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HomeMy WebLinkAboutBATCH - Supplemental - 0055 0057 0059 Swift StreetCITY OF SOUTH BURLINGTON DEPARTMENT OF PLANNING & ZONING 575 DORSET STREET SOUTH BURLINGTON, VERMONT 05403 (802) 846-4106 FAX (802) 846-4101 July 18, 2000 Albert & Marie St. Amand 61 South Willard Street Burlington, VT 05401 Re: Zoning Violation, 55 Swift Street Dear Mr. & Mrs. St. Amand: Please be advised that based on information available to the City, you have commenced land development on your property at the above address without obtaining a permit from the City as required by Section 27.10 of its Zoning Bylaws and 24 VSA 4443(a)(1). Specifically, you have initiated the following activities on the above -described property: Storing the following items on the green buffer zone along the south boundary: one (1) RV camper, two (2) automobiles, two (2) boats with trailers, one (1) utility trailer, and one (1) mobile home. You have seven (7) days from the date of this letter ro discontinue this violation and take appropriate remedial action. Specifically, you must accomplish the following: Remove all items being stored in the green space located between the gravel drive and the southerly boundary line. If you do not accomplish the ac"ons directed in this letter within seven (7) days of the date of this letter, the City may pursue this matter in court. In such court proceeding, the City will be entitled to seek appropriate injunctive relief and fines of up to one hundred ($100.00) dollars per day for each day your violation continues beyond the seven (7) day period provided in this letter. Albert & Marie St. Amand Zoning Violation June 22, 2000 Page 2 If the violation described in this letter occurs again within twelve (12) months of the date of this letter, you will not be entitled to receive a further Notice of Violation from the City before the City pursues further enforcement proceedings. You may appeal this Notice of Violation to the Development Review Board by filing a written notice of appeal (see enclosed) and eighty five ($85) dollars within fifteen (15) days of the date of this letter with the Clerk of the Development Review Board at the following address: 575 Dorset Street, South Burlington, Vermont 05403. Sincerely, Raymond J. Belair, Administrative Officer RIB/mcp 1 Encl cc: Amanda, S.E. Lafferty, City Attorney Certified letter #Z 395 693 819 PUBLIC HEARING SOUTH BURLiNGTON DEVELOPMENT REVIEW BOARD The South Burlington Development Review Board will hold a public hearing at the South Bur- lington City Hall Confer- ence Room, 575 Dorset Street, South Burlington. Vermont on Tuesday, September 19. 2000, at 7:30 P.M. to consider the following; 11 .Appeal #AO-00-09 of Albert &, Marie St. Amand appealing the issuance of a Notice of Violation dated July 18, 2000 by the Administrative Officer and a request for a Stay of Enforcement of the al- leged violation for prop- erty at 55 Swift Street. 2]. Appeal # r+,0-00-08 of Lawrence & Cynthia Caron appealing the is- suance of a Notice of Vi- olation dated July 13, 2000 by the Administra- tive Officer for property at A095 Williston Road. 31 Final plat appficatian #SD-00-45 of William & Charlotte Ross for Stonehedge „M„ Associ- ation to amend a planned residential development consisting of 16 units in tour [4] buildings, Cluster "M". The amendment consists of amending the landscaping plan to ap- prove the "as -built" landscaping, Stonehedge Drive.. 41 Application #MS-00- j' 04 of Henry & Sherry Barton seeking approval from Section 25.118[e]. Exceptions to Yard Set- back and Lot Coverage, of the South Burlington i Zoning Regulations. Re- quest is for permission to allow a 10'x12' deck to project 10 feet into the required 30 foot front yard setback require - meet, 2 Sherry Road. John Dinklage, Chairman South Burlington Development Review Board Sept. 2, 2000 r SEP-18-00 MON 09:00 AM MILLER EvGLESTON CRAMFh FAQ 110, + P, 021 KA1'LILEPN M. BOE VICTORIA J. BROWN MATTHEW J, CARTER ANNB CRAMA )ON R. OWLS510N GARY I-, FktNKLIN SHIREEN T. HART SMT L. iKL INE MARTIN 9.1CLLBR NARK A. SAUNUMS CWL E. WPSTGATS DOUGLAS J. WOLCNSKY FET21 P. YOUNG COUN.WL: PATRICIA L RICh AD NFJLWHENTWAI�;HT MILLER, EGGLESTON & CRAMER, LTD. A7TUrXFY5 AT LAW 150 SOUTH CHAMPWN STREET P.O. BOX 1489 BURLINGTON, TERMONT 0502.1489 VIA. FACSIMILE Raymond J, Belair Administrative Of eer City of South Burlington Department of Planning & Zoning 575 Dorset Street South Burlington, Vermont 05403 7H).EPI7ONE (902) a64.0880 (RUAI_tNUTON) (902) 229.2218 (MONTBELIL'fl) TELECOPIER (602) 864.028 WVLLINGON) (602) 229.2su (MONTPLU") September 18, 2000 Re; Alleged Zoning Violation, 55 Swift Strict Dear ' dlr. Belair: In accordance with our telephone conversation earlier toddy, I write to confirm that lbarr and Maric St. Amand revoke their appeal of the Notice of Violation regarding 5.5 Swift Strc,;t, dated July 18, 2000. As such, we do not plan to attend the heating scheduled for Sal)Lcniber 19, 2000, and we no longer seek a stay of enforcement. Thank you for your attention to this lnatter. Please do not hesitate to convict me at your convenience: with any questions or concerns. Very truly yours, Sllirce, For the Firm cc: Albert and Maric St, Arnand SMI WAgL rmenMay Sell' SArt8,1ah¢Inie 9 1100 IIr -IV w SEP-18-00 MON 09:03 AM MILLER EGGLESTON CRAMER FAX NO. + P, 0- Miller, Eggleston & Cramer, Ltd. lS0 South Champlain Street P.a, Box 1484 f3urlingtott, VT 05402-1489 802.864-0880 Fax: 802-864-0328 FAX COVER SHEET F^AXNtlMUR TRANSMITTED TOO, 846-4101 'Two Pages Including Cover To: Raymond Bettor Cf; South Burlington Departmcnt of Pla uii,V, & Zoning rrom: Shireen T. Mart, Esq. ClicnWaten Albert and Maric St. Amand 55 Swift Street Date: Septetnber 18, 2000 COMMLYCS: Per your request, please find a letter confirming our withdrawal of the appeal and request ('Or stay of enforccment of the Notice of Violation dated July 18, 2000. Tbank you for your attention to this. Shirccn 771c infc,r•mation Contained In this faesiini(a !nessage is infrrrnrcilon rrolec•ted by attonccy,clienr arc�'or the atrn, r:e� l�, ork product priutlege• It i, intended only for rl;e rue oJ'thc biefirvdrra! c:rr»red abavcr trnr! dre privileges acre not 1��aivcd by ria-tucr rf thi.y' l:avrrt bee» sent Ly frrr.: iniifv. if the t'eryun actually recOvi'rrg thisf ic',�i!rrik or arty othee reader of the facsinrrla i.4 not the immeti reelpient or the oniplri,ee or agerei responsible to deliver it to Ike named recip ent, any wee. disseminalion, distrihritia,z, a• capyirrg of the cool nnrnication rs neielly prohihited. If you June received rhrs toerunurrict�,linn bra error, please onnivdiwoly no* us by tKophrrne and retcrrn the or ginal it -Acne to us at U,e above ucWrass vra US. Postal Service. IF YOU DONCY1' tit?CEIVE Llj, P:�QES, P1.,l:nti>_ TELEPIJONE' US lMRtED1ATFLY Al 802464-0 80- CITY OF SOUTH BURLINGTON DEPARTMENT OF PLANNING & ZONING 575 DORSET STREET SOUTH BURLINGTON, VERMONT 05403 (802) 846-4106 FAX (802) 846-4101 September 15, 2000 Shireen T. Hart Miller, Eggleston & Cramer, Ltd. 150 South Champlain Street P.O. Box 1489 Burlington, VT 05402-1489 Re: Administrative Officer Appeal of Albert & Marie St. Amand, 55 Swift Street Dear Ms. Hart: Enclosed is the agenda for next Tuesday's Development Review Board meeting and my comments to the Board. Please be sure someone is present on Tuesday, September 19, 2000 at 7:30 p.m. to represent your request. If you have any questions, please give me a call. Sincerely, Raymond J. Belair, Administrative Officer RJB/mcp Encls Development Review Board September 19, 2000 10) ALBERT & MARIE ST. AMAND - APPEAL OF ADMINISTRATIVE OFFICER'S DECISION This appeal is from a decision made by the Administrative Officer that the property at 55 Swift Street is in violation of the zoning regulations (see enclosed Notice of Violation). The violation involves the storing of various items such as: boats, cars, trailers, RV camper, etc. in the green area required to be maintained by the appellant. The site is developed with two (2) mini -storage buildings (warehouse use) which is a non- complying use in the CI District. The site plan was approved by the Planning Commission on 6/23/87 and was the same plan approved on 9/23/86. A variance for this use was granted by the Zoning Board of Adjustment on 8/10/87. The site plan approved showed a 22 foot wide "green belt buffer zone" along the south boundary to be planted with ten (10) Red Pine trees 7 - 8 feet in height. This buffer was required because the south boundary is the boundary between the C 1 District to the north and the R4 District to the south. This buffer area is currently being used for outside storage not approved by the variance or site plan approval (see photos). Additionally, the Red Pine trees which were required to be planted and maintained in this buffer area do not exist. This is a clear violation of the zoning regulations. The applicant may try to argue that the large red trailer was approved on 7/15/97 when this property was involved in a boundary adjustment with the adjacent property. This is not the case for the following reasons: a) The Planning Commission clearly recognized that this trailer, and another trailer existing at the time, were not approved and required that the plat be revised to remove the large trailer from the plat (see enclosed Findings of Fact). b) The Planning Commission had no authority under the subdivision regulations to allow the expansion of a non -complying use. The appellants are also requesting a Stay of Enforcement. Staff recommends that it not be granted because the appellants have not demonstrated that they will suffer irreparable harm if it is not granted. Boat and Other Items on Green Space 7 Trailer on Green Space 55 Swift Street August 31, 2000 t J ;yrJ City of South Burlington Application to Development Review Board Name ofappiicant(s) Albert and Marie St. Amand Ofliclal Use APPLICATION # HEARING DATE FH,INa DATr FEE AMOUNT Address- 61 _S , Willard..S.t. ; ' Burlington Tclopbonc o .. 658-6252 _ 05401 Represented by Shireen T. Hart, Miller, Eggles on & Cramer, Ltd r16 6 Landowner Albert and Marie St Amand Location and doscri tlon of property 55 Swirt Street Adjacent pmpeny ntvner(s) & Addrecc Type of application check one: k:kappeal from decision of Administraior Officer (includes appeals from Notice of Violation) ( ) request for a conditional use ( ) request for a variance IX) other reques t f or s tay of enf orcement 1 undervAnd the presentation procedures required by State Law (Section A469 of the Planning & Development Act). Also that hearings are held twice a month (second turd fourth Mondays). nut a Icbal advertisement must appear u minimum of tlileen (15) days prior to the hearing. I ague to pay a hearing foe wh{oh Is to offset the cost of hearing. Provision of zoning ordinance in uectinn 24 V.S.A. 54443(a)(1 ; Section 27.10 Zoning Bylaws � _,_�_� _ M_ _w• Reason forappeal Disagree with assertion of land development Other documentation Affidavit of _Marie St. Amand in support of Request _ or. Stay. of Enforcement, (' c Date Signature SOU'('N BURLINGTON ZONING NOTICE )n accordance wldt the South Burlington Zoning Rugulations and Chapux 117, Title 24 V.S.A the South Burlington Dcvcluptncnt Rcvlcw Buwd will hold a public hcuring to the South Durlingwn Murtlelpal Ofl "% Confcretic..c: Rount, 575 Dorset Strcct, South Burlington, Vrnnont on Tuesday, , at 7:30 P.M. to eonsldcr the following: Application of seeldng a from Section of the South Burlington Zoning Regulation& Rcqucst is for permission to MILLER, EGGLESTON & CRAMER, LTD. ATTORNEYS AT LAW 150 SOUTH CHAMPLAIN STREET P.O. BOX 1489 BURLINGTON, VERMONT 05402-1489 KATHLEEN M.BOE VICTORIA J. BROWN MATTHEW J. CARTER ANNE CRAMER JON R. EGGLESTON GARY L. FRANKLIN SHIREEN T. HART SCOT L. KLINE MARTIN K. MILLER MARK A. SAUNDERS GAIL E. WESTGATE DOUGLAS J. WOLINSKY PETER F. YOUNG COUNSEL: PATRICIA L. RICKARD NEIL WHEELWRIGHT August 1, 2000 Clerk of Development Review Board 575 Dorset Street South Burlington, VT 05403 Dear Sir or Madam: TELEPHONE (802) 864-0880 (BURLINGTON) (802) 229-2218 (MONTPELIER) TELECOPIER (802) 864-0328 (BURLINGTON) (802) 229-2513 (MONTPELIER) Enclosed for filing please find a City of South Burlington Application to Development Review Board re: appeal from decision of Administrative Officer. In particular, Raymond J. Belair issued a Notice of Violation regarding 55 Swift Street to Marie and Albert St. Amand. Attached to the Application is a Request for Stay of Enforcement, along with the Affidavit of Marie St. Amand. Finally, please find a check in the amount of $85.00. Please do not hesitate to contact me with any questions or concerns. Very trul ours, Shireen T. art For the Firm STH/jg Enclosures cc: Raymond J. Belair, Administrative Officer Albert and Marie St. Amand S:\SHart\st amand\Easy Self Storage\Clerk Development.ltr.wpd MILLER, EGGLESTON & CRAMER, LTD. ATTORNEYS AT LAW 150 SOUTH CHAMPLAIN STREET P.O. BOX 1489 BURLINGTON, VERMONT 05402-1489 KATHLEEN M.BOE VICTORIA J. BROWN MATTHEW J. CARTER ANNE CRAMER JON R. EGGLESTON GARY L. FRANKLIN SHIREEN T. HART SCOT L. KLINE MARTIN K. MILLER MARK A. SAUNDERS GAIL E. WESTGATE DOUGLAS J. WOLINSKY PETER F. YOUNG COUNSEL: PATRICIA L. RICKARD NEIL WHEELWRIGHT July 24, 2000 Raymond J. Belair Administrative Officer City of South Burlington Department of Planning & Zoning 575 Dorset Street South Burlington, Vermont 05403 Re: Alleged Zoning Violation, 55 Swift Street Dear Ray. TELEPHONE (802) 864-0880 (BURLINGTON) (802) 229-2218 (MONTPELIER) TELECOPIER (802) 864-0328 (BURLINGTON) (802) 229-2513 (MONTPELIER) This office has been retained by Albert and Marie St. Amand to represent them in the above -referenced matter. We are in receipt of your letter to the St. Amands dated July 18, 2000. We are currently reviewing the matter in order to respond to the letter and/or to file a timely appeal. In the meantime, please do not hesitate to contact me with any questions or concerns. I look forward to working with you to resolve this matter. Very truly yours, Neil Wheelwright For the Firm cc: Albert and Marie St. Amand S:\SHart\st a and\Easy Self Storage\belair.ltr REQUEST FOR STAY OF ENFORCEMENT APPLICATION NO. Zoning Violation, 55 Swift Street Dated July, 18, 2000 Administrative Officer Raymond J. Belair Albert and Marie St. Amand (the "St. Amands") seek a stay of enforcement of the Notice of Violation, dated July 18, 2000, issued by Raymond J. Belair in connection with 55 Swift Street (the "Property") The St. Amands dispute that they have commenced land development on the property and seek a stay during the pendency of their appeal submitted herewith, in accordance with 24 V.S.A. § 4466. In order to comply with the mandates of the Notice, the St. Amands must remove a utility trailer, referenced in the Notice as a mobile home, from the Property. This trailer has been on Lot 55 for at least ten (10) years and appears on the Site Plan approved by the City of South Burlington. A permanent, chain link fence has been constructed around Lot 55, such that the trailer is fully contained within the fence. To remove the utility trailer, the St. Amands must permanently dismantle the trailer and incur the substantial expense of somehow disposing of the trailer. Finally, as to the other parked vehicles referenced in the Notice of Violation, they can generally be categorized in two ways. First, some of the vehicles belong to individuals who are currently out-of-state. Second, the remaining vehicles are those which are parked on the Property either during the daytime or week long (i.e. removed during the weekend). As to those individuals who are currently out-of-state, the St. Amands request a stay of enforcement because they are unable to notify these individuals that they must relocate the parked vehicles. The St. Amands do not have the authority, nor the means (i.e. the ignition key) to move these vehicles. Based on the foregoing, irremediable damages will result to the St. Amands if a stay of the enforcement of the Notice of Violation dated July 18, 2000 is not issued. WHEREFORE, Albert and Marie St. Amand respectfully request a stay of enforcement of the Notice of Violation, dated July 18, 2000. Dated this 1 st day of August, 2000. S:\SHart\st amandTasy Self Storage\Request For Stay.wpd MILLER, EGGLESTON & CRAMER, LTD. By: T /� hireen T. Hart P.O. Box 1489 Burlington, VT 05402-1489 (802) 864-0880 Attorneys for Albert and Marie St. Amand 2 AFFIDAVIT OF MARIE ST. AMAND IN SUPPORT OF REQUEST FOR STAY OF ENFORCEMENT APPLICATION NO. Zoning Violation, 55 Swift Street Dated July 18, 2000 Administrative Officer Raymond J. Belair The undersigned, Marie St. Amand, under oath, states as follows: I am one of the owners of the land and premises located at 55 Swift Street. 2. On behalf of the owners of Lot 55, I dispute that land development has been commenced as set forth in the Notice of Violation, dated July 18, 2000. 3. The Notice of Violation regarding 55 Swift Street, dated July 18, 2000, directs that, in part, a "mobile home" be removed from the "green space located between the gravel drive and the southern boundary line" of Lot 55. 4. The utility trailer, which the Notice references as a "mobile home" has been on the property for more than ten (10) years and appears on the approved Site Plan. 5. There is a permanent, chain link fence surrounding Lot 55, such that the removal of the utility trailer will require the permanent dismantling of the trailer. 6. If we must remove the trailer, then we will incur the substantial expenses of moving and disposing of the trailer. 7. Some of the parked vehicles mentioned in the Notice of Violation belong to individuals who are currently out-of-state. I do not have keys for the vehicles, and I do not have phone numbers or addresses for these individuals. We are unable to contact these individuals until they return to Burlington. If we must remove these vehicles, then we will incur significant towing expenses and storage expenses. 8. The other vehicles parked on the Property are parked there during the daytime or during the week (i.e. removed on the weekends). In order to get the owners to refrain from parking their vehicles on the Property, we will reasonably need approximately thirty (30) days. 9. If a stay of enforcement is not granted, then irremediable damages will directly result, Date based on all of the foregoing. M ie St. Amand 1 Subscribed and sworn to before me this day of August, 2000. Notary Publ' My Commission Expires: �0 p S:\SHart\st amand\E.asy Self StorageVN.St. Amand-Affidavit.wpd If "I i AFFIDAVIT OF MARIE ST. AMAND IN SUPPORT OF REQUEST FOR STAY OF ENFORCEMENT APPLICATION NO. Zoning Violation, 55 Swift Street Dated July 18, 2000 Administrative Officer Raymond J. Belair The undersigned, Marie St. Amand, under oath, states as follows: 1. I am one of the owners of the land and premises located at 55 Swift Street. 2. On behalf of the owners of Lot 55, I dispute that land development has been commenced as set forth in the Notice of Violation, dated July 18, 2000. 3. The Notice of Violation regarding 55 Swift Street, dated July 18, 2000, directs that, in part, a "mobile home" be removed from the "green space located between the gravel drive and the southern boundary line" of Lot 55. 4. The utility trailer, which the Notice references as a "mobile home" has been on the property for more than ten (10) years and appears on the approved Site Plan. 5. There is a permanent, chain link fence surrounding Lot 55, such that the removal of the utility trailer will require the permanent dismantling of the trailer. 6. If we must remove the trailer, then we will incur the substantial expenses of moving and disposing of the trailer. 7. Some of the parked vehicles mentioned in the Notice of Violation belong to individuals who are currently out-of-state. I do not have keys for the vehicles, and I do not have phone numbers or addresses for these individuals. We are unable to contact these individuals until they return to Burlington. If we must remove these vehicles, then we will incur significant towing expenses and storage expenses. 8. The other vehicles parked on the Property are parked there during the daytime or during the week (i.e. removed on the weekends). In order to get the owners to refrain from parking their vehicles on the Property, we will reasonably need approximately thirty (30) days. 9. If a stay of enforcement is not granted, then irremediable damages will directly result, based on all of the foregoing. Date f / /00 Subscribed and sworn to before me this SASHarftst amandTasy Self Storage\M.St.Amand-Afridavit.wpd � k Marie St. Amand day of August, Notary Public My Commission Expires: REQUEST FOR STAY OF ENFORCEMENT APPLICATION NO. Zoning Violation, 55 Swift Street Dated July 18, 2000 Administrative Officer Raymond J. Belair Albert and Marie St. Amand (the "St. Amands") seek a stay of enforcement of the Notice of Violation, dated July 18, 2000, issued by Raymond J. Belair in connection with 55 Swift Street (the "Property"). The St. Amands dispute that they have commenced land development on the property and seek a stay during the pendency of their appeal submitted herewith, in accordance with 24 V.S.A. In order to comply with the mandates of the Notice, the St. Amands must remove a utility trailer, referenced in the Notice as a mobile home, from the Property. This trailer has been on Lot 55 for at least ten (10) years and appears on the Site Plan approved by the City of South Burlington. A permanent, chain link fence has been constructed around Lot 55, such that the trailer is fully contained within the fence. To remove the utility trailer, the St. Amands must permanently dismantle the trailer and incur the substantial expense of somehow disposing of the trailer. Finally, as to the other parked vehicles referenced in the Notice of Violation, they can generally be categorized in two ways. First, some of the vehicles belong to individuals who are currently out-of-state. Second, the remaining vehicles are those which are parked on the Property either during the daytime or week long (i.e. removed during the weekend). As to those individuals who are currently out-of-state, the St. Amands request a stay of enforcement because they are unable to notify these individuals that they must relocate the parked vehicles. The St. Amands do not have the authority, nor the means (i.e. the ignition key) to move these vehicles. Based on the foregoing, irremediable damages will result to the St. Amands if a stay of the enforcement of the Notice of Violation dated July 18, 2000 is not issued. WHEREFORE, Albert and Marie St. Amand respectfully request a stay of enforcement of the Notice of Violation, dated July 18, 2000. Dated this 1 st day of August, 2000. S:\Sllart\st amandTasy Self Storage\Request For Stay.wpd MILLS EG ON & CRAMER, LTD. By: Shireen T. art P.O. Box 1489 Burlington, VT 05402-1489 (802) 864-0880 Attorneys for Albert and Marie St. Ainand 7 MILLER, EGGLESTON & CRAMER, LTD. ATTORNEYS AT LAW 150 SOUTH CHAMPLAIN STREET P.O. BOX 1489 BURLINGTON, VERMONT 05402-1489 KATHLEEN M. BOE VICTORIA J. BROWN MATTHEW J. CARTER ANNE CRAMER JON R. EGGLESTON GARY L. FRANKLIN SHIREEN T. HART SCOT L. KLINE MARTIN K. MILLER MARK A. SAUNDERS GAIL E. WESTGATE DOUGLAS J. WOLINSKY PETER R YOUNG COUNSEL: PATRICIA L. RICKARD NEIL WHEELWRIGHT August 1, 2000 Raymond J. Belair Administrative Officer City of South Burlington Department of Planning & Zoning 575 Dorset Street South Burlington, Vermont 05403 Re: Alleged Zoning Violation, 55 Swift Street Dear Mr. Belair: TELEPHONE (802) 864-0880 (BURLINGTON) (802) 229-2218 (MONTPELIER) TELECOPIER (802) 864.0328 (BURLINGTON) (802) 229-2513 (MONTPELIER) Enclosed herewith please find a copy of Albert and Marie St. Amand's notice of appeal to the City of South Burlington Development Review Board, along with the filing letter, Request for Stay of Enforcement and Affidavit of Marie St. Amand. The St. Amands dispute the assertion that they have commenced land development pursuant to either 24 V.S.A. § 4303(3) or Section 28.123 of the South Burlington Zoning Bylaws. Although the St. Amands have filed this notice of appeal to preserve their rights, it is our hope that we can resolve this matter to the satisfaction of the Development Review Board without the need for a hearing. To that end, the St. Amands have offered to construct a six-foot (6) stockade fence along the southern boundary of Lot 55 to shield the neighbors along the southern boundary line from the sight of the vehicles mentioned in your Notice of Violation. In the alternative, the St. Amands are willing to meet with you and/or the neighbors who have complained in order to discuss other remedial measures. Please do not hesitate to contact Neil Wheelwright or me with any questions or concerns. MILLER, EGGLESTON & CRANMR, LTD. Raymond J. Belair Administrative Officer August 1, 2000 Page 2 Again, it is the St. Amands' intention and hope to resolve this matter without resorting to a hearing. Thank you for your consideration. Ve ly yours, Sliireen T. Hart For the Firm STH/ab Enclosures cc: Albert and Marie St. Amand S:\SHart\st amand\Easy Self Storage\Belairltr2.wpd MILLER, EGGLESTON &. CRAMER, LTD. ATTORNEYS AT LAW 150 SOUTH CHAMPLAIN STREET P.O. BOX 1489 BURLINGTON, VERMONT 05402-1489 KATHLEEN M.BOE VICTORIA]. BROWN MATTHEW J. CARTER ANNE CRAMER JON R. EGGLESTON GARY L. FRANKLIN SHIREEN T. HART SCOT L. KLINE MARTIN K. MILLER MARK A. SAUNDERS GAIL E. WESTGATE DOUGLAS J. WOLINSKY PETER F. YOUNG COUNSEL: PATRICIA L. RICKARD NEIL WHEELWRIGHT August 1, 2000 Clerk of Development Review Board 575 Dorset Street South Burlington, VT 05403 Dear Sir or Madam: TELEPHONE (802) 864-0880 (BURLINGTON) (802) 229-2218 (MONTPELIER) TELECOPIER (802) 864-0328 (BURLINGTON) (802) 229-2513 (MONTPELIER) Enclosed for filing please find a City of South Burlington Application to Development Review Board re: appeal from decision of Administrative Officer. In particular, Raymond J. Belair issued a Notice of Violation regarding 55 Swift Street to Marie and Albert St. Amand. Attached to the Application is a Request for Stay of Enforcement, along with the Affidavit of Marie St. Amand. Finally, please find a check in the amount of $85.00. Please do not hesitate to contact me with any questions or concerns. Very truly yours, Shireen T. Hart For the Firm STH/jg Enclosures cc: Raymond J. Belair, Administrative Officer Albert and Marie St. Amand SASHart\st amand\Easy SeirStorage\Clerk DevelopmentAr.wpd City of South Aurlington Official Use Application to Development R.oviow Board APPLICATION # HEARINO DATE FILING DATI3 FEE AMOUNT _ Nanteofapplicant(s) Albert and Marie St. Amand Address. 61 S. Willard..St.;' Burlington. Tciopbono# ...658-6252 05401 Represented by Shireen T. Hart, Miller, EQQ1ps1 on & Cramer, Ltd. Landowner Albert and Marie St Amand Location and doscriiption of property 55 Swift Street AdJaeent property owner(c) A Addmcc Type of application check one: (Kj(q)peal from decision of Administrator Oflioer (includes appeals. from Notice of Violation) ( ) request for a conditional use ( ) request for a variance i() other request f or stay of enforcement I understand the presentation procedures required by State Law (Section 4469 of the Planning & Development Act). Also that hearings ure held twice u month (second and fourth Mondays). nut a legal advertisement must appear u minimum of fifteen (15) days prior to the hearing. I agree to pay a hoaring foe whlolt is to ofy-set the oost of hearing_ Provision of zoning ordinance in uestinn 24 V.S.A. SS4443 a 1 Section 27.10 Reason for appeal Disagree with assertion of land development Other documentation Affidavit .of.. Marie St. Amand in support o f ,.Request for.. Stay .__ . of Enforcement Date ^ SOC)'1H 13 )RLIN(7'f4N ZONING NOTICE Signature )n accordance with tic South Burlington Zoning R.cgulatiqus and Chapter 117, ThIc 24 V.S.A, the South Burlington Dcvclupincnt Rcdcw Buanl will hold a public hctuing to the South Durlingum Munlcipul Oflic:cs, Confcranc c Rouny 515 Durcct Strcct, South Durlington, Vcnnont on Tuesday, , at 7:30 P.M. to consldt,-r the following: Application of seeking a from Scction of the South Burlington Zoning Regulations. Request is for permission to