07-30-79 agendaCITY OF RICHFIELD, MINNESOTA
Office of City Manager
Council Letter No. 228
Agenda July 30, 1979
The Honorable Mayor
and
Members of the City Council -7 4
;
City of Richfield
Council Members:
Subject: Authorization to Retain BRW to Supervise
Heyman Addition Boulevard Improvement
Project
There is an item on the July 30, 1979 city council agenda
requesting council authorization to retain BRW to supervise the
construction of sidewalk and landscaping improvements planned
for the Heyman Addition area of the L/H/N improvement project.
Boulevard improvements, including sidewalk and landscaping, and
the civic plaza area, are to be completed on the north side of
West 66th Street and the east side of Lyndale Avenue, bordering
the K-Mart site. On June 25, 1979, the city council awarded a
contract to Victor Carlson and Sons, Inc. to construct these
improvements.
Construction supervision services for the work in progress
on 65th Street, 66th Street, First Avenue, and Nicollet Avenue,
in the L/H/N project area are currently provided by Hennepin
County. Under terms of the cooperative construction agreement
which Richfield signed with the county in June, 1976, Hennepin
County has provided the inspections, coordination, and surveys
required to reconstruct the city and county streets within the
project area. That agreement, however, does not include the
Heyman Addition and Lyndale Avenue improvements. The developer's
agreement between the HRA and the K-Mart developer provides that
construction of the Heyman Addition sidewalk and boulevard improve-
ments must be completed this year.
The firm of Bather-Ringrose-Wolsfeld, Inc., has submitted
a proposal to provide the construction supervision services for
the Heyman Addition boulevard improvements and the civic plaza
area construction. This proposal provides that BRW will bill
the city for the actual hours needed on the site to manage and
supervise the construction work. The proposal submitted by BRW
indicates that the anticipated construction supervision costs
will amount to approximately 60 of the construction cost, or
less than $13,000. This amount is about 50% less than the county's
cost would be to extend their construction supervision services
to the Heyman Addition work.
Council Letter No. 228 -2- July 30, 1979
It is the recommendation of the Acting Public Works
Director, and the Planning and Redevelopment Director, in which
I concur, that the city council authorize BRW to proceed with
Phase IV, Implementation of Urban Improvements, to accomplish
the design objectives and construction and supervision work
associated with construction of the Heyman Addition boulevard
improvements, City Project No. 742.
Respectfully submitted,
Karl Nollenberger
City Manager
KN/ e j a
cc: Acting Public Works Director
Planning & Redevelopment Director
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REGENED
JUL 25 1979
Richfield City Manager
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CITY OF RICHFIELD, MINNESOTA
Office of City Manager
Agenda July 30, 1979
Council Letter No. 227
The Honorable Mayor
and
Members of the City Council
City of Richfield
Council Members:
Subject: Planning Commission Presentation and
Discussion of Amendments to the Residential
Portions of the Zoning Ordinance and Concept
of Board of Adjustment and Appeals
The planning commission requested the meeting with the city
council which is scheduled for July 30, 1979 for the purpose of
discussing two specific issues:
1. Amendments to the residential portions of the zoning
• ordinance;
2. Organization of the Board of Adjustment and Appeals.
The commission has been studying both of these issues for some
time, first in subcommittee and then as a full commission. The
purpose of the July 30 meeting is to develop a general discussion
between the council and planning commission on these issues and
to request that the city council provide general policy direction
regarding these matters so that the planning commission can develop
a final recommendation.
Residential Amendments
The planning commission will provide general background on
proposed changes to the residential zoning ordinance, describe
their reasons for proposing the changes and the intent of the
proposed changes. Conservation of existing residential character-
istics of the city, through zoning, is the primary theme of the
planning commission's presentation.
The planning commission will also request that the city council
provide policy direction on the basic concept of a residential
zoning ordinance which focuses on conservation of residential
character rather than control of new development. Once a general
direction is determined, the commission will refine the proposed
AD ordinance and submit it to the city council for a public hearing.
•
Council Letter No. 227 -2-
Board of Adjustment and Appeals
July 30, 1979
The planning commission has also been reviewing the city's
zoning variance and appeals process, in an effort to increase
efficiency of operation and provide the commission with more time
to work on redevelopment policy, and long-range planning. The
commission has been studying the concept of a separate board of
adjustment and appeals. However, before submitting a proposed
zoning ordinance change, the commission has asked for an opportunity
to discuss the concept of a separate Board of Adjustment and Appeals
with the city council.
To assist the city council in discussion of these two issues,
I have attached the following information:
1. State enabling legislation
2. Outline of Planning Commission presentation
3. Article on variance process and Board of Adjustment
and Appeals
4. Flow charts comparing the existing variances and
appeals process with possible alternative processes.
•
Respectfully submitted,
w
Karl Nollenberger
City Manager
KN/eja
cc: Planning & Redevelopment Director
•
•
PLANNING COMMISSION PRESENTATION
A. Residential Zoning
1. General concept presentation by Chairman,
Joe Ertman
2. Detail presentation (staff)
a. four new categories of residential zones
b. duplexes
c. variance analysis
d. large development
3. Action Step
a. general discussion
bz direction from city council
• B. Board of Adjustment and Appeals
1. General concept presentation by Commissioner
Steven Lindgren
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462.354 HOUSING, REDEVELOPMENT, PLANNING, ZONING 5268 526!
Subd. 2. Studies and reports. In exercising its powers under subdivision 1, a wit!
municipality may collect and analyze data, prepare maps, charts, tables, and other its ;
illustrations and displays, and conduct necessary studies. A municipality may pub- nin:
licize its purposes, suggestions, and findings on planning matters, may distribute The
i reports thereon, and may advise the public on the planning matters within the mer
scope of its duties and objectives.
Subd. 3. Appropriation and contracts. A municipality may appropriate monies ma•
from any fund not dedicated to other purposes in order to finance its planning nici
activities. A municipality may receive and expend grants and gifts for planning plai
purposes and may enter into contracts with the federal and state governments or and
with other public or private agencies in furtherance of the planning activities au- '
thorized by sections 462.351 to 462.364 a n
.
[1965c670s3] post
to t
462.354 ORGANIZATION FOR PLANNING. Subdivision 1. Planning aE'en•
cy. A municipality may by charter or ordinance create a
lannin
a
en
A sect
li
;
p
g
g
cy.
planning agency created by ordinance may be abolished by two-thirds vote of all t
be
the members of the governing body. The planning agency shall be advisory, except day:
as other powers and duties are imposed on it by sections 462.351 to 462.364, by ame
statute, by charter, or by ordinance consistent with the municipal charter. The `1 of ti
j planning agency may take the following alternative forms: plan
(1) It may, consist of a planning commission, which may or may not ;include of E
municipal officials among its members. The planning commission may be provided sect
with staff which may be a division of the administrative structure of the municipal to t)
government. The commission shall be advisory directly to the governing body.
(2) It may consist of a planning department with a planning commission ad-
visory to it and shall function as a department advisory to the governing body and the
a
the municipal administration. The planning department may be provided with an me
executive director and other staff as in the case of other municipal departments. mul
Unt
Subd. 2. Board of adjustments and ap
peals. The governing body of any mu-
.
nicipality adopting or having in effect a zoning ordinance or an official map shall mer,
[
provide by ordinance for a board of appeals and adjustments. The board shall have
th
e powers set forth in section 462.357, subdivision 6 and section 462.359, subdivi-
sion 4. Except as otherwise provided by charter, the governing body may provide sion
alternatively that there be a separate board of appeals and adjustments or that plar
the governing body or the planning commission or a committee of the planning nin
commission serve as the board of appeals and adjustments and it ma
y provide an tica
appropriate name for the board. The board may be given such other duties as the the
governing body may direct. to,
In any municipality where the council does not serve as the board the
govern- prol
ng body may, except as otherwise provided by charter, provide that the decisions th
e
the .
of the board on matters within its jurisdiction are final subject to judicial reviex
or are final subject to appeal to the council and the right of later judicial review sect
or are advisory to the council. Hearings by the board of appeals and adjustments witL
shall be held within such time and upon such notice to interested parties as is mur
provided in the ordinance establishing the board. The board shall within a reason- be i
able time make its order deciding the matter and shall serve a copy of such othe
order upon the appellant or petitioner by mail. Any party may appear at the hear- the
ing in person or by agent or attorney. Subject to such limitations as may be im- imp-
posed by the governing body, the board may adopt rules for the conduct of pro- 1 dist:
ceedings before it. Such rules may include provisions for the giving of oaths to of t
witnesses and the filing of written briefs by the parties. The board shall provide
o nick
for a rec
rd of its proceedings which shall include the minutes of its meetings, its day:
findings, and the action taken on each matter heard by it, including the final.order. govt
In any municipality in which the planning agency does not act as the board of ad- visit
_justments and appeals, the board shall make no decision on an appeal or petition pen.,
until the planning agency, if there is one, or a representative authorized by it has that
had reasonable opportunity, not to exceed 60 days, to review and report to the has
board of adjustments and appeals upon the appeal or petition. [
[1965 c 670 s 4; 1967 c 493 81] ? 4
462.355 PREPARATION, ADOPTION, AND AMENDMENT OF COMPRE-
HENSIVE MUNICIPAL PLAN. Subdivision 1. Preparation and review. The mor
planning agency shall prepare the comprehensive municipal plan. In discharging heig
this duty the planning agency shall consult with and coordinate the planning ac- of 1?
tivities of other departments and agencies of the municipality to insure conformity and
5271 HOUSING, REDEVELOPMENT, PLANNING, ZONING 462.358
ders the obtaining of such written consent impractical, and such planning commis-
sion or planning board shall report in writing as to whether in its opinion the pro-
posals of the governing body in any case are reasonably related to the overall needs
of the community, to existing land use, or to a plan for future land use, and shall
have conducted a public hearing on such proposed ordinance, changes or alterations,
of which hearing published notice shall have been given in a daily newspaper of
general circulation at least once each week for three successive weeks prior to such
hearing, which notice shall state the time, place and purpose of such hearing, and
shall have reported to the governing body of the city its findings and recommends-_
tions in writing.
Subd. 6. Appeals and adjustments. Appeals to the board of appeals and
adjustments may be taken by any affected person upon compliance with any rea-
sonable conditions imposed by the zoning ordinance. The board of appeals and ad-
justments has the following powers with respect to the zoning ordinance:
(1) To hear and decide appeals where it is alleged that there is an error in any
order, requirement, decision, or determination made by an administrative officer in
the enforcement of the zoning ordinance.
(2) To hear requests for variances from the literal provisions of the ordinance
in instances where their strict enforcement would cause undue hardship because of
" circumstances unique to the individual property under' consideration, and to grant
such variances only when it is demonstrated that such actions will be in keeping
with the spirit and intent of the ordinance. The board of appeals and adjustments or
the governing body as the case may be, may not permit as a variance any use that
is not permitted under the ordinance for property in the zone where the affected
person's land is located. The board or governing body as the case may be, may per-
mit,as a variance the temporary use of a one family dwelling as a two family dwell-
ing. The board or governing body as the case may be may impose conditions in the
granting of variances to insure compliance and to protect adjacent properties.
(1965 c 670 s 7; 1969 c 259 s 1; 1973 c 123 art 5 s 7; 1973 c 379 s 4; 1973 c 539 s 1;
1973 c 559 s 1, 21
462.358 PROCEDURE FOR PLAN EFFECTUATION; SUBDIVISION REG-
ULATIONS. Subdivision 1. Authority to regulate. To provide for orderly, eco-
nomic, and safe development of land and urban services and facilities, and to
promote the public health, safety, morals and general welfare, a municipality
may adopt subdivision regulations which include minimum physical standards
and design requirements as to such urban- services and facilities, and proce-
dures for plat approval, including a procedure for appeals from actions of the plat-
ting authority. Subdivision regulations shall be adopted by ordinance when the
governing body is the platting authority and by resolution when the platting
authority is an agency other than the governing body. A municipality may by
resolution extend the application of its subdivision regulations to unincorporated
territory located within two miles of its limits in any direction but not in a town
which has adopted subdivision regulations; provided that where two or more
noncontiguous municipalities have boundaries less than four miles apart, each is x,
authorized to control the subdivision of land equidistant from its boundaries
within this area.
Subd. 2. Terms of regulations. Subdivision regulations shall require that a
proposed subdivision plat shall be in conformity with the official map if such exist.
In establishing requirements for the location and width of streets, the municipality "
shall take into consideration anticipated traffic needs and the prospective' character
of the development and make any reasonable requirements therefor. As a condition
to the approval of any subdivision plat of lands to which the regulations apply, sub-
division regulations may prescribe requirements concerning the extent and manner
in which streets shall be graded and improved, and electric and gas distribution lines ;
or piping, water, sewer, or other facilities shall be installed. The regulations may
provide, or authorize the governing body or other platting authority to provide, that,
in lieu of the completion of such work before the final approval of the.plat, the gov-
erning body or platting authority may accept or require a contract secured by a cash
deposit
certified check, or a bond in an amount and with suret
and
onditi
sati
,
y
c
ons
s-
factory to it, to assure the municipality' that such improvements and utilities will be
A
actually constructed and installed according to the specifications approved - by the
governing body or platting authority as expressed in the contract; and the munici-
pality may enforce such contracts by appropriate legal and equitable remedies. The
G O A L S: R E S I D E N T I A L Z O N I N G
. CONSERVE RESIDENTIAL CHARACTER
PROMOTE REMODELING/CONSERVATION
PROTECT PROPERTY VALUES/PUBLIC INVESTMENT
R E S I D E N T I A L C H A R A C T E R
::TYPICAL NEIGHBORHOOD
::UNIQUE NEIGHBORHOOD
:'LOW DENSITY MULTI-FAMILY OPPORTUNITIES
:CMEDIUM DENSITY MULTI-FAMILY NEEDS
4)
R E M O D E L I N G/ C O N S E R V A T I O N
'31198 REMODELING PERMITS - 1974-1978
;:69 VARIANCES GRANTED 1974-1979
::DUPLEXES
:CEXISTING DENSITIES
P R O P E R T Y V A L U E S/ P U B
:CTOTAL RESIDENTIAL VALUE
:CTOTAL PUBLIC INVESTMENT
i
C I N V E S T M E N T:
Z 0 N I N G T 0 C 0 N S E R V E, E N H A N C E, & P R 0 T E C T
B 0 A R D O F A D J U S T M E N T A N D A P P E A L S
•
P U R P O S E QUASI JUDICIAL BOARD TO HEAR VARIANCE REQUESTS
AND APPEALS OF ADMINISTRATIVE DECISIONS.
P R E S E N T P R O C E S S
P R O B L E M S
O T H E R C I T I E S
W A Y T O C U T R E D T A P E
A S I M P L E R P R O C E S S
A D V A N T A G E S
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From the office
of
- GORDON PJHITNALL AND ASSOCIATES -
Gordon Whitnall.
Brysis N.Whitnall
Theodore G.Robinson
Kay Kalicka
4315-3/4 Leimert Boulevard
Los Angeles 8,California
PROPER USE OF VARVANCE
BY
GORDON WHITNALL
e
The variance is an essential device in the field of zoning.
But,like water which in proper amount is essential to living, when
absorbed improperly and in excess,can destroy life by drowning, so
it is with variances. SOUAP EFFECTIVE AND DESIRABLE ZONING DE=
PENDS UPON THE LWITED AID FROCK X OF TH_E VARIANCE. But prom-
iscuous , expensive an3improper use of the variance not one ?r -
ects-zon"in`g`to serious,legal-_azar - ut can, an _do metimes dojso misuse the practice of zoning as to create and accentuate the
Very undesirable' ccnditiohi'which zoning,,Is-,,intended.-to-prevent .
The significance of the variance, and the proper limitations
upon its use is revealed best by identifying the position which
the variance occupies in the practice of zoning,and then identify-
ing zoning for what it really is. This is what this memorandum en-
deavors to do.
Zoning is the term applied to the practice by government of
guiding and controlling the type and degree of land-use. The pur-
pose of zoning is to assure the earliest, permanent and productive
use of all property. The purpose-of_zonin is to prevent the in-
trusion of certain types of land-use into areas_better suited for,
a„d `often pr?nctpally oc'cupTed bj?d_ifferent__forTS o_f la- n3 -use that
would be prejudiced `and`damaFed by such intrusion. The _inning oi--
dinance -also-governs"the'-intensity of land-use by means of con-
trolling building height, land coverage and open space. This much
about zoning is widely understood.
But,except for the legal fraternity and a few others who have
specialized in the science and theory of government, there is less
general understanding of the fact that zoning represents a form of
regulation accoreplished through .,what--is_connorily_called the_Qol±ce
power? -The-term "police power" is difficult to accurately define.
In fact, its definition is constantly expanding and its employment
for the purpose of protecting property through zoning represents
one of the more recent extensions of the basic principles of the
police poser. As good a definition of "police power" as seems pos-
sible to devise is that it represents the authority inher_e?nt_ i_
Socie_tYs organized in the form of its savere? over?rmnt,_ __ to._re-
_ ?_ _ .
sort to those acts of Fegu`lii oii deemed--to be essential to protect.
both Society as a whole and the individuals ..and their .property-
;which, together9 -consti tute a camnini ty._
-1-
__
i
The real significance and importance of the variance begins
to be revealed when it is next understood that the use of the po-
lice power, as consistently interpreted by the Courts, is subject
to certain simple and easily understood limitations within the
meaning of our Constitution. That which is most pertinent as it
applies to zoning, and particularly to the variance, is that the
use of the police power shall always be exercised consistently-in
tie presence of similar circumstance-s: -_STa?ed conversely, it is
ar omatic that""the-police-power should never be applied with dis-
crimination. Paraphrased, this means that the use of the police
power should assure that all persons and their propel y_af r.eo:.5e
guaranteed-EQUAL-PR IV I LEGcS ANDOPPORTUN IT I ES_ UNDER _,_S IiA I LAR_C I.R-
.
CLNISTANCES and that the. use of the police power shall never be-§Q
7...
employed as to endow certa}n persons.._or.._pr_.operty,.w.?th_spec.ial._.pr_Lv
ileges-deriied`to all others.under..aimilar"c.ircumstances.,
• Zoning was still a novel experiment (zoning began in Califor-
nia) when it became increasingly evident that when a land-use pat-
tern,.as represented by a zoning map,. was.applied to an existing
community, certain indi_vidual_parcels of land, because of Peculiar
circumstances appl?cab? when Fie sTr,?ct ,?_nterpretation",of the
zoning -ordinance °was`applied to them, could not enjoy the privi-
leges which were available to other -properties in-the same vicin-
ity and under the sane classification. When this was the case a
situation existed in which such properties,being deprived-of priti=
ileges enjoyed by its -neighboring"properties-became'"literally dis-
criminated against through the application of,the -policepower_in,
the form of zoning. Thus, one of the axiomatic limitations upon
the police power became violated and, if allowed to persist, would
jeopardize the entire program of protective regulations. It was
for the purpose of remedying these instances of discrimination
that the variance was devised. The purpose of the variance - AND
THE SOLE LEGITIMATE PURPOSE - is to so modify the application`6f a "
zoning ordinance as it applies to the property in question as will
BRING THE PRIVILEGES OF THAT PROPERTY TO A - PARITY with„ the other`
.properties similarly located and classified. By such an adjustment
of equities the use of the police power, in the form of zoning, is.
brought into conformity with Constitutional limitations upon its.
.use by assuring that it will similarly deal with all persons__or
properties under similar circumstances:"-" There would never be any
need for- a"memorandum such as this if such had been the consistent
use of the variance in the past. But, unfortunately, that has not
been true.
In far too many cases the variance has been employed, not for
the purpose of ELIMINATING DISCRIMINATION AMID ESTABLISHING EQUITY,,
BUT RATHER FOR THE PURPOSE OF EXTENDING SPECIAL PRIVILEGES TO CER
TAIN PROPERTY which, previous to the granting of a variance, al-
.oggyRl./A Y• ? ..4'?..-, . a 'ice,. ? ? ..
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ready enjoyed privileges comparable to those of other properties
similarly situated and classified. Such a_practice is not only
reprehensible from a moral standpoint and results not only in cFe-
feaL of the basic- and Legitimate purpose of zoning; Eat if repre=
sents a'serious and-dangerous -disregard and d3sda-in for our basic
Constitutional concepts of government and its powers. One may re-
move a single stone from the foundation of a building without hav-
ing the structure collapse, although the removal of the stone def-
initely weakens the structure. But several of such acts might well
lead to the destruction of the entire building. So it is when, re-
gardless of motive and whether committed in ignorance or inten-
tionally, we begin to undermine the basic concepts of our Consti-
tution and thus jeopardize our whole form of Society.
We learn from the Chinese that a good picture is worth 10,000
words,•hence this recourse to the picture method. There are pre-
sented below three graphs. The first graph is a simile, sin le,
horizontal strai.ghA-1ing.?It represents by its evenness an leve
__ ------
character_ the privileges. of_a number of parcels of land in a given
-4rea_and `which are s_-imilarly_-_c.lassi.fied und'er` a Toning ord Hance.:
-They are. all equal ly.affected under simi,.lar_..circumstances. This is
as it should be. `.-•_. -_ __
The graph shown next is similarly represented by a straight,
horizontal line except that near its center is a depression. The
depressed portion represents a piece of property which, because of
circumstances peculiar to it'al6n-e such as size,'sliape, spec-?fic_.
dimensions, slope, depression or elevation, cannot literally -con-
form to the provisions of the ordinance as can the _neighboring
property -similarly classified. Thus, this piece of property is
represented graphically as a depression that connotes substandard
privileges. This is a situation that warrants the consideration
of a variance adjustmen-t: The variance'is employed and the adjusf-
'lent i rnwde;but-wfth-cer-fain limitations and conditions that will
assure that the adjustment conveys no more than that,-_ amount.-of-
privilege which-7W-i-11- bring thi-.s---•piece of_property,to a.PAR] TY-wi..th
its neighbors. This adjustment is graphically represented by the
dotted line which bridges across the depression.
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74
f .,
Privileges adjusted
to parity.
Substandard discrim-
inatory limitation.
We find in the following graph another example of a straight,
horizontal line representing equal privileges to all properties in
the same vicinity and under the same classification. But a partic-
ular piece of property,differing in no essential respects from all
of the others,through its owner requests to be permitted some mod-
ification of the requirements of the zoning ordinance through the
medium of a variance. The privileges of this property are initial-
ly on a parity with-the others. What the owner of.the property is
actually asking is that he be permitted some additional privileges
denied to the other properties. If the variance be granted, it
constitutes a grant of a special privilege as represented by the
bulge shown by the dashed line. Such an act not only destroys the
integrity and effectiveness of the zoning program as a whole, but
raises very serious questions as to constitutionality because it
involves using the police power in a discriminatory manner through
granting a special privilege to one piece of property denied to
others under similar circumstances.
l M M M &..O.Grant of special
® ® privileges
As,a means a Pstahlishing,certai.n criteria that may be em-
Qloyed by public,_.aMcials as-a.-guide-when_..dealTni wftl;i variance
issues, there has been_ prepared and. in_eluded in. o_rdinarces_,from"
ime ime, certain stated conditions or required showings. The
writer'-of'this memorandum devised the first of such; arid-the'more
common phraseologies used are still merely adaptations of the or-
iginal. Those which fairly adequately serve the purpose are found
in the following form in some recent ordinances.
-4-
?s`.rct?i..ir!%?>?•:'r..,?-??
/
That there are exceptional or extraordinary,
circ ances or conditions applicable to the proper-
ty or to the intended use that do not apply generally
to the other property or class of use in the same vi-
cinity and zone. ,
2. That such variance is necessary for the pre-
ser?C? t n and enjoyment of a substantial property
right possessed by other property in the same vicinity
and zone but which is denied to the property in ques-
tion.
Z?3 r T hat the granting of such variance will not
eially detrimental to the public welfare or in-
jurious to the property or improvements in such vicin-
ity and zone in which the property is located.
vn4. That the granting of such variance will not
advs'is, y affect.the comprehensive general plan.
The matters here discussed are still further clarified by the
following quoted definition employed in some ordinances to indi-.
cate what comprises a variance.
"'Variance' means a modification of the spe-
cific regulations of this ordinance granted
by resolution of the Board of Adjustment (or
similar agency) in accordance with the terms
'.? of this ordinance for the purpose of assur-
ing that no property,because of special cir-
cumstances applicable to it,shall be depriv-
ed of privileges commonly -enjoyed by other
properties in the same vicinity and zone."
For purposes of contrast and further distinction, the follow-
ing definition of an amendment is helpful.
" 'Amendment' means a change in the wording,
contest or substance of this ordinance, or a
change in the zone boundaries upon the zon-
ing map, which map is a part of this ordi-
nance, when adopted by ordinance passed by
the City Council (or other legislative body)
in the manner prescribed by law."
There is still another manner in which this subject of var-
iances may be effectively analyzed. A zoning ordinance is, of
course, a law. This law says specifically what may be done and
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fir;'.
i
what may not be done. It is ordained by the people of the City
througF-i`--tTie Ci"ty`C"ounciI (or the legislative body of a county).
Sometimes, in fact, it has actually been ordained by a direct vote
of the entire Electorate. The significant point is that it is a
law that defines the rule. Under our Americ,an_fora..af-.governments
there is no one, be it a person, a corporation or a department of
gov wt-,-that may with impunity break any law. There is only
one means 6y which that which a law says shall be ocTne o? that
w t`fi-c a law says shalt not be done may be a tere i?that one-means
ts"` to amend{h_e Taws `Tn California that means, according to our
ante Constitution, that the only authority for amending a law is
vested either in the representative legislative body, which could
be either a city council, a board of supervisors, or in the Elec-
tors direct through the medium of Initiative or Referendum. Nor
may the authority vested primarily in government be delegated by
it to anybody else. This means, in plain english, that if a zon-
in ordinance says that a certain {hing may not be done and the
e ort is made to permt`Tuit to be done by any means other than an
amen men oe _aw,`s R act. is open to very serious legal. atta.
moral auost?ion.. The question becomes no less merely because the
assumed authority to violate the law is exercised by a city plan-
ning commission,by a board of adjustment,or even by the city coun-
cil itself. Therefore, in addition to the above defined criteria
and graphs a rule of thumb that can rather effectively aid a plan-
ning commission, or a board of adjustment, in determining whether
a requested variance would represent a valid adjustment or not, is
to develop an answer to the 0uea4inn - "IV-1A +s,;? -, ; ;r
granted, literally permit the doing of tha _whtc _ e ordinance
t c e y say`s may_no1-Seed-one?Tr_Ano1Ner'rule of thumb would be
found in the answer to the question- "Nould the variance,if grant-
ed produce a conditions..which,i-fe,previosly existing, would con-ssf-
to e a -nonconforming use?" If the answer is "yes",then there _is
sert? ous quesl•;ion concerning the propriety of such a variance.
These reasonings bring us back to an earlier subject of con-
sideration as to when an adjustment is valid. The last point here
attempted to be made is that when zoning ordinances,as they usual-
ly do, properly provide that when circumstances are found to exist
which make the strict application of the detailed provisions of
the ordinance a discriminatory regulationto a given piece of prop-
erty because of circumstances peculiar to it alone, then.the PRQ-
CESS OF INTERPRETING THE..F8CIa-LNjHE_CASE T0._pETERMIINE IF THEY DO
PRODUCE SUCH A LUSCRIUINAT0BY_MINDITJQ represents, not a legisla-
iviv e but a J-LEICIAL interpretation, Here again we become con-
fronted with the basic concept of our Constitutional form of gov-
ernment which divides it into three essential divisions, namely,
the 'legislative, the executive and the judicial. It is not only
the prerogative, but the responsibility, of the judicial phase of
government to interpret and determine whether a certain combina-
tion of circumstances creates a condition within the intent and
-6-
_ Y .
meaning of the Constitution, or violates its basic concepts. Thus,
.when an issue is raised through the application for a variance,the
real matter to be determined is whether the circumstances alleged
to prevail, or such others as can be identified, actually do pre-
vail and that the property in question is discriminatorily depriv-
ed of privileges which other properties enjoy. If, through judi-
!' ° cial interpretation and evaluation, it is found that there is such
mac" Y discrimination, then in zoning matters the judicial process nor
rr? mally contains the authority to make such adjustments as will
bring the application of the law into consonance with Constitu-
tional guarantees. Thus, in the field of zoning, it is perfectly
proper that there shall be such conditional adjustments made as
will assure that the privileges of the property in question are
brought to a parity with other properties in the same vicinity and
classification - BUT NO UIORE. That act represents a judicial
function.
In the field-of..zoning_this-function is normal_!y v_ested in ,a
spec a, agency variously called a Board of Appeals, A Board of Ad-
?astment; some -other title, -and.. such agency 'i s usual ly_referred
1o asa- uaas?iz; 'udicial body. -'These have been a provisions andw
these have been the practices in practically all states except in
W 71
California. It is only recently that California has identified and
extended the authority to local units of government to create the
quasi-judicial agency which, under our law, is referred to as the
Board of Adjustment or the Zoning Administrator, or both. This au-
thority is being increasingly employed.
Prior to possessing this authority and to exercising it, the
general practice in California began with outright legislative
amendments that would make the modification, and gradually that
practice swerved to the point where planning commissions would
_ initially-x-eview applications for variances and recommend to the
legislative body that they be granted by consenting through reso-
n lution, or its equivalent. In time the practice reposed more and
more authority for final determination in the planning commission
but always, for basic legal reasons, where the legislative process
znn is involved, maintaining the privilege of appealing the commis-
< sionts decision to the legislative body. There are two basic weak
-
x . nesses in this practice. One is that the legislative body is less
?^ may:''" familiar with related matters of policy initimately associated
with the whole planning program, particularly the entire land-use
pattern, than is the planning commission and, secondly, the legis-
lative body, being an elective and representative body, is natur-
ally - and excusably - more prone to determine an issue upon the
basis of political expediency than upon the pertinent, physical
facts. This tendency, in itself, has often produced such an as-
sortment of irreconcilable inconsistent actions as to establish
? 1Ya_Yt Yn
r
_.,
( z.
serious legal question and moral question concerning the validity
of the entire practice because of resulting inconsistent applica-
tion
f th
i
o
e pol
ce power.
(Note: As of this date, 1956, the California Congervation
and Planning Act, by means of amended provisions, puts variance
matters into the political arena b
ro
idi
th
y p
v
ng
at quasi-judicial
decisions of the Board of Adjustment may be appealed to the legis-
lative body. This is not true in Los Angeles by reason of Charter
prow-isions which adhere to the American way).
This memorandum undertakes in no sense to indulge in an argu-
ment. Its purpose is merel
to
l
i
y
exp
a
n as lucidly as possible the
fundamental considerations attendant upon the practice of dealing
with variances if the practice is to adhere strictly to both the
spirit and the letter of constitutional law. Possibly the real na-:
ture of the issue can be best illustrated if the field of zoning
b
e left for a moment and we enter into another field where the
same principles are -applied and more generally understood.
It requires little imagination to visualize a situation in
which a legislative body enacts a law declaring it to be illegal
for one to take property belonging to another. The act of breaking
such a law is called burglary or theft. If the perpetrator of a
burglary or theft is apprehended, the next social concern is that
the facts shall be ascertained and the cul
rit shall
b
b
p
.
e su
ject to
the prescribed penalties if'found to be guilty. It would probably •
be considered very strange by any school child, much less an adult,
if
one accused of such a crime were to be judged guilty or inno-
cent by the legislative body that enacted the l
It i
aw.
s not that
the same degree of intelligence is lacking in individuals compris-
ing legislative officers as compared to those who represent judi-
cial officers; it is rather that the viewpoint and incentive of
h
`
individuals in those two positions are so radically different. If
.
conceivably you were accused of some crime, the point here attempt- M
ed to be made could probably be more effectively made by asking
-
the question - "Alould you prefer to have your guilt or innocence
passed upon by a legislative body or by the courts?"
The all too prevalent practice in some places of misusing the
i
var
ance in a manner to completely negate the provisions.and in-
tent
f
i
o
a zon
ng ordinance by producing a so-called "spot zone"
has served to arouse an increasing question concerning the valid-
ity of the practice - both le
all
morall
d
li
i
g
y,
y an
po
t
cally. As a
consequence the pendulum has in some instances been swung to the
opposite extreme. This takes the form of the occasional claim that -
a variance may never be validly employed where a modification of
"
" r
USE
restriction is involved. ._'.;.
-??}6. d?v. err..
4
The question thus raised warrants a separate extensive analy-
sis but not in this discussion. It must suffice at this time to
state that although A USE VARIANCE IS SELDOM JUSTIFIED THERE ARE
CIRCLR4STANCES IN THE PRESENCE OF WHICH A USE VARIANCE IS NOT ONLY
JUSTIFIED BUT IS ESSENTIAL BOTH IN LOGIC AND IN LAW.
Two examples will illustrate the principles involved.
1. A nonconforming industry consists of
three separate buildings, each housing an es-
sential portion of equipment and processing.
One unit burns down. A building permit to re-
build may not automatically be issued. To
prevent the replacement of the destroyed unit
would destroy the usefulness of the remaining
units. A conditional variance would be war-
ranted as fully conforming to the usual re-
quired showing.
2. The initial urban i"mprovement of a
large acreage island completely surrounded by
solid urban development was about to occur.
Tens of thousands of tons of material for pav-
ing, sewers and water system would cause an
avalanche of trucks that would destroy streets
incapable of carrying the loads not to men-
tion the inconvenience, nuisance and hazard
to residents surrounding. An existing rail-
road offered an ideal solution to the problem
except for the fact that no industrially zon-
ed property existed contiguous to the rail-
road and in the area. To actually rezone an
area might permanently introduce heavy uses
that would be unwarranted. A conditional var-
iance limited to a twenty-four month period
was issued. ,It allowed the operation of rock
bunkers,pavement mixing plants,material stor-
age facilities etc. In eighteen months all
this was removed but in the meantime hundreds
of thousands of dollars was saved to devel-
opers and the city, and surrounding residents
were effectively protected against the intru-
sion of uses that would have destroyed the
living environment which the established zon-
ing was intended to protect.
Other actual examples could be cited in which so-called USE
VARIANCES have been properly,employed.
-9-
xr
®r,
x. .' ?. .. _ ._
5y'«? "., ??t ..t" '+F ? _ i ?y??.v.^-t . q ? ??? ? ..A ??`°a•Irtw•".. ' .'t xru.:? ? .?v;?•
;.T
k !
i r
0 o o 0 o o 0
-lo-
4
In summary, therefore, when considering the subjer-t of var-
iances in the field of zoning, it may be accurately and correctly
stated that the consideration of factors involved in dealing with
variances constitutes a quasi-judicial process. Being a quasi-
'dici_a?l function,it is improper both constitutionally and morally,
?fFi `final decision on in such matters should rest with the leg-
ts a ive body. The legislative body creates the rules, but the
_
udici--al agency interprets tTieir'application. To•repose both func-
gions in one place approaches that condition of concentration of
power which, carried to the ultimate, must lead inevitably-to to--
lalitarianism or dictatorship,, which is the antithesis of our form
of Sovernment. The moment we begin to deviate from the basic con-
cepts of our form of government, we have taken the first steps in
the other direction. As a consequence, planning Commissioners, if
they be the officers upon whom is placed the responsibility for
dealing with variance matters, or members of Boards of Adjustment
or the Zoning Administrator - if-they exist - have as their direct
concern the responsibility first to maintain the integrity of and
protect and preserve our form of government upon which we all de-
pendq second, to assure that no individual shall be discriminated
against in the application of the rules established by our govern-
ment through legislation; and, lastly, in the effort to protect
property through zoning against the damages caused by intrusions
of incompatible uses.that nothing shall be done in the way of in-
dividual acts, the doing of which will openly be a violation of
both the spirit and the purpose of zoning.
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