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BATCH - Supplemental - 1068 Williston Road (4)
HOLIDAY INN 1068 Williston Road Area zoned C-1 District Section 13.00 Non conforming uses and structures Section 11.00 Dimensional requirements ) Minimum side yard - 30 feet Existing easterly side yard - 22 feet Proposed easterly side yard - 15 feet Proposed addition 3,700 square feet Parking also non -conforming, subject to review and waiver by Planning Commission with new addition total spaces required 270 minimum With proposed spaces, new parking plan - 253 spaces Use is subject to traffic standards also reviewed by Planning Commission Addition and renovation to main entrance, lounge and restaurant, estimated cost $350,000 f ?5 / 7Vt 000 l�-tie gN, /qllN� 4000, 0b C, May 26, 1982 ludo �villistonRo y- South Burlington, ad 5401 Verra Dear Mr. F1elds: Be advised that , Burlington Zoning Board of Adjustment has granted your request for a zone -Lance. 7be Board will iss)rmal findings at a later date. Upon completion,of site Alan aporovai, thitice will issue a permit. if You have any r=ions please dDn't hesitate to call me. W/mcg Very truly, Richard Ward, Zoning Administrative Officer /M i :!,--� _ C� r c.�,�/ . �� t Y R -nP �..4. oz dv 3. ZONING BOARD OF ADJUSTMENT MAY 24, 1982 Mr. Dinklage asked where the line was drawn between something being a structure or not and was told that if footings or a foundation were needed, it was considered a structure. Mr. Foley said that the units were different distances from the property line, but with the deck, the closest would be 20' from the line. Mir. Guyette noted that the construction was less than 1 year old and peole were already asking for variances. He felt there had been some mis- representation here. Mr. Dinklage was concerned that if the variance were granted, the decks could eventually be turned into more living area, but I•:r. Ward said it would be in the record that the request was only for patios. Mr. Dinklage felt any request to enclose the decks would have to come back to the Board. He wanted to be sure the record was clear that these will be only decks. There was some question about whether the homeowners association, or individual unit owners should be requesting the variances, but the board was told that the association in relation to the entire development called M'indridge was here requesting the variance. The design has been approved by a the association, and all units which have decks will have the sme design. Mr. Dinklage moved that, if approved, this variance apply only to construction of open deck structures and privacy walls for recreation rurposes The motion was seconded by Ps. Guyette and carried unanimously. The appeal was granted on a 4-1 vote. ho. 4 Appeal of Harper Hotels, Inc. L.P. Fields, agent Appeal of Harper Hotels, Inc., L.M. Fields, aEent, seeking a variance from Section 13.00, Non -conforming uses and structures, extension, and Section 11.00, Dimensional requirements of the South Burlington Regulations. Request is for permission to construct an addition containing approximately 3,700 sq. ft., addition to be within fifteen (15) feet of the easterly side yard, existing structure is located to within two and one half (2.5) feet of the easterly side yard. Proposed addition is an increase to the lounge and general circulation area at the Holiday Inn, 1068 Williston Road. Mr, hard said the area was zoned Cl and that the minimum required side yard was 30'. Existing on the east is 2 112' and proposed is 15'. The parking is also non -conforming and subject to review and waiver by the Planning Commission. The required number of spaces is 270 and proposed is 253. The Commission will also consider traffic. The addition will enlarge and renovate the main entrance, lounge and restaurant, and will exceed the 25x rule. Xr. Fields said they would lose 7-10 parking spaces in front with this renovation, but they will add another parkinE lot to the rear of the building. e said that now the lounge was used for that and also for banquets. That meant that banquets could not last beyond 9 pm. 'with the addition, Yr. Fields did not feel traffic would change except between 9 pm and 10 pm. With the addition the banquet room seating will Eo from 175 to 190 and the lounge from 175-180. There will be an addition to the rear of the buildinE- for offices and expansion of restroom space. The entrance area, which has a csno, j Low, will be enclosed. Hr. :aul Graves said he owned the motel next door to t is and leaoed ti:e land around the Holiday Inn. He said tKe Inn had been a very good neighbor and that he did not op;cse the izirovement, Lut he Lai a couple cf concerns. ZONING BOARD OF ADJUSTMENT [If P IAY 24 , 1982 One concern is storm drainage from the back parking lot. Water discharge will have to go onto his property (owned by rrs. Lamplough) and he noted that the area was fragile. He was concerned about snow storage for the same reason, that it might cause erosion as it melted. He noted that the Inn was very close to the boundary line, which meant that they had to use land which was not theirs at times. He felt that with the new parking area people might walk on the Lamplough land to get around to the front of the Inn. He said he would like to deal with the issue of who is responsible for the apron around the building and for liability. He said they would like to work out an agreemer_t with the Inn for the apron and for storm water, Yr. Blais felt those issues would be better worked out at the Planning Commission than here. Mr. Fields noted that if they had to truck away the snow, they would. He said they had done so in the past. He added that they had thought about security in the back parking lot. That will be for employee and overflow parking and will be screened with a security fence 6' high, and will be lighted. Mr. P.oesler, representing Holiday Inn, noted that he was sure an agree- ment could be reached between them and Mr. Graves. He asked that a decision be made tonight, so construction could start. The appeal was granted unanimously. No. 5 Appeal of Clement Couillard Appeal of Clement Couillard seeking a variance from Section 11.00, Dimensional requirements of the South Burlington Regulations. Request is for permission to relocate a sin le family dwelling 26' x 40' with attached garage to within forty seven (475 feet of the required front located to the north of 596 Spear St. q yard, on a lot Mr. hard said the area was zoned R4 and that the minimum required setback was 75' and proposed is 47'. The lot is being considered by the Planning Commission, and the request is to relocate a single family dwelling from Burlington. The new house will be lined up with others in the area. On -site sewage disposal will be needed, and the house will have to maintain the proper setback from the stream in the rear. To go back any farther would require a variance from the stream setback. Mr. Blais noted that the hardship was created by topography and was not created by the applicant. The appeal was granted unanimously. Appeal of Peter Val Preda and Richard Collette (ta),led May 10, 1982) Yr. ward said architect Eike Dugan had submitted a revised plan with the major portion of the building lining up with the Pap,.as restaura_^.t to the south. There is a walkway proposed between the existing brick building; and the proposed 'building. Mr- Dugan showed a scale model of the building. He noted that a corner of the 'building had been removed, so Yr. Pappas would have better viei y -l;t The new building is at the same setback as the Pappas one - 601. Yr. L-uean said most of the mass of the new building was 75' from -helburne Road and that the building ;;as 155: smaller than the first design. If the water tale wiU permit it, there will be a basement. '".r. Reed said he would rather see a basement than a second story, since he felt it overpowered everything, else in that area. RICHARD A. SPOKES JAMES D. FOLEY JOSEPH F. OBUCHOWSKI STEVEN F. STITZEL Mr. Richard Ward South Burlington 575 Dorset Street South Burlington, Dear Dick: ATTORNEYS AT LAW 184 SOUTH WINOOSKI AVENUE P. O. BOX 986 BURLINGTON, VERMONT 05402-0986 June 22, 1982 City Offices VT 05401 In re: Appeal of Harper Hotels, Inc., L. M. Fields, Agent (SO2) 662-6451 (802) 863-28S7 ISAAC N. P. STOKES COUNSEL I am enclosing a copy of my transmittal letter to the Court in the above appeal. I am also enclosing copies of correspondence from Fred Allen, Esq. entering his firm's appearance for the Appellee. As we discussed, I am not entering an appearance on behalf of the City in this matter. I am also returning to you ten copies of the Notice of Appeal. Pursuant to 24 V.S.A. §4471: "Notice of the appeal shall be sent by mail to every interested person appearing and having been heard at the hearing before the board of adjustment...." Therefore, you or the Secre- tary of the Board of Adjustment should check the Minutes and mail copies to those individuals who meet the above criteria. If this creates any problems or if you encounter any mechanical difficulties, please let me know and I will try to help out. You should also make a list of the people, and their addresses who are being sent copies. Please send me a copy of this list for my files. Thanks. Very truly yours, Jos F. Obuchowski JFO/gmt Enclosures RICHARD A. SPOKES JAMES D. FOLEY JOSEPH F. OBUCHOWSKI STEVEN F. STITZEL SPOKES, FOLEY & OBUCHOWSKI ATTORNEYS AT LAW 184 SOUTH WINOOSKI AVENUE P. O. BOX 986 BURLINGTON, VERMONT 05402-0986 June 22, 1992 (802) 882-5451 (802) 883-2857 ISAAC N. P. STOKES COUNSEL Mr. Francis G. !)ee, Clerk Chittanden Superior Court P. 0. Box 187 Burlington, VT 05402-0187 In reaa Appeal of Rarper Hotels, Inc,, L. N. Fields,, avant air Frtank 2 Enclosed for filing in the above -captioned matter are l original Notice of Appeal and Pawl, Frank & Collins' check in the amount of $25, 00 for the filing lea. This is an appeal fram a decision of the South Burlington Board of Ad- justment. If you have any questions or if 1 may provide any additional information, please lot me know. Very truly your*, ,�'®seph 9`. C��auchcxl�ski J1"a®get Lnclosures cc; Peter M. Collins, Esq. Frederic W. Allen, Esq. Mr. Richard Ward DINSE, ALLEN & ERDMANN ATTORNEYS AT LAW 909 BATTERY STREET BURLINGTON, VERMONT 00402 June 11, 1982 Frank Fee, Clerk Chittenden Superior Court P.O. Box 187 Burlington, VT 05402 Re: In Re: Appeal of Harper Hotels, Inc., L.M. Field, Agent Dear Frank: Find enclosed our notice of appearance in the above captioned matter. Thank you. Very truly yours, DINSE, ALLEN & ERDMANN S/ FREDERIC W. ALLEN, DFrederic W. Allen cjd Enc. cc: Richard Spokes, Esquire✓ Peter Collins, Esquire STATE OF VERMONT CHITTENDEN COUNTY, SS IN RE: APPEAL OF HARPER ) HOTELS, INC., ) L.M. FIELDS, Agent ) SUPERIOR COURT DOCKET NO. NOTICE OF APPEARANCE NOW COMES the law firm of Dinse, Allen & Erdmann, and enters their appearance in the above captioned matter on behalf of Harper Hotels, Inc., L.M. Field,.Agent. Dated at Burlington, Vermont, this llth day of June, 1982. DINSE, ALLEN & ERDMANN S/ FREDERIC W. ALLEN Frederic W. Allen )INSE, ALLEN & ERDMANN .TTORNEYS AT LAW " ■ATTERY STREET 9LINGTON. VERMONT 08401.096E Paul, Frank & Collins, Inc. Attorneys at Law Burlington, Vermont STATE OF VERMONT CHITTENDEN COUNTY, SS. IN RE: APPEAL OF HARPER ) Chittenden Superior Court HOTELS, INC., L. M. FIELDS, ) AGENT ) Docket No. NOTICE OF APPEAL FROM DECISION OF SOUTH BURLINGTON ZONING BOARD OF ADJUSTMENT NOW COME Paul R. Graves, Walter B. Levering, Jr. and Evelyn W. Lamplough, "interested persons" as defined by 24 V.S.A. §4464, and in accordance with 24 V.S.A. §4471 et sect., appeal from the decision of the City of South Burlington Zoning Board of Adjustment, where on May 24, 1982, said Zoning Board of Adjustment granted the appeal of Harper Hotels, Inc., L.M. Fields, Agent, seeking a variance from §13.00 and §11.00 of the South Burlington Zoning Ordinano.e. Appellants are entitled to a de novo trial in the Superior Court pursuant to 24 V.S.A. §4472. Appellants base their appeal on the grounds that the decision of the South Burlington Zoning Board of Adjustment was contrary to the best evidence available, and should not have been granted under the conditions provided for in 24 V.S.A. 54468. This notice of appeal is being served upon the Chairman of the South Burlington Zoning Board of Adjustment as an appropriate officer under V.R.C.P. 74. The Chairman of the South Burlington Zoning Board of Adjustment is hereby instructed to serve notice upon all interested parties and transmit a copy of this notice of appeal directly to the Clerk of the Chittenden Superior Court in accordance with the Rules. Appellants stipulate that no transcript is required for this appeal. The record on appeal shall include any plans or other documents filed with the Board of Adjustment by Harper Hotels, Inc., L. M. Fields, Agent. Dated at South Burlington, Vermont, this _/0 10 day of June, 1982. Paul, Frank & Collins, Inc. Attorneys at Law Burlington, Vermont APPELLANTS: Paul R Craves al -ter B. Leverin , r. Cam' -; ✓ �, Evelyn W. Lamploug May 11, 1982 Mr. Lonnie Fields Holiday Inn 1068 Williston Road South Burlington, Vermont 05401 Re: Zoning hearinq Dear Mr. Fields: Be advised that the South Burlington Zoning Board of Adjustment will hold a public hearing at the City Offices, Conference Roos.+, 575 Dorset Street on Monday, May 24, 1982 at 5:00 P.M. to consider your request for a zoning variance. Please plan to attend this meeting. Very truly, Richard Ward, Zoning Administrative Officer Rw/mcg 1w,\uCil SOLITIA VcPTIJMPT-9,FTA6 ()LI-TCGT UTctjgtq mgLq bp6926 bTuu �O 944:Guq f.jIT2 IDG6�TU(3' A9T T�JJCG * 31, JaRS 94: 2:00 �O S COL COIJjT GE )�orjr- T-GCIM2�p '-:y oHM-3 .q f',nPTTc P69LTUd -IP �PG CT9?,. OETTC62v (,-Oi)EGKGUCG j-,'OUj' L)A-,) E)OL26,- 2�r-GG� ou BG SqA-"-26q W9 I: I:PG 'ng! RnrTTL'd.POu SOUTud Bc)gxq oj-vq]n29Frz;,U.P MTTT POTq 9 3P DGUL VX- LTGTq2: b-6 : ;�OUTJJd PG9LTUd Ponp ro"ruji(apoul 11Emloup 0210l TOQ8 MITTTT2.POIJ I�ogq 110TT(pA JULY AIl* I'OUUTG LTGT92 !,Ph TV TaSS SOUTH BURLINGTON. ZONING In OCE ccordance with the So linoton Zoning R ftle South Bvr- Cnopter. 117, Regulation. and Sovih Burlington)Zon n, B.A. the e 24 Adjustment will hold a ardlic Municheari�ipol the South C. rlington Offices' Conference Room. 57l Dorset Street, South Burlington, Vermont On Monday, MOV 24, 1982, at 5.00 P.M. f0 con- sider the tollow)ng; " I. Appeall of Gerald-DlVinconzo seeking o variance, from Section ll.M, Dimensional requirement of the SRoecoaoum Burlington Regulations. nest 1 tar cermission to re- twente 11 IS'x27' garage to within rear, -five f25) feet Me required rear, yard 21 A. peal 9 Wpoticrest Drive. - of Yfng ontl Liu sJosephine 11, a voriarKe, from Sec. 'lionll.Op, Dimensional require. menh and Seri ion 11.25 of the South ion Regulations. Re - west fs for permission to sfruct o mulii.lomily con - dwelling unit t0 within ore nundred and forty (140) feet Of Interstate 89 and O second dwelling unit to within equired sixty-nine (69) feet 01 the r Irons vord, of 701 Dorset Sirle}_ 3. ADOeal of Windridpe Ho Owners AssociOme- )ion,.GM010 John. me. son, ogerd seeking a variance. from Serti,s 11.00, Dimensions ensios requirements Of the South Burling. ton Regulations. Request is for permission to construct a 10x15' deck to within twenty (20) feet of the required reor Yard, Of units 1, 2. Ond 3. Windridge, 175 Kennedy Drive. 4. Appeals of Harper NOtls. Inc, f l.M. Field, agent seeking varl- formi from SectiOn 13.00, Non -con- forming " structures ex- t tension, Sectional) S00 dimes Or X. I requirements Of si tAe South Burling. Permission bons. Request is for Permission t0 construct On oddi. tion containing ODar Oximately 3.700 square feet, addition to be within fifteen (15) feet ofside easterly toted totl' existing structure is Io- withe two and one half f 2.5) feet of the easterly side Proposed otldition is an incr%se 11 ittp lou tion nge and general circulo- oreq dl t illiston RoOtl. he HOlidov Inn, ]OMB W S. Appeal Of Clement Couillord seeking ennlham Sect, Dmswo� on OI the South eouirements Burlington R lotions. Rteequest is for Permission to relocaO single 1Omlly dwell- ing 26'x/O' with attached pprgOe to within lorty seven (47) feel of the required front Vora, on a lot lo- ot toted to the norm of 596 Spear Street. Zoning AdministrativeRicho Word. I May 8, 1962 O CITY OF SOUTH BURLINGTON PERMIT NO ,st. Copy CODE OFFICER APPLICATION FOR ZONING PERMIT Zone. /... 2nd. Copy CITY ENGINEER 3rd. Copy CITY ASSESSOR 4th Copy APPLICANT Date ............................................ l ...... The undersigned hereby applies for permission to make certain building Improvements as described below. (Plans to be submitted If required by Building Inspector.) All construction to be completed In accordance with the Zoning Laws and Building Regulations of the City of South Burlington and the State of Vermont, and con- form to the Regulations of the National Board of Fire Underwriters and any and all Federal Regulations now in effect. ■■■Nova© ■��■■■■■�� -sue . - ■L ONE ■�■■■MEN mum ONE ■L ONE ■■■= • . • .. ::. .. . �■■■oo©© .' �■■■� .:....::::....: ■ice■■■S■ ■■■■■■■■■■■■■ INN ■■■■■■■■■■■■■■■■■■■.■■ ENO �- -......................�.. ■ ■■■� MINN ■■■■■■■■■�■■■�■■��■■■■■■■■■■■■■■■■■MNc �■ ■ ■■■� NO■■ NONE ■■■■■1■■ ■■■■■■■■■■■■■■■■■■■■■■■Eh.,ai■■ INNONE■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■■■■■■■■■..■ ■■■■■■i :: ■� ■ MEMO ■■■■■■■■■■■■ ■■ ■■■■■■■■■■■■■■■■■■■■■■■ = ■MESS ■■■■■■■_■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ NOON■■ NOON■ ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ i ■■■■■■■:■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■SEEMS MON ■SEEN ■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■ .■NM■MNEM■■MMi■■M■M■M MNMM■M■■M■MM■NMMMMMENEM■ •.. ENE ■NINE ..■■ :• ■■ ENE N■■■■ .......■�■..�■■■■■■■_■■■■■■■■ IN MEMO ■E,■■,■■■■ ■■■_=■■■■C■■■■=■■■■■_■■■■■■■■■■■■■■■■■■i■■■■■■ ■■■ .■■■■■■■■ NOON■ ■■�■■■■■■■■■■■■■■■■■■■■■■ ■MEMO ■■■■■■■.■■■■■■■■■■ ■■■■■■.■■■■■■■■■■■■■■■ ■-i .■■■■■■......■. ME■M■MM■N■MMM■■.......MEE ■� ■■■■■■■■■.■■.��°MEN ■■■■..■■■■■■■■■■■■■ M■■ ........■■.. .. M ■ .■...■■■■■■■■■■..MEN C =�= '.: E:■ :::::::::::::::::::N ■ .■ C:9�89EN ...■■■■..■■■...E....■■NINE■ME■N EM■O■■■■■MO■■■■ .....■■■MMMMM■■INN■ONE ■ ........■■■MMMM■■MNONE . ME moss ■...■ ..■■■ .................■. ■'■■■■■■..■■..■EENNN■O=■= ■■MMEN■E■■■■■■EMME■N■ ■ M■ OM■■O■■O ■ O■M■M■■■ . .................... ■■■■■■■i■■■■■MEN ■■■n■■■■■■■■■■■■■■■ moms ■■ ■ ■ a SIGNATURE of OWNER or BUILDER / ADDRESS of OWNER APPLICATION: REJECTED ❑ APPROVED _ --- --7� SIGNATURE OF CODE OFFICER ISSUED TO nntP _ !l 19 O L_--- FORM A-35—Subpoena WAULIFFE PAPER CO., �s�idla,.�'+- i1stic• d!'S ., � %�Liiiil!'�.k ��.� r�A.;�.„, t�ef V�exrt�rrt. Chittenden' f; County, ss. To any Sheriff or Constable in the State, or to ---------._ an indifferent person. _ 4�$ GREETING: 'NU t4v Aut4ority of the State of Vrrn wnt, You are hereby commanded to summon Richard Ward of South Burlington, Vermont to appearkV, at a deposition to be taken by - Attorney Peter M. Collins, at the South Burlington City Municipal Building on the 8 th day of October A. D., 1982 at One o'clock in theafternoon, to give evidence of what you know relating to an action or plea then and there to be heard and tried between In Re: Harper Hotels, Inc./Appeal dfA.fX , aNd of Decision of South Burlington ZoningDWfxxdxxr, Board of Ad; ust nt this they may not om�t, ascot ey will answer their default under the pains and penalties of the law in that behalf made and provided. FAIL NOT, but make service and return according to law. Dated at Burlington in said County, this 1st day of October A. D., 19 82. PAUL, FRANK & COLLINS, INC. By- Peter M. Collins yir`••r, it G.. °.. .2!` .+}w1 ki Cf •'+,.i.ylc. A.,.. s fit{ � 'L '`i..'Aks...ka.+w ti a. e+•i:r,r vw"tea• STATE OF VERMONT CHITTENDEN COUNTY, SS. In Re: Harper Hotels, Inc./ ) Appeal of Decision of ) South Burlington Zoning) Board of Adjustment ) Chittenden Superior Court Docket No. NOTICE TO TAKE DEPOSITION To: Richard R. Ward 1775 Dorset Street South Burlington, VT 05401 Please take notice that at 1:00 p.m. on the 8th day of October, 1982 in your office at the City of South Burlington Municipal Building, South Burlington, Vermont, the appellant in the above matter will take the deposition of Richard R. Ward upon oral examination, before a notary public, or before some other officer authorized by law to administer oath. You are invited to attend and cross-examine. Dated at Burlington, Vermont this lst day of October, 1 1982. 'aul, Frank & Collins, Inc. I Attorneys at I.aw Burlington, Vermont PAUL, FRANK & COLLINS, INC. BY Peter M. Collins CHITTENDEN COUNTY SHERIFF'S DEPARTMENT P.O. Box 1042 Burlington, Vermont 05402 On the day of documents upon ( ) Summons ( ) Summons to Trustee ( ) Affidavit ( ) Writ of Attachment ( ) Final Order ( ) Temporary Order ( ) Restraining Order ( ) Attorney's Certificate ( ) Motion ( ) Petition RETURN OF SERVICE , 19 I made service of the following ( ) Complaint ( ) Interrogatories ( ) Exhibit ( ) Writ of Possession ( ) Judgement Order ( ) Order of Approval ( ) Memorandum of Law ( ) Notice ( ) Notion (. ) Subpoena by delivering a copy of same to a person of suitable age and discretion and then a resident at the usual place of abode of said defendant at , Vermont, (for each of them) a oopy thereof with my return endorsed thereon. Service $ Travel ( miles) Postaqe Copying Sheriff/Deputy Sheriff Town Clerk Notary Fee Other _ c- TOTAL $ A True Copy Attest PAU L, FRANK & COLLINS, INc. ATTORNEYS AT LAW R ALLAN PAUL JOSEPH E FRANK FAIRCHILD SQUARE PETER COLLINS JOHN T SARTORARTORC 110 MAIN STREET B MICHAEL FRYE P. O, Box 527 ANTHONY 8 LAMB , ALAN 0 PORT BURLINGTON, VERMONT 05402-0527 ROBERT G CAIN S. CROCKER BENNETT, 11 MARY ELLEN CLERKIN June 10, 1982 ROBCRT S. DIPALMA Everett J. Reed, Chairman South Burlington Zoning Board of Adjustment South Burlington, Vermont 05401 ti Re: Notice of Appeal by Paul R. Graves, Walter B. Levering, Jr., and Evelyn W. Lamplough Dear Mr. Reed: TELEPHONE 058-2311 AREA COOL 602 REPLY TO: P. O. BOX 527 In accordance with 24 V.S.A. §4471 et se q., §4472 and V.R.C.P. 74, I hereby serve upon you, original and ten copies of our notice of appeal to the Chittenden Superior Court. I have also enclosed our firm check in the amount of $25 payable to the Chittenden Superior Court. Under the Vermont Rules of Civil Procedure, you are instructed to transmit a copy of this notice of appeal, together with the check for $25 to the clerk of the Chittenden Superior Court forthwith. You are further instructed to send copies of the notice of appeal to every interested person appearing and having been heard at the hearing. You should further instruct the clerk of the Zoning Board of Adjustment to transmit the record on appeal to the clerk of the Chittenden Superior Court forthwith. I am sending a copy of this notice of appeal and correspondence to Attorney Robert Roesler, who appears for Harper Hotels, Inc., to Attorney Richard Spokes, as the City Attorney, and a copy to the clerk of the Chittenden Superior Court. Cordially yours, PA FRANK COLLINS, INC. U eter M. Collins PMC:srm Enc. A M Paul, Frank & Collins, Inc. Attorneys at Law Burlington, Vermont STATE OF VERMONT CHITTENDEN COUNTY, SS. IN RE: APPEAL OF HARPER ) Chittenden Superior Court HOTELS, INC., L. M. FIELDS, ) AGENT ) Docket No. NOTICE OF APPEAL FROM DECISION OF SOUTH BURLINGTON ZONING BOARD OF ADJUSTMENT NOW COME Paul R. Graves, Walter B. Levering, Jr. and Evelyn W. Lamplough, "interested persons" as defined by 24 V.S.A. 54464, and in accordance with 24 V.S.A. §4471 et seq., appeal from the decision of the City of South Burlington Zoning Board of Adjustment, where on May 24, 1982, said Zoning Board of Adjustment granted the appeal of Harper Hotels, Inc., L.M. Fields, Agent, seeking a variance from §13.00 and §11.00 of the South Burlington Zoning Ordinance. Appellants are entitled to a de novo trial in the Superior Court pursuant to 24 V.S.A. §4472. Appellants base their appeal on the grounds that the decision of the South Burlington Zoning Board of Adjustment was contrary to the best evidence available, and should not have been granted under the conditions provided for in 24 V.S.A. §4468. This notice of appeal is being served upon the Chairman of the South Burlington Zoning Board of Adjustment as an appropriate officer under V.R.C.P. 74. The Chairman of the South Burlington Zoning Board of Adjustment is hereby instructed to serve notice upon all interested parties and transmit a copy of this notice of appeal directly to the Clerk of the Chittenden Superior Court in accordance with the Rules. Appellants stipulate that no transcript is required for this appeal. The record on appeal shall include any plans or other documents filed with the Board of Adjustment by Harper Hotels, Inc., L. M. Fields, Agent. Dated at South Burlington, Vermont, this I day of. June, 1982. Paul, Frank & Collins, Inc. Attorneys at Law Burlington, Vermont APPELLANTS: Paul R Craves \ \ . c" \ \ J Wa er B. Leverin , r. yn W. Lamplough ' ;) State of Vermont :.� +. Department of Fish and Game Department of Forests, Parks, and Recreation Department of Water Resources Division of Environmental Engineering Division of Environmental Protection Natural Resources Conservation Council Harper Hotels/Holiday Inn Lonnie Field General Manager Rt. 2 So. Burlington, VT 05401 Dear Mr. Field: AGENCY OF ENVIRONMENTAL CONSERVATION DIVISION OF PROTECTION Ill West Street Essex Junction, VT 05452 Telephone: 879-6563 May 26, 1982 RE: 3700 S.F. addition (PB-4-0716) On behalf of the Division of Protection of the Agency of Environ- mental Conservation, I acknowledge receipt of the application for addition of 3700 SF to the existing commercial building (representing 10±% increase) for additional meeting rooms and remodeling. Project is on municipal water and sewers. Located on North side of Route 2 just east of I-89, South Burlington, Vermont. If you have not already done so, you should check with town offi- cials regarding any local requirements that you may need to meet. Meanwhile, if you have any questions, do not hesitate to contact this office at the phone/address above. FOR THE DIVISION OF PROTECTION Ernest P. Christianson, Regional Engineer CC: Town Planning Commission This letter fulfills the notice requirements of 18 V.S.A., §1218.