Kalvig letter to CouncilKALVIG & LEDUC, P.C.
ATTORNEYS AT LAW
JOHN B. DUDIs
Southfield Tower
P.O. Box 1678
BRUCE A. FREDRICKSON*
KALISPELL, MT 59903
KEN A. KALVIG
1830 3,d Avenue East, Suite 301
PHONE: 406-257-6001
Kalispell, MT 59901
FAX: 406-257-6082
MARSHALL MURRAY
ALL ATTORNEYS LICENSED IN MT
(Retired)
W ALSO LICENSED IN NORTH DAKOTA
April 10, 2013
Via Hand Delivery
Hon. Tammi Fisher & City Council
City of Kalispell
201 1 sI Avenue East
Kalispell, MT 59901
Our Client: Montana Venture Partners, LLC
Re: Gardner/VW 2-Lot PUD Zoning Application
Dear Mayor Fisher and City Council Members:
I represent Montana Venture Partners, LLC ("MVP"), developer of the Old School Station
industrial and technology park, who wishes to comment on the above -referenced zoning
application. Thank you for the opportunity to do so. MVP submitted written comments and
materials to the Kalispell Planning Board for its review during the public hearing held on March
12, 2013. We have been informed by the City Clerk that a copy of those materials, which
consisted of a 34" binder ("Planning Board Binder"), has been provided to the City Council for
its review. The written materials contained substantial information and commentary relevant to
the GardnerNW PUD Application. I do not believe the planning office or planning board fully
grasped the relevance and importance of the materials, so I ask you to carefully and thoughtfully
review it all. Along with this letter, I am submitting some additional information in a separate
(and thankfully smaller) binder, the cover of which indicates the material is submitted to the City
of Kalispell in connection with an April 15, 2013 City Council Meeting ("Supplemental City
Council Binder").
Although the material is thick in volume, it all relates to a handful of primary issues, I hope
to adequately point out to you in this cover letter. I have highlighted certain material in the
binders that is of particular relevance to the issues MVP raises, which will help with your review.
The Gardner/VW 2-Lot PUD does not comply with Kalispell's PUD Zoning Regulations
April 10, 2013
Page 2 of 4
At Tab 19 of the Planning Board Binder, I provided a copy of those portions of Kalispell's
PUD Zoning Regulations ("PUD Regulations") addressing the PUD application and the Planning
Board's role in review of it. Based upon my review of Section 27.19.020(3)(e) and other
subsections, it is clear the PUD application does not comply with the PUD Regulations. In
particular, the application does not contain "proposed plans for handling" sewage disposal, water
supply, storm water drainage, landscaping, vehicular traffic, pedestrian traffic, and signage, among
other things. The PUD Regulations state the application "shall" contain that information. Nearly
all of these deficiencies for the first 2 lots are identified in numbered paragraphs 8, 9, 10, 11, 12,
13 & 14 found on pages 17-18 of Staff Report #KPUD-13-01 dated March 6, 2013. The planning
office appropriately points out the importance of addressing those issues, but mistakenly suggests
the applicant should provide that information prior to the issuance of a building permit, which
review would be done after the City Council has approved the PUD zoning and the public review
and comment process has closed. Prior to the issuance of the staff report, planning staff also noted
these and other deficiencies. See, Tabs 14 & 17 of the Planning Board Binder. The PUD
Regulations plainly require the applicant to provide those plans with the PUD application, which
entitles the public, including my client, the opportunity to fully review and comment on them. Of
particular importance to my client is how sewer and water are being provided to the site, the
applicant has proposed no plans for sewer and water, and my client has been denied its ability to
participate in the PUD review process.
In my review of the PUD Regulations and how the present application fails to comply
therewith, all found at Tab 19 of the Planning Board Binder, I highlighted particular provisions in
the regulations and offered written comments at the right-hand side of the page. My written
comments point out where the 2-lot PUD falls short of meeting the PUD Regulation requirements.
The Planning Board did not address these written comments; neither did the planning staff in the
March 26, 2013 Memo from Sean Conrad, found at Tab 32 of the Supplemental City Council
Binder. The planning office's justification for not addressing my comments seems to be that they
view the Gardner/VW PUD as small in size and scope so this PUD will be held to a different
standard. In reality, the Gardner property covered by the PUD Placeholder is approximately 80
acres, nearly double the size of Hutton Ranch, and the B-5 zoning allows all the same commercial
uses and more that were allowed and have developed in Hutton Ranch. I have recopied for you
the PUD Regulations and my comments about the Gardner/VW PUD not meeting them, all of
which is found at Tab 36 of the Supplemental City Council Binder.
Gardner PUD area needs to connect to the Old School Station water and sewer
Due to the lack of proposed plans for handling sewer and water to the Gardner property,
MVP has been in the dark about how it will be provided, but has heard from various sources that
these two lots and other portions of the Gardner property will not connect to the Old School
Station lines. If true, this creates potentially two problems for MVP and the City of Kalispell.
First, at the City's requirement, MVP increased the size of its water and sewer lines at substantial
cost, so those lines would have capacity to serve property south of Cemetery Road and beyond,
and MVP, pursuant to its Latecomer's Agreement with the City of Kalispell, gets that additional
expense reimbursed through the utility service of new development. Second, the City of Kalispell
has repeatedly made it clear that the Old School Station water and sewer infrastructure was put it
April 10, 2013
Page 3 of 4
and oversized so that it would be used by property developing south of Cemetery Road. This
position has been reiterated in studies done in connection with the planning for the Old School
Station lines, the Kalispell Growth Policy, the staff reports prepared for the Gardner and Siderius
Annexations, in a pamphlet prepared by the City regarding latecomer agreements, and in
statements made by City Council members. See, Tabs 2-6 & 8 of the Planning Board Binder and
Tabs 26, 29-30 of the Supplemental City Council Binder.
The planning board did not want to get into the issue of the latecomer contract at all, but it
is relevant in this PUD review process. MVP and the City need to be told what the applicants'
plans are for sewer and water. If there are alternative ideas, some of which would result in the
City not charging latecomer fees to development on the Gardner property, then MVP wholly
would object to such proposed plans and the City's interpretation of its commitment to MVP.
MVP and the City have a right to and need to know how water and sewer service will be provided
to these first two lots and to all the Gardner property. I completely disagree with the planning
office's assertion that the only thing the Planning Board and the City Council needs to know is
that utilities are available and there is capacity. More than that is required in a PUD. When the
Hutton Ranch and Startling PUDs were proposed, those developers provided drawings and reports
that discussed and showed how and where the PUD property would connect to the City's existing
infrastructure. This information was given for the first and subsequent phases of those projects.
Anyone looking at that information would immediately and easily know what the proposed plans
for sewer and water were. Hutton Ranch for example, shows how lines from particular buildings
will connect to the City infrastructure. See Tabs 33-35 of the Supplemental City Council Binder.
Kalispell needs to follow through with its promises and commitments made to MVP, that
as property along the Highway 93 South Corridor develops, it will utilize the Old School Station
lines and contribute toward reimbursement for those lines. MVP will support development along
the Highway 93 South Corridor and understands why the City would welcome working with the
Gardner family. MVP has also been an important partner with the City, as evidenced by its
public/private partnership on the oversized Old School Station infrastructure. It is important that it
continues to receive from the City the support and assistance it needs to recoup the cost of its
infrastructure investment.
Approval of the 2-lot PUD application sets bad precedent and sends the wrong message
The City Council needs to carefully and wisely consider the 2-lot PUD application. As
stated above and shown in the submitted materials, the applicant has not submitted an application
that complies with the PUD zoning regulations for these first two lots. A further problem with the
application is that it does not adequately address future phasing, which is an important element of
a PUD.
The Planning Board and City Council extensively discussed the importance of phasing and
the conceptual (at a minimum) information that needs to be provided about future phases when the
PUD regulations were amended in 2008, creating the PUD Placeholder concept. Members of the
Planning Board expressed concern about the amount of information that would be provided at the
outset of a PUD when a placeholder was established. See, Tab 10 of Planning Board Binder.
April 10, 2013
Page 4 of 4
Councilman Hafferman initiated a lengthy discussion about the amount of information that would
be provided regarding future development after the initial phase. See, Tab 27 of the Supplemental
City Council Binder. In that discussion, and in earlier statements made to the planning board and
in the staff report regarding the proposed amendments to the PUD zoning regulations, Planning
Director Tom Jentz, repeatedly assured everyone that a PUD applicant would need to provide at
least a minimal level of information about future development, just as developers in the past have
been required to do. He specifically calls out the Starling PUD as an example the Council was
particularly pleased with and he assured the Council that the changes to the PUD regulations were
only making the PUD regulations consistent with how the City had processed PUDs in the past.
See, Tabs 9 & 10 of the Planning Board Binder; see also, Tabs 27 & 29 of the Supplemental City
Council Binder. At Tabs 22-24 of the Planning Board Binder, we submitted material from the
Starling, Hutton Ranch, and Valley Ranch PUDs as examples of the standards PUDs have been
held to in the past. The GardnerNW PUD looks nothing like these examples. If the current PUD
regulations were written to ensure that what was done in the past with PUDs will also be done in
the future, something has gone terribly wrong. At Tab 21 of the Planning Board Binder, Bruce
Lutz succinctly points this out.
I believe this may be the first PUD to be developed in a PUD Placeholder area. If this
application, in its present form, is approved, it establishes precedent for what all future PUD
applicants will expect and demand. It would be arbitrary and capricious for the City to not treat
everyone else in the future the same. If one PUD developer is allowed to not meet the terms of the
regulations or ignore future phasing, then they all must be allowed to do it. Imagine if Phil Harris
of Hutton Ranch was coming to you at this time with an application for just a movie theater and
presented no plans for the remainder of his property. Gardner's property is larger than Hutton
Ranch.
Finally, and in closing, Kalispell must stand by the private developers that have invested in
over -sizing the City's infrastructure. If the City does not, then what developer in the future would
be willing to advance such costs.
I intend to be at the City Council meeting when this topic comes up and will be available
to offer further comment and answer any questions you have.
Sincerely,
Ken A. Kalvig
ken@kalviglaw.com
cc: Montana Venture Partners, LLC
Enc. Bound written comments submitted as public comment for City Council meeting on or
about April 15, 2013 on Gardner/VW 2-Lot PUD Zoning Application