Blythe Waters Notes from Gate Hearing.pdfBerry, Cathy
From: Blythe Waters [blythewaters@gmail.com]
Sent: Friday, May 13, 2016 9:07 AM
To: Berry, Cathy
Subject: Blythe Waters Notes from Gate Hearing
Attachments: Gate Hearing.pdf
M. Blythe Waters
blythewatersftmail.com
Animal Care of Ponte Vedra
880 North A1A Suite 21
Ponte Vedra Beach, FL 32082
(904)280-4544
1
Berry, Cathy
From: Blythe Waters [blythewaters@gmail.com]
Sent: Friday, May 13, 2016 9:07 AM
To: Berry, Cathy
Subject: Blythe Waters Notes from Gate Hearing
Attachments: Gate Hearing.pdf
M. Blythe Waters
blythewatersftmail.com
Animal Care of Ponte Vedra
880 North A1A Suite 21
Ponte Vedra Beach, FL 32082
(904)280-4544
1
Thursday, May 12, 2016
Gate Hearing
Objections:
TR Hanline - Gate: objection - de novo testimony in quasi judicial hearing - hearing
should be restricted to only those materials presented to the city
Sneed - Barry Adeeb, Beach Diner - objection - no showing that permit was issued by a
properly elected building official
Eakin - objection - city adopted Mr. Lindorf's report - therefore any material in Vol 1 not
contained in Vol 2 should be struck from the record. Also no showing that permit was issued by
a properly elected building official
City Presentation
Jeremy Hubsch: Building and Zoning Director - Does the request meet all city codes
and requirements - only question that city is able to address
• CG Zoning - allows for mixture of any uses allowed in the code - retail
establishments and gas ales allowed in code - therefore combination allowed -
most intense zoning district since 1982, both this and previous code allowed for
service station and prior code defined automobile service station as gas station -
we have intensified this designation when the CI zoning was eliminated.
• Determined that under applicable code - site permit as submitted requires no
variances or use by exception
- Steve Lindorf - review plan - offer comments.
• Is use permitted? - yes all uses stand alone in CG zone and allowed in combination
by code. note* and minor automotive repair - permissive not requirement.
Supplemental regulations - buffer and landscape and off street parking regulations -
the site plan met all these supplemental regulations.
• Look at alcohol sales and hours - code is mostly to guide restaurant use- allows a
restaurant to stay open but not serve - this is a matter left for another day - when
alcohol permit is requested
• Parking entitlements of Beach Diner - city has no obligations to enforce lease - this
is a landlord lessee issue for an independent court - No specific number of spaces
allotted to beach diner, lease does not allow for use by outparcel lessee to
specifically utilize parking the the shopping centers parking, 1997 expansion - no
follow up by applicant or city that the parking was conditioned on parking space -
just permission of lessor
Thursday, May 12, 2016
• Ingress and Egress - meets city's minimum requirements - must be with permission
of applicant
• Review communications from objectors and provide historic info about how local
cities administer their code and if this permit is in accordance with that historical
precedent. Issued a review - Duty is to impartially administer black and white
language of code - Code was properly administered in issuing this permit.
GATE Presentation
• John Peyton - 2 year process - accusation that this process was not transparent -
Untrue - looking for many years - found a distressed site in foreclosure - Gate
would not have purchased this property if it were not a permitted use - DO not buy
property that requires rezoning. Did confirm with city that their reading of the code
was correct and that it was permitted under current code. Not a mega store (up to
15 pumps) - a Neighborhood store - the design is unique and specific to the
beaches community Tearing down a building that is 3 times larger and is not in
compliance with current parking code. Bus code - busses fuel all over the city. All
buses will not fuel a this location all the time. Conflict with Beaches diner - believe
that it can coexist -dispute is about parking - BD believes that they are entitled to
unlimited to parking that is unencumbered in their lease - city has not engaged in
the tenant landlord dispute.
• TR Hanline - Site development plan process - staffs' role - administrative position -
does not legislate or create new standards and by law can not make decisions
specific to an appeal or objection - they must apply code fairly and evenly or they
are outside the limits of the law. Can only apply code as it exists. Gate is not
requesting a variance, exception or waiver. Gate's plan meets or exceeds the
standards of the current code. Gate even agreed to comply with new standards
adopted after they had purchased this property - they did not ask to be vested or
grandfathered under previous more relaxed standards.
• Tony Robbins, Prosser - Planning and Public Administration - A service station with
a retail store is allowed under the land use guidelines for this site. Zoned
commercial general - the most intensive zoning designation. Pyramid - commercial
limited is a step down from CG and then he next step down is commercial
professional office. All less intensive uses are allowed in more intensive districts.
• Brad Davis, Prosser - Civil Engineer, engineer of record on this project- began due
diligence in 1/2014 - review of code, use, setbacks, parking, pups, engineering, D/
W connections, utilities available. 9/9/2014 - requested a zoning confirmation letter
2
Thursday, May 12, 2016
from COAB - provided on 10/7/2015 - use was permitted, no concurrency. Then
prepared the submittal package as required by COAB sec 24-67 - 10/12/2015 - 2
rounds of comments - approval granted 2/9/2016 - comments form public works on
utitilites, engineering also answered. All code is met or exceeded including:
sec 24-161- off street parking and loading (current building doesn't meet current
code)
sec 24-165 - service stations
sec 24-66 - stormwater, drainage and treatment requirements (current building
doesn't meet current code - this plan more than doubles AB standards, storage
meets both peak flow and peak storage demands)
• Russ Irvine, Architecture and design practice, took architectural cues from ABCC -
white brick material from the building - seen in skirting and frontage, also weathered
wood lap siding, careful attention paid to rear elevation - wood lap siding and bhama
shutters to add a softer residential feel to the rear view from sturdivant.
• Janet Whitmill, Landscape Architect, water conservation and local plants - meet and
exceed requirements by approx 1.5 times. Water star certification - dictated by water
mgmt district. Based on Citizen in put - new plan is 2-3 Times requirements - goal is
screening per residents - for water conservation - trying to reduce sod areas - tried to
use salt tolerant and meet water star requirements
• Austin Chapman, Prosser, Transportation Engineer, traffic counts show that a thriving
shopping center would actually generate more trips both primary and secondary.
Calculated according to currently accepted methodology. Atlantic, strdivant, sylvan,
pine all meet FDOT standards for expected traffic.
• Mark Bachara, director of security, GATE - When crimes are committed in and around
service stations - they are sminilar of those committed in other retail locations -
crimes of opportunity. GATE uses SOA surveillance, robust cash mgmt, clear lines of
site into and out of store, zero tolerance for illegal activity. Front windows free of
advertisements for clear site lines. minimum of 2 employees in store at all time, walk
property
• Courtland Eyrick, Appraiser, MAI - study of effect that Gate Service Stations have on
paired sales in single family residences: Does not adversely affect residential
property values - however retail centers that are underutilized or in disrepair can
adversely affect property values
3
Thursday, May 12, 2016
• TR Hanline - Parking issue - argument stated to representatives - in 1997 - Adeeb
filed applications for variance from required setbacks and permit for expansion of
Beach Diner - told at variance hearing that he would still have to meet parking
requirements - not that the shopping center would have to meet parking
requirements. email 11/13/15 from Adeeb -no specificity, no lease, no assigned
parking for Beach Diner - no documented right to any specific number of spaces in
adjacent parking center. * Note - permits issued by city do not convey rights of one
private party to another party - only a deed, easement or lease between the parties
can grant property rights - and if one of those agreements is entered into then the city
has not role in enforcement of said agreement. A permit does not give away or take
way private property rights. Our code requires that the shopping center have 84
dedicated spaces for its use and those spaces cannot be double counted in the
Beach Diner's parking allowance.
• Mike Kinnard, Store manager - Gate provides job, promote from within - opportunities
for advancement, Provide a safe, friendly environment where store employees go out
of their way to assist customers.
• TR Hanline - agree to be bound by renderings of architectural plans as well as
enhanced landscape engineering plan - 2 offered conditions over and above code.
• Mayor Peyton - good faith to meet and exceed requirements, transparent, have
engaged commission and community, search for remedy for unhappy citizens - while
we can revisit our code - we have to apply current rules to this application.
Cross Examination
Sneed/Davis: is an engineer, applied terms as defined.
Sneed/Irving: regulations and codes - applied when designing a project, Defined
terms, applied as written
Sneed/Whitmill: Landscape architecht, regulations and codes applied as defined
- Sneed/Robbins: Heard Lindorff's testimony, agree that the process of a zoning is
minatorial - are not allowed to create policy but only apply code, Testified regarding
1997 variance of Mr. Adeeb - but has no personal knowledge of proceedings or of
record keeping processes in AB in 1997
Sneed/Lindorf: Not a Lawyer, No legal training to interpret leases, contracts, etc.
testified that employees of the city must apply the code as written.
4
Thursday, May 12, 2016
Convenience stores and gas stations limited to 6 pumps are both express uses
permitted in CL and therefore in CG zoning districts. How many seats does Beach
Diner Have? Expired 2010 DBPR license shows 94 seats - in report that is 19 years
old - Beach Diner showed outdoor seating - not used in calculations. If parking is
calculated on a shopping center standard - then number of seats doesn't matter if it is
in the same parcel. Steve Lindorf - laymen's interpretation of a lease, question left
incomplete. Moved on to outside dining - does it surprise you that there was outside
dining - showed picture - no food on tables - no evidence of dining. Lindorff Report
Except questioning - fairness - yes, consistency - yes, comprehensiveness - yes - it is
improper for a zoning director of the city to give misleading information during the
zoning process. Lindorff - in principal yes- but that mistakes can be made based on
current information, It is improper for a zoning director to intentionally give mistaken
information to an applicant - yes. It is inappropriate to ask only one interested party
for information regarding disputed material -yes, Would a independent restaurant
with 119 seats need 30 parking spaces under the current code - yes
- Sneed Hubsch: Did you rely on Lindorff review to determine it would be a service
station - yes as well as code, historic information. Use of the word and - does it
require all of the above? - Hubsch -example - beer distribution - e allow for distribute
of beer and wine and we allowed him to sell only beer. Shall is always mandatory -
Hubsch agrees - a particular or specific shall control over general - code defines and -
defines that all the connected provisions SHALL (aka Must) apply. Definition -
automotive service station and minor automotive service. Hubsch - clarifies
automotive repair the code has always intended to limit service - and would require
automotive service - which would be a more intense use than what has been
permitted. Gate - seating diagram for restaurant - hubsch did not ask beach diner for
a seating diagram because he was neither the applicant nor owner. No outdoor
seating was present at the time of submittal or issuance of permit. Reemphazied
repeatedly - no one had any personal knowledge of Mr. Whorly's methods or what
was applied to the 1997 variance. Email - shopping center standard -12 spaces -
restaurant standard verbally told that 4 seats 1 space. Expansion of restaurant -
requires more parking. Again with the how were standards applied in 1997? No way
of knowing. Was advance notice provided to Adeeb of approval? No, any need to
provide parking information - applicant provided, confirmed submitted seating plan
visually. Under current code if 119 seats - need 30 parking spaces.
West/ Payton: Why gate is not amenable to building with just 6 fueling stations - goal
is to meet demand during peak hours - site is limited - goal is to meet peak demand -
is it financially feasible? Would you still make a profit? Cannot speculate. Cost
5
Thursday, May 12, 2016
benefit analysis of 6 fueling stations - no study done. Becky Hamilton VP of Real
estate - Deliveries - 5-6 weekday 1-2 satruda, none sunday
- West/Hubsh - Why is a convenience store with gas, limited - why is that treated as a
use by exception in CL district - To prevent Targe station at large intersection - why
was this updated in code - no discussion in minutes - 3/2008 Sonja Doer - variance to
add gas to an existing convenience store on Mayport Road. To avoid lighting canopy
and large megastationas it would be objectionable to adjacent neighbors. Stated that
both retail sales and automobile service station - code allows for mixed usage.
Convenienece stores are not specifically referenced in the code? No Hubsch - they
are specifically mentioned. In 1982 code - CL provision - conveience food store with
retail gas sales - updated to add a restriction for 6 fueling positions in 2002. prior to
that the code said that all gas stations require a use by exception in CL - intent of
planners in defining the number of pumps was to avoid megastations. - they did this
in CL district - In CG - higher classification - no pump restrictions - 3 places they could
have placed restrictions in the code - but they did not - no goal to limit pump numbers
in CG - not your role to deny a submission but to inform them of deficiencies. How
much weight to preambles? States goals - guiding document - steers guiding uses
permitted below it. Any ambiguous sections of code in reviewing this project - No.
Eakin Presentation -
On behalf of himself and the co-owner of his property - no personal vendetta against
Gate Gas. Object to site plan based on zoning.
- Hubsch relied on Lindorff's report regarding zoning. Mr. Lindorff - this limiting
provision does not apply to the proposed project however b/c food stores are
permitted by right under our code regardless of size or type, and an automobile
service stations permitted by right subject to no limitations. Convenience with retail
sales of gasoline is also a permitted use in CG just like the above - BUT it carries a
restriction on 6 pumps.
- The law is that if different language is used in different portions of the code then they
are intended to have different meanings. difference in terminology is significant - a
retail outlet for the sale of food is not the same as a convenience store? Failed to
define the difference between the two - just to state there is a difference.
6
Thursday, May 12, 2016
- All of AB's gas station with retail sales. i.e. Kangroo station with more pumps on
Mayport road is classified as a convenience store with gas according to Duval County
Tax Appraisers office
- Eakin - rebuts that adding minor automotive repair is more intense that an additional
pump - - tire changes and oil changes - air driven power tools are in his opinion Tess
intense than a fueling position
Sneed Presentation
• Procedural Objection - unclear basis for objection
• Testimony about email - 4/25/2014 - From Hubsch to gate - already recanted on
reading further into code
• Asked to read additional email into record - In response to an email from Ross
(prosser- planner) don't have a strong opinion on 10 pumps - will get pulse of city mgr
and atty if they are headed that direction. Hubsch in response to emails - these were
a cursory review of conceptual project - fall of 2014 - reached decision just before
11/10/2015
• Convenience store - 6 pumps more restrictive than retail store of 6400 sq feet & 7
pumps - yes (hubsch)
• Adeeb - how did he come to lease? - made a deal with property owner needed to
expand - if approved would sign lease - hence 1997 variance request - granted and
sign lease.
• Adeeb testified that he signed off at city (no evidence) to be representative of
landlords Bill Nicol and John Green - property owners - so Adeeb attended CDB
meetings personally - Note * is this his testimony why there is no evidence that
landlords gave approval as required by the city.
• Testimony regarding seats - 1997 - 94 - indoor seats/25 outdoor seats despite that
drawing shows 76 seats inside/ 25 seats inside on variance request to the city
• INside has not changed since 1997, outside seating changes repeatedly
• Traffic study - 65-85 spaces needed on a weekend and 40-60 spaces during week.
West Presentation
7
Thursday, May 12, 2016
• Convenience store - not a takings case - decreased profit margin - not the city's
problem
• Reliance on preamble is legally allowed - Blackman vs. Miami
• Burden of Proof - competent substantial evidence
• Dodi Glass - Concerns - not due thought given to existing business and focused on
CL designation though this project is CG
Hainline X Adeeb:
• Answers about seats - 94 inside/45 seats no service outside at time of issuance of
permit
• Deposition 4/14 - 80 seats - erratta sheet - 94 after coating seats
• Require 30 spaces under code - 118/4
• Which is it?
• 11/30/2015 - Exhibit #23 - email to Hubsch from Adeeb - knew 19 spaces were what
the city was requiring under code from Gate.12/1/2015 - additional email offering to
meet with Jeremy at any time - this goes counter to testimony that he was not
advised by the city at anytime what was going to be required of gate regarding
parking.
• X Flowers - opinion - no data or computation done to come at 10% net Toss that he
testified to.
• X glass - pyramid zoning - restrictions decrease as intensity of category increases -
Yes (glass)
• Agreed also that zoning code is how complain is enacted.
TJ felt that the purpose of the constitution would be entirely defeated if interpreting it as
a legal document - he spoke out constantly for careful adherence to the law as it is
written:
Our peculiar security is in the possession of a written Constitution Let us not make it
blank paper by construction
8
Thursday, May 12, 2016
Jefferson: The general is then an instrument is to be so construed as to reconcile and
give meaning and effect to all its parts. TJ
The legislature's laws have always some rational object in view; and are so to be
construed as to produce order and justice.
Common sense is the foundation of all authorities of the laws themselves, and of their
construction
Compromises suggested by speakers
Reduce fueling positions
Add electric charging station
decrease lighting by 20
Increases beaches diner parking
Call to review and revamp zoning codes
Conditions gate offers - 24 parking spaces, enhanced landscaping, willing to add an
accessory carwash or service bay, to be bound by renderings of architectural plans
Questions:
Elected to carry out the will of the people
Jeremy - speak to evolution of language over time and age of code - 1982 vs today.
Jeremy speak to how our comprehensive plan reconciles our residential character with
the fact that we are bordered by 2 commercial corridors. we have Asked to look at the
comp plan as the constitution and be our guiding principle. And TJ felt that the purpose
of the constitution would be entirely defeated if interpreting it as a legal document - he
spoke out constantly for careful adherence to the law as it is written:
Our peculiar security is in the possession of a written Constitution Let us not make it
blank paper by construction
9
Thursday, May 12, 2016
When were Kangaroo and BP on mayport rd permitted? - prior to change in code -
however - if they had been judged under the CL zoning prior to change where limitation
of 6 fueling stations - would have been a use by exception - they did not - historical
precedent is that these stations have not needed a use by exception - they have been
permitted in CG- Tab 27 A - mixed use convenience store and gasoline service station
Environmental impact studies - included in the ABC exhibits - read over lunch
Mr. Hanline - you mentioned how many things you do above and beyond -is there
anything that Gate as a company or this station in particular will do to limit
environmental impact
We are elected to carry out the will of the people
St. Augustine rescinded permit for 7-11 - has not affected their stature as a business
friendly environment - they are growing by leaps and bounds. - can you give a specific
example in regard to this particular local case of rescinding an offer has had a negative
impact on real estate values
Higher intensity use - retail sales of food or convenience store? since retail sales of food is only in CG -
seems that this is higher intensity use - does it matter? Yes - if a convenience store is allowed as a less
intensive use then it is allowed de facto.
Common sense is the foundation of all authorities of the laws themselves, and of their
construction
Mrs. West - In your opinion - do you thinK that it makes common sense for us to require
Gate to put a car wash or service bay to be in compliance with the letter of the law to be
a service station as permitted?
Mr. Sneed?
Mr. Eakin?
Testimony regarding gas station as a negative externality suggested a 10% decrease in
property values - seems that no account was taken into the fact that a dilapidated under
10
Thursday, May 12, 2016
utilized shopping center is also a negative externality - seems that estimates may be
grossly exaggerated.
Mrs. West - do you agree with the contention that a dilapidated under utilized shopping
center is a negative externality with regards to adjacent property value?
Negotiation
30 spaces with waiver for impermeable surface increase to 76% and waive the terminal
tree islands in 4 locations
Ingress only on Sturdivant - no egress to the North
vacuum station moved to front of property
enhanced landscaping with eye to line of sight
willing to be bound by renderings of architectural plans
Dumpster service - 7 AM and 9 PM
Outdoor Speakers - prohibited except for safety regulations
HVAC shall be kept behind opaque enclosures to further reduce sound and screened
from view.
*Curbside parking from the city
Offsite parking for employees
11