HomeMy WebLinkAboutTemp. Occupancy Comments~ i
MERIDIAN CITY COUNCIL MEETING: January 21,1997
APPLICANT: ALBERTSONS INC. ITEM NUMBER; 10
REQUEST: DISCUSSION OF TEMPORARY OCCUPANCY
AGENCY
CITY CLERK:
CITY ENGINEER:
CITY PLANNING DIRECTOR:
CITY ATTORNEY:
CITY POLICE DEPT:
CITY FIRE DEPT:
CITY BUILDING DEPT:
MERIDIAN SCHOOL DISTRICT:
MERIDIAN POST OFFICE:
COMMENTS
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ADA COUNTY HIGHWAY DISTRICT: ~~
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ADA COUNTY STREET NAME COMMITTEE:
CENTRAL DISTRICT HEALTH:
NAMPA MERIDIAN IRRIGATION:
SETTLERS IRRIGATION:
IDAHO POWER:
US WEST:
INTERMOUNTAIN GAS:
BUREAU OF RECLAMATION:
OTHER:
All Materials presented at public meetings shall become property of the City of Meridian.
MeulemanMiller&Cummings 1
LAW OFFICES
~~Ir F,M N,~MII,LER & CUMMING,~1.L~
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XOBHRT L. M1t.LBR
RICHARD w, MOLl.L1tUP
TELSPHONB tJ03J 3~/J~066
TBI,BAAx(soBJ 336-9712
*uC&NSED JN1DA!!O AND NBvADA
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••'•1ICBNSBD IN IDAHO ANA wASXINCTON
••••LlCBN3'BD 7N 1DAH0 AND CALlPnRNIA
January 16, 1997
Mr. Will Berg
City Clerk
City of Meridian
33 B. Idaho
Meridian, Idaho $3642
Re: Albertson's Store, Tcn Mile Rd and Cherry Lane;
Dear Will:
As you are aware, this fum represents Albertson's, Inc. in connection with the above
mferenced store. At the City Council meeting on September 3, 1996, the Council agreed to issue
a 90 day temporary Certificate of Occupancy subject only to resolving the issue of the easements
for sewer and water between Albertson's and Mr, Lovan, the adjacent property owner.
The temporary Certificate of Occupancy was issued on November 7, 1996. The
Conditions/Comments section of the certificate states "This is a 94 day Temporary Occupancy
pending easement agreements." Albertson's hereby requests to be placed on the agenda of the
City Councit meeting on 1liesday, January 21, 1997 for the purpose of requesting that the
condition be removed and a permanent Certificate of Occupancy be issued.
Thank you for your cooperation.
ly you ,
Richard W. M emp
RWM: uis
cc: Mikc Baldner
Bob Banks
Bil! Arnold
JAN 16 '97 16 47 1 PAGE.02
Jan-16-97 04:41P MeulemanMiller&Cummings 1
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Original m Follow: Yes No
JAN 16 '97 164? 1 PAGE.01
Jan-21-97 03:45P MeulemanMi l lerB~Cummings
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1
MEULEMAN, MT[.LER & CUN1MllVGS LLP
9G0 Broadway Avenue -Suite 400
Post OtTice Box 955
Boise, Idaho 83701 ~tECEiVED
JAN 2 1 ]997
TF.t,F,RAX C.QVER SHEET CITY OF MERIDIAN
DATE: January 21, 1997
TO: Will Burg FAX NO, 887-4813
COMPANY: Meridian City Clerk
CC TO: Wayne Crookston, Jr. FAX NO. 888-3969
Michael E. Baldner FAX N0.385-6888
FROM: Richard W. Mollerup
R~: Albertson's Certificate of Occupancy
Albertson's Store located at Ten Mile & Cherry Lane; Meridian, TA (MM&C #125,372)
TOTAL NUMBER OF PAGES SENT tincludvigwvereAeo(): 7
TIME SENT: 3:50 p.m.
SENT BY: Brandi
IF YOiJ DO NOT RECEIVE ALL TkiE FAGES, PLEASL CALL US BACK AS SOON AS
POSSIBLE -- PHONE 208-342-6066; TL-LEFAX 208-336-9712
DOCUMENTS TRANSMITTED: January 21, 1997, Memorandum.
MESSAGE: Please present this Memorandum at tonight's Council meeting,
CONFIDBNTIAUIY NOTTC'F.
THF, INFORMATION C:ONTatNF.l) iN THIS FACS(Mit,l> I5 C't)NI~U)LN'11AL INI~U)tMATCON OR ATTORNEY WORK PRODUCT Ok b(Yrtt ANt) IC
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JAN 21 '97 15 51 1 PAGE.01
MeulemanMiller&Cummings 1
LAW QFFICFS •
MEULEMAN, MILLER ~ CUMMINGS LLP
RUSINhS.S LAW • REAI. ESTATE LAW • t:C)NSTRUC'rION LAW
KtMtiERLY J. BLAS•
MrCI~E~E L BUYD•• 960 DRC)At)wAYwVE„ SUITE +00
R1(:! WLD A. LvMMlA1Gg pC~ST OFFICE e0X 955
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OEOfFREY ). McC'C)NNELL••^
WAYNfi v MEULEMAN
RQBERT L MILLER
RLC,HARD Vv. MOLLkR(:P
MEMORANDUM
TO: City of Meridian
FROM: Richard W. Mollerup
Counsel for Albertson's, Inc.
DATE: January 21, 1997
(208)341.6066
EAX
(IOS)336r91)2
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SUBJECT; Certificate of Occupancy
Albertson's store located at the intersection of Ten Mile Road and Cherry Lane;
Meridian, Idaho ("Albertson's Store")
This Memorandum is given in support of Albertson's request for a permanent Certificate of
Occupancy for Albertson's Store.
ISSUE
The sole issue addressed in this Memorandum is whether the City should remove the condition for
"pending easement agreements" from the 90-Day Certificate of Occupancy issued November 7,
1996, under Permit No. 15788.
AppI,1CABLE CITY ORDIN~,~C~F,S
The City has required that Albertson's construct sewer and water lines across its property to the
property adjacent on the west owned by Mr. Lovan. The City's position was based upon Sections
5-1?~ and 7-517 of Meridian City Ordinances which read as follows:
"All proposed !ex?~siQns of the municipal water,~ystem to serve undeveloped
areas...shall comply with existing water system extension policies and the overall
master plan for City's municipal water supply system. The cost for all extensions
to any property shall be the responsibility of that property owner or his agent. The
cost for water service extensions within the property for which the extension is
requested shall also be the responsibility of the owner or his agent. ...such water
JAN 21 '9? 15 52 1 PAGE.02
MeulemanMi l ler&Cummings 1
MEMORANDUM
TO; City of Meridian
FROM: Richard W. Mollerup
Counsel for Albertson's, Tnc.
January 21, 1997
Page 2
line extensions, public or private, shall be extended to the farthest boundary of the
property."
Section 5-124 Meridian City Ordinance.
t~
The owner or developer of a new subdivision or a development whether
subdivided or not shall, at his expense, construct the ~ extensions of t_he
public sewer,~vstem to provide public sewer facilities for each lot or building area
in a subdivision; additionally, the owner or developer shall have the responsibility,
at his expense, of installing the main sewer line to the boundary of his development
which is farthest away from the point at which the initial connection is made to the
present city sewer main.
Section 7-517 Meridian City Ordinance.
The proper ordinance regarding sewer i believe should be Section 7-527 rather than 7-517. The
above portion of City Ordinance 7-517 (which has been quoted by the City Attorney) is one
paragraph of a five paragraph ordinance and deals with required use of sewers, not sewer line
extensions. The thrust of 7-517 is that the owner or occupants of houses, buildings and other
property situated in the City which abut or have a permanent right of access on a street or alley in
which there is located a public sewer are required to cease other methods of sewage disposal.
Section 7-527 is the sewer ordinances that corresponds to the water ordinance Section 5-124 and
reads as follows:
"All proposed extensions of the municipal sew,~raae svstem to serve undeveloped
areas ...shall comply with the overall master plan for the City's municipal
sewerage system. The costs for al! extensions which lie outside the boundary
limits of the property for which the extension is requested shall be the
responsibility of the property owner or his agent. Costs for sewer extensions
within the property for which the extension is requested shall also be the
JAN 21 '97 15 52 1 PAGE.03
MeulemanMi l ler&Cummings 1
•
MEMORANDUM
TO: City of Meridian
FROM: Richard W. Mollerup
Counsel for Albertson's, Inc.
January 21, 1997
Page 3
responsibility of the owner or his agent. Sewer extensions shall be required to
extend to the farthest boundary of the development ...."
Meridian City Ordinance Section 2-527.
FA T
On May 9, 1996, the City of Meridian issued a Stop Work Qrder citing (i) size and grade of
sanitary sewer line, and (ii) Albertson's failure to provide water service to the Lovan property. At
that time, asix-inch sewer line was being installed in front of the Albertson's Store and the City
had requested an eight-inch line. During a meeting between the City Engineer, Mayor, Scott
Edens of Albertson's, Inc., and Albertson's Engineer on May 9, ] 996, the City approved the
installation of a six-inch sewer line in front of.Albertson's Stare. That approval was confirmed by
letter dated May 14, 1996, to Mr. Gary Smith, City Engineer, from Craig Slocum of CSIiQA
Architects.
On June 17, 1996, the City issued a Stop Work Order prohibiting work on the fire hydrant until a
decision was made on the 11/2 inch service. By field order dated July I i, 1996, Albertson's was
directed to proceed with the installation of a 1'/z inch domestic service line to the i.ovan parcel
adjacent to the west and the Stop Work Order dated June 17, 1996, was repealed.
Although Albertson's did not believe it was IegaUy required to install sewer and water lines to Mr.
Lovan's property or grant easements under Meridian City Ordinances, in the spirit of cooperation,
Albertson's agreed to do so. On September 3, 1996, the undersigned appeared before the
Meridian City Council on behalf of Albertson's to request the Council's approval of a Sewer
Easement from Albertson's to the City, a Water Easement from Albertson's to the City and a Late
Comer Agreement to obtain reimbursement for a portion of its construction costs pursuant to
Meridian City Ordinance Sections 5-124(b) and 7-527(b). During the Council meeting on
September 3, 1996, it was the City's position it could not accept the above easements or the
above sewer and water ]fines for maintenance due to the size of the lines, As a result, the Council
requested that Albertson's grant sewer and water easements directly to Mr. Lovan. Since the City
Engineer had testified that he had reviewed the easement forms and they appeared to be in the
same format as standard easement forms and, therefare, acceptable, Albertson's stated that they
would be willing to grant Mr. Lovan the same easements they intended to grant to the City;
JAN 21 '97 15 53 1 PAGE.04
MeulemanMiller&Cummings 1
MEMORANDUM
TO: City of Meridian
FROM: Richard W. Mollerup
Counsel for Albertson's, lnc.
January 21, 1997
Page 4
provided, however, Albertson's would not require Mr. Lovan to assume all maintenance
obligations as the City would have been required to do, but would agree to share the maintenance
obligation4. Councilman Roundtree stated, "My concern is that we are pursuing easements for
ourselves and willing to accept the terms and conditions, why would we expect anything different
or would we be negotiating for Mr. Lovan if the casements were in the City. Would he have bccn
made a part of the negotiations of those easements." After some discussion of the reasonableness
of A]bertson's in offering the easements to Mr. Lovan, the Council passed a motion authorizing
the issuance of a 90-Day Certificate of Occupancy to Albertson's, which could only be terminated
in the event the Council determined that Albertson's was unreasonable in its negotiations with Mr.
Lovan regarding the easements. Councilman Morrow stated that, "Once the effort has taken
place, if there is no willingness on [Mr. Lovan'sJ part to participate, then very candidly our staff
goes back to the City and says `This is where we are and there is no desire on Mr. Lovan's part to
negotiate' and from that point on we make the decision as a Council as to where we want to go
and were off and gone."
On September 23, 1996, Albertson's submitted a draft Grant of Water and Sewer Easements and
Maintenance Agreement ("Lovan Easement") to Mr. Lovan's counsel. On October 22, 1996, a
follow-up letter was sent to Mr. Lovan's counsel requesting comments to the draft Lovan
Easement. As of this date, no comments have been received from Mr. Lovan or his attorney
regarding the Lovan Easement and the only communication with Mr. Lovan has been an offer
from him to sell his property to Albertson's.
1. Meridian City Ordinan~,~s 5-124 and 7-527 are not at~nlicable in this instance and
c 4titLte an unc n~titL Tonal to ing, It has always been Albertson's position that the
above-quoted City Ordinances do not apply to the construction of Albertson's Store.
Both City Ordinances are premised on extensions of the municipal systems to serve
undeveloped areas. The construction of Albertson's Store does not extend the municipal
system for either water or sewer. Existing water and sewer was located in the right-of-
way for Ten Mile Road at the time of the construction of Albertson's Store. The
construction of Albertson's Store contemplated only connection to the existing municipal
systems and did not require the expansion of either system. The ordinances appear to
contemplate an expansion of the municipal systems within the public right-of--way. No
JAN 21 '97 15=53 1 PAGE.05
Jan-21-97 03:47P MeulemanMillerBCummings 1
•
MEMORANDUM
TO: City of Meridian
FROM: Richard W. Mollerup
Counsel for Albertson's, Inc.
January 21, 199"7
Page 5
provision in either ordinance contemplates an easement be granted for such extension
lines. Had the drafters of the ordinances contemplated the construction of expansion of
municipal water and sewer lines on private property, the requirement to grant easements
for those lines would have been included in the ordinances. in short, since there was no
"extension" as contemplated by the Ordinances, Albertson's never had the obligation to
further extend the utility lines to the property boundary. Further, even if an extension
took place, the Ordinances do not permit the City to acquire an easement across private
property without compensation, let alone permit the City to require an easement to be
granted to a third party without compensation.
2. The City has bee~„placed in the position of mediating a contract between ap roes. Through
a series of circumstances, the City has been placed in an untenable position of mediating or
orchestrating private contract rights between individuals. The sole condition contained in
the current 90-Day Certificate of Occupancy is "pending easement agreements" between
Albertson's and Mr. Lovan. Use of its governmental authority to force private contract
rights is not a proper use of that authority.
3. Albert4on's has been more than reasonable in its offer of easements to Mr_ L.nvan. The
Lovan Easement was carefully drafted to contain the same terms and conditions as the
water easement, sewer easement and late comer agreement which appear to be acceptable
to the Council during the Council meeting on September 3, 1996. Meridian City
Ordinances 5-124(b) and 7-127(b) entitle Albertson's to reimbursement of "all or a
portion of the costs" of extending those lines from property owners who will benefit from
such extension who have otherwise not paid or contributed their proportionate share to
the construction costs. The actual additional costs of Albertson's construction of
additional water and sewer lines to Mr. Lovan's property was approximately $5,500.00.
.Albertson's should be entitled to reimbursements for all of that cost since Mr. Lovan's
property will derive the sole benefit of that additional cost. Nonetheless, Albertson's
agreed to prorate the costs of the construction of the water and sewer lines on a square
footage basis and the Lovan Easement requires only that he reimburse Albertson's
$563,50 at the time the owner or occupant connects to the water line and $2,692.62 at the
time the owner or occupant of the Lovan property connects to the sewer line for a total of
$3,256.12. In addition, the maintenance provisions of the Lovan Easement have been
changed from the easements offered to the City. The easements offered to the City
JAN 21 '9? 15 54 1 PAGE.06
MeulemanMiller&Cummings 1
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ML• MORAN~DUM
TO. City of Meridian
FROM: Richard W. Mollerup
Counsel for Albertson's, inc.
January 21, 1997
Page 6
required the City to perform and pay for all maintenance of both the sewer and water line.
Under the Lovan Easement,lvLr. Lovan would only be obligated to reimburse Aibertson's
for 17.05 percent ofthe actual cost of such maintenance.
4. Mr Lovan has refused to cooperate or ngg~tiate with Albertson'$. The Lovan Easement
draft has been in Mr. Lovan's possession for four months and at no time during that four
months have any comments to the substance of that easement been received by
Albertson's. By his refusal to communicate with Albertson's, Mr. Lovan has refused to
negotiate any reasonable resolution to this issue.
The City should remove its condition to Albertson's 90-Day Certificate of Occupancy and issue
an unconditional permanent Certificate of Occupancy. I reiterate Councilman Morrow's convnent
on September 3, 1996, "Once an e1I'ort has taken place, if there is no willingness on [Mr. Lovan's]
part to participate, then very candidly our staff goes back to the City and says `This is where we
are and there is no desire on Mr. Lovan's part to negotiate' ...." I respectfully submit that this is
where we are. The City should remove itself from a position of negotiating private contract rights
and issue the Certificate of Occupancy without further delay.
RWM:bIg
JAN 21 '97 15 54 1 PAGE.O?
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DECEIVED
JAN 2 1 1997
qTY OF 1~ER1D~t~~
January 29, 9997
Mayor & City Council Members
City of Meridian
33 E. Idaho
Meridian, ID 83642
Re: A/bertson's at Ten Mile & Cherry Lane Store
Dear Sirs
Please postpone Item # 10 on tonight's City Council agenda concerning
Albertsorf's discussion of the temporary occupancy permit. This concerns an
agreement between them and myself and we haven't come to that agreement as
of yet. After discussing this issue with my attorney (Howard Manweiler), we are
asking for this delay due to the lateness of receiving the information from Richard
Mollerup which you received via faxed to you this afternoon. Thank you for your
consideration.
Sincerely
Wally Lb an
** TX CONFIRMATION REPORT **
AS OF JAN 21 '9?'18 02 PAGE.01
CITY OF MERIDIAN
DATE TIME TOiFROM
06 01121 17 57 2083450365
MODE MIhVSEC PGS CMDti STATUS
EC--S 04'59" 011 180 OK
MERIDIAN CITY COUNCIL MEETING;__ January 21.1997
APPLICANT: ALBERTSONS INC. ITEM NUMBER; 10
REQUEST: _ DISCUSSION OF TEMPORARY OCCUPANCY
AGENCY COMMENTS
CITY CLERK:
CITY ENGINEER:
CITY PLANNING DIRECTOR:
CITY ATTORNEY: ~~
CITY POLICE DEPT: / ~~
CITY FIRE DEPT: ~~ ~ja'~
CITY BUILDING DEPT: ~ n
MERIDIAN SCHOOL DISTRICT:
MERIDIAN POST OFFICE:
ADA COUNTY HIGHWAY DISTRICT:
ADA COUNTY STREET NAME COMMITTEE:
CENTRAL DISTRICT HEALTH:
NAMPA MERIDIAN IRRIGATION:
SETTLERS IRRIGATION:
IDAHO POWER:
US WEST:
INTERMOUNTAIN GAS:
BUREAU OF RECLAMATION:
OTHER:
All Materials presented st public meetings shall become property oTthe City of Meridian.