert opinion, a ready-mix operation is processing. Fischer emphasized that a ready-mix operation has been defined and regarded as processing within the sand and gravel context "since I can remember." Fischer reiterated that the ready-mix operation is significantly less time and - equipment intensive than the preparation of the aggregate in the extraction process (mining, screening, crushing and washing). Fischer also confirms that there was no adverse environmental impact from a ready-mix plant. Fischer's testimony included a video tape of a typical ready-mix plant. This tape demonstrated the minimal impact of the operation and its lesser intensity to gravel processing operation up stream of the ready-mix plant. Garwin McNeilus, a competitor of Fischer's in the ready-mix business, gave further expert testimony. McNeilus is a large aggregate and ready-mix producer in Southern Minnesota. Beside his vast experience in processing sand and gravel and making them into concrete, McNeilus designs and manufactures ready-mix equipment. With a life time in the 419664 3 sand and gravel and ready-mix business, and as the world's largest manufacturer of ready-mix processing equipment, it is difficult to imagine a more qualified expert witness. McNeilus opined that ready-mix operations are defined by the industry as "processing." McNellus' opinion must be afforded considerable weight because of his experience and position in the industry. There are few people in the world who know as much about making ready-mix concrete as Garwin McNeilus. McNeilus absolutely refuted • the City Administrator's characterization of the ready-mix operation as involving greater intensity than the sand gravel extraction operation already occurring on the property. McNeilus explained that sand and gravel extraction requires end loaders,conveyors, crushing and washing, all of which cost ten times more than is involved in a ready-mix operation. Furthermore, these operations take more time and have a greater impact on the materials, and the surrounding environment than the mere addition of cement and water and the mixing with aggregate in order to make concrete. The City presented no contrary definition of "processing" from a qualified expert. Instead, the City relied on the incompetent, unqualified and confused testimony of two City officials: City Administrator, Dennis R. Kraft, and City Planner, Lindbergh S. Ekola. Neither Kraft nor Ekola has any expertise in the aggregate or ready-mix concrete processing business. Nonetheless, they gave "opinions" about an operation about which they had little knowledge and no understanding. Between the two they have been in less than ten sand and gravel operations and neither professed to have more than a rudimentary appreciation of - the equipment involved in sand and gravel extraction and ready-mix processing. 419664 4 In addition to their incompetence, Kraft and Ekola were inconsistent and confused. Ekola was unable to determine whether there were three permits on the Property or two permits. In his initial direct testimony Ekola emphatically stated that there were three permits — a CUP, a Mineral Extraction and Land Rehabilitation Permit and a Mining Permit After being worked on over the noon hour break by the City Attorney, Ekola had a revelation that there were only two permits. How can the testimony and opinions of a regulator be taken seriously when either he can't count to three, or he can't figure out without woodshedding from the city attorney how many permits he is charged with enforcing. In addition, Ekola admitted that he has no previous experience regarding the permitting and regulation of this type of land use. Ekola is an unexperienced young planner fresh out of school in North Dakota before coming to his position in Shakopee. For a short time, Ekola held a low level position in the Phoenix planning department. While in Phoenix, Ekola had no involvement in regulating gravel processing. By his testimony in this case, Ekola demonstrated that he still has a lot to learn. Besides its incompetence, the City's case was undermined by its contradiction of itself. For example, Kraft and Ekola gave opposing views about whether crushing and washing had been approved on the Property, and they offered contrary definitions of "processing". Nevertheless, both City officials testified that, from their respective capacities, a ready-mix operator does not constitute processing. The basis of their testimony appeared to be three- fold. First, both City officials erroneously testified that ready-mix is inconsistent with the Property's agricultural zone simply because ready-mix operations are a conditionally 419664 5 permitted use in the City's heavy industrial (I-2) zone. From this Ordinance provision, § 11.33, Subd. 3, the City argues that the ready-mix process operation can not be otherwise permitted in the agricultural (A-1) zone. Ready-mix is not a separately and specifically mentioned use in the A-1 Zone, but it is so mentioned in the I-2 Zone. Therefore, the City concludes without rationale or logic that ready-mix can not be allowed in the A-1 Zone. i -' [Compare Shakopee Zoning Ordinance ("S.Z.O.") § 11.33, Subd. 3 (G) with S.Z.O. § 11.24; Plaintiffs' Trial Exhibit 4]. Kraft, however, acknowledged that nothing in the Shakopee Zoning Ordinance specifically prohibits ready-mix operations in an agricultural zone. And, - the Shakopee Zoning Ordinance no where states that the provision for a CUP in one zone • bars such use in all other more restricted zones. (Testimony of Kraft). ,'%✓` Moreover, consistent application of the City's argument to plaintiffs' Property would bar the plaintiffs' rock crushing operation. "Rock crushing or gravel work" is a conditionally permitted use in the I-2 Zone. (S.Z.O. § 11.33, Subd. 3(F)). Nevertheless, the crushing operation has existed on the Property since 1989. Crushing has never been objected to by the City, and the continuation of crushing was specifically approved by the City this Spring. Like "ready-mix plants," rock crushing is not specifically permitted in the agricultural zone. Both City officials testified that rock crushing constitutes "processing" and the agricultural zone conditionally permits only"mining." (S.Z.O. § 11.24, Subd. 3(H)). Mining is specifically defined as sand and gravel extraction "without processing." (S.Z.O. § 11.02(82)). The conditionally permitted use is "Mining." Therefore, the rock crushing land use, which is not claimed to violate plaintiffs' permits, must be authorized by plaintiffs' second permit, the Mineral Extraction and Land Rehabilitation Permit. That permit allows processing, 419664 6 including crushing. There is no reason to conclude that the Gravel Extraction permit does not allow ready-mix processing. Like rock crushing, ready mixing is processing. Ancl like crushing, ready mixing is a conditionally permitted use in the I-2 Zone. Therefore, ioke crushing, it is permitted processing pursuant to plaintiffs' Mineral Extraction and Land Rehabilitation Permit. Second, the City officials rely on their admittedly "quite limited" background in the field to define "processing" as "aggregate extraction," thus excluding ready-mix operations. This narrow interpretation of "processing" is internally inconsistent. It relies upon the Shakopee Zoning Ordinance definition of "mining" which has been specifically defined as extraction "without processing." (S.Z.O. §11.02(82). But processing is repeatedly provided for and anticipated in the Mineral Extraction and Land Rehabilitation Permit and the applicable Ordinance provisions. (See S.Z.O. § 11.05, Subd. 7(C)(6) and (C)(8).' The City's narrow interpretation of"processing" is not consistent with the course of dealing between the parties to the CUP. The plaintiffs have conducted and the City has approved other "processing" operations on the Property, i.e. crushing and washing. Since the actions of both parties demonstrate that processing is permitted, there must be a rational basis related to the public health, safety and welfare to distinguish between crushing and ' , ready-mix operations. No such distinction exists. Therefore, both processing operations ` i"`-'. must be allowed. 1 The City's admitted practice of not drafting a separate document when issuing a Mineral Extraction and Land Rehabilitation Permit (see Plaintiffs' Trial Exhibit 2) has effectively deemed the City's Mineral Extraction and Land Rehabilitation Ordinance as the ' Permit on the Property. 419664 7 Ekola attempted to bridge the inconsistency by testifying that crushing and washing were never permitted on the Property and that he was unaware of the existence of these operations. Ekola adopted this position despite admitting that he drafted the map for plaintiffs' CUP amendment application. This map included the"WASH PLANT."(Plaintiffs' Trial Exhibit 26). Ekola also acknowledged that the application for the 1991 Mineral Extraction and Land Rehabilitation Permit specifically describes"crushing"and "washing" as requested uses on the Property. (Plaintiffs'Trial Exhibit 8). Plaintiffs have openly operated the crusher since 1989 and the wash plant since 1990. (Testimony of Bert Noterman and Tom Zwiers). At no time has the City objected to those operations and Kraft's testimony on this point contradicted Ekola's. When called by plaintiffs in their case in chief Kraft stated that the crushing and washing operation were permitted processing. Moreover, the proceedings that lead up to the CUP revocation never cited any violations related to the plaintiffs washing and crushing. Certainly, the City would have claimed that these activities violated the CUP in support of its claim that substantial and repeated permit violation occurred. Since the-City did not rely upon those grounds in revoking the permit, such processing is authorized by the applicable permits. Kraft also unsuccessfully attempted to address the inconsistency of his narrow interpretation of "processing." While Kraft conceded that the City approved the operation of the crusher and wash plant on the Property, he argued that the intensity of the ready-mix operation distinguishes the ready-mix operation as manufacturing; rather than processing. Kraft could not articulate what caused ready-mix operations to be a more intensive land use on the Property than the existing mining, crushing, screening and washing processes. Kraft's 419664 8 inability to explain why ready-mix processing was more intense probably stemmed from his ignorance about the fundamental operations and the equipment involved. Its easy to say one process is more"intense" than another process if you don't have a clue what your talking about. Kraft's uninformed and unknowledgeable testimony about process intensity is belied by the parade of eminently qualified experts offered by plaintiffs. Those experts know the business, the equipment and the operation. Their testimony established that ready-mix processing is not more intense than mining and crushing. The single factor that Kraft noted to distinguish ready-mix processing was the inclusion of cement in the operation. Yet, cement is a natural material that is made from :-f- ground limestone. Furthermore, cement constitutes less than 10 to 12% (by weight) of .: 1' • - ready-mix concrete. (See Testimony of Shiely). Finally, each of the experts on processing identified the most intensive steps in the processing operation to be the mining and crushing. (See Testimonies of Shiely, Fischer and McNeilus). The addition of cement to the process, in the experts' opinions, did nothing to make the operation more intense or create an adverse environmental impact. In fact,Shiely testified that mining and crushing represented the "preponderance of the effect on [the] minerals." This conclusion is supported by the relative time allocated between the mining, screening, crushing and washing processes compared with the time required for the ready-mix operations. As the third basis for concluding that the ready-mix operation does not constituting "processing," the City officials contend that the definition of processing is controlled by the Merila Plan submitted in the original CUP application on the Property on April 30, 1985. (Defendant's Trial Exhibit 2). The Merila Plan, however, does not form the basis of the 419664 9 Mineral Extraction and Land Rehabilitation Permit. More importantly, using the Merila Plan to limit the plaintiffs'use of the Property would unjustly reward the City for its arbitrary and legally insufficient denial of plaintiffs' CUP application in 1985. The Merila Plan is referred to in CUP Condition No. 17. Condition 17 states that plaintiffs' plan for operation report shall be adopted as the "Mining Permit." While the Mining Permit, as a condition precedent to the CUP, was necessarily issued prior to or contemporaneous with the issuance of the court ordered CUP, no reapplication or renewal of this permit has ever been sought. In contrast, CUP Condition No. 2 requires the issuance of the Mineral Extraction and Land Rehabilitation Permit. That permit was reapplied for and reissued this Spring. (See Plaintiffs' Trial Exhibits 8 and 14). The Mineral Extraction and Land Rehabilitation Permit, issued pursuant to Condition No. 2, rather than the Mining Permit issued pursuant to Condition No. 17, controls the processing which is permitted on - the Property. The Mineral Extraction and Land Rehabilitation Permit was issued pursuant to §11.05, Subd. 7 of the Zoning Ordinance. That provision of the Shakopee Zoning Ordinances permits and regulates aggregate processing. (See S.Z.O. §11.04, Subd. 7(C)(5) and (6)). "Mining" on the other hand, as defined by the Shakopee Zoning Ordinance does not include processing. (See S.Z.O. §11.02(82)). Hence, the "Mining Permit" must govern and involve something other than plaintiffs processing operations. The processing operations are subject to the Mineral Extraction and Land Rehabilitation Permit. Nothing in that permit or in §11.05, Subd. 7 of the Zoning Ordinance prohibits ready-mix processing. Plaintiffs, therefore, must be allowed to exercise 419664 10 all rights and engage in all land uses that are authorized by the three permits that the Court of Appeals ordered to be issued for plaintiffs' land. In any event, the Merila Plan cannot be construed as barring plaintiffs' ready-mix operation. Kraft relies on the single line from the Merila Plan's cover letter: "[t]here is no intent to mix asphalt or concrete." (Emphasis added). That 1985 intent, however, does not bar a ready-mix operation on the Property in 1991. This Court cannot accept such a vacuous reading of this document. The Merila report was prepared at the request of C. S. McCrossan Construction Company. When Merila wrote the report, McCrossan was the general contractor for the construction at Canterbury Downs. (Plaintiffs' Trial Exhibit 21; testimony of Noterman). McCrossan made the application for the permits because it needed gravel for Canterbury Downs. At the time of the application, the owners of the Property anticipated McCrossan setting up ready-mix and asphalt plants at the Canterbury Downs site. ` That construction site was located less than 1-1/4 miles away. (Id.). Due to the proximity of these processing operations and McCrossan's demand for aggregate at the race track, McCrossan did not then intend to site a ready-mix plant in the gravel pit. In 1985, the Canterbury Downs project provided a site for the ready-mix processing operation, and it created a unique and short-term demand for the gravel. The Canterbury processing site and gravel demand is gone, but there is not doubt that the Merila report referred to and anticipated a processing operation on the Property. The window of opportunity to sell sand and gravel to and process it at Canterbury Downs was available to plaintiffs but for the City Council's "arbitrary and capricious" denial of its CUP. Scott County Lumber Co. v. City of Shakopee, 417 N.W.2d 721, 729 (Minn. Ct. 419664 11 App. 1988). When the City illegally denied plaintiffs' CUP application in 1985, the construction of Canterbury Downs proceeded without plaintiffs'gravel. McCrossan finished its work in Shakopee, and there is now neither a demand for gravel at Canterbury nor the opportunity to site a ready-mix plant there. Unfortunately, however, the record of the case became fixed after the City's illegal actions and as the litigation proceeded. When the Court of Appeals finally ordered the City to issue the permits in 1988, time and circumstances had changed in Shakopee. When they finally got their permits, plaintiffs could no longer take advantage of the demand that the Canterbury Downs project created for their aggregate. Along with the lost opportunity to sell gravel to Canterbury Downs went the rationale for the 1985 "intent" not to mix concrete at the site. Consequently, it would be unjust to now reward the City for its arbitrary denial of the CUP by fixing in time a restriction tied to an opportunity the City unlawfully foreclosed. Since the Court can not recreate the construction at Canterbury Downs, it should not impose an "intent"that was only applicable and relevant to a situation and an opportunity that the City illegally denied plaintiffs from pursing. Moreover, literal construction of the Merila Plan would also contradict the City's interpretation of the permitted uses on the Property as established by the course of dealing between the parties since 1988. The City has knowingly permitted and expressly approved washing on the Property despite the exclusion of that activity under a literal interpretation of the Menla Plan. (Testimony of Ekola; see Defendant's Trial Exhibit 2; Plaintiff's Trial Exhibits 8 and 14). As time changed, the permitted uses on the property have changed and grown within the ultimate land use permitted by the various permits. A ready-mix operation, 419664 12 like crushing and washing, involves the expanded processing uses customary to sand and gravel extraction. Just as crushing and washing are allowed processing pursuant to the permits, so is a ready-mix plant. Finally, since the Mineral Extraction and Land Rehabilitation Permit was reapplied for and reissued in May of 1991, the Merila Plan is no longer relevant or applicable. As noted above and established by the clear language of the CUP, the Merila Plan related to the Mining Permit, not the Mineral Extraction and Land Rehabilitation Permit. Pursuant to the CUP Condition No. 1 and the applicable Ordinances (S.Z.O. §11.05, Subd. 7(A)), the CUP and the Mineral Extraction and Land Rehabilitation Permit must be reapplied for every three years. The Mining Permit has never been reapplied for nor has the City t • required any action on that permit. The other permits, however, were reissued in 1991. But '` ;,,, _ neither the 1991 application for a renewed CUP nor the application for a new Mineral Extraction and Land Rehabilitation Permit(see Plaintiffs'Trial Exhibits 8 and 9) relied upon or referred to the Merila report. In fact, the Mineral Extraction Permit application specifically describes the operation as follows: "Mining, crushing, washing and processing aggregates." (See Plaintiffs' Trial Exhibit 8). The City issued the Mineral Extraction and Land Rehabilitation Permit based upon plaintiffs' 1991 application and without reference to the Merila Report. (See Plaintiffs' Trial Exhibits 14,May 9. 1991,Planning Commission Minutes at 4). Therefore, since at least the Spring of 1991, the "intent" and restrictions of the Merila Report are no longer relevant and they no longer apply to plaintiffs' permitted land uses. Even if Condition 17 and the Merila report precluded the mixing of concrete, with their 1991 applications to the City, 419664 13 plaintiffs abandoned that intent and revised their described uses to meet the conditions of 1991. Since the Spring of 1991, plaintiffs intended to process aggregate into ready-mix concrete, and the Mineral Extraction Permit issued in May 1991 permits such processing. B. Plaintiffs' Ready-mix Processing Plant is a Permitted Accessory Use. To further emphasize the permitted status of plaintiffs' ready-mix operation on the Property,plaintiffs presented the testimony of experts who established that a ready-mix plant is a permitted accessory use to a sand and gravel extraction operation. These experts also demonstrated that there was no additional adverse environmental impact from a ready-mix operation. Thus, such processing use was not inconsistent with a sand and gravel extraction operation on agriculturally zoned property. R. K. Hoagberg, an environmental geologist previously recognized by the Minnesota Court of Appeals as "an expert in Minnesota's gravel needs and resources," Scott County Lumber, 417 N.W.2d at 727, presented data evidencing the number of ready-mix operations at or near aggregate extraction sites. (Plaintiffs'Trial Exhibit 23). Hoagberg's data showed that over 55% of ready-mix plants in the metropolitan area are in presently active or once active sand and gravel extraction pits. The data further evidenced that over 65% of hot mix plants in the metropolitan area are sited in presently active or once active pits. Finally, Hoagberg established that the significant majority of the gravel operations in the metropolitan area have either a ready-mix or hot mix processing operation in them. Therefore, a ready-mix operation is without question customarily incidental to a gravel extraction operation. Hoagberg also testified that there was"no environmental impact"from a ready-mix operation. Hoagberg dismissed as "inconsequential" any adverse impact from 419664 14 the one-half to three-quarter of 1% organic mixtures in ready-mix. These natural materials are easily stored and controlled. And, a spill presents no threat of environmental damage. The City offers no evidence to the contrary. Shiely testified that it is "customary" and "part of normal operation" for ready-mix to be sited in a gravel pit. Shiely explained that the washed aggregate "must be incorporated to be useful" and that virtually all washed aggregate is used for malting ready-mix concrete. Shiely also demonstrated that there was no additional adverse noise impact from a ready-mix operation. Indeed a ready-mix plant is quieter than the mining, crushing, screening and washing operations that are already located on the Property. Shiely added that traffic would be at least doubled if the ready-mix operation was a separate site, necessitating two trips for every one currently required. McNeilus testified to the frequency of siting ready-mix operations in sand and gravel pits. McNeilus noted that the only pits without a ready-mix operation are where the aggregate is not of sufficient quality. According to McNeilus, ready-mix operations are an "integrated part of the total product," with the primary use of washed aggregate being for ready-mix concrete. McNeilus also concluded that no additional adverse environmental impact would arise from a ready-mix operation. McNeilus illustrated his point by citing his ready-mix operations in Rochester next to the Mayo Clinic and near a "pricey" residential area. Based upon his experience, McNeilus stated that traffic would decrease two to three times if ready-mix is allowed on the site. Finally, McNeilus described plaintiffs' portable ready-mix operation as a "low-profile plant." 419664 15 Fischer also testified that "virtually all" aggregate sites have either a ready-mix or a hot mix operation. Those pits that do not have a further processing operation are, according to Fischer, due to poor site locations. When asked whether he foresaw any additional adverse environmental impact from a ready-mix operation, Fischer stated succinctly, "none whatsoever." The absence of any noise or dust problem was evident in the video of AVR's significantly (ten times) larger ready-mix operation in Burnsville. (Plaintiffs' Trial Exhibit 20). Fischer further explained that two to three times more traffic would be created if the ready-mix operation is not permitted to operate on the Property. Fischer further noted that of his numerous ready-mix operations in the metropolitan area only one is located in an industrial zone. Finally, Gary Botzek, the Executive Director of the Aggregate Ready-Mix Operators of Minnesota, gave his expert testimony that ready-mix plants are typically found in connection with mining operations. For all practical purposes, plaintiffs' experts' testimony that ready-mix is a permitted accessory use to a conditionally permitted gravel extraction operation in an agricultural zone was uncontroverted. The City's evidence to the contrary again consists of the incompetent, non-qualified testimony, or more accurately speculation by City officials. Kraft objected to defining ready-mix operation as an accessory use to a sand and gravel extraction site by analogizing the situation to the City's allowance of cattle raising in an agricultural zone but excluding on the same site the slaughter of the cattle. Kraft's analogy fails the salient ingredient of an accessory use; namely, that slaughterhouses are not customarily incidental to cattle raising. Likewise, Ekola could only support his conclusion that a ready-mix 419664 16 operation is not an accessory use to a sand and gravel extraction operation by citing to vague recollections of some sites in Shakopee which he believed did not have a ready-mix operation. C. The City Presented Irrelevant and Unsupported Alternative Theories. Despite the Court's explicit restriction of the issue before it to be whether a ready- mix operation is processing (Order and Memorandum dated August 21, 1991), the trial witnessed the City's attempt to avoid this issue and resolve the case under alternative theories. The City put forth evidence going to two erroneous resolutions of the case: (1) that plaintiffs were time-barred from appealing the City Administrator's interpretation that ready-mix was not a permitted use; and (2) that plaintiffs' setting up of the portable ready- mix equipment violated CUP conditions and thus barred the ready-mix operation. The record going to the former issue backfires on the City, and the latter contention simply has no support in the record. 1. Plaintiffs were not Time-barred to Appeal. On June 13, 1991, the City Administrator, Dennis Kraft,wrote plaintiffs and directed them to remove the ready-mix processing plant. Kraft relied on his or his unqualified staff's "interpretation" that the ready-mix processing was not a permitted use on the Property. (Plaintiffs'Trial Exhibit 10) (emphasis added). Even though plaintiffs voluntarily elected not to operate the ready-mix plant following the City's notification,' the City Attorney, Karen To date,the ready-mix aggregate process and operation has produced only an estimated 100 yards of concrete, which is the equivalent to approximately to 1-112 hours of continuous operation. This minimal operation is attributable to initial runs to check for proper set up of the operation and subsequent periodic rims to insure continued maintenance of the equipment. (Testimony of Mathias Fischer). 419664 17 Marty, threatened in a Ietter dated July 25, 1991, to revoke the CUP if the equipment was not removed from the Property by July 31, 1991. (Plaintiffs' Trial Exhibit 11). The City Attorney's letter gave the plaintiffs "retrospective" notification that the City Administrator's June 13th letter was an appealable City determination pursuant to the Zoning Ordinance. The City maintained that the plaintiffs had 7 days in which to appeal the June 13th City Administrator's "interpretation." By the time plaintiffs were given notice of the City's position, the time for appeal had expired by over a month. The City Attorney's July 25th letter was the first and only notification to plaintiffs prior to revocation that the City Administrator's June 13th letter was, in fact, a final determination pursuant to § 11.04, Subd. 4 of the Ordinance. Plaintiffs were never given notice that Kraft's determination was appealable, or that such appeal was required within 7 days. It appears that the City's standard practice is to notify property owners in advance of a 7-day period for appeal pursuant to the Zoning Ordinance. (Plaintiffs' Trial Exhibits 12, 13 and 14). In fact, the City Administrator admitted that the City routinely notifies adversely affected property owners of the 7-day appeal period when"formal"determinations have been made. (Testimony of Kraft). By the wording of its June 13th letter and its subsequent claim that the time for appeal had expired, it is obvious that the City attempted to sucker plaintiffs into unknowingly sacrificing their due process rights. In June,the City told plaintiffs that the City "may" initiate legal action. The City never mentioned any mandatory steps the plaintiffs could, yet alone must, take to protect their rights. By July 25, however, the City was able to inform plaintiffs, chapter and verse, about the procedural rights that the City maintains 419664 18 were already forfeited. Moreover, the City Administrator failed to warn the plaintiffs of the 7-day appeal period even though he knew about the long-standing legal dispute between the parties regarding the use of the Property, including Scott County Lumber, 417 N.W.2d 721. Kraft characterized that case as a "bitter" loss for the City. (Testimony of Kraft). The City Administrator also admitted that there was an informal and cooperative course of dealing between the City regulators and the gravel operators since the Court ordered the permits to be issued. In the past the operators had come to the City to informally discuss permit issues and the City had worked with the operator on various compliance matters. For example, Ekola prepared the site map (see Plaintiffs'Trial Exhibit 26) which was used for the CUP amendment regarding security lighting at the pit. Planning staff reports and the Planning Commission minutes reveal that the operator was conscientious and responsive to the City regulatory requests. (See Plaintiffs'Trial Exhibits 5 and 7). But on June 13, 1991, the City claims that the cooperative and informal course of dealing between it and NBZ changed without notice. The City attempts to boot strap Kraft's letter from a warning that legal action "may" be initiated to a final determination or interpretation under the Zoning Ordinance, from which a formal and timely appeal must be taken. Fundamental due process prevents the City from changing the rules of the game without advising plaintiffs of their appeal rights. The injustice of the due process violation which the City attempted to wrought on the plaintiffs is underscored by the subsequent "extreme" action of the City. Despite available alternatives, such as misdemeanor prosecution, or an injunctive action seeking removal of 419664 19 the plant, the City took the admittedly "most extreme" step of revoking plaintiffs' CUP and Mineral Extraction and Land Rehabilitation Permit. (Testimony of Kraft). Curiously, prior to the July 25th notification, the City had already made preparations to revoke plaintiffs' CUP. (Plaintiffs' Trial Exhibit 16). Of course, plaintiffs were never given notice of this revocation planning. In contrast to the City's brinkmanship, plaintiffs attempted to resolve the dispute through the only available channel: this Court. The futility of going through the City's procedures had been demonstrated by the City's rejection of plaintiffs' land use proposals in 1981, 1985 and its punitive threat to revoke the permits in 1991. (Testimony of Noterman). Consequently,with the revocation issue ultimately set for public hearing before the City Council on August 20, 1991, plaintiffs brought a Motion for a Temporary Restraining Order before this Court. Plaintiffs believed in good faith that their ready-mix operation was a permitted use on the Property. (Id). Plaintiffs are also willing to disassemble the ready-mix equipment upon a judicial determination that the ready-mix operation is a non-permitted use on the Property. (Id.). But if plaintiffs are correct and a ready-mix processing operation is ultimately allowed by the courts, they should not be required to take equipment down just to avoid the City's caprice. The wasted cost of again setting up the plant are not justified and would punish plaintiffs for legally using their land. The critical enforcement issues are whether plaintiffs had a good faith belief that the ready-mix processing was permitted when they set it up; whether the plant was operated in defiance of the City claim that the plant wasn't allowed; and whether plaintiffs are willing to abide by the ultimate judicial 419664 20 determination of this matter. Each of these issues have been addressed and none support the enforcement action taken by the City. 2. The Alleged CUP Violations are not Supported by the Record. The City alleged the following violations: Condition No. 8 (failure to secure City approval for portable buildings); Condition Nos. 16 and 17 (non-compliance with submitted maps and plans); Condition No. 18 (failure to prepare an Environmental Assessment Worksheet for the ready-mix operation); and Condition No. 19 (taking action which could delay completion of the use of the Property beyond the permitted 17 years). Each alleged violation is unfounded. First, the ready-mix equipment is not a building as defined by Shakopee Zoning Ordinance, § 11.02, Subd. 12. (Plaintiffs' Trial Exhibit 4). The ready-mix processing plant does not have a "roof' and it does not "provide shelter or enclosure for persons, animals or chattel." These are the definitional criteria of"Buildings" pursuant to § 11.02, subd. 12 of the Ordinance. Therefore no building official approval was necessary. In any event, the City is estopped from claiming building approval is necessary for this equipment because it failed to object to the placement of similar crusher and wash plant equipment on the property without approval by the City's building officials. (See Testimony of Kraft and Ekola; Plaintiffs'Trial Exhibits 8 and 14). There is no reason to treat the ready-mix equipment any differently. Second, the City erroneously assumes that Conditions Nos. 16 and 17 preclude the existence and independent authorization of the Mineral Extraction and Land Rehabilitation Permit issued pursuant to Condition No. 2. This permit has been repeatedly acknowledged 419664 21 by the City as "approved." For example, the City planning staff in 1990 and 1991 reported to the Planning Commission regarding Condition 2 of the CUP that the Mineral and Extraction and Land Rehabilitation Permit had been "approved" by the City Council. (Plaintiffs' Trial Exhibits 5 and 7). The Mineral Extraction and Land Rehabilitation Permit was specifically re-issued in May 1991. The City has made no acknowledgements of approval concerning CUP Conditions Nos. 16 and 17, and no specific renewal or re-issuance of the Mining Permit under Condition No. 17 has been sought or granted. As discussed above, the ready-mix operation is, like the crusher and the wash plant, processing. Consequently, like the crusher and the wash plant, the ready-mix plant is not intended to be covered by Condition Nos. 16 and 17, which concern mineral extraction only. And plaintiffs' Mineral Extraction and Land Rehabilitation application sought a permit for an operation described as "mining, crushing, washing and processing aggregate." (Plaintiffs' Trial Exhibit 8). Clearly permission to conduct processing was sought, and such permission was granted when the permit was issued in May, 1991. Even if there was some technical deficiency by plaintiffs' failure to secure building official approval of the ready-mix plant (Condition 8) or failure to adhere to the Gravel Extraction Plan map by not indicating where the ready-mix equipment would be located (Conditions 16 and 17), those matters are not material or substantive. The critical issue is whether a ready-mix plant is processing and thus permitted by the Mineral Extraction and Land Rehabilitation Permit. If the Court concludes that the ready-mix processing is permitted, then the City could not deny approval of the portable building or deny deviation from the originally submitted Map B. Use of permitted equipment could be denied only for 419664 "reasons relating to the public health, safety and general welfare. Scott County Lumber Co., 417 N.W.2d at 726-27. There has been no competent evidence that the ready-mix plant endangers the public health, safety or welfare. Therefore the City must issue any necessary building approvals and map changes necessary to allow the permitted ready-mix processing use to proceed. C.R Investments Inc. v. Village of Shorewood, 304 N.W.2d 320, 324 (Minn. 1981). The City can no more deny ready mixing in 1991 without showing that it endangers health, safety and welfare than it could deny the gravel extraction permits in 1986. Third, the expert testimony and the video of the ready-mix processing operation refute the existence of any additional adverse environmental impacts from the ready-mix operation. Even Kraft initially testified that there was no additional adverse environmental impact from plaintiffs' ready-mix operation. Only when he was recalled as a defense witness did Kraft resurrect his specious traffic and visual impact concerns. Kraft admitted that he had no factual basis for raising a concern about traffic except he believed that cement (constituting a relatively insignificant portion of the ready-mix mixture) would be brought on the Property. He admitted that he-did not know whether the cement truck traffic would have any adverse impact on the roads or the capacity of the roads. The experts in the field all agreed that the ready-mix operation on the Property will reduce the traffic by as much as two to three times. Further, Kraft could not distinguish his concerns about the visual impact of the ready-mix site from a grain silo on an adjacent property. In any event, the City could not identify any aesthetic regulations on the Property which plaintiffs' ready-mix operation violated. 419664 23 Since there is no additional adverse environmental impact from the ready-mix operation, Condition 18 has not been violated. The original EAW assessed the environmental impact from gravel mining and processing. Nothing further needs to be considered merely because a ready-mix plant will simply be added to the processing equipment already in use on the Property. There will be no added environmental impact to assess. Fourth and finally, it is hard to comprehend how an increased demand for the aggregate on the Property caused by the ready-mix plant could delay the use and reclamation of the Property. Regardless, CUP Condition No. 19 provides no automatic extension of the 17-year duration of the CUP. In 17 years plaintiffs' operation will be terminated as required by Condition 19. The only effect that the ready-mix operation will have is that the gravel will be used more efficiently and effectively during or before the expiration of the 17-year permit life. In summary, the City failed to put forward anv credible evidence in response to plaintiffs' eminently qualified expert testimony. The entire expert record establishes that a ready-mix operation is processing. Processing is the ultimate issue in this case. As an additional basis for plaintiffs' permitted operation, plaintiffs' uncontroverted experts' testimony demonstrates that ready-mix processing is "customarily incidental" to permitted sand and gravel operation. Therefore, the ready-mix plant is also a permitted accessory use or structure. The expert testimony also emphasizes the lack of any adverse environmental impact from the ready-mix operation. Finally, the City's alternative resolutions of this case, 419664 24 which were also irrelevant to the issue to be tried, were without any credible support in the record. • ARGUMENT I. PLAINTIFFS' READY-MIX AGGREGATE PROCESSLNG OPERATION IS A PERMITTED USE ON THE PROPERTY BECAUSE IT CONSTITUTES 'PROCESSING." This Court has already determined that "processing" is a permitted use on the Property. (Order and Memorandum dated August 21, 1991). The Mineral Extraction and Land Rehabilitation Permit, which repeatedly provides for "processing" (S.Z.O. §11.05, Subd. 7(C)(6) and C(8)), was issued pursuant to Condition No. 2 of the court ordered CUP. The Extraction Permit was subsequently reapplied for and granted less than six months ago. The Mineral Extraction and Land Rehabilitation Permit Application specifically describes "processing aggregate" as the operation to be conducted on the Property. (Plaintiff's Trial Exhibit 8). Moreover, processing was contemplated by the plaintiffs when submitting their original 1985 plans on the Property (Defendant's Trial Exhibit 2) and by the Court of Appeals in ordering the issuance of the CUP, Scott County Lumber, 417 N.W.2d 721. "Processing" has been defined by the United States Supreme Court as: "A process is a mode of treatment of certain materials to produce a given result. It is an act or series of acts performed upon the subject matter, to be transformed and reduced to a different state or thing." Cochrane v. Deener, 94 U.S. 780, 781 (1876). Every Court that has addressed the issue of whether a ready-mix operation constitutes processing held that a ready-mix operation is within the definition of processing. 419664 25 The Supreme Courts of both Ohio and Oklahoma found that for taxation purposes the actual mixing of the component materials of concrete (water, cement, sand, gravel, rock, airentraining agent, etc.) constitutes processing. V. N. Holderman Paving Co. v. Bowers, 170 N.E.2d 65 (Ohio 1960);Boardman Supply Co. v. Bowers, Tax Commr., 145 N.E.2d 543 (Ohio Ct. App. 1956); Auxier-Scott Supply Co. v. Oklahoma Tax Comm'n., 527 P.2d 159 (Okla. 1974). In a similar case, the Supreme Court of Illinois in Van's Material Co. v. Dept. of Revenue, 545 N.W.2d 695, 697 (Ill. 1989), held the "process" for concrete begins when the four components, sand, limestone, water and cement, in specific proportion" are mixed to produce ready-mix concrete. More recently in a zoning case, the Montana Supreme Court found that ready-mix operation was processing. Missoula County v. American Asphalt, Inc., 701 P.2d 990 (Mont. 1985). The facts in Missoula County are almost identical to this case. The property owners in Missoula proposed an asphalt and concrete batching plant on property which was zoned single family residential. The applicable zoning allowed gravel extraction only with a special permit. The property, however, was located ina county which allowed gravel processing only in industrial zones. In granting the asphalt and concrete operations on the subject property, the Montana Supreme Court specifically found that aggregate processing "include[s] washing, crushing, screening, and concrete and asphalt batching." Id. at 993, 991. A ready-mix operation meets the United States Supreme Court definition of processing. The ready-mix equipment, through a series of acts, transforms aggregate into a different and distinct product: namely, concrete. The actual ready-mix process involves the metering out of predetermined quantities and grades of aggregates. These aggregates 419664 26 are then combined into a hopper where they are mixed together with cement and water to form a new mushy substance: ready-mix concrete. (See Testimony of Shiely). Concrete is almost entirely aggregate, but in the processed concrete form the materials are usable and marketable. Experts in the aggregate field universally regard ready-mix operations as processing. The expert testimony in this case established that conclusion. The City submitted no credible evidence to the contrary. In fact, it appears difficult if not impossible to conclude otherwise. The unanimous case law precedents and the uncontroverted testimony of experts in the field supports but one conclusion: a ready-mix operation is a "processor of materials." As such, plaintiffs' ready-mix operation is a permitted use on the Property. The City's further interference with this use must be enjoined. Once the Court has determined that the ready-mix operation is processing, then any technical deficiencies in plaintiffs' building plan approval or maps are not substantive and should be ignored. The City must be ordered to issue any procedural building approvals or site map modifications that are necessary to conduct plaintiffs' permitted processing operation. II. PLAINTIFFS' READY-MIX AGGREGATE PROCESSING OPERATION IS A PERMITI-ED ACCESSORY USE TO THE EXISTING SAND AND GRAVEL OPERATION ON THE PROPERTY. Within an Agricultural Preservation District, upon which the Property is located, the following uses are "permitted accessory uses": 419664 27 A. Any incidental machinery, structures, or buildings necessary to the conduct of agricultural operations or other permitted uses. (S.Z.O. § 11.24, Subd. 4) (Plaintiffs'Trial Exhibit 4). "Accessory use or structure" is defined as "[a] use or structure subordinate to and serving the principal use or structure on the same lot and customarily incidental thereto." (S.Z.O. § 11.02(1)) (emphasis added). The evidence introduced at trial is both overwhelming and undisputed that ready-mix processing operations are "customarily incidental" to sand and gravel extraction operations. Each of the experts in the field of aggregate extraction testified that most sand and gravel extraction sites have a ready-mix or asphalt operation located on or near them. This fact is further evidenced by data introduced at trial by Hoagberg who has been recognized by the Court of Appeals as an expert in Minnesota gravel operations. Within the metropolitan area, over 55% of all sand and gravel extraction sites have a ready-mix operation plant on or near them. Over 65% of these sites have an asphalt plant at or near the pit. The significant presence of ready-mix and asphalt operations on aggregate extraction sites is explained by the simple fact that the principal purpose of sand and gravel excavation is for either ready-mix concrete or asphalt. (See Testimony of Shiely). Thus, as the expert testimony repeatedly emphasized, it does not make economic or environmental sense to establish two independent sites for mining and processing gravel into a marketable and useable form. Separate siting requires unnecessary transportation of the aggregate to ready-mix processing sites and concrete back from the ready-mix plant. Additionally, because aggregate is not principally sold in its unfinished state, ready- mix processing operations are simply the necessary next step in processing of wash gravel 419664 28 into a finished, marketable product. (Testimony of Shiely). Plaintiffs' ready-mix operation is not a departure from the existing sand and gravel operation; rather it is part of a "continuum" of similar processing, the purpose of which is to make raw sand and gravel into a useable product. (See Testimony of Shiely and McNeilus). The sand and gravel operation prepares the aggregate for further processing by screening, crushing and washing aggregate into separate grades for use in a ready-mix operation. While the ready-mix operation merely mixes the aggregate in a hopper with water and cement to create concrete, the sand and gravel operation requires the initial mining, a series of screening and separating devices, a large crusher, and a wash plant. Indeed, the sand and gravel operation requires much more involved and significantly more costly equipment than the equipment needed for plaintiffs' ready-mix processing operation. (See Plaintiffs' Trial Exhibits 19 and 20). The ready-mix plant is merely subordinate to and serves the principal use on plaintiffs' Property -- the gravel extraction. Moreover, ready-mix plants are customarily incidental to gravel extraction operations. Significantly, the City made no effort at trial to establish that the additional processing of this aggregate into concrete involved equipment so dissimilar from what was already on the site that it could not be an accessory use. Courts have consistently found asphalt and concrete plants to be a permitted accessory use to aggregate excavation sites. The Supreme Court of Montana, held that gravel processing, which it defined as including "washing, crushing, screening, and concrete and asphalt batching, . . . [is] part of the recovery of gravel resources," or in other words an accessory use to gravel extraction. Missoula County v. American Asphalt, Inc., 701 P.2d at 419664 29 993 (emphasis added). Further, the United States District Court of Georgia very recently held: [T]he Plaintiff has a right to operate asphalt and concrete plants as accessory uses under the zoning ordinance because an accessory use is any use which is `customarily incidental, appropriate, and subordinate to the principal use' of the property, and evidence before the Court leaves no doubt that asphalt and concrete plants are customarily found on a crushed stone quarry. Blue Circle Aggregate v. Harris County, No. 90-820-Col. (M.D. Ga. June 11, 1991) (emphasis added). Similarly, in Booth v. Board of Adj. Rockaway Tp., 234 A.2d 681, 683 (N.J. 1967), the New Jersey Supreme Court found an asphalt plant to be an incidental accessory to mining and quarrying operations. The Court relied on the evidence that approximately 95% of the materials supplying the proposed facility would come from the existing operation and that most of the equipment necessary for the proposed facility was already utilized in the existing operations. Id. See also Silliman v. Falls City Stone Co., 305 S.W.2d 322, 324 (Ky. 1957) ('The operation of such [asphalt] plants in connection with rock quarries is customary and should be regarded as incidental to this quarry in the sense that they are collateral or accessory to the main operation"); Hinkle v. Board of Zoning Adjust. & App. of Shelby County, 415 S.W. 2d 97 (Ky. 1967). The experts and data in this case support the obvious: in the metro area ready-mix operations are "customarily incidental"to a sand and gravel excavation site. Experts further attest that a ready-mix operation is just another step in the processing of aggregate. Moreover, case law has consistently held a ready-mix operation to be a permitted accessory use to an excavation site. As such, plaintiffs'ready-mix aggregate processing operation must be allowed to continue as a permitted accessory use on the Property. 419664 30 III. IN ANY EVENT, REVOCATION OF PLAINTIFFS' CUP AND MINERAL EXTRACTION LAND REHABILITATION PERMIT WAS ARBITRARILY ASND CAPRICIOUS BOTH AS A MATTER OF LAW AND BY THE CUP'S TERMS OF REVOCATION Under Minnesota statutory and case law, a CUP cannot be revoked so long as the conditions agreed upon are not violated. Minn. Stat. § 394.301, Subd. 3 (1991); State Ex Rel. Neighbor's Org., Etc. v. Dotty, 396 N.W.2d 55, 59 (Minn. Ct. App. 1986) (CUP "continues until its provisions are violated"). The conditions of CUP at issue here — drafted by the City --further limited the City's ability to revoke plaintiffs' CUP and Mineral Extraction and Land Rehabilitation Permit. Pursuant to Condition 20 of the CUP, the permits can be revoked only upon a finding of"substantial" or "repeated"violations of the CUP. (Plaintiffs' Trial Exhibit 1). The City reviewed the CUP less than 6 months ago and found the plaintiffs in compliance. Therefore, the permit revocation only alleges a "substantial" violation of the CUP. (Testimony of Kraft). There is no claim of repeated violations. Plaintiffs' setting up the portable ready-mix equipment without operating it was not a "substantial" CUP violation, even assuming arguendo that the ready-mix aggregate processing operation was not a permitted use on the Property as either "processing" or as an "accessory use." A. Plaintiffs did not "substantially" violate the CUP. The City's only alleged violation was the plaintiffs' set up of the ready-mix aggregate processing operation. The equipment has never been substantially operated. As soon as plaintiffs learned that the City challenged whether the ready-mix plant was permitted, they acted responsibly and immediately and did not mix concrete on the site. Even though they believe the plant complied with the permits, plaintiffs waited to operate their plant and 419664 31 looked to the courts to resolve the issue. Had plaintiffs blatantly ignored the City's warning and proceeded to operate their ready-mix operation as scheduled, then an arguable "substantial" violation of the CUP could have arisen (assuming, again, that the operation was found to be a non-permitted use). Plaintiffs have lost four months of operation and revenues from the plant because of the City's threats and actions. The only action requested by the City that plaintiffs have not agreed to is the dismantling of the plant prior to an objective third-party determination of whether the ready-mix operation is a permitted use. (Testimony of Noterman). Plaintiffs have made repeated efforts to negotiate with the City. Moreover, plaintiffs believed they were legitimately and reasonably exercising their rights under the CUP and the Mineral Extraction and Land Rehabilitation Permit when they set the plant up. Based upon their knowledge of the industry and the City's ignorance about - gravel extraction and processing, the plaintiffs, in good faith, concluded that a ready-mix operation is a permitted use on the Property. When the City disputed that conclusion, plaintiffs sought a judicial determination of the correctness of their proposed use on the Property. (See Testimony of Noterman). The City has failed to lawfully and fairly regulate the use of plaintiffs' land for over a decade. The latest actions concerning the ready-mix operation are just a continuation of this pattern. Consequently, given the obvious futility of their trying to resolve a matter with the City, the plaintiffs resorted to the courts. The law and case precedent about whether the ready-mix operation constitutes either "processing" within the Mineral Extraction and Land Rehabilitation Permit or a permitted accessory use to the existing sand and gravel operation demonstrate that the plaintiffs were not in substantial defiance of the zoning and permit restrictions on the Property. Rather, 419664 32 their proposed use on the Property for ready-mix processing has, in fact, been uniformly permitted in the jurisdictions to have confronted the issues. (See supra §§ I and II). As such, plaintiffs' conduct in setting up the ready-mix equipment without more can at worse be seen as "mistaken," but in no way can it be judged as constituting a "substantial"violation of the CUP. Furthermore,in order to uphold the CUP permit revocation,this Court must find that plaintiffs substantially violated the permit. Neither the Zoning Ordinance nor the permit define "substantial." But a substantial violation must be interpreted in the context of the law relating to CUP denial. In other words, to find a substantial violation, the City must have the same sort of evidence that would be necessary to deny a CUP. As established in Scott County Lumber, the City's denial of a CUP must be for reasons relating to the public's health, safety or welfare. 417 N.W.2d at 726-27. Therefore, a substantial violation,justifying permit revocation, must also be for reasons relating to public health, safety or welfare. There is absolutely no evidence to support a find that the mere set up and non- operation of a ready-mix plant endangers the public health, safety or welfare. Therefore, there is not a legally sufficient basis to support a finding that plaintiffs substantially violated the permit. B. The reasonableness of plaintiffs conduct following notification of its alleged CUP violation legally bars the City's Revocation of the CUP It is inappropriate for a court to grant or uphold a decision terminating the operations of a business when the business to be affected has shown a willingness to rectify the alleged violation and the business had acted with a good faith belief that its ope,ations 419664 33 were permitted. Reserve Mining Co. v. Environmental Protection Agency, 514 F.2d 492, 537 (8th Cir. 1975). Here, the plaintiffs testified to a willingness to disassemble the ready-mix operation upon a judicial determination that it is a non-permitted use on the Property. The plaintiffs have elected not to run the ready-mix operation until the issue has been decided in the Courts. And, the plaintiffs' acted with a good faith belief that the ready-mix operation was a permitted use on the Property. The substantial case law supporting plaintiffs' belief that the ready-mix operation is a permitted use on the Property, either as processing or as an accessory use, further evidences the reasonableness of plaintiffs' position. The reasonableness of plaintiffs'conduct is particularly apparent given the substantial evidence of the City's discriminatory treatment of the plaintiffs. First, there is the "retrospective" notification by the City informing plaintiffs not only that the June 13th letter of the City Administration was a final adverse determination, but also that their time for appeal of that determination had expired. This tactic is contrary to fundamental due process and the City's practice of affording adversely affected land owners notice of their appeal rights. (See Plaintiffs' Trial Exhibits 12 and 13). Second, the City pursued the most stringent and economically damaging enforcement against the plaintiffs for their alleged violation of the CUP. This was done despite plaintiffs' compromise position of not running the ready-mix operation until the matter was judicially determined. Furthermore, the City had numerous other less extreme options available to enforce its version of the permit. For example, the City could have sought injunctive enforcement of the CUP. The City could also have charged plaintiffs with a misdemeanor 419664 34 and resolved the issues in a criminal court, or the City could have simply fined plaintiffs for the alleged CUP violation. Third, the City obviously plotted to revoke the permit before the matter even came . before it for hearing. In July, the Planning Commission discussed revocation of the CUP two weeks before the plaintiffs were even notified that this alternative was even being contemplated. (See Plaintiffs'Trial Exhibit 16). Fourth and finally, the City determined that the ready-mix operation was "processing," despite the absence of any expert testimony to support this conclusion. In Scott County Lumber, 417 N.W.2d at 727-28, the Court of Appeals held that expert testimony may not be discounted, and that the City acted "irrationally" in reaching its conclusion by preferring to rely upon community opposition rather than expert testimony. After being chided by the Court in 1988 for not giving proper weight to expert testimony, the City's rejection of that evidence in this case is certainly suspect. In summary,the City's required finding that plaintiffs'"substantially violated"the CUP cannot be supported by the record. Additionally,.plaintiffs'willingness to remove the ready- mix operation if it was found to be a non-permitted use on the Property and its good faith belief that the operation was permitted precludes the City from closing down the gravel mining business. Consequently, the City's action is at best "arbitrary and capricious," and perhaps more appropriately discriminatory and vengeful. In either case, the City's revocation of the CUP must be reversed as insufficient to support the very conditions of revocation established by the City. The mere set up of the plant does not threaten the public's health, safety or welfare. 419664 35 CONCLUSION The City's case is not only without support on the record, but also contrary to the law. Neither the record nor case law support the City Council's "interpretation" that ready-mix is not a permitted use on the Property. The experts in the field universally maintain that a ready-mix operation constitutes "processing." All relevant case law precedent agrees. Likewise, the experts and the qualified data on point establish that a ready-mix operation is "customarily incidental" to a sand and gravel extraction operation. A ready-mix operation is typically the final step in the processing of washed aggregate into a finished product. For economic and environmental reasons such processing equipment is "customarily" found at or near the sand and gravel extraction site. Case law accords with the record, consistently finding a ready-mix operation to be a permitted accessory use to a sand and gravel operation. Whether this is regarded as permitted processing or a permitted accessory use, the plaintiffs' ready-mix operation on the Property is authorized by the applicable Ordinance provisions and permits. The City must be enjoined from further interference with plaintiffs' use of their Property.. Finally, even if the ready-mix operation is not a permitted use, the City Council's record cannot support a finding of a "substantial" violation of the CUP. At a minimum, the CUP and the Mineral Extraction and Land Rehabilitation Permit revocations must be overturned to permit plaintiffs to conduct their sand and gravel extraction and processing operation. 419664 36 Dated: October ,. , 1991. BRIGGS AND MORGAN BY • /-•–•— yimothy R. Thornton k#109630) Jack Y. Perry (#209272) 2400 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 (612) 334-8400 Attorneys for plaintiffs NBZ Enterprises Inc., successor in interest to Scott County Lumber Company and Bert Noterman; Moon Valley Aggregate, Inc.,a/k/a G &T Trucking, Inc. 419664 37 10 - OTHER CIVIL STATE OF MINNESOTA DISTRICT COURT COUNTY OF SCOTT FIRST JUDICIAL DISTRICT Court File No. 91-09739 NBZ Enterprises, Inc. , Plaintiffs, vs. DEFENDANT'S BRIEF City of Shakopee, Defendant. ISSUES (1) Is a ready mix plant included in the processing allowed on Plaintiffs ' property? (2) Did the City Council have a factual basis for its holding that the ready mix plant substantially violated Plaintiffs ' Conditional Use Permit? (3) What is the appropriate remedy? FACTUAL BACKGROUND Plaintiffs own certain land in Shakopee, Minnesota, hereinafter referred to as the Property, on which they operate a sand and gravel mining operation. In order to locate this business on the Property, in 1984-85 Plaintiffs ' predecessor in interest, Scott County Lumber Company, filed applications with the City. The City refused to grant the necessary permits, and Plaintiffs sued. In 1988 they were granted Conditional Use Permit No. 376 and a Mineral Extraction and Land Rehabilitation Permit. Soon thereafter Plaintiffs began removing sand and gravel from their property. In early June 1991, Plaintiffs moved a ready mix plant onto their Property. The City became aware of the ready mix plant through citizen complaints. At the City Council meeting of June 4, 1991, the City Council questioned Tom Zwiers about the ready mix plant. Tony Gleekel, Plaintiffs ' attorney at the time, also was present. The City advised Plaintiffs that the ready mix plant was not permitted, and entered into discussions for its removal with Zwiers and Gleekel. The City worked with Plaintiffs over a period of several weeks, including the following: June 13 , 1991, letter from Dennis Kraft, City Administrator, to Tom Zwiers. (P1. Ex. 10) The letter directed Zwiers to remove the ready mix plant by June 24 , 1991. As per standard practice, although the letter was appealable, it did not spell out appeal procedures. Plaintiffs neither appealed the letter, nor removed the ready mix plant by the deadline. June 17 , 1991, meeting between Lindberg Ekola, City Planner, and Tom Zwiers. Zwiers advised Ekola that Plaintiffs would not back away from the issue. He stated that the ready mix plant was processing equipment, and threatened to sue the City. (Testimony of Ekola) June 24 and 25, 1991, telephone conversations between Kraft and Gleekel . Gleekel assured Kraft that the ready mix plant would be removed. (Testimony of Kraft) 2 July 1, 1991, meeting between Ekola and Zwiers. Zwiers told Ekola that he had reviewed the situation with his partners and they had decided not to remove the ready mix plant. Zwiers stated that they felt they had the right to operate it, and it was up to the City to stop them. Zwiers also mentioned he would call his attorney Gerry Duffy, who is a partner in the law firm where Gleekel works. (Testimony of Ekola) July 3 , 1991, letter from Gleekel to Kraft stating that the owner of the portable ready mix plant, AVR, Inc. , had agreed to dismantle it and would remove it from the site within 45 days. (Def. Ex. 8) July 25, 1991, letter from the City Attorney to Zwiers. Attorney warned Plaintiffs that if the plant were not removed from the site by July 31, 1991, the City would advertise for a public hearing to consider revocation of Conditional Use Permit No. 376 for violation of conditions 8, 16, 17, 18 , and 19, as authorized in condition 20. (Pl. Ex. 11) Plaintiffs then advised the City that they had hired new counsel. (At trial Zwiers claimed that Tony Gleekel did not represent Plaintiffs. However, Plaintiffs failed to tell either Gleekel or the City that until July 26, 1991. ) (Testimony of Gleekel and Kraft) They did not remove the ready mix plant by July 31, and the City correspondingly scheduled the public hearing. Plaintiffs did seek a temporary restraining order, but it was not granted. 3 Under Paragraph 20 of Plaintiffs ' conditional use permit, the City may review or revoke the permit. (Pl. Ex. 1) The City had received a number of complaints, and viewed the ready mix plant to be a substantial violation. (Testimony of Kraft) At the public hearing, the City Council heard testimony and made findings in their resolution relating to violations of several conditions of the conditional use permit. (P1. Ex. 15. ) Plaintiffs did not offer any evidence to refute any of the violations; rather, Plaintiffs ' only evidence was testimony from Mr. Fischer and Mr. Thornton that they believed that the ready mix plant was included in the processing they were allowed to do on their property. (Testimony of Kraft and Laurent) Plaintiffs did not indicate what provisions, if any, in the conditional use permit or the mineral extraction and land rehabilitation permit supported their position. (P1. Ex. 15) At the end of the hearing, the City Council revoked Plaintiffs ' conditional use permit and mineral extraction and land rehabilitation permit. (Def. Ex. 1. ) The next day Plaintiffs obtained a preliminary injunction prohibiting the City from interfering with their conditional use permit. At the same time, the Court enjoined Plaintiffs from operating the ready mix plant. Trial was set for the next month on the issues surrounding the ready mix plant. At trial, the City presented expert testimony on the issues before the Court, relating to the zoning on Plaintiffs ' property, and whether a ready mix plant is allowed under the City zoning ordinances, Plaintiffs ' conditional use permit, or Plaintiffs ' 4 mining permit. (Testimony of Ekola and Kraft) The City also identified the facts relied upon by the City Council in determining that the ready mix plant substantially violated Plaintiffs ' conditional use permit. (Testimony of Kraft and Laurent) Plaintiffs presented evidence on peripheral issues, such as who manufactures ready mix plants and their environmental impact. None of the mining operators, equipment manufacturers, or other witnesses presented by Plaintiffs were experts in land use or zoning, which is the core of the matter before the Court. Plaintiffs ' witnesses Joseph Shiely, Garwin McNeilus, Mathias Fischer, and Rudolf Hoagberg did not know how Plaintiffs ' property was zoned. They likewise had not even read Plaintiffs ' conditional use permit or Plaintiffs ' mining permit. Shiely and Fischer testified that ready mix plants are sometimes located within or near sand and gravel mines, but had no idea how many of these were located in industrial zones, agricultural zones, or residential zones. Although Plaintiffs ' use of their property is subject to an Environmental Assessment Worksheet (EAW) , (Def. Ex. 7) Shiely and Zwiers discussed environmental issues without having read or being familiar with that document. Shiely and McNeilus admitted that a ready mix plant requires hauling in cement, with additional traffic, water use, and other impacts on the environment. Such items would be addressed in an EAW, yet they also discussed environmental issues without regard to Plaintiffs ' EAW. 5 Despite their lack of information on planning and zoning, Plaintiffs ' witnesses did provide insight into the uses anticipated to be legal on Plaintiffs ' property. McNeilus testified that sand and gravel mining is taking raw material from the ground to stockpiles. In comparison, he stated that processing is a continuum with bridge construction as one end of it. Zwiers stated that Plaintiffs started processing in 1989, and at that time their processing was screening and crushing. He gave his opinion that processing was washing, crushing, and screening aggregate. Bert Notermann, who has been involved with this property since at least 1981, described his 1984-85 applications, and stated that there was no intent to put a ready mix plant at the mine then. Hoagberg testified that ready mix plants frequently operate at construction sites or in former mines, and so have an independent productive capacity without regard to the existence of a mine. Although Zwiers is the operator of the mine, he apparently has operated in reckless disregard to the law. He stated that he had not read the documents described in Plaintiffs ' conditional use permit, and was not aware of the contents of the Merila memo (Def. Ex. 2) or the environmental assessment worksheet for this site. (Testimony of Zwiers) Although Plaintiffs claimed the Court' s decision in Scott County Lumber Ccmmanv v. City of Shakopee, 417 N.W.2d 721 (Minn. App. 1988) allowed them to operate a ready mix plant, he had not read that decision. Fischer initially did not remember the previous ready mix plant he had in Shakopee. He eventually recognized the conditional 6 use permit he had obtained, for a ready mix plant in the Heavy Industrial zoning district. (Def. Ex. 5) At trial Zwiers raised, for the first time, a curious argument that his 1991 renewal of the mining permit was either an entirely new permit or an amendment of the 1988 permit. He did not explain how he believed that such a permit or amendment could be issued with no supporting documents, when, at the same time, he had submitted documents and testimony to support amendments to Plaintiffs ' conditional use permit. Notermann alleged the same point, but also failed to explain how he could think that the materials required in the original application would not be required this time. Notermann' s testimony lacked consistency. He claimed that his conditional use permit allowed a ready mix plant, but was unable to show the City any documents to support his statement. To the contrary, he noted the absence of any mention of a ready mix plant in the list of buildings or equipment in the Merila memo, and the explicit disclaimer on page 1 that "There is no intent to mix asphalt or concrete at this site. " He stated that he was involved in obtaining the original conditional use permit and mining permit, and he knew wells and asphalt plants needed permits, but that he did not think he needed to contact the City prior to moving in the ready mix plant. The City presented two planning experts to discuss the zoning and land use issues which are the core of this case. Lindberg Ekola, City Planner, has worked as a planner in three states, and 7 has a masters degree in Community and Regional Planning. Ekola testified that Plaintiffs ' use of their land is governed by the City ordinances, Conditional Use Permit 376 and Plaintiffs ' mining permit, which is the usual and short way of referring to the mineral extraction and land rehabilitation permit. These permits run with the land, and govern whoever owns the land and desires to operate a mine there. Processing must be defined in the context of these permits and the City ordinances, and means crushing and screening aggregate. The City has relied upon Plaintiffs ' Maps A, B, and C (Def. Ex. 4) and the Merila memo (Def. Ex. 2) , which do not indicate a ready mix plant on the site. Ekola testified that all ready mix plants in Shakopee have been located in the Heavy Industrial zoning district, and all have obtained a conditional use permit in order to operate. He noted that most of them have been on construction sites, and only one on the site with an operating mine. Ekola provided his expert opinion that a ready mix plant is not a permitted use of Plaintiffs' property. The City' s next witness was Dennis Kraft. Kraft has a masters degree in planning, and has worked for numerous planning commissions and cities. Since beginning in Shakopee as Community Development Director, he has been promoted to City Administrator. Kraft is presently an adjunct professor at Hamline University, and has been admitted into the AICP, the highest professional certification available for planners. (Def. Ex. 12 . ) 8 Kraft provided background in land use and zoning, explaining the reason for different zoning districts, and the distinction between the Agricultural Preservation zoning district, which is for agricultural and residential uses, and the Heavy Industrial zoning district, which is for the most intense manufacturing uses. Related land uses may not necessarily go in the same zoning district, since they may not be compatible with the surrounding area. Kraft explained why mining needs a conditional use permit to be in an agricultural preservation zone, and that manufacturing uses such as ready mix plants are incompatible with the agricultural zone. Kraft concluded with his expert opinion that a ready mix plant is not a permitted use of Plaintiffs ' property. Mayor Gary Laurent also testified. He is a land developer and homebuilder, and president of his own company, Laurent Builders. Laurent rejected Plaintiffs ' allegation that the City' s action was vindictive, and confirmed that most of the City Council and City staff has changed since Scott Company Lumber Company sued the City. He was not bitter about the past litigation, although it appeared to him that the Plaintiffs were. When the City Council revoked Plaintiffs ' conditional use permit, they focused on the ready mix plant. The City Council heard from staff regarding the violations of the conditional use permit; Plaintiffs did not refute any of the staff comments. The City Council followed the procedure they had followed previously that summer, and revoked the conditional use permit and mining permit. 9 ARGUMENT The standard of review in this case is whether the City' s action was reasonable. Honn v. City of Coon Rapids, 313 N.W.2d 409 (Minn. 1981) . It is not, as Plaintiffs suggest, whether the City acted arbitrarily and capriciously, or whether the public health, safety, and welfare support a ready mix plant. Id. Plaintiffs bear the burden of persuasion that the reasons stated by the City Council for its actions are either without factual support in the record or are legally insufficient. Hubbard Broadcastina, Inc. v. City of Afton, 323 N.W. 2d 757 (Minn. 1982) . The reasonableness of the City's actions, and the strong factual and legal basis for the City' s position, is set forth below. The hostility, personal attacks, and twisting of facts with which Plaintiffs ' brief is replete, is typical of the way Plaintiffs have acted throughout this summer. Plaintiffs took every opportunity to accuse the City of being arbitrary and capricious. The City sometimes found it difficult to remain calm and objective. Nonetheless, the City carefully relied upon its ordinances and resolutions in taking action, making sure there was a legal and factual basis for its statements. Plaintiffs appeared to rely upon their subjective feelings, without regard to the law. (1) IS A READY MIX PLANT INCLUDED IN THE PROCESSING ALLOWED ON PLAINTIFFS ' PROPERTY? Zoning principles . The City governs the use of land through its zoning ordinance. Under this ordinance, Shakopee is divided into various 10 agricultural, residential, business, and industrial zoning districts. The regulations for each zoning district list permitted, conditional, and accessory uses. Each of these possible listings of uses are considered below to indicate the lack of authority for a ready mix plant on Plaintiffs' property. A land use not included in one of the lists is prohibited. See City Code Sec. 11.03 , Subd. 1.C; Sec. 11.24, Subd. 2 . Zoning is based on the need to protect certain uses of land from others. As stated in Minn. Stat. Sec. 462 . 351, cities are faced with mounting problems in providing means of guiding future development of land so as to insure a safer, more pleasant and more economical environment for residential, commercial, industrial and public activities, to preserve agricultural and other open lands, and to promote the public health, safety, and general welfare. The right to use property as one wishes is subject to and limited by the proper exercise of the police power. City of St. Paul v. Carlone, 419 N.W. 2d 120 (Minn. App. 1988) . Similar or related uses are not automatically allowed in the same zoning district, as the compatibility of the uses with the purpose of the zoning district and surrounding uses must be considered. See, e.g. , Farmington Township v. High Plains Cooperative, 460 N.W.2d 56 (Minn. App. 1990) . A farmer had constructed a 30, 000 gallon petroleum tank on his property and leased it to a cooperative. The Court required the removal of the tank after examining "whether the activity was carried on as part of the agricultural function or was separately organized as an independent productive activity" . Id. at 59 . Large equipment, leased to a third party, as an independent productive activity, is 11 prohibited. The same situation exists here: Plaintiffs have added a large piece of equipment to their property, which equipment is owned by a third party, and which is an independent productive activity. Permitted uses do not include a ready mix plant. There is no dispute that Plaintiffs ' property is zoned Agricultural Preservation, and therefore governed by City Code Sec. 11. 24 . (P1. Ex. 4, p. 301) Subd. 2 of that section provides that "no structure or land shall be used except for one or more of the following uses" . It is uncontested that sand and gravel mining, and ready mix plants, are not included in the list of permitted uses. Conditional uses do not include a ready mix olant. City Code Sec. 11.24, Subd. 3, allows structures or land to be used for certain additional uses, if a conditional use permit is obtained. (P1. Ex. 4, p. 301) A conditional use permit "allows property, within the discretion of the governing body, to be used in a manner expressly authorized by the ordinance. " TPW, Inc. v. City of New Hooe, 388 N.W.2d 390, 392 (Minn. App. 1986) . Provisions in local zoning ordinances for special [conditional] use permits are designed to meet problems that arise when a certain use, although generally compatible with a particular zoning classification, should not be permitted as a matter of right in every area within the zone because of hazards inherent in the use itself or special problems which its proposed location may present. 12 Rockville To. v. Lang, 387 N.W.2d 200, 203 (Minn. App. 1986) . The land must be used in accordance with the conditional use permit, in order to protect the use or the area around it. The list of conditionally permitted uses in the Agricultural Preservation zoning district includes "mining, sand and gravel extraction", but not ready mix plants. A review of the relevant definitions reveals that this phrase does not anticipate any particular processing of the sand or gravel. City Code, Sec. 11. 02, paragraph 82 , defines mining as the extraction of sand and gravel, without processing. (P1. Ex. 4, p.269) Likewise, the definition of an extraction area in City Code Sec. 11. 02, paragraph 46, refers only to excavation and removal of sand and gravel, without mention of processing. (P1. Ex. 4, p. 266) A ready mix plant is not authorized by the plain meaning of this language. Similar language was interpreted by the Court in Prior Lake Aaareaates, Inc. v. City of Savage, 349 N.W. 2d 575 (Minn. App. 1984) . When a mine sought to add an asphalt plant, the Court ruled the language did not authorize it. Construing the terms "mining" , "excavation" and "land reclamation" according to their plain and ordinary meaning and construing them strictly against the city, we cannot find that they include the processing and production of road base materials. At 578 . The same situation exists here: the conditionally permitted use of "mining, sand and gravel extraction" does not include the processing or production of road base materials, including concrete. 13 It should be noted that the list of conditional uses allows "structures in excess of 35 feet in height" with a conditional use permit. (P1. Ex. 4, p. 301-1) At trial Notermann testified that the ready mix plant is approximately 40 feet in height. Despite the ordinance language, Plaintiffs have not sought or obtained a conditional use permit for the ready mix plant. In contrast, the Heavy Industrial zoning district does include ready mix plants in its list of conditional uses. City Code Sec. 11.33 , Subd. 3 .G. (P1. Ex. 4, p. 310-9) Under the principle inclusius unius est exclusio alterius, the inclusion of ready mix plants in one district indicates that the exclusion in another district was intentional. To allow ready mix plants in the Agricultural Preservation zoning district would require judicial amendment of the ordinance. See Prior Lake Aggregates, supra at 579. Without ready mix plants being listed as conditional uses in the Agricultural Preservation zoning district, the City lacks authority to grant permission for Plaintiffs to have a ready mix plant in the Agricultural Preservation zoning district. Cf. Prior Lake Aggregates, supra at 579 ("there is no provision in the [city's] zoning ordinance which allows the City Council to grant a special use permit for an asphalt plant in a rural zone") . Although Shakopee has had several ready mix plants, all have been located in the Heavy Industrial zoning district, and all have obtained conditional use permits. (Testimony of Ekola) These included one owned by AVR, which owns the ready mix plant on 14 Plaintiffs ' property. (Testimony of Fischer) To allow the ready mix plant here, without the proper zoning and a conditional use permit, would be to grant Plaintiffs a special privilege denied to all other business operators in Shakopee. That would violate the principle that zoning ordinances are supposed to operate uniformly. Id. Nonetheless, Plaintiffs have argued that they may have a ready mix plant because they have a conditional use permit for a sand and gravel mine. Their argument appears to be three-fold: (a) their conditional use permit allows processing, and the ready mix plant is just more of the same; or, (b) their mining permit allows processing, including the ready mix plant; or, (c) they received permission to operate a ready mix plant when they sued the City to obtain a conditional use permit back in 1985. These arguments are mistaken, as discussed below. (a) Plaintiffs ' conditional use Dermit does not allow a ready mix plant. Plaintiffs ' use of their land is governed by Conditional Use Permit 376 . (Pl. Ex. 1) That document does not contain the phrase "ready mix plant" or the word "processing" . Therefore, any permission to conduct any particular processing must be contained within the City ordinances or the documents referred to in Conditional Use Permit 376. Plaintiffs ' conditional use permit was granted in accordance with City Code Sec. 11. 04 , Subd. 6. (P1 . Ex. 4, p. 285) The ordinance requires the City Planning Commission to make certain 15 findings, which presupposes that the Planning Commission will have full information on the proposed use of land. When Plaintiffs applied for and received their conditional use permit, they did not state that they were going to place a ready mix plant on the site, and in fact did not intend to do so. (Testimony of Notermann) Therefore, the conditional use permit does not anticipate or authorize a ready mix plant on the site. (b) The nrocessina allowed by Plaintiffs ' mining permit does not include a ready mix plant. Plaintiffs ' conditional use permit, in Conditions 2 and 17, requires a mining permit (also known as the mineral extraction and land rehabilitation permit) . This permit is governed by City Code Sec. 11. 05, Subd. 7 . (P1. Ex. 4, p. 294) Neither the City Code provisions nor Plaintiffs ' mining permit anticipate or authorize a ready mix plant. City Code Sec. 11.05, Subd. 7 does not mention a ready mix plant. It does mention "processing" three times, in Subd. 7 .C, paragraphs 6 and 7, and in Subd. 7.D. (P1. Ex. 4, pp. 296, 297) These provisions, when read in context, do not authorize or envision any particular kind of processing. Rather, they simply provide that, if processing occurs, it must be located in a particular area, in properly maintained buildings, and may continue for up to one year after the mining operation is terminated, with an additional conditional use permit. Plaintiffs ' conditional use permit requires them to obtain a mining permit in conditions 2 and 17. (P1. Ex. 1) City Code Sec. 16 11. 05, Subd. 7 .A. likewise requires a permit for all commercial mining operations. (P1. Ex. 4, p. 294) Nonetheless, at one point Plaintiffs claimed the ordinance was their permit. This argument ignores Plaintiffs' action in seeking a mining permit in 1985, (Def. Ex. 6) and in fact was rejected by Notermann at trial, who identified the application and affirmed that Plaintiffs had a mining permit. (Testimony of Notermann) The ordinance merely sets forth the general framework within which a mine will be allowed. Authority for a business to perform any particular action would be contained in that business' own mining permit. Plaintiffs contradicted their own argument in two other ways. First, they made the surprising argument that they were required to get three permits: a conditional use permit, a mineral extraction and land rehabilitation permit, and a mining permit. This argument appears to be based on a statement Ekola made at trial, when he was confused by the City Attorney's reference to the "mineral extraction and land rehabilitation permit", since he always calls it the "mining permit" . (Testimony of Ekola) If Plaintiffs ' argument were valid, then their operation is illegal because they do not have three permits. Second, Plaintiffs alleged that they sought and received an entirely new mining permit in 1991. (Testimony of Zwiers and Notermann) This supposed new permit contains no provisions, but rather apparently exists solely through their application. The Planning Commission approved a permit on May 9 , 1991, but the minutes reflect that the commission "moved to approve the re lewal" 17 of the existing permits. (P1. Ex. 14, p. 4) It is ingenuous to argue now that the 1991 renewal was an original application, when it did not meet any of the ordinance requirements. (See also Plaintiffs ' brief at 22 , where they admit the existing permit was "re-issued" . ) As Plaintiffs ' mining permit, the City has accepted those documents described in paragraph 17 of Conditional Use Permit 376. (Testimony of Ekola; P1. Ex. 2) These documents are the following: maps A, B, C; the conditions of the approved permits, which are those in Conditional Use Permit No. 376; and background information contained in a memo prepared by Plaintiffs ' consultant, Merila and Associates, Inc. City Code Sec. 11. 05, Subd. 7 requires Maps A, B, and C to show certain information. (Pl. Ex. 4, p. 294) Per the ordinance, Map A shows existing conditions. Map B is required to show "structures to be erected" and "location of all machinery to be used in the mining operation". Plaintiffs' Map B shows a rock crusher, but no ready mix plant. Map C shows the end use plan for the site. (Def. Ex. 4) The absence of a ready mix plant on these maps indicates that it was not intended to be included in the machinery or processing on Plaintiffs' property. Merila and Associates memo does mention mixing concrete, as in a ready mix plant. (Def. Ex. 2) At page 1, it specifically states that "There is no intent to mix asphalt or concrete at this site. " This memo also contains listings of equipment (p. 1) and buildings (p. 2) , in which a ready mix plant is conspicuously absent. 18 Plaintiffs seek to explain away this language, saying their intent has changed, but their intent is not the issue. The City Council granted Conditional Use Permit 376 based on Plaintiffs ' representations, as set forth in the Merila memo. The memo' s language speaks for itself. Condition 17 of Conditional Use Permit 376 requires Plaintiffs to have a "plan for operation" . Plaintiffs fail to explain what their plan for operation is, if it is not the maps, conditions, and the Merila memo. In addition, Plaintiffs failed to offer any testimony to show how the Merila memo ceased to be a part of their plan for operation. Notermann has applied for a mining permit previously. Fischer has had a ready mix plant previously in Shakopee, with a conditional use permit. Shiely operated a mine in Shakopee with both a conditional use permit and a mining permit for years. It is difficult to comprehend how they expect the Court to believe that they did not know a plan for operation was required or that they could ignore their existing one. Based on the mining ordinance, Plaintiffs ' mining permit, Maps A, B, and C, and the Merila and Associates memo, the processing allowed does not include a ready mix plant. The only processing allowed under these documents is that specified therein: crushing and screening. 19 (c) Plaintiffs did not receive permission to operate a ready mix plant when they sued the City in 1985 . Plaintiffs have alleged that the decision in Scott County Lumber Co. , Inc. v. City of Shakopee, 417 N.W. 2d 721 (Minn. App. 1988) granted them authority to have a ready mix plant. A review of this decision, however, reveals that it does not mention ready mix plants, nor contain the words "process" or "processing" . Rather than give Plaintiffs' carte blanc to do anything on their property they desire, as they imply, the Court specified that Plaintiffs must comply with the conditions of their conditional use permit or risk revocation of that permit. "If the applicant was to subsequently fail to maintain the standards required by the planning commission, the city could revoke the permit. " Id. at 722 . The Court warned Plaintiffs that they are bound by the limits and conditions of their conditional use permit, and that the City had the right to revoke that permit for non-compliance. Accessory uses do not include..a ready mix plant. In addition to permitted and conditional uses, accessory uses are allowed in the Agricultural Preservation zoning district. City Code section 11.24, Subd. 4, allows as accessory uses "Any incidental machinery, structure, or buildings necessary to the conduct of agricultural operations or other permitted uses. " (P1 . Ex. 4, p. 301-1) Since a mine is neither an agricultural operation nor a permitted use under Subd. 2 , it may not have an accessory use. See Prior Lake Agareaates, supra at 579, holding that 20 conditional uses may not have accessory uses if the ordinance does not so provide. Assuming, arauendo, that the word "permitted" were absent from this section, a ready mix plant nonetheless fails the definition of an accessory use. In City Code Sec. 11.02, paragraph 1, an accessory use is defined as a use which is (1) "subordinate to and serving the principal use" and (2) "customarily incidental thereto. " (Pl. Ex. 4 , p. 262) It is not relevant that uses are related, or have similar equipment. (P1. brief at 29 . ) See Lowry v. City of Mankato, 231 Minn. 108 (1950) . A ready mix plant is not subordinate to, and does not serve, mining. Plaintiffs presented no evidence on this half of the test for an accessory use. A ready mix plant is a separate productive activity, and can operate as an independent use of land. (Testimony of Hoagberg and Fischer) The City has had ready mix plants located in abandoned mines and on construction sites. (Testimony of Ekola) A ready mix plant serves the construction of roads and bridges; (testimony of goagberg) ; not sand and gravel mining. After a mine is depleted, the ready mix plant may continue in operation. Likewise, a sand and gravel mine may operate without a ready mix plant. (Testimony of Shiely and McNeilus) Plaintiffs ' mine has operated for three years without a ready mix plant. (Testimony of Zwiers and Notermann) The second half of the test for an accessory use requires that it be customarily incidental to the main use. A ready mix plant is 21 not customarily incidental to a mine. No mine in the City's Agricultural Preservation zoning district has included a ready mix plant. (Testimony of Ekola) Only one mine in Shakopee has contained a ready mix plant, and that one is located in the Heavy Industrial zoning district. That ready mix plant also has a conditional use permit. (Testimony of Ekola) Plaintiffs presented evidence on this half of the test for an accessory use. They argued that ready mix processing is incidental to rock crushing and sorting. There is a significant qualitative difference between ready mix processing and rock crushing. Compare Hawkins v. Talbot, 248 Minn. 549, 80 N.W.2d 863 (1957) with Prior Lake Aggregates, supra. Both cases involved non-conforming mining uses. In Hawkins, the Court held that the use of a rock crusher was not an extension of the non-conforming use. In Prior Lake Aagregates, on the other hand, the Court held that an asphalt plant was an illegal extension of the non-conforming use. Ready mix plants are far more similar to an asphalt plant, producing road materials, than to a rock crusher. . Plaintiffs also presented testimony that many mines have ready mix plants on site or nearby. (Testimony of Shiely and Fischer) However, if a ready mix plant is merely nearby, it is not within the definition of accessory, which requires that the use be "on the same lot. " (Pl. Ex. 4, p. 262) These witnesses did not know which mines were located in agricultural, industrial, residential, or other zoning districts. (Testimony of Shiely and Fischer) Since each zoning district lists the allowed accessory uses, the zoning 22 is critical to a determination of whether a use may be allowed as an accessory use. Since a conditionally permitted use is not allowed an accessory use, and since a ready mix plant fails the test of being an accessory use to a mine, Plaintiffs are without a legal basis for their claim that a ready mix plant is an accessory use to their mine. Plaintiffs ' conditional use permit and mining permit spell out the uses allowed on their property. Neither the conditional use permit nor the mining permit anticipates or authorizes a ready mix plant. Rather, the processing allowed on Plaintiffs ' property is limited to the crushing and screening identified in those permits and supporting documents. Plaintiffs grace the Court with various out-of-context definitions of "processing" from other states and federal courts. They cite numerous tax cases, which have no bearing on this case whatsoever. Many of the quotes in Plaintiffs ' brief include asphalt plants along with ready mix plants, despite the holding in Prior Lake Aaarecates, supra, that.an asphalt plant is not allowed in a sand and gravel mine located in an agricultural zoning district. The issue before this Court is not whether a ready mix plant could be considered processing in any context, but rather whether a ready mix plant is within the processing allowed on Plaintiffs ' property. As shown by review of the applicable ordinances, permits, and cases, Plaintiffs lack authority to operate a ready mix plant on their property. A ready mix plant is not a permitted use, a 23 conditional use, or an accessory use allowed in the Agricultural Preservation zoning district. It is not included in the allowed processing under Plaintiffs ' conditional use permit or mining permit. It is not authorized in the mining ordinance, nor by the Court' s decision in Scott County Lumber Comoanv, surra. Plaintiffs may not place and operate a ready mix plant on their land in the Agricultural Preservation zoning district. (2) DID THE CITY COUNCIL HAVE A FACTUAL BASIS FOR ITS HOLDING THAT THE READY MIX PLANT SUBSTANTIALLY VIOLATED PLAINTIFFS ' CONDITIONAL USE PERMIT? The City Council determined that Plaintiffs ' action in placing a ready mix plant on their property, and by failing and refusing to remove it, despite assurances that it would be removed, substantially violated the terms of Plaintiffs ' conditional use permit. (Def. Ex. 1) The particular conditions violated were conditions 8, 16, 17, 18, and 19. The term "substantial" is not defined in the zoning ordinance, and therefore the usual and customary definition may be relied upon. The definition of the term "substantial" in Webster's New Collegiate Dictionary, (1980) is "consisting of or relating to substance", and "not imaginary or illusory: real, true". The City Council found substantive and real violations. Condition 8 required all portable buildings to be approved by the Building Official. A portable building as part of or along with the ready mix plant. (Testimony of Kraft) Zwiers admitted that he did not seek a building permit for it. 24 Condition 16, mentioned in the July 25, 1991 letter to Plaintiffs, (P1. Ex. 11; Def. Ex. 1, last page) related to adherence to Maps B and C. As discussed above, Map B showed "structures to be erected" and "location of all machinery to be used in the mining operation", and did not include a ready mix plant. Plaintiffs violated this condition when they added the ready mix plant without City Council approval. Condition 17 required Plaintiffs to have a plan for operation, consisting of Maps A, B, and C, conditions, and the Merila and Associates memo. The ready mix plant violated this condition by being contrary to the Maps and to the Merila and Associates memo, which specifically provides that "There is no intent to mix asphalt or concrete at this site. " (Def. Ex. 2, p. 1) Condition 18 required an environmental assessment worksheet. (Def. Ex. 7) The EAW for Plaintiffs' property did not consider or allow the use of ground water or water utilities, nor did it mention or authorize a ready mix plant. The ready mix plant will use substantial water and impact the environment contrary to the descriptions of the project in the EAW. Condition 19 indicates that the City's approval of the permits is made in reliance upon Plaintiffs' representations regarding the life of the operation. Ready mix plants are a viable use of land by themselves, and may exist in a depleted mine. (Testimony of Hoagberg, Fischer, and Ekola) With this additional, independently productive, use of the property, Plaintiffs might continue this 25 non-farm, non-residential use of the property beyond the 17-year expected life of the mine. At the City Council meeting where these violations were discussed, Plaintiffs did not present any evidence to refute them. (P1. Ex. 15) Plaintiffs now try to come in, after the fact, and justify their position. The City Council could not consider evidence not before it. Its decision must be reviewed based on the facts which were before it, and the validity of that decision must be determined without regard to Plaintiffs' new arguments. Plaintiffs arguments lack merit, as well. Condition 8 requires a building permit. Plaintiffs' attorney repeatedly asked witnesses how many ready mix plants they had "been inside" , apparently admitting that a ready mix plant is a building. Cf. Plaintiffs ' allegation in their brief that a ready mix plant has no roof or enclosure (at p. 21; this "fact" did not appear at trial) , which makes it difficult to comprehend how Plaintiffs ' witnesses had been "inside" some. Plaintiffs do not address or attempt to excuse their violations of Conditions 16, 17, or 18 . They ignore Conditions 16 and 17. Although they argue that there would be no detrimental environmental impact from a ready mix plant, they ignore the fact that the ready mix plant is not covered in Plaintiffs ' environmental assessment worksheet, required by Condition 18 . Plaintiffs ' sole response to Condition 19 is to allege that the mine will be depleted more quickly with a ready mix plant than without. They ignore the potential continuation of the ready mix 26 plant if this Court allows it to be placed on their property under their existing conditional use permit and mining permit. Under Minn. Stat. Sec. 462. 3595, Subd. 3 , a conditional use permit "shall remain in effect as long as the conditions agreed upon are observed. " If a property owner fails to observe those conditions, the City may revoke the permit. Scott County Lumber Company, sutra, at 722 . Likewise, City Code Sec. 11. 04, Subd. 6.C. 11, (P1. Ex. 4, p. 289) , and Condition 20 of Plaintiffs ' conditional use permit provide that the City Council may revoke the permit when the permit holder violates its conditions. Once the City Council found violations, it could elect any of the various available remedies. Minn. Stat. Sec. 462 . 362 provides that a city may enforce its ordinance through penalties provided in the ordinances, or by various court actions. The City revoked two other conditional use permits during the past summer. (Testimony of Laurent) It is hardly surprising that the City Council and Planning Commission would discuss and consider revoking this one, too, for Plaintiffs ' violations. The City tried to work with the Plaintiffs, but the Plaintiffs made assurances and then acted contrary to them. Plaintiffs persistently failed and refused to cooperate with the City. After considering Plaintiffs ' violations of their conditional use permit in a public hearing, at which Plaintiffs could have but did not present any evidence to refute the evidence of violations, the City Council properly found that Plaintiffs had substantially violated their conditional use permit. 27 (3) WHAT IS THE APPROPRIATE REMEDY? The ready mix plant violates the City zoning ordinances, and Plaintiffs ' conditional use permit and mining permit. Due to the revocation of these permits, Plaintiffs have no legal right to operate a mine on their property. Plaintiffs must close down the mine and reclaim the land as required by City Code Sec. 11.05, Subd. 7.D, (P1. Ex. 4) , and Plaintiffs ' Map C, which includes specific land rehabilitation provisions for Plaintiffs ' property. (Def. Ex. 4) An injunction is appropriate to prohibit a property owner from using land in violation of the City zoning ordinance. "Trial courts are empowered to issue injunctions enforcing zoning ordinances. " City of St. Paul, supra at 132 . As our courts have recognized, "an injunction is often the most efficient way for a local governmental unit to deal with continuing zoning violations. " Rockville TP. , supra at 205; City of Minneapolis v. F and R, Inc. , 300 N.W.2d 2, 4 (Minn. 1980) . See also City of Mahtomedi v. Dominic Spvchalla, 308 Minn. 429, 243 N.W. 2d 31 (1976) . The remedies requested by the City are the minimum necessary to protect the public interest. As stated so aptly by the Court in Rockville Tp. , supra, "There is apparent irreparable harm to a governmental unit by a continuous and knowing violation of that body's duly promulgated laws and regulations. To permit such violations is to deny the local unit's authority to govern. " At 205. Plaintiffs ' continued operation in violation of the City Code causes irreparable harm to the City. 28 Despite Plaintiffs ' request, an injunction should not be granted to allow a violation of law. Cf. Kelty v. City of Minneapolis, 157 MN 430, 196 N.W.487 (1923) , holding that a plaintiff may not seek an injunction to keep an illegal structure. The public interest lies in having ordinances enforced, not in allowing one property owner freedom to ignore the laws when it suits him or is profitable for his business. The City's duty of protecting the property rights of all its citizens is paramount. See State v. Stortmen' s Country Club, 214 Minn. 151, 7 N.W. 2d 495 (1943) . Plaintiffs also failed to exhaust their legal remedy, and therefore should not be granted an equitable remedy. Adelman v. Onischuk, 271 Minn. 216, 135 N.W. 2d 670 (1965) . Under Minn. Stat. Sec. 462 . 361, Subd. 2 , a municipality may raise as a defense the fact that the complaining party has not attempted to remedy the grievance by use of procedures available for that purpose under ordinance. Plaintiffs failed to exhaust administrative and legal remedies when they did not appeal the City Administrator's June 13 , 1991 letter under City Code Sec. 11. 04, Subd. 4 . Plaintiffs ' argument that the City owed them notice of their appeal rights is peculiar. Plaintiffs are responsible for pursuing their legal remedies, not the City. Likewise, Plaintiffs are responsible for keeping track of applicable statutes of limitations. A party serious about pursuing its legal remedies will check the relevant statutes and ordinances. 29 The City does not customarily describe appeal information in its enforcement letters, although it does have a practice of notifying people after Planning Commission actions of their right to appeal to the City Council. (Testimony of Ekola) This courtesy should not result in an obligation in a different setting. Here, Plaintiffs were represented by competent counsel, who indicated that Plaintiffs were going to remove the ready mix plant. (Testimony of Kraft and Gleekel) It is far more believable that Plaintiffs ' counsel allowed their appeal period to lapse because he agreed with the letter, than that the letter somehow misled Plaintiffs into foregoing their appeal. (Plaintiffs raise a similar argument that they were due special notice in their letter to Judge Menke dated October 4 , 1991, regarding amendments to the City zoning ordinance. Notices were published and public hearings were held prior to adoption of this ordinance. This ordinance has been discussed in public meetings for approximately nine months, and yet Plaintiffs only now noticed. Their failure to pay attention to the City actions, read the published notices or minutes, attend public meetings, or watch the meetings on television, cannot be blamed on the City. ) Plaintiffs lack clean hands. Although the City sought to work this matter out with Plaintiffs, Plaintiffs have refused to cooperate. Without any objective reason whatsoever, Plaintiffs have accused the City of being arbitrary and capricious. Their extreme prejudice seems to be based on emotions left over from their 1985 lawsuit, and reflects a lack of awareness that staff and 30 the majority of City councilmembers have changed since that litigation. (Testimony of Kraft and Laurent) Present staff and City Council has no emotional ties to the earlier lawsuit, and no ax to grind. (Testimony of Laurent) Plaintiffs ' negative "try and make me" attitude has effectively barred reasoned discussion of the issues. Plaintiffs have ignored the City ordinances and their conditional use permit and mining permit, and have failed to indicate what document or ordinance authorizes the ready mix plant on their property, despite requests from the City. Plaintiffs allowed their previous attorney to represent that the ready mix plant would be removed, then broke the promises to dismantle and remove it. (Testimony of Kraft) Plaintiffs ' extreme prejudice has made it very difficult for the City to work with them. Without a conditional use permit and mining permit, Plaintiffs may not conduct any mining activities on the Property. This fact, coupled with Plaintiffs ' previous reluctance to comply with the City ordinances, causes the City to respectfully request that the Court require Plaintiffs to remove the ready mix plant from their property, cease all mining operations, and to begin and complete the land rehabilitation as required by law. CONCLUSION A ready mix plant is not a permitted, conditional, or accessory use in the Agricultural Preservation zoning district in Shakopee. The City Council reasonably determined thPt the processing allowed on Plaintiffs ' property by their conditional use 31 permit and their mining permit was limited to crushing and screening, but not making ready mix concrete. The City Council had a valid factual basis for its determination that the ready mix plant substantially violated Plaintiffs ' conditional use permit, and appropriately revoked that permit and Plaintiffs ' mining permit. Plaintiffs should be enjoined from operating the ready mix plant on their property, and, due to the revocation of the conditional use permit and mining permit, should cease all mining operations and immediately begin reclamation of the land. Respectfully submitted, Dated: October 9, 1991 _ DEFENDANT CITY OF SHAKOPEE 71 By: Z �` � Karen E. Marty. / (#205746) C,% City Attorney 129 E. First Ave. Shakopee, MN 55379 • (612) 445-3650 [NEZ.FIN] 32 SCOTT COUNTY ECONOMIC DEVELOPMENT COALITION MEETING MINUTES SEPTEMBER 18, 1991 Members in Attendance: Barry Stock, Colleen Jones, Randy Kruger, Greg Hoehn, Ken Anderson, John Albinson, Jim Parsons, and Kay Schmudlach Guests Present: Nat Wisser The fifth meeting of the SCEDC was called to order at 8 : 00 a.m. on September 18, 1991 in the Prior Lake City Hall Community Room. I. Approve Minutes of the August 21, 1991 SCEDC Meeting MOTION BY JOHN ALBINSON, SECONDED BY KEN ANDERSON, TO APPROVE THE AUGUST 21, 1991 MEETING MINUTES. THE MOTION PASSED UNANIMOUSLY. II. Treasurer's Report Kay reported that the checking account balance is now $7,431. 25. That includes the deposit from both the City of Savage for $500. 00 and Scott County for $500.00. However, a check for $2, 500.00 was sent yesterday to Twin Cities Certified Development Company for membership dues. The total in the checking account then is $4,931.25. The only outstanding membership contribution is yet to come from Marquette Bank of Shakopee. III. Appointment of Additional Offices A discussion regarding the Scott County appointment was held. Kay was asked to contact the County to see who would be their official representative on the Board. At the next meeting an appointment will be made. IV. Discuss Membership with Twin Cities Metropolitan Development Company Barry updated the committee on the negotiations with Bob Heck, Executive Director of the Twin Cities Certified Development Company. Barry reported that the coalition has negotiated a membership contract with the Twin Cities Certified Development Company in which half of the membership fee, or $2, 500 will be paid up front, and 1 the remaining will come in from the revenues generated by small business loans processed in Scott County. Barry further reported that there are openings on the Twin Cities Certified Development Company Board if anyone is interested. The development company will be sending us information that will explain the process, and this information will be sent out to our financial institutions so that they are familiar with the process. The committee discussed hosting a training session with the Board from the Scott County Economic Development Coalition and all of the financial reps in the County. Also the committee discussed creating a form that will assist us when using the SBA. Barry will be distributing the information through the next month's agenda packet. At that time we will discuss establishing a training session. V. Progress on the One Year Work Program A. Marketing Committee Jim Parsons reported that the Marketing Committee had met and discussed who should be their initial contact and how they want to contact the businesses, banks, brokers, etc. The committee had also discussed creating a clearing house for information and decided that it should be Barry. The committee also discussed whether they should be designing a brochure and creating a logo. The entire coalition discussed the clearing house issue and agreed that Barry would be the clearing house information person. Barry would have, on his computer, a data bank of all the available land and buildings in Scott County. The Business Retention Committee will be creating a form that will allow us to inventory these sites. The process will be that if someone contacts a city either through the banks, through a broker or through a city and that city cannot meet their needs, the next step will be to refer them to Barry. Barry can then look through his inventory and forward that request either to the city official or contact the business directly with a referral to a specific city and a specific site. The Marketing Committee also discussed hiring a marketing person in the future to put together a professional brochure. The committee than discussed the target. The Business Retention Committee reported that they had also discussed this and decided that business retention should be the number one priority. Our 2 initial focus should be maintaining and expanding the businesses we already have in Scott County. The Marketing Committee agreed with this. There was also some consensus to move this initial phase into a second phase. This may be looking outside of Scott County into the Metropolitan area and targeting other brokers to either an outreach program and/or through hosting a business exposition. B. Business Retention Subcommittee The Business Retention Subcommittee reported that they had been working on several issues. One is to create a brochure that would be very brief. A brochure with a two or three part fold over that will list the services of Scott County Economic Development Coalition. The brochure would offer contact people and list the issues in which these businesses should be responding to such as expansion, new location, labor, etc. The committee is working off a brochure that was prepared by another similar organization. The committee will be putting the brochure together and printing out 1, 000 for initial distribution. Distribution will be based on a list to be prepared by each city and/or going to a list company. John Albinson agreed to research the list companies and see if we can purchase a more comprehensive list of all the businesses in Scott County. The committee also talked about doing a visit. What we would do is pick out 6 businesses that either are significant in size and informant and/or in the process of or' nearing a time when they will be expanding. Kay will be calling city reps to identify those businesses. We will put together a list of 6 per city to visit over the next year. This will be approximately 36 throughout the year. The committee assigned to do the visitation will include the local city representative, the local banker and someone from the business retention team. They will be calling on these businesses to make just a half hour or an hour presentation on the purpose of the Scott County Economic Development Coalition, how the coalition can help that business and how to work with us. Kay will be calling the cities within the next two weeks to get these. City reps are encouraged to contact their local financial institutions to see if there are any businesses that are considering expansion at this time. 3 Other things looked at by the Business Retention Committee include an inventory of business space and an industrial location guide. Kay was asked to draft an inventory list that will be a check list that should be filled out before each meeting by the business rep to bring to the meeting to share so that Barry can keep his data base up to date. Another effort being made by the Business Retention Committee is a labor survey. The labor survey will be a comprehensive county wide labor survey and will take the place of any Star City Survey being done by the individual cities. Barry has contacted the County and for 4 cents a label they will process a label that will provide us with a name of every registered voter in Scott County. Ken Anderson has been working with Kay Lewis from the Extension Service on coming up with a format for the labor survey and a way in which to tabulate the labor survey. Barry suggested that we contact our utilities and ask for a fee to cover the cost. This will be a tentative date for the survey will be Spring. VI. Update on Joint Powers Agreement Revisions Barry distributed an updated copy of the Joint Powers Agreement. The committee walked through all of the revisions being requested by either our coalition or by our attorneys representing it to the committee. The committee requested Kay to have her attorney review it and following his review, and notingno additional changes, the committee will be requesting that their corresponding bodies approve the changes. The October meeting will, hopefully, be the last review of the Joint Powers Agreement. VII. Other Business A survey of land and vacant building status of Scott County communities was discussed. Kay reported that the forms are not available at this time but will be prior to the October meeting. They will be distributed in the October packet so that city reps can fill them out and share them at the meeting. Jim Parsons noted that he was contacted by a business about relocation in Jordan. It's called McKay Data; they create electronic signs. They're currently located in Prior Lake. They are looking for a site that has both highway access and allows electronic signs. The committee discussed this and agreed that Kay should 4 contact them prior to other communities finding sites for this business. John Albinson requested a recap of all the assignments. The following assignments were made: - John Albinson is to get a list of businesses in Scott County. - Barry Stock is to call the County regarding clarification of the labels for the labor survey. - Barry is to work with the Business Retention Committee to produce the brochure. - The Business Retention Committee is to meet with the State regarding a survey format. - The Marketing Committee is to work on a press release to announce that we are now members of the Twin Cities Metropolitan Certified Development Company. - Kay is to have the Joint Powers Agreement reviewed by her attorney. - Kay is to prepare a format for the Business Inventories and the Industry Location Guide. - Kay is to call the cities regarding setting up visits with the 6 businesses from each community. VIII. Adjournment The meeting adjourned at 9:45 a.m. 5 g2"/ SHAKOPEE COMMUNITY DEVELOPMENT COMMISSION City Council Chambers September 18, 1991 Chairman Albinson called the meeting to order at 5: 45 p.m. with the following members present: Charles Brandmire, Mike Beard, Jon Albinson, Jane DuBois and Mike Pennington. Commissioners Miller and Mars were absent. Barry Stock, Assistant City Administrator was also present. Brandmire/Pennington moved to approve the minutes of the July 17 , 1991 meeting as kept. Motion carried unanimously. Mr. Stock gave a brief economic development update. He noted that Rahr Malting is considering a $10, 000, 000 expansion. The expansion, which is planned for 1992 , will include a new malt house. Mr. Stock also noted that the Shakopee City Council recently approved preliminary and final plats for Mulberry Meadow (Market St. ) for nine single family and two duplex lots and Meadows 6th Addition for 32 single family lots. Mr. Stock stated that the City of Shakopee recently acquired several parcels adjacent to 5th Ave. and Market St. At the September 3 , 1991 Shakopee HRA meeting, staff was directed to research development options in terms of zoning for the area in question. Mr. Stock stated that he felt it was important to take a comprehensive look at the overall land use of the property within close proximity to the 5th Ave. and Market St. project when evaluating potential land use impact. Mr. Stock then shared with the Committee the amount of vacant residentially zoned land within the Metropolitan Urban Service Area. At the present time there is only 21 acres of R-3 zoned property. Mr. Stock also noted that the Comprehensive Plan designates 4th Ave. as a collector street. Staff believes that single family housing developments to the south of 4th Ave. should be buffered from 4th Ave. with either commercial development or housing of a higher density. Since the majority of the property south of 4th Ave. is presently occupied by single family housing, staff believes that rezoning the property to R-3 would be more appropriate than commercial zoning. Mr. Stock stated that the draft Comprehensive Plan has designated that the majority of the vacant land within the study area be used for single family residential housing. However, the Comprehensive Plan did not recognize the development restraints within the area. Mr. Stock reminded the Committee that several developers in the past have independently attempted to initiate development within the study area. However, due to the irregularly shaped parcels, bedrock and lack of through streets, development has become cost prohibitive. Mr. Stock stated that rezoning the property to a higher density would allow for the development of single family Minutes of the Community Development Commission Page - 2 September 18, 1991 units up to and including four-plexes and townhouses with five or six units would also be permitted as a conditional use permit. Mr. Stock stated that R-3 zoning would provide a buffer between 4th Ave. and single family residential development to the south of 4th Ave. It would also allow higher land use intensity which may make a residential development project more feasible. Mr. Albinson stated that he was concerned about the small piece of property just east of the City' s Public Works compound and west of the Shakopee East Apartments. He noted that presently the property is zoned B-2 . Staff is proposing to rezone this property to R-4 . Mr. Albinson stated that he felt the property owner would object to R-4 rezoning and would possibly sue the City for a taking of his property. It was the consensus of the Commission that Mr. Albinson was perhaps correct and that the property in question should not be rezoned to R-4 . Commissioner Brandmire stated that he felt that if the City Council was serious about taking a look at rezoning a property that they should take a comprehensive look as outlined by staff. An overall rezoning of the area would appear to be justified based on the rational presented by staff. Brandmire/Pennington moved to recommend to the Shakopee Planning Commission that the appropriate City officials be directed to initiate the rezoning of the property within the study area to R-3 , medium density residential and a small portion of R-4, multi-family residential . Motion carried unanimously. Discussion ensued on the Downtown Committee recommendation regarding additional parking in the downtown area. Mr. Stock stated that for the past two months, staff has been gathering information regarding the availability of parking in the downtown area. The Downtown Committee is recommending to the Community Development Commission that they request City Council to authorize the appropriate City officials to obtain an appraisal of the Gene Brown property for acquisition and parking lot development purposes. Mr. Stock noted that MN/DOT representatives have stated that the City must vacate the parking lots North of 1st Ave. by November 30, 1991. Mr. Stock stated that it may be possible for the City to negotiate an agreement for the continued use of the lots beyond the November 30, 1991 deadline. However, at some point in time, during the actual mini bypass construction, there will be a shortage of parking as a result of the mini bypass construction. Mr. Stock stated that, at the present time, the major employers within the City Hall block include the City of Shakopee and Amzak Cable. The parking needs of these two businesses equate to approximately 34 additional 8 hour stalls. The question to be addressed revolves around suitable parking for these persons when the actual mini Minutes of the Page - 3 Community Development Commission September 18, 1991 bypass is being constructed through the existing parking lots North of 1st Ave. Mr. Stock stated that the Downtown Committee did evaluate several alternatives, including the acquisition of the Gene Brown property. The Gene Brown parcel has a suggested list price of $107 , 000 . The cost estimate to improve the site for parking purposes ranges between $25, 000 and $30, 000. If the parking lot were developed, it would create between 40 and 46 new parking stalls. Mr. Stock noted that Mr. Brown has stated in the past that he would not be willing to entertain a lease agreement with the City for temporary parking needs. A second alternative considered as a potential parking site is located on the City owned property behind the library. The parcel is approximately the same size as the Brown property and subsequently generate the same number of parking spaces. The cost estimate for parking lot construction would be comparable to the Gene Brown parcel . The third alternative considered by staff and the Downtown Committee revolved around the Wampach property. Mr. Stock stated that the Downtown Committee eliminated this as an alternative due to its proximity to potential users of said parking lot. Mr. Stock stated that currently Marquette Bank owns the parking lot adjacent to their Auto Bank facility at the corner of 3rd and Holmes St. The lot provides parking for approximately 26 stalls. Mr. Stock noted that he has received a correspondence from Mr. Mike Phillips, Vice-president and cashier from Marquette Bank, suggesting a proposed leasing arrangement. Mr. Stock stated that the site could be leased on an annual basis for approximately $6, 600 . Commissioner Brandmire stated that he is a little bit concerned about the property owners who will be relocated as a result of the mini bypass. He stated that he is also concerned about the future development of the property North of 1st Ave. He felt that perhaps it was time for the City to consider having a consultant or developer look at the downtown to determine where additional parking lots should be created as well as what redevelopment potential there may be in the downtown area, especially on the property located North of 1st Ave. and south of the mini bypass. Mr. Stock stated that the Downtown Committee has met with all the property owners who will be relocated as a result of the mini bypass. Many of the persons to be relocated occupy residential units. Jack Brambilla also has discussed the possibility of renovating his building located at the corner of Lewis and 1st Ave. for commercial purposes. Presently several of his tenants will be forced to relocate and he is considering redeveloping the aforementioned space for their use. Mr. Stock also stated that the Downtown Committee is presently working on a list of work tasks Minutes of the Community Development Commission Page - 4 September 18, 1991 that could be performed by a consultant. The Committee has, in the past, discussed utilizing a consultant to develop a set of requests for proposal specifications that could be used to solicit developer interest in the downtown area. Mr. Brandmire stated that a number of residents feel that parking in the downtown area is inadequate and therefore do not shop in the downtown area. Mr. Brandmire went on to state that the identification of additional parking spaces was not going to be the answer to resolving all the problems in the downtown area. Commissioner Albinson stated that he felt the idea of leasing parking spaces from Marquette Bank seemed to be the most attractive because it gave the City of Shakopee time to perhaps hire a consultant who can develop a set of requests for proposals specifications to solicit developer interest in the downtown area. It also would simply give the City Council time to decide what, if any, action they want to consider to facilitate redevelopment in the downtown area. Discussion ensued on the market demand for commercial space in Shakopee. Discussion also ensued on what the CDC can do to facilitate developer interest in downtown Shakopee. Mr. Albinson stated that the viability of a redevelopment project in downtown Shakopee is still three years down the road. Mr. Stock stated that Mr. Albinson is correct but that if Council chooses a redevelopment approach, it will take time. Finally, to attract a developer is not going to happen overnight, even with a consultant' s concept plan, market analysis and financial assistance package. Beard/DuBois moved to recommend to City Council that they direct the appropriate City officials to take the necessary steps to develop the parking lot behind 1st Ave. and also negotiate a lease arrangement with Marquette Bank for parking adjacent to their Auto Bank facility. Motion carried with Albinson voting nay. Commissioner Beard stated that he felt the action taken would save the City some money and keep other properties on the tax rolls. Chairman Albinson stated that he was not sufficiently satisfied that the parking behind the Library was needed. He felt that perhaps the parking needs could be accommodated through a leasing arrangement with Marquette Bank. Commissioner Beard stated that he has not noticed a serious parking problem in the downtown area. However, he stated that the downtown business owners are here on a daily basis and that if they believe there is a problem, that he would defer to their knowledge of the problem. Commissioner DuBois stated that she felt that if the Minutes of the Page - 5 Community Development Commission September 18, 1991 downtown business owners could encourage their employees to park in parking lots further away from their businesses, or perhaps on street, that it would eliminate much of the alleged parking problem in the downtown area. Commissioner DuBois questioned whether or not it would be possible to put crushed rock down as a surface for the parking lot behind the Library to save some dollars. Mr. Albinson stated that he thought this would be in conflict with the City Ordinance. Mr. Stock stated that he believed Mr. Albinson was correct. Brandmire/Beard moved to table the review of the 1991 CDC One and Five Year Work Plans. Motion carried unanimously. Beard/DuBois moved to adjourn the meeting at 7 : 00 p.m. Motion carried unanimously. Barry A. Stock, Recording Secretary MINUTES OF THE SHAKOPEE PUBLIC UTILITIES COMMISSION The Shakopee Public Utilities Commission convened in adjourned regular meeting on September 9 , 1991 at 4 : 30 P.M. in the Utilities meeting room. MEMBERS PRESENT : Commissioners Cook, Kirchmeier and O' Toole . Also Liaison Wampach, Manager Van Hout and Secretary Menden. Motion by Cook, seconded by O'Toole that the minutes of the July 1 , 1991 regular meeting be approved as kept . Motion carried. Commissioner Kirchmeier abstained. Motion by Kirchmeier, seconded by O'Toole that the minutes of the August 5 , 1991 regular meeting and September 3 , 1991 regular meeting be approved as kept . Motion carried. A communication from Murphy' s Landing regarding the approval by their board to purchase the 150 KVA transformer over a five year period. They will be billed for the time and material for installing the transformer. Liaison Wampach gave his report . Manager Van Hout was asked whether he had gotten a request for a street light at 6th and Harrison . Revised estimates for the downtown bypass electric relocation was given to the Commission . The estimate for the Shakopee Public Utilities Commission cost was $217 ,000 . 00 . The bid opening will be held on September 18 , 1991 at the Shakopee Public Utilities building . The Tahpah Park sprinkler service was discussed. Manager VanHout recommended that exception be granted from the standard SPDC requirements for a single meter and backflow valve. The exception is due to City ownership and control of the Park. All State plumbing code requirements would still be met . It was the concensus of the Commission to forego our requirement of a meter and backflow preventor in the required location due to the public nature of the project . The progress of the tank painting and cleaning was reported by Manager Van Hout . The Comm 7sion congratuiat, T Ray Friedges on recognitior of an accomplishment achievemer.'. ward given to him by the MMUA on accrediation of classes cn first line supervision taken. The Commission was advised that notification of our cold weather rules must be given to customers by October 15 . Dates for the Fall Minnesota Municipal Utilities Association meetings were given the Commission . The Meadows 6th Addition plat was reported by Manager Van Hout . There were no lost time accidents for August , 1991 . Motion by Kirchmeier, seconded by O'Toole that the meeting be adjourned. Motion carried. , / /. G (.0,6 '1 �- ` Barbara Menden, Commission Secretary MINUTES OF THE SHAKOPEE PUBLIC UTILITIES COMMISSION The Shakopee Public Utilities Commission convened in special session on September 16, 1991 in the Utilities meeting room. MEMBERS PRESENT: Commissioners Kirchmeier, O'Toole and Cook. Also Manager Van Hout and Secretary Menden. The Personnel Policies for the Shakopee Public Utilities Commission employees were discussed at length. Various changes are to be made to the policies and will be presented to the employees along with their 1992 wages discussion . Motion by O' Toole, seconded by Kirchmeier to adjourn to executive session for the purpose of contract discussions . Motion carried. Motion by Kirchmeier , seconded by O'Toole to adjourn . Motion carried . 1 k -Barbara Menden, Commission Secretary MINUTES OF THE SHAKOPEE PUBLIC UTILITIES COMMISSION The Shakopee Public Utilities Commission convened in special session on September 30, 1991 at 4 : 30 P.M. in the Utilities meeting room . MEMBERS PRESENT: Commissioners Cook , Kirchmeier and O'Toole . Also Manager Van Hout . Secretary Menden was absent . Motion by Kirchmeier, seconded by O' Toole that that Shakopee Public Utilities Commission award the Highway 169 distribution relocation project to the low bidder, Schmader Electric Construction in the amount of $379 , 775 . 00 . Motion carried. Motion by O' Toole , seconded by Kirchmeier that the • meeting be adjourned. Motion carried. Lou Van Rout , Manager ATTEST: I1.r" \ -- Barbara Barbara Menden- C mission. Sec . Minnesota Department of Health Division of Environmental Health 925 Delaware Street Southeast P.O. Box 59040 Minneapolis, MN 55459-0040 (612) 627-5100 • September 22, 1991 . fiCT 0 7 1991 Shakopee City Council c/o Ms. Judith Cox, Clerk Cl7y .nit- City Hall 129 East First Avenue Shakopee, Minnesota 55379 Dear Council Members: This letter is to inform you of the results of pesticide analyses conducted on water samples collected on June 5, 1991 , from city Wells Nos. 2, 6 and 7. The sampling was performed as part of the routine monitoring of your water supply conducted by the Minnesota Department of Health. As indicated by the attached pesticide test results, atrazine was detected in the well water. The Environmental Protection Agency has established a maximum contaminant level (MCL) (enforceable standard) for atrazine. Levels Detected Maximum Contaminant Level Chemical (micrograms per liter) (micrograms per liter) atrazine Not Detected (Well 2) 3.0 0.03 (Well 6) 0.09 (Well 7) The concentration of this chemical was below the MCL. Based on the concentration of pesticide detected, the department offers the following recommendations or comments: 1 . There is no need to limit the use of the well due to the presence of atrazine as long as the concentration of atrazine remains below the MCL. 2. This Department will continue to monitor the pesticide levels as a part of our routine public water supply surveillance program. If you have any questions regarding the analytical results, please contact me at 612/627-5180. Sincerely, %-Zf.. Richard D. Clark, P.E. , Supervisor Public Water Supply Unit Section of Water Supply and Well Management RDC:RHS:bs Enclosure cc: John Hines, Minnesota Department of Agriculture Water Superintendent An Equal Opportunity Employer r7 CITY OF SHAKOPEE BUILDING ACTIVITY REPORT - SEPTEMBER 1991 September 1991 September 1990 No. No. Valuation No. No. Valuation Month Y.T.D. Y.T.D. Month Y.T.D. Y.T.D. Single Family-Sewered 5 83 5,967,850 8 69 4,375,700 Single Family-Septic 1 12 1,945, 600 3 15 1,965, 600 Multiple Dwellings - 7 779, 600 - (# Units) (YTD Units) (-) (14) - (-) (-) - Dwelling Additions 7 65 321,470 1 52 127, 450 Other 3 15 114,380 1 14 120, 110 New Comm. Bldgs 1 5 2, 611,800 1 5 4, 460, 000 Comm. Bldg. Addns. - 1 40, 000 4 1,741, 000 - New Industrial-Sewered - - - 1 11,972 , 000 Ind. Sewered Addns. - 1 16,400 - 2 1, 012,800 New Industrial-Septic - - - -- - - - - Ind. Septic Addns. - - - Accessory/Garages 4 32 257,290 2 27 153 ,804 Signs & Fences 3 53 136,067 3 65 86,745 Fireplaces/Wood Stoves 1 2 5, 800 1 10 21,755 Grading/Foundation - 3 202 , 500 1 5 101, 000 Remodeling (Res. ) 1 26 188, 209 - 18 95, 000 Remodeling (Inst. ) - 1 30,000 - - - Remodeling (Comm/Ind. ) 2 38 2 ,489,397 - 26 655,700 TOTAL TAXABLE 28 343 15, 076,363 21 313 26,888, 664 TOTAL INSTITUTIONAL - 1 30,000 - - GRAND TOTAL 28 344 15;106,363 21 313 26,888, 664 No. YTD. No. YTD. Variances 2 5 1 3 Conditional Use 2 8 1 6 Rezoning - 2 - - - - Moving - Electric 44 263 30 236 Plumbing & Heating 49 364 36 308 Razing Permits Residential - 1 1 2 - 2 Comm./Ind./Inst. - - Total dwelling units in City after completion of all construction permitted to date 4, 588 Jeanette Shaner Building Department Secretary CITY OF SHAKOPEE BUILDING PERMITS ISSUED IN SEPTEMBER, 1991 9192 Dean Frick 1136 Clover Court Deck 700 9193 Timothy Walters 1009 Dakota Street Deck 1, 680 9194 Novak Fleck 963 Goldenrod Lane House 75, 000 L13 B 2, Meadows 5th 9195 Northstar Auto 4908 Valley Ind. Blvd. No. Sign 15, 000 9196 Michael Kurvers 1198 Jefferson Street Porch 4, 300 9197 LeRoy Menke 1760 E. 4th Avenue Remodel 6, 000 9198 Bernard Jeurissen 2967 Marschall Road Grain Bin 5, 000 9199 Marlyn Estenson 723 West 1st Avenue Sign 2,500 9200 Lawrence Sign Inc. 327 So. Marschall Road Sign 6,700 9201 John O'Loughlin 2988 Valley View Road Ag 30, 000 9202 Rick Jeurissen ' 2967 Marschall Road Mobile Home 9, 000 9203 Novak Fleck 1064 11th Avenue East House 71, 900 L 2 B 2, Meadows 5th 9204 Gary Sorenson 4915 Eagle Creek Blvd. Deck/remodel 6,400 9205 Fine Line Homes 1308 llth 'Avenue East House 74, 150 L 16 B 2, Prairie Estates 9206 Harold Olson 940 So. Holmes Stg Bldg 2, 000 9207 Joan Rosentreter 1271 Sapphire Lane Remodel 3,800 9208 Edman Builders 2043 Eaglewood Drive House 155, 000 L 1 B 1, Eaglewood 2nd 9209 Twin City Fireplace 1057 Van Buren Stove 1, 600 9210 Jeff Flood 7700 Highway 101 Comm. 10, 000 9211 Ronald Pallansch 430 East 5th Avenue Stg Bldg 2, 000 9212 Michael Koehnen 1192 Murphy Court Deck 2, 900 9213 Great Scapes Inc. 320-330 Shawnee Trail Decks 6,500 9214 Kraus Anderson 380 Marschall Road Comm. 1, 350, 000 9215 Timothy Platt 8615 Boiling Springs Ln. Stg Bldg 9, 000 9216 John Trutnau 1016 Dakota Street Addn. 25, 000 9217 Novak Fleck 1008 Goldenrod Lane House 67, 500 L 2 B 3, Meadows 5th 9218 Novak Fleck 1043 Goldenrod Lane House 61,700 L 5 B 1, Meadows 5th 9219 Cole VanHorn 437 East 4th Avenue Stg Bldg 2, 000 Total: $2, 007,330 TO: Dennis R. Kraft, City Administrator FROM: Gregg Voxland, Finance Director RE: Riva Ridge Industrial Revenue bonds DATE: October 1, 1991 I have received a copy of a letter from the trustee for the above mentioned bonds to Mr. Hauser. The ownership of Rive Ridge has apparently failed to supply the trustee with certain management information. Unless the information is supplied shortly, the trustee will declare a technical default on the bond issue. The actual payment of the debt service on the bonds is current as far as I know. The impact of this is that while the City has no financial obligation for bond payments, the bonds are issued in the name of the City and a default can have a negative impact on Shakopee's image in the market place. This is for Council informational purposes only. r, r r 0 N r i N 4- Z a W C 2 - r 0 �1 0 4-O( m 1A-1 0 0 o > RI m m -i m -i v < m D > v Z < v 0 v -4 D > -4 < -4 ,o > PI 0 -4 CZ) -I r -4 v -4 2* -- +0r 0 0 m A 0 A rn -4 X -4 3 4- C z D 4-i D C) MO 0 C D D X r Z r 0 Zrn Z 1- �' 11 C -1Z 0 N to Z rn 00 M -r 0 a r 70 4-1 D m > r r" r. < O -n 73 c Z 0 (0(0(04-4 WW(0(0(0rrr4-r (0W(0WWrrrr4-r WWWWWWI 4-4-4- r (00000070) WWWWWO U1UiU1U1 WWWWWWWWWWW WWWWWWNNNN 4- 4-00-4(04- 00(4NJ4- UiWN4 COWNrVV0AWN4- U1WNr00V o0CI4- r OO130) 0DC3-13DC) 0OC)0rM0 C) 00-13102. 3 -(-(Mrrn -iNC>C)m -41110mrrm D -4-Imre>0 D SS0Z S00-<C)Z 2<C'110rZ 73 2273Q)0)I < xia zrnm0Ca rnmz-rCr 1 mmn i- 0 arn / mrC)C)Z-A D mm0 mz a C)> 0<112. 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Chairperson Melanie Kahleck Presiding 1. 7 : 30 P.M. CONTINUED PUBLIC HEARING: To consider an application for a Mineral Extraction and Land Rehabilitation and a Conditional Use Permit for gravel Mining. Applicant: David McKenna Action: Resolution No. 604 2 . 8 : 00 P.M. CONTINUED PUBLIC HEARING: To consider an application for a Mineral Extraction and Land Rehabilitation and a Conditional Use Permit for gravel Mining. Applicant: Raymond Ames Action: Resolution No. 624 3 . Adjourn Lindberg S. Ekola City Planner NOTE TO PLANNING MEMBERS : 1. If you have any questions or need additional information on any of the above items, please call Terrie or Aggie on the Monday or Tuesday prior to the meeting at 445-3650 . 2 . If you are unable to attend the meeting, please call the Planning Department prior to the meeting. TENTATIVE AGENDA ADJ.REG.SESSION SHAKOPEE, MINNESOTA OCTOBER 15, 1991 Mayor Gary Laurent presiding Swearing in of new police officer, Craig Robson 1] Roll Call at 7 : 00 P.M. 2] Reading by Mayor Laurent of City' s Non-Discrimination Policy 3] Approval of Agenda 4] Liaison Reports from Councilmembers 5] Mayor' s Report 6] RECOGNITION BY CITY COUNCIL OF INTERESTED CITIZENS 7 ] Approval of Consent Business - (All items listed with an asterisk are considered to be routine by the City Council and will be enacted by one motion. There will be no separate discussion of these items unless a Councilmember so requests, in which event the item will be removed from the consent agenda and considered in its normal sequence on the agenda. ) 8] Approval of Minutes of September 17th, and 24th, 1991 9] Communications: 10] 7 : 30 P.M. Public Hearing on the vacation of cartways (Breegeman, Mielke, and Petsch) 11] Boards and Commissions: Planning Commission: *a] Correcting Grammatical Errors in the Zoning Regulations, Ordinance No. 320 12 ] Reports from Staff: a] Report by City Attorney on Roberts Rules - Consideration of suspension of rules to reconsider amending zoning ordinance_ b] Early Retirement *c] Approve Paying Assessment Against City Property *d] Comprehensive Sewer Plan *e] Request for Deferment of Special Assessments *f] Application for Premises Permit *g] Approve Bills in Amount of $612 , 275. 54 *h] Purchasing Error 13 ] Resolutions and Ordinances: *a] Ord. No. 321 - Changing Snow Emergency Routes 14] Other Business: 15] Adjourn Dennis R. Kraft, City Administrator OFFICIAL PROCEEDINGS OF THE SHAKOPEE CITY COUNCIL ADJ. REG. SESSION SHAKOPEE, MINNESOTA SEPTEMBER 17 , 1991 Mayor Laurent called the meeting to order with Cncl. Vierling, Clay, Zak, Sweeney and Wampach present. Also present were Dennis Kraft, City Administrator; Barry Stock, Asst. City Administrator; Dave Hutton, City Engineer; Karen Marty, City Attorney; Lindberg Ekola, City Planner; and Judith Cox, City Clerk. The following items were added to the agenda: 16 . 5 - Special HRA meeting. 13A - Discussion on assessments for 2nd Avenue. Sweeney/Vierling moved to approve the agenda as amended. Motion carried unanimously. Liaison reports were given by Councilmembers. Mayor Laurent gave the Mayors report. Mayor Laurent asked if there was anyone from the audience who wished to address anything not on the agenda. There was no response. The following items were added to the consent business: 10A - Clete Link rezoning request. 11F - Stop sign at Bluff Avenue. lli - Vacation of Cartways. 12C - Resolution No. 3468 . The following items were removed from consent business: 10E - Preliminary and final plat of Mulberry Meadow. 11h - Shakopee Bypass - Letter of Understanding. Vierling/Zak moved to approve the consent business as amended. _ Motion carried with Cncl. Sweeney abstaining from 11F. Wampach/Zak moved to approve the minutes of August 20, 27 , and 28th, 1991. Motion carried unanimously. Mr. Jim Stillman was present to give a review of the Municipal Facility Task Force Report. He said the goal of the task force was to identify and analyze needs within the moratorium area and south of the Senior High School, and to look at the different funding options available. The high priorities the task force identified were a Community Civic Center, Sr. High School addition, Additional Athletic Fields, Soccer, Football, etc. , Sr. Housing, City Hall , Library, Band Shell . Official Proceedings of the September 17 , 1991 Shakopee City Council Page -2- Sweeney/Wampach moved to direct the appropriate city officials to place the Municipal Facility Task Force Report on the next Committee of the Whole agenda for further discussion. Motion carried unanimously. Clay/Sweeney moved to direct staff to prepare necessary documents to release a portion of the land South of High School from the moratorium. Motion carried unanimously. Mayor Laurent opened the public hearing on an amendment to the zoning ordinance which would delete mineral extraction as a conditional use in the Agricultural and Rural Residential districts - Ordinance No. 304 . Mr. Ekola explained that City Council directed staff to schedule another public hearing to reconsider the proposed ordinance amendment to delete mineral extraction as a conditional use in the AG and R-1 districts. Subsequent to this action the Planning Commission reaffirmed their earlier action to recommend to City Council to delete mineral extraction as a conditional use in the Ag and R-1 districts. He stated that the four alternatives identified by staff are to adopt the ordinance amendment, amend the ordinance as drafted, table the ordinance, or take no action. James Bates, 16670 Franklin Trail, representing Richard and Dave McKenna, said the McKenna ' s have been working on this project since September of 1990 and have spent a large amount of money in pursuing the permit for a gravel operation on the border of Prior Lake and Shakopee. He said it would be unfair to the McKenna 's to delete mineral extraction as a conditional use now as they have followed all the rules to obtain a permit. They requested that the matter be delayed to allow additional time for their permit application to be completed. Dave McKenna, 8221 Horizon Dr. , addressed the mediation that will be taking place on Friday, September 27th. He said they are prepared to go to the Planning Commission when the Environmental Assessment Worksheet is completed. Mayor Laurent closed the public hearing. Dennis Kraft said that if the ordinance is passed, their alternative is to either sue or apply for a rezoning from AG to Industrial . Melanie Kahleck was present and said the Planning Commission would require that an Environmental Assessment Worksheet be done. Discussion was held on adopting the ordinance but postponing its effective date. Official Proceedings of the September 17 , 1991 Shakopee City Council Page -3- Zak/Sweeney offered Ordinance No. 304 , An Ordinance of the City of Shakopee amending City Code, Chapter 11, Zoning Ordinance by amending Section 11. 24 , Agricultural Preservation District (AG) , and Section 11. 25, Rural Residential District (R-1) , to delete mineral extraction as a conditional use, and moved its adoption. Sweeney/Zak moved to amend the ordinance to become effective as of November 7 , 1991. Motion carried with Cncl. Clay opposed. Motion carried unanimously on main motion as amended. Dave Hutton reviewed the request for street light improvements to 6th Avenue between Jackson and Van Buren Street. The total cost would be approximately $1, 375, with $45. 83 cost per parcel . Jim Realander, 1679 6th Avenue, was present and said he is in favor of having the street light put in and assessed to the property owners. Mayor Laurent stated that the City appreciated Mr. Jasper' s giving an easement for the street light at no cost to the City. Mayor Laurent closed the public hearing. Wampach/Zak offered Resolution No. 3469 , A Resolution Ordering a Street Light on 6th Avenue, Between Jackson Street and VanBuren Street, Project 1991-9 , and moved for its adoption. Motion carried unanimously. Vierling/Zak offered Ordinance No. 318 , an Ordinance of the City of Shakopee, Minnesota, Rezoning Certain Land From R-4 to B-1, Which Land is Located at 1440 West 3rd Avenue, and moved for its adoption. (Motion approved under consent business) . Lindberg Ekola reviewed an ordinance amendment which would allow additional conditional uses in the I-1 and I-2 districts. It would allow the sale of industrial equipment and licensed recreational vehicles. He said the Planning Commission has recommended denial. Rod Krass, representing the Brambilla ' s suggested some changes such as allowing retail sales of passenger automobiles, and light duty trucks that could be taken in on trade, and also to delete the provision to allow these commercial uses in the I-1 district and limit them only to the I-2 district. Mr. Brambilla would like to relocate to an I-2 zone which is in his financial reach and is a good location. Jon Albinson, representing the three property owners adjacent to the proposed Brambilla site, said that he feels this would be spot usage and should be looked at carefully by the City Council . He said the sale of trade in vehicles should not be allowed at all. Steve Korte, Conklin Company, said they are a proponent of the Planning Commission recommended denial of this Official Proceedings of the September 17 , 1991 Shakopee City Council Page -4- amendment. He feels the City should follow the Planning Commission' s recommendations and that this would constitute leap frogging from one zone to the I-2 zone. He feels it would open up the chance of many other businesses wanting to come into this area. He said he had a concern on the traffic safety issue, a business such as this would create more traffic on the thoroughfare. Melanie Kahleck, Chair of the Planning Commission, said that the Planning Commission voted against this proposed amendment because of their responsibility to protect the rights of the residents within the Valley Industrial Park. Monique Brambilla, 620 Monroe Street, said she does not feel a traffic safety issue would arise. Rod Krass said that in all probability Mr. Brambilla ' s request would be the only one in 20 years. Cncl . Wampach said he feels the City should try and help Mr. Brambilla out as best they can. He said he is in support of the Brambilla ' s request, he has a good business and has been a good citizen. Cncl. Vierling said that it is not Mr. Brambilla that is being voted on, it is simply the usage of this land. Cncl. Zak asked if the old Malkerson property would serve his needs. Mr. Brambilla said the Malkerson property would require too much extensive work on the already existing garages to accommodate RVs. He said he has been in the City for 32 years and that it is not his idea to move, he is being forced. He said he is simply asking the City for help, this is the only available parcel that he can afford. Zak/Vierling offered Ordinance No. 319, An Ordinance of the City of Shakopee, Minnesota, Amending Chapter 11, Land Use Regulation (Zoning) , Section 11 . 32 , Light Industry (I-1) , and Section 11. 33 , Heavy Industrial (I-2) , By Adding 'One New Paragraph to Subd. 3 , Conditional Uses, In Each Section, Relating to Retail Sales, and moved its adoption. Motion fails with Cncl . Clay, Vierling, Zak, Mayor Laurent opposed and Cncl . Sweeney and Wampach in favor of the ordinance. Mayor Laurent called a recess at 9: 20 p.m. Mayor Laurent reconvened the City Council at 9 : 35 p.m. Vierling/Zak offered Resolution No. 3461, A Resolution Approving the Preliminary and Final Plat of West End Addition, and moved for its adoption. (Motion approved under consent business) . Vierling/Zak offered Resolution No. 3462 , A Resolution Approving the Preliminary and Final Plat of Mark J. Weinandt Addition, and moved for its adoption. (Motion approved under consent business) . Sweeney/Zak offered Resolution No. 3471 Resolution Authorizing Issuance, Awarding Sale, Prescribing the Form and Details and Providing for the Payment of $1, 725, 000 General Obligation Official Proceedings of the September 17 , 1991 Shakopee City Council Page -5- Improvement Bonds, Series 1991A, and moved for its adoption. Motion carried unanimously. Vierling/Wampach moved to direct the appropriate City officials to enter into design agreements with Boarman, Kroos, Pfister and Associations and Intra Design for design work on the new City Hall in the amounts indicated in the proposals submitted by those respective firms. Motion carried unanimously. Sweeney/Clay offered Resolution No. 3463 , A Resolution Approving the Preliminary and Final Plat of Mulberry Meadow 1st Addition, and moved for its adoption. Motion carried unanimously. Vierling/Zak offered Resolution No. 3464 , A Resolution Approving the Final Plat of the Meadows, 6th Addition, and moved for its adoption. (Motion approved under consent business) . Sweeney/Vierling moved to refer the 1992-1996 Capital Improvement Program to the Committee of the Whole for further discussion. Motion carried unanimously. Vierling/Zak moved to remove from table the applications from Dangerfield ' s Restaurant, Inc. for On Sale and Sunday Intoxicating Liquor Licenses. (Motion approved under consent business) . Vierling/Zak moved to approve the applications and grant On-Sale and Sunday Intoxicating Liquor Licenses to Dangerfield' s Restaurant Inc. , 1583 East 1st Avenue and direct staff to deliver the licenses upon their compliance with the City Code. (Motion approved under consent business) . Vierling/Zak moved to ratify waiving the 30 day review period for the application for exemption from lawful gambling license by Shakopee Ducks Unlimited for September 17 , 1991 at the Shakopee VFW Club in Shakopee. (Motion approved under consent business) . Vierling/Zak moved to approve the bills in the amount of $599 , 731. 38 . (Motion approved under consent business) . Vierling/Zak moved to authorize the appropriate City officials to execute an agreement with the Shakopee Jaycees for the funding on the Tahpah Park Sprinkler System, Project No. 1991-4 , whereby the Shakopee Jaycees will contribute a total sum of $33 , 665 . 00 towards this project. (Motion approved under consent business) . Vierling/Zak moved to direct the appropriate City staff to make the following changes to traffic signage on Bluff Avenue: 1. Remove the stop signs at Market Street and Bluff Avenue because they do not meet State warrants. Official Proceedings of the September 17, 1991 Shakopee City Council Page -6- 2 . Remove the stop signs at Prairie Street and Bluff Avenue because they do not meet State warrants. 3. Install "No Trucks Allowed" signs at Naumkeag Street and Bluff Avenue and any other locations on Bluff Avenue as deemed necessary by the Public Works Department to prohibit trucks from using that portion of Bluff Avenue between Naumkeag Street and Main Street. 4. Install "No Parking" signs on Bluff Avenue between Naumkeag Street and Marschall Road to prohibit trucks from parking overnight on a city street. (Motion approved under consent business) . Vierling/Zak moved to appoint Dave Hutton, Public Works Director, as the City of Shakopee's Commissioner in the Shakopee Basin Watershed Management Organization for the terms of December 31, 1988 - December 31, 1990 and December 31, 1990 - December 31, 1992 . (Motion approved under consent business) . Sweeney/Clay moved to authorize the appropriate City officials to execute a revised Letter of Understanding dated August 21, 1991 between the City of Shakopee and Mn/DOT regarding the Shakopee Bypass (DOC #CC-190) . Motion carried with Cncl. Sweeney opposed. Vierling/Zak offered Resolution No. 3465, A Resolution Setting a Public Hearing to Consider Vacating 3 Unnamed Roads in the City of Shakopee Commonly Referred to as the Mielkle driveway, the Breegemann driveway and the Petsch driveway, and moved for its adoption. (Motion approved under consent business) . Dave Hutton reviewed the Scott County Transportation Plan. Sweeney/Vierling moved to direct Dave Hutton to carry on further discussion with Brad Larson, Scott County, and bring back the information to Council. Motion carried unanimously. Vierling/Clay moved to direct staff to solicit proposals for consultant services to add two additional Engineering Consultants, in addition to retaining Orr-Schelen-Mayeron and Associates, as the City's consultants. Motion carried unanimously. Vierling/Zak moved to approve the payment in the amount of $6, 000. 00 to S. M. Hentges & Sons, Inc. , P.O. Box 212 , Shakopee, MN 55379 for the Valley Industrial Blvd. , North, Project No. 1990-8. (Motion approved under consent business) . The City Administrator updated the Council on meetings he has attended regarding the Bloomington Ferry Bridge and the Highway 101/CR 18 interchange. Official Proceedings of the September 17 , 1991page -7- Shakopee City Council Sweeney/Wampach moved that the first Council meeting in November be changed to the first Wednesday in November, which is November 6th, at 7 : 00 p.m. Motion carried unanimously. Vierling/Zak offered Resolution No. 3466, A Resolution Accepting Bids on Tahpah Park Sprinkler System, Project No. 1991-4 , and moved for its adoption. (Motion approved under consent business) . Vierling/Zak offered Resolution No. 1467 , A Resolution Accepting Bid on Jefferson Street Watermain from 12th Avenue to Tahpah Park, Project No. 1991-8 , and moved for its adoption. (Motion approved under consent business) . Vierling/Zak moved to approve a contingency in the amount of 15% for use by the City Engineer in authorizing change orders or quantity adjustments on the 1991-8 project. (Motion approved under consent business) . Vierling/Zak offered Resolution No. 3468 , A Resolution Declaring Adequacy of Petition and Ordering the Preparation of a Report for Improvements to Vierling Drive, Between County Road 79 and County Road 17 , and moved for its adoption. (Motion approved under consent business) . Vierling/Zak offered Resolution No. 3470 , A Resolution Accepting Bid on the 1991 Pavement Preservation Program, Project No. 1991-6, and moved for its adoption. (Motion approved under consent business) . Vierling/Zak moved to authorize the appropriate City staff to increase the contract quantities by a maximum of 25% by adding additional streets to the 1991-6 project. (Motion approved under consent business) . Cncl . Sweeney stated that he had some concerns about the access of citizens to the system. He noted that in the past residents have contested their assessments because they were knowledgeable about the system and how it worked. He is concerned that there may be people who live in the 2nd Avenue improvement area with large assessments who are not comfortable in approaching city hall and dealing with the system and consequently are denied equal access to the system. He suggested a pilot program where the City could assure that the people whom the City is assessing actually understand what their rights are and how to exercise those rights. He suggested that we recruit some staff members whose skills are that of dealing with people. He suggested that they draft a letter to the people within the 2nd Avenue Improvement area offering to meet with them on a one to one basis and explain to them what their rights are and how to access those rights. Consensus was that the pilot program was a good idea. Official Proceedings of the September 17, 1991 Shakopee City Council Page -8- The next Committee of the Whole meetings were set for October 8th and October 22nd, at 7:00 p.m. Mayor Laurent recessed for an executive session at 10:45 p.m. Mayor Laurent re-convened the City Council at 11:54 p.m. and stated that no action was taken during the executive session. Zak/Vierling moved to direct the appropriate City officials to execute stipulation agreements with MnDOT for the property to be acquired as a result of the Mini By-pass project. Motion carried unanimously. Sweeney/Vierling moved to appoint the City Attorney as Deputy City Clerk for the purpose of taking minutes of the City Council meeting on September 24th at 8:30 a.m. at the Scott County Courthouse. Motion carried unanimously. Sweeney/Vierling moved to adjourn to September 24, 1991 at 8:30 a.m. Motion carried unanimously. [The meeting will take place at the Scott County Courthouse prior to the trial regarding the revocation of the conditional use permit for NBZ formerly Scott County Lumber. ] The meeting adjourned at 11:56 p.m. Tic Ji d'th S. Cox it Clerk Carol Schultz Recording Secretary OFFICIAL PRECEEDINGS OF THE CITY COUNCIL ADJ.REG.SESSION SHAKOPEE, MINNESOTA SEPTEMBER 24 , 1991 Mayor Laurent called the meeting to order at 8 : 51 a.m. Council- members Gloria Vierling, Steve Clay, and Robert Sweeney were present. Councilmembers Joe Zak and Jerry Wampach were absent. Also present were Dennis R. Kraft, City Administrator; Karen Marty, City Attorney; and Lindberg Ekola, City Planner. The meeting was convened in a courtroom at the Scott County courthouse. The mayor recessed the meeting for an executive session to discuss pending litigation regarding the Council ' s revocation of the NBZ conditional use permit. The mayor re-convened the city council and stated that no action had been taken during the executive session. The meeting was adjourned at 9 : 00 a.m. (/ Karen:'Ma `qty ' Deputy City/Clerk RecordingLSecretary 96Q) MEMO TO: Dennis R. Kraft, City Administrator FROM: Dave Hutton, Public Works Director SUBJECT: Vacation of Cartways DATE: October 11, 1991 INTRODUCTION: A public hearing has been scheduled for October 15, 1991 to consider vacating three unnamed cartways/driveways. BACKGROUND: In 1972 , the City of Shakopee and Eagle Creek Township consolidated. At that time, all of the township roads and maintenance responsibilities were inherited by the City of Shakopee. According to staff' s review of the file on this case, at the Minnesota municipal hearings Shakopee informed the township residents that the same level of services would be provided after the consolidation as before. The Order of Consolidation on file at the courthouse does not address road maintenance as it pertains to these specific cartways. There are 3 previously owned township roads that have long been called cartways, which the City assumed and provides maintenance on them. The maintenance provided consists of snow plowing, sanding, grading, weed control , etc. The level of maintenance varies for each of the 3 cartways. The 3 cartways are unnamed but are commonly referred to as the Mielke, Breeggemann and Petsch cartways. These cartways are basically driveways and in staff ' s opinion there is some question as to whether or not they serve a public purpose, but rather are benefiting private properties. Based on the financial position of the City and reductions in state aids, all departments have been asked to look for areas to reduce expenditures . These cartways are just one of many areas being reviewed. The Public Works Department was one of the City departments that was being considered for layoffs in 1992 based on the Financial Analyst ' s Report, yet more and more streets and parks are being constructed and developed each year. It is being increasingly more difficult to provide the same levels of service with no staff increases. Staff believes that the commitment to township residents in 1972 by the City to provide the same levels of service was made in good faith and with good intentions, but obviously the City of Shakopee is not in the same financial position today as it was in 1972 . Staff would like the City Council to reconsider the maintenance responsibilities of these cartways. In that regard, a public hearing has been scheduled for October 15, 1991. The City Council reviewed these cartways in 1983 but based on the opposition to the vacation by the effected property owners, elected not to change their status. There are some complex legal issues and property rights issues involved. Because of those, staff would like to offer some basic definitions and terminology that will be used during the discussion. "Easements" are rights given by a property owner for the use of a strip of land by the public or any other person for any specific purpose (City Code definition) . Easements can be private (between property owners) or public (open to anybody) . "Dedicated right-of-ways" are roads dedicated to the general public use, rather than specific persons. Legally, there is no difference between a public easement and a public right-of-way. A private easement is different in that it is only for specific persons. "Roads or streets" mean those public easements or right-of-ways that are constructed to minimum City standards. For rural roads, the minimum standards are as follows: Right-of-way - 60 feet Pavement width - 28 feet Gravel shoulders width - 5 feet Maximum cul-de-sac length - 1000 feet "Land locked parcels" are those parcels that do not have access directly to a public road, either by a private easement or a public easement. If they have access by a private easement, they are not landlocked. "Driveways" are typically narrow roads serving only one or two parcels. They do not have to meet any street standards for width or type of driving surface. The City Code does not allow more than 2 homes to share a driveway. Dead end streets are not allowed in the City Code. They must end in a cul-de-sac. Because the legal issues and levels of maintenance are different for each driveway, staff is proposing to discuss each one separately with specific alternatives for each. CartWay Locations , A \ i ,„-_-_, ) i.::"..--\ ...:,(1,..iw A...; 1.4 SJR - I. r� ••a: t � 11 /‘. ,„:-,-./ ` �• J � 1 f•ice- • L_. r ......., . • 1 i / ir----,__,.,., ! IONS- NI1h... .,' ••_ —....... t- L....-..:...„ t -. .. . , .. w r. « r� ti _ f I —— ._ k f_t- • - ft.. '-'i , ____ 9 I i . u ....... [ .,... ..„,_ _a __ F I /c � ( aI • ' .aaa.rt. --- IO ~^ -dab ad Zak. I -— O HTH ict:r ....- 1 ...... , ' a n s n . t'� „ �., r-7.i ill I ra MK 3 ' PETSCN z iiiiiih . 22 TINIC•1 -4"111. tin .IIMMMIMPOIMIIIIMISI e.•na : ys I too .e Igam•IIR•••• •a.. c... Q tl Q �' +‘, MIE KQ E 27 • -� 3 r� t ) 1. c s—- I �I I ,. I a c. le . � r . . \ 1. ...,Clefk,zs .. J ‘,t,, 1. / L�-�{. I\ r' rN' • JJ I amu" V-' " I JJI i t MIELKE DRIVEWAY BACKGROUND INFORMATION: Physical Condition of Driveway: This driveway extends south of County Road 42 for approximately 1/2 mile. (See following map) . It is a dead end driveway with no cul-de-sac. The driveway is gravel and is approximately the width of an alley (16 feet wide) . There is an existing electric line along this roadway and, if vacated, an easement would need to be retained for that utility. Public Use: This driveway appears to have been constructed to serve two landlocked parcels, namely the Stemmer and Mielke parcels. There is a house on each of those parcels that share the driveway. The driveway also abuts 3 other parcels, namely two Theis parcels and the Goldberg parcel. The properties abutting the driveway are essentially agriculture in nature. There is another parcel located in Prior Lake that is landlocked just east of the southerly Theis parcel, but has access to this driveway by virtue of a private easement with Theis. This parcel is legally landlocked now and vacating this road will not change that existing condition. The Mdewakanton Sioux Community recently purchased the Mielke property and will be using the driveway for certain community events (i. e. pow wows, etc)-. Since the Community owns adjacent contiguous parcels which abut County Road 82 , this property (old Mielke) is no longer landlocked, but rather directly abuts County Road 82 . (See attached map on their preliminary development proposal) . Extent of City Maintenance: The City maintains the entire 0. 5 miles of driveway by plowing the road after each snowfall, sanding if necessary, grading (3 - 4 times annually) , adding several loads of gravel as needed and weed mowing (as needed) . Cost Savings Resulting from Vacation: Maintenance costs are largely dependent on the severity of winter. Based on existing salaries, equipment, and material costs it is estimated that the City maintenance costs range from $2 , 500 during a light winter to $3 , 500 during heavy winters. Due to the narrow driveway it is sometime difficult to plow without damaging the adjacent fields and ditches. Status of Easements: The status of any easement for this driveway are somewhat confusing and difficult to ascertain. It appears that originally, there was a private easement (50 ' wide) allowing the Mielke parcel to utilize adjacent Theis parcels to access County Road 42 . It does not appear that a public easement was ever obtained or recorded. By virtue of maintaining the driveway, the City has assumed the public interest but only that portion of the driveway being maintained (16 ft. wide) . In 1983 , when the City held the last vacation hearing, the City Council informed the affected property owners that all maintenance would cease unless a 50 ft. easement were dedicated to the City and recorded. (See attached letters) The subject easement was drafted but never signed or recorded. The City, though, continued all maintenance. Based on the property research, it is the City Attorney' s opinion that there is a public easement (due to maintenance) which is a minimum of 16 feet wide and maybe 50 feet wide. The historical records are somewhat ambiguous making a positive opinion impossible. Landlocked Parcels: The Mielke property is no longer landlocked due to a change in ownership. The Theis and Goldberg parcels abut County Road 42 and are not landlocked. The Stemmer parcel may or may not be landlocked now, but certainly would be if the public easement were vacated. Unless a private easement is obtained first, staff does not believe that this driveway should be vacated. Prescriptive easement rights may exist based on the years the driveway has been used by Stemmer, but this law does not apply to public easements, only private. Other considerations: The Sioux Community has submitted a preliminary concept plan to develop their parcel by constructing roads to their property from County Road 42 and County Road 83 (See attached map) . Their proposal would be to construct those roads within their boundaries with their own funds, but petition the City to construct the connector roads outside of their property. The Community' s proposal was just submitted to staff recently and is still under review by the Community. No timetable for the requested improvement is given. Due to the fact that this road is substandard and does not conform to City requirements and only wide enough for one vehicle, staff does not feel that this road could be used for major traffic generating events such as a pow wow without first upgrading the road to minimum City standards. It is also quite difficult to maintain in its present condition. The City' s existing policy for new road construction is to assess them 100% to the abutting benefitted properties. Comprehensive Plan: This area is zoned R-1 and is essentially agriculture in nature. It will probably remain rural for some time. The City' s Comprehensive Plan does not identify a future street in this location, although the aforementioned preliminary development plan should be considered. ALTERNATIVES: 1. Vacate the road. 2 . Cease all maintenance (abandon) . 3 . Do nothing - Keep maintenance as is. 4 . Upgrade this road to minimum City standards (28 feet of pavement with 5 ft. shoulders) . RECOMMENDATION: Based on the legal research done by staff and the preliminary development proposal submitted, staff recommends No. 3 , not vacating the road. Staff also recommends Alternative No. 4 , but the timing of this construction should be in conjunction with the proposed Sioux Community development. Additional right-of-way would be necessary to construct a City street. Consideration should be given to placing this improvement on the City' s 5 Year Capital Improvement Program. L________________i \ L N CO RD 42 . I ,"?' r' WEiNANDT ACRE. c App'N Theis , Goldberg L 1 11 \. r _ ,-- /'"//': i Stemmer 1 \ t I0 Theis N ` 1Jeurissen Mdewakantc DEI �l , M(ELKE ADOfTIO?d Sioux p�. (Mdewakanton Community N ' °N �c Sioux Community) • H 14 i . ''. \ 1L i—: V t -� 1 cgGC ,y„ J. (._ cit.:. vP = 7,..._______,_, „ n• ,,0,1 3 u 4, 1 EAGLEWOCO 1 ;�,G 32N _ I11 I L.- ) f' z / (>. t BREEGGEMANN DRIVEWAY BACKGROUND INFORMATION: Physical Condition of Driveway: This driveway extends east of County Road 17 for a distance of approximately 1. 0 miles. (See following map) . The driveway is essentially a non-existent, substandard road. There is no gravel base, nor is it suitable for any vehicular traffic or safety vehicles. The driveway is approximately 8 - 10 feet wide and is essential two wheel paths wore in the ground. It is only wide enough for one vehicle to occupy it at a time. Public Use: This driveway is basically used by farm equipment (tractors, combines, etc. ) to access adjoining fields. There are no homes on this driveway. Extent of City Maintenance: Prior to 1983 , the City maintained this driveway on an "as needed" basis, consisting of snow plowing and occasional grading. Since 1983 (as a result of the last vacation hearing) , the City Council ordered all maintenance on this road to cease. There has been no City maintenance since 1983 . (Note: If there is no maintenance done what is the public benefit and purpose of this road?) Cost Savings Resulting from Vacating: None, as there is no maintenance being performed. If future maintenance is requested, though, the City may need to resume maintenance again. Status of Public/Private Easements: Based on research at the County Recorders Office, it appears that the first segment, abutted by Hauer and Bernhagen, contains a 16 foot easement (8 feet on each side of the property line) . It is not clear as to whether this is a private easement or public easement. By virtue of maintaining this easement from 1972 to 1983 , the City Attorney feels that it is a public easement. The next segment, abutted by Hauer and Bernhagen, has a 33 foot public road easement on the north side of the section line. The next segment, abutted by Hauer and Breeggemann has a 66 foot public road easement. West of Breeggemann there is a 33 foot public road easement abutted solely by Hauer property. Landlocked parcels: Based on the review of property descriptions, it appears that only the Breeggemann parcel could be considered landlocked if the public road were vacated. This parcel may have prescriptive easement rights to the 16 foot easement but would not have any on the remaining 33 ft. public easement if vacated. Comprehensive Plan: The Comprehensive Plan does not identify a future street in this area. If this area were to develop, any future street needs would be obtained through the platting process. ALTERNATIVES: 1. Vacate the road. 2 . Close the road (Abandon) . 3 . Obtain the necessary right-of-way and construct a City street to minimum standards. 4 . Do nothing. RECOMMENDATION: Staff seriously questions the public purpose of this road but does not recommend vacating the roadway because it may or may not landlock the Breeggemann parcel. If the first 16 foot easement is private, Breeggemann would have prescriptive rights to continue using the driveway without it being a public road. It cannot be determined if this easement is public or private though. Since the condition of the road makes it unsuitable for vehicular traffic, staff recommends simply installing a "road closed" sign at the entrance of the road (essentially abandoning it) until such time as the road is constructed to minimum City standards. By officially closing the road, the City is informing the public that there will be no maintenance on this road, thereby reducing any liability associated with a non-standard City road. Staff does not feel that a City street should be built on this road at this time, but rather when development warrants it. Due to the present condition of this road, abutting land parcels will not be permitted to develop until the proper infrastructure is in place. / s", 1Y1 1 Y , _ 1 _ _ — S I / 1 1 1 / . . 1 11 I O��pl �0 1 ��syr i L? • n , 1 s 1 l 1 XQ '' \s ‘ 1 '\ - p 1 •141;". --\i. , ro ca moo . 1 l / G4111\11., 1 / c _ _-- .- ' i 1 (---)0 ; cq �,. 1 1 W 1 cu 1 / 7 u 1 =iu I a -� 1 CO I as ad.\r G I,• t: I cI= 5:-.!lc i A 1CC c I —•i t,.r �:}`c. •F1 I \ U I OA S: 1 , Z 'v c• . 1 1 T x / aco s I - _ =1-r I 1 t 1,1 cr) Gk.' / Ow ! . S J G r _ _1N -L- - I _ _ I. 52:1 ` W --,..—6 \......j_ •i_\ De't ,LiNi":3 \ \ 1 , N- •,-,J ` 1 1 W 1\ cr) )---ul L 1 , 2 \ 1 li________1 i 1 1 en PETSCH DRIVEWAY BACKGROUND INFORMATION: Physical Condition of Driveway: This driveway extends east of McKenna Road for approximately 0. 6 miles. (See following map) . This driveway is located just north of the City corporate limits and just north of the proposed McKenna gravel mine. The first part of the driveway (0 .2 miles) has a substandard, gravel base and is only 8 - 10 feet wide. The remainder of the driveway from the first curve to the farmhouse has no gravel and is basically wheel ruts with vegetation in the middle. This is essentially a dead end road with no cul-de- sac. Public Use: This driveway currently serves the Petsch land. there is a vacant unoccupied house at the end of the driveway. The abutting properties are essentially farm fields. Extend of City Maintenance: The City maintains the first 0 . 2 miles of the driveway (to the first curve) . Maintenance consists of plowing the road after each snowfall and grading it once or twice per year (more if requested) . Every other year or so, additional gravel is placed if needed. Weeds are mowed as needed. Cost/Savings Resulting from Vacation: Maintenance costs are largely dependent on the severity of winter. Based on existing salaries and equipment costs, it is estimated that the maintenance costs on this road ranges from $1, 500 during an easy winter to $2 , 500 during a heavy winter. Depending on the type of equipment used, due to the narrow driveway, the plows must sometimes back out of the driveway. Status of Easements: In researching this driveway, it appears that Petsch obtained a private easement from McKenna/Shutrop to have access to his landlocked parcel. Shortly after that (in 1960) the township designated the first section of the driveway as a township road and assumed maintenance. From the first curve to the home is a private driveway. If the City were to vacate this road, the easement will revert back to Petsch, since that is where it was taken over from by the governing body. Hence, Petsch would still have access rights to McKenna Road, only the maintenance of the driveway would not be the City' s. Landlocked parcels: None, based on the above discussion. Comprehensive Plan: This area is currently in the R-1, Rural Residential zone and is basically in an agricultural area. This area will probably remain rural in nature for many years. The Comprehensive Plan does not identify the need for a future City street in this are. As the area develops, City streets can be secured through the platting process. ALTERNATIVES: 1. Vacate the road. 2 . Stop maintenance and close the road. 3 . Do nothing. RECOMMENDATIONS: Staff recommends vacating this road. Staff feels that this is basically a driveway and questions the public purpose and expending the maintenance dollars. By vacating it, the easement rights revert back to Petsch, thereby avoiding landlocking the property. 1 1 \ \ 1 __'' ..., Z., .._ N , t ) . : 4i n FC17C H T S. • , .1 eihtA.'v . . -s _ . . ,c-,,,. ..... ,-/ .... -"c- ..,........ 15 \ -............. Cs 16 \ --...,.... 1\ i Shutrop Huber `� U McKenna Petsch -- - • PETSCH FRMHOUSE 22 . ►1 I 1 1 . tinii _i \ . PLANNING COMMISSION RECOMMENDATION: Per Minnesota Statute 462 . 356, the Planning Commission must first review any proposed vacations to make sure it is not in conflict with the City' s Comprehensive Plan. In Staff' s report to the Planning Commission, it was pointed out that none of the 3 cartways are shown as future streets in the City' s Comprehensive Plan. There is inadequate right-of-way to construct a street to minimum City standards. Planning staff feels that any future streets needed in this area could be obtained as development occurs (i.e. platting) . The current maintenance by the City may benefit the adjacent property owners, but currently provides minimal public service. The Planning Commission spent a considerable amount of time discussing these cartways and obtaining testimony from the public. At the conclusion of the discussion, the Planning Commission voted to oppose any vacations that would create landlocked parcels. FINAL SUMMARY AND RECOMMENDATIONS: Staff seriously questions the public purpose of those roads and questions the expenditure of public funds to maintain them. But based on the additional deed research done, it appears that vacating all 3 of them is not the best alternative legally. By all outward appearances, those roads are driveways. There are no other such situations in Shakopee where the City is maintaining such woefully, substandard roads. Unfortunately, the issues are somewhat more complex, as previously discussed. Staff recommends the following: 1. Do not vacate the Mielke driveway, but instead add it to the City' s 5 Year C. I.P. for potential future upgrade. 2 . Abandon the Breeggemann driveway by installing a "Road Closed" sign at the entrance. 3 . Vacate the Petsch driveway. It should be noted that it would take a 4/5 vote for Council to pass this action. ACTION REQUESTED: 1. Move to deny the request to vacate the Mielke driveway and direct staff to add this road to the City' s 5 Year C. I . P. for future upgrade. (Some thought should be given to officially naming this street also. ) 2 . Direct staff to abandon the Breeggemann driveway by installing a "Road Closed" sign at its entrance. 3 . Vacate the Petsch driveway by offering the attached Resolution No. 3481 and move its adoption. RESOLUTION NO. 3481 A RESOLUTION VACATING THAT PART OF A CARTWAY, COMMONLY REFERRED TO AS THE PETSCH'S DRIVEWAY, LOCATED EAST OF MCKENNA ROAD, ALONG A LINE BETWEEN SECTIONS 15 AND 22 , RANGE 22, TOWNSHIP 115, SCOTT COUNTY, MINNESOTA WHEREAS , it has been made to appear to the Shakopee City Council that the . 2 miles of cartway, commonly referred to as the Petsch' s Driveway, located east of McKenna Road and described as follows: The south 1 Rod of the SW 1/4 of the SE 1/4 of Section 15, Township 115 Range 22 and the north 18 1/2 feet of the NW 1/4 of the NE 1/4 of Section 29 , Township 115 Range 22 . no longer serves any public interest or use save and except for the installation and maintenance of public utilities; and WHEREAS, a public hearing to consider said vacation was held in the Council Chambers of the City Hall in the City of Shakopee at 7 : 30 P.M. on the 15th of October, 1991; and WHEREAS, two weeks published notice has been given in the SHAKOPEE VALLEY NEWS and posted notice has been given by posting such notice on the bulletin board on the main floor of the Scott County Courthouse, the bulletin board at the U.S . Post Office, the bulletin board at the Shakopee Public Library, and on the bulletin board in the Shakopee City Hall ; and WHEREAS , all persons desiring to be heard on the matter were heard at the public hearing in the Council Chambers in the City of Shakopee; and NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SHAKOPEE, MINNESOTA: 1. ) That it finds and determines that the vacation hereinafter described is in the public interest and serves no further public need as a street; 2 . ) That all that part of the Petsch' s Driveway lying east of McKenna Road, along a line between Sections 15 and 22 , Range 22 , Township 115, Scott County, Minnesota, be, and. the same hereby is vacated; 3 . ) That the City reserves, however, to the City of Shakopee, its licensees and franchise holders a perpetual easement on, under, and over the said vacated street for utilities with the right to install, maintain, repair, lay and relay the utilities by the City, its licensees and franchise holders; and 4 . ) After the adoption of the Resolution, the City Clerk shall file certified copies hereof with the County Auditor and County Recorder of Scott County. Adopted in regular session of the City Council of the City of Shakopee, Minnesota, held this 15th day of October, 1991. Mayor of the City of Shakopee ATTEST: City Clerk APPROVED AS TO FORM: City Attorney 1983 ACTION CITY OF SHAKOPEE INCORPORATED 1870 129 E. First Ave. - Shakopee, Minnesota 55379.1376 (612) 445.3650 November 10 , 1983 .?•, ; Mr. Peter Breeggemann 615 Sommerville Shakopee , MN 55379 Mr. Eugene Hauer 2088 Hauer Trail Shakopee, MN 55379 Dear Sirs : On September 20, 1983 the City Council of the City of Shakopee Minnesota discussed maintenance of the cartways serving your pro- perty and other cartways in rural Shakopee . As a result of that discussion, City Council agreed to con- tinue the maintenance of all cartways now maintained by the City, provided they met specific conditions established by the City Council . The conditions are as follows : 1 . Maintenance will continue as long as the property is owned by the immediate property owner and heirs , but no assigns . 2 . Maintenance will be performed only on public right-of- way . The public right-of-way must be 50.00 feet wide . The cartways serving your parcel is a private easement and has not been dedicated to the public. The City must cease all maintenance of that roadway until a public dedication of right-of- way, including a turn around, is made. The minimum width of right-of-way required by City ordinance is 50 feet . In order to continue maintenance of the cartway serving your property, a 50 foot public road easement must be dedicated along the present road alignment . Should you have any questions regarding the requirements specified and approved by City Council , or if you have any questions about the easement dedication, contact me at 445-3650. The City Engineer will contact you to discuss how you want the additional right-of-way dedicated . Sincerely , z,V` , it 157l"N-.----_ John K. A'nderson - City Administrator JKA/jms cc : Charles 7Bdirnhdge•n.t r t o 1 Bd' Spuairi.e r CilE.y: E//guneer IDS Karkanen, Public Works Director Scott l a nd An Equal Opportunity Employer 1983 ACTION eggra CITY OF SHAKOPEE , INCORPORATED 1870 ' 401 :4 129 E. First Ave. • Shakopee, Minnesota 55379-1376 (612) 445-3650 KOt November 10 , 1983 ` ' 1 Mr. Clarence R. Petsch RFD 2 Jordan, MN 55352 Dear Mr. Petsch: On September 20 , 1983 the City Council of the City of Shakopee Minnesota discussed maintenance of the cartways serving your pro- perty and other cartways in rural Shakopee. As a result of that discussion, City Council agreed to con- tinue the maintenance of all cartways now maintained by the City, provided they met specific conditions established by the City Council . The conditions are as follows : 1 . Maintenance will continue as long as the property is owned by the immediate property owner and heirs , but no assigns . 2 . Maintenance will be performed only on public right-of- way. The public right-of-way must be 50.00 feet wide. The cartways serving your parcel is 35 .00 feet wide. The City must cease all maintenance of- that roadway until a public dedication of right-of-way, including turn around, is made. The minimum width of right-of-way required by City ordinance is 50 feet . In order to continue maintenance of the cartway serving your property, an additional 15 .00 feet of public road easement must be dedicated along the present road alignment . Should you have any questions regarding the requirements specified and approved by City Council , or if you have any questions about the easement dedication, contact me at 445-3650. The City Engineer will contact you to discuss how you want the additional right-of-way dedicated. Sincerely , John K. Anderson City Administrator JKA/jms cc : Bo Spurrier , City Engineer 6.„J4fn Karkanen , Public Works Director Harold Araenndi ; .t r 1 / P r It r c : _ l 'Ale !, George Shutrop An Equal Opportunity Employer 1983 ACTION CITY OF SHAKOPEE rid° INCORPORATED 1870 129 E. First Ave. • Shakopee, Minnesota 55379-1376 (612) 445-3650 i% KU\� November 4, 1983 - ''(z rr Mr. Eugene Mielke 2706 County Road 42 Shakopee , MN 55379 Mr. Peter Stemmer 2704 County Road 42 Shakopee , MN 55379 Dear Sirs : On September 20, 1983 the City Council of the City of Shakopee , Minnesota discussed maintenance of the cartways serving your pro- perty and other cartways in rural Shakopee . As a result of that discussion, City Council agrees to continue the maintenance of all cartways now maintained by the City, provided they met specific conditions established by the City Council . (This cartway designation does not include that private portion of your drive from the wye to your house . ) The conditions are as follows : 1 . Maintenance will continue as long as the property is owned by the immediate property owner and heirs , but no assigns . 2 . Maintenance will be performed only on public right-of way. The cartways serving your parcel is a private easement and has not been dedicated to the public. The City must now cease all maintenance of that roadway until a public dedication of right-of-way is made. The minimum width of right-of-way required by City ordinance is 50 feet . In order to continue maintenance of the cartway serving your property, a 50 foot public road ease- ment must be dedicated along the present road alignment . In the past , the City has maintained your driveway up to your farm yard because there was no turn around. Now that there is a turn around at the wye , the City will limit plowing and maintenance to that 1 ,320 feet of wye drive between the wye and County Road 42 . T 1t II earll o / Pro a r c s _ V a / / ' tl An Equal Opportunity Employer Mr. Eugene Mielke/Mr. Peter Stemmer Page Two November 4 , 1983 Should you have any questions regarding the requirements specified and approved by City Council , or if you have any questions about the easement dedication, contact me at 445-3650 . The City Engineer will contact you to discuss how you want the additional right-of-way dedicated. Sincerely, 7"‹ f / John K. Anderson City Administrator JKA/jms cc : Bo Spurrier, City Engineer Karkanen, Public Works Director Norbert Theis Martin Theis Sioux Community Proposal 1/2 29 T. // P 22 - - N 1/2 5 2c i. //.: P 22 • - • i AREA-5L.... iril(� ,1. 40Ac RESIDENTIAL ; ii___ eft�/ � AREA-2 .i` ti 11irli it2OAc " SIDENTIAL/ __,- I: ).. . (1.-\*'4"K• i I _ ;11./\_„7 ... .—., .--.. . . .. . /i• • •• 41Ao aoAc\7 . I COMMER.CIAL 7.--- I . IL::'. " :'\-\:::\.,,,-'''..-*'''''4., l ------ • CULTURAL` CENTER/MUCENTER/MUSEUM, & COMMERCIAL (FUTURE) -- N-RECREATION POW-WOW/ - _- i CULTURAL FESTIVALS - DRAWING NO.1 / - RESOLUTION NO. 3481 A RESOLUTION VACATING THAT PART OF A CARTWAY, COMMONLY REFERRED TO AS THE PETSCH' S DRIVEWAY, LOCATED EAST OF MCKENNA ROAD, ALONG A LINE BETWEEN SECTIONS 15 AND 22, RANGE 22, TOWNSHIP 115, SCOTT COUNTY, MINNESOTA WHEREAS , the City Council of Shakopee has determined to vacate the . 2 miles of cartway east of McKenna Road, commonly referred to as the Petsch' s Driveway; WHEREAS, a public hearing was held on October 15, 1991 before the City Council in the City Hall after due published and posted notice had been given by the Clerk on September 20, 1991, a reasonable attempt was made to give notice to all affected property owners, and all persons interested were given an opportunity to be heard; WHEREAS , it appears that it will be in the best interest of the City to vacate such street and that the cartway no longer serves any public interest or use, save and except for the installation and maintenance of public utilities; WHEREAS , any person, corporation or City owning or controlling easements contained upon the property vacated, reserves the right to continue maintaining the same or to enter upon such way or portion thereof vacated to maintain, repair, replace, remove or otherwise attend thereto; WHEREAS , four-fifths of all members of the City Council concur in this resolution; NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Shakopee, Minnesota: 1. That it finds and determines that the vacation hereinafter described is in the public interest and serves no further public need as a street; 2 . That the cartway described as follows is hereby vacated: The south 1 Rod of the SW 1/4 of the SE 1/4 of Section 15 , Township 115, Range 22 and the north 18 1/2 feet of the NW 1/4 of the NE 1/4 of Section 29 , Township 115, Range 22 . 3 . That the City reserves, however, to the City of Shakopee, its licensees and franchise holders a perpetual easement on, under, and over the said vacated street for utilities with the right to install, maintain, repair, lay and relay the utilities by the City, its licensees and franchise holders; Adopted by the Council this 15th day of October, 1991. Approved: Mayor Attest: Clerk ONSENT MEMO TO: Dennis Kraft, City Administrator FROM: Terrie Sandbeck, Assistant City Planner RE: Ordinance Amendment to correct grammatical errors in the list of Permitted Uses within the Highway Business (B-1) District DATE: October 15, 1991 INTRODUCTION: The Shakopee Zoning Ordinance currently lists motor homes as a Permitted Use within the Highway Business (B-1) Zoning District. This is the result of an error in copying and updating the Zoning Ordinance that was adopted by the City on April 1, 1978 . BACKGROUND: Attached is a copy of the Permitted Uses within the B-1 Zoning District from the Shakopee Zoning Ordinance that was in effect between April 1, 1966, and April 1, 1978 . (See Appendix A. ) At that time, the B-1 District was titled the "Thoroughfare Business District" . Section 11. 1 (1) of this Ordinance listed "Motels, motor hotels, and hotels" as permitted uses within this zone. However, that same portion of the Ordinance that was adopted on April 1, 1978, lists "Motels, motor homes, and hotels" as permitted uses. (See Appendix B. ) PLANNING COMMISSION RECOMMENDATION: To avoid confusion and clarify the intent of the Ordinance, the Planning Commission recommends that the Ordinance be amended to correct grammatical errors, and that the Permitted Uses within the Highway Business District be amended to change "motor homes" back to "motor hotels" . ALTERNATIVES: 1. Adopt the proposed Ordinance Amendment correcting grammatical errors in the list of Permitted Uses within the Highway Business District (B-1) . 2 . Deny the proposed Ordinance Amendment correcting grammatical errors in the list of Permitted Uses within the Highway Business District (B-1) . ACTION REQUESTED: Offer Ordinance Amendment No. 320, amending City Code Chapter 11, Land Use Regulation (Zoning) , by Repealing Section 11. 29, Highway Business (B-1) , Subd. 2 , Permitted Uses, and Enacting One New Subdivision in Lieu Thereof Relating to the Same Subject, and move for its adoption. Ech.I b 4- H SECTION 11 i "B-1")THOROUGHFARE BUSINESS DISTRICT PAGE 7 Section 11.1 Permitted Uses CH. 10.1 Within the "B-1" Thoroughfare Business Use District, no struc- ture or land shall be used except for one (1) or more of the following uses; in areas sery•• • . • •1' sewerage system. it11.1 (1) Motels, motor hot:Bland hotels provided the site shall contain not less tha• our •un•red (400) square feet of lot area per unit. 11.1 (2) Drive-in businesses as regulated in Section 19.2. 11.1 (3) Seasonal produce stands. 11.1 (4) Motor fuel stations subject to the regulations of Section 19.1. 11.1 (5) Nursery and garden supply stores. 11.1 (6) Commercial recreation including bowling alleys, jump centers, golf driving ranges, miniature golf, skating, and swimming pools. „pert II J 11.1 ('7) Restaurants, cafes, taverns and liquor stores. D 11.1 (8) Car wash,provided off-street parking space is constructed DIST. to accommodate that number of vehicles which can be washed during t� a maximum fifteen (15) minute period. �-- 1 . , Section 11.2 Conditional Uses as prescribed by Council Resolution. V�- I Section 11.3 Accessory Uses f Within the "R-1" Thoroughfare Business District, the following uses shall be permitted accessory uses: 11.3 (1) Any incidental repair or processing necessary to con- duct a permitted principal use. 11.3 (2) Private garages, off-street parking and loading spaces as regulated in this Ordinance. • 11.3 (3) Signs appurtenant to_any permitted use, as regulated in Usk e. 'S i IN) C1 . c�.-..c_P 11.3 (4) Buildings temporarily located for purposes of construc- tion on the premises for a period not to exceed time necessary to complete said construction. 11.3 (5) Decorative landscape features. 113 (6) Public telephone booths provided all yard requirements are met. 11.3 (7) Dwellings when combined with a permitted principal use and not occupying the first floor. 11.3 (8) Other accessory uses and structures customarily appurt- enant to a permitted use, such as incidental storage facilities. Section 11.4 Lot Area, Lot Width, Height and Yard Requirements Within the "B-1" Thoroughfare Business District, the following minimum lot area, lot width and yard requirements and maximum height limitations shall apply subject to the additional requirements, exceptjons and modifications as set forth in this Section, Section 18, and Section 19. .. - -. • Height-2 stories or 25' - - • . . . - Lot Area-9,000 sq. ft. :- _ - Lot Width-60 ft. vt, .. • Front Yard-30 ftp;,/ Side Yards-10' o 20'.when ffbutting the "R"Residential District. Rear Yard-10' in uding i of alley width, or 20' when abutting the "R" Residential Dist -- - _____________ ' SECTION 12 "B-2" NEIGHBORHOOD BUSINESS DISTRICT_ Section 12.1 Purpose To provide a center for convenience shopping in a residents "B_2" neighborhood. New "B-2" Districts shall have a minimum area of two(2)acres in Locations where analysis of residential population dem DIST. onstrates that such facilities are required. Section 12.2 Application The owner or owners of any tract of land in the "B-2" Neighbor- hood Business District may submit to the Council a plan for the use ,_, U/p`I: and development of all or part of such tract subject to the require- ments set forth in this Section. The proposed plan shall be referred to the Planning Commission for study and report. The Planning - Commission shall transmit to the Council their findings and recom- mendations for consideration and action. • Section 12.3 Permitted Uses Within the "B-2" Neighborhood Business District. so structure or land shall be used except for one or more of the following neigh- borhood retail sales and service business uses supplying commodities or performing a service primarily for residents of the surrounding neighborhood, and in an area served by a public sewerage system. t, li -.r.•,-- =';;- le ... L ••-• -, - . . . . . f) 1- Sou : Shakopee Zo n;n Orel i!X111 GE- ' 41/1/Gt. +0 4/// /7g • Cxhi bi 4 13 1 SEC . 11 . 28. 13-1 - THOROUGHFARE BUSINESS DISTRICT. IPermitted Uses Conditional Uses 1. Motels ,(Motor Homes) Hotels 1. Mobile Home Parks . 's r- 2 . Public or Quasi-Public (Lot must have 400 sq. ft. per unit) Uses for needs of Tra- 2 . Drive-in Businesses . veling Public. 3 . Seasonal Produce Stands . 3 . Animal Hospitals and 4. Nursery and Garden Supply Stores . Veterinary Clinics . 5 . Commercial Recreation 4. Private Clubs and Lodges . 6 . Restaurants , Cafes , Taverns , 5 . Open Sale Lots . Liquor Stores . 6 . Historical Buildings , 7 . Car Wash. Museums . 8 . Auto Sales , Services and 7 . Art Institutes . Repairs . 8. Funeral Homes . 9 . Wholesale Businesses . 9. Play Houses . 10. Home and Trailer Sales . 10 . Multiple Dwellings . 11. Parking Lots . 11. Supply Yards . 12 . Public Buildings . 13 . Public Utility Buildings . 14 . Offices and Banks . 15 . Retail Businesses . 16 . Motor Fuel Stations . _ i Accessory Uses 11 Permitted Conditional ; i ii 1. Any incidental repair or pro- 1. Dwellings when combined cessing necessary to conduct a with a permitted use , 11 permitted principal use . - not on first floor. 3i 2. Private Garages , Off-Street Parking, Loading Spaces . ; 3 . Temporary construction buildings . i 4. Decorative landscape features . ! • 5 . Public telephone booths . 6 . Other accessory uses customarily ; appurtenant to a permitted use . Height and Yard Requirements 1. No building shall exceed 2 stories or 25 feet. : i : f ! i i is i j Ste: C� ofSe ,pt 1-andd use 12sul .WonS (zon;r ) 4-1-78 T/I/-ry it, 1%.5/-79 -292- ORDINANCE NO. 320, FOURTH SERIES AN ORDINANCE OF THE CITY OF SHAKOPEE, MINNESOTA, AMENDING CITY CODE CHAPTER 11, LAND USE REGULATION (ZONING) , BY REPEALING SEC. 11. 29 , HIGHWAY BUSINESS (B-1) , SUBD. 2 , PERMITTED USES, AND ENACTING ONE NEW SUBDIVISION IN LIEU THEREOF RELATING TO THE SAME SUBJECT. THE CITY COUNCIL OF THE CITY OF SHAKOPEE, MINNESOTA, ORDAINS: Section 1 - That City Code Chapter 11, Land Use Regulation (Zoning) , Sec. 11.29, Highway Business (B-1) , is hereby amended by repealing Subd. 2 , Permitted Uses, and enacting one new subdivision in lieu thereof, which shall read as follows: Subd. 2 . Permitted Uses. Within any Highway Business District, no structure or land shall be used except for one or more of the following uses: A. Motels, motor hotels [homes] , hotels (lot must have 400 square feet per unit) . B. Drive-in retail business. C. (Repealed by Ordinance No. 158 , 4th Series, adopted 1-22-85. ) D. Churches. E. Restaurants, Class I. F. Retail business. G. Liquor stores. H. Essential services. I. Offices and banks. J. Car washes. K. Service establishments. L. Auto sales, service[s] and repair[s] businesses. M. Wholesale businesses. N. Class II day care facilities when located in the home of the day care provider. Note: The bracketed language [thus] is deleted; the underlined language is inserted. Section 2 - General Provisions. City Code Chapter 1, General Provisions and Definitions Applicable to the Entire City Code Including Penalty For Violation, and Section 11. 99, Violation a Misdemeanor, are hereby adopted in their entirety by reference, as though repeated verbatim herein. Section 3 - Effective Date. This ordinance becomes effective from and after its passage and publication. Passed in session of the City Council of the City of Shakopee, Minnesota, held this day of , 1991. Mayor of the City of Shakopee Attest: City Clerk Approved as to form: City Attorney Published in the Shakopee Valley News on the day of , 1991. [11. 28] -2- MEMORANDUM /a 0, . TO: Mayor and Members of City Council FROM: Karen Marty, City Attorney DATE: October 11, 1991 RE: Reconsideration of Past Actions At the October 1, 1991, City Council meeting, the Council requested information on a series of related questions dealing with reconsideration of Jack Brambilla ' s requests for rezoning or adoption of an amendment to the zoning ordinance. These questions are discussed below. 1. Can a motion to reconsider be made at this time, relating to either the rezoning or ordinance amendment request? No. Under Robert' s Rules of Order (1990 ed. ) , a motion to reconsider "enables a majority in an assembly, within a limited time and without notice, to bring back for further consideration a motion which has already been voted on. " (Sec. 36) A motion to reconsider is done without notice, at the same meeting as the original action. Paragraph (b) specifically limits these motions to being made on the date of the meeting. The making of this motion is subject to time limits, as follows: In a session of one day - such as an ordinary meeting of a club or a one-day convention - the motion to reconsider can be made only on the same day the vote to be reconsidered was taken. In a convention or session of more than one day, a reconsideration can be moved only on the same or the next succeeding day after the original vote was taken (not counting a legal holiday, weekend, or other single day on which no business meeting is held) . These time limitations do not apply to standing or special committees. Robert ' s Rules therefore prohibits reconsideration of a motion voted on at a previous meeting. If the City Council holds a two- day meeting, then the motion could be made on the second day relating to action taken on the first day. This section does not authorize reconsideration of a motion acted on at a meeting two weeks previously, even if the later meeting is an "adjourned" continuation of the first meeting. 2 . Can the City Council suspend its rules to take up the issue again? Yes, if there is no conflict with state and local law. Under Robert' s Rules, a motion to suspend the rules is sometimes appropriate. When an assembly wishes to do something that it cannot do without violating one or more of its regular rules, it can adopt a motion to Suspend the Rules interfering with the proposed action - provided that the proposal is not in conflict with the organization' s bylaws (or constitution) , local, state, or national law, or the fundamental principles of parliamentary law. (Sec. 25) Suspension of the rules is allowed, except when the action proposed would violate local or state law. In Chanhassen Estates Residents v. City of Chanhassen, 342 N.W. 2d 335 (Minn. 1984) , the Minnesota Supreme Court reviewed a motion to reconsider which was made one month after the initial action. The Court questioned the motion, but noted that the city council had the authority to waive the rules of procedure by a 4/5 vote of the council . A. Does state law prohibit reconsideration of the amendment? Maybe. Under Minn. Stat. Sec. 462 . 357 , Subd. 3 , and City Code Sec. 11. 04 , notice and a public hearing is required prior to adopting an amendment to the zoning ordinance. For each of Mr. Brambilla ' s requested actions, the City provided proper notice and public hearings. The question thus arises whether the previous notice and public hearings can be relied upon in a new reconsideration of the same issues. A review of case law indicates that our courts have not decided this question. In the Chanhassen case, the opponents to the issue were given new notice prior to the reconsideration. It could be argued that the matters were voted down, and therefore any new consideration is a new issue needs new notice and hearing. On the other hand, it could be argued that this is the same issue revisited, and since concerned citizens very recently had the opportunity to be heard, new notices and public hearings are unnecessary. B. Does local law, other than that discussed in paragraph A above, prohibit reconsideration of the amendment? Yes, unless certain requirements are met. City Code Sec. 11. 04 , Subd. 7 .J prohibits reconsideration of any amendment for six months, unless the Planning Commission feels new evidence has been discovered. Any amendment which is denied wholly or in part by the Council shall not be resubmitted for a period of six (6) months from the date of said order of denial, except on grounds of new evidence or proof of change of conditions found to be valid by the Planning Commission. Prior to reconsideration of any particular rezoning or amendment of the zoning ordinance, either six months ' time must pass, or the Planning Commission must accept as valid a claim that new evidence has been found. The "new evidence" or "change of conditions" presented so far consists of a petition and letter; Planning Commission could be asked to determine whether it finds these to be valid. 2 3 . Can the City Council simply undo what it did previously? Yes. A motion to rescind or to amend something previously adopted is allowed under Robert' s Rules of Order. (Sec. 34) Unlike the motion to reconsider, these are not limited in time. " [T]here is no time limit on making these motions after the adoption of the measure to which they are applied, and they can be moved by any member, regardless of how he voted on the original question. " If the City Council desired, it could rescind or amend its previous denials. The City Council also can rescind and expunge from the minutes its previous action. Arguably, once the previous action is rescinded or amended, the original motion again is before the Council. This would avoid the six-month prohibition set forth in paragraph 2 .B above. However, the concerns set out in paragraph 2 .A above relating to notice and public hearing would remain. 4 . If the City Council does not take any of the above actions, can the request for an amendment be raised again before six months is over? Yes, if modified. City Code Sec. 11. 04 , Subd. 7 .J prohibits reconsideration within six months of any amendment which is denied wholly or in part. It does not prohibit consideration of any other amendments. If Mr. Brambilla were to come forward with a new request for a zoning map amendment, or a zoning ordinance amendment, the City Council could consider it without waiting the six months, and without the need for Planning Commission to review the validity of the new evidence or proof of change. If you have questions regarding this, please let me know. Signed , A074_ 11 /"41 L`, Karen Marty, Ci y •ttorney KEM:bj m [BRAMB] cc: Dennis Kraft Lindberg Ekola 3 MEMO TO: Honorable Mayor and Council FROM: Dennis R. Kraft, City Administrator RE: Reconsideration of Zoning Ordinance Amendment DATE: October 11 , 1991 INTRODUCTION\BACKGROUND: At the Council meeting of October 1st the City Council directed the City Attorney to research the question of whether the Council has the authority to suspend Robert' s Rules and reconsider an earlier vote on amending the zoning ordinance in such a manner as to allow the sale of motor homes as a conditionally permitted use in the I-2 zone. (This item was considered by the City Council and the Planning Commission in conjunction with a request made by Mr. Jack Brambilla to relocate his business from downtown Shakopee to a parcel of land in the I-2 district immediately south of Valleyfair. ) Mayor Laurent and I met with Jack and Doris Brambilla and their attorney, Rod Krass and discussed this item on October 11th. Mr. Krass indicated that he would like the City Council to reconsider the suspension of Robert' s Rules and to subsequently reconsider the amending of the I-2 district as described above. Mr. Krass and the Brambilla' s both recognize that a 75% affirmative vote (at least 5 of 6 Councilmembers) must vote in the affirmative in order to amend the zoning ordinance. A simple majority vote would be required for the City Council to suspend Robert' s Rules. Mr. Krass further indicated that the reason he will appear before the City Council at this time is to deal with this question with a degree of finality so that Mr. Brambilla can proceed with his plans to relocate his business. Attached is a memo from Police Sergeant Kaley to Chief Steininger relating to the impact of traffic flow on the public safety for the rezoning request as submitted by Jack and Doris Brambilla. This information was received by the staff along with information from many other departments and was considered prior to the drafting of the staff memo to the City Council on the early rezoning request (to rezone the subject property from I-2 to B-1) . This information is specifically being submitted to the City Council at this time as requested by Jack Brambilla. The question of traffic safety was not an issue during the rezoning consideration and came before the Council at a much later date (October 1, 1991) during which time the conditional use permit amendment question was before the City Council . ALTERNATIVES: 1. Suspend the rules and reconsider the amending of the I-2 district to allow the sale of recreational vehicles and motor homes in the I-2 zoning district. 2 . Do not suspend the rules and allow for the above mentioned reconsideration of amending the zoning ordinance. RECOMMENDATION: It is recommended that the City Council consider the information contained in the City Attorney' s memo and all other relevant information presented to them on this issue and decide whether they desire to reconsider this item after the suspension of Robert' s Rules. A staff recommendation is not included at this point because this is purely a policy question to be addressed by the City Council . In the past the Council has received staff recommendations, recommendations from the Planning Commission and testimony from many individuals both in favor of and opposed to the project. ACTION REQUESTED: Move to suspend Robert ' s Rules and reconsider the amendment of the zoning ordinance to allow the sale of motor homes as a conditionally permitted use in the I-2 district. SHAKOPEE POLICE DEPARTMENT IN HOUSE MEMO TO: Chief Steininger FROM: Sgt. Kaley DATE: July 20, 1991 SUBJECT: Rezoning requested by Jack and Doris Brambilla Police staff were asked to review concerns for rezoning property located at Hwy. 101 and Valley Park Drive. Jack and Doris Brambilla have requested property that is currently zoned I-2 to be rezoned as B-I. The concerns of the police department are limited to traffic flow and public safety. After observing this area and reviewing information I do not see any concern for traffic flow or public safety. The light traffic flow in this area would not experience a significant increase by rezoning to B-i as requested by Jack and Doris Brambilla. Valloy BUSINESS PARK October 8 , 1991 Mr. Lindberg Ekola CITY OF SHAKOPEE 129 East First Avenue Shakopee, MN 55379 Re : Brambilla Issue Dear Lindberg: I believe the enclosed letter from FMG/Tsumura dated October 2 , 1991 is self-explanatory. Please file accordingly. Respectfully, VAfEY GREEN BUSINESS PARK / 41/k- Jon/ R. Albinson Pr6ject Director JRA: jmcx-72 . 2 Enclosure 5276 Vaiiey Industrial Boulevard South • Shakopee, Minnesota 55379•Telephone: (612) 445-9286• Facimile: (612) 445-9372 FMG Ti TSUMURA Prestige Home Fragrances and Luxury Bath Products October 2, 1991 Mr. John Albinson Valley Green Business Park 5276 Valley Industrial Boulevard South Shakopee, MN 55379 Dear John: Mr. Bill Henning was at our Shakopee facility on Monday,9/30/91 asking us to sign a petition to relocate the Brambilla Motor Homes to the Industrial Park. I have informed him that I will not sign this petition, and that we at Tsumura International oppose such an installation. Best : • !ards/ Ron Whi. ►-rman Senior 'ce President- Operations RW/jm 12800 WHITEWATER DRIVE•MINNETONKA, MN 55343•(612)945-9400•FAX(612)945-2080 DIVISION OF TSUMURA INTERNATIONAL INC. 1(21 T iy October 15, 1991 The Hon. Gary Laurent Mayor, City of Shakopee 129 East First Avenue Shakopee, MN 55379 City Council Members CITY OF SHAKOPEE 129 East First Avenue Shakopee, MN 55379 Re: Amendment to CUP Ordinance - Brambilla Dear Mayor Laurent and Council Members : By this letter, we wish to clarify our positions as they may relate to the ongoing, above-referenced process . On August 8, the Planning Commission for the City of Shakopee held a public hearing for Jack Brambilla' s requested rezoning of a parcel of land located at the corner of Valley Park Drive and Highway 101 . The Planning Commission accepted testimony from interested citizens and weighed the merits of the rezoning request based on the philosophies of sound land use planning, the Comprehensive Plan and other issues pertinent to the request. Staff ' s memo of August 8 to the Planning Commission suggested that denial of this rezoning would be appropriate. The Planning Commission agreed with Staff and recommended denial to the City Council . On August 20, the City Council addressed this rezoning issue, taking into consideration Staff ' s recommendation, the Planning Commission' s recommendation and additional testimony given by us and other interested parties . City Council, based on the information provided and after a thorough discussion of good land use practices, concurred with the Planning Commission and voted for denial of the rezoning request. Additionally, Council directed Staff to look at opportunities for amending the Conditional Use Permit (CUP) Ordinance to address the Petitioner' s needs . On September 5, the Planning Commission addressed an amendment to the CUP ordinance which would create the opportunity for Mr. Brambilla to do business under a CUP in the I-2 zone. Staff ' s report to the Planning Commission included a draft of an ordinance Mayor Gary Laurent City Council Members Page Two October 15, 1991 that could have served the needs of Mr. Brambilla. It detailed the various land use issues which should be discussed by the Planning Commission in making its determination if an amendment to the CUP Ordinance was appropriate. The Staff provided the Planning Commission with as much information as possible to make a decision on the merits of amending the ordinance. Once again, Staff ' s recommendation was for denial. Planning Commission accepted testimony from the general public, including us . We presented the land use issues and suggested that the amendment to the ordinance was not in the best interest of the City as a whole. Also, we suggested modifications to the proposed ordinance that we think would have improved the ordinance in ways that would clarify areas left open for misinterpretation by future CUP applicants wishing to use this ordinance, while at the same time establishing an amended ordinance which would be far more acceptable to the community than the draft presented to the Planning Commission. After thorough discussion of all the issues, the Planning Commission voted to recommend denial of the amended CUP Ordinance. On September 17, the City Council addressed the issue of the amendment to the CUP Ordinance. At that meeting, the Staff ' s recommendation for denial, the Planning Commissions ' recommendation for denial and the testimony presented by a variety of individuals, of which we were one, was taken into consideration. Our presentation to the Council was almost identical to that which was presented to the Planning Commission on September 5 . Again we presented logical reasons for denial of this ordinance amendment and also suggested ways we believed the draft of the ordinance could be improved if the Council chose to pass this ordinance. We believe the decision of the Council is in the long term best interests of the City. On October 1, the City Council was approached by the attorney for Mr. Brambilla with a request that the Council reconsider its September 17 action denying the amendment to the CUP Ordinance. During the hearing it was suggested there was pertinent information to warrant Council ' s reconsideration of this issue. One of those items was the suggestion we made representations that Mr. Brambilla could purchase land owned by Valley Green Business Park and that he would have no difficulty with rezoning, variance or CUP requirements if he were to purchase our land. No such representations were made by us . On the contrary, we told Mr. Brambilla that his efforts to locate his retail business on any I-2 zoned land would be extremely difficult because of the zoning. Mr. Brambilla said this would not be a problem because the City owed him and he would be taken care of. 0: Mayor Gary Laurent City Council Members Page 3 October 15, 1991 A letter from us to Mr. Brambilla dated June 12 , 1991, also was placed in the hearing record. This letter was presented to support the alleged representations by us to Mr. Brambilla. This letter is taken out of context. It was written after we met with Mr. Brambilla and told him that we thought he would not succeed with his rezoning. He said he could. We wished him luck. We also tried to find him other suitably zoned properties, including a possible combination of an existing B-1 parcel for his sales and an I-2 parcel for his servicing. It is in this context that we made the offer in the letter to help with the City. We thank you for the opportunity to place this information in the public record. We would have preferred to be able to handle this testimony in person, but were unable to do so due to conflicts in schedules . Respectfully, VALLEY GREEN BUSINESS PARK 6 on R. Albinson Project Director JRA: jmcx-77 cc : Dennis Kraft /, 2 . Do not suspend the rules and allow for the above mentioned reconsideration of amending the zoning ordinance. RECOMMENDATION: It is recommended that the City Council consider the information contained in the City Attorney' s memo and all other relevant information presented to them on this issue and decide whether they desire to reconsider this item after the suspension of Robert' s Rules. A staff recommendation is not included at this point because this is purely a policy question to be addressed by the City Council . In the past the Council has received staff recommendations, recommendations from the Planning Commission and testimony from many individuals both in favor of and opposed to the project. ACTION REQUESTED: Move to suspend Robert' s Rules and recon zoning ordinance to allow the sale of motor homes as a conditionally permitted use in the I-2 district. 1) MOVE TO RESCIND THE ACTION OF SEPTEMBER 17 , 1991 TO DEFEAT ORDINANCE NO. 319 , WHICH ORDINANCE ADDS CONDITIONAL USES IN THE I-2 ZONE. 2) OFFER ORDINANCE NO. 319 , TO ADD CONDITIONAL USES IN THE I-2 ZONE. ��- b. MEMO TO: Dennis R. Kraft, City Administrator FROM: Barry A. Stock, Assistant City Administrator RE: Early Retirement Policy - Resolution No. 3483 DATE: October 10, 1991 INTRODUCTION: On October 8, 1991, the Shakopee City Council met in a Committee of the Whole meeting to discuss a proposed Early Retirement Policy. At that time, the Committee of the Whole moved to have the Early Retirement Policy placed on the next agenda of the City Council. BACKGROUND: Attached is Resolution No. 3483 , A Resolution of the City of Shakopee Adopting an Early Retirement Policy. Several minor changes have been made to the Resolution since the Committee of the Whole meeting. New language that has been added to the Resolution is underlined. Language which is proposed for deletion has a dashed line through it. Staff is in the process of meeting with each of the employees that are eligible for the Early Retirement Incentive Program. Unfortunately, at the time the Council packet was assembled we do not have a clear indication of how many persons would be interested in the program. At the Council meeting on October 15, 1991, staff will be prepared to present more concrete data on which employees intend to take advantage of the Early Retirement Policy. Staff will also prepare a cost benefit analysis to illustrate the impact of the Early Retirement Incentive Program on the 1992 budget. ALTERNATIVES: 1. Offer Resolution No. 3483 , A Resolution of the City of Shakopee Adopting an Early Retirement Policy for the City of Shakopee. 2 . Make amendments to Resolution No. 3483 and offer the resolution as amended. 3 . Do not adopt a Early Retirement Policy for the City of Shakopee in 1991. 4 . Table action pending further information from staff. STAFF RECOMMENDATION: Staff recommends Alternative #1. ACTION REQUESTED: Move to offer Resolution No. 3483 , A Resolution of the City of Shakopee Adopting an Early Retirement Policy. BAS/tiv RESOLUTION NO. 3483 A RESOLUTION OF THE CITY OF SHAKOPEE, MINNESOTA, ADOPTING AN EARLY RETIREMENT POLICY. WHEREAS, the City is in the process of budgeting for the upcoming fiscal year, and has learned it may face a reduction in work force; and WHEREAS, the City has been approached by employees who are interested in taking early retirement; and WHEREAS, before the budget is finalized, the City would like to allow employees desiring to take early retirement an option to do so; and WHEREAS, the City has a small number of employees, and therefore would be crippled if a large number of employees in any given department took early retirement. NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SHAKOPEE, MINNESOTA, AS FOLLOWS: That the an Early Retirement Policy is hereby adopted, which shall provide as follows: EARLY RETIREMENT. City employees may elect early retirement, subject to the provisions set forth below. An employee is eligible for early retirement if (a) the employee has worked for the City of Shakopee for at least 15 years; (b) the employee is eligible for a full or reduced pension upon retirement; and (c) the employee shall be at least 55 years old on or before December 31, 1991, unless the employee is a police officer, in which instance the minimum age shall be 50 . Such a retiring employee would receive a lump sum payment covering the following items: 1. All accumulated unused vacation time. 2 . Up to one-third of accumulated unused sick leave, up to a maximum of 960 hours. (Police officers 45% of 960 hours. ) 3 . A percentage of the salary times years of service based on the following formula: 1% for each of the first 15 years of service, plus an additional 0 . 2% for each year thereafter, up to a maximum rate of 3% . These payments for vacation, sick leave, and years of service would all be calculated on the basis of the employee ' s current 1991 base salary or wage scale (excluding overtime) . These benefits would be in lieu of any benefits described in any existing personnel policy or contract. This early retirement package must be requested accepted, in writing to the City Administrator, by an interested employee on or before 4 : 30 p.m. , November 29 , 1991, with the employee retiring by December 31, 1991. A partial or conditional acceptance will not be considered. Any employee taking early retirement shall be required to sign appropriate documents prepared by the City Attorney. A maximum of two employees per department may take early retirement. If more than two employees in the same department request it, they shall be selected on the basis of the following: the most highly placed (with department head being the highest position) employees shall have priority over lower employees. If two employees are in the same job position, the employee with the most months of service with the City shall have priority over the employee with fewer months. Passed in session of the City Council of the City of Shakopee, Minnesota, held this day of , 1991. Mayor of the City of Shakopee Attest: City Clerk Approved as to form: _ City Attorney [EARLYRET] 2 C J �' 1` -• oC0mo t 9 z 0C x �9�•' 0 r a 0 0 9 0rn X ' r• r-• rt (D (D Cr1 V1 C) V1 C/1 C:7 (z 0 (TI to 0 to tri SI O r M A r• (D rt •• Cr1 7C CT] Cif 70 .< rl CTI 7C (:I MI 1"I 0 0 tnErr n Z Cr) � M M N Z Cf) M y � rte' tri (D O O' (D r-' r-• 1•r ••1 1-t 1-1 0 O' 0 Co Co V 4' U' Z H CO 77' N AJ - - - - - - - - CD CO CD N r r 'D N N 'D Co CO ON W N co J` 4" ',n O C TJ g N w0 r-• 0 0 'D 0. N H (+I'-4 a' 0 CO N co r-• 4.- moi N•'. (D N 'D 1-' VI U' 1/40 J„a 'O < 0T1 O' r•• 0- ON 'D U' rC C C) 0 N O' V 0 0 U' ON N.) (II NI CO CO ta U' r-• V ,O Z 0) p1 N W N A . W ON W J` � O' � 0'. a' Cl)C rt C) (t A rt 0 CD A 4, N 0 0 Ln 'D I-' a C=1 'O t.n N J` V N ON U' ` P71 a) O CO II CO 'D to N r 0 ca r+ C) < 'D 'D 0 r-• r-• O N f 0 A rt C N W 0 ON ON V O N > CI 'ONN J` 4- NNr- , DCI rt r; E N • M OJ (D r-• W r-• 0 CN ON 0 Co W H co V V .t N ON 0 V1 , • yC b A '1 'D ON U' W W Co a' CO 0 0 0 0 Ln Ln U' U' < C=I (D rt (D rt z C1 A H G.b 0 III N La 4J W V CO 4 M�7 r• (D N 0 - • - • - - - 3. Z (D 0 ' N r U D 'D ' 0 Cl) )' to W W r A U' O~ ' a R. A. CO U' N VD I-. CO V N '.4 r-' O' W 1-• tri 'D N C=I r• • 0 co 4- v' ON 0 r-• Co V C) 'D -J O' LI) V ON 1/40 1C M Z HI Z O Oo Cy V 'D U' N 0 'D N.) CO 'D A N) r-' I--, N.) V Cl) '( H r( 0 N P- 4- VD 0 U' 0 la . N N ON !.*- 1-' ON H M M �) (Z'1 r 0 <n <n <n<n <s -CA <n 'D rt %C 1✓ 1-•' <A r 1✓ r' N.) W CT! 'D (D 0 V 'D LA N 'O Co ON r-• Z pi • • � 0-t ON co ON . N P- 4-- 0 H co W U' U, Ln 0 , V F-I 'D V N N N N.) 1-' 0 CO H V N 'D 'D W V I-' C O E ON N on La V Co U' N ',a W CO N CO La CO Co ' C'7 'O (7 La 0 -.4 4" N D' . - 1•-' r N.) O' N ON L42 MD 0 CA b F-• 0• V P. O' N W CO N 4J V U' U' CO La 1✓ ON > 1� 4". a' rnrnVr OtikA, Z L a1 op N.) Co Co O C 0 CO M `C rt > :A a() ON 'D 4" 'D r-' D1 M a J J -‘,', r A CIO 7 V U' Co A 'D 'D N 11 Q; 'D r-• U' 4" A aJ I- 'D 1-•' -.4 W O' w-. � O N N 1--• N U' Cl) CO QQ 0 w r N CO 0 0 (D rt La N V N N co N W 0 4 W.:o 0 A tea' NI� CA I A' _ O' '0 'D N ' V 0 V 1--' r-• w 'D r (D r 07 ON V N - CCD 0 N W C/1 1/4 r N V 'D 0 N CD La 'D U' N,, C 4- N 'a , (D 1.4 rt Co 4- v' M4-., ... Co W N W C/! 'a 1 A t✓ r•• fD O'D VW 0. ON v' V (CD 0 r-' 'OD V W N Cl) rt O r-• 1-' N. CO r-' N N) rr U' U' W 4- 'O V V a' Iv CO • • I-, w CO t-' . 0 W N V1 A O r r O N W N •,3' N U' •t A 0 � r• t-, v+ Co r. cn 01 A rt <n v1-CO I-. </1 r<n</> <n r r+ O O' OL- CO V •g- v r-' Y 'D N 'D CO CO H co O W 1--0 'D CO 'D a N N W0--• 0 'DON N C'• A N 'D t✓ U' 'D W 'O C', ON V 0 U' O' N 0.N' N ,,. . 1`,1 ^J ���• EARLY RETIREMENT BUDGET ANALYSIS Asst. Police Chief 1992 1993 1994 Asst. Police Chief budgeted wages & benefits $52 , 819 . 16 $52 , 819 . 16 $52 , 819 . 16 Less Retirement Package Cost (36, 082 . 13) --- --- Less Cost of Replacement 1. (patrolman-entry level) (21, 474 . 64) (32 , 211 . 96) (32,211.96) 2 . Less Cost of Addn Sergeant ( 2, 400. 00) ( 4 , 056. 00) ( 4 , 056. 00) 65,,oo Actual Budget Savings $ (7 , 137 . 61) $16, 551 . 20 $16, 551 . 20 1 . 5/1/92 Start 2 . 1/1/92 Start 3 . Wage and benefit calculations do not include sick leave/vacation benefit differentials. 4 . The amounts depicted will increase or decrease dependent upon when and if certain positions are filled. The retirement package cost may also vary dependent upon the amount of sick or vacation time logged by the Asst. Police Chief prior to Dec. 31, 1991 . 5. Calculations do not include COLA adjustments EARLY RETIREMENT BUDGET ANALYSIS Building Official 1992 1993 1994 Building Official budgeted wages & benefits $51, 176. 63 $51, 176 . 63 $51, 176. 63 Less Retirement Package Cost (15, 423 . 42) --- --- Less Asst Inspector Wage & 1 . 2 . 3 . Benefits (43 , 498 . 84) (46 , 057 . 39) (48 , 615. 93) Plus Budgeted Unemployment Exp. $ 6, 500 . 00 --- -__ Actual Budget Savings $ (1, 245. 63) $ 5, 119 . 24 $ 2 , 560. 70 1. Step 3 - Bldg. Official 2 . Step 4 - Bldg. Official 3 . Step 5 - Bldg. Official 4 . Wage and benefit calculations do not include sick leave/vacation benefit differentials. 5. The amounts depicted will increase or decrease dependent upon when and if certain positions are filled. The retirement package cost may also vary dependent upon the amount of sick or vacation time logged by the Asst. Police Chief prior to Dec. 31 , 1991 . 6. Calculations do not include COLA adjustments TO: Dennis R. Kraft, City Administrator FROM: Gregg Voxland, Finance Director RE: Assessment Against City Property DATE: October 3, 1991 Introduction Council has levied an assessment against City property for the Shumway project. Background Council has levied an assessment against city property parcel number 27- 001454-0 in the amount of $4,622.66 for the Shumway project. Council can let the assessment run and pay the annual installments plus interest out of the general fund or another fund. Alternatively, Council can prepay the assessment using the Capital Improvement Fund which is the course usually taken. Alternatives 1. Pay the assessment over time out of the General Fund. 2. Prepay the assessment out of the Capital Improvement Fund. Recommendation Alternative number 2. Action Move to prepay the assessment for the Shumway project levied against city owned property parcel number 27-001454-0 in the amount of $4,622,66 out of the Capital Improvement Fund. # lad. CONSENT MEMO TO: DENNIS KRAFT, CITY ADMINISTRATOR FROM: DAVID HUTTON, PUBLIC WORKS DIRECTOR SUBJECT: COMPREHENSIVE SEWER PLAN DATE: OCTOBER 9, 1991 INTRODUCTION Staff is seeking City Council authorization to execute a contract with the consultant selected to prepare the Comprehensive Sewer Plan, namely Short-Elliot-Hendrickson, Inc. BACKGROUND The proposed Shakopee Comprehensive Plan recommended that a Comprehensive Sewer Plan be completed as a supplement to the Comp Plan. On April 16, 1991 the City Council of Shakopee authorized staff to seek proposals from consultants to prepare this plan. An extensive Consultant Selection Process was completed with a recommendation to the City Council that if a consultant were utilizied, the consultant recommended by the Committee was Short-Elliot-Hendrickson, Inc. (SEH) . Staff also prepared a proposal to complete this study utilizing in-house staff and resources. On August 20, 1991 the City Council reviewed the recommedation of the Selection Committee as well as discussed the option to utilize in-house staff. At the conclusion of the discussion, the City Council determined that this project was best suited for an outside consultant and directed staff to negotiate a contract with SEH to complete the project and finalize the scope of services desired. Staff has had numerous meetings with the consultant to finalize the desired scope of services. City departments that were involved in this process included Engineering, Planning, Administration and MIS. In addition a contract has been negotiated which is substan- tially in comformance with the original proposal submitted by SEH. Attached is the final contract for consideration by the City of Shakopee. The City Attorney has reviewed and approved of the language in this proposed contract. The final contract indicates that the Scope of Services can be completed for an estimated cost of $100, 000. The actual payments will be based on hourly rates and actual hours worked. The contract is requesting that maximum payment allowed without revising the contract be $110,000, in case additional work is desired by the City. All funds for this study will come from the Sanitary Sewer Enterprise Fund. ALTERNATIVES: 1. Direct the appropriate City officials to execute the contract with Short-Elliot-Hendrickson, Inc. for completing the Comprehensive Sewer Plan. 2 . Deny the request. 3 . Table the request in order to revise the contract per City Coucil direction. RECOMMENDATION: Staff recommends Alternative No. 1. ACTION REQUESTED: Move to authorize the appropriate City officials to execute a contract with Short-Elliot-Hendrickson, Inc. for the purposes of completing a Comprehensive Sewer Plan for a not-to-exceed fee of $110, 000, which includes a $10, 000 contingency. AGREEMENT FOR ENGINEERING AND PLANNING SERVICES BETWEEN THE CITY OF SHAKOPEE, MINNESOTA AND SHORT-ELLIOTT-HENDRICKSON, INC. THIS AGREEMENT made as of the day of in the year Nineteen Hundred and Ninety-One by and between the CITY of SHAKOPEE, MINNESOTA, hereinafter called the CITY, and SHORT-ELLIOTT- HENDRICKSON, INC. , 3535 Vadnais Center Drive, St. Paul, Minnesota, hereinafter called SEH. WHEREAS, CITY requires cost effective quality professional engineering and planning services in a timely manner, and WHEREAS, the CITY intends to retain SEH to provide professional engineering and planning services associated with a Comprehensive Sanitary Sewer Plan and associated reports on project feasibility, and WHEREAS, the CITY and SEH deem it mutually advantageous to set forth the general details herein. NOW, THEREFORE, the CITY and SEH agree that the following shall constitute a joint Agreement. SECTION I - BASIC SERVICES OF SEH A. GENERAL 1. SEH agrees to perform professional services in connection with the Project as hereinafter stated. 2. SEH shall serve as the CITY' S professional representative in all Engineering and Planning phases of the Project, and shall give consultation and professional advice to the CITY during the performance of their services. - 1 - B. COMPREHENSIVE SANITARY SEWER PLAN Services performed by SEH shall include the following: 1. Establish and Document Existing Conditions a. Add the City' s current sanitary sewer system to the AutoCAD base map. b. Add physical data attributes of all sanitary sewer systems. Information will be obtained from asbuilt drawings for all systems installed since 1974. Add all data contained in the 1974 Sanitary Sewer Capacity Report. This data includes: i. Manhole numbers ii. Manhole inverts iii. Pipe sizes, grades, and capacities c. Determine average and peak flows for each existing sanitary sewer subdistrict and for all pipes over 8" diameter. 2. Update the 1982 Infiltration/Inflow Study Analysis a. Utilize fluorometric flow calibration techniques to quantify the wet weather (high river level ) infiltration in the River District. Alternatively, SEH will set weirs or flumes with the assistance of City staff. City staff will check and read them daily. Flows will be measured during a two month period encompassing late winter (dry weather flow) and early spring (wet weather/high river level flow) . Flows entering the River District will be measured simultaneously. b. Using six metering points, subdivide the River District into four segments and compare measured flows to calculated sewage flow to identify problem areas. - 2 - c. City of Shakopee to bypass pump and video tape selected sanitary sewer mains during times of high river levels as requested by SEH. d. Recommend rehabilitation where cost effective. e. Estimate flow rate anticipated from River District after rehabilitation. f. Field check four private industrial service meters to verify accuracy of current user measured flows. Meter' s manufacturer' s literature, installation, and calibration will be reviewed. g. Provide a report documenting results. 3. Review the Facility Plan being Completed by the MWCC on Lift Station L-16. a. Meet with the MWCC to review the System Improvement Study. b. Meet with the MWCC to review their recommended Facility Plan. c. Incorporate this data into the Comprehensive Sewer Plan. 4. Determine Future Flows a. Review the market study being prepared for Valley Green Business Park and compare to the growth rate for the Industrial District as forecasted in the Comprehensive Plan. - 3 - b. Estimate future flows based on the City' s projected growth and appropriate sewage generation rates. c. Consider the impact of Rahr Malting' s proposals to expand their plant and provide their own treatment and disposal system. d. Consider a flow diversion from the East District to the VIP District to relieve lift station L-16 as necessary per the MWCC Facility Plan. 5. Monitor Chaska Interceptor Planning a. Review the preliminary System Improvement Study and meet with the MWCC to discuss alternatives. b. Provide projected flow data to the MWCC for their use in preparing the study. c. Meet with the MWCC to review their preliminary Facility Plan and provide input and recommendations. d. Incorporate the final Facility Plan information into the Comprehensive Sewer Plan. 6. Prepare a 20-year Sanitary Sewer Expansion Plan a. Consider flow diversions from the VIP District via the Chaska Interceptor or South Shakopee Trunk Sewer to the Prior Lake Interceptor to relieve MWCC Interceptor 7023 to the extent necessary. b. Subdivide sewer districts based on the foregoing data and develop an ultimate trunk sewer system consistent with Comprehensive Plan goals, policies, and objectives. - 4 - c. Identify all projected sanitary sewer extensions with possible interim solutions for temporary service prior to new trunk/interceptor installation (e.g. , new regional hospital ) . d. Consider the long-term cost effectiveness between deep trunk sewers and lift station and forcemain systems. e. Prepare a 5, 10, and 20-year plan for the orderly expansion of the MUSA line in conformance with Metropolitan Council guidelines. Prepare a MUSA line expansion map. f. Address any other sanitary sewer issues raised in the Comprehensive Plan and offer recommended solutions. 7. Coordinate with the City and with Regulatory Agencies on the Status of the Comprehensive Sewer Plan a. Coordinate with MWCC, Metropolitan Council, and other consultants working for the City. b. Meet with Shakopee Public Utilities to coordinate with the Implementation of the Comprehensive Water System Plan. c. Meet with City staff at least once a month to discuss progress on the Comprehensive Sewer Plan. 8. Prepare an Improvement Schedule a. Develop a schedule of improvements acceptable to the City. - 5 - b. Estimate budget costs for each improvement to provide a means of projecting future financial needs. c. Incorporate the results of the feasibility studies. 9. Develop a Comprehensive Sanitary Sewer Plan Document a. Review and assemble data. Prepare text, drawings, and schedules. Present the document to the City Council once in a draft form, and once in a final form. b. Complete the document in the format necessary for the City to submit a comprehensive plan amendment to the Metropolitan Council for approval. Deliver 20 copies to the City. c. All work will be performed and delivered in an automated format. SEH will provide the City with data presented in an AutoCAD-based comprehensive sewer plan package. This includes providing the FMS/AC software and two days of on-site training for the City' s AutoCAD operator. The FMS/AC software installation consists of a planning package plus a sanitary sewer system template. This includes graphics, a data base, and a tie of sanitary districts to a Lotus 1-2-3 spreadsheet for flow calculation. C. PRELIMINARY REPORT PHASE When authorized to perform the Preliminary (Feasibility) Report Phase, SEH shall: 1. Consult with the CITY representatives to determine the scope of the project. The scope is anticipated to include preparation of Report(s) for the Valley Industrial Park and South Shakopee Trunk Sewer(s) as applicable: - 6 - a. Study trunk sewer routing(s) which will serve the Industrial District north of the T.H. 101 bypass, the VIP District diverted flow, and South Shakopee District. b. Study the impact of MWCC construction/coordination on the proposed Chaska Interceptor. c. Review MUSA line concerns with MWCC and Metropolitan Council. d. Accomplish preliminary designs which include construction staging as necessary to accommodate growth. 2. Make such investigations and perform other tasks determined by SEH to be necessary to complete the Preliminary Report for the proposed project. 3. Prepare a Preliminary Report in sufficient detail to clearly describe the project. The Preliminary Report will include the following unless otherwise agreed to by the City and SEH: a. Background Information b. Reason(s) for Report c. Design Criteria as needed d. Proposed Plan(s) e. Easement Requirements f. Permit Requirements g. Proposed Project Schedule h. Estimate of Cost i. Project Financing j . Results and Conclusions - 7 - 4. A completed draft copy of the Preliminary Report shall be submitted to the City staff for their review and comments. 5. Twenty (20) copies of the final Preliminary Report(s) will be furnished to the City after the comments of the City staff have been received by SEH. 6. SEH shall participate in the presentation of the contents of the Preliminary Report if requested by the City at the following: a. A City Council Meeting b. A Public Hearing c. A Public Informational Meeting D. OPTIONAL SERVICES If authorized in writing by the CITY, SEH shall furnish optional services of the following type: 1. Preparation of applications and supporting documents for government grants, loans or advances in connection with the project. Preparation or review of environmental assessment worksheets and environmental assessment impact statements. Review and evaluation of any statements or documents prepared by others and their effect on the requirements of the project. Assistance in obtaining approvals from authorities having jurisdiction over the project. 2. Additional services due to significant changes in the general scope of the Project or its design including but not limited to, changes in size, complexity of character or type of construction. 3. Providing services of professional consultants for other than the basic services stated in the Agreement. - 8 - 4. Preparation of descriptions for permanent and/or temporary easements. 5. Serving as an expert witness for the CITY in any litigation or other proceedings involved in the Project. 6. Additional services in connection with the Project not otherwise provided for in this Agreement. SECTION II - THE CITY'S RESPONSIBILITY A. THE CITY SHALL: 1. Provide full information as to its requirements for the Project. 2. Assist SEH by furnishing all available information pertinent to the Project. 3. Guarantee access to and make all provisions for SEH to enter upon public and private lands as required for SEH to perform work under this Agreement. 4. Provide such legal, accounting, and financial services as may be required for the Project. 5. Give prompt written notice to SEH whenever the CITY observes or otherwise becomes aware of any defect in the project. 6. Furnish television inspection of sewers, land surveys, soil borings, laboratory material tests, soil tests and other special items pertinent to the Project. 7. Be responsible for the accuracy and/or omissions of data furnished by the CITY consisting of, but not limited to, computations, asbuilt drawings, and maps. - 9 - 8. Examine all studies, reports, sketches, opinions of construction costs, drawings, proposals and other documents presented by SEH and promptly render in its decision pertaining thereto. 9. Pay all costs incidental to acquisition of regulatory or review agencies' permits and/or approvals. 10. Designate a person to act as CITY'S representative with respect to SEH' S service to be performed under this Agreement; such person shall have complete authority to transmit instructions, receive information, interpret and define the CITY' S policies and decisions with respect to service covered by this Agreement. 11. Furnish (or instruct SEH to provide at the CITY'S expense) necessary Optional Services as provided in this Agreement or other services as they may be required. 12. Bear all costs incidental to compliance with the re- quirements of this Section II. SECTION III - PERIOD OF SERVICES A. COMPREHENSIVE SANITARY SEWER PLAN The schedule for completing the services called for in the Comprehensive Sanitary Sewer Plan phase is highly dependent on the input and activity of others, including but not limited to the Metropolitan Council, MWCC, the City of Shakopee, and others. It is estimated that all work will be completed within twelve months after authorization to proceed. - 10 - B. PRELIMINARY REPORT PHASE It is estimated that the services called for in the Preliminary Report phase of this Agreement will be complete and the final report submitted to the City within two months of separate authorization to proceed on the Preliminary Report phase. C. GENERAL Unless sooner terminated as provided in Paragraph VI .D. , this Agreement shall remain in force for a period which may reasonably be required for the completion of the services called for in that phase of work last authorized. SECTION IV - PAYMENTS TO SEH A. BASIC SERVICES SEH shall be compensated monthly for the work described in Section I . Said compensation shall be the total payroll cost of the personnel assigned to the project times a factor of 2. 13 plus the cost of expenses as outlined in Section IV.C. and the cost of equipment utilization as outlined in Section IV.D. An estimate of the cost for the work, anticipating the need for two feasibility studies, is $100, 000. This includes expenses and equipment utilization and providing the FMS/AC software ( $3, 600) . It is agreed that after 90% of the costs have been incurred, SEH will notify the CITY and confer with representatives of the CITY to determine the basis for completing the work. It is agreed that the cost of the work will not exceed $110, 000 unless the scope of work is modified. B. PAYMENTS FOR OPTIONAL SERVICES The CITY shall pay SEH monthly for optional services performed described in Section I .D. Monthly payments shall be based on the total payroll cost of personnel assigned to the project times a factor of 2. 13 plus the cost of expenses as outlined in IV.C. plus equipment utilization as outlined in Section IV.D. - 11 - C. EXPENSES The following expenditures made by SEH employees or professional consultants specifically for the Project are not included in Basic Services and shall be paid for as agreed in Section IV of this Agreement. 1. Transportation expense. 2. Fees paid in the name of the CITY for securing approval of authorities having jurisdiction over the Project. 3. Report and plan reproduction expenses. 4. Special travel and expenses connected therewith required in connection with the Project and authorized by the CITY. 5. The cost of special consultants or technical services as required. D. EQUIPMENT UTILIZATION The utilization of equipment (computers, electronic survey equipment and automatic data plotting equipment) for data acquisition, detailed engineering computations and plan preparation is recognized as benefiting the CITY through more efficient production of project documents and minimization of costs involved with document modification when the project scope or other conditions change. The CITY, therefore, agrees to pay the reasonable cost for the use of such specialized equipment on the project. SEH invoices to the CITY will contain detailed information regarding the use of specialized equipment on the project and charges will be based on the standard rates for the equipment published by SEH. - 12 - The CITY shall pay SEH monthly for equipment utilization. E. DEFINITION The payroll cost of salaries and wages as the basis for payment under Paragraph V.A, and V.B. shall mean the cost of salaries and wages paid to principals and employees engaged directly on the Project, including, but not limited to, engineers, planners, surveyors, technicians, drafters, specification writers, estimators, stenographers and clerks, plus cost of fringe benefits including, but not limited to, Social Security contributions, unemployment, excise and payroll taxes, Workmen' s Compensation, Health and Retirement Benefits, incentive compensation, sick leave, vacation and holiday pay applicable thereto. SECTION V - GENERAL CONSIDERATIONS A. INDEMNIFICATION Not withstanding the Scope of Services to be provided by SEH pursuant to this Agreement, it is understood and agreed that SEH is not a user, handler, generator, operator, treater, storer, transporter or disposer of hazardous or toxic substances, . pollutants or contaminants as any of the foregoing items are defined by Federal, State and/or local law, rules or regulations, now existing or hereafter amended, found or identified in the CITY. It is further understood and agreed that services SEH will undertake, for the CITY'S benefit, are potentially uninsurable obligations involving the presence or potential presence of hazardous or toxic substances, pollutants or contaminates. Therefore, the CITY agrees to hold harmless, indemnify and defend SEH and SEH' s officers, subcontractor( s) , employees and agents from and against any and all claims, losses, damages, liability and costs, including but not limited to costs of defense, arising - 13 - out of or in any way connected with, the presence, discharge, release, or escape of hazardous or toxic substances, pollutants or contaminants of any kind, except for such liability as may arise out of SEH' s negligence or intentional acts in the performance of services under this Agreement. B. LIMITATIONS ON SEH' S LIABILITY The CITY hereby agrees that to the fullest extent permitted by law SEH' s total liability to the CITY for any and all injuries, claims, losses, expenses, or damages whatsoever arising out of or in any way related to this Agreement from any cause or causes including, but limited to, SEH's negligence, errors, omissions, strict liability, breach of Contract or breach of warranty shall not exceed SEH' S total fee for the services rendered on the project. C. REUSE OF DOCUMENTS All documents including computer data files and drawings prepared by SEH pursuant to this Agreement are instruments of service in respect to the Project. All data (printed and electronic) for this project is intended for comprehensive sanitary sewer planning and maintenance purposes. Prior to making sanitary sewer extensions, system connections, or capital expenditure decisions, field verification of critical comprehensive sanitary sewer plan data is necessary. Data compiled as part of this project is from a variety of sources, including City records, agency records and reports, and consultant reports or asbuilts. Compiled data is not intended or represented to be suitable for design purposes by the CITY or others on any other Project. Any such use without written verification or adaptation by SEH for the specific purpose intended will be at the CITY'S sole risk and without liability or legal exposure to SEH; and the CITY shall indemnify and hold harmless SEH from all claims, damages, losses and expenses including attorneys' fees arising out of or result- ing therefrom. - 14 - D. ASSIGNMENT SEH shall not, without the written consent of the CITY assign any interest or obligation in this Agreement. E. INSURANCE SEH shall secure and maintain such insurance as SEH deems necessary or appropriate, but as a minimum as required by City of Shakopee specifications, to protect him from claims under Workmen' s Compensation, accidents or claims for bodily injury, death or property damage which may arise from the performance of SEH services under this Agreement. F. TERMINATION This Agreement may be terminated by either party upon seven days written notice should the other party fail substantially to perform in accordance with its terms through no fault of the party initiating the termination. In the event of termination SEH shall be compensated for services performed to termination date, including expenses and equipment costs then due and all terminal expenses. G. FAILURE TO MAKE PAYMENTS If the OWNER fails to make any payment due SEH for services and expenses within thirty days after receipt of SEH ' S statement therefor, the amounts due SEH will be increased at the rate of 1% per month from said thirtieth day, and in addition, SEH may, after giving seven days ' written notice to the OWNER, suspend services under this Agreement until SEH has been paid in full all amounts due for services, expenses and charges. - 15 - APPROVED: CITY OF SHAKOPEE, MINNESOTA SHORT-ELLIOTT-HENDRICKSON, INC. BY: BY: TITLE: TITLE: BY: BY: TITLE: TITLE: BY: TITLE: ADDRESS FOR GIVING NOTICES: 129 East First Avenue 3535 Vadnais Center Drive Shakopee, MN 55379 St. Paul, MN 55110 - 16 - CONSENT i 1 -e) MEMO TO: Dennis R. Kraft, City Administrator FROM: Judith S. Cox, City Clerk RE: Request for Deferment of Special Assessments DATE: October 9 , 1991 INTRODUCTION: The City has received an application from Roger O. and Eunice M. Dedeker for the deferment of special assessments against their property as a result of the reconstruction of Shumway Street between 3rd Avenue and 6th Avenue. BACKGROUND: As you are aware, both Minnesota Statutes and the City Code have provisions for Senior Citizens to defer their special assessments if it would be a hardship for them to make the payments. Mr. Dedeker has completed an application stating that it would be a hardship for him to make payments for the special assessments against his property as a result of the recent reconstruction of Shumway Street. According to Mr. Dedeker' s application, he and his wife do meet the conditions outlined in the City Code. ALTERNATIVES: 1. Approve the request. 2 . Deny the request. RECOMMENDATION: Alternative #1, Approve the request. REQUESTED ACTION: Approve the application from Roger O. and Eunice M. Dedeker, 610 West 3rd Avenue, and grant deferment of special assessments to parcel #27-001310-1 for the 1991-1 Shumway and Scott Streets public improvements, pursuant to the conditions outlined in Section 2 . 82 of the City Code. O1SENT / f MEMO TO: Dennis R. Kraft, City Administrator FROM: Judith S. Cox, City Clerk RE: Application for Premises Permit for Shakopee Youth Baseball/Softball DATE: October 9 , 1991 INTRODUCTION & BACKGROUND: The Shakopee Youth Baseball/Softball is applying for a Premises Permit to sell pulltabs at the Dangerfield' s Restaurant and Bar (formerly the Shakopee House) . The Association currently has a Premises Permit for Cheer' s 2 Ya. The State Gambling Board requires the City Council to adopt a resolution approving the permit prior to their consideration of the application. RECOMMENDED ACTION: Offer Resolution No. 3482 , A Resolution of the City of Shakopee, Minnesota, Approving a Premises Permit for the Shakopee Youth Baseball/Softball, and move its adoption. RESOLUTION NO. 3482 A RESOLUTION OF THE CITY OF SHAKOPEE, MINNESOTA, APPROVING A PREMISES PERMIT FOR THE SHAKOPEE YOUTH BASEBALL/SOFTBALL WHEREAS, the 1990 Legislature adopted a law which requires Municipal approval in order for the Gambling Control Board to issue or renew a Premises Permit; and WHEREAS, the Shakopee Youth Baseball/Softball is seeking a Premises Permit for Dangerfield' s Restaurant and Bar, 1583 East 1st Avenue, Shakopee, Minnesota. NOW, THEREFORE, BE IT RESOLVED, by the City Council of the City of Shakopee, Minnesota, as follows: That the Premises Permit for Shakopee Youth Baseball/Softball, at Dangerfield' s Restaurant and Bar, 1583 East 1st Avenue, Shakopee, Minnesota be approved. Adopted in Adjourned Regular Session of the City Council of the City of Shakopee, Minnesota, held this 15th day of October, 1991. Mayor of the City of Shakopee ATTEST: City Clerk Approved as to form. City Attorney / J6 CONSENT Without detailed checking, Finance staff is not aware of any bills in the attacsthat respective division to exceed the division totalbudgets adopted byCouncil . Included in the bill list is a bill from Kustom Signals, Inc. in the amount of $1,860.00 for a radar unit ordered by the Police Chief. At this point there are sufficient appropriations left in the Police Division capital equipment account to cover the purchase. However, this item is not listed in the detail budget as an item to be purchased this year. 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W 0 0 WW 2 0 A N 0 )- J r 0 r A r r 0 N W N 0 0 rr 0 0 r 0) 0 Nr r 0 N r r N 0 r r r 0 0 Nr I I I I I I I I I I I I I I I I I I I I 0 0) r 0 (41- W 0 W 0) A W 0 r W W 0 0 WW 4-4 0 A N 0 m--4 r 0 r A r r 0 N W N 0 0 rr Z 00 AA W N W (D rr r CO 0 (D 00 C) U1 00 !F )-- 00 AA r W 03 C) WW 00 " ( • a O YD * IIID * r 3 M U) D U) C) D no 0 M r 0 --1 Co co 0o co o, co co o,co o, —4 -I 11-- !O 0 0 0 0 0 0 co o t H W H H H H H F� I-, HH I-•, H W H rHF-, I-, I-, I-, v1 00 w.p- • 4 p- 4-- .- • .p-- .p-.p- w .p. - 4- •l 4- p-- �-A- H r-- H vON ii N N W N w N w N N N �H H H \0�"0'0 's HH I--, \O co • 11 LA.) H H ODNO wH \o 0 0 0 0 0 0 0 0 > 0 0 0 0 0 0 0 0 0 0 0 o -4 vi I-' - w F-' I-, F-,w 0 0) 0 0 0 0 0 0 0 0 0 0 0 0 O H co -4 N I-'w 0\-4 w 0 c+ 0) 0 0 0 0 0 0 0 0 0 0 0 O H oN ON I'' H r H r I-' 0 O 00000 0 0 0 N W 011 0 0 0 OH H J H w CDD Co CO CO ' 0G Oo Co CO CO CONCorCO CO NN W 0 000000 Co n I I I I I I d H H H H I-, H H H I-' H H H H H H H H H H F-. H 1-H 0 0 0 0 0 0 0 0 000 00 0 0 000000 0 a H C b U) b CO H H H H F-' H H H I-, F-' H H HH H H F-' H H H H H N c) O cr Iv N W (D O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 C) C r•cG £ "i H p (D F-' ''i 0 x (D a cn r- 0 '•i K r CO > c+ c+ F-H 07 P) C!) CO O r ' cn H O• H H 0 (D '=i c+ C C co. < 0 H H CO K cc+ccnn (D -3 N) H \..nH 0 0 OD H u) w a 3 N) H W W W .I OD W H H Co c+ 0 -1 F-' N -P' -0 W 1 N \O ON CO I-' N CO CNN) w W N -P'N) N) N N) N) C p. N\O 0 'O `n v1 -J \O \n \O vl w CO -4 F-' N F-H H H H 0 0+ IV Co - ON � 'U' 0 N 0 000N IV 0 0 o Co 000000 c+ C) > ? C•) W N W W N W • F-, 1 NviOWC0 OONODOD \O N \.n N O1N CO O Co Cl) 70 Cn 0 0 b ( D D Cl) (D CD D D CD O (D > G c$ rrrrr• r• rr• rH. i N .i Cl- c+ c+ c+ c+ c+ c c+ + c+ K Cl) CI) CO b C) t7 C1) Ub 3 `=J '=J 0C + H O D ✓ til P (D H p D H H 'i K 7D K 0 H cC fa, C] H 11 N � C n CH O .i 3 -� 0Cn el Cn R° '-') D u'n z>K cc C Ca r• 0 G t-i r• a P 0C CD 0 0 C" C7 =I ? PH C 0 oN r '1 O N r t 3 s D 0 X Cl) ao P C Ctxi 0 = c+ a\ 0\ 0\ a o- ON ON o- LO Lo a ON ONONONONONON Co x 0 N \IDvi 'O LO O CoIO '- "0 CO CO Co CO CO CO co Co Co CO CO Co Co Co CO vi w N H 0 ON 0 vi W W W W W W N) o Cn Z Li0 - = p = Mw0 rPC V ti n 0 D n = CC) m > CCl))o td 0 3 .0 O cC 0 `< •0 a 0 R° 0 tri o Cl) = x H tz x 0N p fi W � H 0) 0 co CD CDD 0 C. Ox 0 0 x Cl) 1-i) c+ (D 0 0 0 '0 '0 (D CO (D O C CD CD ,1 C) X 1 N O vt - H H co H y`' co 9 O W N H co W vt - H OD c3* 7 W -3 -3 0 N •D 0 \O v9 vt -� vi CoW CO 0NOO v, - 00 N Co - 'U' U � � O 0 la- CONSENT TO: Dennis R. Kraft, City Administrator FROM: Tom Steininger, Chief of Police SUBJECT: Purchasing Error DATE: October 11, 1991 INTRODUCTION: I made a mistake and purchased a Radar Set contrary to City Policy. BACKGROUND: A month ago, I purchased a radar set. At the time, I knew there were provisions in my budget for this. When the Finance Department advised me this was not the case, I checked and discovered that there is in fact no radar set in the 1991 Police Budget. Last year, we put a new car on the road and equipped it with the radar out of the Sergeant' s car. As part of our attempt to save money last year, we did not purchase a radar. Last month, when the Sergeant ' s asked for replacement radar for their car, I apparently got my years mixed up, thought it was in the budget and authorized the purchase. There is money set aside in the 1992 Police Budget for Cellular Telephones. I am requesting to be allowed to spend $1, 860 of this money to pay for the radar set. ALTERNATIVES: 1. Disallow the purchase. 2 . Allow the purchase and authorize use of funds set aside for cellular telephone equipment to pay for it. RECOMMENDATION: Alternative #2 . ACTION REQUESTED: Move to amend the 1991 Budget to allow an expenditure of $1, 860 for the purchase of a radar unit and to decrease the amount budgeted for a cellular telephone by a like amount. cONSENT cu MEMO TO: Dennis R. Kraft, City Administrator FROM: David Hutton, Public Works Director RE: Snow Emergency Route Amendments - Ordinance #321 DATE: October 8, 1991 INTRODUCTION: Staff would like to propose several minor amendments to the snow removal ordinance in regard to designated snow emergency routes prior to this year' s snow season. BACKGROUND: The snow season parking restrictions were last amended in November of 1989 . The amendments that were made at that time clarified when calendar parking restrictions were in effect and enforced. The 1989 amendments also designated certain streets in the City as snow emergency routes. The designation of snow emergency routes provided the City with the ability to immediately tow vehicles parked along designated snow emergency routes. In other cases, towing may only occur after a four (4) hour time period has elapsed since the issuance of the citation for said parking violation. After monitoring snow plowing operations in 1990, I would like to recommend several amendments to the designated snow emergency routes. The proposed changes are minor in nature but will serve to enhance snow plow operation while still allowing most residents within the urban area to be within two (2) blocks of a designated snow emergency route. ALTERNATIVES: 1. Move to offer and adopt Ordinance No. 321. 2 . Do not offer or approve Ordinance No. 321. 3 . Amend Ordinance No. 321 as drafted and move its adoption. 4 . Table action pending further information from staff. STAFF RECOMMENDATION: Staff recommends Alternative #1. ACTION REQUESTED: Offer Ordinance No. 321, AN ORDINANCE OF THE CITY OF SHAKOPEE, MINNESOTA, AMENDING CHAPTER 9, PARKING REGULATIONS, SEC. 9 . 50, PARKING DURING STREET MAINTENANCE AND PARKING BETWEEN NOVEMBER 15 AND APRIL 1, BY REPEALING SUBD. 8 , RELATING TO SNOW EMERGENCY ROUTES, AND ENACTING ONE NEW SUBDIVISION IN LIEU THEREOF, RELATING TO THE SAME SUBJECT, and move its adoption. [9 . 50] ORDINANCE NO. 321, FOURTH SERIES AN ORDINANCE OF THE CITY OF SHAKOPEE, MINNESOTA, AMENDING CHAPTER 9 , PARKING REGULATIONS, SEC. 9 . 50, PARKING DURING STREET MAINTENANCE AND PARKING BETWEEN NOVEMBER 15 AND APRIL 1, BY REPEALING SUBD. 8 , RELATING TO SNOW EMERGENCY ROUTES, AND ENACTING ONE NEW SUBDIVISION IN LIEU THEREOF, RELATING TO THE SAME SUBJECT. THE CITY COUNCIL OF THE CITY OF SHAKOPEE, MINNESOTA, ORDAINS : Section 1 - That Chapter 9, Parking Regulations, Sec. 9 . 50, Parking During Street Maintenance and Parking Between November 15 and April 1, is hereby amended by deleting Subd. 8 , relating to snow emergency routes, and enacting one new subdivision which shall read as follows: Subd. 8. Snow Emergency Routes. The following streets shall be designated as snow emergency routes: [Adams St. from Sixth Ave. to Third Ave. ] Apgar St. from Sixth Ave. [First Ave. ] to Tenth Ave. Fourth Ave. from Holmes St. [Fuller Street] to Marschall Rd. Harrison St. from Third Ave. to Sixth Ave. and Tenth Avenue to Vierling Drive Holmes St. from First Ave. to Tenth Ave. Market St. from Fourth Ave. to Tenth Ave. Minnesota St. from First Ave. to Fourth Ave. Scott St. from First Ave. to Sixth Ave. Shakopee Ave. from Tenth Ave. [Holmes Street] to Eleventh Ave. Sixth Ave. from Holmes St. [Main Street] to Adams St. Spencer St. from First Ave. to Tenth Ave. [Eleventh Ave. ] Tenth Ave. from Marschall Rd. to Shakopee Ave. [Harrison Street] Third Ave. from Harrison St. to Scott St. [Highway 169 to Holmes Street] Twelfth Ave. from Adams St. to Taylor St. Vierling Dr. from County Rd. 16 to County Rd. 79 Note: The bracketed language [thus] is deleted; the underlined language is inserted. Section 2 - General Provisions. City Code Chapter 1, General Provisions and Definitions Applicable to the Entire City Code Including Penalty For Violation, and Section 9 . 99 , Violation a Misdemeanor or Petty Misdemeanor, are hereby adopted in their entirety by reference, as though repeated verbatim herein. Section 3 - Effective Date. This ordinance becomes effective from and after its passage and publication. Passed in session of the City Council of the City of Shakopee, Minnesota, held this day of , 1991. Mayor of the City of Shakopee Attest: City Clerk Approved as to form: ib'�4,d;%) ,/ City Attorney Published in the Shakopee Valley News on the day of , 1991. [9 . 50] -2- CITY OF SHAXOPEE CITY SNOW E ■mmmm COUNTY / STA 1 -..�_ _t - j - -. - � .- �a ....„, ._ ,, ,_ ________ ....b. ,.,_..., ...,. , ,\ ...• � i .: \. . 7. -. siC- - ...,in •om ___,.,,...., �j ,_----..,,.--- - ----o-,�.r , „. -ow- • - :-.- . _., -----„---- . . _.... .. ,i . 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