(use conditions as proposed by the Eastside Neighborhood Coalition)
Conditional Uses for the Salvation Army facilities located at Haskell Ave. & Lynn St.
Notes legally attached to the Site Plan SP-03-27-06
by the Lawrence City Commission on (date . . .)
The Lawrence City Commission approves Site Plan No. SP-03-27-06 pursuant to all legally binding conditions and provisions included herein, and attaches to and makes this a part of said site plan:
Section I: Purpose
In lieu of the standard Uses Permitted Upon Review process, and in an attempt to resolve disagreements between the parties, the issues addressed in this contractual agreement have been negotiated by the City of Lawrence, the Salvation Army, and neighborhoods and property owners surrounding the proposed Salvation Army site.
Considering that site plans functionally clarify on-site physical arrangements, while zoning districts with permitted uses functionally harmonize site activities with adjacent land uses, it is recognized that this contractual agreement, as attached to Site Plan SP-03-27-06, and the conditions contained herein constitute an unorthodox approach to land use regulations. Such an approach might not even withstand a legal challenge in a court of law.
The officially adopted zoning and use permit regulations within Chapter XX of the Code of the City of Lawrence have been crafted to provide the legal elements to assure compatibility of permitted land uses on adjacent properties, including: defined terminology, uniform procedures, consistent use groups, clear deadlines and expiration dates, enforceable penalties, an equitable appeal process, and revocation authority by the City Commission. In addition, such zoning regulations have a history of case law with applicable precedents, which may or may not apply to a conditional site plan such as this.
Section II: General Provisions
Therefore, because this document and the land use conditions herein, as attached to only a site plan, fall under few or no such code provisions as listed above, this document shall endeavor to construct their legal equivalent, and lacking that, to append the zoning and use permit provisions herein, so as to bring this document under the legal authority of all applicable zoning and use permit requirements of Chapter XX of the Code of the City of Lawrence, specifically Sec. 20-808, 20-1608, and 20-1613.
If officials or the public encounter any ambiguity in enforcing this document, the code provisions as intended for Use Permit Upon Review shall apply as interpretive and functional guidelines, specifically Sec. 20-1608 and 20-1613.
Because Sec. 20-1428 through Sec. 20-1435.3 for site plans include time constraints of an entirely different nature than those in Sec. 20-1608 through Sec. 20-1613 for UPR's, the following time frame considerations shall apply to this site plan No. SP-03-27-06.
Section III: Particular Use Activities Permitted
Section IV: Definitions (functional and time-frame)
Hello Sheila:
Thank you for your comments about how land use conditions might be
attached to the Salvation Army site plan SP-03-27-06. However, I am
submitting an addition to your 1 June Staff Report about this item
(attached herein). While you have discussed the enforceability of such
conditions and have included the Salvation Army version of such
conditions, I am astonished that nowhere under Agenda Item #9(b) have
you included the Neighborhood Coalition proposal for such site plan
conditions. Instead, an untitled version is buried in the "rezoning"
part of #9(a) under the generic caption of "correspondence".
The Salvation Army proposal is a nine-item list of "commitments" that
are legally quite non-specific and contain no periodic review
provisions. The Eastside Neighborhood Coalition proposal includes a
nine-item list of legally worded use activities, specific time
constraints and surrogate UPR review and revocation provisions, and
definitions of terminology.
Both proposals were discussed at the 3 May 2006 negotiation session
between the Salvation Army and the Eastside Neighborhood Coalition.
Both proposals are on the table. To avoid the appearance of favoritism
towards the Salvation Army, I think you would be wise to present both
proposals in the City Commission agenda on equal footing: that is
equally identified, equally accessible , and equally referenced and
evaluated in your Staff Report.
Please revise your staff report accordingly, and include as "Attachment
B" the "Neighborhood Coalition Proposed Site Plan Conditions", or at the
very least, make it an identified item under Agenda Item #9(b) along
with the other site plan attachments.
Also, please include this e-mail as an attachment under Agenda Item #9(b).
thanks so much for your work,
Michael Almon