HomeMy WebLinkAboutLetter by Sherer & Wynkoop, LLC
04/13/2007 14:19 FAX 2088874865
SHERER&WYNKOOP.LLP
Igj 002/004
Law Offices
Stephen T. Sherer
David E. Wynkoop
Attorneys at Law
SHERER & WYNKOOP, LLP
730 N. Main Street
P.O. Box 31
Meridian, Idaho 83680-2604
ssdwlawlBlmcleodusa.net
Phone 208~887 --4800
Fax 208-887-4865
April 13, 2007
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APR 1 3 2007
City Clerk
Meridian Planning and Zoning Commissioners
33 E. Idaho
Meridian, Idaho 83642
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Via facsimile to 888-4218
and first class mail
Re: Busted Shovel CUP to convert
restaurant to a bar
Dear Commissioners:
We urge your denial of the Busted Shovel CUP application. As downtown Meridian
businessmen and property owners, we are of the opinion that this CUP request is not in the best
interests of the downtown merchants, the City of Meridian, or the citizens of Meridian. We are
unable to personally attend the hearing because of prior commitments. Please consider this our
written testimony.
1. Skid Row Problem.
There are now three bars within one block of the Busted Shovel, with a CUP
application in the works for a fourth. Counting the Busted Shovel as a bar results in five
bars with one block. There is a very real risk of this block becoming a low class skid
row. This is incompatible with the vision of a vibrant pedestrian friendly downtown. It
also risks lowering the property values of the other property owners in the vicinity. It
reflects badly on the City to allow expansion ofa "slum block", with attendant assaults,
public nuisances, drunkenness and other social problems, all within one~halfblock of the
new City Hall.
Generally, we have observed a deterioration in the quality of the business in the
change from "Harry's" to the "Busted Shovel." Previously, it was restaurant that sold
drinks. It is transitioning towards a pure bar and if this CUP application is granted, the
transition will be complete. This is highly undesirable for the kind of vision we all want
to create for downtown Meridian; namely, an attractive family friendly environment. We
certainly prefer to see this site become a quality restaurant that furthers the goals of
downtown redevelopment.
04/13/2007 14:19 FAX 2088874865
SHERER&WYNKOOP.LLP
Igj 003/004
Meridian Planning and Zoning
~2M
April 12, 2007
2. Sidewalk Problem.
The Busted Shovel has failed to comply with the conditions of its current CUP.
The Busted Shovel has an outdoor dining area located on the sidewalk. This sidewalk is
part of the public right~ofMway and is not private property.
The 1995 CUP required that a License Agreement be obtained from ACHD and
that a minimum five foot clear zone be maintained for pedestrian and bicycle traffic.
ACHD has confirmed that the Busted Shovel is illegally operating on the sidewalk
without a License Agreement. The License Agreement for the previous restaurant was
tenninated in May of 2006. According to ACHD, the Busted Shovel has never applied
for a License Agreement. Even though no License Agreement exists, the Busted Shovel
continues to use public right~of-way for a sidewalk cafe.
Also, everything was to have been located within 5-112 feet of the building.
(FFCL, Harry's Bar & Grill, p. 7, '5(2)), and to be moved inside after 10:00 p.m. (p. 7~8.
'6). See CUP request for Sidewalk Cafe, August 15, 1995, Harry's Bar & Grill. This
requirement has been repeatedly violated.
Our observation is that the prior business did a pretty good job of maintaining the
clear zone and cleaning up after its customers. This has deteriorated markedly since the
Busted Shovel took over the site. Busted Shovel customers regularly expand the outdoor
seating by pushing the railing toward the curb and tree well, well beyond what is allowed
by the CUP. This leaves inadequate room for pedestrians and bicyclists to use the public
sidewalk and certainly much less than the five foot clear zone required by the CUP. As
Meridian downtown grows and attracts more foot traffic, it becomes even more critical to
have adequate pedestrian facilities.
In 1995, both the Meridian Police Department and the Meridian City Engineer
opposed this outdoor seating. Since the Busted Shovel has failed to comply with the
conditions of this CUP, the prior CUP should be revoked immediately.
Moreover, failure to comply with past CUP conditions leads to the conclusion that
this business is unlikely to comply with any new conditions associated with a new CUP.
At the very least, the Busted Shovel should clean up its customers' cigarette butts
and beer bottles off the public sidewalk and behind the building.
3. Inadequate Parking.
Parking is now in short supply in downtown Meridian. The CUP application says
that the business has five private parking spaces, however, the landlord for the Busted
Shovel has previously refused to authorize Busted Shovel customers and employees to
park in the private lot behind the bar and has previously had customer and employee
vehicles towed. This places even more demand on the scarce available public parking
04/13/2007 14:19 FAX 2088874865
SHERER&WYNKOOP,LLP
I4J 004/004
Meridian PI8lU1ing and Zoning
-3.
April 12, 2007
spaces. Even five spaces is woefully inadequate. A business with 2400 s.f. of floor area
plus outdoor seating should have much more than five parking spaces. Unless the Busted
Shovel can prove to the City that it has an agreement for adequate private parking spaces
to serve the customers it attracts, this CUP should be denied based upon inadequate
parking.
4. Inaccuracies in ApDlication.
The application alleges it is made by the owner. Our understanding is that it is
made by the tenant, not the property owner.
In conclusion, we respectfully submit that downtown Meridian is moving forward in a
very positive manner consistent with the vision set forth by the City and the Meridian
Development Corporation. Converting the Busted Shovel to a bar is not compatible with that
vision and is a deterioration of the status quo. Please vote to disapprove this CUP application
and request staff to revoke the prior CUP or to strictly enforce the prior CUP conditions.
Sincerely,
22
David E. Wynkoop
STS/DEW fjlm
Cc: MayorDeWeerd