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HomeMy WebLinkAboutAP201800001 Staff Report 2018-12-05AGENDA DATE: 12/5/2018 TITLE: Route 29 LLC Appeal of Zoning Administrator's Determination of Proffer Violation SUBJECT/PROPOSAL/REQUEST: Appeal of Zoning Administrator's Determination that Route 29 LLC's ZMA 2012-005 Hollymead Town Center Al Violated Proffer Regarding Cash Payment of Transit Operating Expenses ITEM TYPE: Regular Action Item STAFF CONTACT(S): Richardson, Walker, Kamptner, Herrick, Graham, McCulley, Ragsdale PRESENTER (S): Amelia McCulley LEGAL REVIEW: Yes REVIEWED BY: Jeffrey B. Richardson BACKGROUND: Hollymead Town Center Al (ZMA 2005-15) was originally rezoned to Planned Development Mixed Commercial on September 12, 2007. The rezoning was amended by Route 29 LLC twice: on January 12, 2011 with ZMA 2010-014 and most recently with ZMA 2012-005 on December 11, 2013. The relevant proffer was provided with the original rezoning and was not changed with the two amendments. Proffer #4 of ZMA 2012-005 states: "Public Transit Operating Expenses — Within thirty days after demand by the County after public transportation service is provided to the Project, the Owner shall contribute $50, 000 cash to the County to be used for operating expenses relating to such service, and shall contribute $50, 000 cash to the County each year thereafter for a period of nine (9) additional years, such that the cash contributed to the County pursuant to this Proffer 4, shall total Five Hundred Thousand Dollars ($500, 000). The cash contribution in years two through ten shall be paid by the anniversary date of the first contribution. " Public transit service was established to the site on May 2, 2016 and is ongoing. The service is operated by JAUNT. On May 20, 2016, Rebecca Ragsdale, Senior Planner, requested payment of the first $50,000 cash contribution be made payable to the County by June 20, 2016 (Att B). Subsequent to this, Route 29 LLC filed litigation relating to the transit proffer to seek relief. On May 7, 2018, Rebecca Ragsdale requested payment of $150,000 be made by June 18, 2018 to satisfy the three proffer payments that are past due (Att C). On August 7, 2018, the Zoning Administrator issued Route 29 LLC an official determination of violation (NOV) for failure to pay the transit proffer (Att A). On September 6, the appellants filed this appeal (Att E). STRATEGIC PLAN: Quality Government Operations: Ensure County government's capacity to provide high quality service that achieves community priorities. DISCUSSION: A commuter bus run by JAUNT on behalf of Charlottesville -Albemarle Transit (CAT) constitutes "public transportation service." That is the trigger for the transit proffer payment. All other contentions the appellant makes are more appropriate considerations as amendments to the proffer. Proffer amendments are processed through a rezoning application rather than an appeal. These and other considerations have been discussed with the appellant although a proffer amendment has not been fully pursued. Greg Kamptner, in his role as Deputy County Attorney, sent a letter to the appellant's attorney, Pete Caramanis, stating that the transit proffer had been triggered because "JAUNT provides `public transportation service' within the meaning of Proffer 4." His letter further stated "Unless, and until, Proffer 4 is amended, it is an enforceable obligation of Route 29 LLC. Failure to comply with the proffer will be a zoning violation. Amending Proffer 4 would have to be accomplished through the rezoning process and ultimately be subject to approval by the Board of Supervisors" (Att D). BUDGET IMPACT: Proffers are intended, among other things, to provide mitigation of impacts and public benefits without increasing the financial burden on the locality. The owner's failure to meet its proffer obligation results in a $50,000 revenue loss per year, or $500,000 over the 10-year life of the proffer. RECOMMENDATION: Staff recommends that the Board adopt the attached Resolution (Attachment F) to deny Route 29 LLC's appeal and to affirm the Zoning Administrator's August 7, 2018 determination. ATTACHMENTS: Attachment A: Notice of Violation: August 7, 2018 Attachment B: First letter requesting transit proffer payment: May 20, 2016 Attachment C: Second letter requesting transit proffer payment: May 7, 2018 Attachment D: Letter from Greg Kamptner to Pete Caramanis regarding Transportation Proffer: December 1, 2015 Attachment E: Appellant's letter of Appeal: September 6, 2018 Attachment F: Resolution Denying Appeal and Affirming Zoning Administrator's Determination FAX (434) 972-4126 COUNTY OF ALBEMARLE Community Development Department 401 McIntire Road Charlottesville, Virginia 22902-4596 TELEPHONE (434) 296-5832 NOTICE OF OFFICIAL DETERMINATION OF VIOLATION The Date this Notice of Determination is given is August 7, 2018. REGISTERED MAIL # RE 234 267 096 US Route 29 LLC (Owner) Wendell Wood, Manager PO Box 5548 Charlottesville, VA 22905 Property: Hollymead Town Center Area A-1 03200-00-00-042A, 03200-00-00-04400 (portion), 03200-00-00-04500 (portion) and 04600-00-00-00500 (portion) Zoning: PD-MC-Planned Development Mixed Commercial District Dear Mr. Wood: TTD (434) 972-4012 No: VIO-2018-153 Same as Above Owner of Record This notice is to inform you that the above -described Property is in violation of the Albemarle County Zoning Ordinance due to unsatisfied proffers from ZMA-2012-00005. Proffer 4 specifically provides: " Public Transit Operating Expenses — Within thirty days after demand by the County after public transportation service is provided to the Project, the Owner shall contribute $50,000 cash to the County to be used for operating expenses relating to such service, and shall contribute $50,000 cash to the County each year thereafter for a period of nine (9) additional years, such that the cash contributed to the County pursuant to this Proffer 4, shall total Five Hundred Thousand Dollars ($500,000). The cash contribution in years two through ten shall be paid by the anniversary date of the first contribution." By letter dated May 20, 2016, the County made demand for the first $50,000 cash contribution under this proffer by June 20, 2016. A second annual payment was due in 2017. The County further sent a reminder VIO-2018-153 Page 2 August 7, 2018 letter on May 7, 2018, demanding payment of the third required annual payment by June 18, 2018. All the three required payments have yet to be made. These proffer violations are unlawful violations of the Zoning Ordinance, and may result in civil penalties, criminal penalties, injunctive relief and/or other remedies, pursuant to Albemarle County Code § 18-36. This letter is also to order you to comply with the above proffers by September 6, 2018. Failure to comply with these proffers may result in legal action being taken against you and any other owner, tenant or other responsible party. Your timely compliance with this order does not excuse the violations cited herein and does not preclude the County from pursuing further legal action for these violations. Pursuant to Virginia Code § 15.2-2301: "Any zoning applicant or any other person who is aggrieved by a decision of the Zoning Administrator made pursuant to the provisions of Virginia Code § 15.2-2299 may petition the governing body for review of the decision of the Zoning Administrator. All petitions for review shall be filed with the zoning administrator and with the clerk of the governing body within thirty (30) days from the date of the decision for which review is sought and shall specify the grounds upon which the petitioner is aggrieved. A decision by the governing body on an appeal taken pursuant to this section shall be binding upon the owner of the property which is the subject of such appeal only if the owner of such property has been provided written notice of the zoning violation, written determination, or other appealable decision. An aggrieved party may petition the circuit court for review of the decision of the governing body on an appeal taken pursuant to this section. The provisions of subsection F of Virginia Code § 15.2-2285 shall apply to such petitions to the circuit court, mutatis mutandis." In accordance with Virginia Code § 15.2-2299, failure to meet all conditions of ZMA-2012-005 shall constitute cause to deny the issuance of any of the required use, occupancy, or building permits. If you have any questions, please contact Lisa Green, Senior Code Compliance Officer, at 434-296- 5832 ext. 3013. ,� (. / R 4 � �JP(3 1, r, Amelia G. McCulley, Ad.C.P. Zoning Administrator County of Albemarle RE 234 267 096 US AUTHENTICATION OF RECORD/ CERTIFICATE OF MAILING (Code of Virginia § 8.01-390) (Notice of Official Determination of Violation) 1, L/SA �s9eEW , hereby certify: 1. that I am a Code Enforcement Officer and an employee of the Albemarle County Department of Community Development; 2. that on U�rr 07 , 20 /8 , I mailed a true copy of the record attached hereto, consisting of a Notice of Official Determination of Violation dated AaXyyT 7 20/F pertaining to that property identified as Parcel ID Number(s) D32 p32-LK to the recipient(s) identified thereon at the address(es) specified thereon; and 3. that the copy of such record which is attached hereto is a true copy of the record that was mailed. Dated: $b /20/2 Signed COMMONWEALTH OF VIRGINIA CITY/COUNTY OF The foregoing Authentication of Rec ord/Certificate of Mailing was signed, sworn to and acknowledged before me by /r& ZCaw,&,A"bemarle County Code Enforcement Officer, this day of , 20 -g—. Notary Public My Commission Expires: Zj' P'.l_AN ciA{ y �ji Notary Registration No. 77 (o - n : REG. A774770 EAD �Zy .. � N COUNTY OF ALBEMARLE Department of Community Development 401 McIntire Road, North Wing Charlottesville, Virginia 2290245% Phone 434 296-5832 Fax 434)972-4176 NOTICE SENTFIRST CLASS MAIL, CERTIFIED MAIL, AND ELECTRONIC MAIL May 20,2016 91 7199 9991 7035 5776 0457 Wendell Wood Route 29 LLC PO Box 5548 Charlottesville, VA 22905 RE: ZMA 2012-00005 Hollymead Town Center A 1 Proffer 3- Transit Stop Benches Proffer 4-Public Transit Operating Expenses Tax Map Parcel 03200-00-00-042AO Dear Mr. Wood, In accordance with the proffers approved with rezoning ZMA 2012-0005, Albemarle County hereby requests that the requirements of Proffer 3 and 4 be satisfied. Specifically, the County hereby requests the following pursuant to the terms of the Proffer 3: 3. n r ' n - The Owner has constructed oae public transit slap within Hailymead Town Center Area A -I and 2 benches shall be installed within 30 days after transit service is established to the trmsit stop;. Public transit was established by JAUNT to Hollymead Town Center on May 2, 2016. The County requests that two benches be installed by June 20, 2016. The County hereby requests the following pursuant to the terms of the Proffer 4: 4. Public Transit Operating Exomses - Within thirty days after demand by the County after public transportation service is Provided to the Project, the Owner shall contribute $50,000 cash to the County to be used for operating expenses relating to such service, and shall comnribute $50,000 cash to the County each year thereafter for a period of nice (9) additional years, such that the cash contributed to the County pursuaA to tNs Proffer 4, shall total Five Hundred Thousand Dollars ($500,000). The cash contribution in years two through ten shall be paid by the anniversary date of the first contribution. Since public transit service was established to the site on May 2, 2016, the County requests that the first $50,000 cash contribution be made payable to the County of Albemarle by June 20, 2016. Going forward, you will be sent an invoice each year as a reminder that the proffer payment is due (example enclosed). Please remit payment to Community Development and include a copy of this letter and the invoice when making the payment. Be advised that failure to comply with proffers will constitute a zoning violation and may result in civil penalties enforced by the Zoning Administrator as well as withholding of building permits and plans. Should you have any questions, please contact me at (434) 296-5832 ext.3226 or rraasdaleOalbemarle.org. Sincerely, Y'Of �-4 Rebecca Ragsdale Senior Planner -Zoning 2 County of Albemarle 401 MCINTIRE ROAD CHARLOTTESVILLE VA 22902-4596 Bill to: ROUTE 29 LLC ATTN: WENDELL WOOD P.O. BOX 5548 CHARLOTTESVILLE VA 22905 INVOICE FY2016-00001053 Type Date 5/17/2016 Page 1 1000-0301 Purchase Order ID Customer ID Salesperson ID Shipping Method Payment Terms ID ROUTE 29 LLC UPON RECEIPT Item Number Description Quantity Rate Amount EXPENSES Expenses 1 $50,000.00 $50,000.00 ZMA 2012-00005 Hollymead Town Center A-1 Proffer 4- Public Transit Operating Expenses To ensure proper application of your payment, Total $50,000.00 please remit the yellow invoice copy. A self-addressed remittance envelope is included for your convenience. COUNTY OF ALBEMARLE Department of Community Development 401 McIntire Road, North Wing Charlottesville, Virginia 22902-4596 Phone (434) 296-5832 Fax (434) 972-4176 NOTICE SENT FIRST CLASS MAIL, CERTIFIED MAIL, AND ELECTRONIC MAIL 91 7199 9991 7035 5776 0662 May 7, 2018 Wendell Wood Route 29 LLC PO Box 5548 Charlottesville, VA 22905 RE: ZMA201200005 Hollymead Town Center A-1 Proffer 3- Transit Stop Benches and Proffer 4-Public Transit Operating Expenses Tax Map Parcel 03200-00-00-042AO and others Dear Mr. Wood, The Board of Supervisors approved your rezoning application number ZMA201200005 on December 11, 2013 with proffers. You were advised in a letter dated May 20, 2016 that the terms of Proffers 3 and 4 of ZMA201200005 must be met. Specifically, the County hereby requested the following proffers be satisfied. 3. Public Transit Stop Construction - The Owner has constructed one public transit stop within Hollymead Town Center Area A-1 and 2 benches shall be installed within 30 days after transit service is established to the transit stop- 4. Public Transit Operating Expenses - Within thirty days after demand by the County after public transportation service is provided to the Project, the Owner shall contribute $50,000 cash to the County to be used for operating expenses relating to such service, and shall contribute $50,000 cash to the County each year thereafter for a period of nine (9) additional years, such that the cash contributed to the County pursuant to this Proffer 4, shall total Five Hundred Thousand Dollars ($500,000). The cash contribution in years two through ten shall be paid by the anniversary date of the fast contribution. Since public transit service was established to the site on May 2, 2016, the County requested that the first $50,000 cash contribution be made payable to the County of Albemarle by June 20, 2016. A second payment was due in 2017 and now a third payment is due in 2018. The County hereby requests that payment of $150,000 be made by June 18, 2018 to satisfy the three proffer payments that are past due. Be advised that failure to comply with proffers will constitute a zoning violation and may result in civil penalties enforced by the Zoning Administrator as well as withholding of building permits and plans. Should you have any questions, please contact me at (434) 296-5832 ext.3226 or rragsdale(aD-albemarle.org. Sincerely, �AKJ'41_6 Rebecca Ragsdale Senior Planner -Zoning COUNTY OF ALBEMARLE Department of Community Development 401 McIntire Road, North Wing Charlottesville, Virginia 2290245% Phone (4M) 2%-5832 Fax (434) 972-4176 NOTICE SENT FIRST CLASSMAIL, CERTIFIED MAIL, AND ELECTRONIC MAIL May 20, 2016 91 7199 9991 7035 577L 0457 Wendell Wood Route 29 LLC PO Box 5548 Charlottesville, VA 22905 RE: ZMA 2012-00005 Hollymead Town Center A-1 Proffer 3- Transit Stop Benches Proffer 4-Public Transit Operating Expenses Tax Map Parcel 03200-00-00-042AO Dear Mr. Wood, In accordance with the proffers approved with rezoning ZMA 2012-0005, Albemarle County hereby requests that the requirements of Proffer 3 and 4 be satisfied. Specifically, the County hereby requests the following pursuant to the terms of the Proffer 3: 3. Poblic T=it Stag Qnstraction - 1he Owner has caasuucted one public transit stop within Hollymead Town Cent= Area A-1 and 2 benches shall be installed within 30 days after transit service is established to the transit stop. - Public transit was established by JAUNT to Hollymead Town Center on May 2, 2016. The County requests that two benches be installed by June 20, 2016. The County hereby requests the following pursuant to the terms of the Proffer 4: 4. Public Transit Opera ' tg Ezncmm - Within thirty days after demand by the County after public Uansportanon service is provided to the Projec4, the Owner shall coutnbute $50,000 cash to the County to be used for operating expenses relating to such service, and shall com t ribute $50,000 cash to the County each year thereafter for a period of nine (9) additional years, such that the cash contributed to the County pursuant to this Proffer 4, shall total Five Hundred Thousand Dollars ($500,000). The cash contribution m years two through ten shall be paid by the anniversary date of the first contribution. Since public transit service was established to the site on May 2, 2016, the County requests that the first $50,000 cash contribution be made payable to the County of Albemarle by June 20, 2016. Going forward, you will be sent an invoice each year as a reminder that the proffer payment is due (example enclosed). Please remit payment to Community Development and include a copy of this letter and the invoice when making the payment. Be advised that failure to comply with proffers will constitute a zoning violation and may result in civil penalties enforced by the Zoning Administrator as well as withholding of building permits and plans. Should you have any questions, please contact me at (434) 296-5832 ext.3226 or rragsdaleg albemade.org. Sincerely, J4�-4 Rebecca Ragsdale Senior Planner -Zoning N County of Albemarle 401 MCINTIRE ROAD CHARLOTTESVILLE VA 22902-4596 Bill to: ROUTE 29 LLC ATTN: WENDELL WOOD P.O. BOX 5548 CHARLOTTESVILLE VA 22905 INVOICE FY2016.00001053 Type Date 5/17/2016 Pa e 1 1000-0301 Purchase Order ID Customer ID Salesperson ID Shipping Method Payment Terms ID ROUTE 29 LLC UPON RECEIPT Item Number Description Quantity Rate Amount EXPENSES Expenses $50,000.00 $50,000.00 ZMA 2012-00005 Hallymead Town Center A-1 Proffer 4- Public Transit Operating Expenses To ensure proper application of your payment, Total $50,000.00 please remit the yellow invoice copy. A self-addressed remittance envelope is incfuded for your convenience. LARRY W. DAVIS COUNTY ATTORNEY GREG KAMPTNER DEPUTY COUNTY ATTORNEY COUNTY OF ALBEMARLE Office of County Attorney 401 McIntire Road, Suite 325 Charlottesville, Virginia 22902-4596 PHONE: (434) 972-4067 FAX: (434) 972-4068 December 1, 2015 Via Email pcaromanis@rcmplc.com and Regular Mail Peter J. Caramanis, Esquire Royer Caramanis & McDonough 200-C Garrett Street Charlottesville, VA 22902 Re: Hollymead Town Center — Transportation Proffer Dear Pete: ANDREW H. HERRICK JOHN C. BLAIR, 11 SENIOR ASSISTANT COUNTY ATTORNEYS RICHARD A. DELORIA ASSISTANT COUNTY ATTORNEY I have reviewed your letter dated November 16, 2015, in which you challenge the County's reliance on Proffer 4, which was originally accepted by the Albemarle County Board of Supervisors in conjunction with the rezoning of Hollymead Town Center Area A -I (ZMA 2005- 00015) on September 12, 2007. Proffer 4 was most recently accepted in conjunction with ZMA 2012-00005. Proffer 4 provides in part that, within 30 days "after demand by the County after public transportation service is provided to the Project, the Owner shall contribute $50,000 cash to the County to be used for operating expenses ..." Proffer 4 also commits the Owner to contribute $50,000 each year thereafter for 9 additional years. Proffer 4 has not been amended since it was originally accepted. The purpose of Proffer 4 was to partially address the transportation impacts that would result from rezoning the Hollymead Town Center Area A-1 lands from Rural Areas, an agricultural zoning district, to Planned Development — Mixed Commercial, a district that allows large scale commercial uses composed of both office and retail. The rezoning authorized 278,000 square feet of retail and office uses. The transportation impacts resulting from this rezoning were a key consideration, and many of the proffers accepted in conjunction with the rezoning addressed transportation -related impacts. While it may be true that no other rezoning in Albemarle County has included a proffer in which an owner has committed itself to contribute a cash amount for public transportation service similar to that in Proffer 4, transportation impacts may be addressed at the rezoning stage in a number of ways. Each rezoning is evaluated on its own merits and the proffers are tailored by the owner to address the impacts generated by its particular project. Proffer 4 was not unreasonable in 2007 nor is it unreasonable now. Peter J. Caramanis, Esquire December 1, 2015 Page 2 JAUNT provides "public transportation service" within the meaning of Proffer 4. To the extent that the proposed route will be a commuter route, the parking lot in Hollymead Town Center Area A-1 is not planned to serve as a park -and -ride location. Instead, Hollymead Town Center Area A- I will serve as a transit stop, a use envisioned by the commitment by the Owner in Proffer 3 to construct a transit stop within Area A-1. It may reasonably be assumed that riders will get on and off the bus at the Area A-1 transit stop. While Route 29 LLC may want the JAUNT bus to primarily be dropping off shoppers at the Hollymead Town Center Area A -I transit stop, the plain language of Proffer 4 does not restrict "public transportation services" for purposes of the proffer. Moreover, Hollymead Town Center is a large employment center and providing public transportation for the employees of Hollymead Town Center reasonably addresses some of the transportation impacts resulting from the Area A-1 rezoning. Unless, and until, Proffer 4 is amended, it is an enforceable obligation of Route 29 LLC. Failure to comply with the proffer will be a zoning violation. Amending Proffer 4 would have to be accomplished through the rezoning process and ultimately be subject to approval by the Board of Supervisors. If Route 29 LLC is interested in pursuing amending Proffer 4, I suggest that you contact the County's Department of Community Development (434-296-5832) to schedule a pre - application meeting. Very truly yours, Attorney ROYER ^CK PETER CARAMANIS Attttorneyat Law CARAMANIS & pcar 200-C@arrett .com McDONOUGH 2Otes Garrett Street Charlottesville, VA 22902 (434) 260-8767 ■ Fax (434) 710-4061 REAL ESTATE EI BUSINESS 9 BANKING M WILLS, TRUSTS 5 ESTATES N CIVIL LITIGATION N CIiIMINAL DEFENSE EE FAMILY LAVJ N MILITARY LAW COLLISON F. ROYER PETER J. CARAMANIS September 6, 2018 STACEY L. MCDONOUGH J ESSICA F. PHILLIPS ERNEST A. HARPER _ Board of Supervisors of Albemarle County SHELLIE S.TAYLOR Attn: Claudette Borgersen, Clerk TAYLOR R. ODOM SAMANTHA V. RICCI 401 McIntire Road Charlottesville, VA 22902 cborgersen@albemarle.org Via Email and Hand Delivery Amelia G. McCulley, Zoning Administrator County of Albemarle 401 McIntire Road Charlottesville, VA 22902 amcculle@albemarle.org Via Email and Hand Delivery RE: Petition for Appeal of Notice of Official Determination of Violation No: VIO-2018-153 Dear Members of Board and Ms. McCulley: As you Imow, I represent Route 29 LLC in connection with the proffers related to Hollymead Town Center Area A-1. I am in receipt of Ms. McCulley's letter to my client dated August 7, 2018 captioned "Notice of Official Determination of Violation" related to the unpaid invoices for Proffer 4, as referenced therein (the "Transit Proffer"), which is the subject of ongoing litigation (the "Notice of Violation"), I hereby submit this letter as a formal petition for appeal of the Notice of Violation pursuant to Virginia Code §15.2-2301, to request that Ms. McCulley reconsider her determination, and to the extent her decision remains unchanged, to petition the governing body to review the decision for the reasons and on the grounds more specifically set forth below. History of the Transit Proffer Issue The debate over the Transit Proffer goes back some time. The Transit Proffer was initially put in place by a prior owner and developer at the height of the real estate boom as part of ZMA-2005- 00015. After the real estate market had crashed, the property was acquired by my client who requested certain proffer amendments in order to facilitate development within Area A-1, namely the Kohl's store. Among those proffer amendments was a request to amend the Transit Proffer which gained the support of the Planning Commission. Unfortunately, when those amendments got before the Board of Supervisors, it was determined that the public notice did not permit ROYER, CARAMANIS & MCDONOUGH, PLC IS A VIRGINIA PROFESSIONAL LIMITED LIABILITY COMPANY www.rcmptc.com amendment of the Transit Proffer, and so my client was faced with a choice to amend those other proffers that he could and to keep the Kohl's project moving forward or to start the process over and likely lose the Kohl's project. They chose to accept those proffer amendments which were possible at the time, saving the Kohl's project and planning to resubmit a proposed amendment to the Transit Proffer at a later date. This is all clear from the Board of Supervisors minutes for ZMA- 2010-00014. It was everyone's expectation at that time (the County's and my client's) that the Transit Proffer would be amended. In 2016, there was conversation within the County government related to a new commuter JAUNT bus (the "Commuter Bus") to travel from Hollymead Town Center to downtown Charlottesville and the University of Virginia. My client spoke at multiple public meetings, as did I on their behalf, informing the County that before it appropriated funds for this new Commuter Bus route in reliance on the application of the Transit Proffer, that it understand our position that the Transit Proffer is not triggered by a Commuter Bus that has nothing to do with any impacts caused by the development. Without addressing our repeated comments, the Board of Supervisors did authorize funding for the Commuter Bus. We subsequently filed an application to amend the Transit Proffer (ZMA-2016-00002), held a community meeting at which there was no opposition expressed, and received nothing but understanding comments from the public and from County officials. Nevertheless, when the County's staff report was released, it not only recommended denial of the application, but was unable to cite even one favorable factor to our request — the first time in all of my years that I have seen such a one-sided staff report. We deferred our request so I could have follow-up conversations with staff regarding the nature of the report and my concern that important staff turnover in the midst of our application had led to some important oversights. Before we could even hold such a meeting with staff, my client was issued the first invoice for the full Transit Proffer amount. My client took that as a clear sign from the County that it had no intention on trying to amicably solve the issues before us, and consequently, filed the pending lawsuit over the Transit Proffer. That being said, my client always intended and still intends to reach an amicable resolution to this matter which involves a reasonably amended and jointly agreed proffer. We have made additional overtures regarding such discussions since the lawsuit has been pending, but, again, have received no real indication from the County that it desires an amicable resolution. The latest action, of course, has been the issuance of additional invoices and your Notice of Violation. We believe this background is relevant to show that my client has not been ignoring the issue, but rather has been making a great deal of effort to (1) head off the issue before it became a problem by their initial comments at the public meetings, (2) attempt to resolve the issue through a proffer amendment application, and (3) attempt to engage in dialog regarding a mutual agreement, but unfortunately has not seen those efforts well -received or reciprocated. The context of the failure to pay the invoices is critical to understanding these matters and whether a Notice of Violation should have been issued. 10ROYER CARAMAN IS Sc Page 2 of 4 14cDONOLIGH The Underlying Arguments Regarding the Transit Proffer It is also not possible to truly evaluate the appropriateness of the Notice of Violation without considering the underlying arguments being made related to the Transit Proffer and the changes in circumstance over time. Before getting to the merits of the argument, it is important to note that conditions have changed significantly since the initial Transit Proffer was adopted in 2007. Around that time, the real estate market was at its peak and considerably more development than what we now see was contemplated at Hollymead Town Center ("HTC). In addition, at that time, Route 29 was a much narrower road and was the only real option for getting people from Charlottesville to HTC. Now, there have been many transportation improvements including the widening of Route 29, the construction ofTown Center Drive and the extension of Ber1cmar Drive. All ofthese improvements alleviate transportation -related concerns and minimize the potential impacts of the development on traffic. This leads us to the crux of the argument against the imposition of the Transit Proffer, and consequently to the request to reconsider and withdraw the Notice of Violation — HTC Area A-1 has not caused and is not anticipated to cause impact as would justify my client being required to pay $500,000 toward the Commuter Bus. Some of the relevant points are as follows: The Transit Proffer only applies to HTC Area A-1. The Commuter Bus by its very definition is intended to take people who live in the HTC area to places closer to downtown Charlottesville, i.e., "commuters". HTC Area A-1 does not include any residential units, i.e., no commuters. Furthermore, the people who come to HTC Area A-1 to work are (a) minimal in number and (b) do not work typical 9-5 work day hours which would be served by the Commuter Bus. In other words, the Commuter Bus is not intended to, and does not, bring people to and from any of the businesses within HTC Area A-1, and more importantly, does not address any impact actually created by HTC Area A-1. Rather, over the course of its existence, the Commuter Bus has taken a mere handful of people who live near HTC to their jobs at UVA or in downtown Charlottesville. Again, this need is completely unrelated to the HTC Area A-1 development. My client could hire a van and a driver to shuttle those people at a fraction of the cost of the Transit Proffer if transporting these people were actually their responsibility. 2. HTC is a large development, and it seems County staff can get confused in trying to justify the application of the Transit Proffer by assessing the larger project. In fact, in their report for ZMA-2016-00002, Staff specifically tried to link HTC Area A-1 and A-2, stating, in part, "When Hollymead Town Center Area A was initially discussed, the transit proffer was intended to cover all ofArea A, which is now Area Al and A2. When the two projects were split, the proffer remained in the Al proffers. The A2 proffers made provision for affordable housing, a pocket park and greenway, a 2 acre site for a recycling center or other public facility, and cash proffers for the residential uses. The transit proffer addresses the transportation/traffic impacts generated by Area Al and A2." That is a complete misstatement of fact, because it is without question that the proffers for HTC Area A-1 only relate to Area A-1 as is clear on their face. As stated previously, the transportation/traffic impacts have already been addressed by the widening of Route 29 and the construction of additional, alternative roads — much of which it should be noted was funded by my client who has spent over $11 Million in those efforts. OROYER CARAMAN I S & Page 3 of 4 WDONOUGH It is clear from the County's own Land Use Law Handbook and otherwise, that proffers are generally intended to address "the impacts resulting from a rezoning," and that they must be "reasonable," connected to the rezoning by an "essential nexus" and show "rough proportionality to the impacts they seek to address." The application of the Transit Proffer to the Commuter Bus, and the Notice of Violation that has arisen as a result, fail to meet any of those standards. As stated above, the Commuter Bus does not address any impact resulting from the rezoning. The rezoning of HTC Area A-1 did not create additional commuters. Any traffic impacts caused by the rezoning have been fully addressed by the widening of Route 29, the construction of Town Center Drive and the extension of Berkmar Drive. There are no transportation/traffic impacts left to address, and the Commuter Bus is certainly not the type of public transit contemplated by the original Transit Proffer. For the foregoing reasons, we ask that you reconsider and rescind the Notice of Violation. We would hope this could be done in the context of working toward an agreed resolution to the Transit Proffer situation as a whole, but at a minimum, that it be rescinded pending determination by the Court whether the Commuter Bus was a legitimate trigger of the Transit Proffer. Again, we believe there is reasonably middle ground here, but we certainly cannot find it unless the County is also attempting to do so. We, once again, ask that the County come to the table to discuss this issue in an attempt to resolve it. To the public, it seems on the surface very clear that this has been a simple "money grab," where the County tries to fit a square peg into a round hole just to get the maximum amount of money it can from proffers which may never otherwise be triggered. However, that interpretation goes against the nature of the individuals that I know and work with at the County, so I am asking that those honorable and well-intentioned individuals give this matter a fresh and objective look and help work with me to resolve it in everyone's best interest. I look forward to your reply, and will be happy to meet to discuss or otherwise answer any questions or provide any additional information that may be helpful as you consider this appeal/petition. Best regards. Very truly yours, Peter J. Caramanis Cc: Greg Kamptner, County Attorney (via hand delivery) Shellie S. Taylor, Esq. Client (via email) IMROYER CARAMAN IS & Page 4 of 4 McDONOUGH RESOLUTION DENYING ROUTE 29 LLC'S APPEAL AND AFFIRMING THE ZONING ADMINISTRATOR'S AUGUST 7, 2018 DETERMINATION WHEREAS, on December 11, 2013, the Albemarle County Board of Supervisors approved ZMA 2012-005 Hollymead Town Center Al with proffers; and WHEREAS, Proffer 4 requires the contribution of $50,000 cash per year to the County for a period of ten years and a total cash contribution of $500,000 to be used for operating expenses relating to public transportation service to Hollymead Town Center; and WHEREAS, Proffer 4 requires the first payment to be made within thirty days after demand by the County after public transportation service is provided to Hollymead Town Center, and payments two through 10 to be made by the anniversary date of the first contribution; and WHEREAS, public transportation service was established to the Hollymead Town Center on May 2, 2016 and is ongoing, and on May 20, 2016, the first $50,000 contribution was requested in writing to be paid to the County by June 20, 2016; and WHEREAS, Route 29 LLC did not make the payment, and filed suit against the County seeking relief from the requirements of Proffer 4; and WHEREAS, on May 7, 2018, the first three contributions of $50,000 each, or $150,000, was requested in writing to be paid by June 18, 2018, and Route 29 LLC did not make the payment; and WHEREAS, on August 7, 2018, the Zoning Administrator issued a Notice of Official Determination of Violation to Route 29 LLC for failure to pay the amount due pursuant to Proffer 4; and WHEREAS, Route 29 LLC appealed the Zoning Administrator's August 7, 2018 determination to the Board as provided by Virginia Code § 15.2-2301, asserting that Proffer 4 should have been previously amended and should still be amended. NOW, THEREFORE, BE IT RESOLVED that, upon consideration of the foregoing, the executive summary prepared for the Appeal of the Zoning Administrator's Determination and all of its attachments, and the information presented at the Board of Supervisor's December 5, 2018 meeting, the Albemarle County Board of Supervisors hereby denies Route 29 LLC's appeal and affirms the Zoning Administrator's August 7, 2018 determination that Route 29 LLC is in violation of Proffer 4 because public transportation service is provided and Route 29 LLC has failed to make three annual $50,000 contributions to the County for a total of $150,000, and has thereby failed to satisfy Proffer 4 accepted in conjunction with ZMA 2012-005. I, Claudette K. Borgersen, do hereby certify that the foregoing writing is a true and correct copy of a Resolution duly adopted by the Board of Supervisors of Albemarle County by a vote of to as recorded below, at a meeting held on December 5, 2018. Aye Nay Mr. Dill Mr. Gallaway Ms. Mallek Ms. McKeel Ms. Palmer Mr. Randolph Clerk, Board of County Supervisors