HomeMy WebLinkAboutAgenda 13_SP-19-39_793 907 Shelburne Road_R L Vallee_Request LtrJON T.ANDERSON
ADMITTED IN VT
janderson@primmer.com
TEL:802-864-0880
FAX:802-864-0328
30 Main Street, Suite 500│ P.O. Box 1489 │Burlington, VT 05402-1489
4451827.1
August 11, 2020
VIA HAND DELIVERY
AND E-MAIL MKEENE@SBURL.COM
Marla Keene, P.E., Development Review Planner
Planning & Zoning Department
City of South Burlington
575 Dorset Street
South Burlington, VT 05403
Re: In Re: R.L. Vallee, Inc., 793 & 907 Shelburne Road, Site Plan Application
#SP-19-39
Dear Marla:
Enclosed please find a Motion to Reconsider.
Many thanks for your help.
Very truly yours,
Jon Anderson
JTA/alb
Enclosure
4451809.1
CITY OF SOUTH BURLINGTON
DEPARTMENT OF PLANNING AND ZONING
IN RE: R.L. VALLEE, INC.
793 & 907 SHELBURNE ROAD
SITE PLAN APPLICATION #SP-19-39
MOTION TO RECONSIDER
R.L. Vallee, Inc., SkipCo, Inc. and Phoenix 2, LLC (together the “Applicants”) hereby
request the Development Review Board (“DRB”) reconsider a certain 21-page decision (the
“Decision”) concerning a site plan application filed by the Applicants, dated July 13, 2020.
Attachment 1 is a copy of the first page of the Decision. The Applicants request the DRB to
reconsider at least the portion of the Decision including page 6 in which the DRB ruled that the
Applicants were illegally expanding a gas station use by using the lot located at 793 Shelburne
Road to the lot located at 907 Shelburne Road and because sales of fuel will also take place on the
lot at 907 Shelburne Road. In fact, no portion of any fuel sale will occur on that lot.
Dated: August 11, 2020 PRIMMER PIPER EGGLESTON &
Burlington, Vermont. CRAMER, PC
By: ____________________________________
Jon Anderson, Esq.
30 Main Street
P.O. Box 1489
Burlington, VT 05402-1489
(802) 864-0880
janderson@primmer.com
Attorneys for R.L. Vallee, Inc., Skipco, Inc. and
Phoenix 2, LLC
ATTACHMENT 1