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HomeMy WebLinkAbout8A - Hillcrest Homes Di~Y STAFF AGENDA REPORT AGENDA #: PREPARED BY: SUBJECT: 8A JENNITOV~PLANNER CONSIDER APPROVAL OF RESOLUTION #97-XX DENYING AN APPEAL OF HILLCREST HOMES FROM A DECISION OF THE ZONING OFFICER RELATING TO BLUFF AND TOP OF BLUFF DECEMBER 1, 1997 DATE: INTRODUCTION: Hillcrest Homes is appealing a decision of the Zoning Officer relating to definition of BLUFF and TOP OF BLUFF. DISCUSSION: Section 5-1-7 Definitions of the City Code reads as follows: . BLUFF: A topographic feature such as a hill, cliff, or embankment having the following characteristics (an area with an average slope ofless than 18 percent over a distance for 50 feet or more shall not be considered part of the bluff): (A) Part or all ofthe feature is located in a shoreline area; (B) The slope rises at least twenty five feet (25') or more above the ordinary high-water level of the waterbody; (C) The grade of the slope from the toe of the bluff to a point twenty-five feet (25') or more above the ordinary high-water level averages thirty percent (30%) or greater; and (D) The slope must drain toward the waterbody. . TOP OF THE BLUFF: The higher point of a fifty foot (50') segment with an average slope exceeding eighteen percent (18%). Planning Department interprets the definition of bluff as follows: 1:\97files\97appeal\97-110\97-110cc.doc 1 16200 Eagle Creek Ave. S.E., Prior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTUNITY EMPLOYER I:\97fi1es\97appeaI\97-110\97-1IOcc.doc · Part or all of the feature is located on a riparian lot. · The slope rises at least 25 feet or more above the OHW, anywhere on the slope and any distance from the OHW. On Prior Lake, this means the slope rises to at least 929.0 elevation on any part ofthe slope on the lot. · The grade of the slope from the toe of the bluff to a point 25 feet or more above the OHW averages 30% or greater. On Prior Lake, this means that the grade on the slope from the toe to 929.0 elevation or greater is greater than 30%. This can be any distance from the OHW. · The slope must drain towards the lake. Slopes draining away from the lake are not considered bluffs. . Another significant factor in determining bluffs is a grade of 18%. The definition oftop and toe of bluff are the highest and lowest points of 50 foot segments with slopes exceeding 18%. It is our interpretation that the entire 50 foot segment with a slope exceeding 18% is part of the bluff, with the highest point being considered the TOP OF BLUFF. Because the definition of TOP OF BLUFF and TOE OF BLUFF do not specify which 50 foot segments or which slopes, the top and toe can be located anywhere on the slope, no specific distance from the OHW. The definition of TOP OF BLUFF determines what is considered part of the bluff and what is not. Exhibit A is a diagram of this interpretation. Exhibit B is how this interpretation relates to the specific lot in question. Hillcrest Homes contends that because the definition states "... an area with an average slope of less than 18 percent over a distance for 50 feet or more shall not be considered part of the bluff" that this area is removed from the slope before a determination on top of bluff is made. Then, when the determination for top of bluff is made, this area cannot be a part of the top of bluff because it has been eliminated by definition. Exhibit C is Hillcrest Homes' 2 1:\97fi1es\97appeal\97-110\97-1IOcc.doc interpretation and Exhibit D is how this interpretation affects their specific lot. In meetings on October 4, 1997 and October 22, 1997, the DNR has given staff their interpretation of the definition of Bluff and Top of Bluff. The definitions that the city has adopted are the same as those in the 1987 DNR Shoreland Management Regulations. The DNR has concurred with the Planning Department staff interpretation. Attached is a written response affirming their position. Staffs conclusion is that the statement about not including areas with slopes less than 18% is meant to allow construction on flat areas of lots where there may be multiple bluffs. When the top of bluff is determined to be the highest point of a 50 foot segment where the average slope exceeds 18%, the area downhill from the top of bluff must be part ofthe bluffby definition. The Planning Commission, after much discussion, felt the definitions were ambiguous and cumbersome. The minutes of the meeting are attached. Upon considering staff interpretation of the ordinance as written, they felt staff interpretation was correct. They directed staff to work with the applicant in composing revised definitions and setbacks to be clear, specific and easily understood. This is to be considered with the revised Zoning Ordinance. Staff has worked with the applicant to write revised definitions. Staff, as well as the DNR, feel the proposed language is more concise and open to less varying interpretations. Attached is a copy of the proposed revision discussed at the Zoning Ordinance public hearing on November 24, 1997. The Planning Commission felt the proposed bluff language was concise and less open to varying interpretations. The Planning Commission recommended the revised bluff language be incorporated into the Revised Zoning Ordinance. There are a few different items yet to be resolved with respect to the Revised Zoning Ordinance. A continuation of the discussion will take place in December. The revised bluff language will be brought to the City Council as part of the Revised Zoning Ordinance to be a topic at the December 8, 1997 council workshop. 3 Additionally, the Planning Commission heard a variance request from Hillcrest Homes to the bluff and top of bluff setback, as written in the existing City Code. The proposed variance places the proposed home at the same bluff setback as the proposed revised bluff language. While the Planning Commission empathized with the applicant on the timing of the proposed amendment, they felt the hardship criteria were not present with respect to the property. They also stated that it would be improper to grant a variance based on an ordinance recommendation yet to be approved and adopted. If the variance to bluff and top ofbluff setback is appealed by Hillcrest Homes, the Council will hear the variance appeal in late December or early January. ISSUES: The City Council must determine if they agree with the staffs interpretation ofthe ordinance. The issue here is not to determine where the applicants feel the bluff is and the setbacks are in relation to the proposed house, but to determine if staff interpretation of the City Code is correct as written and adopted by the City Council. ALTERNATIVES: 1. Uphold the decision of the zoning officer by adopting Resolution #97-XX. 2. Uphold the position of the appellant and direct staff to prepare a resolution with findings supporting such action. 3. Other specific action as directed by the Council. RECOMMENDATION: Alternative #1, to uphold the decision of the zoning officer. ACTION REQUIRED: Adoption of Resolution #97-XX affirming the decision of the zoning officer 1:\97fi1es\97appeal\97-1 10\97-1 10cc.doc 4 RESOLUTION 97-XX RESOLUTION OF THE CITY COUNCIL UPHOLDING THE RECOMMENDATION OF THE PLANNING COMMISSION IN THE MATTER OF AN APPEAL BY ffiLLCREST HOMES, INC., OF A DECISION OF THE ZONING OFFICER RELATING TO BLUFF AND TOP OF BLUFF, MOTION BY: SECOND BY: WHEREAS, the Prior Lake City Council conducted a hearing on the 1st day of December, 1997, to act on an appeal by Hillcrest Homes Inc. of the Zoning Officer's interpretation of definition of BLUFF and TOP OF BLUFF and WHEREAS, the City Council reviewed the definitions of BLUFF and TOP OF BLUFF as written and adopted in 1995; and WHEREAS, the appellant has not set forth adequate reasons for overturning the decision of the Zoning Officer; and WHEREAS, the Planning Commission has recommended the City Council uphold the decision of the Zoning Officer: NOW THEREFORE, BE IT RESOL YED BY THE CITY COUNCIL OF PRIOR LAKE: FINDINGS 1. Hillcrest Homes Inc. appealed the decision of the Zoning Officer relating to the interpretation of BLUFF and TOP OF BLUFF as described in Section 5-1-7 of the City Code in order to permit a future residential dwelling on property located in the R-l (Suburban Residential) District and the SD (Shoreland Overlay) District at the following location, to wit: 16091 Northwood Road, legally described as Lot 92, Northwood Road. 2. The Planning Commission reviewed the appeal as contained in Case File #97-110, held hearings thereon on November 10, 1997, and recommended upholding the decision of the Zoning Officer. 3. The Prior Lake City Council reviewed this appeal on December 1, 1997. 4. The City Council has considered the effect of overturning the decision of the Zoning Officer upon the health, safety, and welfare of the community, the existing and anticipated traffic conditions, light and air, danger of fire, risk to the public safety, the effect on property values in the surrounding area and the effect of the appeal on the Comprehensive Plan. 1:\97fi1es\97appeal\97-11 O\ccres.doc P~g~ 1 16200 Eagle Creek Ave. S.E., Prior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQUAL OPPORTUNITY EMPLOYER LLLL OLL Z:) 0"" _an ~LL ~O <cwo. '.... ~ 0 - a:.... an :E ~ C X-ZZ Wu- -~ LLLL LLLL i!:) (/)~ %8l NtfH.L H3.Ltf3HS t 3d01S H1.IM 1.N3W93S .DS :J:J (179 :J 0 J:2Hid .10 N. \\ %8l NtfH1. 5S31 ~ 3d01S H1.IM 1.N3W93S .DS ~ - c:t. ~~ cl 0 <->i= - 11')< t- - luU- \3:)~ ~(l u.tt u-:;;) "::)...s -J~ -D u. cf')O - :t: r "'" ~ LEh ~ \.YO 0'0 , f:J ;<: (:) ~ (-;J' b'f. b'~ . 80b t,Pb Q'4 ~ II, ~/t6 hll, _ .s'6 t7;'b {'I, <f'6 t, 6 o~6 1~6 i:: r" b f-,~b S'El- '?'eb- (Eb I~ 8t:b- '!'~b c;fb diEb '=' V) UJ ~ o ....J Cf.) ~,- I In N ~o :..'N f/ o q> p\c m ~ '=' ~ In - (:) ,... ~Ob ~.., ... In " <:> , - , ' , " o ,... In - o N In N 0 0 V) (") In (') 0 ~ in ~ ~'iQ It) In In o CD It) CD o " ~ " o CO In CO o 0') - '0 In _ ,,0) ,I in .0 o ,... LlI LlI a. a. 0 0 "#. ..... "#. CI) -I co co CI) ,... ~ ,... ~ :f!: 2: i ~ ~ ~ ..... .... t- .... ~ CI) 2: a: ~ t3 ~ ~ C) -I C) ~ LU CI) UJ a: CI) Cl 0 <r- 0 =9 it) '0 NOT 'PA-RT EXHIBIT C HILLCREST HOMES. INTERPRETATION OF BLUFF AND TOP OF BLUFF ...... 'J ~ fY)1't) <t-, r., t)- 'IT'" '" ..... a-tI}() .... <:r- "I (f-. ~J e- '11 ():, ~ o F 6LL>F~_ ... u r-- M Ir -~ ['<, 0-- ~25' ') I ).. \ " " .1 20' 15' 10' i 5' 50' , ..; 30' 90' 85' 80' - 75' 70' 65' 60' 55' 56" C(. Cl, ~ ~ ~ () Q. ;!. . . -r t-\ \ S e LV F F M f ETS c..,,-,Tgtz,tA of BL.ufF DBy,,vITIO,v " fll ~ - I C- "5 In ~ nr :r- 0-- '11 rt) 0- " Ir ()- 'I ~ 0- J a r~ '" 0- ... (}.~ r}:" ,;::. ~~ L, ~ 0: 2:' "'r,) ~~ <1- ~ !? L' ... ;! f\;. '0 -, C7' (:~I j 605k 0& I ~Ol-> ~ " 'n ~J I) :t- lJ'o <J (to OHVv (I- 30' 25'. 20' 15' 5' 10' Minnesota Department of Natural Resources Metro Waters - 1200 Warner Road, St. Paul, MN 55106-6793 Telephone: (612) 772-7910 Fax: (612) 772-7977 November 7, 1997 Mr. Don Rye City of Prior Lake 16200 Eagle Creek Avenue, S.E. Prior Lake, Minnesota 55372-1714 RE: INTERPRETATION OF BLUFF DEFINITION IN SHORELAND AREAS Dear Mr. Rye: Oflate, we have had a great deal of discussion regarding bluffs within shoreland areas of the City of Prior Lake. This discussion has included the bluff failure which occurred earlier this year, as well as number of potential and proposed developments on lots where bluffs are present. The City of Prior Lake has adopted language, from Minnesota Rules, defIning bluff, top of bluff, and toe ofblufJ. I have reviewed the City's ordinance, and have met with City staff to review the administrative procedures used to determine top and toe of bluff for specifIc projects. While the language in state rule is admittedly a bit cumbersome, I concur with the manner in which the city is administering the ordinance as it pertains to bluff determination. The intent of the regulations limiting development on and within the bluff and bluff impact zones is to ensure slope stability, and to preserve the natural appearance of these topographic features in shoreland areas. The 30 foot structure setback from the top of bluff provides a minimwn distance between the bluff top and the proposed building site for the maneuvering of building materials and equipment during construction. If the existing definitions of bluff, top of bluff, and toe of bluff, as adopted, are deemed difficult to efficiently and effectively administer and enforce by city staff, the DNR would entertain, under the flexibility provisions of the Shoreland Rules, alternative defInitions, provided the original intent of bluff protection is not compromised. If you have any questions, please call me at 772-7910. Sincerely, ~~~~" Patrick J. Lynch-rtl Area Hydrologist c: Ed Fick, Shoreland Hydrologist DNR Information: 612-296-6157, 1-800-766-6000 . TTY: 612-296-5484, 1-800-657-3929 An Equal Opportunity Employer Who Values Diversity ft Printed on Recycled Paper Containing a ~., Minimum of 107< Post-Consumer Waste PROPOSED TOP OF BLUFF AND BLUFF SETBACK EXAMPLE i , ! I_ i ~ 40' I (j-l , 1 ,- I ~' -30'- :.: o "ct ~ lU CI) CJ ~ Q ...., r-- 5 lY\ Ql .s II- ['oJ Q-- if) IV) tr 11.2% , I 25' 14.3% . -25' "20' 15' - 10' i 5' I 55' .~ SO" 95' 1 00'1" ~ '\0' 90' 80" 75' 70' 65' 60' tt :) ~ ~ Q. E ..... u ~ I"r)"" 0"-. ~ t)- o <r- ~ ..... ll" t<) Q ...... q- "" (r.. lo G- '1J Oc> ,It- f'>. , ~ 'j " I'll ~ V, 0'- 'l' flf ll" 0-- :,--. '1l 'f) rr 0- I) l}_ '" - 0'- 'i'l '" Q ft ..... 0- ... o-.~ i:,.... ct:. ~L, ll" 0:: ~ O'-I't) ~~ "'::0 0-,1/'. ...: fo, (\ t..... a- 'J? ~ '0 0- V) <l Il' .... u ';to Q (roo 0/1 vJ ! j , I ! :/ 30' 25'" 20' 10' 5' , , I PROPOSED TOP OF BLUFF AND BLUFF SETBACK EXAMPLE I 0' 95' 90' I 10 , r ~ :10', 'j . , 70' 65' fJ ~ E--. f}j & Q ::3 ::::J a:, If: .:j ~ ~ ~ t:::, ~ e '" ;;- " 0- ' "~ ,~ .... ~ )- (). " tl " )- 0- .... lJ -.9 '\ ct ht' cf \ 0% q-' &0\ .. C\...\~ <\v\? .I. "I C\ ~ \ 55' ..... U :)- Q II'- D/ivJ 12% ..-~..---- 25' ,) " 'f~'1 el ! . ,!&f ~I h. " 1- , -i ! '1~" ,1 I \- - qoll{ cl "'1 fl , I 40' 25',-- 20' 3D' 60' 5' 10' October 31, 1997 Hillcrest Homes Attn: Chris Deanovic 14122 Louisiana Avenue Savage, MN 55378 RE: Bluff Interpretation Dear Mr. Deanovic, In regards to your recent inquiry as to what constitutes a bluff, the following are definitions as cited from Section 5-1-7 of the City Code. . BLUFF: A topographic feature such as a hill, cliff, or embankment having the following characteristics (an area with an average slope ofless than 18 percent over a distance for 50 feet or more shall not be considered part of the bluff): (A) Part or all of the feature is located in a shoreland area; (B) The slope rises at least twenty five feet (25') or more above the ordinary high-water level of the waterbody; (C) The grade of the slope from the toe of the bluffto a point twenty-five feet (25') or more above the ordinary high-water level averages thirty percent (30%) or greater; and (D) The slope must drain toward the waterbody. . TOP OF THE BLUFF: The higher point of a fifty foot (50') segment with an average slope exceeding eighteen percent (18%). Planning Department interprets the definition of bluff as follows: . Part or all of the feature is located on a riparian lot. . The slope rises at least 25 feet or more above the OHW, anywhere on the slope and any distance from the OHW. On Prior Lake, this means the slope rises to at least 929.0 elevation on any part of the slope on the lot.: . The grade of the slope from the toe of the bluff to a point 25 feet or more above the OHW averages 30% or greater. On Prior Lake, this means that the grade on the slope from the toe to 929.0 elevation or greater is greater than 30%. This can be any distance from the OHW. . The slope must drain towards the lake. Slopes draining away from the lake are not considered bluffs. 16200 Eagle Creek Ave. S.L Prior Lake. Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245 AN EQCAL OPPORTCNITY EMPLOYER HHI HILLCREST HOMES, INC. 16714 Jaguar Ave., Lakeville, Minnesota 55044 (612) 898-7663 Office (612) 898-3364 Fax '~ Builder Driven By Quality Crqftsmanship and Value." Date Nov. 3,1997 Jennifer Tovar Planner Dept. Of Planning and Zoning City of Prior Lake 16200 Eagle Creek Ave. Prior Lake, MN 55372 Dear Jennifer: Hillcrest Homes, Inc., wishes to appeal the staff interpretation of "Top of the Bluff" and.the resulting impact of the staff interpretation on our property at 16091 Northwood Road. As cited from section 5-1-7 of the City code the definition ofa bluffand "Top of the Bluff' are.ils follows: BLUFF-A topographic feature such as a hill, clitf, or embankment having the following characteristics (an area with an average slope ofless than 18 percent over a distance for 50 feet or more shall not be considered part of the blutl): (A) Part or all of the feature is located in a shoreland area: (B) The slope rises at least twenty five feet (25') or more above the ordinary high- water level of the water body; . (C)The grade of the slope from the toe of the bluff to a point twenty-five Jeet (25') or more above the ordinary high-water level averages thirty percent(30%) or greater; and (0) The slope must drain toward the water body. TOP OF THE BLUFF- The higher point of a fifty foot (50') segment with an average slope exceeding eighteen percent (18%). The. definition clearly states that " an area with an average slope of less than 18% over a distance of 50' shall not be considered part of the bluff'. The 50' segment between the 9338.1ld94f elevation points on the easterly side of the site in question has an average slope of 16%, and therefore should not be considered part of the bluff. In addition, the DNR definition for "Top of the Bluff' from which the city has adopted their ordinance states: "Top of the Bluff" means the point on a bluff where there is, as visually observed, a clearly identifiable break in the slope, from steeper to gentler slope above. If no break in the slope is apparent, the top of bluff shall be determined to be the upper end ofa 50' segment, measure on the ground, with an average slope exceeding 18 percent. Builder License # 20036544. Member of the Builders Association of the Twin Cities 5. On November 10, 1997, the Planning Commission directed staff to work with the appellant to compose definitions that are less ambiguous to be considered with revisions to the Zoning Ordinance to be heard by the Planning Commission on November 24, 1997. 6. Upholding the decision of the Zoning Officer results in a legal building envelope of approximately 10,330 square feet. 7. The contents of Planning Case File #97-11 0 are hereby entered into and made a part of the public record and the record of the decision for this case. CONCLUSION Based upon the Findings set forth above, the City Council hereby upholds the decision of the Zoning Officer and concurs with the recommendation of the Planning Commission that by definition of TOP OF BLUFF, area with slopes less that 18% over a distance of 50 feet, cannot be excluded from the bluff. 50 Foot areas with slopes less than 18% located only between the toe of the bluff and the top of the bluff are intended to be excluded. Passed and adopted this 1st day of December, 1997. YES NO Andren Kedrowski Mader Robbins Schenck Andren Kedrowski Mader Robbins Schenck {Seal} City Manager, City of Prior Lake 1:\97files\97appeal\97-110\ccres.doc Page 2 I b ~ en - -:I: I- o I- en w - ..I Q. Q. ~ Z o - ~ ~ w a: Q. ~ W I- Z - en - u. u. i! en 3: o :I: co I- - CO - J: X W ,y -1\\ .Q,,-N> 0/ '. [\W -p. 7J /~ -<:jr/,' . .,.f}/ , ' ~ GUil 5. @ (.0.) GUil c:J <:D ~ ~ L::::J \iUi1 ~ 2J -- ~-,,/./ . -\I ~ 1/ ,'/'~ ( \ / / ,/ ~- ..;/" / ',," .r.// / '-<:;- 0- // / \ i),(l . / \ ". \. ;c ,~' ~/.I / ''''~, ~\l V- I ! ::J ~ (J19 ::l 0 dOl- \ ^ t"II~"S .,r'fJV\ " -". .~." ....~ d" ~-? _ ~, ~ ~ - - . ~'! <- "" -". (;:"" /, ~' , I':: /' .~;-~ / ~\}""":f'" .. (.~ ;. '-.. L }'tJ ,h.;r. r. f,C/) - .:I: I- o ... .fffi d'_ ...I 0. 0. c:( Z o ~ .~ ~ w a: 0. a: w ... ..z - - CJ) w ~ o ::I: lii w a: g ...I - ::I: 3= o J: C I- - In - J: >< W 'v ~ (iUil ~ @ ~ IiUi1 c:::J to ~ ~ l:::::J UiiU ~ ;'0 !.Iv' I O\,~~ ~Q ~~(\19 'fJ~ \ <'b · / <. -S" o ~.....- " d'c?_?~ ;' - S ~ --;", '{-. -> o .~' ~~ }-, ,,- ""\. >:,' . (, : ./ ~'J'" /~ MEMORANDUM DATE: TO: FROM: November 18, 1997 Planning Commission Don Rye, Planning Director Jenni Tovar, Planner Proposed Bluff Language Jane Kansier, Planner; Bob Hutchins, Building Official; Pat Lynch, DNR; Hillcrest Homes; Jim Albers and BUD Waund, Edina Realty; McKnight and Associates RE: CC: Upon the direction of the Planning Commission at its November 10, 1997 meeting, the Planning Staff met with a local developer and real estate agent. The purpose of the meeting was to write revised bluff and top of bluff definitions to alleviate the cumbersome and difficult to interpret current bluff definitions. Based on this meeting, the Planning Staff is proposing the following amendments to the Shoreland and Zoning Ordinances: TOE OF BLUFF: Definition to remain the same. TOP OF BLUFF: The highest point of the slope, as measured from the toe of the bluff, where the grade is 30 percent or greater. BLUFF SETBACK: As measured from the TOP OF BLUFF, the upper end of a segment at least 25 feet in length having an average slope less than 18%. This removes the floating 50 foot segment. TOP OF BLUFF is determined as measured from the TOE OF THE BLUFF, with the slope measured between the 1 foot contours. The building setback is determined by the slope as measured from the TOP OF BLUFF (25 feet minimum), not distance to meet the intent of the ordinance. If the slope from the top of the bluff, towards the street, never drops below 18%, then the lot would be unbuildable without a variance. PROPOSED TOP OF BLUFF AND BLUFF SETBACK EXAMPLE ;'. ! . If ~ " t:I (!) ~ Q ;:! ~ Q) ~ '" 0"- -.: .... f;' .. 0- , \)- .. .. I, : 172% 20% -- - -- .'. 32' - ~t40' " '\: ., -",.'.'; ,:~3",..-- ' . \' ;25' I I J ..'. 12"0' 15' - 10' i 5' , ~ . DO' 95' 90' 1 ]'1 -:. . \0', 80' - 70' " ~ 0- 25' . 65' 55' 60' It ~ ~ ~ Q. E ...... u <r---- r-..,,,, 0--. l\-) I)- o c:r-- l\-) ..... 11' l"I\ () \)' '.... ~ Q- ~ ~ I)" () Il ..... 0- "- ~.:>" 0::....... i:. ~L, 0-':)- ~.... "'~ (to~ "'::-0 "', l/'. r () (to Ou () ,.... a-- ~ ~ '0 (J'o 50' 40' 25',.- 20' 10' 3D' 5' V) <l ()> -.. u :t- o It- OH vJ :./ I r:- SENT BY: DNR 'lETRO; 11 -24-97 11 :57; 6127727573 ==> 6124474245; #2/2 Minnesota Departrnenl of Nal ural Resources Metro Waters - 1200 Warner Road, St, Paul, MN 55106-6793 Telephone: (612) 772.7910 Fax: (612) 772-7977 November 24, 1997 Ms. Jenni Tovar, Planner City of Prior Lake J6200 Eagle Creek Avenue S.E. Prior Lake, Minn.c:sota 55372.1714 RE: PROPOSED BLUFF DEFINITION REVISIONS .Dear Ms. Tovar: 1 have reviewed the proposed revisions to the definitions of toe ofhlufT. rop ofblufJ. and hluffsethack (or purposes of administering your shcrcJand zoning a'dinance. As I had expressed. to Don Rye in my November 7. 1997 letter. the language c:cataincd in the state shoreland regulations, which the city has previously adopted., is somewhat difficult 1.0 administer. The changes you propose, as defined in your November 1 X. J 997 memo to the Planning Commission, l'Cpresa1t n:asonablc alternatives to the existing lzanguage: in your ordinana::. In Addition to the ddinition changes, the city is proposing to relax. the: sctbll.Ck from the top of bluff from the current 30 fcellO 25 feet. This redw:tion of five feet should not. nwaially affi:ct the infect of the bluff protection language. provided. the provisions regarding building. grading. tilling and vegeta1i.on alteration within the bluff impact l.one (the bluff itself and land within 20 fcxt landward ofthc top ofblum are retained. 'The DNR is not. opposed to the proposed zoning amendmcnl!, and the relaxation of the bluff setback standard can be ~provc:d through implcmc:nti1tion of the flexibility provisiCHlS of the state shoreland rules. If the City Council proceeds with approval of the proposed amendments. please forward a copy df the resolution to me. If you have any questions. please call me at 772~7910. Sincerely, \~-~~4J2---_._' Patrick J. Lynch 1H Area Hydrologist c: Ed Fick, ShorcJand Hydrologist I)Nr~ InronllalkHl: <d:!.:!'.lI1.tiIS7, J-Xf.lf.l 7('() (,f/()O . TTY: f,l:' i'll'. ~.l.s.l. '-X()().(,57 \lI.2'.1 .\" Elt'I.11 (Il'~hllhlllll~ 1~1iI"lu~l'r ""Ihl \.'.lllJ~." J)i"a~jl~ ..... 1'llIItctllll\ R~'\ l\ h'd f-'''\PCf ('Ollla:lllll?'.1 c...I Miltlllllll11 'U 1"'.(0 1'\)..l"<':UII~l:Ill1:r y..';h:II' · Another significant factor in determining bluffs is a grade of 18%. The definition of top and toe of bluff are the highest and lowest points of 50 foot segments with slopes exceeding 18%. It is our interpretation that the entire 50 foot segment with a slope exceeding 18% is part of the bluff, with the highest point being considered the TOP OF BLUFF. Because the definition of TOP OF BLUFF and TOE OF BLUFF do not specify which 50 foot segments or which slopes, the top and toe can be located anywhere on the slope, no specific distance from the OHW. As per our conversation today, you can appeal this interpretation to the City Council. We will need a letter stating your appeal and how your interpretation differs from ours. Any information you can provide us on your interpretation will be helpful to the City Council and Planning Commission prior to the meeting. The next scheduled Planning Commission date is Monday, November 10, 1997. We will need your interpretation and response to this letter by Monday, November 3, 1997 to be scheduled for that meeting. Please call me if you have any questions. Sincerely, j~ Since there is a clearly identifiable break in the slope we feel the 50 ft. segment with an average slope of16% is not part of the bluff. We believe the low point of this 50 ft. segment clearly identifies "Top of the Bluff", and the point from which the 30 ft. bluff setback is measured. Using this setback point would place the proposed structure in an appropriate location in reference to the adjoining property structures, thus creating consistency in the neighborhood. I .1 Pres. Hillcrest Homes, Inc. .. ~ ~-