INFORMATION #4 07-22-2002DRAFT
Reply to Minneapolis
Peter K. Beck
612 343-5374
peter, beck~gpmlaw.com
July 22, 2002
William C. Griffith, Jr.
Larkin, Hoffman, Daly & Lindgren, Ltd.
1500 Wells Fargo Plaza
7900 Xerxes Avenue South
Bloomington, MN 55431-1128
Re~
Tollefson Development, Inc.
Twin Lake Crossing
Dear Bill:
This letter is in response to your letter of July 15, 2002, asserting that the
application of Tollefson Development, Inc. ("Tollefson") for approval of the Twin Lakes
Crossing project (the "Development") has been approved by operation of law. We
believe that a careful review of the facts regarding this Development does not lead to
such a conclusion.
Tollefson's applications for approval of the Development were filed with the City
on April 30, 2002. The applications were heard by the Elk River Planning Commission
on May 28, 2002. The Planning Commission recommended denial of the proposed
rezoning for the Development, finding that the e~:isting zoning of the property is
consistent with the City's comprehensive plan and that there is no compelling reason for
changing the existing zoning. This recommendation was forwarded to the Elk River City
Council for final action by the Council. The Council hears and decides planning
applications on the third Monday of each month. Tollefson's applications were,
therefore, scheduled for hearing and action by the City Council on June 17, 2002.
Because the Development as proposed involved significant filling of wetlands, the
Development was also reviewed by the City of Elk River Technical Evaluation Panel
("TEP") on May 30, 2002. Tollefson and its consultant were present at this meeting.
The TEP found that the Development as proposed violated the State Wetland
Conservation Act, due to excessive filling of wetlands, and recommended a number of
changes to the Development, including the relocation of roads and the elimination of
some lots. Tollefson indicated that revised plans would be prepared and submitted for
review by the TEP, and a second meeting of the TEP was scheduled for June 13, 2002 to
review the revised plans. This meeting was scheduled so that TEP review could be
completed prior to City Council review and action on the Development on June 17, 2002.
However, no revised plans were submitted and Tollefson did not show up for the June 13,
William C. Griffith, Jr.
July 22, 2002
Page 2
DRAFT
2002 TEP meeting. The TEP therefore recommended denial of the Development to the
City Council.
On June 14 and 17, 2002, city staff had conversations with Tollefson regarding
the recommendations of denial from the Planning Commission and the TEP and the
upcoming City Council meeting on the evening of June 17, 2002. Tollefson was advised
that the Development could go ahead to the City Council with recommendations of denial
· from the Planning Commission, TEP and staff; or the Development could be continued to
the Council's next planning agenda, on July 15, 2002, to allow for the submission of
revised plans to address the Planning Commission and TEP issues. Tollefson indicated it
preferred the matter be continued, and was advised that such a request would have to be
made in writing. The enclosed letter from Tollefson was received by fax during the day
on June 17, 2002.
In its letter, Tollefson indicates that it is "in the process of finishing up the
revisions to our plans for Twin Lakes Crossing", and requests that the City "please
continue consideration of our pending request for rezoning and preliminary plat approval
to the next earliest possible date with the city council." In response to this request, the
City Council opened the public hearing on the development at its regular meeting on
June 17, 2002, and continued the public hearing to its next planning agenda on July 15,
2002.
City staff continued to discuss the Development with Tollefson following the
June 17, 2002 City Council meeting, and advised Tollefson that its request for a
continuance had been granted and that the Development had been continued to the next
planning agenda on July 15, 2002. In addition, the written minutes of the June 17, 2002
Council meeting specifically state that the public hearing on the' Development is
continued to July 15, 2002. (See enclosed copy of page 7 of the minutes of the June 17,
2002 Elk River City Council meeting.) These written minutes were distributed to the
public and approved by the City Council at its June 24, 2002 meeting, prior to the
expiration of 60 days from April 30, 2002.
In your letter of July 15, 2002, you state that the Development has been approved
by operation of law because the City Council did not act on it, "at the next meeting,
June 24, 2002". However, Tollefson did not request that consideration be continued to
the next City Council meeting. Tollefson requested that consideration be continued to the
"next earliest possible date with the city council". Tollefson was advised prior to making
this request that the next date for City Council consideration of planning items was
July 15, 2002, and that this was the date the item would be continued to. Following the
granting of its request for a continuance, Tollefson was advised of the continuance and
the date to which the Development had been continued. This information was also
published in the written minutes of the City Council. All of this occurred within the
sixty-day period mandated by Minnesota Statutes, Section 15.99.
William C. Griffith, Jr.
July 22, 2002
Page 3
DRAFT
The procedure of the Elk River City Council is to consider planning items on the
third Monday of each month. Although the City Council had two regular meetings
between June 17 and July 15, 2002, pursuant to the Council's procedures, no planning
items were scheduled for either of these meetings. (See enclosed agendas for the June
24, 2002 and July 8, 2002 City Council meetings.) All planning items arising from the
Planning Commission's June meetings, and all planning items continued from the City
Council's June planning agenda, were scheduled for the City Council's July planning
agenda, on July 15, 2002. This included not only Tollefson's Development, but also four
other planning items tabled or continued from the Council's June 17, 2002 planning
agenda to the July 15, 2002 planning agenda. (See Items No. 3.2, 3.3, 3.4 and 6.7 on the
June 17, 2002 agenda, a copy of which is enclosed.)
We do not believe that Tollefson has the right to determine, after the fact, what
the "next earliest pOssible date" was for City Council consideration of the Development.
Tollefson made a request that the City continue consideration of his Development to the
"next earliest possible date with the city council". The City Council determined what
that date was, continued consideration to that date, and advised Tollefson of the
continuance and the new date for consideration, all within the 60 days mandated by
Minnesota Statutes, Section 15.99.
We believe the facts set forth above are more than enough to comply with the
requirements of Minnesota Statutes, Section 15.99. However, there are additional facts in
this matter which make it clear that July 15, 2002 was the earliest possible meeting at
which the City Council could have considered the Development.
Tollefson's June 17, 2002 letter requested continuance of the Development
because it was "in the process of finishing.~up the revisions to our pl .ans for Twin Lakes
Crossing". The revised grading plan for the Development was not received by the City
until July 8, 2002. This plan was immediately submitted to the TEP and was reviewed by
the TEP in a meeting held on July 11, 2002. The revised plan and TEP's comments were
then submitted to the City Council for action at the previously scheduled continued
hearing on July 15, 2002.
Even if the City Council did not have the right to determine that July 15, 2002
was "the next earliest possible date" for the City Council to consider the Development, in
fact, July 15, 2002 turned out to be the earliest possible council meeting following
submission by Tollefson of the revised plans referred to in its letter requesting a
continuance at which the Development could be considered. We do not believe that
Minnesota Statutes, Section 15.99 requires that this Development be approved as of June
24, 2002, before Tollefson had even submitted the revised plans that Tollefson itself
requested a continuance to have time to prepare.
William C. Griffith, Jr.
July 22, 2002
Page 4
DRAFT
Tollefson requested that consideration of its Development be continued to the
next earliest possible date with the City Council so that it could finish up revisions to its
plans. The Development was acted on by TEP and the City Council within one week of
receipt by the City of the revised plans. This is clearly the earliest possible date on which
the City Council could have acted on the Development.
Because the Elk River City Council granted the applicant's request for a
continuance, determined that the next earliest possible date for consideration by the City
Council was July 15, 2002, continued the Development to that date and advised Tollefson
that it had done so, all within 60 days of the application date; and because July 15, 2002
was, in any event, the earliest possible date following submission by Tollefson of revised
plans on which the City Council could act on the Development, Minnesota Statutes,
Section 15.99 has been complied with.
As you know, the City Council will consider the preliminary plat for the
Development on its August planning agenda, August 19, 2002.
Very truly yours,
GRAY, PLANT, MOOTY,
MOOTY & BENNETT, P.A.
By:
PKB :ch
Enclosures
CC:
Mayor Stephanie Klinzing
Council Members John Dietz
Paul Motin
Louise Kuester
Dan Tveite
City Administrator Pat Klaers
Director of Planning Michele McPherson
Peter K. Beck
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