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HomeMy WebLinkAbout8B - Buckingham Disposal AGENDA #: PREPARED BY: SUBJECT: DATE: INTRODUCTION: DISCUSSION: STAFF AGENDA REPORT 8 B Donald Rye Planning Director Consider appeal of Buckingham Disposal from ordinance interpretation October 16,1995 In June, City staff was made aware of the existence of a recycling operation conducted by Buckingham Disposal at 5980 Credit River Road. The facility was opened without benefit of a Certificate of Occupancy and a subsequent determination was made by the Planning Director that the use was not a permitted or conditional use in the 1-2 zoning district. The owner of Buckingham Disposal appealed this decision pursuant to Section 7.4 of the zoning ordinance. The Planning Commission, acting as the Board of Adjustment, heard this request on August 28 and, following its deliberations, recommended that the City Council uphold the appellant's contention that the recycling operation fits within the definition of light manufacturing as contained in the zoning ordinance. Section 7.4 states that the Council shall make its decision by resolution within 60 days. The issue to be resolved is whether the City Council agrees with the staff interpretation of the ordinance or with the appellants view that the recycling operation falls within the definition of light manufacturing in the zoning ordinance. Attached to this report are the planning commission staff report, the use listing in the 1-2 zoning district, a letter to Mr. Buckingham from the City Manager, the staff memorandum making the determination of use, a memo from the building official, a letter from Mr. Buckingham describing the operation, a letter from the City Manager, a letter from Mr. Buckingham's attorney filing the appeal, a response to the appeal letter from the Planning Director, a summary of operations and a letter 16200 Eagle Creek Ave. S.E., Prior Lake. Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTUNITY EMPLOYER ISSUES: from Scott County indicating that the facilities license has been denied. The planning report had three options specified: 1. Recommend support of the staff determination 2. Recommend support of the appellants position 3. Recommend the staff determination be upheld and that staff be directed to conduct a study pursuant to Section 2.5 of the zoning ordinance to determine under what circumstances a recycling center may be allowed in the 1-2 zoning district. The staff recommendation was alternative 3. The Planning Commission recommended alternative 2. If Council believes that a recycling operation as described by the appellant does not fit the definition of light manufacturing as discussed in the planning report, it should uphold the staff determination. If Council believes that the recycling operation fits the definition of light manufacturing, it should uphold the appellant. If Council believes that a recycling operation is sufficiently different from other traditional light manufacturing uses, it should direct staff to conduct the appropriate study to define how such a facility should be regulated. Staff is of the opinion that such a use raises some particular concerns related to outside storage, appearance, storage of potentially hazardous materials on site such as chlorofluorocarbons in appliances and control of traffic and drainage. The only effective way to establish criteria and monitor compliance with respect to such uses is to define recycling as a conditional use in the 1-2 zone. The study recommended by the staff would define any other safeguards that would be appropriate to consider for this use. 2. 3. Uphold the staff interpretation of the ordinance that a rec~cling operation. does ~ot fit the curr~nt definit~o~~.. '. .' . of light manufacturing. This would effectively prohibit / continued operation of the recycling operation. Uphold the appellants position Uphold the staff interpretation and direct staff to conduct a study to determine the proper method of regulation for recycling operations ALTERNATIVES: 1. RECOMMENDATION: Alternative 3. No further enforcement action would be taken pending the outcome and council action on such a study. It is our expectation that the study would recommend that recycling be a conditional use in the 1-2 zone. ACTION REQUIRED: Motion to direct pre aration of a resolution consistent with the City Counci action. PLANNING REPORT AGENDA ITEM: 4 SUBJECT:Consider appeal of Buckingham Disposal from ordinance interpretation SITE:5980 Credit River Road PRESENTER:Donald Rye PUBLIC HEARING: DA TE:August 28,1995 YES X NO-N/A -- INTRODUCTION: In June, City staff was made aware of the operation of a recycling operation conducted by Buckingham Disposal at the above address. The facility was opened without benefit of a Certificate of Occupancy and a subsequent determination was made by the Planning Director that the use was not a permitted or conditional use in the 1-2 zoning district. The owner of Buckingham Disposal is appealing this decision pursuant to Section 7.4 of the zoning ordinance. The Board of Adjustment has the responsibility to hear the appeal and make a recommendation to the City Council to either uphold the interpretation by staff, determine that the staff interpretation was incorrect and grant the appeal or to recommend some alternative resolution of the issue such as a zoning ordinance amendment. DISCUSSION: The letter from Tom Buckingham dated July 18 describes the operation of his business and presents the rationale under which he believes his use is a permitted use in the zoning district. The staff memorandum dated July 21 presents the reasoning leading to. the conclusion that the use is not permitted in the 1-2 district.The letter from the appellants attorney dated August 9 constitutes the formal appeal.As of August 21, the detailed statement referred to in the third paragraph of Mr. Cairns letter has not been received. The role of the Planning Commission in the appeal process is advisory only. Once the Commission determines a position, a recommendation is to be made to the City Council for final action. In considering the appeal, the Commission should consider all of the material contained in the staff report as well as testimony offered by the appellant on his behalf. The language of the ordinance should be read in such a way as to allow all provisions of the PCREPT.DOT 16200 Eagle Creek Ave., Prior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTIJNITY EMPLOYER ordinance to be applied in a consistent fashion. Consequently, the Commission should look beyond the case before it and consider the implications of its recommendation. The ordinance currently defines light manufacturing as " the processing and fabrication of certain materials where no process involved will produce noise, vibrations, air pollution, fire hazards or noxious emissions which will disturb or endanger neighboring properties." Fabricate is defined as "To construct by combining and assembling" while manufacturing is defined as "to make or process a raw material into a finished product, esp. by means of a large-scale industrial operation." Staff does not believe that a recycling center where used materials are gathered, separated and, in some case~, reduced in bulk, conforms to either definition. The staff memorandum also lists other reasons why it was felt that recycling centers are not currently permitted in the 1-2 district. AL TERNA TIVES: The Planning Commission has three alternatives: 1. Recommend that the City Council uphold the staff determination and direct continued enforcement actions to be taken. 2. Recommend that the City Council uphold the appellant and direct termination of zoning ordinance enforcement. 3. Recommend that the City Council uphold the staff determination and direct that staff conduct a study pursuant to Section 2.5 of the zoning ordinance to determine under what circumstances, if any, RECOMMENDATION: It is recommended that the Planning Commission recommend Alternative 3 to the City Council. ACTION REQUIRED: Motion to adopt Alternative 3. BUCKAP.DOC - -, .J - J ] G C-1 S-D 2.3 2.4 2.5 the taxable value and to promote the public health, safety and welfare. (Ord.93-18)(C)\-~C' ')) LIGHT INDUSTRIAL DISTRICT is intended to provide areas of the community which will allow general industrial uses which due to their size and nature would not conform to the Special Industrial District. CONSERVATION DISTRICT is provided to recognize vital environmental resources of the community as steep slopes, wetland and unstable soil conditions and allow development only after careful analysis. SHORELAND DISTRICT is established to protect water and shoreland resources from unwise development and water pollution and to preserve economic and natural environmental qualities of the shoreland environment. Land located within the following distances from protected waters is considered to be within the Shoreland District: 1000 feet from the ordinary high water mark of a lake, pond, or flowage and 300 feet from a river or stream, or the landward extent of a flood plain on such river or stream, whichever is greater. DISTRICT BOUNDARIES: District boundaries shown within the lines of the roads, streams, and transportation rights-of-way shall be deemed to follow the centerlines. The vacation of roads shall not affect the location of such district boundaries. When the Zoning Officer cannot definitely determine the location of a district boundary by such centerlines, by the scale or dimensions stated on the Zoning Map, or by the fact that it clearly coincides with a property line, he shall interpret the location of the district boundary with reference to the scale of the Zoning Map and the purposes set forth in all relevant provisions of the Ordinance. Where a district boundary line divides a lot of record into two or more districts, any portion of the lot within fifty (50) feet of such division may be used for any use of either district as approved by the Board of Adjustment. DISTRICT REQUIREMENTS: Except for Planned Unit Developments, all buildings and uses in each district shall be subject to the requirements listed under Sections 3 through 9. Planned Unit Development standards may be applied to any Residential Districts at the request of the land owner and at the discretion of the City Council. Where Planned Unit Development standards differ from the original district standards, the Planned Unit Development standards shall apply. USES NOT DESIGNATED: A use not specifically designated as a permitted or conditional use anywhere in the City is considered prohibited. In such a case, the Council, Commission or a property owner may request a study by the City to determine if the use is acceptable and if so, what Zoning District would be most appropriate for the use and what conditions an.d standards, if any, should be attached to the development of the use. If found acceptable an amendment to the Zoning Ordinance may be initiated by the Councilor Commission permitting the use. (Ord. 83-6) Section 2, Page 2 ...~"-......_~_......_--_..-----_......~--............,.....~,,..~..~--".~----.---- PERMITTED USES CONDITIONAL USES ,I I I I I I I I I I I I I I I I I I I 1. Light Manufacturing 1. Manufacturing 2. Research Laboratories 2. Public Utility Buildings 3. Testing Laboratories 3. Water & Sewer Treatment Facilities 4. Offices 4. Airports 5. Supply Yards 5. Truck & Railroad Terminals 6. Warehousing 6. Grain Elevators 7. Truck Terminals 7. Commercial . Recreation 8. Public Parking 8. Animal Clinics 9. Parking Lots 9. Food Product Processing 10. Mini-Storage Units C-1 CONSERVATION 1. Agriculture 1. Water & Sewer Treatment Facilities 2. Single Family Dwellings 2. Commercial Recreation 3. Camps & Cottages 3. Airports 4. Public Parks & Playgrounds 4. Cemeteries 5. Public & Parochial Schools 5. Radio & TV Stations 6. Hunting Preserves 6. Sanitary Land Fills 7. Golf Courses 7. Animal Clinics 8. Specialized Animal Raising 8. Animal Feed Lots For 9. Stables & Riding Academies more than 10 animals 10. Public Buildings 11. Marina (Ord. 83-6) 12. Wholesale Plant Nurseries (Ord 90-07) 13. Agricultural Preserve (Ord 93-12) Section 3, Page 5 ~/L June 30, 1995 Tom Buckingham Buckingham Disposal 5980 Credit River Road SE Prior Lake, MN 55372 Subject: Recycling Center Located in Prior Lake Dear lVlr. Buckingham: Building Official, Gary Staber, and Planning Director, Don Rye, have had the opportunity to review the materials you submitted on Friday, June 23. In addition, they inspected the site on June 26. I am attaching a copy of their written findings. Based upon the materials you submitted, the site inspection and a review of the City's Zoning Ordinance and Uniform Building Code, our findings can be summarized as follows: 1. Recycling is not a permitted or conditional use in the 1-2 Zone. 2. The plans provided were not to scale, and did not show both first and second floor layout. A code analysis should be completed by a qualified engineer or architect focusing on such issues as exiting, sanitation facilities, occupancy separations, allowable square footage and site access in generaL 3. It is apparent that alterations have been made to the building without proper permits, either by the current or former occupant. In short, the recycling operation continues to be contrary to the City's Zoning Ordinance, City Code and Uniform Building Code. According to Gary Staber, the Uniform Building Code issues are resolvable. What needs to occur first is that the Council should consider whether it wishes to add recycling as a permitted or conditional use in the 1-2 Zoning District and, if so, what safe guards should be associated with such usage. BUCKHAi\12.DOC 16200 Eag1eCreeI< Ave., Prior Lake. Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTIJNnY E~1PLOYER Page 2 Tom Buckingham June 30, 1995 If you desire to have the Council consider such a request please provide me with a letter to that effect which we will submit to the Council together with supporting materials. You can expect that staff will recommend numerous safeguards if the Council is positively inclined to allow recycling uses as a conditional use or permitted use. Until the Zoning Ordinance is revised and your operation comes into complete compliance with the City Code, Uniform Building Code, County and State requirements, you may not operate the recycling facility from this location. To do other wise is contrary to the law and undertaken at your sole and exclusive risk. If you have anlestions please feel free to contact me, Don Rye or Gary Staber. FB:db Attachment / Fax (612) 447-4245 MEMORANDUM TO: FROM: RE: June 26, 1995 Frank Boyles, Gary Staber Don Rye Buckingham Disposal DATE: I have reviewed the material presented to us on Friday, June 23 by Tom Buckingham. In addition, I have reviewed the zoning ordinance and visited the site on June 26 with Gary. I have concluded that a recycling center is not a permitted or conditional use in the 1-2 Industrial zoning district. I base this finding on several factors as follows: . When the ordinance was written in 1983, recycling \vas fairly well established as a legitimate land use and yet the ordinance makes no specific provision for such a use.!t is possible to conclude from this that this use was not considered as a viable use in this district. . Light manufacturing is a permitted use in the 1-2 district and is defined as " The processing and fabrication of certain materials where no process involved will produce noise, vibrations, air pollution, fire hazards or noxious emission which will disturb or endanger neighboring properties." The definition of manufacturing is" to make or process ( a raw material) into a finished product, esp., by means of a large-scale industrial operation:' The notion of a recycling center where used materials are gathered. separated and reduced in bulk does not conform to the traditional definition of manufacturing. . A significant portion of the recycling operation is conducted outside.Large metal bins,semi trailers and trucks are located around the site and the recycled materials are stored outside until moved elsewhere.In addition, the general public drops off material outside in the storage yard. In that respect, the recycling operation has a distinct commercial aspect to it as it generates traffic much as a retail use might. . The zoning ordinance provides that uses not specifically designated as permitted or conditional uses are prohibited. I believe that the recycling operation is sufficiently different from uses which would qualify as light manufacturing as to put it into the prohibited category. In that case, the ordinance provides for a study of the use to determine if the use is acceptable and, if so, in what zoning district and with \vhat additional conditions and standards, if any. Based on the foregoing, I conclude that Buckingham Disposal operating as a recycling center is not a permitted or conditional use in the 1-2 district. Frank Boyles From: To: Cc: Subject: Date: Gary Staber Frank Boyles Don Rye Buckingham Disposal Monday, June 26, 1995 3:53PM Hi Frank, Buckingham came in with some information late on Friday afternoon. Don and I had a chance to go out and tour the site today. We met Tom Buckingham on site and told him after our tour that we would be going back to City Hall to write memos regarding the facility. My comments are as follows: 1. A code analysis should be completed by a qualified engineer or architect. Items such as exiting, sanitation facilities, occupancy separations, allowable square footages, and site access in general should be addressed. 2. Building plans should be to scale, 1/8 or 1/4 inch per foot is preferred. 3. Building plans should be complete showing both the first and second floor layouts. When Don and I were touring the structure it became quite obvious that the former tenant made several alterations to the building without proper permits. It was also noted that Buckingham made some alterations and modifications to the building without proper permits. Mr. Buckingham while being cooperative, is not totally innocent in that this situation we are reacting to seems to have been created largely by Mr. Buckingham himself. Rather than giving my first impressions at this time, I would rather wait for the architect's code analysis for a more thorough response. Page 1 ~ ~(!.~.: ~ ~ 1 \ z. II G S"' J?d3 BUCKINGHAM DISPOSAL, INC. 5980 Credit River Road Prior lake MN 55372 Phone: 226.6441 Fax: 226-6442 (612) 334-8532 July 18, 1995 Frank Boyles, Manager City of Prior Lake Prior Lake Courthouse 4629 Dakota Street S. E. Prior Lake MN 55372-1714 Dear Mr. Boyles: In the past week or so I have had discussions with a number of advisors regarding your concern about our operations in Prior Lake. This letter is to offer a view of the situation that I believe will support a conclusion on the City's part that my use of the property is entirely consistent with the City's Zoning Code. As you know, my business services over 1000 Prior Lake residences. In addition to picking up MSW from those residences, I also have a contractual obligation to do weekly curbside recycling pick-up. There is no realistic alternative to processing the recyclables at my property. If I am not able to do so, even for a brief period of time, the effect may be adverse to the Prior Lake residents that I serve. In addition, I offer residential generators drive-in and drop-off service for recyclables and compostable materials (the latter being regularly used by Prior Lake residents since they can avoid the $2.00 per bag charge for curbside pick-up). Since it is not clear to me that earlier staff review of my operations reflect a thorough understanding of what my business and use of the property is, let me offer specifics. There are a number of components to my business: there are offices; my trucks are parked overnight and operate from the property; I warehouse certain materials for limited periods of time; I maintain and store supplies for my business; and I run a recyclable materials processing operation which, in my view, is clearly a permitted "light manufacturing" use. Let me also clarify what my business is not. It is not a site for processing or transferring Mixed Municipal Solid Waste (commonly known as "garbage") as that term is defined by Minnesota law. Your staff has indirectly seemed concerned that my property in Prior Lake will have some processing of MSW done there. That is not the case. My vehicles for MSW pick-up are stored overnight at the property. Otherwise, under my Scott County Licenses, I am prohibited from 726139.1 processing MSW; and I do not have an MSW transfer station license nor do I have any intention to secure such. You have raised the concern that my use of the property is not for Light Manufacturing as permitted by the 1-2 Zoning classification. I ask that you reconsider this tentative conclusion for the following reasons: 1. My business is "processing" materials. The raw materials are the unsorted recyclables. My process is the sorting, compacting and packaging of the recyclables into marketable form. The City definition of Light Manufacturing is properly broad enough to encompass clearly what we do. The "finished" material or product is sold to end-users for incorporation into additional manufactured products. In effect, we are the first of several manufacturers/processors that allow the entire recycling system to function effectively. 2. My processing does not produce "noise, vibrations, air pollution, fire hazards or noxious emissions..." All of my processing is now and will be done indoors; and the sorted materials are stored in enclosed shipping containers until volumes adequate for transport are collected. 3. The only portion of my processing which is "outdoors" is the mere placing of the separated materials into distinct and enclosed containers. 4. My operations have no commercial aspects. I do not sell anything to the public; I merely pay generators of recyclables a fee for their delivery. None of the persons dropping materials off need parking on-site as the time they are on the property is minimal. The number of trips per day by such persons will likely not exceed 35 during the week and perhaps as many as 100 on Saturdays. These vehicle movements will hardly be noticed on County Road 21, especially when it becomes a four lane road which I understand is planned for the future. 5. As to the Becker Ice Arena use of a portion of the property, I am unaware of any City Zoning Code provision that requires a conclusion that my manufacturing and Becker's need be "compatible." In fact, they clearly are; otherwise I would not have been able to secure their sub- lease of a portion of the building. Becker has other operations in the immediate area; its continued location and expansion in Prior Lake is welcomed, I am sure, by the City. As to building code issues, your staff is aware that I have engaged Prior Lake architect Pat O'Keefe (O'Keefe Design Associates) to advise on how to assure that the modest interior alterations we have made (building one partition wall and eliminating a couple of others) to the property are up to code. We will do our best within reason to do the same with 726139.1 improvements, if any, done by the prior owner/user that may not have been done with permits or up to code. The only significant physical change to the building which I "viII seek permits for is the addition of a canopy at the west end of the building to provide weather protection for people dropping off reyclables. And that is not really my first preference. I would prefer to add a drive through door on the south side of the building so that customers would actually come into the building, drop off materials, and then exit to the north. This procedure would be much easier for the customers and more consistent with my business practice of running all processing operations of my business indoors. This would be consistent with the telephone company's use of its building just to the west of my property. Of course, I am very concerned about your suggestion that we cease the recycling operations pending consideration of a zoning amendment which I believe is unnecessary. I understand that such a process may take up to 90 days. In the meantime, I have contractual and license obligations to provide services to your residents. If I cannot continue the light manufacturing processing that I am doing, there may be serious disruption in those services --- and possibly some additional expenses to your residential generators since any interim solution is bound to be more expensive than what is happening now. I assure you, and you can independently ascertain if you wish, that I have and will own and manage a sound business providing needed and cost-effective service to my customers, most of which are Prior Lake residents. A great majority of these customers have been serviced by my business for many years; they would not continue with me if my work was not exemplary. ~rUIYf(' --1 lb~ b~c."-,~~' cc: Mayor and City Council Members John A. Cairns, Briggs & Morgan 726139.1 I r ------- August 1, 1995 Tom Buckingham Buckingham Disposal, Inc. 5980 Credit River Road Prior Lake, MN 55372 Subject: Appeal to City Code Requirements Dear Mr. Buckingham, ..... '" Thank you for your July 18, 1995 letter. After reviewing the letter, it is clear that there is a disagreement regarding the interpretation of the zoning ordinance with regard to recycling operations. Two portions of the City's o.rdinance are instructive: Section 2.5 of the Zoning Ordinance entitled "Uses not designated" provides that: "A use not specifically designated as permitted or conditional use anywhere in the City is considered prohibited. In such a case, the Council, Commission or property owner may request a study by the city to determine if the use is acceptable and, if so, what zoning district would be most appropriate for the use, and what conditions and standards, if any, should be attached to the development of the use. If found acceptable an amendment to the Zoning Ordinance may be initiated by the Council or Commission permitting the use." The City Code goes on to say in Chapter 5-6-4 Appeals that "An appeal from a ruling of the Zoning Officer may be made by the property owner or agent . within thirty (30) days after the order utilizing the procedure as follows: A. The property owner or agent shall file with the Zoning Officer a notice of appeal stating the specific grounds upon which the appeal is made. B. The Zoning Officer shall transmit the appeal to the Board of Adjustment for study and recommendation at its next regular meeting. C. The Board of Adjustments shall make its recommendation within sixty (60) days and transmit to the City Council for official action. BUCKNGHM.DOC. . 16200 EagTeCreeK" Ave. , P"nor Lake, Mmnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTIJNITY E.'1PLOYER D. The City Council shall make its decision by Resolution within sixty (60) days and a copy of the resolution shall be mailed to the applicant by the Zoning Officer." Planning Director, Don Rye, has reviewed the City Code with respect to recycling operations and provided his interp"retation. Your July 18 memorandum outlines your interpretation. Don Rye, in his capacity as the Zoning Officer, does not believe that the Zoning Ordinance addresses recycling operations as either permitted or conditional uses. Consequently, . you have the opportunity to appeal Mr. Rye's findings to the Board of Adjustment which is the City's Planning Commission. The Board of Adjustment, and subsequently, the City Council have the option of supporting Mr. Rye's interpretation and/or directing that revisions be made to the Zoning Ordinance to address recycling operations specifically. To expedite this process, I have interpreted your July 18 letter to be a notice of appeal as required under the code. I have asked the Planning Department to initiate the process set forth in 5-6-4 and 2.5. In the meantime, I must advise you that until the Zoning Ordinance is revised and your operation comes into complete compliance with the City Code, Uniform Building Code, County and State Requirements, you may not operate the facility from this location. To do otherwise is contrary to the law, and undertaken at your sole and exclusive risk. . Whether or not the Zoning Ordinance is revised to accommodate the recycling use, it will be necessary for you to submit a building permit application, supporting materials and fees in order that the work already accomplished will be deemed legal under the State Building code laws. Feel free to contact Planning Director Don Rye, or Assistant Planner Deb Garross, to schedule the appeal you are requesting before the Planning Commission and City Council. cc: Don Rye, Gary Staber an ns 16200lb~~W~~.R2S,rior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTIJNITY EMPLOYER LAW OFFICES BRIGGS AND MORGAN PROFESSIONAL ASSOCIATION 2400 IDS CENTER MINNEAPOLIS.. MINNESOTA 1515402 TELEPHONE (612/ 334 - 8400 FACSIMILE (612) 334-86150 WRITER'S DIRECT DIAL NUMBER SAINT PAUL OFFICE 2200 FIRST NATIONAL BANK BUILDING SAINT PAUL, MINNESOTA ~at01 TELEPHONE (612) 223 - 6600 FACSIMILE (612) 223 - 64150 (612) 334-8532 INTERNET ADDRESS: CAIJOH@EMAILBRIGGS.COM ,"4 August 9, 1995 Frank Boyles, Manager City of Prior Lake Prior Lake Courthouse 4629 Dakota Street S.E. Prior Lake, MN 55372-1714 Dear Mr. Boyles: We have confirmed that the Buckingham Disposal, Inc. matter will be on the planning commission agenda for August 28, 1995. I have asked Don Rye to set the matter towards the end of the agenda as I will not be able to get to Prior Lake much before 8:00 that evening. We do not agree with your statement of the situation in your August 1 letter. In particular, we disagree with the options that are on the table for consideration. The Planning Commission and City Council could accept our view of the situation rather than supporting Mr. Rye's flawed (in our view) interpretation or directing revisions of the ordinance. Prior to the meeting, we will submit a more detailed statement of our view of the situation. Included will be a recitation of the discussions held with city staff before your first correspondence and other facts that we believe are material to the situation. We will try to get this material to you by August 18 so that it can be assessed by the staff as they prepare their report and considered by Planning Commission members ahead of the meeting. 728106.1 MEMBER, LEX MUNDI, A GLOBAL ASSOCIATION OF INDEPENDENT LAW FIRMS BRIGGS A.ND MORGAN Frank Boyles August 9, 1995 Page 2 In the interim, I would appreciate receiving from you and your staff: 1. A list of the Planning Commission members; and 2. A description of the circumstances under which the City permits the operation of Lloyd's Construction Services, Inc. to operate in the 1-2 zoning district. yours, JAC/vkh cc: Tom Buckingham Steve Rathke, Esq., City Attorney 728106.1 August 14,1995 Mr. John A. Cairns Briggs And Morgan 2400 IDS Center Minneapolis, l\1N. 55402 Dear Mr. Cairns: Frank Boyles asked me to respond to your letter of August 9 concerning Buckingham Disposal. I have enclosed a Planning Commission roster for your information. Concerning Lloyd's Construction Services, it appears that they have occupied the building without benefit of a Certificate of Occupancy and their circumstances in that regard are similar to those of your client. The Building Department will be following up with this to rectify the apparent code violation Thank you for bringing this matter to our attention. r)nc. erely, . ./ . '---iJ' i,~/I ~ Donald Rye (j Director of Planning cc: Frank Boyles Gary S taber Document2 16200 Eagle Creek Ave.. Prior Lake. Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTUNIT'.' E~lPLOYER BUCKINGHAM DISPOAL, INe 5980 CREDIT RIVER ROAD PRIOR LAKE,:MN 55372 612-226-6441 6/95 SUMMARY OF OPERATIONS BUCKINGHAM DISPOSAL COMPANY WAS FORMED 27 YEARS AGO WITH TIm RECYCLING OPERATIONS STARTED IN JANUARY OF 1988. BUCKINGHAM RECYCLES IS OPEN TO 1HE PUBUC FROM 9 AM TIIL 3 P.M, MONDAY TIIRU FRIDAY WITH THE EXc~ON OF lHURSDA Y EVENING WIllCH IS TIIL 7 P.M AND EVERY SATURDAY FROM 10 AM J'llr4-P:M- MATERIAL-ACcl:fr' 1l:ill AT THIS F AcnJTY INCLUDE SCRAP METAL, - ..-.DRAIN.O~MAGAZINES~(~SPAPgR>omCE PAPER, PHONEBOOKS, ~tiJq), tIN-CAm;t;tA~~, ~.~'1ffiliB~. OTHER. RECYCLING ITEMS ~AKEN.BUT MAY INCLUDE A SMALL SERVICE .. ,- . ~ FEE ARE:. CO:MPOS~ ApPuANCE,'TIRES;' AND T.V. 'So ALUMIN1.JM---cx:Ns'" ARE-PoR:c:a:A.SlID FROM 1HE PUBLIC. WE OPERAlE OUT OF AN ENCLOSED Btm.DING OF APPROX. 14,000 SQ. Fr. ALL RECYCLING MATERIAL IS PROCESSED HERE BY OUR OWN EMPLOYEE'S (GENERALLY THREE FUlL 'I'Th1E) THAT DO STRIC'lL Y RECYCLING SUCH AS BALING CARDBOARD OR PLASTIC OR SIMPLY CRUSHING CANS OR HELPING CUSTO:MERS. MATERIALS ARE THEN TAKEN DmECIL Y OUTDOORS AND PUT INTO S:a1I- TRAILERS AND ARE SHIPP.BD DmEC'IL Y TO THE MILLS. ON A D~ Y BASIS BUCKINGHAM HANDLES APPROX ONE TON OF CARDBOARD AND ONE THOUSAND POUNDS OF ALUMINUM CANS. SCRAP :METAL, MAGAZINES NEWSPAPER AND O'IHERRELATED ITEMS ARE CONTAINED IN SMALL AMOUNTS IN CAGED TYPE CONTAINERS AND lRANSFERRED INTO ROLL-OFF BOXES OUTDOORS. WE THEN lRANSPORT OUR OWN MATERIALS TO MARKET. DR:1\iN-OILIS CONTAINED IN A SECONDARY CONrAINER. STORAGE TANK AND IS El\1.t'lltlJ FEEKLY BY: EDEL OIL SERVICE OF NORTHFIELD, lvfN EP A #.MND-985-742-774. BUCKINGHAM ALSO OPERATES A SOLID W ASlE COILECTION BUSINESS AND A ROIL-OFF CONSTRUCTION BOX RENTAL C011P ANY WITH AN ADDmONAL lHREEEVn'LOYEEs:-nm TOTAL EMPLOYEES FOR ALL OPERATIONS ARE NINE WEnCH INCLUDES MY WIFE AND MYSELF. BECKER ARENA PRODUCTS, INC. IS A 1ENANr OF OURS RENTING APPROX. 9~600 SQET. THEY MANUF ACTIJRE ICE HOCKEY ARENAS AND Elv1PLOY LESS mAN SIX ffiv1PLOYEES. 1HEIR MAIN OFFICE IS LOCATED ON COTTONWOOD LANE IN PRIOR LAKE. BUCKINGHAM ALSO FOLLOWS 1liE SCOTT COUNTY REQUIREMENTS WInCH ARE AS FOILOWS: lHE Nl.11vfBER OF W ASlE APPLIANCES STORED AT THE FACILITY SHAIL NOT EXCEED SIXTY. ONCE TIm NUMBER OF APPLIANCES REACHES SIXTY, '!HE liCENSEE SHAIL HA VB AIL APPLIANCES RElvfOVED FROM THE FACILITY. ALL APPLIANCES THAT CONTAIN HAZARDOUS MATERIALS (CFCtS, PCB CAPACITORS AND :MERCURY SHALL BE RElvfOVED FROM THE SITE BY AN APPLIANCE COILECTOR OR DELIVERED TO A FACILITY lHAT WILL RElvfOVE TIIE HAZARDOUS MATERIAL. THE VENDOR WE USE IS JR'S APPLIANCE DISPOSAL, INC. OF INVER. GROVE HEIGHrS, :MN. USED OIL AND WASTE BATIERlES ARE MANAGED IN ACCORDANCE WI1H THE SCOTT COUNTY HAZARDOUS W AS1E ORDINANCE NO. 12 THE NUMBER OF W ASIE TIRES DO NOT EXCEED FIFTY. THE TIRES ARE 'J STORED IN AN ENCLOSED BUILDING OR ON AN AREA IN DIRECT SUNLIGIIT, VOID OF ANYVEGETATION.- ._- ---- ACCESS SHALL BE CONIROILED BY WHAlEVER MEANS THE OWNER! LICENSEE DETERMINES TO BE WORKABLE. THE OWNER/UCENSEE SHAIL BE RESPONSIBLE FOR RErv10V AL AND PROPER DISPOSAL OF ALL UNACCEPTABLE W AS1ES. ONLY SEPARATED RECYCLABLES ARE MANAGES AT TInS SITE. :MIXED MUNICIPAL SOLID W ASlE IS NOT lRANSFERRED, STORED IN CONTAINERS OlHER 1HAN COlLECTION VEHICLES OR lIPPED FOR PROCESSING OR lRANSFERRED FROM TInS SITE. SCOTI COUNTY HAS NO llrlJilJ US THAT THE PRESENT SEWER SYS'IEv! IS ADEQUATE AND ACCEPTABLE AS TIm CITY HAS APPROVED. TIm COUNTY HAS ALSO INFORMED US THAT THEY HA VB MAILED NECESSARY FORMS AND mAT liCENSES WOULD BE APPROVED BY THEM ONCES WE HA VB CO:MPLIED WI1H THE CITY OF PRIOR LAKE ORDINANCES. THE BUCKINGHAM COMPANIES EMPLOYEE SUMMARY AREA 6- 1-95 DRIVERS 3 AD:MINISTRATION 3 RECYCLING CENTER 2 CLERICAL OFFICE I TOTAL 9 SCOTT COUNTY ENVIRONMENTAL HEALTH COURTHOUSE A 102 428 HOLMES ST~~TI:i5, 1995 SHAKOPEE, MN 55379-1393 (612) 496-81 n Tom Buckingham Buckingham Recycling Center 5980 Credit River Road Prior Lake, Minnesota Re: Solid Waste Facility License Dear Mr. Buckingham: This letter regards your application to operate a Recycling Facility in the City of Prior Lake. We have reviewed your application and must deny your license for the following reasons: 1. Lack of approval (zoning, conditional use, etc.) by the City of Prior Lake. 2. Failure to obtain and submit a Permit-By-Rule from the Minnesota Pollution Control Agency. In accordance with the Scott County Administrative Procedures Ordinance No. 1, Section 7.01, you have the right to make a written appeal to this decision. I have enclosed a copy of this Ordinance for your review. We will be sending you a refund of your annual license fee of $100.00. The application fee that you submitted of $50.00 is non-refundable. Denial of this license application does not prevent you from reapplying once the above mentioned items have been addressed and satisfactorily completed. All operations relating to the acceptance, storage and sorting of recyclable material must cease at this location until a license is obtained from this Office. Continued operation is a violation of the Scott County Solid Waste Ordinance NO.2, and subject to those penalties outlined in that Ordinance. If you are close to resolving the above noted issues, or if you have any questions please contact Jeff Peterson or myself at 496- 8177. Sincerely, a~ Allen Frechette Environmental Health Manager cc: Dick Underferth, County Commissioner, District 4 Frank Boyles, City Manager, City of Prior Lake! John Roach, Assistant County Attorney O:\S~\BUCKINGH.VIO An Equal Opportunity/Affirmative Action/Safety Aware Employer