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269787 WHITE - CI TV CLERK - � . -f��`1) PINK - FINANCE� T7 �t`j CANARV - DEPARTMENT G I TY OF SA7 NT PA V L COL1I1C1I � <l• EiLUE�� t MAVOR � � � � . Fll@ NO. , uncil Resolution Presented By � Referred To Committee: Date Out of Committ� By Date WHEREAS, on March 10, 1977, the City of Saint Paul issued Building Permit No. 029872 to The Green Mill Inn, Inc. , of 57 Hamline Avenue South, to construct a parking lot on the North side of Grand Avenue between Hamline Avenue and Albert Street on Lot 24, Block l, �ir�Tann' s Addition; and WI�REAS, Gerald Sullivan and William Bartelheim, owners of adjacent residential property (Lots 23 and 25, Block 1, Wann' s Ad- dition) , pursuant to Section 64.203 of the Saint Paul Legislative Code, appealed for administrative review to the Board of Zoning .� Appeals which, after hearing, found that the City' s permit was prop- erly issued in accordance with the procedure specified in Section 62.108 and, therefore, denied the appeal; and WI�REAS, Gerald Sullivan and William Bartelheim, pursuant to Section 64.204 has appealed the decision of the Board of Zoning Appeals to the Council of the City of Saint Paul; and WHEREAS, the City Council held a public hearing on August 16, 1977, at which all interested parties were heard; now, therefore, be it RESOLVED, That the Council of the City of Saint Paul hereby finds, determines, and declares, based on the record, that the City' s permit was properly issued in accordance with the procedures and re- quirements of Sections 62.103, 62.104 and 62.108 of the Legislative Code; and be it COUNCILMEN Requested by Department of: Yeas Nays Butler Hozza In Favor Hunt Levine __ Against BY Roedler Sylvester Tedesco Adopted by Council: Date Form Approved by City Attorney Certified Passed by Council Secretary BY B}� Approved by iVlayor: Date Approved by Mayor for Submission to Council By BY `NHITE - CITV CLERK PINK - FINANCE GITY OF SAINT PAITL Council �� CANARV - DEPARTMENT f � � � bLUE. ,�- MAVOR � � Fll@ NO. Council Resolution Presented By Referred To " Committee: Date Out of Committee By Date 2. FURTHER RESOLVED, That the appeal of Gerald Sullivan and William Bartelheim be denied; and be it FINALLY RESOLVED, That this decision be eommunicated to the Zoning Administrator for any necessary enforcement proceedings. COUNCILMEN Requested by Department of: Yeas Nays � Butlerr Hozza [n Favor Hunt —�„� Levine-- __ Against BY Roedler Sylvester '�ec�cc° 19� Adopted by ncil: Date S�p 2 � Form Approved by City Attorney Cer ed Pas Coun �l Secret� BY� �^r"LX v SEP 2�! 1977. Approved by Mayor for Submission to Council Appr by �1�layor: Da � � By � � By PUBLISHED SEP 2 4 t977 � I i , - � � �� . ; , , � , � , , : � - \ � , , , . ' - September 27. i977 � � � . . . . . � � � . .1 . . . . . , � . . � . . . . . . 1 M�. G1Pnn Ericksan Mr. Peter Re��ie�r � Su��v�.sor of Ccxtc� Fnforcc�ment ; Attorney at Ls+�r — Room 1►ts5, City Ha].1 1�5�3 i�orthem �'eelsral. Bldg. _ St. PauL, Mirnkssota St. Pa�l, Minnasota , . � , • Pianning Cc�anZssicm � Mr. RQger CYiristiansorr &s�r.d oP Zo�iag 'Appeals 4I8 Co�zce �1dg. Gr�e Building . St. Paul, M3n�t�aoCa St. Patiil, Minrte�ota � . � Aear C��'Lxtlemen� � ' I here�oith tr��smi.t to you a copq of. a r�salution of t�e St. PauL'City Cotmcil, C.P. 269?��, adopted S�ter.��r 2Ci, I�77 den3'�S �e gPPeal of _ Ger�].d 3ullip�srt snd tJilliem Earte,lhsim to a decision of .t�:e �oara o� � Zoning A�p�a1s aP�icting the a�plication of the t�e�a Mill Imn.; Inc. to � ; conets�uct s� par�cing 2or;on the �orth side af Grand Avanue 'bet+re�n Ha�m].ine � A�nue rind Albe�s�t Street. ' , � , , 9ery Cruly ,your�, � � Cit� Clerk . Attach. , � ABO:dcr ; � � � '. � ' ea: Mr. Uonald C. Willeka � Attor�ney at Law � 3$Ch F'loor, I� C�ntar Him�sspolis, Minnasota � � _ � ~ . - � , . , , : . .. � � , . , �� , LAW OFFICES OF JARDINE, LOGAN & O'BRIEN DONALD M.JARDINE 1350 NORTHERN PEDERAL BUILDING JOHN M.KENNEDY,JR. JERRE F.LOGAN WABASHA AT 6TH EUGENE J.FLICK 70HN R O'BRIEN ST.PAUL,MINN. 55102 RICHARD T.DOLEZAL GRAHAM HEIKES CHARLES E.GILLIN GERALD M.LINNIHAN (6�2) 22�-060 t JAMES J.GALMAN ALAN R.VANASEK PIERRE N.REGNIER September 8, 1977 MARKA.FONKEN GERALD E.WALLIN PATRICK M.FLYNN LOUIS R.TILTON Members Of $t. Paul Ci ty Counci 1 KENT E.CHARPENTIER c/o St. Paul City Clerk 386 City Hall and Courthouse ROBERTJ.TYRRELL St. Paul , Minnesota 55102 ofcoun�l RE: Administrative Review of Building Permit No. 029872 Our File M 5319 All of the Members of the City Council : As you are aware, Section 64.206 of the St. Paul City Zoning Ordinance provides that all final decisions by the City Council in matters involving administrative review shall be in the form of a written resolution. The appeal of the above matter involved numerous issues in which findings had to be made by the St. Paul City Council . Before I can adequately advise my client as to any possible appeal to the Ramsey County District Court as provided for in Section 64.206 of the St. Paul City Zoning Ordinance, I will have to review the resolution passed by the St. Paul City Council in this matter. I realize that a voice vote was taken in this matter but it is my understanding that a written resolution has never been passed by the City Council in this matter. I would respectfully request that a written resolution be acted upon in this matter as soon as possible. At page 3 of the Memorandum of Law presented by the attorney for the Green Mill , Inc. addressed to the Board of Appeals, the understanding between my clients and the Green Mill , Inc. is spelled out wherein he states "The Green Mill Inn has been seeking to accommodate where possible the wishes of its neighbors so it voluntarily ceased work on the lot pending the outcome of this appeal ; work will not resume without 24 hours prior notice to appellants' attorney." Until a resolution is passed by the City Council , the outcome of this appeal is still pending. However, contrary to this agreement between the parties, the Green Mill Inn, Inc. has gone ahead with construction of this parking lot. You must, therefore, realize the urgency of the passage of a resolution as soon as possible so as not to jeopardize the rights of the appellants in this matter. Any consideration as to whether the decision of the City Council should be appealed is premature at this time until a written resolution is passed by the City Council and served upon the appellants pursuant to Section 64.206 of the St. Paul City Zoning Ordinance. I would respectfully request that a copy r; � ZOti55 NW `s<<od�auu�W ,�a�ua� SaI `aool� u�8� Me� �.�e �fauao��.y a�alL�M '� pleuoa :�� u�/2fNd aa�u6aa •N aaaa� , L�.��Y N3I�8�0 '8 N11901 `3NIabtIC ��f�na�. sano� •pays��qnd pu�e pass�d s t �� se uoos s� aw uodn panaas aq uo��n�osaa �.ey� �.o LL6L `8 aaqwa�das Z a6�d t��uno� �'�.t� lnpd '�S ' . . ., � -• » ` ! � ��" �'�7�'ju S/ � . � � O' CON NOR 5� HAN NAN � - • ATTORNEYS AT LAW PATRIG1t J.O�CONNOR " ' � � � ' � � -- ' �' ' " � �747 PENNSYLYANIA AVE.N.W,� 1�REDERICK W.THOMAS � � yypSMINGTON.D.C.20006 �OLn.wa�TeRS ' THIRTY-EIGHTH FLOOR. I DS TOWER THOMASA.KEILERIIC 80 SOUTH EIGHTH STREET �Z�Z�7B5-B700 MICMAEL E.;MCGUIRE KENNETi+ B.JONES.�R:�� • • MINNEAPOLIS,MIN•NE-S��'PA� 55402 � � _ wi�u��+�r.H NNAN*R' � � � ROBERTJ.CMRISTIANSON,�JR. • � � • JOF�NJ.•rIYNN . . CNARLES B.FAE6R[ H.ROB6RT HAI.PEp• FRANK J.M�AL2 (6�2) 341-3800 JOSEPN C.DItLON JOHIV W.ROGERS TMOMA$ M.QUINN* DONALD G.W�LLEKE � � TELEX 29-0$84 HOWARO 6.FELDMAN+ JAMES R.DORSEY TEIECOPIER 612 34t-380O(256I � DAVID R.MELINCOFF• ANDREw J.SHEA � DEI.ANCCY W.OAVIB• DOUGLAS M,MGMILLAN - . RICMARQ O. MOR6AN CMARLES O.REITE PHIUP R.HOCMBERG* � WILUAM R.MCGRANN .qpUSTIN LOSADA�* OAVID BURUNaAME• TMOMAS V.VAKERICS• WALTER C.PARKINS OOUGLA4 M,CAfiNIVAL• MIGHAEI M.WHALEN ABOGA00 MARTIN M,BERIINER• TERENCL V.BOYLE* � K[NT E.RICMEY . ALFONSO XI1.42 �710 SEGURtTY LI�E BLGO. MOPE S.FO$TEQ* JOMN J.SOMMERVILLE MADf71D 14,SPAIN OENVER�COIORADO 80202 DRIAN P.PMELAN• JAME9 A.RUBENSTHIN MICMAELJ.CONION• NANCY F,FOWLER (�i)228-1205 (303)673-7737 . MICM4EL PATRICK pEORGE CMARlE3 T. NIXON � -DONALD B.ARBOUR• JEREMIAH J. KEARNEY � LAWRCNCE A,JONE$• JOHN B.BLATZ I¢ WILLIAMC.KELLYU918-1070) � 9 .SePtellWQ];. 19.�/ . ftAIPMF,DERLOw1�G23-t972) OF COUN$CL JOSEPM F.CA3TIELLO+ . FRED O.THOMP$ON� �JAMES D. McKE�e1TT• � � � � � •NOT M[MS[P 0I MIMM[90TA oAN Pierre N. Regnier 1350 Nor.th .Federal Building Wabasha at Sixth � St. Paul, Minnesota . 55102 Re: The Green Mi11 Inn, Inc. Our File No. 10,449-001 Dear Sir: I am in receipt of a copy of your letter of September 8, 1977, to the Members of .the St. Paul City Council. I must respectfully disagree in the strongest terms po�sible with your allegation that The Green� Mill Inn, Inc. or the undersigned, their counsel, ever agreed to _ suspend work at any period past .the date when the City Council took action on your client's appeal. I was p.resent in .the Chambers of the St. Paul City Council at approximately 10:45 A.M. , CDST, on Tuesday, August 16th, 1977, when the City Council voted, four votes in favor and three votes against, to deny the appeal brought by your clients. The action The Green Mill Inn, Inc. in building its parking lot after that date is not in violation of any� agreement with you or .your clierits since the "outcome of this� appeal" to .the City Council was clearly decided on and as of that date, and any agreement concerning ceasing work was at an end .the moment� the outcome was decided. That is precisely why I used the word ."outcome. ° '- t'" � y � . , : t a�zx. �g .a�x�nzz�a . a�inbs� 'uosuei�.st.zq� .zabog •�uI �uuI Z T.z y� uaa,z� acty Xsaja ��.i� Zn2d '�S o/� Z-r�uno� ��z� Tn�d '�S au� �o s.zaquiay�i/1 :�� / �"�t u/M�Q a�TTTM '� Pt�uoa , J -��.a 's.zno� •pa�.�uiw�za�. si �a��o a� ��. pas-rap� aq as2atd ��ITbut -pzooa� •s�.uatZ� �no� .zo no�I �uo�� pania�az uaaq spu �Zda.z ou pu� '�a��o ��q�. �o a�.�p au�. a�uts pass�d an�u sq�.uoui aaau� �T��x� •paut��.qo aq ptno� a�u�iz�n a�.�T�do�dd� uE papino.zd ��.-r� au� �q pa��.iuuad �T�.uasaxd �.�u�. ueq�. a�ua� .zaubiq � pZinq o� s�.uazT� �no� o�. •�uI 'uuI Tt.iys uaa.z� aqs �q za��o u� buiu.za�uo� no1� o� a�.o.zM I 'LLfit ' 6 aunr up •uoi�.ua�.�E sa.zznba.z �a�.��u .zau�.an� aup LL 6T aaq�ua�.dag 6 -Z- ab�a � .zazubag •N a.x�aia - _ �� ; . - WHITE� - C�TV CLERK PINK - FINANCE G.I T�Y O F SA I N.T PA U L . Counc.il � � CANARV - DEPARTMEfJT 1 � � BLUE - MAVOR . Flle NO• � - ncil Resolution Presented By � � � Referred To - Committee: Date Out of Committee By Date WHEREAS, on Mar 10, 1977, the City of Saint Paul issued � Building Permit No. 0 872 to The Green Mill Inn, Inc. , of 57 Hamline Avenue South, t construct a parking lot on the North side of Grand Avenue bet een Hamline Avenue and Albert Street on Lot 24, Block l, Wann' s-A dition; and WHEREAS, Gerald Sulliv n and William Bartelheim, owners of adjacent residential propert (Lots 23 and 25, Block 1, VJann' s Addition) , pursuant to Sectio 64.203 of the Saint Paul Legislative Code, appealed for administrat 've review to the Board of Zoning Appeals which, after hearing, f und that the City' s permit was properly issued in accordance wi h the procedure specified in Section 62.108 and, therefore, de ied the appeal; and WHEREAS, Ger��d Sullivan and W lliam Bartelheim, pursuant to Section 64.204 has appealed the deci 'on of the Board of Zoning Appeals to the Council of the City of aint Paul; and WHEREAS, the City Council held a p lic hearing on August 16, 1977, at which all interested parties we heard; now, therefore, be it RESOLVED, That the Council of the City f Saint Paul hereby finds, determines, and declares, based on th record, that the City' s permit was properly issued in accordan with the procedures of Section 62.108 of the Legislative Code; and e it FURTHER RESOLVED, that the appeal of Gerald ullivan and William Bartelheim be denied; and be it COUNCILMEN Requested by Department of: Yeas Nays Butler Hozza In Favor Hunt Levine . __ Against BY Roedler Sylvester Tedesco Form Approved by City Attorney Adopted by Council: Date Certified Passed by Council Secretary BY D By Approved by Mayor: Date Approved by Mayor for Submission to Coancil BY BY I WHITE - CITV CLERK � PINK - FIN�ANCE � COl1flC11 CANARV - DEP TMENT GITY � OF SAINT PALTL File � NO. BLUE - MAVO Council Resolution Presented By Referred To Committee: Date Out of Committee By Date 2. FINALLY RESOL , that this decision be communicated to the Zonirig Admi�nistrator or any necessary enforcement proceedings. � � • \ ; COUNC[LMEN Requested by Department of: Yeas Nays Butler ' Hozza In Favor Hunt Levine _ Against BY Roedler Sylvester Tedesco Form Approved by City Attorney Adopted by Council: Date Certified Passed by Council Secretary BY By Approved by Mayor: Date Approved by Mayor for Submission to Councii � By By :. . „f. .. .., . . . . ��..-. � .. .,. . .. ., . .:, . ... .,. . , _ ,-j. , .._,. � ..... � , • . . . `'. . � . . . . . . � ' .. , , 3 k, � . . i' . . . � . . . . � - � . ' .' .\ . . _ . � �.Y; . • . . � , . . , 1 `� �; /�' . . , . ' . ' .. . . � ! . . � �1 i .- ' � . � .� � . .. • . .. - �..�� F, i, / � � h . . . � . . % � . . , . , . . . . .._ ( k.. 4, . . , a � - , �w . , -. � I `��. , - ` . , � : ' • / _ : � , . . \ .._ ' . . .. • .. . � , - l - ' � . .. 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( �.. 1 � . j .'� r � 8Mi!' �M�i X+1A��t , . _- �M�C�t�' �a�3.�tEl�tsp 'V�'�,, ,�O �r ts4i, 8�a�, !�#' �[�t� �i,��'�a: + x� � ' 1i��..Hd�1cwlh�ti� �o a oa � � ` � �� ' 13�e &�s'td.o! � �d . � � � � � � � � ' = F�.l�t-+�►l�es+�toa. �o! � �'�a��.11;� �b�ir �v ` o!'. , ' , � � �� A�l.'y!��iM'�.�. ��' �� '��' ,�';a ' �� A�.bet� L'tb�rt� ,�rd �S�dl�mr. ' �R� 1�R�< �� tA�r,��wl. z�ralutiom a�#is�ing �i� ab�le�. �*� ; ,� , � 4 � . 4 . . ...� � : - �I ' , . . ` ,_ � � � . �r�.s�r. �ycu7.y �a, �: 3 ` , ' - . � � � \ . i , Gtt�► t3l.�!!� � ' � , � � . , � . . ', A��+� _ - - � j � � s �y � , , , - � , ; . � �t� �Fl�o��ag 8�a!'�!z Lo�o� �t#aet ' . � , f� . 1�� _ , � .. : ,, 1 � l�t. �1�em 8�c'1�1Uw�� #l�jr 11�bl.t�iII ,� ; a . ;_ , ; , : � , , -. , , � , . .: i � � �, , / ; �, > : . r: . . � R :� , . . . :i,� : . .. . . . ., . .- ..` . .�: _ ;� . . .. ... , � .. . .. . -� - .,;.. .. . . � � . . � � . . . . . � � .. �. . . _ , � - - 5 . . ' ' .. . .. ,- . , . � - j � . � # � ' . � . . � � . � . . � , .. � � . .. �.�� .. . � � �� - - . . � �t ,. . . � /.�' _,. ,! 3 I `� ' { �: / - - � ` � � . . ' �� ' . � � �� . . . - � -. _ _ ' a �at � . , � . �' �� -� � . - . . . . � r� � � �, � s�e , , , ,� ;, . , � , , s . ,, ,- . . p..,,.- • :�, . � .. y... �-.. I.�. L.� , . ►� � � BOARD OF ZONING � CITY OF SAINT PAUL OFFICE OF THE MAYOR - CITY PLANNING � DONALD L. SPAID AIP August 3, 1977 PLANNING COORDINATOR Rose Mix, City Clerk 386 City Hall & Court House St. Paul , Minn. 55]02 Dear Madam: This is written in response to the appeal of Messrs. Sullivan and Bartelheim from the decision of the St. Paul Board of Zoning Appeals, rendered June 7, 1977, pursuant to the issuance of a building permit to construct a parking facility issued to the Green Mill Inn, Inc. May 3, 1977. On January 31 , 1977 plans were received by the Planning Staff for construction of a � - •'-�-• F^r +hp Green Mill Inn, Inc. on Lot 24, Block 1 , Wanns Addition, City ' res then in operation, the plans were reviewed lice Department, the Assistant Fire Chief, ineer, Sewer Engineer, and ��fice Engineer, � ding Code Enforcement. Subsequent to these , �, the developer. m eceived by the Planning Staff. These plans with the request for revisions, found to -� .aff and the Traffic Engineer. Subsequent to � o �ent to the Green Mill Inn, Inc. , the Building �, � �he Department of Public Works, according � / �, tractors for the Green Mill Inn, Inc. picked , � ,n May 4, 1977 construction was halted under ^ o �a � o r / � nhe appellants to allow for an Appeal To � N o �so on May 4th, Messrs. Sullivan and Bartelheim � � � � � � � � a � � ing Appeals on June 7 , 1977 and was denied by � y of Zoning Appeals hesolution dated June 21 , 1977. v � rved by mail on the appellants on June 28, 1977. � �rtelheim filed the current appeal with the � � re the City Council on August 4, 1977. Attached w is a copy of: � � �esolution dated June 21 , 1977. � ' report dated June 7, 1977. Board of Zoning Appeals meeting. ' ,�c�-v�� - - (/�Char7es L. McGuire Principal Planner CLMcG/gf 421 Wabasha Street, Saint Paul, Minnesota 55102 (612)-298-4151 0 , ' , " `r . • . . � , _�:`� _►,�t,�i�; , . � city of saint paul board of zoning appeals resolution zoning file number 8144 � �ale _— J�ane 21 , 1917 WHEREAS, on March 10, 1977 the City of Saint Paul issued a parking lot permit to the Green Mill Inn, Inc. of 57 Hamline Avenue South, fo1r proper�y on the north side of Grand Avenue between Hamline and Albert (Lot 24, Block l , Wann's Addition�, and, WHEREAS, Gerald Sullivan and William Bartelheim, owners of ad�acent residential property (Lots 23 and 25, Block 1 , Wann's Addition), have applied for appeal to an Administrative Order under the provisions of Chapter 64 Sections 205a and 206, and WHEREAS, the Saint Paul Board of Zoning Appeals conducted a public hearing on June 7, 1977 pursuant to said appeal in accordance with th� requirements of Section 64.203a of the Saint Paul Legislative Code, and � WNEREAS, the Saint Paul Board of Zoning Appeals, based upon evidence presented at the public hearing, as substantially reflected in the minutes attached hereto as Exhibit A, made the following finding of fact: 1 . The City's permit of this parking lot was praperly issued in accordance with the procedure specified in Section 62.108 of the Saint Paul Legislative Code. NOW, THEREFORE, BE IT RESOLVED, by the Saint Paul Board of Zoning Appeals that the appellant's request to reject the Administrative Order under the provisions of Section 64.203a of the Saint Paul Legislative Code is hereby denied in accordance with the application for Administrative Review (Exhibit B) hereto attached. . ��.._....____ _ . .._.._..,...._..,...... --- moved by Zachary , , seconded by Fi shman i n favor 4 against 3 . �r _ . ,c�,a,nw�aaaa��r,? � M � � � � i a ` . - � r o ? a- a. o � : - ;�;�''�,�. � � 0 1 �nr,�i.'��i: �� o,; �- � o � � `:c. s "'�,,°��''�:� a �• � � ; ;O�i � a Yy, Q � � � O `'� � y . 3 � !� � � �7'U ~ ��N� � s � ? ��; � �� r0 ,fD � . � �p• `° , ^7 p� O s � � ; OQ�o �"h o. �,m �v � � � � -•, .� �,� �A�; O � � �..:� '� ; ! v�O O'� � .4L � _ v,e 3� ``.°, a c, � ' .... ± .°z zo�' � aa. -as � � .��• � N� x � ~ d � 00 0 „ � ti �. � � !�7 !'O a `� a ,r `° `' � c ;� � � � ° �o M °. ,�.° o a ,: :v� �(i11►1�tlY"YVYVJ C v� a r � � '" !'� � . A. � Q � � ; v � cc a a � �N� Oi 0. iv; ;�: M � � � �v' ie'F; p � �. „ ;S; � � � � ; 0. � � � y � � O �y ; � � W �� R. � C1C7 � � il+ ;�A o a, � � -� ;�.� a o Z � ;� � � ..°s �- ;m � ' � � �~ � o�c � �• '�M � � � � A � � ;..a.�- 4 � � � � i W y � y � 'Lv. � N. � � :-�; � Q � � � �� V � � N � �• �/� vy• . Q v, � y0. Z Q. p � E �. i � � � > ce y o e � p� � o A' � b 'o ; < RQ a� .r�- � � _ �• � � i .�C��'7+ Q a' � M � � �3 � , , � � � �� MINUTES OF MEETING OF BOARD OF ZONING APPEALS TUESDAY, JUNE 7, 1977, IN CITY COUNCIL CHAMBERS, SAINT PAUL, MINNESOTA PRESENT: N6nes. Zachary and Morton, Messrs. Fishman, Benshoof, Horak, Grais an umner of the Board of Zoning Appeal$; Mr. Thomas Sipkins, Assistant City Attorney; Mr. Richard Amey of the Division of Housing and Building Code Enforce- ment; Messrs. DZUgan and McGuire and Mnes. Berman and Fox of the Planning Staff, SULLIVAN-BARTELHEIM #8144: An appeal for administrative review of the decision o t e oning m�nistrator in granting a permit for parking for Green Mill Inn on the north side of Grand between Hamline and Albert. The appellant was present. There was opposition. Ms. Berman showed slides of the subject site, and Mr. McGuire read the staff report. He then asked the Board to dismiss the charge regarding the site plan and to support the other charges. Mr. Pierre Regnier, attorney with the law firm of Jardine, Logan & 0'Brien, represented the appellant, and said a parking lot permit was not involved, only a building permit. He explained the historical background, citing the 1965 petition sent to the City Council when the new zoning code was being prepared requesting that this property not be used for anything but -residential and the 1968 request for a 9-car parking lot providing ingress and egress. He said the report was not made a part of the file from the Traffic Engineer recomnending approval if used ;� � for employee parking only, in 1968. The matter was sent to the Board of Zoning, ' � who denied the parking lot permit. In 1969 the matter was sent to the City Council for review, resulting in denial of parking lot permit for 9 cars. H� said Staff only pointed out pros and cons in their report of arguments .;�� against granting the permit. He said in 1975 the new zoning code was adopted and when Grand Avenue c�m� up before the Council , people on Grand were concerned about encroachment of commercial on residential . However, he said, the neighbors were assured by City Council that the new zoning ordinance was more restrictive than the old one, and there would be no further encroachment on residential use by this owner. In 1977 Green Mill asked for a parking lot permit and submitted drawing of parking lot 41 ft. wide by 150 ft. deep. Notes on the plan in January 1977 indicated concern for headlight glare into adjoining homes. The parking lot was to be used in conjunction with the Green Mi11 bar. In March revised drawings were submitted to the Planning Department by Green Mill showing fence and reducing parking spaces to 15, with a 12 ft. setback from the front and a 3 ft. setback in back, giving 150 ft. that could be used for 15 parking spaces. Mr. Regnier said the plans were approved by some initials by J.B. on behalf of D.S. Revised plans also show approval by Tufte. Original plans were sent to Traffic with no problems from a traffic viewpoint. No indication was shown that the plan was sent for any purpose other than traffic. He said the plan was also sent to the Fire Department and he did not know whether they approved it with the fence. Headlight glare problems were left up to the applicant. The building permit was applied for and issued to Richard Kelly to construct a parking lot. There still was no evidence that the parking lot permit had been issued. Ramsey County District Court issued restrainrng order for building of that lot, which .� was set for hearing, and agreement was made holding off on construction until a review could be held. � SULLIVAN-BARTELHEIM Page 2 � Mr. Regnier cited procedural errors as: 1 ) No parking lot permit issued. City ordinance contemplates two permits. a) Parking lot permit must be issued by City Zoning Administrator per page 75 of zoning code (62.�104(a)). b) City Zoning Administrator has no authority to change or vary terms of the zoning ordinance in carrying out his duties. Only he can issue parking lot permit. 2) A site pl�n was submitted, which was not accurate nor complete. But the site plan was never approved or reviewed by the Planning Commission itself. No evidence exists that the Planning Coordinator ever saw the site plan. The Minnesota Supreme Court stated that whepe authority ic aranted to City Council , they have absolutely no authority to delegate �at power away. Delegating authority must be done with certain rules. Resolution submitted to Planning Staff did not set out rules or guidelines, It is a serious matter for the Planning Cor�nission to not approve because the Planning Comnission would have held hearings. Neighbors were not asked. Mr. Regnier cited substantive errors as follows: 1) The 300 ft. requirement should be measured along the right-of-way so the lot it is accessory to i.s within control of the property it is accessory to. Staff ineasured as the crow flies. 2) Failed to show owner on site plan. Ownership shall be shown of all lots intended �°`� to be used for parking. No indication of who will be bound by parking lot site plan. 3) Parking space for �andicapped. If provision is made for them, you reduce the number of parking places because handicapped requTres 12 ft. , not 9 ft. , so this parking lot will not solve any problems in that area. 4) Drainage. Lot shows drainage with arrow pointing to Grand Avenue. Public Works said owner should drain overland. Property is located 4 ft. from the parking lot and drainage could be into his basement. The plans do not adequately depict drainage, 5) 62.104(b) requires minimum of 40 ft. (20 ft. for parking, 20 ft. to maneuver). Width will be decreased from 40 ft. so no regulation on tbe 40 ft. requirement. 6) Re delegation of authority, Planning Cor�nission shall consider traffic circu- lation within parking areas. Signature on plans did not take into consideration the factor of delegation of authority so people could express their opinions. No guidelines so people can express their opinions re proposed use and develop- ment of abutting land. Parking lot will affect abutting property owners. The plan and parking lot in general will not provide harmonious relationship. Zoning code is intended to put more restrictive rights upon the City of St. Paul and authority to control . Site plans do not even show the house to the west, nor distance from parking lot to house that is shown, or any lighting on the parking lot, or any distances from gas station driveways to the east to this driveway, or sloping of parking lot on the west side. Site plan does �� not have controls regarding noise, lights, environmental impact, etc. Mr. Regnier said there is danger of carbon monoxide poisoning. He said the Bartelheim bedroom is only 4 ft. from the parking lot and the glare of headlights would affect homes on Summit Avenue. He said the parking lot is accessory to the bar. There , � 1 � � SULLIVAN-BARTELHEIM Page 3 ; ,`"'`, is no evidence that the License Comnittee or inspector were ever contacted. He said 54 ft. of parking was.eliminated on Grand Avenue to put in the parking lot, thereby destroying property values. The �raffic hazard was ignored and the comprehensive plan was not considered. Mr. Regnier cited Section 64.201 of the ordinance and said the duties of the Board of Zoning Ap eals are 1 ) that the directives of ordinance be observed 2) public safety 3� substantive justice is done. He said granting ti� permit denied all these things and he asked that the permit be repealed. Mr. Regnier then showed slides of the subject area. Mr. Don Willeke, attorney in IDS Building, Minneapolis, submitted his bri�f, with the original to Chairman Morton and a copy to Mr. Reg�tier. He said tbe lot in question was vacant since before 1969 with a For Sale sign on it, and it was one of seven lots zoned B-2, being zoned corrmercial before that time. He said in April 1977 Green Mill Inn acquired the property and their restaurant has been located there since 1932. Residents in the area asked for off-street parking. He told of the effort by Green Mill Inn in preserving trees, with everythi�g done pursuant to the special condit�on wse permit and with approval of all city departments and the Planning Department. The Green Mill tried to accommodate the neighbors whenever possible, Mr. Willeke said, and he said Mr. Regnier's clients contend that the permit was not issued properly by representatives of the City of St. Paul . He then answered Mr. Regnier's arguments. �� 1 ) 1968 case. That is the case before the Board and decisions 4f pr'�or - � City Council do not bind the present City Council . It is incorrect to bring up ancient history. 2) Handicapped parking. This is not required, but if Mr. Regnier's clients wish, they will put in such a spot in front, which would eliminate the pine tree. 3) Fencing. Green Mill volunteered to build as high a fence as the neighbors want and that the City allows. 4) 300 ft. objection. This is not true. 5) Who are the owners? Green Mill acquired the property by contract for deed. He said Mr. Regnier's stdtement regarding the "Board ensuring occupants will not be unreasonably affected" lacks clarity and precision. He said it appears that the appellants are trying to use this clause to force Green Mill to go through a variance procedure when the use is permitted under 6-2, He said Green Mill has met all applicable standards, are not creating a nuisance in seeking a variance, and are trying to retain a use which is fully compatible with the zoning ordinance. Such use permit should not be taken away and the appeal should be denied, Mr. Willeke said. He added that if this procedure was improper, there are more problems than just this case. ..,,,i+ Ms. Katherine Wegler, 1510 Grand Avenue, spoke for District #14 Planning Committee. She spoke of a meeting where Green Mill representatives were present. She had no cor�nent on the specific appeal or meri�s of Green Mill 's expansion, but said she endorses the recommendation of the comprehensive parking study by the . i ,� • � • SULLIVAN-BARTELHEIM Page 4 '�'' City all along Grand Avenue to provide planning for off-street parking so as to avoid parking problems in the near future. Mr. Owen Sorenson, 1366 Grand Avenue, said r�ei�hbprhood-commi.ttees have been meeting with people from Green Mill and they think the parki�ng lot should not be allowed and are in support of Mr. Regnier's arguments. They would oppose the parking lot for all the reasons stated, and that the parking lot was once denied because neighbors were against it for reasons of neigbborhood erosion. Ms. Marylou Gladhill , 1358 Summit Avenue, said she lives across the al.l.ey. .. - She agreed with Mr. Regnier. She said her bedrooms face the back lot and the noise and lights would affect her nine year old daughter. Mr. Ray Faricy, state representative, said he had attended the District #14 meeting the night before and thought it was beneficial that the neighbors got together with Green Mill . He �aid the City �of 5�;:. Paul had better wake up as' to what it is going to do with one of its best commercial areas, such as Grand Avenue. He asked the Board to come up with some recommendation to address the problem. He mentioned similar situations at Cleveland & Marshall and at Fairview & Grand. He said the City Council is on record as saying there shall somehow be expansion along Grand Avenue, but there is no evidence" of it. He appea;led to the Board to request various planners to address the problem. Ms. Janet Johnson, 1352 Osceola, read the Randolph Heights Neighborhood Association endorsement of the District #14 plan. �.� � Ms. Morton stated that the Board was looking at an administrative appeal and the endorsement read by Ms. Johnson was out of order. Mr. Anthony King, 1365 Sumnit Avenue, said he had lived there since 1951 , and he can look through the front of his house onto the lot which would become a parking lot. He said there has recently been deterioration of the area and he was concerned about any further corronercial establishment deteriorating the neighborhood. He mentioned burglaries in the area recently. Ms. Morton again stated that the Board was reviewing an administrative order. Mr. Arnold Niemier, 1364 Summit Avenue, said his only reason for being involved was from a humane consideration and Bartelheim cannot continue living there with the parking lot coming in. He said Green Mill patrons have changed--they park everywhere and are a nuisance. Mr. Hummer asked Mr. Sipkins to tell the Board about the parking lot permit, and Mr. Sipkins said this was a classic case of zoning confrontation. Re Mr. Regnier's procedural points, Mr. Sipkins saidthat regarding the parking lot permit, the City Attorney's office thought issuance of the building permit would be sufficient and would suffice. Regarding the delegation of authority question, it is true that delegation was made by the Planning Commission to the Planning Board and the delegation was not accompanied by any instar�ce of guidelines. The City Attorney felt delegation made by resolution of the Planning Comnission would provide proper delegation for Staff reviewing site plans and it was the intent of the �,,� ordinance to handle most of these site plan reviews in an administrative manner. Regarding the necessity of a public hearing before the Planning Commission under . � � ' � � SULLIVAN-BARTELHEIM Page 5 r''�+ Section 64.209, Mr. Sipkins said this section does in fact apply to special condition use and site reviews. However, the provision itself does not require public hearing and says the Planning Commission "may" withhold public hearings as it sees fit. � Regarding substantive matters raised by Mr. .Regnier, Mr. Sipkins said the City Attorney believes the manner in which Staff ineasured distance between the parking lot and the nearest point of the building was r�asonable. The City Attorney feels evidence of ownership was answered. The City Attorney agreed with Mr. Regnier that handicapped parking is required under the state building code, with one handicapped space for each 50 parking spaces, and he said the site plan should be so updated. Regarding other matters, such as drainage, maneuvering, etc. , the City Attorney can only rely on the �expertise of Public Works and other departments which approved the site plan. Mr. Sipkins said Section 62.108 is the crux of the matter, and the question is what exactly can the Planning Staff, the Planning Coordinator or Planning Comnission do under this section? The area was zoned B-2 in October 1975 and • is not in accordance with the comprehensive plan of the City of Saint Paul . This matter is outside the scope and review of the Board of Zoning Appeals, he said, and is a legislative matter or a matter for the City Council . �•,� Regarding Section 62.108(c), the theory, according to Mr. Regnier, is that this turns all site plan reviews into something akin to special use permits. The Board of Zoning Appeals does not deal with special use permits, Mr. Sipkins said. Even if that theory is acce�tted, the question becomes whether or not the standards and conditions set out in the ordinance have been met by Green Mill in its application, and whether the review work done on this permit was sufficient and in accordance with terms of the ordinance under Section 62.108(c). If sufficient, then the Zoning Administrator's decision in granting the build, ng permit should be upheld by the Board, Mr. Sipkins said. Afterward there , can be an appeal to the City Council . If the Board feels the review was insufficient, there are several things that can be done. The City Attorney questioned whether the building permit could be revoked, but the site plan could be remanded to the Planning Department staff for what�ver additional review or guidelines the Board would see fit to protect basic properties. Or the site plan could be sent back to the Planning Commission itself and ask them to fashion their own remedy in regard to granting or denying the permit, in which case litigation would possibly ensue. Mr. Sipkins said the issue before the Board of Zoning Appeals is to decide whether the review according to this particular plan was sufficient in terms of the Ordinance. Mr. Grais wanted to know if the Board could decide based on what they consider the equities in the case, or would the Board have to decide on the technicalities. Mr. Sipkins said the Board should decide on the basis of Section 62.108(c). ..<�' ` � . - , SULLIVAN-BARTELHEIM Page 6 .�., � Ms. Morton asked �Mr. Sipkins if the Board must have a plan, and Mr. Sipkins said if the Board is going to consider revocation of the building permit, then there must be grounds on which to revoke and those ground could include insufficient site plan review based upon Section 62.108(c). A motion was then made by Mr. Horak determining that the permit was issued in accordance with the Ordinance and that the appeal should be denied. The motion was seconded by Mr. Hummer. The motion was then passed on a roll call vote of 4 to 3, with Ms. Morton and Niessrs. Grais and Benshoof dissenting. Ms. Morton then said the parking lot can proceed, and Mr. Willeke noted that the handicapped parking space will be put in. Submitted by: Approved by: .�,pr.. � u'�''�M�.. )� ./. � Jean S. Berman Gladys Morton, Chairman ! ��► ..� , � . ^` . - . � � PLAIJNING BOARD STAFF REPORT aune 7, 1977 Plat Map 8144 1. APPLICANT'S NAME : Messrs. Gerald F. Sullivan and William L. Bartelheim 2. CLASSIFICATION . � Amendment � Appeal � Permit � Other 3. PURPOSE . Administrative Review of Orders Issuing Building Permit No. 029872 for Construction of a Parking Facility 4. LoCATiox . For Use by Patrons of The Green Mill Inn, Inc. North side of Grand Ave. between Hamline and Albert 5. LEGAL DESCRIPTION : Lot 24, Block 1 , Wanns Addition 6. PRESENT ZOIJING: 6-2 7. PURSUANT TO Zoning Code Chapter: 64 Section: 205 Paragraph: 2 8. STAFF INVESTIGATION & REPORT: Date: 6-�-77 By: CLMcG A. The appellants are appealing the decision of the Zoning Administrator to issue a building permit to allow construction of a parking facility for use by patrons of the Green Mill Inn, Inc. on property described above. B. The appeal,prepared by Mr. Pierre N. Regnier of the legal firm of Jardine, Logan & 0'Brien as attorneys for the appellant; charges that errors in fact and procedure were comnitted and that the permit was issued in violation of Zoning Ordinance Sections 62.103 a, k & 1 ; 62.104, 62.104 i ; 62.108 a, b& c, and 64.209. Since the alleged errors are numerous and many of the charges are lacking in specific detail , this staff report will attempt to deal with each section cited on a point by point basis. 1 . To the allegation that the permit was issued in violation of Section 62.103 paragraph a, we respond that (1 ) the building official has det�rmined the subject site to be in the same zoning district as the principal use and less than 200 feet from the building it is intended to serve, said distance being measured as specified in the paragraph , and (2) the owner has not indicated any intent to use other lots or parcels for parking. We therefore deny the allegation and bid the appellants bring their proof to the Board. 2. To the allegation that the permit was issued in violation of Section 62.103 paragraphs k and 1 , we respond that the building official reviewing the permit request interpreted these provisions to apply only to "required" off-street parking and the proposed parking facility was not "required" to meet the conditions of the Ordinance. While this interpr�tation can be questioned, the resultant error if it is in fact found to be an error, can be corrected by adjusting tlae site plan to provide for a single, appropriately marked and dimensioned parking stall for exclusive use of the handicapped. 3. To the allegation that the permit was issued in violation of Section 62.104, we question the allegation on the basis that the charge is not specific in that this section of the Ordinance contains 13 paragraphs lettered"a" through°m"'and the allegation is thus unanswerable. We therefore bid the appellants specify their charge before the Board. .� ,#. • ' Messrs. Sullivan & Bartelheim Page 2 4. To the allegation that the permit was issued in violation of Section 62.104 paragraph i , we respond that the p]ans for the proposed parking facility were reviewed by the City's sewer engineer, who made no objections to the proposal and indicated that the lot "should be allowed to drain overland," and further that the revised plans provided by Green Mill Inn, Inc. indicate that the paved surface is to be sloped to provide drainage into the public street as is customary in areas where no storm sewer connection is possible. (See Public Works Letter Attached). We therefore deny the allegation and bid the appellants bring their proof to the Board. 5. To the allegation that the permit was issued in violation of Section 62.108 paragraph a, we respond that The Green Mill Inn, Inc. did submit a site plan to the Planning Commission for review and approval as required in the section, as is evidenced by the presence of th�t site plan in Zoning File No. 8081 . We therefore deny the allegation and request the Board throw it out in view of the evidence. 6. To the allegation that the permit was issued in violation of Section 62.108 paragraph b, we respond that the site plan provided by Green Mill Inn, Inc. was reviewed for the Planning Coordinator by appropriate City staff including: 1 . The Department of Public Works Office Engineer 2. The Department of Public Works Sewer Engineer 3. The Department of Public Works Traffic Engineer 4. The Traffic and Accident Division of the Police Department 5. The Assistant Chief of the Fire Department 6. The Housing and Building Code Enforcement official 7. The Current Planning Staff as is specified in Section 5 of The City of Saint Paul Procedure Manual dated October 1976; We further respond that the Planning Commission has in fact delegated its powers and duties granted under Section 62.108 to the Planning Coordinator by Planning Commission Resolution 75-48 dated November 7, 1975 with respect to site plans for parking facilities. (See City of Saint Paul Planning Commission Resolution 75-48 attached). We therefore deny the allegation and bid the appellants bring their proof of any error under this section to the Board. 7. To the allegation that the permit was issued in violation of Section 62.108 paragraph c, we respond that the� review process as outlined in paragraph c of this document adequately "considers" subparagraphs 1 , . 2 & 3 of this section; that the revised plan provides appropriate landscaping and fences which the administration has required under subpara- graph 4 of this section; and that paragraph 5 of this section is not applicable to this site. We therefore deny the allegation and again bid the appellants bring proof of any error under this section to the Board. . ' � . . • r Messrs. Sullivan & Bartelheim Page 3 8. To the allegation that the permit was issued in violation of Section 64.209, we respond that no Planning Comnission approval for the proposed facility is required under the terins of the Ordinance as we understand it and we therefore deny the allegation and bid the appellants bring their proof of error under this section to the Board. C. In summary, the Staff recommendations to the Board of Appeals are as follows: 1 . If in fact the Board finds the permit was issued in violation of Section 62.103 paragrap�s k & 1 , that the Green Mill Inn, Inc. be directed to prepare a new site plan providing a handicapped parking stall ; and 2. Upon the provision of a new site plan, if required under paragraph 1 above, absent any other proof of error, the Board of Zoning Appeals should permit Green Mill Inn, Inc. to proceed with the construction of the proposed parking facility in accordance with their plans under Building Per mit No. 029872 or order a new permit issued as the Board finds appropriate. 2.2,. . � j • � � �� LAW OFFICES OF �� JARDINE, LOGAN & O'BRIEN •.Q DONALD M.JARDINE 1350 NORTHERN PEDERAL BUILDING JOHN M.KENNEDY,JR. JERRE F.LOGAN WABASHA AT 6TH EUGENE 7.FLICK JOHN R.O`BRIEN ST.PAUL,MINN. 55102 RICHARD T.DOLEZAL GRAHAM HEIKES CHARLES E.GILLIN GERALD M.LINNIHAN (6�2) Z27-060i JAMES J.GAI,MAN ALAN R.VANASEK PIERRE N.REGNIER J u 1 y 5, 19 7 7 MARK A.FONKEN GERALD E.WALLIN PATRICK M.FLYNN LOUIS R.TILTON MY'S. Rose Mi x, Ci ty C1 erk KENT E.CHARPENTIER Room 386 City Hall & Courthouse ROBERTJ.TYRRELL St. Pdul � MN. 55102 ot'Counsel Re: M 5319 Sullivan and Bartelheim v. Green Mill Inn, Inc. , et al Dear Mrs. Mix: Enclosed herein for filing, pursuant to Section 64.204 of the City Zoning Ordinance, is a Notice of Appeal to the St. Paul City Council from the decision of the St. Paul Board of Zoning Appeals which was rendered on June 21 , 1977. I am also enclosing herein a draft in the amount of $50.00 as payment for the required filing fee. I would request when this matter is brought before the City Council that the City Council be apprised of the appellants' request for an evening meeting on this matter. I would further request that the hearing on this matter not be held from July 25 to July 30, 1977, since I will not be available at that time. Yours very truly, JARDINE, LOGAN & 0'BRIEN ' �C.��.� Pierre N. Regnier PNR/fb ;.�� ` � . ,, encs. �"�',.��, cc: Frank Horak, Secretary Board of Zoning Appeals . �.�` 421 Waba.sha, St. Paul , MN. 55102 � Glen Erickson, City Zoning Administrator, . 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't. � Na 3290'�S--A�davit ot Ser�ie�b�Ma1L(Bs�,1867) Miller-Dav1s Co.,MinneaDOlie �tate of ,�Tir�t�e�ota, ss. RAMSEY Countyof............................................................................... St. Paul .... Fl orence...Baumgartner.. ................ o the.........�.�.ty o .............. .. . ........................... ......................................................... County of............Rdmsey... . in the Stccte o innesota, bein�s duly sworn, says that on the . ............................................... ...................5......................da o �!........................................., 19............, he seraed the annexed................................................... f.......�u 1 __ ...........Noti.Ce.of...�P.p..ea.�... . ........_..._ , __...... ................................................................................................... on......City. Cl.erk.;..._Donal.d C...Willeke ...................................... .... . ... ............................................................ .................. th.e attorne�(8) for......S.t......Pa.u.1..x...Gr�en...Mi..1...1.....1.i?.n.�...Inc.�.......................................................................................................... the.........................:.:..........................in this action, by mailing to...........thema.............................. a copy thereof, inclosed in an envelope, postage prepaid, and by depositin� same in the post o at......St.. Pau I .Minnesota directed to said ccttorney(s) at...386...C. l.ty„_Hd,ll _.& (;oul"t Ouse, St. PeUI , MIV.� �� ................................:......................�........... ................................. the last known address of said attorney(s). 38th F10o1^ I DS TOweY', Mi nneapol i s, l�N. Subscribed and sworn to be f ore me, t ' .........5.................. � [� . da JU1�/ � 1 .....��.....��.....�.?-��:�..��.................. __.............. ;.w : , ._. .......;,�.............. �y ��G.��/.v�...,�� "..':. s... �..... .. ...MAR�HA 1. NELSEN Notdr�Public..... ' i�n1�RY_PU�UG-MINNESOTA ........................................ . RJiI'}44�Y COUNTY My Commission Expires,,,,,,,,,,,,,,,,,,,,,,, ,,,,;�,.......My Commission Exp�res SePt,ta,1��9 �..r,r��:r .>...,�,,,«,,. .. .. ... ��`t'�''�R'�� 3�f.�sQ �,�t��`►� �.l� ��s �� 71� . , .�' -� - . Y° . � .. ) ' . . . i't-�� . . . ; t` � . F - r � � /- - � � , . � � � l �3 � � ' I ; ",� �`h,�;"'y 1 . �` � �� +`' �� P - . . } ..s ! v.�•WM � r . : � t � '� �.�, _ �; � . , , '�„ � � ` � _ , � � _ I Q� , ` � ; , , , . _ , '' , �� - � � ; � , . . _ . , , . , . �� . , � > , ��_ , � � � ' � j. � � �� , I -; � ' �� , ` ,. . ' . . . , � . � �� ,. , , � � � , �i' � - ��' . 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' _ ' , .� . ' � ,� .f � . � �_�. - . n . ' . � . � � � . . . � � .� ..Y. , � , I _.� � ... „ / � � � . . . . . � � .. � � ' '\ � ,. � / .. . .. . � . . l . . . . . . . . . � \ � ,�� ' 1{ � � � � , � .. . � . . . .. , , -� � ;.. .. � 4� �. �. , � : '� .. . � .. . �.��' t � �� ' ... . ��. ..' '.. . . . � . . .. �� . .. �` . . .. . „ . . � �." . . . . � . . . . i� � �.�:�. . �. CITY �F ST.PAUL DEPARTMENT OF fINANCE AND MANAGEMENT SERVICES �ssESSn,+r�vir avis�oN 113 CITY HALL ST.PAUL.MINNESOTA 55103 July 22, 1977 City Clerk File No. X1922, Page . Dear Citizen: As a courtesy Co you, and as required by law, we want to notify you . about a public heazfng which may affect you. ' ; T'he Council of the City of St. Paul will hold a public hearing in the Council Chambers of the City Hall and Court House (third floor) at 10:00 a.m. on August 4, 1977 on: 1'he agplication of Gerald Sullivan and William Bartelheim for an administrative review of the Parking Lot Permit for Green Mill. Property is located on the north side of Grand Avenue between Albert St. and Hamline Avenue. Legally deacribed as follows: Lot 24, $lock 1, Wann's Addition. If you would like further information about this hearing, contact the Current Planning Section of the Planning Board, 421 Wabasha Street, or telephone 298-4154. ' While the City Charter requires that we notify you of the hearing, we wanC to help you to l�arn fully about any action that could affect you, or your community. Therefore, I sincerely hope you can attend this hearing, so that you caa make your views about it known to the City CounciZ, whether for or against. J. WM. DONOVAN e�-- W� VALUATION � ASSESSMENT ENGINEER rF-- co,, u. � m� ' c� �'; �� - �:� J C� �, LL. ..r ..�d� t,.�f C��r- . . C�r�d y�.,�� . � _ . . I � .. .J' �'i" i . � °�'�,7 �7 . � . . : . , � • v � �� July 21 , 1975 'r•ir. David f�oza ��E�� President, St. Paul City Council Room 719 City Hal l ��L.� � ��TS St. Paul , r�innesota 55102 C�f.;r�ci� ��es:ct=ni Dear Sir : David H. Hozza Since the 3 parcels of land adjoining my property are Zoned B-2, I request that my duplex at i363-1365 Grand Avenue be Zoned B-2 also. :•iy property is described as Lot 23 , Block I, iYanrits Addition to St. Paul , Ramsey County, Minnesota. The adjoinino parcels Zoned B-2 are also in Block I, �tfann' s Aduiti.on: 1) Lot 24 (a vacant lot) 2) Lot 25 (a sinale fa�nily home) � 3) Lots 26, 27 �, 28 (a gas station} - Res ectfully y urs , . c �� Gerald F. Sullivan 1363 Grand Avenue � St . Paul , ��innesota Phone : 298-2050) jyork . 298-2049) 690-4329 Home f . . � f_. _ ... . . 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" T�l:�.�..� ' t ' � i i� '., ,. �, � �� x r � � � � . i i . � . . : 10� n n �s ► � r t Y��j;! j � �. - _- - -- -- • �!�' � , i � � - — - - _- - _ _ � � . � � �....� . � „ n „ ,. .► f. ., r. .� .. ., „ „ .,• � ., „ „ ,� .. � - �" "i : • . ., . . . t � ►i I� b �i N �� • rr n, �. .r • t ( . : ` . . � �190 at �t `� � /l .) i� �.� i.. �i II l� l. lf N ��n`r.� -• ` � : ;�• i4 � k r � AVE �, - - -.. - _ I ��,::. -- --- __ �� t �+ _ �.. " ._au .� - - - 4 � • : ' ' ' , ,� ,�, .); 6chD.P/GN � '1:.'�-�� - Si, n .r �N � f� - •• •• ': .. �� '. � � •• "�:.... .. '; _ . UA . r • � :� � � � �. ' � s.�r� ' „��`1 1. , �� r .. n �i i. r i r � � 4 1 ` ' i �l.. .' t , I I �! � i � r � � .. — 1'__ -� � • • • �� I� L t ; .,. ., „ ,..;, , u E _ � : . . _ .I_. _ _ � �� _ . ____.__ ' � a: � ; . � �n � � `. , , ,. ., .. .f ., ,,. „ _,� � ;,- � . � � : , � . � � �� -� . - - a• � �� •• ; , n ,, n .. r, ,. „ .. ,. ! ' .rt i� �t i� r �r•. � • r �: . . ' S A✓E. � . . • l..t .t . . . .J_ . ' � fi. T �soo s� ,�t _{ � I � , , ,�. Lt , - ;P � .. , . .__ - - - . . . ' � � �. �t y .,. ZyC..y 1_l..tu�. �. N� „ �� . . /ril/�PMOUNT j � • �+tt.1 ' 4 � � . � � . . ' , � � �t/� • +� '. . � . . - -� .,r. ,-�_t.,.. .,,.. . ,� ; t"'r'"� � : }�; ; � • . . �_...i ? N �. ,. • ' � , i j ° i. e ♦ � r i • � r i �i r�. .,�'. ;�` .t , �'.'. .; � � i ' ( i � N M Tq q q i. n ►e a r 1 I � - � � . ' , y .- - . �� f ii n n �. i . _' �.' :. . _ . . � . ' ' � � - .�. , . I .,,, ,.,. . ; IIIII ► � �� , � � � � � =' • � � � � � � . . . ' ' � � � � i . _ � . ' . , E . _ - k ,- _ . , . �, : �. � . . i . , . � )�cfo.re i:hc }3Q�'il:D O)�' TO_��L'i�:�', T�I.'PE71I,S � Cl'1'1' OI�' �`.i. ).'i�UL In i�c� nclm:i_n;..;t::rativc I;��rie�� . ) Of .1.SSL1c111C:i O'� F;Lll_�.C� 1_I1:� � � � . I'criniL No. U2�;>77. ) ) ) Z Oiv_L I�TC� I.�I L�, �;0. � Gc�a��1d 1'. Suli:.�_van ::in�i ) 81�r�'t ��i1.J_iam r�. 33�z.r_t:c7_hLir!1, ) ) 1�pp�ll�nts , ) � . . v�a. . � �'�1��iOR1�1:IDUi•1 �L� P�:✓t�l:':��' --, ) Il�? OPPOS_�`1�i.C:' l:, The Green T•Sill lnn, Inc. , ) A�>PF't'1L �� ) — R�sponG�n.t, ) � ) . . TYIe District 14 Planning Co�itte Supports the Development of Ofi-Street ' Parking Along Grand Avenue and Within the District. In Light of the Need f`�� for Off-Street Parking and the Prevention of Haphazard Development i ` � the Co�.ittee ha.s Resolved that a Study be Initiated by the City of St. Paul ! to Develop an Adequate Proposal to Benefit the Entire Business and Resid.ential Co�nunities. Therefore; the District 14 Planning Cotmuittee ' Proposes a Moratarium be established on a11 Off-St�eet Parking Developement until a �omplete Study be P�formed and Recomendations made to t�:e City of Sto Paul Affecting Grand Avenue in General and Grand Avenue within the District; , in Particular. ,:, ;. , , �� ,. h, � �� `' i� ,.. ��: ", ,; ... � . . � .. . . . . 4`.... . . . : i . . . . .. . . .. .. . .. .. .. .. i . . � . . .. . � �� . . � � .�� . . � .. . � . . . .. . . . ' ti r fi:'A � ` -�_~ . # . • �)jT `I')1 C3 ��l"C�:.1 I�1.1_.L�L 1 il T)� I 12 C. �.��il(_' �i)=.^..C'_I: L�1�1 .Ctlri t.:� �3 YC'SI=�lUY'c3T1� �_C)C.�t�'CZ OTt llainli.i�c �it. thc� inl.cr:�c:ctioi� ��r:i.,.h Grai�cl -- u l.oc.:�tian i.t: l�ias ocr.tzl�iccl for_ ��: �•�ars -- s.iYice 193?_ . Th�:�� G�,�-�en. r.iil.� _ ��t�rz is jus�ly farno��s for iL-s r_eraarl�aalE� ��znd --- uTzt_il. ��eceiltly -- unirnit�.�tc.:d deep disi� pan pizz��s . Rc�,idents ' i.n the 1re�_i of Lincol;l and �Ia�;line have made sL-t�ong deman.ds thaL- the Giee.i T�Iill Inn acquire off-si�re�t par};.ing for_ its paL-roz�s. Tlzey even raad� thes� c:ernands before a. Cor.�unitte� of the St. Paul Cit�� Council . In part in 7-esponse to these dernands of n�ighborir_q residen�s, the o�:T.lers of the Gree11 ::ill Inn began to tl�.inl� of t.}i� lot across Grand Avenue --- less � thur. ?_C'C a c�� a:auy �ro.:� Li��z�- r��` ^ �. �. ;t�.r.i:.:. Ti7�1� ��.1eu the tel_ep:�or:e num:�er i�ainted o�� t;?e lo_zg-eaist�.�}y �OR :i�1.,L SZC3i"1 �iZ:l b•:-.C�di1 I7�C�0�1c:�lOI�iS �t'lt.t2 i:�l� O��iT1E,'1=_. � ZEc�.Clli":J to a purr.hase of the lot. They �c�ol., do�an tne anci.ent FQ� S:iL�.�.' s'_gn, filled in the hole, and remcvecz one of three tr:.-:=_s on th.e prop��rty, tal:ing care to p-reserv� a ver�� ]_arge oak (by covering its very sensitive root syste�n witn coarse gravel) and several other trees, including a pi�e tree aL- ttie fr.ont of thc lot. Th_is c•�as all done pursuant to a City of St. Paul Sp�cial Use PermiL- relating to a site plan approved by the Departmerit ot nublic ��orl:s 0�=ice . ., . 1_;n��:i_r�ec1°, t_hi� Ucpai�t:r.icrlL of )?l�i_�1:i_r• l�o��Ics :��,�ti�c:�_ J..i,�i.uc��l' , fi.]�ie Dcpat t_mcilt oi' f'ub.l :i.c Ylo1-)cs '1.'r��:� Eic 1,r��.;:i n��c.r, t_lic `.�:'Ti.l.�j T.0 c1I1C� L'�CClClE:'."?�: �):l.V.l_S:I.OI1 Of (:17(: l.'U7.] C'C'_ i.?i_'.j��11'(;Illi`ili'. � . � �_Il['_ �S51b�:�1I1� �.'111C'.i G�' (:.1).C3 }''1.I�C'_ L7C.f)�.l'3:�']fiCll i:� i L1C ;ii1�,f.i:1,Il�,'. , anc� 13;i:i._ldiilg Cocic I;!zior.cenient Oi:f_:ic.i��l , ��T�ci thc� Sl�.��f: C o�� 1C 1�Zc11�21:LI1CJ Cp?[llll:LSE.;lOI.1. Suc�deiiJ_y, o�z a day ii� t�Zay, tt�c� nc�igri?�ors .de:rc no long�r complaining because Tlie Gr��en I•ii1.1 In?Z h��d no par}:iny , btiL- instead because ii� ��:as iilstallinc,r so�� in a lot ��l�l]_GIl iar a loiig tinie hac� bcen zon.ed for �jUSi: S1ZCi1 �:� USE'. Tne Gree�� D�ill In1i ha,> been s�e}:inr to acco:�?:.�- da�e where possible the wis3ics oL- its neic;hbo�� so it . vclu:��a�i�Y ::�a�e� �•:crlc cr. ��u �o,� 1�c�;c:�:�; ;�1.c ct.�co�,i�� oi �his a veu__; G•:or.: �•�ill no�� rc�sur:�e �•:�_thoLic �4r_,- }� � ' ' 24 lio�� p�-�_�.r notice to a?�p�llan ts ' a f.��.orn�y. lll� appel_lants arc� not contest in;r Lri� zon�ng o.r use o� the lot ir� question; they a.�-�� only coiZ�c,3:c(ing that tlZe permit has iiot been p�:operly issu�d by -t�ie ��ppropriGi�e authorities of the Cii:y oT St. Paul . � . The appc�].7_ants ' attorney in his <zppF��a.l dor_u- meiii� ciL-es a nun�ber of sc�ctions o.f_ tiie 7,oning Or_dinance, severzl o£ �ahich are very 1or-►g and cont�iz�i i�lany ��ictor_s so it i.s ha�.d to tel]. just what the C.OiTl�7l:aint is. Nevertlleless, the respondcnt i_n t:his bri.ef shall a�tempt to dcal with tl�e sc�cti.ons citc�d. • }1C�biE'VC:'1'� }.):'�<)r(3 � (i"`t;c:l1ZC..'.C� C;;.�llt11.11�1�].(�I1 1_`� 1;1�1(�C •of c�ach se��t�_ion c:i.i.e;1 }.�y r_i��>,�cr] .l.<lnt:s, iL s>l�ould }�-:, ,-c,� c�i��,�ltasi•r..c�:± '.:h;�f= ti7c� a�;��l.lai;ts dv I10L: �t��;�c,z�r tc� 1�:� . c].a:i.mi.r�q i�h�;i: i-.he responde�zt. acted i.�;lprc�j��c�i-J_�� i.ri �.��,y �•a�iy OJ' t:�l�l� ]_f: C11C1 I:Ol` C�O �lll'ju�1�_Il�y` 1{: ;4�.S •`�Ll��;�JS°Ci �.0 C�O. �1'}7". ZO1"?lI1CJ (j�C1117a17CC SEGt.lOI1S C1]__CUSS�'Ct �.7('lU�•J aJ_-e tak<�n ir precise7.y t11e s�t-��_� order as -Lh��i:. givcri by tl�e i?�TJ211aT.ts. Il . Sections Ci�.ed b�� n;��llants A. Sec�iOr� G2 . 1.03 (a) li1i: 1'Gc150i1 �i11S S�C::1011 �•TuS C1t�C� c�.��Gc11"S '�A . � t 3 �� . �. � ' ... '' J'i '1 L 1-l�il '. _ .♦ i_ .1 lJ l. �.�� . F�E' l. ! f.'�S l' '-4-:;t�iii_ l- iv.�. l._t:_ _Jc:� ?1Ci ��.?.�chii� the s�..1e d�s�i'i.c�. as thc �rinci�->_il tz�e , ��nci �•:i�hir. th�-�� h�.�nc:.re:;'i (300) f:E>et of. ti�e bL11.�C`li:C 1i; 1-.�-�. 1.T1t".:=?:C,�'u t0 SF'1'�TE Pi?E.'c?SUI=3�l lYOIi? t11� near.est poii:t a- �he builc�inc� t�c� t'rie nc��-�.�es�_ :�oi.zt oT ��7•� oi�-sti��^[= pa?-.:inq lo�. Rc��pond�nt ' s ans;,Ter is si::lpl.e : �t i� . E. Section G� . lU4 This section contai.n� the specific si�andards f_or parking lots . T}iere are , _l.3 st�L�aratc standarc�s (dr�signat�ed �� through ��I�� . �1'�"1G Y'�?S�JO11C�:.`nt .s Lrongly� co��tends t2iat ii� coi�lp]_ies �vit11 each aiid cvery one of the _�_ clilj:)7_]_C�ii:)1C_' :;�.�Ii1C�i:J'C�::. .� f �:�1(_' ��j!�`>!.`_�_�_�LI!�.�� li.l`.'i' c] :.i��:'.i: i.l 1 (' C7i;lT�).�:.111t=r (:'-�{Ul.i:'�' 7'�:'�11i1.7=CS �;�]::1'�. �_�')C1� �,'l"iii:.0 1.t=� i:i1=1 ?1C1�- .lE'�].V�'. ��:IlC' :!_'t':>t�G:l�.l�)t{: EOl" �'Ci�.li: I;C)�li'C�} r;t;C'tiiS:l.'1CJ , `1�llc_: 1 Ct�i)J:�.::_'i��.� ��?iOUC;,: �t;l Ci1:�-.�. CC_:�?;1;111.1": i...�i i].C>i! �:)C3%'1:'l�i`il 7.�:a �ltt:0:�11'c?'7' �i:l" f �l:'- C:i)i�',.�J.ii:�'t.. � �l�.t:Ol_:It:'1/ � �5�1'�.%C, VOZUIlt'.l;('_1C'C. TO }?.i1.�_:: i3 �71.Gi1<:C \ti�:i.l.�_ l:il_i:' i'.;?�ai: }�t'3:-I!1.i.:��.�'i,. n n jJV :it.dilC��lii.� C� � 1:i OY�CiC_'I" �O I'itOL'l� CU:iIyJ�.f'i=E'.1_jj OI=1SC�11i:�, �:1.�.: par}:ing 1_ot f rom ad j o i.n-�:ig propc�-�j. hut to d�ite ch�i� oFfer h�s 1>�en i.7na'"E:�. . 1�3E' o�rer i_s � co_Ztinui_n� o;l�,. CO?�C�1�:.1CT:�.CZ Oill�! 11�0?7 c1�Tt.�Y'O�'�:.�_ r`1T �.}?E'_ C_�.i:1' C)1' u t'�:_rJ_�??1.^.�: from its s�_u;.zd<<rds . C. �?C�.i0i1 G7 .1.�1j (;�1 c�?:G'_ �1 ) �'' c• ' j . c c � �7•--r 1 -i�, l�I�SE' ��Cu__v:l.� Y�.;Cll1.3:('_ CT1� �_C.OL �Z�..._.C.:LC«T;J�:u r�c�2"}:li1CJ S::�IC`.c� fO� :',:iC}7 �� S�c;C�'c> O?� r:!"uC��_Oii tl?;..�i'�.:= . The respon,'��1-i��. d��s nc;� bel.i.eve ti�is I`E?:1C11:�.-E'T.',:^ili^ c�ppli.c,_, t0 c 1.0� Of ZE'_SS t�i"ci:7 �� >J�tCE�S � }�11� ]_L :L'i: 1S ClE:'tE'��;1.'�I�i'�� .hat the Cit=y Pl.a��ninc; Co:�?:�liss�on ' s Sta.f�: c�rr��d ir. izot ii7i��osing t�h�zt require:::ent on �hc 1.5-.spacc 1_0� :in c{ues- • tion here, the respondc��t hci��;:zth ��oltznf�e�rs a�z1 ac3re�:s to provide such a sp<<ce by e::panc�iiiq th� first :;;�ac�� from 9 �0 12 f�e� in �:Tidth. Unf_ort.tir�a4ely , this will require tlie r�,mov«l of i�li� 2 0 Loot tal l pine tree n�ar the f ron 4 of ap�r?:L- lant I3artclhe�im' s housc �•lhich the r�spc�;tident I�ad souc�ht �O Sc1JC il:� i`ill c�CCC1IROC�ilt.:l.O:l �.O I�L�. 13ClCt:.C'.1.�1Clill. �). :iF`C�:I_C);") �:'. . �.n� �:I � . T�,:y.�f�c�1.].�.itiLs ��.�- 1--i_c�z: c:�t.cci t��.l of: Scct::ioJZ 62 . .1_0�4 WJ_'I;IlOU�: ��::_']_T1<� >�IC:C'..1�1C. 1��0�`] �'.�1G�� C:1::.C' �il1�Jf.�C'_C"�:l_Oil �:I_� � �Jliich r_c�_at�:s L-o �irai.riag� in par).incJ lc�ts. Draii�a�c mus t= no L- f lo,.a ori to acij oining pr.o��cr t=y or_ t.o��ard builcl- inqs. `i'n� bluc�pr.int pzcpa�ed by 7lrchi�tect Ric}.zard G•7. FIatld�or_d, �zs api�roved by tne S��a�r Eiic�i�zeer of t.he Det�arLme�t of i'ublic ��lor_?.s of tl�e C_i_ty of St. Paul , el_e�rly reruirGS clr�inac�e south to�Vard- Grand T��T�i7ue, not cast oz we:�t to-,��ard the appcl]_anLs ' l.ots . A vi_su�:l i.z�snect-?.cn o{ t:he �oo.r.}; do:�c� hefiare -t�l�cry r��:,r�o�c3��i_ v�:1 - uritaril�T ceasc_d �-:c>rJL indic��L-cs th�z��_ -Ll�e lr�t i.s h�:ing fi.11e�? to cira�ii in accol-dat�ce �•rith. tlze arclzitecL' s speci�=ir.:ations . .�cco�_dirlgly , rc,sl�o�zdent b��l_ievc s th=is ob=j�c- tion to u� aLsolutel_�� c�rou?��llcss , sp�iri.ous , anc� intcr- posed solely fa�- t21e purposc� of delay arid confusion. E . Sect.ion 62. 1_0£3 (a) This section requirc�s i�hat a site plan be sut�mitted to the Planning Cornmission. _�_ 1 �'. �J..:1`i . I�pi�;,:I I �1r�Ls ' c>�:,.;ccf.i.��n b:i:;,,�1 ui��i I:.}�.i.s � �1.,� c;� � 1S� ] l_}:C'. �1)�: ])C(_'Cr:'Cj.LI1C; C)�) �C'('�'..1.U21 � ;�>';_,�_Ll�l'.�.j' CJ' .: .:i';,��i i, .�. 1' . ficct= i��;� G:'. _�.Oii (�_�? '1`}11S tiCC`i;lOi1 1E'_.';l'.]_J=C:S t:�1C' S1LC'. }%_��.:1 t� 't�'.__ 1.;: _. form p.r�scribeci by tlie Gor��is�i.on �,nd b�� ir1 �.cc�.�ru:.,,;:;�� •J]_:tYl t.11�` ZOIZ1_Il� OY�C._L1?�9.?1CC� c"1:7C1 �c'_iii11�:S ui-:(� COT?:'::-...�..Ci?? K�' dele�ate i�s at�tro-rif:y to ti�`� Planninq Co�rd:i_,:�::co_. `.1'his secti,on also iequirc�s r_c:vi.�•; o� s_�t��> ��a?�s ro_ COTil'Ji1t'..IlC:C3 :�i1�11 ��7G OJ=C�1I1c?I7Lc S OL �::: C'1.'..�% O�' :�`_ . T'%.ilil . �1� lI1C�:LCc-1i=GC�. 1k�OV�,-�'.� L.�2=2.C�:I_C�17�1' ��?:,: i:c:�;.L"i:— ;,l^:�'- C•i.^�"^.f'. 1.=��;i.1-. C)�= rj ;-.1' T�r''`.T (�;,'_' 'nn:' =>i �n;r,�i `' " _._i '_h _, siLe pJ_a?� auL�i�iti.ca k�y ,-es;»:?c?�,i-;. 'i'h.� qu.^:>iio.� o� ;•;i_��t�?e�- t=1i�-: I?�__:_:-rr��g �,�:�:-'.i_�_- �l�.O]" �luS 1"CC:?]_VC'_�: �1?i �:I?J�Y'UL�='_�:'i:r' CiC�1_:?�7c�:=lOI1 Ui :::'_l�n''�i1.Y.:_- cl.��j�cc`ir'S t.0 ��G �2I"15�:'i�iEC� �� Ili_' I�r,i'r1.�� 'i:�VO 'l�f�c7.�-S C.'_�'�.'_Ii:j C�l�?I.C�"1 ��1�` YI.�111:11:?C� �'.OU�_Cl�11�.i.C�Z' �li:1S �;'��.'7] c:j��;L�O'V1=_'� �i1C}' Sl{;� Y.��.c1I"1S �Lli:�ll�:i:'.. t.0 ).�Ic�li?71.i7C� (;OIlii;!1-5:�10I7 ��t':�i0__�.:�10=1 7.5-��8. T_f, ��itllout ad�nittiz7� it, t�ie ir?sta.lt ca.�e :oe� in fact involve a.z improL�e� d�legation of <:�t.tl�o?=it1� , i.hen a qre��t many �;.itc plaiis in St. l?aul are arc;a��,ly illec�al. . . �_ (�,. �;c�c:i,:i.c:�t� (i�� . �0� '1'h�� l.c�:.:l-. oi ;;cc�t�.�r��l C��', . 20�1 is . a� fo1.:l.c��:�s (;�;; ti: einph�:t�, i_:.; ac�Ici��c.i} : �1��1�' )�]_�lll?1.1.11C3 �;Qi(;:il !.�iS.lOII S}2�:11.1. 1.I1V�St.Z(�:��_�'. i.".11�: C:L1 C:i.lii;S�:cii"1C('S Oi- i_'i.li:�: Sl1C}i Cc-1:�c'. c.11C1 Sli�l l.�. ----=- � 110�.?�'� Sl1Ct1 T>;11_�:1.G:�� vil0 I:lc,l` ]_11 _1. �5 Oi_% :.i?::.J': )��' ' a�f:ccl-.cci i::l�c�_-ci�y , of the t?_r;c �znd ��1�.;c�� o� a:i .- hr��:ri.r�c; carzi.c.� ri�.zy L; h:��lci r.^lai-i�,�c:., thc.r_��..o �� . rcqi�.irc�;i under i_�s r_�ulc�s of procc:lure . � The I�1ar.ning Co!inissio�l n�•_iy impose suc'-: co�- C�:L�IUTIS O.l:' .I.:L1Rlt.ci i 10?1S lI7 CJj_c�i1�1_Ila c�l?��7�O�.�?1. <1� lTl_l�T C��'��'tiTll21� ]_Tl ]_T_S �LiC1CjiC:�i1� �E I1P_C:�:SS�z�='�' t0 fu:��ill the .�i�irit a�d p�:rpose o�` �.his Owd�_n- an::�, ��nd t.o pr_otec� adjac��?"?L properties. Based L�pon the L�•�o uses of tl.e �•�ord " suc':" in this scct.i_o:n, �_t :•roul�? ��zppear that t::iJ J��1,.1.UIZ ap�'i.es t� the precedi�zg Se�-�ion 64 . ?_G8 relati::c,: to those ,__-• s�an�es �•�i�er� � u�.zilczinq ��r�:�it i5 val.i.cz io.r n?or� �r_;?z onc� year. PesL onden� does not unaer_st�i�d �i'17�' LI�1� S��c- t1.011 �dc�S C?{_.('�_l. . �I . .�'>CCi,lG?"1 G� . �_li�i �C� rl'}ll.i SGCtlO;"1 c11.lU:i_� i:�7� Cli=� Gi 51.. �'c.tt� �O impose �raff;c circul�_ition, 1�.nd5capi.lr , and f-enc�nc; r�quir�ments anc? furtl�er stltes that in rev=ie�;�iny si-� plans, c:onsic:e.ra�ion ai10L1.LC� be given to : (:s) the arrangemcnt of buildir�gs, tises �„i; faci.].ities of_ the propos�c: developm�nt in oide?� to assure abu��ing property aiid/or its occup�zizts will not� be unre�sonably �i�fectc>c.. (L�phasis �c:cled. ) . . 11�ii��i.i_t�;�c�:L}r, t_liis i-c•;��?:i.r��r,ic,rll_ a.:; vc��-�� v��:�uc:�. .Zt: ltic7.� CVi'.I1 ��E! �I1�1 .1_i1�: i:::ItCI' Q.f �)OG.i. �.C)Cjil �. Ci':�:rL:;*��1i1't;il?:i� .`i].1"1CC' 1_t l.t�i'S I10 Z'C'il�_ �i .c1I-IC:ili Ci I�CJ C'O 1.1". �. t:" f t �TU`,`1('VF'Y� Sc:):i��'. �111.C:ili"!C�' I1e:)' }::�:' Cj::i]_Ili_:�: j:iO�il i_i;•? � ,� �t rl — t— �� 1 >i� �. � r_t � -. , .. cl(��CCtl'Jc, 11,.J_C'.d.�0i.�_l.��__i � l;ill]":.} L.10i..Cj�t �.�?:_lC �•:O:CCi ,:1: . �:?'.=:. :Ct skioul_c? ;;e c]_c��.r.l_y notc�ci i:1i:�� .ii�� o.c�c?i._�, ,-, ' _ . � ._ ..,_i..C'��- Ci�J<':. :?v i. for3�id O�•iTll"-3]"S Oi I�l:'Uj��?2_`��' il'�0::1 li?:�i:1I"1Cj USL:; '�=�"7E'I"C;Ui: �•ri'11_C?i would affccL ai�ut�ii�g pr_oper�.y . It cou�d b� arqu-;d th��, � c�Tl�' .L1S� Of UI1E' � :i �L'07:?�ty c�i fE.'C�.S �:�JUi:�1.T1�t p1_Qi�i',?"i'J 1?7 � 017E.-' WcZ�' OY' c?!70L�11'I'. i'illc�t. 7_S :�'OI:�1C.Cic'i� 1S ��U:?Z�ci�iOrl�ii��.L�� c"LfI'E'..C:t1Il j Gf d�Jllti 1.?7C7 �1"O�Ei:i_i.' . Tlle a��pe:Llan�s live o?1 prop4r_�ies �ai:ici: so-� a C:027S1C�21c-i��.P �1T'il�' �1c�.V? ;�?�I'. 'LC�?lc'� ��—L . R'i-.E'.�T 1?J� O?7 GrC2S1�1 L Vc_,1!�:1: "" ��1J1'�� J CC:T_ l,•�. l ...t'.�' .:l..L �ll_..., _. �J:...l ,i.., .�,__ . l_ II �11 • r _�'t. �'7dS I10 U T'icii�li_'1 �'sY';Ii�U. f Oi_ ?'10"t�I��_T1 j. ()Z?�� Ui_ �;::: clj?-- �F.'�.�c111LS 1"C�.Y T�d:?�.' �'�_'�lX'S �1Vi�C.1 I)�'.'C�•iE?C�'1 c�tl Ov�'1"�'LOi•is1� trash fill.ea vacan� 1ot �nd �:. la�,��e, bus�;- Sir�c1.�=�:i r Ga,� :i"E:c"1�10;"!� S1�t?:t:P.C� O:`� O.Z� O� ��. P�:tt� � S }7115_!.C`Z' CU:i':":t�1=— C1F11 1I1��'..EiS�:Ci lOT1S . L'��'S d11C� �:CUC:};.S L1rG� C�O!ZSt.�:Il��ti parl.ed on botii si.des vr Gr�zr.d c�venu�, and , in <id�?ition , � cars �znd tru.,rs are .�orr�all�T parked .o�. tl�c cancre:e apron of �he Gas S�ation. t�?'guably, ther�iorc, i�he efi�c�ct: of. �he 15-r_ur lot, scr�eiiecl by L-enccs as Iiic1}1 as thc City �•�:i ll_ perru_�L, is not unrcasonable. ' . _9_ ].r� f:urt.}�cr�.:,i�c�.� c�� t�.hc� rc�c1ui_rc:�i,�c�nt o` ��.:son-� �i},:l.c��l<.�;,, t.11c� C�.ty I"i'.t�ll:l.t"CC1. 1.11�1� f:�]!� � i�;.:J;,c>r:cacni-. ' s� 1.oi: c�,�:i.�i: ��s-� GT:<<ricl i��c.�nu.c:� oiil.y, �.;n�l tic�i� i.r�i-.� t.l:�� -t).lc�•,� l�c�t��.rz�i Ci:arl�l I�v��riri;�. :Ci. �?1�;�, rc�clu_�r�c:l a �; .l_/?_ foot, fi�r:cc �.o ]_�:� }:3t. ilt_ ��r.c�u.l�i i.lic :Lr,L , a�zd f�:r',.»c1:-� L-lze� i-c�:;�,oizc:��,� c Lc> :i.i_��_►i�:. tii�:� lc�t �:it_ ?�:i_qllt_ . tfo;��:��Te.r, i�i�is requirct:�ent shou]_c� :�ot b�� u��d �=U ��ZGS(�:L'VE; 't�"1�� :itiitU:.< CUO c1I1�G��r �Ol" t:.}]C, a�i�c":��_CiI1l.J. It is iiot �.�s i.f thc .r_espoi:dent bought the pro��l:t.y s�cretly -- it was ior s�le (��_Tid borc, a large FO:: S�,��E s:i.gn} f_or maliy yea.�s. �i'he r_e�ponden� d ic� no t buy a l�otise secr��_1y and l�:nac?: it do�-m in a f�i:�� rno�-c� Lyp;cal Of :�OI:'i:j CLE:VC�ZO�C?Y'S. �L'I"i� ZC?S�Gi1C�-L'il"V C�1.Ci I10t. 5_^_E_'�i.'L c� zc�ni n^ r.hz�r�� t�h.ro�zcti�� f}?� C? tj� Cotinei.J. . 7 t }�o�.�.�T`�� a �Tac�:nt lot 1.o�z;� zoned F3--2. 7'1�� api e]_lan�s hac7 ye�r_s and �=��.rs to act. ��IIE'.y C�1Ct 1"lOf�. l�l:�'�' 110':•7 �IY'E�' SE'E}�_i.X1C� �:O i15�' V:+.�'tl� UI" spurious t�chnic<�]_ oU�iectians to accoz�pli.sh �•:na� rr.ey r_ould havE� reasonab]_y accomplished by bu�-ing L�i� :Lot�. III . Genera]_ Leqal Consider_a-�icns Lss�ntial_ly, ��hat thc appellant_s arc trying to do in this case is i.o turn a nornal Sitc� }?lan Revz�;•a for a cl_earl.y pc�rmitt�ci use into a p�oceedi_ng� f_or a va�iance, ,' _10_ tt,,a�-� f`o;:.c:i.�ic� ;,lic, rc.::.;pc,i�:lc�<<<. 1_o j��s.;l:.i.;:s✓ c��i�,l� ,�_t,c�i <_��,�,�1-�y� • ci�:J�c�c;L ol i t:.; 11:.c^ <�i t.}1:� j,i:�opc�..�.y r�:.; E>c�.r,:i:i.t.c.c.�c.i i�y l.}�� %UIl.lTt!( C)1Cl.l_1-I<;:!i,:.: . ��.�)7]_,'`.; ]_:_i �)E:J.I1`j (}.Oil�, l.):i(.;i.11::;��' �IIC'. ci��UL.i.1.11�J )�.1'i_)—' . P:_']":L)� G�di?C-,:1-:3 1lil��(�itl1 11C)i'. i.0 �..l.�:i, t:�E,. 1.1:�". --• fLl.�_:1� �>;.e.l.'-- llllt:t:.(3C� �� L.�li' "t:r'�'1'.!S (>.�: �:}li` `1,0111_U�� i'�C�:1J!:°.LTLCC` -- �'i;l_LC��; i".?:;i �'G��OI7(�C'?1i: �C'C:}:� i G lil�.li.E? O:� 1.�;5 1)a=C�r��i�:�'. �l'Y11S 1.`1 �) T10V':.1 c?I1Cl �J�'7'11lClOi1::� i:'t].E'-Oi�i� �ll]C�. shou:Lc; not be aI Lo�-red i�o t_alcc� root:. The a�?p��llaz�ts are (c.tic:��t for :,or�;� r�i.:,or �:iic: even s;�arioas tcc:n;zical_ �bjcc�ion�:} af�;�,z:re�ii.ly p1_�:�;,_i_n�x great: s �r_ess oi: tlic� �•:o.r_<:i "afFer_L-c�c:'" :iii �i„� �7�.:;.ze ��.,r�:...-�� 1111111'('c3SO-i:a1.y �_'=i E'_CLL'Ci�� c1S �G:.2�C�. _l.I: ,��E'C�lOIl �� l�)Si � Tl1-L� is �.-Lti:y��_Y� ll�ll: ��ii�� iiil� .;i_uii�icll.i.i dc� i:il:,_i: CC�i!Cct:i_i:c_:u in t21-� �.T�3rianc�� .,cct_ioz-� (Sc�c�ic_i G�: . 2U`;} �•ali_�c;I: Zl7.o-,•r.� t}lE �irJ=YC7 Ji: GO?�1.1:r; /'�i�i?':'��S UI" �}?C_ ��i."�".j� �'.C)':'.I-1C'.1..� t.0 , 'c?.:i-' V�1r:l�:I�C�S fr'OP�1 i.l?E' �i:11_I'_c?;1CG OI1.�_j ;•1??i'Y_ "t' ir}1f' :ii.l:!_C� applic�tior� ��,o�!ld ca�.�se "cxcci�e.�_�n.?:L uzici�.:c liar_ds}�:i;:;" . Ti�e st�.ndzrd fot �rc�r ianc,e.s ��r� as fol.la;•�s : pro�-i.czed suc!-i re)_ief_ rn�iy b� �j_L�*_1t��c; �•iitl�ouL- subst��n�ial_ dct..ri�ne_zt to �ile ptl�_L1C C�QG�l a.�c? � �vi.tl�ot�.t sttb5t��iii.i��.11_y ir�;p�,i_rinq t}�i� intcr,t �zn�1 purpc�;e oi ti�►i:� Urdi_izacr.c. In gran�i_r:g a vari.�znce, the Ci.ty Counc.i]_ or Lo�a��d o� l�ppeals may at_t.�;cit i�he.reto sucli coziciit_i.oi::� 1.-cc�ar�lirig � the loc::tion, ch�racter, <Znd oth�r fcatux�c�s of tlre }�.raposed uscs as it �t;ay dec:m rc:asonable in f.u.rtlir�rance o� i:he ��ui-pose of this Ordi.�zan;:e. and �a pr_otE�ct adjacent ��roperti�s . `.Phis is clearl_y a far di.fLcrcnt �staildard t_i�an that • —11 — � , • . ' rc:c�iia.:ri_n5) L1��<� ��cljac.c�r�t, �>roj�cr�l.y i�<>i ;�� "t.ti�rc�,;o»,:l��l.�y� affcctc�d" . �, . . .1.�1F' :1.I1�tdll� C�I:;E' ��1.�..�..`_; �Cjl��.i�:-�-�' L�I1C�C.'.Z' i_il(` _l.�l�•1 � o.f: O's( r<�nc1 Z' ___�.'� l .l.y.:��: or_i�Toi t_.h _Si:. P� :� 1:, 7.75 i�1ii��, �� 0, - I�l`I I��.l°1. 2�1 5"7_1 (l�u�,} �•ri�;•rc� t.h:, i-i.inrie:sotz ;;��;>��crn�� Cc�u�-t �1:'..I.C� ��.(. �'].11.�tCjC' �•;c1S c�l"��'Li=1c�t�' 117 Ci�'_I"1.�'lili:j il �j`�C.C1i11_ l];SC . Pe:r.m�_t �•�here tl�e usc� ��s iri corn;�l_.7.arce �ai_Lh zon:i_ng ordinances. 7.'ne Court s L-a tecl <.t� 27 5 Z•linn . 4� G , 1��7 \.t1. 2c3 at 573 . IIis application met �zl_1 e�.1_Si;.'!.T1�3 s�..��.zd��rcis o� tlie bui.l;�ing and zoi�=ing orc�i.n�nces o:C �he vi.11age i.hcn in eff��ct artd aPi�ea:L:s i_o havc� ,.�GCIl �'^jC'CtE-:C? �`�iI1Gl;)::1��-�, }�c>Cc:LI:�G C� :?i 1Cjl?— . bo.rnaocl o�.>posi_�.,_or�. In dcnyina, i_�, th�., �.%il- lac�� cou.?icil ciid not �=0110,� the 3-c.co:,�^Z��n�.�i- tion� o:E it� planni�.c� cor:��iss:i.o,� or co�i�ic:cr tl�c rc;�orf-; o� it� p��; ce, r_.r_:� , ,�r h�`��.?t�l,: depart;r��n�s t.o the eirect thal: rzo poten�i��._L r ;<7.�.c1_'C�S ��iC�tlli.i iO.t.tO��r :L?_ �:T7 �iT3c?I:t]'i?!_'I"ii; k�:21.�Ci_?_71CJ ��cr_� con�:,�t�-uci.ed on p.l_ai_n+�i_�f ' s L�r_o1�rt1� . lU t=�1�' JCii1LC� E'.i��E_'CL SE'.f_' 1'�1(:'X�171C1f:'1= �%. �:1'i�V Ui: P�ii��ne�tPoli�, 2G7 I•i:i.nn. J_55 , ]_2� i�..[�:. 2c3 �£;3 (1963) ; U�_SE_'il v . Ci_LV of i�i�_ri�zc�a�_�ol:�s , ?63 I�iinn, l, 11.`_� i�I. P1.. 2d 734 (1962) . The OlsUn c�se, supr_a , l��id c:oti•�n ti�ic st��nciard of rcjecting a us� other��*ise permitted by t=hc� zo��ing classification -- tllat of a tec�al rzuisance . Ol.scn v. Cityo uf 1�1i.nneapolis, 263 i•Ti_nn. � , .115 PJ .l�d. 2d at 739 . It is clear that a legal nuisance i� a far ditferenL- con- r_ept Lhan that embodi_ecl in the plzr�is� "unreasonably a.ffc�cted" . �.I�11C? ll.`.:(: 1�'ll'LC:I1 1-C`:;OC71iC�t'Tl�-. :>t:it�..`� i.:+� l.li �.:l1:LE> �CiI:;C-'. �i:; :111 � ]11.�1I1C1 C'(i)'.:;i.?:. (�U_ V . ��l�-'y� U� �S�.C)i>in.! Ilc� ! <)Ci � ( 'i ( t- ,i ['(' U f ( � �r ' 'I ' �..1 2 )> i•1:i.i:�i . �7�1 , I_.).:� t� .1, . 2c� _�_��, �_�..) /?. (:C)?; ,):1�.L:?.�.�' 1:,J t.. ! l lic, . � ,,. �:1_'�'.<"1 :I_r�. ��:i17,c:�1 ��1::'. .�_Jf_. 1_.`; l.C)C:<<i:::'.Ci. l(� � %C.1111.I1C O{� �:�_•:. � 1 - !" ;, � . , . ., , , ;- ,..�,_, . �- T-,.-; ' ,_�.,,' _ . , cl.� .�t�=t.CCI _t 11 T1"l.l.%111(1 ; LI1�: �Jll]-(_l _11 U. �.. .�)�l ... ._�.lill.l .. ...i 1_U U��t��.i 21 �i "}�c'C1�?1_ l::;C �'C'.1711_I_{� 'i.:; Ir�t?CI1 l._1 ;i'1"li:E,J: {�}:�ill i_)�i��i". l=C'C�CLI.Y�C� �.O O��{�i.l'lIl �l Vc1I'�.�3i1Ci.` ��c'')_Itl1.t:.. '1'�1C: ii:tlll::_::=�Oi:�? Su��rcm� Court �•r�nt o?z to stat:e iiz l��nc7!i��c�c th��t _i_s p�rtict?l�:.r.ly on pc�i>>.t �•�it�h tl�e presezlt ca:�� : j''7('_ �1c�VC' I"10i:E'_Cl ti1�1i= L�1�'1�C` ].3 CCill i�_C:��:1:c1�:>':� cZl1t.I1Gt l-Ly for tl��e propo:>i_',�i_ori th�x:� t;i�� r_:i i�y si�o�.l�� s::t forth �c�:�:_�c�_i'ic ��'::�.ric'=�?-d.�; t.0 <<,��1_�� , t-v ��-I�i-�.i.CF,t.in.7�; S�oY' :-fJr�cj'u I --US''. ��C t+i:t.-i_l:� ;il��i t:�7:�t i:L C��'111.�1�_ O�' ��i:_' ii:�I_?i?1t: 1.� cll":)l_-1=I'<:i�:"y c.E_Ci llit?CS,�_1_ \di1C21 i:�1c'SC Si.;�.lI1C,1�lYCaf� �,;r'f' ]iZ^i:. �n� I�1.int1 a �t� �;�� , 9 5 i�!.;•;. 2ci a� 5 G U . (I,;:;,_��i�.:._ �_:_, �?ir)iJ�1_C�C. } L'it::Lll� 7��.�.l;i.� �� C�1.�::y' G� �.- .1.: T`i i J 7U_; . - _ ._---------_ -----___�_.._..__....___------ f'1 J.Il Il a _1_J% � .L> / � 1 F��/ 1`t . '�`!'. L U �r;� � 5�) �_L_3�l.i 1 i Golc�e�1 �- C�_t:y c�:� S'-_ Lo�_�i�� .',:,�c;; , 2C 6 I:;;_�•i-�, _.�.------------------------------------ [�G, 12?. I�i.:;. 2c. �>%0 (:L9C>;) ; G1��:?1: �% C; _.•, o` I_�ir.nc�z�;c��^i=_;, sur�?-,� . ------------------- I�'. Sutl„t�:U'V ' `.l'll: Y'!"��0?1C1�I1� }1c.:� li1G'� u1_1 c j�}"�_�_]_Ccli7.�_^ E;��F'.C:! L 1C starxdards. It: :i.s �zot cl-eati_tic� a izuis�iilc� i�y aizy st:rect-.1i of the iiu.�giriatioi;. It is not h�LC petil�ioniz�c� ior a vari_ance. Ii� i.s s:en.iny to r.et-.ain z s}�.�ci_zl u;;c ��er::lit wliich �•�as c�ranl.�d t:o i.t after a norir,al, a3-�:1 coi��Y.lcte Si_i�c. 1'lzn Rc�vietia for a use �ahich is f:ull.y c��mp��t=ib�_c. ��:ith j�J"C'.VLOUSI�� C'.St:.c7�Jt_l;}1('_c;� GUillllc� CF.1{�C`C�j01".1C`�; . 1_�S i)�C'_C::1.i11 U:;c l'.�T:!;ii.l-_ :cl�c;itlii. �ic�l_� 1_�c.� t.<Z�ccn <<t:��y. 111 j)%l l'�:.:LCIl.� �".11" � LIl.i1 cl])�;!1 �..�.%li7��; :_�li'_)t) �.(� ilCi'� �>C �)O��1i! I.1.�. •'.�'ii LC) �,�.li:(� t=}ll' Vi1C�l1r'. <-1iZCl� 1.C':;j)r)',"1C�1.'ll �. �.)�'_� .l_t'V(`:; � ' �i :. A . t , �� Oii.i'�� `y' (��il��:CtCi UT7]=C:""l ,U :ci .>l�% c�1.�:�::1C,i'.(`Q _�_i1I1C;U::.'jC` C)f: :iRCi. ! <�i] �i: . �.�):iC �_�� i1:1C� �-.U.:t:"1 t-.1:f. ., :L1��=0 c1 I_(tC�li1.1'i_'i;iC:ii�: � �l:li: ]"�'.i_;�):%I"�.:.��;`�!l� Tt'11;;�" t;�°.�.)<. �`l V�t'_":;_�2i"iC:C'_ i:?'_ :i,t_:� t1i;C. O; :Lf::; j�rC)i��;;'�-4�� , �ZC�SI��'CtrUl.�� SL1��i�t1.t.FnC�r � � C�iJ��i.2 .� i;E�iVi�l��T � ''' i /'; �' ;, '� � t S �-_ . ,a ; � t � � t , < t: I3 y .,.. �. � `�/..-: ':� �. ° . , d �' ::�--- .._-- ---- Don�a1_;_ C. F�d.i_1lc;:e �— ----- Tliirty-7;.ic3;��1� F'l.o��r , ID� To�.:c,.- 80 Sout�z i�;ic�1:�IZ St.r_cc�i�. I��1in�ne�.�p� L:i_�_ , ;-Iiz�;�e:;o�a 5��2 Gt2 3r 1_--;�;i;0 • I,R,�;,.,-,��;L'__.� ?-,�:, �u -i�.: ,.-�;, �� Vi.i �� v_:�'._._•; ��'1'F;�_� : �}..�� 7 , 1_97'1 . • � . —].4— 1� � i � ��4. .. . . . .` I Si. FAUL CITY PLANNING A Speci�l Use �ermit has been a��roved for the facility as irdicated below. 4 copy o� the final plan is attach:.�d for yoar recor�s. Other co�ies have been delivered 'ce the Divisian of Nousi�g and Bu�ldin� Code Enforcement and to the Deoartrne�� of P�!bl i c t�Jorlcs , Di v i s i an cf O�erati ons. Uport appl i catl on, they wi i 1 issue the necessary permits based up�;r ihis plan. Develapment or the facility rust substant?ally confo nn ta the attacl��d plan or the permit may be voided. f� Da te: • 3-10-77 u�fC'I�?.'>�' �y' � �� Zoning File Number: � � sos� ��1 �-z��d�-� . R�,�licant's name . Green Mill Inn, Inc. �G��' '" L��-- ``• 57 Hamline Ave. So. � address : St Paul , Mn \7 ^(\7 I//^J d. ,�.. . . . . � , � . . A{(/1..� . . �� / �•J `✓' � / � �.�i � Purpose parking lot ', Locatfon . North side Grand Ave. between HamTine and Albert . Legal descriFtion : Lot 24, Slock 1 , Wann's Addition . � Plans apFroved . 3-9-77 _ Final pians dated � 3-2-77 received . 3-3-77 Ccmments . �„ �� SPECIAL llS� °ERMIT APPROV�L �': s; «��a•t*�•`+* CITY OF SAINT PAUL ? a DEPARTMENT OF COMMUNITY SERVICES � ;..�..: " ... DIVISION OF HOUSI.NG AND BUILDING CODE ENFORCEMENT •445 Ciry Halt,St.Paul,Minnesota 55102 George Latimer. Mayor 612-296-4212 August 16, 1977 - ,�"��s� RECEIVE� r�� ,�.� 1977 M E M O R A N D U M "� Rubll Wu�t ' TO: Mrs. Ruby Hunt, C ilwoman � FROM: Glenn A. Erickso RE: �t�. 3�fi�+�a- b� �2 parkir�g l�t plans a;pproved administrativel�'Tsince F1c�obe� 25, 197�, the date of the new code, of these d!� , ��Z �m:=�!a�s. �e�s��=- ��°t�t�`�.�--��tt�ld#r�.En�ilr�;- ��'�'�+ been mea�ured from tYa,�� z�,earest po�r�t of the b�tilding to nearest pc�int of the parking lot in a straight line as the ordinance directs. G.A.E. ��O � O' CONIVOF2 c'x hfANNAN ATTORNEYS AT LAW PATRICK J.O�CONNOR 1747 PENNSYLVANIA AVE,N.W. fHEDERICK W.THOMA9 �oen.wa�Teas THIRTY-EIGHTH FLOOR, I DS TOWER WASH�N070N,o.C.20006 THOMASA.KELLERIl[ 80 SOUTH EIGHTH STREET f20z)7Ci5-B700 MICHAEI E.MCGU�R� � �� RICHARD L.POBT PATRICK J, OCONNGR KENNETH B.JONES,�R.� � MINNEAPOLIS, MtNNESOTA 55402 WIILIAM T.NANNAN• R06ERTJ.CHRISTIANSON,JR. JOHN J.�LYNN CHARLES B,FAEORE -- H.ROBERT Hl�lAEfi• FRANI( J.wnL2 (g12) 341-3800 JOSEPM F.DILL'ON JOHN W.ROGERS TF�OMA�i N,qU1NN+ DONAID C.wILLEKE � TELEX 29-0594 , ' . HOWARD G,c[IDMAN• . JAME`i R,DORSEY TEI.ECOPiER 612 341-3800(2Sfi) OAVID R, MELINCOFF� ANDREW J.SHEA �- DELANCF_Y W.OAV15� OOUGIAS M.MCMILLAN - R7GHARD G. MORGAN CHARLES D.REITE PHILIP R,HOCMBERG• WILLIAM R.MCGR4NN AOUSTIN LOSA.DA* DAVID. BURLINGAME* THOMnS V.vAKERICSt WALTER C.PARKINS DOUGIAS M,C:�IRNIVAI+ MICHAEL M.WHALEN ABOGA00 MARTIN M.BERLINER* TERENCE P.BOYI.E-• KENT E.RiCHEY ALFONSO X11�42 1710 SECURITY LIFE BLDG. HOPE 5.FOSTER• JOHN J.SOMMERVILLE MADRID 14,SPAIN DENVER�COLORADO 80202 BR14N P,PHELAN� JAMES A.RUBENSTEIN � � MICHAEL J.CON�ON+ NANCY F.FOWLER • (9�)228-1205 (303�573-7737 M�CMAEL PAT{ZICK GFORGE CHlti2LE5 T, NIXON DONALO S,ARHOUR< JEREMIAN J. KEARNEY LAWRENCE A.JONES• JOHN B.BLATZ II[ � -- RALPH F,BERLOW U0 2 3-19 7 21 � WiLLIAM C.KELLY(19�8-1970) 15 -August� 19 77 oF COUNSF_� � � � � JOSEPH F, CASTIELLO+ . FRED D.THOMP50N* JAMES D. McKEY1TT* • •NOT MEMBER OF NINNEBOTA BAR Honorable Members of the St. Paul City Council � c/o St. Paul City C1erk 386 City Hall and Courthouse St. Paul, Minnesota 55102 „�^ . L . y .. . *-, _ r n n^+Z ��: Administ��:�a-�:ive .CtCV.LCW �.� uu��u:�ny rcri�ii��: ,.1c. 02�� , � � (Parki.ng Lot-Green Mill Inn, Inc. ) Honorable Members of the City Council: At naon today, we rec�ived a capy of Mr. Regnier' s letter addressed to you pleading certain raatters with rESpect to the above-entitled matter, together with a copy of a document entitled "Memorandum of Law" prepared by Mr. Regnier. No response is made to the matter of the 1975 re- zoning of Mr. Sullivan' s lot, as the matter is xelated in Mr. Regnier' s letter, except to say that the record is clear that Nir. Sullivan �aanted his property zoned B-2. Tl�iat is admitted. He wanted, in the worc�s of his attorney, "to pr�tect his own property by having it remain commercial. " As to the document entitled "Meznorandum of Law, " it is our position that there are a number af conclusive statements contained i:herein that are incor�^ect and clearly deserve a reply. Conclusions are made therein and matters ar� stated as facts w�iich either have not b�en accepted as such or are c].early not true. Accordingly, th�re is enclosed Honorable Members of the fit. Paul City Council Page -2- 15 August 197? , with this letter to you and also filed with the City Clerk . as a part of the record in this case, the Respondent' s Reply . to Appellant' s D�emorandum. � We appreciate greatly the consideration you have given ta this matter. � � � Very sincerely yours, � c�zc�� . �-�i+�._._ . Donald C. Willeke DCW/n lw Enc. cc: Pierre N. Regnier, Esquire � � Before the CITY COUNCIr� OF THE � CI'i'Y OF ST. PAUL In re Administrative Feview ) . � � of Issuance of Building ) � Permit No. 029872 ) ) ZONING FILE NO. Gerald F. Sullivan and ) 8144 William L. Bartelheim, ) � . Appellants, ) ) vs. ) MEMORZINDUM OF RESPONDENT ) IN RESPONSE TO The Gresn biill Inn, Inc. , ) APPELLANT'S MEMORANDUM ) Respondent, ) ) Property Subaect to Appeal: ) 1361 Grand Avenue ) Lot 24, Block l, Wann' s ) � Addition to St. Paul ) I. - THE CT.TY COUNCIL CANNOT IGNORE THE FVORDS "NEAREST POINT. . . TO THE NEAREST POINT" IN §62. 103 (a) OF' THE CITY ZONING ORDINANCE. The Appellants have constantly ignored the ��aords "nearest point. . . to nearest point" as they appear in Section 62. 103 (a) . In this case, the point of the Respondent' s premises nearest to the parking lot is not even on the "sidewalk side" of the lot. It is on the other side o.f the lot, and is about 200 feet, more or less, from the nearest point of the parking lot. The Appellants have constantly striven to read a "pedestrian" requirement into the Ordinance. There is none. The Ordinance uses the word "measured,." not "walked" or "paced. " Measurements of distances can certainly be made through buildings. Indeed, as any person knows, they can . be right through mountains, and can be done with great accuracy. The 300 foot requirement is clearly a radius -- hence the two uses of the word "point" in the Ordinance. If the City Council had meant to prescribe a legal pedestrian path, they could have easily and clearly done so. In this a_nterpretation the Respondent is supported by long practice of the Division of Housing and Building Code Enforcement of the City of St. Paul . If a change is to be made in this interpretation, it should at least be prospective, not retroactive. Counsel for the Appellants has obviously misr�ad the ��s� cf ?i�tle C�:�?da Rro; � er Restailr�r.t.�� Inr. , v. Cii-y �f Little Canada, Ramsey County District Court File No. �12802. T1-�e Ordinance then in effeet which gave rise to that case sta�ed that: "No license shall be issued for premises located ��ithin 1500 feet of any school building or church building located within the limits. " Obviously there is no language in the Little Canada Ordinance about "the nearest point of the building to the nearest point of the off-street parking lot. " But if Anpellan ts insist on a pedestrian path , let them have their way• The m�asure is approxi_mately_ 295 feet if one walks normally, and not � usiilg inilitary-style s uare corners. -2- II. � THE PARKING LOT IS NOT A NUISANC� AND fIA.S NO`i' BEEN DETER'�'IINED TO BE SUCH. ' � In a flight of assumptions which is little short of amazing, the Appellants would have this City Council first assume the Respondent' s parking lot is a legal nuisance and . then that is should be banned. It is not a l.egal nuisance. It is a fu11y permitted use -- a fact in which the Board of Zoning Appeals concurrs. Whether Mr. Sullivan requested B-2 Zoning for his property and whether Mr. Bartelheim acquiesced in it, is not even important to that fact. The fact is that the whole area in question is "B-2. " The parking lot stood vacant, and "for sale" for years, next to Sullivan and Bartel- heim' s B-2 lots and they never made any moves �to acquire it, seek its down-zoning or seek down-zoning of their nroperty. Now they are seeking to twist the plain meaning of the words of the Ordinance in a strong attempt to undo the years they wasted. By seeking to label a parking lot as a "nuisance, " they have engaged in yet another distcrtion oi the Zoning Ordinance. "Nuisance" is clearly defined in the Zoning Ordinance. "�60. 365 Nuisance : A substantial unreasonable and continuous invasion of the ase and enjoyment of a property right which a reasonable person wauld find annoying, uripleasant, obnoxious, or offensive. " It is almost hurnorous to note thai: the ve next definition is of an Off-Street Parking Lot: -3- � "§60. 366 Off-S�treet Parking Lot: A facility providing vehicular parking spaces along with adequate drives and aisles, for maneuvering, so as � • to provide access for entrance and exit for the parking of more than three (3) vehicles. ° Is an "Off-Street Parking Lot" a "Nuisance"? Of course not. �r I. THE APPELLAlVT5 IGNORE THE �VORD "UNREASONABLY" IN SECTION 62. 108c (3) OF THE ZONING ORDINANCE. Appel:Lants cite in full text the provisions con- tained in Section 62. 108c (3) cf the Zoning Ordinance and pror.eed here as they have elsewhere to recite the effects that u parkir.y lct, u��;d�r "w�rst-case assum�>tions" could have on ac�joining commercially-zoned pro�erty. kespondent is not claiming that it is seeking to construct a rose garden. It is buildin g a parking lot like any other parking lot in a commercial zone throughout the City of St. Paul. As such, it will have somewhat of a different effect than the junk- filled vacant lot which the propertl� was before Respondent' s purchase. But it is not � se unr_easonable , anymore than the use of part of the rest of the zon� in question for a Sinclair Gas Station is unreasonable. P,s to the allleged lare of headlights , the Respondent r.as repeatedly off_ered in writing to build as high a fence as -4_ � . ! _ e � � 1 � � the neighbors �aant and as the City will allow. The Respondent is understandably weary of the repeated charge that nothing is being done in this regard. As to otYier automobile noises, it should be remembered that Mr. Bartelheim lives next to a gas station on the corner of Hamline and Grand -- not on some secluded cul de sac. And Mr. Sulli,van lives not far from that same location, all on lots zoned B-2 . Would a parking lot have an unreasonable effect on the Appellants an d their property? Hardly. A few slides showing property locations, toqether with general allegations that this parking lot will be used like the pa.rking lot that it is intended to be, do not constitute a basis for finding e:itYier itiat ttiere is a pubiic r7ui5ai�ce ur c:-�a� the health, safety and *,�eliare of the puk�lic �aill be adversel�:• affected. IV. � THE RECENT DECISIONS OF THE D�INNESOTA SUPREb1E COURT SUPPORT THE RESPOND�NTS. The Appellants citE the 1946 case of Alexander Company vs. City of Owatonna, 222 Minnesota. 312 , 24 N.W. 2d 244 (1946) . The opinions in more rec�nt cases squarely address the issues at hand. The instan t case clearly falls unde r the law of � -5- Ostrand v. Village of North St. Paul, 275 Minn. 440, 147 N.W: 2d 571 (1966) where the Minnesota Supreme Court held the Village was arbitrary in den_ying a Special Use Permit � ' where the use caas in compliance with zaning ordinances. The Court stated in 275 Minn. 446, 147 N.W. 2d at 573: His application met all existing standards of the building and zoning ordinances of the village then in effect and appears to have been rejected prin- cipally because of neighborhood opposition. In denying it, the village council did not follow the recommendations of its planning commission or con- � sider the reports of its police, fire, or health departments to the effect that no potential hazards would follow if an apartment building were constructed on plaintiff` s property. To the same effect see Alexan der v. City of Minneapolis, 267 Minn. 155, 125 N.W. 2d 583 (1963) ; Olsen v. City of Minneap�].i�, 263 Minn. 1., 115 N.W. 2d 734 (I.9h21 � � The use which respondent seeks is, in this case as in Inland Constr. Co. v. City of Bloomington, 292 Minn. 374, 195 N.W. 2d 558 (1972) compatible with the zoning of the area in which the lot is located. Here, as stated in Inland, the burden of proof required to obtain a Special Use Permit is much lighter than that required to obtain a variance permit. The Minnesota Supreme Court went on to state in language that is particularly on point with the present case: We have noted that th�re is considerable authority for the �roposition that the cit�r should set forth s ecific standards to apply to applications for s�c al-use p permits and that a deni.al of the permit is arbitrary and illegal when these standards are met. 292 Minn. at 3�78, 95 N.G7. 2d at 560. (Emphasis supplied. ) Citing Zy1ka v. City of Crystal , -6- 283 Minn. 192 , 197 , 167 N.W.. 2d 45, 50 (1969) ; Golden v. City of St. Louis Park, 2G6 Minn . 46, 122 N.W. 2d 570 (1963) ; Olsen v. City of Minneapolis, suPra• . V. CONCLUSI�N There is no basis, either in law or on the record in this case for finding that this permitzed use of a B-2 Zoned lot, violates any of the standards of the Zoning Ordinance -- either �.s to location or as to use. :It is a park- ing lot, not a thr_ee-ring circus or a sauna. It meets the standards imposed under the Ordinance for parking lots both as those standards are set out in the Ordinance an d as they have been uniformly enforced by the City' s admin.�strators for a lonq time. Its owners have gone out of their way to accommodate the abutting praperty owners who stood by doing nothing for so long. It is a legal adjunct of a small business of the type the City needs if it is to survive. Accordingly, it is respectfully submitted that the appeal should be denied. Respectfully submitted, O' CONNOR & HANNAN By: � Donald C. Willeke Attorney for Respondent 3800 IDS Tower Minneapolis, Minnesota 55402 Telephone: (612) 341-3800 -7- � . , • .. � . LAW OFFICE.S OF JARDINE, LOGAN & O'BRIEN DONALD M.JARDINE 1350 NORTHERN PEDERAL BU[LDING JOHN M.KENNEDY,JR. JERRE F.LOGAN WABASHA AT 6TH EUGENE J.FLICK JOHN R O'BRIEN ST.PAUL,MINN. 55102 RICHARD T.DOLEZAL GRAHAM HEIKES CHARLES E.GILLIN GERALD M.LINNIHAN (612) 227•060� JAMES J.GALMAN ALAN R.VANASEK PIERRE N.REGNIER AUgUSt �Z� �9�� MARK A.FONKEN GERALD E.WALLIN Honorabl e Members of the $t. Paul PATRICK M.FLYNN �1 t,y �OU11C1� LOUIS R.TILTON KENT E.CHARPENTIER c/o St. Paul City Clerk 386 City Hall and Courthouse ROBERTJ.TYRRELL St. Paul , Mi nnesota 55102 ofcounsel RE: Administrative Review of Building Permit No. 029872 (Parking Lot-Green Mill Inn, Inc. ) Honorable Members of the City Council : On August 4, 1977 a Public Hearing was held by the St. Paul City Council regarding the Appeal filed from the issuance of the Bu�ld�ng Permit to construct a parking lot accessory to the Green Mill , Znc„ such parking lot to be located on the north side of Grand Avenue between the residences occupied by the two appellants. The final vote on that date was to lay over the voting on this matter until all City Council persons were present. Therefore, this matter was laid over until August 16, 1977. I am submitting herein and filing with the City Clerk for part of the record in this matter a Memorandum of Law discussing two of the grounds raised by the appell�nts in this Appeal . I am submitting this Memorandum and this letter directly to the City Council and to the attorney for the Green Mill , Inc. Based upon my initial conversations with the office of the City Attorney, I have refrained from discussing this matter with the St. Paul City Council members except at the Public Hearing. I have also advised my clients to do likewise. It is the opinion of the City Attorney's office that the City Council when acting in a review capacity of a ruling by the St. Paul Board of Zoning Appeals is acting in a quasi-judicial manner. Therefore, based upon previous opinions issued by the office of the City Attorney, it is improper for a party to such a proceeding to hold an ex parte meeting with a member of the City Council priar to or during the hearing process. Therefore, my failure to meet and confer with each one of you individually regarding this Appeal is not the, resu�,t of my not desiring to so confer with you but it is th�, resul't. of a �egal opinion that such a consultation with you individually�w,ould �e0pardiz� ;the legality of the entire proceedings. I am therefore sabmitting �his''letter and Memo- randum to you which would also be made part �o� the record in this case. . _: I will not be available the morning of August 16, 1977 so as to be present at the City Council meeting. I have advised my clients, however, that it is my understanding from the Motion that was made at the last hearing and, . • . Page 2 Members of the City Council August 12, 1977 upon the advice of the City Atto�ney the only part of this proceeding that has been continued is the actual voting by the City Council . If the City Council determines to allow the Public Hearing to be reopened and new facts are presented to the City Council , I would respectfully request the oppor- tunity to appear at another hearing to refute the facts which may be pre- sented�contrary to the position of my clients. Following the conclusion of the Public Hearing on Au�ust 4, 1977, a letter signed by Gerald F. Sullivan addressed to David Hozz:,a, President of the St. Paul City Council , dated July 21, 1975 was introduced as part of the record by Councilman Hoz��. While I do not feel that letter is relevant to the particular Appeal in question, and does not have any relevancy to the Appeal brought by Mr. Bartelheim, I would like to submit the following explanation to that letter. Prior to the adoption of the new zoning ordinance Mr. Sullivan's property and all the property east of it were designated as commercial property. The original map proposed by the Planning Commission, and first considered by the City Council in 1975 indicated that Mr. Sullivan's property would be down zoned to an RM-2 and the remaining lots east of his property would be zoned B-2 (commercial ). Mr. Sullivan then circulated a petition against the B-2 zoning of the two lots east of his property, which include a lot upon which this proposed parking lot would be located and Bartelheim property. Mr. Sullivan then contacted some of the Council people and indicated his opposition to the proposed B-2 zoning adjacent to his property. Mr. Sullivan supported an RM-2 zoning and the two lots east of his property. Mr. Sullivan was unable to attend the City Councilimeeting on July 16, He gave the petition to Douglas Skor�a �ras the President of the Surranitt Hill Association and who spoke to the City Council regarding zoning matters on Grand Avenue. Rttached hereto is an Affidavit signed by Douglas Skor dated August 10, 1977. The City Council having failed to grant Mr. Sullivan's request then contacted attorney Joseph T. 0'Neill requesting assistance in his opposition to the zoning of the lots east of his property as commercial . Attached is a letter of August 10, 1977 signed by Joseph T. 0'Neill which confirms the fact that Mr. Sullivan did in fact contact him. Mr. Sullivan then determined that the expense of fighting the commercial zoning was to great and at that point de- termined that the best avenue of aporoach for him would be to protect his own property by having it remain commercial.. . At that point, Mr. Sullivan wrote the letter of July 21, 1975 to Councilman Hozza requesting that his property by zoned B-2 along with the adjoining properties. This explanation is submitted so as to clarify any misunderstanding in this matter. It is quite clear that Mr. Sullivan at all times in 1975 and at the present, supports a residential zoning of bothhis property and the two lots east of his property. • � , � Page 3 Members of the City Council qugust 12, 1977 On behalf of the appellants we appreciate your patience and attention which was given at the hearing of August 4, 1977. t�Je respectfully request that you give full consideration to the Memorandum of Law which is attached hereta, Yours truly, JARDINE, LOGAN & 0' RIEN i�� Pierre N. Regnier PNR:ng encls. cc: Donald C. Willeke Attorney at Law 38th Floor IDS Tower 80 South 8th Street Minneapolis, MN 55402 Harriet Lansing City Attorney 647 City Hall and Courthouse St. Paul , MN 55102 A' F' F' I' -D A V z T STATE OF MINNESOTA ) . ss. COUNTY OF RAMSEY ) Douglas L. Skor, being first duly swo�n, deposes and states as follows: 1. I am a resident of the City of Saint Paul and currently reside at 688 Fairmount Avenue. I am a past president of the Summit Hill Association. During July of 1975 I was president of the Association. 2. On July 16, 1975 I appeared at a hearing held by the Saint Paul City Council on the proposed new zoning ordinance as it would affect Grand Avenue. At that time I gave a brief state- ment on behalf of the Summit Hill Association concerning the zoning of Grand Avenue. 3. Shortly before the hearing I met with Gerald F. Sullivan concerning the proposed zoning for certain property on the north side of Grand Avenue near its intersection with Hamline Avenue. Mr. Sullivan presented me with a petition signed by him- self and other residents of that vicinity, opposing any commer- cial zoning for this property, and asked if I would present the petition to the City Council, since I would be speaking anyway. I agreed to do this, and as part of my presentation to the City Council on �uly 16, I read and submitted this petition and also spoke in support of it as president of the Summit Hill Associa- tion. 4. Attached hereto is a copy of the petition described above. Dougl . S or �� Subscr�b�d�and sworn �.o before me this ✓� �`day of ' � , 1977 . ��-�� ` . �c.�,r� Not ry Pu ic '!�'��:�� -2- . , � �ji/7� /- . 'Z � i • TO THE ST. PAUL CI TY COUNCI I, , � . � �� We, the undersigned, ad�acent property owners ob�ect to any spot re--zoning to either B-1 , B-2 or B-3 classification for I,ots 24 or 25 in block 1 , Wanns Addition to St. PauZ, Ramsey County, Minnesota. . � �� L�O�-�.Q. � �� 6�3 �— ��- s�� .� �.� � � �� — ��= �� a �� /�. �_� 7- i�- ��s" �-y � � � ( � �36 d �-u-�f � -- / � - �,� (�-�.t*-s��„ o � �, �� 7�� I3 � d � � . �-� � � - �s= ��— �� /3s�' 7 7�2 �t�"� : � C2�t�y - � � � -- � � � , _ ...� - ..,...:,>..�.:._:�.�_��....,,�.�..�...,..�.::��w.._��..�.,.y:...,�.:.�..... . . � - :.�..,.,at:.,....s.�;:::,s..�.,,...s�:.w.....�_ �.�..,-.,�.-i�:a.e�a....., ...� ._._. . .. ;..:. . . ��r � C.• ) ' O'NEILL, BURKE AN� O�NE�LL LTD• TELEPHONE A-I-I-p�ZNEYS AT LAW g505 (612) 227- 60 WEST FOURTH STREET �BLE ADDRE55 SAINT PAU L,MiNN ESOTA pBo 55102 JOHN B•BURKE,JR• OF COUNSEL JOSEPH T.O'NEILL G�EN M.CADLE pp-rItICK H.O�NEILL gRIqN F.LEONARD 1„L�CHAEL R.O'BRIEN August 10, 1977 ' To Whom It May Concern: 1975 , I was contacted middle of July, Mr, Sullivan, , Sometime in the Grand Avenue• requested mY by Jerry Sullivan of 1363ber of years, to resist a proP�sed rezoning who I had kasW anf attorney ann' s Addition to the assistance B1oCk One, W Grand of Lots 24 and 25 . address is 1355-1361 City of St. Paul. The street Avenue. the lots were me that although roposed Mr. Sullivan informed that it was being P presently zoned commercial, to go to B2• Mr• Sullivan wanted our by the City felt the council should rezone was the waY all the rest of that representation because he to residential since it side of Grand Avenue was zoned. all the me that considerinq h he was o forward, althoug Mr. Sullivan later informe factors, he did dorlof having the lots zoned residential• definitelY in fa Very truly yours, O'NEILL� BURKE AND O'NEILT, LTD. r ► By ose . O'Neill to a city ordinance that prohibited the issuance of a liquor license to a premise within 1500 feet of a church or school . That ordinance, just like the ordinance in question, did not specify whether the distance was to be measured by a straight line or by the shortest public right of way. The City Council decided to measure the distance by public right of way rather than by a straight line. The Court in upholding the interpretation by the city council held: "Within its discretionary power, the City of Little Canada could determine what method of ineasurement was to be used where no method is specified. Unless the method of ineasurement is unreasonable or arbitrary, the plaintiffs are not in a position to invoke the power of this court to void such a discretionary decision. The councils' decision to measure the distance by public right of way does not constitute an unreasonable or arbitrary use of discretionary power. Summary judgment must, therefore, be granted in favor of the defendants". One St. Paul City Council member on August 4, 1977 was concerned as to what protection a purchaser such as the Green Mill Inn, Inc. has when the City Council is left to its discretion in interpreting ordinances. One practice which is uniformily followed is to enter into a purchase agreement contingent upon the ability of the purchaser to obtain the necessary permits and licenses to use the property as he desires. Perhaps such contingency exists in this case and that is why Mr. Jerry Kelly was the owner of record when the permit was applied for. Furthermore, as the city attorney stated, a purchaser is presumed to know the law. In this regard, we submit that any person purchasing property and applying for permits must realize that the ultimate decision as to an interpretation of the ordinance lies with the City Council since the City Zoning Ordinance provides for administrative review of the issuance of any permit by the Board of Zoning Appeals and then by the St. Paul City Council .This City Council has the ultimate authority of interpreting the city ordinance and not the City Zoning Adminstrator, Planning Department, or Board of Zoning Appeals. II. THE CITY COUNCIL HAS THE AUTHORITY AND THE DUTY TO REVIEW THE ISSUANCE OF A PERMIT WHEN THE ISSUING DEPARTMENT HAS FAILED TO PROPERLY APPLY THE CRITERIA ESTABLISHED BY THE CITY COUNCIL IN THE ST. PAUL CITY ZONING ORDINANCE. �; The relatively new St. Paul Zoning Ordinance contains provisions which help to avoid a situation created by the issuance of a permit to construct a parking lot accessory to a bar where such parking lot is to be located on a lot totally surrounded by residential homes. The residents on Grand Avenue were distinctly assured by the St. Paul City Council in 1975 that the new zoning ordinance would protect them from the intrusion of nuisance uses near to residences. The zoning code as adopted provides the means to prevent the nuisance from occurring and the City Council can and should utilize this authority in protecting the character of this neighborhood. When applying this review authori�y as provided in the zoning code, the St. Paul City Council should keep in mind section 60.200 on page 1 of the new zoning code relating to the intent and purpose of the ordinance. The very first purpose stated in section 60.200 is to "promote and protect the public health, safety, morals and general welfare of the community." This purpose section also provides that a zoning ordinance is adopted "to conserve property values" and "to protect all areas of the city from harmful encroachment by incompatible uses". Section 62.108C of the zoning ordinance contains specific -2- - `. - , provisions which, unlike the old city zoning ordinance, allows the St. Paul City Council to achieve the purposes as stated in section 60.200 of the ordinance when dealing with parking lots. Section 62.108C provides as follows: "In reviewing the site plan, the planning Comnission shall consider: 1 . The location and design of driveways providing vehicular ingress to and egree from the site, in relation to streets giving access to the site, and in relation to pedestrian traffic. 2. The traffic circulation features within the site and location of automobile parking areas, and may make such requirements with respect to any matters as will assure: a) Safety and convenience of both vehicular and pedestrian traffic both within the site and in relation to access streets. b) Satisfactory and harmonious relations between the development on the site and the existing and prospective development of abutting land and adjacent neighborhoods. 3. The arrangement of buildings , uses and facilities of the proposed development in order to assure abutting property and/or its occupants will not be unreasonably affected. 4. The Planning Commission may further reuiqre landscaping, fences, and walls in pursuance of these objectives and same shall be provided and maintained as a condition of the establishment and the continued maintenance of any use to which they are appurtenant. 5. In approving the site plan, the Planning Commission may require marginal access drives where such marginal access drives are necessary for safety. " The City Council in 1969 found that a nine car parking lot would have an adverse effect on the abutting property and the neighborhood and at that time the City Zoning Ordinance did not contain the specific criteria and factors to consider as does the present ordinance as cited above. The testimony and evidence in the form of charts and slides clearly evidence that the planning department when it approved the site plan (note: the Planning Corr�nission never approved the site plan or reviewed it) apparently totally ignored certain factors which definitely will have an unreasonable effect up�r� abutting properties and the neighborhood as a� whole. There is no provision to protect the Bartelheim and Sullivan homes from the injuries of carbon monoxide. It should be specifically noted that the bedrooms of the Bartelheim residence will be located four feet from the parking lot. The engineering department indicated that it will be up to the applicants to prevent the glare of head- lights, however, there is nothing to indicate from the plans how they intend to take care of the glare of headlights. There is nothing shown which will evidence how the applicants will control the noise of the automobiles in this parking lot especially in view of the fact that this parking lot would be used in conjunction with a bar that is open until 1 :00 A.M. The plans do not show any provision for lights on the lot and therefore, we do not know whether �the lot will be dark and therefore unpatrollable by the police or whether there -3- , ' . + , � will be many lights shining into the residences adjoining and abutting the lot. The applicants have never answered the allegations made by the appellants regarding the design of this lot which will not allow for the total number of parking spaces given the fact that they have sloped off the back portion of the lot eliminating the 40 foot requirement. The problems presented by this parking lot are the same problems which planners have submitted as grounds for criticism of urban commercial strip zoning. In a leading treatise on zoning, American Land Planning Law by Williams, the author points out that commercial strip zoning is not an efficient way to promote good business, and the existence of many curb cuts tends to interrupt traffic flow and also result in more accidents; and commercial frontage tends to have a blighting influence on residential development nearby and behind. All of these problems as foreseen by planners and other jurisdictions and as presented by this particular case before the City Council can be prevented by the City Council exercising its authority under the Zoning Ordinance and applying the criteria as set forth in section 62.108C. The city attorneys seem to infer that a recision of the building permit would be a down zoning and therefore illegal . It should be kept in mind that this property zoned B2 can be used for many uses other than a parking lot and there- fore by denying this parking lot, the city council is not denying the Green P�ill , Inc. all reasonable use of the property. There are many provisions of the new zoning code that would be declared invalid if the law provided that once a property obtained zoning under a spe�ial use district, it could not be regulated or controlled by other provisons of the zoning law. The staff of the Planning Department advised the Council and the Council in turn advised the citizenry that the new zoning ordinance contained protective devices which prevented harmful encroachment of imcompatible uses and nuisances even though a property was zoned so as to permit a particular u�e. That advice is con- sistent with the Minnesota Supreme Court of Alexander Company vs. City of Owatonna, 222 Minn. 312, 24 NW2d 244 (1946) . In Alexander, a city ordinance provided that a permit was needed for curb cuts to any drivein business. The property in question was zoned corrnnercial which allowed a drivein business. The City Engineer granted a permit. However, the City Council conducted a hearing and ordered that the curbs be replaced and the curb cut permit be rescinded. The plaintiff argued that by refusing to give him a curb cut permit, they were in fact denying a permitted use of his business. The Supreme Court of Minnesota upheld the right of the city to deny the curb cuts in this commercial area of the city. The Court held that the general police powers of the city granted them such authority based upon the evidence that these curb cuts would be a traffic hazard. In doing so, the Court held that public safety is a sufficient factor and concern of a city, so much so that a person can be denied the right to use property for a legally perrnitted use if it will constitute a nuisance or endanger the public. It is the appellant's position that the overwhelming evidence in this case evidences the fact that this parking lot will be a nuisance and will have a direct effect upon the health, welfare and safety of the adjoining property owners and the neighborhood. For these reasons, independent of the manner in which the interpretation of the 300 foot provision is resolved, the construction permit for this parking lot should be rescinded. -4- _ ,�. ; . ,, . . � • CONCLUSION The appellants respectfully submit that the building permit in question be rescinded based upon the grounds submitted in their notice of appeal dated July 5, 1977. This memorandum only highlights two of the grounds for the appeal and does not in effect waive the other basis for the appeal . The appellants submit that the building permit should be rescinded on a finding that the most logical and practical interpretation of section 62. 103A is to measure the distance from the nearest point of the building to the nearest of of the off-street parking lot by way of the shortest legally traveled route. Another basis for rescinding this permit which is independent of the three hundred foot (300) requirement is the failure of the Planning Department and Zoning Administrator to consider the criteria set forth in 62.108C of the city ordinance. Furthermore, the evidence in this case clearly indicates that the proposed use of this parking lot will be a nuisance and create an endangerment to the public health, safety and welfare of the adjoinging properties. Respectfully submitted, JARDINE, LOGAN & 0'BRIEN ��-'� Pierre N. Regnier Attorney for Appellant 1350 Northern Federal Building St. Paul , Minnesota 55102 -5- . � . , � ,�.�pt ��, `'� U� �t�� _ �� , f � �} - - - --' — - ---- \ - � -- � C� : : � _ . „ � ,�, `:_ , _ _ � `,., ��.� � _ , .. i i .,., �;-- _•__�._ , :: -:_ ,_.. ,_ . ` �\.. � a - — - � — --- — ---, ____� � , ,�� _� � � -� � , — -- � - -r . - - _ _ - -- _ ;; � '� `• � -,-- � � 1 � r � ��<� �' ' ��'`� ��F � °i'.�'°j� � �I �� p��o�;�� o 0 0 0 0 0 0' o o� a � �� , , � , , I v- � ; I .I � , : ; � w \ ' � ' ' ` ' � � � 1 � ' ' � � i i - ' 1 �;� n'�, � � � � i l i !�..�__ r � � � _ - � -.� ; i _ Q . , , - �''p"'�e�..r--�- � �.._. . � i.T_ _I_.._�+.�T �...�, ,.,,,,,� i— �- -j- i-- - -r �, V � , � � � � . f � � � . ► ,!, ; � � I � � � I � � � , �� ► �� ° � � -� ; ; � � ' I i I I � � � � I I � � '� � !; � � <i , i i ! ; i � � ,, --�,- � I I � � � ! ¢ .: o ��o � p � � p � :., i 4 � � � 1 � � �-- . ., , , �� , � � � 1oI I¢ o_ � ( �o c.n � � R'" � I :.;�•. .,,.s. , ' _ ' �-__ _... �'�`-�'-= i I -- - . _ . ...... . - ' ��------_ .._ _ _J __ - :- _ _ _ . _ - -, , �--_.______.-._.-_.`___�. _.-_`` � . - • --- =� r- -_ � , �'T..F1Ni7INC; IIUAi�ll SZ'AFF REPORT +�U�� 7, 1977 Plat Map � 8144 i: A��rrc:!�rrr's riart� . Messrs. Gerald F. Sullivan and �Jilliam � L. Bartelheirn - 2. CLASSIFICATION . � Amendment D Appeal � Permit � Other 3. Pv�POS�: . Administrative Review of Orders ISSUing Euildirl� • Permit No, 0`L9872 for Constructi�n of a Parking Facility 4. LdCATION . For Use by Patrons of The Green t�1i11 Inn, Inc. North side of Grand Ave. between Ham7ine and Albert 5. l.EGAL DESCRIPTION : Lot 24, Block 1,, Wanns Addition b. PRESENr ZONING: a-2 7. PURSUANT TO Zoning Code Chagter: 64 Section: 205 1'aragraph: Z B. STAFF INVESTIGATION & REPORT: Date: 6-1-77 $y� CLMCG � A. The appellants are appealing the dec�sion of the Zoning Administrator to issue a building permit to a71oU� construction of a parking facility for use by patro • of the Green Mi�l Inn, Inc. on property described above. � B. The appeal,prepared by Mr. Pierre N. Regnier of the legal firm of Jardin�, Lr -:n & 0'Brien as attorneys for the appeliant; charges that errors in fact and . procedure were corrur►itted and ihat the permit was issued in violation of Zoni-ng Ordi nance Secti ons 62.103 a, k & 1 ; 62.7 04, 62.104 i ; 62.108 a, b& c, and 64.209. Since the alleged errors are numerous and many of the charges ar� lackiny in specific detail , this staff report t�ill attempt to deal with each sect�on cited on a paint by point basi�. 1. To the allegation that the permit �aas issued in violation of Sect�ion 62.iO3 paragraph a, �,�e respond that (1 ) the building official has determinzd the subject site to be in the same zoning district as the principal use and less than 200 feet from the building i� is intended to serve, saicl dis±ance being sneasured as specified in the paragraph , . ard (2) the o:•rn?r has not indicated any intent to use other lots or parcels for parking. � tde therefore �eny the allegation and bi� the appellants bring their proof to the Board. � 2. To the allegation that the permit tilas issued in vio7ation of Section fi2.103 paragraphs k an�+ I , tde re,pond that the bui7ding o-Fficia7 reviewing , the �e nnit request inzerpreted these provisions to apply only to "require�" -_ off-street �arking and the propased pat�king f�ci7ity was not "required" - to meet the conditions of the Ordinance: While this interprztation can be questione�, the resultant error if it is in fact found ta be an �rror, can be corrected by adjusting the site plan to provic�e for a s-ingle, appropriately mar'ced and d�►nensioned Qarking stall for exciusive use of the handicapped. 3. To the allegation that the per;nit was issued in violation of Section b2.104, �:�e question tt�e allegat�or� on the basis that the charc�e is not spec��Fic in ' � that this sectior� of th° Ordinance contains 73 paragraphs lettered''a" thr��ugh'�ri'and the �llegation is thus unar��werable. tJe therefore bid the appel7ants specify their eharge before the Foard. . � � . � . , __-,, _.,__ , __ ,_ , _ - --. _ _ _ _ _ .__- �.• ',f.� .H. - - <ti/L....-•�T-•-'. . - - ..; . � .� .. .. i . .. �./ . ...._ . �M: __.. ._... ,r._. � . 1 .��.-� .. . _. . . • ."_._...`_'_.' "' ,. _. '_...______..� .h . �- " ... �.. � .._. . .. : . . _._ __-__. .... _ ,i . '_ ____'.'__'______ _.-.__�______ ' _ ._. _.__'_._ _ ._.._ _.._.__ :..�-.-..�. . . . _ ...___t- - ._:.'... ..._. _-._� _ _'__-".-"_ � tPJ F:C tiDt�lI��1STR11T1VL-" f{EVIE41 OF ISSUII��CE OF �iIILDING PERr�I T fJO. 029t�12 A{��Ila��ts: � . I;erald f". Sullivan, 1363 Grand Avenue, Lot 23, alock 1 , - :danns /ldditiun. 1•lilliani l_. t��►r�elheiu►, 1355 Grar�d Avenue, Lot 25, Qlock 1 , ' :Jan��s �1cicli tic�n. � itesE�un�len t: Gr��n Pti 11 Irui, Inc. , 57 Haml ine Avenue South, Ci ty of� Sdit�t r uul . i'�•oE�erty Subject to Appeal : 1361 Grasid Avenue, Lot 24 , alock 1 , ldanns P.ddi tion. Prescnt Use of F'ro;:erty: 1363 G►•and �Ivenue is a duplex r�sidence; 1355 Grand Avenue is a sinyle faniily residence; 1361 Grand Rvenue is a vacant lot havin� been issued building per��iit �Jo. 029�72 for excavatior� in �ca�,)unction �•rith the construction of a parkinu lot, said parkinq lot. intencied to be used in conjunction a�ith the Green hlill Car lacited on Hamline Avenue. � Ti�is appeal is taken by the appellants to the Board of Z.oning t�ppeals up�n the �rounds th�t there has been an err-or in fact and procedure in the issuance of peruiit No. 029�372. Said permit t•;as issu�d iri violat�ion of the Z�niny Ordinanr_e Sections 62. �03{a) ; 62. ]04; 62.103(h}(1 ) ; 62.104(i ) ; ti2.10?.(a) ; 62.l Of;(b) ; 64.249 and 62.108{c) . A hea►�iny before the tioa►,d of Zoning ��peals is requestecl pursuant to City Ordinance Section 64.203(a). � . .?AP.�JIi•;c, LOGF,P! F. U'l3(tItf�! i g�'� -- � '�u'--`=ti-.�-- -- -�---- pierre t�d. Re=;nie1� � A`to�-neys for �i►1�r�l �a�� ., 13:i0 ;�;�rthcrr� Feder��l l>uilcJinq St. F';�;j1 , t•1ir�nesotd `�51!i'� � �2�-�h�1 _._ _. --=- .----- � --______--------� �� - � � � ` . . .._ .`� __._.-.. �:��.�-__=_�=_ : �. ,.. ;4� �? AFFIDAVIT State of Minnesota ) County of Ramsey � ss. , .. . _ � APPL lTlOt� FOR Z01�t�1G ORDItaAMCE Vlk .NCE , , - .,�. ... . . � • '•-.'•�y:,;`^ CI7Y OF SA1NT PAUL �::.�" ' . ZONING E30ARD � � � � � A �F ZUNING CODE CHAPTER��SECTiOr PARAGRAPH IS REQUEST[D IN NFORMI7Y WITH THE POWERS VESTED IN TH "LONItJG ESOARD . ��1�__'�/Q �T I I�C ��I�� ON PROY�RTY ( � DESCRIElEU OELOW� — � A. Applicont; NAME:�!�'�c��.�,..�_� LI{/1�� __eS��'/-fx-1�� v�� i /� � � �,�vr� � � s�s�.�� ADDRE55 �. Propet4y interost of applicant• (owner` nfract purchaser, atc.) 2. Nome of owner (if different) B. on; � 1. Legat description: LOT BLOCK ADD. 2. Lot size• + 3. Present Use Present oning Dist. 1 IC. Reasons for Request: 1. Proposed use � ( 2. Whot characteristics of the property �event its being usad for any o( ihe p��mitted Iuses in your zone? � i � i ; 3. How da the above site conditio s prevent ony reasonobla use o( your property under f the t�rms oF the Zonin9 Ordina e? � � '"� a � � C� � �� _" � �,�� -a �.� , � 4. State the specific va�iation _ propnate. I � 5. Explain how yow cuse on(orms to eoch of the following: � a. Thot the strict ap icotion of ihe provisions of theZoningOrdinance would result in peculior or ex eptional prnctica! difficulties, or exceptionol undua hordships. � � ( � � b. 7hot the gro ing of a varionce will �ot be substantial detri- CASH4ER5 USE ONLY ment to t public good or a _ substonti impairment a( the � _ � .. �7�J� . _ _ intent nd purposa of fhe � �i^� ��F'• r`'T j y r�N�4FFJti'_''' Zoning rdinance. � �� 4 n 1n ��JL�JL LL.t'.R L�S. �.� I , � � . ��1s,.�...vr'�� b ��,t°_/.�,�J $ignaturo TT�YG.�i�JU � , ��(J��"'.��i�a,,,1��LLil•��-�U f -�-�--. p,�v�.. -- Cqse Number pofe Recaived � � � � ... . i <� I i : � � ! � � � , � , I i f � f � i f � . , � ; ; ! ; ; , , � � ; � � � . � .' 3 � _ � � � � � � , , � 1 � � . 3 � ' �^ I � � r � � � � � �' f � ' , ' � i ; � r - , � F 1 , . � � • � � �i � � ; � � 3 • � E � I t t � i � I ;------------t � ; � ; � ; � � ' i ' � � � r S � I i � � � T' -�, v, — � � ; p + 3 m j � N N.nwN CA � ; . i ' W � O (�! � i ' :b' I - = = ; I � � ; � � i , o '�4�' m P �� - I � 7� t�1 �» p � 0 � i ; ` , fi -a p ; � ! ; (' L�+.�i -�- v-.-� � ..�-- 1 _ . ' I � � 3o �mp �� f o � E 4 � ! ( � ��D � -{ ; � � oo ! f j� i 4` �-1�' m A� � F .-+ . ; N ; -� ➢..�. o m t ° � � ; '; D � � a' -�n � � �+ � ` � , � � � � � � 3 1 { t � Ld —a �" ' - r o v� ± , m �, ,-1 'p , � ! . �+ ! " � � � �� I � -n �j � . . _ f ' � ` I i i , ._ ----� i � 4 � . � ` Z .�.-s'!r"� I � 1 ^ � � � � � ��',} � m ' � � � � � 1 � � ^�� y� ; � � r� ( .,..�;, ��_. .v r I � � a�-. i j ' --.! �_.__ ...__� i a``e�+, i �.,�... �, .,_..._._ w_ ----------��r ��•'�f;— � "r"1 I ___�__�_.__------- -------`--- --—=- '-- — i O �'1�l L..1'�.i� � . t , _ . �� We the undersigned are opposed to the construcLion of a parking lot at 1361 Grand Ave. St.Paul. -It is a ��stop gap proposal that is very detrimental to the neighborhood r � the Green Mill Tavern bar patrons would be a nuisance -It s use by to surr�unding homes. -A more suitable comprehensive solution should be found for parking. titi'e the undersigned support the appeal by Ttr. Bartelhcim and rtr. Sullivan and oProse the placemeiit of a �arking lot by The Green Ttill at 1361 Grand Avenue due to its aclverse ef£ect on tlie ad�acent Properties and the nei�}iborhood. � N.�11�tE ADDRESS _ _____� , � 3 �� . ! J��. / � ��-��`/�� ' . � ` . . . � . � � � � ,�/�� 'Z'��iv�`.'�'" / . . . ', f`v�G�2fi� ��- �� ' ��„�,�.--,.�� , � �� ' '�_ uyr� j 3.�J , � L�*�t�" . � ` �.�.�: �� .-% � . � �� ` �� . . �.� �.. ��,�/J//��., � �'��-��" ,�� ,��-�. _ � �� J , , A /��r�-' . + . �,p-��,,.�C.�� " j� .�� ,�`�� ` { I1 f. L�� 4 7 .`7/T-� -�y'V� � I. -�.{,��L�."L' . ,- . ��.�. !'-.� / �� v� r '\ . - , � . . 1�� ;'�,v�, > . � ��- ��..�/` C�'�. � � .3l�� .��,�,v7 ,�. l/�� .�-- ;� `�' 1 i; . r / � / /i `� ��,�� +;� 1 G� ,: � . � : ' �� '�,t„`,`-�C.,r,..'�..__ � 3 L,� � �j-a2.0 � �x'� � . ' � _ � ; � - � ,�'�,�� -3� �' ��- , , . , . � � � . �� - -� � .� �'.�_ _ ,� � � 1 � ��a_.�.�e_�' . � , ��. �� U� �� . �� s _ ��- � �� ;�S � � � �'�� . a �C f L 5 �!� 1-cx '� .� � 1 .�1�` c�� . /, '3 �' � ��..��-�� `—�� `, ,.�,.� c —� rj (�, �` � � � � 3 ��- � �• � � v � � � � � _ � � `� � 177�' Gi !�/.�'� �� _ � _ , � � �' i�� , ��' � � �� ' �.'� � , lv`� �S . �� J i`�/�-, � s S � -- � ��-� � . We, the undersigned residents, ob�ect to the Green Mill parking lot at 1361 Grand Avenue as impracticable and an inf'rin�ement on a predominantly residential neighborhood because: , 1. On a 41-foot lot sandwiched between twc residences, it would be a nuisance to the neighbors. Since it woulci coneentrate the current ob�ectionable practices of Green Mill late-night patrons (noisy motorcycles, hot rods, bra,wling, tt�rowi:�� bottles and cans, unsocial public displays, etc. j in a small area. 2. It's entrance onto Grand Avenue would be blind and creai;e an additional traffic hazard to an already dangerous area of fast-moving traffic. � 3. It would remove two large oak trees from an area that has lost many elm trees and to be replaced by blacktoppin� the entire lot, to ct�ange the environment of the nei�hborhood. NAp�E ADDRES S � � 3 �� L�.NC:✓o(.,� ft ve- ;^; �.. ' �-t� ��,�U i�,,.,�:Lrrl,,, I:�G�� L��Cc l�� -';�1�, ' � i 3G. I L � ��>-,2. . �'��-,��t /,�q� ` G��e. ✓'� 6�� g � ' � � f - /3� � �� o Gn.� , , �1,� � �.-�-�.-,..r�.��= � � � `� � . � ��w� � ��'�`� �3 7 �7 ��l y � .�� q �� , / _._---_ � �3� L � � �.,:�-��,� c cY--c � / r os a , << �� I�'� �--� . ��l�r � � C � � ____ We, tl�e un@ersi�ned resider.ts, ob;ject t� t�e Green Mill. parking � lot at 1361 Grand Avenue as impracticable and an infringement on a predominantly rnsidential neigk�borhood because: , 1. On a �+1-fooi, lvt sandwich�d hetween two residences, it would be a nuisance to the nei�hbor:. Since it would concentrate the current ob�ectionable prsctices of Green N�ill late-nigt�t patrons (noisy motcrcycses, hot rods, brawling, tt�rowin� bottles and cans, unsocial public displays, etc. ) in a small area. 2. It's entrance onto Grand Avenue would be blind and create an additional traffic hazard to an already dangerous area of fast-moving traffic. 3. It would rem:ove two large o�k trees from an area that t�as lost r.iany elm trees and to Ue replaced by blacktepping the entire lot, to ct�ange tfie er.vironment of the neighborhood. NAI� ADDRESS � �. i'�.��`��.,�.�./ /' 3 .5 -� ,,.�1�—��_''�r-� , '- '��1�-'�- '•� l , ;�:k��.s2�v.w-.../ � .�5 i``��`','-,,``-_. ��-�-�-= ' ' �- � z %. �c��c�-� �'3�'3 �'J��,.-� �.. titi�-� ��i' � _ /3�� -�� , _,; �h , �, , , ; r � , _ _ --�, ✓�,;��, ;� L�- :z.. �L.�.�� ,'..� � �`�- : ��.� .�� '��r� - - - , ._., , , � -''/�, Fj�, f o'�'�.L-�'Z'�L"'2'� / ?J�G;. C �'�',�r,.w�-4:�' L(.�1.� � '"�� ,��,,�� .;,) ct-c��-�=�� /.3 �� ►--�(. �L"'�' . -, � �� ' � , � ��,1 �-c� �'L l.'`�., �cL„ti,,�.�., l,\ � .�-�='�=- �.3 � `�r+.t ' .� , � . � � �J�� , �,��o �,�.�� .� `^'ZL�-t�� j�ZC c--�� ` � ..; ;��.�_ � �� r � "✓ �i�. L ��. ,.�.i. _,<zl ��y��,:r - �l J s _ : � � ; , ^, � � �,�� y , '� � � - �� i . � - `�,..t� ,.� .� , _ �� l � �� Y.- C, � ... , � , � � � � ;,r ��Z �C� ��L��• ` ��`.�../ !%�� ,�� ' t� ,f' _,;,� �1�z:.,,4-_� _—.� � ;��-� 4:�:.,: ,./�L�=�-x'c.<=-�C_. / ' + ' -� . ` ,��:` -rr %� / �j% /_.J T� . �.��R�/ ��'./��: . . . . - ' .-r.., �� l 4 �� /�� r� � � � C� � � �� . , . City of St. Paul St. Paul City Council 15 West Rellogo Boulevard St. Paul, P�iinnesota 55102 Dear Council hlembers : This: letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lat at 1361 Grand Avenue. Respectfully, r • I Vv � ��: � �� c� , ,�,�n � � ��, �e� �I�,�-� � ��s � (3 3 0% ��a►� -I��- � � ` � �� 7 V �i� 4 ! � f: ,�� G � � � � �� ` fD �� w� . ��+e -f-,�-e- (` �►'` ' - a� � T�- � � ��r r , � � a�- rr'° . �o.,.�s �- �ea l � cu`�S ��- _ � � -�o �,� ��-� � ��- - �,S � \ln.-�"O �Cs-� ��R..�� ( �ac�� C- ' � �,�,._� _ _ _ ------- ;— --- - . __ _. City of St. Paul 5t. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council I�Iembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this shoul.d nat be construed as a dampening of riy support of the Green Mill Inn nor a Iessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Pau1 City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � `,��Q"�� r C 5��-�� , . � ��, City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council �Zembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a narking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby aZlowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, f \' ' c . \�� . Vc� �1 �oo� �(1��;n � ��c o� O Q�S"� C F��2 �C h,`�R �� . � � ,� ; City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 � Dear Council Members : This: letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening o£ my enthusiasm far the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Sartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � j. � ~ �� N�v �(l'"�V � � ° � ^ v io . � /J�`//^' __ _� � � %// ✓J!/f7/ � _ � G , � er ' ; ` �;�� d�� f =��,�.� � � 5 . ��'"[ ��i�� S S f�� G , , . � . - ---- __ -- _ _ - _, _ ,j � City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, PSinnesota 55102 Dear Council r2embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of ny support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, ' l� N 1��G� x-� � Z, s-�'. �!�r.��R,� r�_ � ' c� , � . 21 —► s. "'�`�-- �S___ �.� � �- � ��.,� r-- � �� -�� c�5 �� , . �,, r,: . _ ___ _ ;. - -- ___ -- ___ _-------__ -- _. i-- --_ _-- - City of St. Paul St. Pau1 City Council 15 West Kellogg Boulevard - St. Paul, Piinnesota 55102 Dear Council Members : This� letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �o� ►t `�� S°�� oLd �� a_ � �c.ruK/ � �yyN'Rr0 T/q � U 55° � � - � � : . �; �- __ -- - _- ..- - _------ __ ----------- . _ __;-- -- _ - City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, P•iinnesota 55102 Dear Council rlembers : This� letter expresses my support of the Green Mi11 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the couneil hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green ?�Iill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � �J "i'� ..-�il � / `�' 3 3 /�in PS �'r� S� 6�i�l� /►'l i n h ,�i S/(G �J� ��'`� c2 U /%S 5 .Sc C.�o� Gh�u.�� K.�i 'l„!c-Z:- �.�ii�.�vC �� /�,✓ .�x,�5 � �� _ _. —------------ - _ ---I— -- --- _ _ _------ ----- --- - City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mil1 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. � Respectfully, �_ � ,��L��-�-z--� � �-�� ,�; ;G, ��; �� 7 C-' �� Q� �� ,�� 1 , ,�- f �� - r , _ _ ____ - __ _ --------- _ _ ___.. _ ___--:- __�--- — _ ----------_--- ' City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council r�embers : This letter expresses my support of the Green Mill Inn in it� efforts to construct a narking lot at 1361 Grand Avenue. Although the time of the council hearing preverrts me from persona�ly attending the hearing, this should not be �onstrued as a dampening of my support of the Green r��1i Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly ur�e the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully __ _�-- � + , , )��7,c,�.v.-� _ _ , __ -- --------- _ _-;-- --- --- - City of St. Paul St. Paul City Council 15 West Kellogg Boulevaxd St. Paul, rlinnesota 55102 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 136i Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Pau1 City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � � � a�� ,��:�� , �� ;��j� , . ��,_ ., _ __ __ _ _. �, _ ,�'j, � _ - - - - �. --- __------ _ _ _-------- __. - �- ----- ., City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, P�finnesota 55102 Dear Council Members : This� letter expresses my support of the Green Mi11 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly ur�e the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, . � � � i � _ ---._._ . ------ -_.-----_-_ _--� - – _ _ _ — ----=---____-- ------ ^= �-= nf St. Paul August 1 , 1977 Gity of St. Paul St, Paul Ci.ty Council 15 West Kellogg Blvd. St. Paul, MnT 55102 Dear Council Members ; This letter will ex Inn in its effort to press my stron S The time of the councilchearinrkin upp°rt of the Green Mill person in su g lot at 1361 Grand A to be PP°rt of the Green g Prevents me from a venue. present Mill b ppearin The youn � lessen my desire to seeuthen no way does my inabilit and should mbe' WhO °Perate the Green Parking lot a y encoura ed Mill, are fine pProved. in a deeent neighborlg in their desire to Young p�ople, neighborhood �� Y fashion. There iS a operate their business I sincerelub in the area. large need for a construction ofy�hope that the council wi; go� parking lot at 1361 Grand A ee fit to allow the uenue. Respectfully, �O�A� J ck 4��ard 81 So. Pascal St. St. Pau2 � � 55116 1� ��___'_"..._ ...«.....n•zfw�arw= ..... . �-.�._...._ ' City of St• Paul St. Paul City Council _ _ - - -_-_ _- -- _ n.��teSZ�r d-- _ 1� _ �ip��wi�«b �f 3t� . JOHN M. ISAFfSEN �" Z� "' �� ; �; �- � , �s-`'�. .�.Q. . s+ . C.-� Cex�•ri.c.,i.,, f �i 15' �►�1 • K�.LC.t� $t.v'p , _ �'t• .��.,�,�. r1c�N. �i a 2: . �� ""'°i:3��...r- t7��nc.: 1..: . I : i _ � , : i -�- h�,�.��„� �ra.�t�,rQ.s s w�.� S•�.� o�- _ . �. � . � � . . �=� �-`�f,r. ��;,;,Q,�,� ��. �;.�!w�..� �.a��.t. � � �/y � ��. .. . �.� �.: �,i�� .��.. 'TU ��bf c3►e�►o�i �-: E.�►(J�.-L.� �X.`f�il`► ti,l -�t.e.: `:�4-y- '� y , � � �� +� 1 C�.�at� �ie��. "' '' � � �.. �.� �'"�'e. '�i�' ' �n."`� �,►� : Caw�c:��... � �� + �- p�ai�:+i oN a� �P1P��- i � �.1 t� uS�c.�-:a � 1.hsa '$tj ��..� �t.�:. Ya.ts wti � ",�'�ne�e�.b�; t1�#�.�.�►�t�t� 1 �' �r��.N �w1t�c.. �'Nt� '� C�ow�S�'�,'T � �►l��.K.`�,t� �" a'r 1'S 101 �o�► : :, - C�' t � � . . ; ..^� . _ � ,__.� , � . _ :. � ..,�., . . .�N�.` . � . . r � � � �, � , . . . .. . •- � _ �� ` � ti' .� l• I~1�1' � . .. � � � .� � .. . . . , . �Z . . �` .. . . .. } . . i �� ,1.� � . . .. . � 7� . . : �,�--� _ ,!�✓ �� ' ..:%�� :.;f � -�.- �. � 3;�" '�'��-"� . . . � ''�f- a . . . � . . .- ..� . . . .. . .. `. . . _ . . . � . � . . . �� ar• _ . .� . , . �. - . , � . �� - ^-::'C.ay... . ... " ..;,:�...-,:i:_,,.. • �»�-,�',''�-', •'"�'�6�=._..�'.�----��' � ---"� - ,.. .... _ 11��d s��;``�� i� . �, : �. City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Pfinnesota 55102 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a uarking lot at 1361 Grand Avenue. A�though the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, ��--P v � �`� . U � � Z--� ��-�-�----�---�----� L""-'� �e , P�..�, �, SS i °S � '�� __. . _ _ __ __ _ - ; _ � , ._ _ _ _ --- ; . -- -�- - __ ------------- City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, riinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of riy support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �2 � ,��,e '��/y� � �G ��C':4.�Rs�.c� S�� 1 ��i��L /'y/�n'�-� S S�la 5 ��.2� . %��r/�'�,�,�-, ��o��7�N��i� ��q; �- �i�Q� � �y1�1 s � - �v,,� � � . �� _ _ ---- : ..----_ _ ___,— -- - ; City of St. Paul St . Paul City Council 15 West Kellogg Boulevard St. Paul, P�iinnesota 55102 Dear Council r4embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamlir�e avenues . I strongly ur�e the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelhe�m, thereby allowing the Green : Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � 0 ��k�,�� r�/'� , i �/D� � � �.� � �, ��ur yy,�,�,. s�� 7 � � � ��`-� G� �- � � � �-.�.Y' ��",vy f-o � �f/�J' �' 7`-�,,�y.,� � /� a � l �-�go � a( . �� __ ----- ;• ,- -- - - - ---____----------__------- City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 i Dear Council 1�Zembers : - . This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of ray support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I stron�ly urge the St. Paul City CounciZ to reject the petition and appeal by Geral.d Sullivan and William Bartelheirn, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, l�. ��/ /OlJN� �lJi�l�E' � � , � 09U' /��. 1 , ��//� � d �� i9 �/ � . ��, . -- _ - - - ---- ---- -- --- ----- -_ ___- - ;-- ------- - ____-- -- __ .� -- - --- --- , � _ __ _. . �_ . _--------- " - __--�- -_ __ _.-------------- City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, PSinnesota 55102 Dear Council l��embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby aZlowing the Green Mil1 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, ; ��. � � - / � . � _.. -- - -- --_—- - -------- �" __� - --- _ -- -------__ c�ty of st. P�.ul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 551�2 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy , support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �� n� _ w ^ , \ City of St. Paul St. Paul City Council 15 West KelZogg Boulevard St. Paul, Piinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mil1 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green r1i11 Inn nor a lessening o£ my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � �� -- � �� s �� :� �� `'�� - , . �;. i City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, rSinnesota 55102 � Dear Council l�sembers : , This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of r!iy support of the Green riill Inn nor a lessening 'of my enthusiasm for the need of a parking Zot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, I��'2�� , , ;c�I� � 1 � .2 S�— �Q��!� ►�t�i /r� � � � � f��- 3 � � 2 `� � � �" �� , . ��_ . - ---- -- ---------- -- - ---- _; _ __------- _ __--- -- - -- _ �.� _ - - __ - _ .. - - -------------- , -� — --- -- City of St. Paul St. Paul City Council 15 West KelZogo Boulevard St. Paul, Pfinnesota 551�2 Dear Council I�sembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the GxEen Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � � � / G:�%f��L_ �`� � �� !G��Ss�� , �� c�� _ �� _ _ ----------- -;— -- _ ---------=-----------.. City of St. Paul Sfi . Paul City Council 15 West Kellogg Boulevard St. Paul, riinnesota 55102 � Dear Council r2embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mi11 Inn nor a Zessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � # ,l �� / � � U � _ �� _.____- -___--- - -- -_.. .. __ __ _ ._ __ __----- __ _ -_– –�--- --_—_-- --- __ _ .____ _ _ _ _-- �.3 � City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sul�ivan and William Bartelheim, thereby allowing the Green :�Ii11 Inn to construct a parking lot at 1361 Grand Avenue. spectfully, / „%/ /� ,;% � , ' . �� 1r,��. � _ _ �s�-`,� ,�� -- _ __ _� . _.__ _. ___ -> -- T`_�� _ d _._ ��i_,�� .-_--_ � � - - _ _ �_ �\ ---- -------------------- • _ _ _ _ __.._ __ _ _ - - _ --- --?-- -__ ---- '� _. ;� . ._ . — —- ; __ -- � I City of St. Paul St . Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 Dear Council rlembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of r�y support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal tay Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking 1ot at 1361 Grand Avenue. Respectfully, �� s ��e� �'� , a�� .�� , . __ - - ---__--------___---------- __i- -- - _. �_�_ ._ . -------- -_._. City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a uarking 1ot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelhe�m, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � /' r , �� J � . � � �� C�'�` �� \.J�� "� h ^ r �a'v � � `V�/� �c�� , °�. �� , �� ( �� ` . �� ,r--� � . �,� c� -'� . �, ______- - ------ --- ; __?-- — - __ _ City of St. Paul St . Paul City Council 15 West KelZogg Boulevard St. Paul, rlinnesota 55102 � Dear Council P�7embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking 1ot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of ray support of the Green Mi11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �- � 1� -+��i�` °Iqq �M a� �v�. �0.�5: F;r.� O�.�t ; � � � � w� �,�,- �:�-� /5�q/L Sc%G w: ,.rv�r- f a d , . �� .________ ___ __________ : _ ____ _ _ _ _____ _ � __ ___ __ _ ., _ __ _ _ _. f _ > } ---- - . �._- - _- ------- , -,— --- _ City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota SS1Q2 i Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Gran.d Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of ny support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly , urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �. � � �� f G l�� .O�tl��.� � ,� ------ --------------------_ -- _ _ --- ,;__ ; - ,� City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 � Dear Council Members: This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of r�y support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � � G�/!2�_ - , v �:.l�Q�" - �'f , ��- � - ��Z� � � � � ��- �� /��. � . . �, ., ___. , _ :� - _ . -- _ . ------- • _ _ . � _ _-,— --- - - , c�ty of st. paul 5t. Paul City Council 15 West Kellogg Boulevard St. Paul, P�iinnesota 55102 Dear Council I��embers : This letter expresses my support of the Greeri Mi11 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald SulTivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � : i�� 3 �� . � � �� P.� ��. . �5-�os- , � - �,_ _ . _ _. __--- -- -----� --;— . ; City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, riinnesota 55102 Dear Council Members : This: le�ter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should t�ot be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, _ �� C� e _ �� _ __ --------- . _ __ _ ._ _ -�— -- - - � City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, riinnesota 55102 i Dear Council Members : This letter expresses my support of the Green Mil1 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this shoul.d not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the GrEen Mill Inn to construct a parking lot at 1361 Grand Avenue. � Respectfully, �, G�'' `� � / ��:6y� �� ^ i��o �- Sr�l�� . ,�f. �� , �s1�8 �, ---- -----__--_------- _ __ _ _ _ __ _ _ -- - --,_ _-------- . _ __ _ _ . , . , � 1 City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 i Dear Council r�embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the counci3. hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petitian and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, r � � � �� O�IGz�� J/S4"'u � �� 51` �/� .S� , �2'�- .s .s%D/ . ��, .�. _ _ _ � . -------- • --- -- - - -- __, __.�.- City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mi11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, , F � � � lJ�/� V �'l �1 �- • � 6 `T� �3,ZlA�►2 Sfi. l�,��► L.-- ► , 5��r �y . �� . . - --— ---------- � —�-- --- __ ----------- - City of St. Paul St . Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 i Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of �y support of the Green l�iill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. -> � � � Respectfully, � ' � -� /��-�� :y� � � � � �- a 5 ��- � � ''�`�� -�� ,%��rc�� i - ��_.. --- ----- __---------___ . — ---__ ___ - -.__ — _. _. _ .-- —�__ _---------. . ,. _____ _.__ _ � _ .� , j 1 City of St. Paul St. Paul City Council " 15 West KelZogg Boulevard St. Paul, riinnesota 551�2 � Dear Council Members : fihis letter expresses my support of the Green Mill Inn in its efforts to construct a parking Iot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking 1ot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully � `G�7�/`�2��,� �� , � ��'..c�:�- •�-� Go-cti�.�� , , ` �� y � . �� _ _ �;: : . �. - - --- --- - - - --------- ----__-----_ . _ —_ _. _ -------_. City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, P�linnesota 55102 Dear Council Members : This� letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. ° Respect lly, ,, � � �� ' . , ��e, Q- � __ ��Zy,..� , _ +e,: _ ' . r City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, r�finnesota 55102 Dear Council Members : This� letter expresses my. support of the Green Mil1 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues , I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green ?�Iill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �, � ,' � ��;S �� , � � �-� � �� ' 3 �v . � � � �I'l. �Ik'�� P�, . A. i9� ��SS,'g _ ., City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, PTinnesota 55102 i Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of ny support of the Green 1�1i11 Inn nor a less"ening of my enthusiasm for the need of a parking 1ot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and �dilliam Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �,, ,� �� i �� _ — -------_ _--_-------------- --�--- _ - - - _ _ _ _ _ _. .� -- ---.___ _ . __ _ _. , ._. .. ._. _ ..__. _. . . - - City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, rlinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of riy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, ��pr� � I . � �""� � � �,� - �_ . . �) i . ��. _______ .------- . -,— ---- -- City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, rlinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of r�y support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sv.11ivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, -� � ��-�-��-� �� , _ ��, _ _ .. . . . _ . -- • __ _____ `_ -�- --- - _ __ City of St. Paul 5t . Paul City Council 15 West KelZogg Boulevard St. Paul, Piinnesota 551�J2 Dear Council riembers : This: letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. AZthough the time of the council hearing preuents me from personally attending the hearing, this should not be �onstrued as a dampening of rny support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, , �: � � � � � ` ' , ��; '� s � ` l �-� S L ,��,� �� %� � � �" : �.. _ l�/ _ , ..y -� / - J��,. L � /.J J �J i L� s ��'�t S. lL�� f� �w -��,�-- ��'� � ___ � � l J� L_, ,�.� �: c��.v l� �� a / . �.�FK / . \ --------�----�------- ;- --�- --- - - - City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, rSinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of r�y support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � � �� l�� s� ��..�.-� ��. ' ��. ��1-_. �(`��Nw � . �, _-. ----- -� _ �— -- - - City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, tiinnesota 55102 � De�.r Council I�Zembers : This letter expresses my support of the Green Mill Inn in i.ts efforts to construct a parking lot at 1361 Crand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for � the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Su17.ivan and William Bartelheim, thereby allowing the Green Mi11 Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � �1 �/. �c • / �� I�a��-,�c,,�e 1 � � �� . ��„L"�i �-_ � ta � • ��z `� �� S� -� � �s,,�-- . `� �3 . ��.'' �� c _ _--__` �il 0 3 _...__._ __ --� , - �.. . _ _____--- — _ .,} E . _ . ,� . __ ,, . . ___. __-- -- ----_- - ---- _ ----------_ __ __ __ _ __ --- __ ..__... _ .___---- - , . _ � --------- ----- City of St . Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council Members : This: letter expresses my support of the Green MilZ Inn in its efforts to construct a narking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �----- � / \� �� -`- � � �� , ; �7['A.��T�� GLA.S , i Windows and Lamps Made to Order Complete Restoration ��►'.�e� " 792 Grcnd Avenue St. PauL Minnesota 55105 "Bullet" � JOHN M. CAMPBELL Phone : 224-�30 � �' City of_ St. Paul St . Paul City Council 15 West Kellog� Boulevard St. Paul, P�iinnesota SS10� Dear Council 1�Iembers : This� letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � _ ,� - \ -- _:. __ �� __ - --- ---— -- ---------- - - _;_ - - -- City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, P�iinnesota 55102 Dear Council Members : This� letter expresses my support of the Green Mi11 Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of �y support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition anci appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Nlill Inn to construct a parking lot at 1361 Grand Avenue. Respectful y, �,� �� 1/��/ � `i/I� �O�jeN�( ��+9�( S'�. /��ul /��.Jif .S".s/o I � . , City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, 2iinnesota 5510� Dear Council Members : This� letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me fram personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, lr ` � � �� sT�� D��,v�R ^ �nra��-�R /��/��f�1=�ZD�� L r� ��r�� S � �� ,��v � �� - : �4�/�� D,d/2�ss � � �� r�coc�/ �,� . .� . . , ��,��„ Y� r, '�� •��7iK. . �r� ' Ka�rl H'. Ke�sr.�. ; 7�9Z t�i l�►t+e.*9t,Piqi*�Zt�'i� , . � ,:,: City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council l�7embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � `.�.� C�:�,��.�.,� �� s �-}-� � ^ � : C�v'�c �C �c ,;�1 d�s ��fi�'�wf� � � � (� 7 ( c_ �� -c.�.� : �C,� r �u C�� i��j�""�- �`3 � U �� L�s �I�� - �� _ `: _ . - -. _ -------_ I' ----- ----- - _ ------ -- _ -r- --- ,� City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, P�iinnesota 551�2 Dear Council 1�Zembers : This� letter expresses my support of the Green �nn in its I�1i11 1 efforts to construct a parking lot at 1361 Grand Ati ;Although �nue. the time of the council hearing prevents me from pe attendin rsonally g the hearing, this should not be construed as a dam- f � �ening � y support of the Green Mill Inn nor a lessening of m iasm for � enthus the need of a parking lot at Grand and Hamline ave stron 1 nues . I g y urge the St. Paul City Council to reject the petit-, eal b zon and aPP y Gerald Sullivan and William Bartelheim, thereby af,Qwing the Green Mill Inn to construct a parking lot at 1361 Grand ��venue. � : Respectfully, ; � ` � `�� C��-1 k �,R`T�5� /�c� � �M�� C�-t K�';� '�r � ��D S�� "�1��L-S' � � r , r � f, , ; �" ` �.�.� . f , � . �� t . .� City of St. Paul St. Paul City Council 15 West Kellogg Boulevard . . St. Paul, rfinnesota 55102 Dear Council rZembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly ur�e the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � f'�-�'� f /�v C�TK-�' �`G �- �i�%'�'�'` -�� - �� r /��7 �.� � - ��- a,��.-� , - - �� City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, r�iinnesota 55102 Dear Council r2embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of iny support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking Zot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject tl�e petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, , . � �� : � ��J,� /di/ �,��i�"i �� .5�,�-- �'D,u�".�'�'�� , � . � � _�' � , ,�� n � �� S � S � __ c �--�- . �, City of_ St . Paul St. Paul City Council � 15 West Kellogo Boulevard St. Paul, P�iinnesota 5510� Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mil1 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge �the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � • �o ��s. �� w�� . , - - ---- - - -- _..--;- - - _ City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55IO2 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of ny support of the Green Mi11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Res ctfully, l� �l� ` , `� ` � � �'7 —6 3 3 � �19i� pN �U cz�►� /��- �q.b-oo�o ��j �� / , �� 1' ��d �' J �� , ' �� y�.� � � � , . , ___ __ ---- ----------_ . _ _ __:_ _ __ --- - _ _ __ .r _ �� _ _ _ _ _ . � _ _ __ __ -- . -------. _ ------- � ---�- --- - __ _ _. City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 , Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green Mil1 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � � ;l `� �� ( �S. t��s�,� L.��+F�,� ��2�� i• (,r�,�,,,.-�- � � C2,,,�,�- �,Z,';�--- � � - ��_. ; _ _ . . _ . _. 5.� �; _ . _ ----_ ____._ . -___ ________ _; _ - � ---------- ,- - City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, P�linnesota 55102 Dear Council Members : This� letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green ?�Iill Inn to construct a parking lot at 1361 Grand Avenue. Respectfuliy, ,� ,\ _, 1 ` -�_ �� ✓��' / � SA n�� KCN/1/� ��r �"P � C�Ni�v rv� � � ��T" �F�� - � /�'i / �N , �SidS— , - ��__ _ ._ - - -----_ _ .. -------- - --�— -- --- - City of St. Paul 5t. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 Dear Council r�embers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelhe�m, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Resgectfully, Q 1 ��o ��,�-�� , _ �� i City of St. Paul St. Paul City Council . 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 i Dear Council rlembers : This letter expresses my support of the Green Mi7.1 Inn in its efforts to construct a parking Iot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of riy support of the Green r1i11 Inn nor a Iessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I s�Crongly , urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to constxuct a parking lot at 1361 Grand Avenue. Respectfully, ��, � � , ` t � ` ` _ " � �, ? ��(,,�� s� , , _ ��,_. -, �� City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council rlembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. J Respectfully, I � ��/3 � /. � - �'�-r �. C��e%�� . �� _ .. __._ - - . --- _ _ _ _ __-- - _, -----�,------ ----- ---- City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 551�2 i Dear Council TZembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Crand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening o£ my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, :.., �' , , , . �r,�`' N✓ a � , ✓ �-�� C�� - �+�`- p�iu,/ i� �y �. �� .�. o� ��-� _ ��, -; __ _ ; City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, riinnesota 55102 Dear Council rlembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my support of the Green Mill Inn nor a lessening of my enth�siasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �� t�� .� �I � l� �cQ.� 4 � � �f 6 ti�-- Q- l 3 S Z ��e � c� t�. �� A � Q , - �� .. < « � �, ._ _ . . . _ . ------- --�-- --- - City of St. Paul 5t. Paul City Council 15 West Kellogg Boulevard ' �-� � St. Paul, Pfinnesota 55102 � � Dear Council I�Iembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking 1ot at 1361 Grand Avenue. Although the time of the council hearing prevents me frorn personally attending the hearing, this should not be construed as a dampening of rsy � support of the Green Mill Inn nor a lessening of my enthusia�'ni for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. PauZ City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue, Respectfully, � �y - �S Lt� " . �'%�'u`'� � . _ �� . ' � : City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, riinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at I361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green rlill Inn nor a lessening of my enthusiasm far the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelhe�m, thereby allowing the Gr�en Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, _ , S U_�1, ,"� ��1 �� n,a�-�. Ao-f. - • !0� � , _ �, .___ - -------- --__ — _.--�– -- _ _- City of St. Paul St . Paul City Council I5 West Kellogg Boulevard St. Paul, Piinnesota 55102 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a narking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of r�y support of the Green rZill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and HamZine avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � ; , - � �- ��'-� - .� �� , � - �� ,. _ _ , . _ - . .-------- _ _. �- --- -- - City of St. Paul St. Paul City Council 15 West Kellogo Boulevard St. Paul, riinnesota 55IO2 i Dear Council I�iembers : 'This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of My support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking 1ot at Grand and Hamline avenues . I st�ongly urge the St. Pau1 City Council to reject the petition and a�ipeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � b � � � � i� � l 6�(� ��►�� t� �.� � , , . , ____ _____ __ ____ _ . _ __ __ _ __ ____ __ __ __,__ _____ _ .__ _ . .; City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, rfinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me. from personally attending the hearing, this should not be construed as a dampening of my support of the Green Mill Inn nor a lessening o£ my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �-- %`�� -CL•4i s'�. J � 3 , . �� -- .. ..-------- _ � ---- _-,- -------------_ _ City of St. Paul St . Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of r�y support of the Green Mi11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, G�Gi��i� �� • d,�'�d/1,C) iq�,e �T �/�-c// �� JiV � . `� _ __ _�_ _ --------_ . . -- -- . - --------------------. .._____ City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council rZembers : This: letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of my support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking 1ot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sul,livan and William Bartelheim, thereby allowing the Green ?�Iill Inn to construct a parking lot at 1361 Grand Avenv.e. Respectfully, �/� . s�`�� ✓`� . r Q �� i��o �� , `4 � , _ .\ _ _ ______ __ ; _.. - - : - - - City of St. Paul St . Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, �his should not be construed as a dampening of r�y support of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 136I Grand Avenue. Respectfully, /�� L�� Z� y . � ,��'1 . , �� : _ ��_ --�- -______ __ . _---- - _ _ _ ___ _ -----__ _ _ __-- --; __ _ ___------- 'i , ;: . _.____ _ _.....____--=------_... City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 � Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of my suppart of the Green r1i11 Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheirn, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, S L��c�P ivL� l Sa � �ar� /��( � , ��4 S 1 . w. �� s� z ��u �i�/ / . �• �� r''Z' 'r�/d / . ��__. -_---------- ------------- -- , _-- -.._ ._ _ _- -___ -__. _ ____ ---�.._ __---- ,, _ __._ _ _-- -- i; t _ ___ . .� ------- � --,- ----- - ------ City of St . Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, rlinnesota 55102 Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green r1i11 Inn nor a lessening af my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and tiJilliam Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, �_ , � ��,� �� C. � _ �l � �� , . , --- . _,-- -- - - ---------- ._.------.----- { City of St. Paul St . Paul City Council 15 West Kellogg Boulevard St. Paul, Piinnesota 55102 Dear Council rTembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 13b1 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rzy support of the Green Mill Inn nor a lessening a£ my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to xeject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, � 6� .�0, 1 � p Cn� �fi; s t � l'�n. Ss�o � � � r , _ ,_ City of St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, PSinnesota 55102 , Dear Council Members : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be �onstrued as a dampening of My support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking 1ot at Grand and Hamline avenues. I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, , ^ �� //J , � � , . �.. ---------------------- _ ___ _ _- -- ------ _ - --� - ------____ _ - -; , . City of_ St. Paul St. Paul City Council 15 West Kellogg Boulevard St. Paul, Plinnesota 55102 / Dear Council rsembers : This letter expresses my support of the Green Mill Inn in its efforts to construct a parking lot at 1361 Grand Avenue. Although the time of the council hearing prevents me from personally attending the hearing, this should not be construed as a dampening of rsy support of the Green Mill Inn nor a lessening of my enthusiasm for the need of a parking lot at Grand and Hamline avenues . I strongly urge the St. Paul City Council to reject the petition and appeal by Gerald Sullivan and William Bartelheim, thereby allowing the Green Mill Inn to construct a parking lot at 1361 Grand Avenue. Respectfully, ��`�t- � �ANiec�4 MclRp�ty /�y�g .q;�2Mck�r av� sri�,�� M�J.�s,os— � \ . � - - . ---- -__ - --- _ __ __ - ------- -------____ -�--- ,; _ __ �