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REVIEW COMMENTS -- P" :4'.. ') -""'\ , ,. .... ....~, CITY OF BOYNTON BEACH MEMORANDUM TO Honorable Mayor and City Commission FROM: Nicholas I. Igwe, Assistant City Atto ey RE: Boynton Landings vs. City of Boynton ach (Sign Code violations /display of illegal banners) DATE: December 15,2000 Recently the Code Compliance Division issued three citations to Boynton Landings Ltd., the owner of Boynton Landings apartments, located at 230 N. Congress Ave., for hanging 10 banners on individual poles at the entrance of the apartment. While the citations were pending in the court system, Boynton Landings unsuccessfully sought to administratively modify the approved site plan to permit the banners on the property. Boynton Landings' appeal of the administrative decision to modify its site plan was denied by the Planning and Zoning Board. Ultimately, the Commission ratified the Planning and Zoning Board's decision. On December 14, 2000, the three citations were tried in the county court. We are happy to announce that our Office prevailed on this matter. Boynton Landings was adjudicated guilty of the charged offenses and ordered to pay a total of $699 in court costs and fines. Boynton Landings was ordered to remove the illegal signs by 5 P.M. December 18, 2000. We are thankful to Courtney Caine, Code Compliance Officer, Scott Blasie, Code Compliance Supervisor and Code Compliance Division for their professional support and assistance in the prosecution of this matter. Thank you. Cc: James Cherof, City Attorney Kurt Bressner, City Manager Quintus Greene, Director of Development Mike Rumpf, Planning Director Lusia Galav, Senior Planner Scott Blasie, Code Compliance Supervisor Courtney Cain, Code Compliance Inspector Members ofthe Code Compliance Board Members of the Planning and Zoning Board ~ SlIgwe filelBoynton Landings Memo: '--.....--.. Galav Lusia From: Sent: To: Cc: Subject: Galav Lusia Tuesday, October 17, 2000 11 :41 AM Igwe, Nicholas Rumpf, Michael Boynton Landings Appeal Nicholas, I have prepared the staff report for the above referenced appeal. I have a question for you regarding what constitutes "public notice" and "due notice to the parties of interest" as provided in Chapter 1, Article VII, Sec. 1 E. HEARING OF APPEALS. we are planning to put this item on the November 8, 2000 City CJmmission meeting. Please advise as soon as possible. Thanks. Lusia P+D ill 2~/6D C! ~ 1:1/)'/00 1 /Jrr-tJ;.') _ ? - P()2Fzj tr ~{/fUi-q ~2h . J; if ~ <'1111~;V .-yf H:!/,~ L-i h~c/ a.... /i/( /2 _ 0--0--~ J-o'h.- ~, ~/J~ ( I 11'f(~ 2j ~i:AI",- "'-U/a;-(~~:C~ .:2- c'{ h- --v ~J.i cJ Iv U-4; (c,1>>>U-fl..., (fI{j b()('A:J cYf 20"1 r~) /} p~v--fj\ atA. 2f1~~t +- / ! '-' (/ { 6ch )LevI4~; ~~------- .- . - [.1,/fJ-~ ^-- 1'<' 2rrl/cz:hv Ca:1.rL i~/l/Ic-c..., ~~1 CY[)~Q.o~ V David M. Layman, 561/650-7990 ~~ff~~[~~ ATTOR:-IEYS AT LAW 1~~~~la li.bY! II UO -00 I ~ /-:::::\ r-~~7 (f '-'I Ij Ii SJ V ~~U e-mail: laymand@gtlaw.com June 29, 2000 VIA FEDEX Mr. Michael W. Rumpf Planning and Zoning Director 100 East Boynton Beach Boulevard P.O. Box 310 Boynton Beach, Florida 33425 Re: Request for Code Review and Appeal of June 20. 2000 Determination Dear Mr. Rumpf: ()fb.e} il1'2.t dek.~mihcla{lt/V'- . UXLj YVl~de ( () 'J'lJ.Yle..I) 2000 lL~) );Jvt1Sf DD--653 As you know, this firm represents CSC Boynton Landing, Ltd., the owner of the Boynton Landings Apartments (the "Property"). This letter serves as an application for Code Review and an appeal of the determination made in your June 20, 2000 letter regarding the signs located at the Property. We respectfully appeal the determination made in your June 20, 2000 letter on the same grounds originally set forth in our original letter to you requesting a minor modification to the site plan for the Property. Enclosed please find a check for $200.00 for the appeal fee. We desire to pursue the approval of the signs where they are currently located and, accordingly, we also request a Code Review. Pursuant to Chapter 1, Article VII, Section 1. B. of the Boynton Beach Code, kindly forward our appeal with the documentation we previously provided you with (i.e., we had previously provided you with (4) copies of the Boynton Landings survey and photographs of the signs) to the appeal board for placement on the board's next available agenda. Please call me at 650-7927 to set up a pre-application Code Review meeting with your staff. '.A Da . . Enclosure cc: Mr. Danny Ruda (w/o encl.) WPBiCANI:-;OF/2707S9/Ssx301'.DOO6l29Ioo/20821 013800 GREENBERG TRAURIG, P.A. P.O. Box 20629 WEST PAL'll BEACH. FLORIDA 33416-0629 561-650-7900 FAX 561-655-6222 www.gtlaw.com 777 SOLTH FLAGLER DRIVE SUITE 300 EAST WEST PAUl BEACH, FLORID.~ 33401 MIAMI :\'EW YORK WASHINGTON, D.C. ATLA:-ITA PHILADELPHH Tyso:-;s COR:'iER SAo PALLO FORT LALDERDALE WEST PALM BEACH ORLA:-;DO TALl.AHASSEE BOCA R.\TON 28 Boynton Beach Code ARTICLE VII. APPEALS Sec. 1. Appeals from decisions of an admini~trative official. A. ELIGIBILITY. Appeals of decisions of an administrative official may be taken by any person aggrieved or by any officer, board, or bureau of the governing body affected by any decision of an administrative official under any ordinance enacted pursuant to the Land Development Regulations of the City of Boynton Beach. B. FILING. Appeals shall be filed within fifteen (15) calendar days after rendition of the order, requirement, decision, or determination with the official from whom the appeal is taken specifying the grounds for the appeal. A current cenified survey and a fee as adopted by resolution of the City Commission, plans, drawings, documents and/or other material constituting the record upon which the action was taken shall be collected by the administrative official and, together with the completed appeal, forwarded to the appropriate appeal board for placement on the board's next available agenda. C. STAY OF WORK. Upon posting of acceptable surety (see Chapter 7) by the appellant in an amount equal to 110 % of the potential costs of delays and damages as certified by a design professional, all work on the premises and all proceedings in furtherance of the action appealed from will be stayed, unless the official from whom the appeal was taken certifies that by reason of facts stated in the certificate, a stay would cause imminent peril of life or property. In such case, proceedings or work shall not be stayed except by a restraining order which may be granted by the board or by a court of record on application, on notice to the officer from whom the appeal is taken and on due cause shown. D. ASSIGNMENT OF APPEALS. The City of Boynton Beach has several boards/commissions which deal with a variety of appeals, variances, exemptions, exceptions, etc., as follows: 1. The building board of adjustment and appeals will hear and decide appeals of administrative 1997 S-5 decisions or detenninations made in the enforcement or administration of LDR Chapter 20, Building, Housing and Construction Regulations and the various building codes and ordinances adopted by the City. See LDR Chapter 20, Article VII, Section 2D for detailed information. 2. The City Commission will hear and decide appeals of administrative decisions or determinations in the enforcement or administration of environmental review pennits; excavation, dredging and/or fill pennits; major/minor site plan or master plan modifications and height exceptions. 3. The concurrency review board will hear and decide appeals of administrative decisions denying a certification of concurrency and/or a , conditional certification of concurrency. I 0Y1f1<?~ II! r:" (10 'S.QtiI i c..e 4. The board of zoning appeals will hear and decide appeals of administrative decisions or determinations made in the enforcement or administration of all portions of the Land Development Regulations not specifically enumerated within the jurisdiction of the City Commission and/or the building board of adjustment and appeals and/or the concurrency review board. See LDR Chapter 2, Section 10 for detailed information. E. HEARING OF APPEALS. Each board or commission shall fix a reasonable time for the hearing of the appeal, give public notice thereof, as well as due notice to the parties in interest. Upon the hearing, any party may appear in person, by agent or by attorney. F. REVIEW OF ADMINISTRA TIVE ORDERS. In exercising its powers, each board or commission may, reverse or affirm, wholly or partly, . or may modify the order, requirement, decision, or determination made by an administrative official and may make any necessary order, requirement, decision, or detennination, and to that end shall have all the powers of the officer from whom the appeal is taken. The concurring vote of a majority of the members present shall be necessary to reverse any order. requirement, decision, or determination of any administrative official or to decide in favor of the General Provisions applicant on any matter upon which the board or commission is required to pass. G. INDEMNIFICATION. In the eventa claim or lawsuit is brought against the City, its officers, employees, servants or agents, the applicant hereby agrees to indemnify, save, and hold harmless the City, its officers, employees, servants or agents and to defend said persons from any such claims, liabilities, causes of action, and judgements of any type whatsoever arising out of or relating to the appeals from decisions of an administrative official whether the appellant is the applicant or any other party. The appellant agrees to pay all costs, attorney's fees, and expenses incurred by the City, its officers, employees, servants or agents in connection with such claims, liabilities or suits. Nothing contained herein, however, shall act as a waiver of any of the City's immunities provided for in Florida Statutes, Section 768.28. (Ord. No. 96-49, ~ 7, 1- 21-97) Sec. 2. Appeals from decisions of the concurrency review board. A. ELIGIBILITY. Appeals of decisions of the concurrency review board may be taken by any aggrieved party affected by a board decision. B. FILING. Appeals shall be filed within fifteen (15) calendar days after rendition of the order, requirement, decision or determination with the planning and zoning director specifying the grounds for the appeal. A fee as adopted by resolution of the City Commission together with other documents and materials constituting the record upon which the action was taken shall be collected by the planning and zoning director and, together with the completed appeal, forwarded to the planning and development board for placement on the board's next available agenda. C. HEARING OF APPEALS. The planning and development board shall fix a reasonable time for the hearing of the appeal, give public notice thereof, as well as due notice to the parties in interest. Upon the hearing, any party may appear in person, by agent or by attorney. 1997 S-5 29 D. REVIEWING APPEALS. In exercising its powers, the planning and development board may reverse or affirm wholly or partly, or may modify the decision or determination made by the concurrency review board and may make any necessary order, requirement, decision or determination, and to that end shall have all the powers of the concurrency review board and the planning and zoning director. The concurring vote of a majority of the members present shall be necessary to reverse any order, requirement, decision, or determination of the concurrency review board or to decide in favor of the applicant on any matter upon which the board is required to pass. (Ord. No. 96-49, ~ 7, 1-21-97) Sec. 3. Appeals from decisions of the board of zoning appeals, and the building board of adjustment and appeals. A. ELIGIBILITY. Appeals of decisions of the board of zoning appeals and the building board of adjustment and appeals may be taken by any aggrieved party affected by a board decision. B. FILING. Appeals for judicial relief shall be filed with the circuit court within thirty (30) calendar days after rendition of a board decision. (Ord. No. 96-49, ~ 7, 1-21-97) Sec. 4. Appeals from decisions of the City Commission. A. ELIGIBILITY. Appeals of decisions by the City Commission may be taken by any aggrieved party affected by a commission decision. B. FILING. Appeals for judicial relief shall be filed with the circuit court within thirty (30) calendar . days after rendition of a commission decision. (Ord. No. 96-49, ~ 7, 1-21-97) Sec. S. Withdrawal or denial of appeal. A. REFlLING AFTER DENIAL. Upon denial of an application for relief hereunder, in whole or in part, a period of one (1) year must run prior to the ADMINISTRATIVE APPEAL 1-000-4-413.70 DATE FILE NO. PROJECT DESCRIPTION MADE ADAP NAME BY I 11'5 t=Vl en - ("::0 \ 5:>;:> G\.-h ~:\.J)- -~ \0 Cu.Ai~-E C::J31L D\'" .~~ Pxk ~~\_~, ~c:, ,,~LJ r- . YI~/~'1 <Tl-rJ:r~ ~ ...~- (~~\" '"C::. Q~'(~ S~~I~'tt:"'" lj' !~1 o/r6 pn Q7-oo:") (~-114-</) (~JI J~(~ o riff'" l~ (1~..d ,nl lhl J:.. L. . ~IY' y_../ . ~ .~ ~ D:\SHARE\ WP\FOR.lI.1S\PROJTYPE\A.DAP. WPD Galav Lusia From: Sent: To: Cc: Subject: Igwe, Nicholas Thursday, July 27, 2000 11 :31 AM Rumpf, Michael Galav Lusia RE: Appeal process- Boynton Landings (banners) Mike: I have reviewed Mr. Layman's letter of June 29, 2000, requesting a code review and appeal of your department's June 1, 2000 administrative decision denying his request for site plan modification to allow banners on his client's property. Please consider the following: Question presented: Whether Mr. Layman's letter of June 9, 2000 asking for reconsideration, tolls the 15 day period to file his appeal under DR Part III, Chapter 1, Article VII, section I. B? Brief Answer: No. Facts: On May 18, 2000 Mr. Layman wrote a letter requesting a modification of an approved site plan. On June 1, 2000 letter denying the request for modification was generated. On June 9, 2000 letter seeking a reconsideration of the June 1, 2000 decision denying the proposed site plan modification was made. On June 20, 2000 a letter denying the request to reconsider was generated. Applicable Law and Analysis: The above referenced code section permits Mr. Layman to file an appeal within 15 days of an administrative decision. Nothing in the code permits the filing of a "motion" to reconsider. Under Florida Rules of Appellate Procedure, a motion for reconsideration of a decision does not toll the time period for filing an appeal. In this instance, Mr. Layman's appeal clock started running from June 1, 2000 when the City advised him of the decision to deny his modification request in writing. As stated earlier, nothing in the code allows the filing of a "motion to reconsider" and thus Mr. Layman's appellate right could not have commenced on June 9, 2000 when he filed for reconsideration. It is clear that the letter seeking to appeal the administrative decision is untimely as that letter was received more than 15 days of the decision denying his proposed modification. Though not requested by Mr. Layman, there may be other section of the code that may afford him a relief. ----Original Message---- From: Rumpf, Michael Sent: Monday, July 24, 20004:47 PM To: Igwe, Nicholas Cc: Galav Lusia Subject: Appeal process- Boynton Landings (banners) Hey Nick, we need your assistance to confirm the validity of a current appeal application. This apartment complex purchased and erected entrance banners. Our code prohibits banners so code enforcement cited them. They 1 contacted an attorney to get involI,cQ ""ho says our code doesn't prohibit them. IlleY asked that their site plan be modified to allow the banners we responded negatively due to code. They then submitted an application an appeal. Our first review was conducted by June 1 st and findings communicated in a June 1 st letter. We then submitted a 2nd letter to further drive our point home that it was prohibited. On June 29th they filed an appeal letter. The code requires that an appeal be sent within 15 days. This means they are too late based on the first determination. We are meeting with them on August 2nd. Can you confirm that we are correct in our determination that they are prohibited and that they have exceeded the appeal period? Thanks, MR. 2 DEVELOPMENT DEPARTMENT MEMORANDUM NO. PZ 00-217 TO: Mike Rumpf Planning ~d Zo g Director FROM: Lusia Galav Senior PI I DATE: July 24, 2000 SUBJECT: Boynton Landings ADAP 00-001 I have reviewed the information contained in the above referenced file. The applicant has chosen to appeal the administrative decision regarding banner signs located at Boynton Landings. I have a concern regarding the validity of the appeal. The applicant is using your letter dated June 20, 2000 as the start of the required 15-day filing timeframe. (Chapter 1, Article VII., Sec. 1. B.). However, the original decision was made through the minor modification process and conveyed through my letter dated June 1, 2000. The appeal request letter is dated June 29, 2000. I recommend a legal opinion be sought to verify that the appeal is legitimate. In the event that the appeal is valid, the code states that this matter would go before the board of zoning appeals, which is no longer in existence. Therefore, the appeal would be forwarded to the City Commission for their review and determination. Review of past appeal applications indicates that a staff report with exhibits, conditions of approval and a development order, is placed directly on the City Commission agenda. No special advertising requirements are outlined in the code. The applicant is also seeking a code revision and has requested a pre-application meeting to discuss same. A pre-application meeting is set for Wednesday, August 2,2000 at 9:30 AM with David Layman the applicant. Nicholas Igwe, Assistant City Attorney, will also be joining us. As an appeal may involve further legal action in a court of law, I recommend that we include the City's legal counsel in all further actions involving this application. Galav Lusia From: Sent: To: Cc: Subject: Rumpf, Michael Monday, July 24,20004:47 PM Igwe, Nicholas Galav Lusia Appeal process~ Boynton Landings (banners) Hey Nick, we need your assistance to confirm the validity of a current appeal application. This apartment complex purchased and erected entrance banners. Our code prohibits banners so code enforcement cited them. They contacted an attorney to get involved who says our code doesn't prohibit them. They asked that their site plan be modified to allow the banners we responded negatively due to code. They then submitted an application an appeal. Our first review was conducted by June 1st and findings communicated in a June 1st letter. We then submitted a 2nd letter to further drive our point home that it was prohibited. On June 29th they filed an appeal letter. The code requires that an appeal be sent within 15 days. This means they are too late based on the first determination. We are meeting with them on August 2nd. Can you confirm that we are correct in our determination that they are prohibited and that they have exceeded the appeal period? Thanks, MR. 1 Galav Lusia To: Cc: Subject: Blasie,Scott; Cain, Courtney Rumpf, Michael; Igwe, Nicholas Boynton Landings - Banners Please be advised that the attorney for Boynton Landings filed an appeal dated June 29, 2000 to the administrative decision regarding the ten (10) "banners" located in the front of the entrance on Congress Avenue. On the advice of the Assistant City Attorney, Nicholas Igwe, no further citations should be issued while the appeal is in process. Thank you for your cooperation. Lusia 1 OCT-16-00 10:12 AM CODE COMPLIANCE - ~ - --: CITY OF BOYNTON BEACH ~ _. ~ . "'. l00E.Bo;riIaABIICh~ ",." . . -.",~, ~OId/llllee . ,.IqnItnBadl,Fl33>&35 :;-"'-.'._" ,,- o eo.rty CocIt . (561)375-1120 ~. 08 0036 4 . FLORIDA UNFORM CODE CITAtioN .' 1IlIlIlIInIf*l"" ... .. ,. ~ .. ___.... m ....... .. ~ IIIINt lilt an. '.: ~-;;JO " ./ b~~ ~Go:;6'licJ;~: ~ ". L' ,._J>-" .';., . -., J ' -..':. '.' rr'jn'7d""'l:;,.,,Ci,;';'c'S"""- ./l"":_,_,}",,,<~;, . ~ -- ." ","" .,- . A./ (cl7i':'t*'?r.5'~O~.J;f !:U'; .,~,:, ~ '7 ... ZIp S(J/ --~7"o" r;;"cl;' ;n~':::e~'";J.S:; r-' n6 'T'Ji'f'lIo'~l%'r/;~ . .,~:. ,J......... -- ...\"..;. t l~$.:l; ft~JA..~ "li~' ~'r~~' .1'!'~.,ozr ::Ft~. . io~'~: a~I.i.fJA7IT S~L! 7./~..>.~. ;~ .':~ . '...' :. .'," ;-..~~.." ;J.t'r1!,l;-. '-,\ W ;i\~ /-/7 ,'Br..iJ,'6t-F L.~ ,I~fij /~'.;'i;;>'''''.'''':! . ~ . I. -. ~ ..Bt'/ /1" i-;;::..... 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Rumpf Planning and Zoning Director 100 East Boynton Beach Boulevard P.O. Box 310 Boynton Beach, Florida 33425 Re: Request for Minor Site Plan Modification for Boynton Landings Dear Mr. Rumpf: This firm represents CSC Boynton Landing, Ltd., the .owner of the Boynton Landings Apartments (the "Property"). This letter serves as a request:;.for a minor modification to the Boynton Landings site plan. Enclosed please find a check for $100.00 for this application for the minor modification, four (4) copies of the Boynton Landings survey (we could not obtain copies of the site plans) and photographs of the architectural accents being added to the site plan. These architectural accents were recently added to the Property and for your convenience are shown on the attached surveys plans as red dots. As you can see from the photographs, these accents are an architectural enhancement to the entranceway to the Property. These sturdy poles are painted with Benjamin Moore exterior gloss material and are designed to withstand sustained winds of 120 miles per hour and were installed by direct burial with the bottom 36" section below grade. These architectural enhancements cost over $7,000. We respectfully request a minor modification to the Boynton Landings site plan for these architectural enhancements to the Property. Please call me at 650- 7927 if you have any questions or need any additional information. Enclosures cc: Mr. Danny Ruda (w/o encI.) GREENBERG TRAGRIG HOFnu.:'i LIPOFF ROSE:'i & QUE:'iTEL, P.--\.. WPB;C"r-;INOF,~70759:5sx301' DOC5118:00'~08J:1.'O~8'IJox 20629 WEST PALM BEACH, FLORIDA 33416-0629 561-650- 7900 Fu 561-655-6222 iii SOLTII FLAGLER DRIVE SlilTE 300 E.\ST WEST PAUl BEACH, FLORIDA 33401 MIAMI NEW YORK WASHI:'iGTO:'i. D.C. PHILADELPHIA 5,\0 PAULO FORT L.\l!DERDALE WEST PAUl BEACH ORL.\:'iDO TALL.\!L\SSEE BOL\ RATO:'i CCE~iff(\;~ DEPARTMENT OF DEVELOPMENT Division of Planning and Zoning Building Planning & Zoning Engineering Occupational License Community Redevelopment June 1, 2000 David M. Layman Law Offices of Greenberg Traurig P.O. Box 20629 West Palm Beach, Florida 33416-0629 Re: Boynton Landings MMSP 00-033 Dear Mr. Layman: In response to your request for administrative review and approval of modifications proposed to the above-referenced, approved site plan, please be informed that the proposed change shown on the revised plan dated 5/19/00 are in violation of the City of Boynton Beach Land Development Regulations. The ten (10) "architectural accents" as described in your letter dated May 18, 2000 and shown in the photographs are defined as "banners" and as such are prohibited per Chapter 21, Signs, Section 3.D., a copy of which is attached for your information. Please be advised that the existing ten (10) banners are not permitted and must be removed from the site. Please contact me at (561) 742-6260 if you have additional questions. Sincerely, - "tL~i deau ca~~alav, AICP Senior Planner Cc: Michael W. Rumpf, Director of Planning and Zoning Scott Blasie, Code Compliance Administrator I:\SHRDA T A \PlanningISHAREOIWPlPROIECTS\BoynlOn LandingslSoynlOn Landings doc America's Gateway to tlte Gulfstream 100 East Boynton Beach Blvd.. P.O. Box 310 Boynton Beach. Florida 33425-0310 Phone: (561) 742-6260 FAX: (561) 742-6259 4v-R r' (}u- 0:.1 / ~lBfr"H" 4 Boynton Beach Code question prevents signage allowable under the provisions of this ordinance from adequately identifying the business or other activity located on such property. The board of zoning appeals may only grant a variance to: A. Allow a setback less than that required under the chapter; B. Allow the area and/or height of a sign to be increased by up to twenty-five (25) percent of the maximum allowable height or area; or C. Allow the number of signs to be increased over the maximum allowed by this code. No variances may be granted to signs expressly prohibited by this chapter. (Ord. No. 96-61, ~ 1, 1-21-97) Sec. 2. Exemptions. The permit requirements of this chapter shall not apply to the following signs, provided however, that said signs shall be subject to other provisions of this code: J:<) S' A. Real estate signs not exceeding five (5) square feet in area which advertise the sale, rental or lease of the premises upon which such signs are located. These signs must be set back ten (10) feet from the property line, meet the structural requirements and must not exceed four (4) feet in height. Only one (1) such sign is allowed per street frontage. B. A single residential yard sign, not exceeding three (3) square feet in area (Beware of Dog, Watch your Step, Name and Address, etc.). C. Window/door signs using less than twenty (20) percent of the total glass area facing in anyone direction. This area is not included in the total sign area allowed under this chapter. These signs are not permitted in residential zoning districts. D. Political signs. These signs must comply with Article III, Section 6.D of this Chapter. 1997 S-5 E. Flags. , " , F. Bulletin boards not over eight (8) square feet in area for public, charitable or religious institutions when the same are located on the premises of such institutions . G. Occupational signs denoting only the name and profession of an occupant in a commercial building, public institutional building or dwelling house and not exceeding two (2) square feet in area. H. Memorial signs or tablets, names of buildings and date of erection, when cut into any masonry surface or when constructed of bronze or other incombustible materials. 1. Traffic- or other governmental signs, legal notices, railroad ~rossing signs, danger signs and such temporary, emergency or non-advertising signs as may be approved by the city. J. Signs indicating the address and/or name of the residential occupants of the premises, not exceeding two (2) square feet in area. K. Vehicular signs. L. Bus shelter signs. Sec. 3. Prohibitions. The following signs and related equipment are prohibited in all districts: A. Any sign and/or sign structure which does not meet all the criteria set forth in this chapter. B. Animated/fluttering signs C. Balloons D. Banners (not including special civic event, recreational, expositional or temporary business identification signs) E. Bus bench signs F. Festoons . ( (~ EXHIBIT "H" s General Provisions jewelry and the like, but not used merchandise generally. No outside storage or display shall be permitted in connection with such uses. AP ARTl\fENT - A room or a suite of rooms occupied, or which is intended or designed to be occupied, as the home or residence of one (1) individual, family or household, for housekeeping purposes. APARTMENT, EFFlCIENCY - A dwelling unit consisting of one (1) room, other than a bathroom, and providing cooking facilities. APPLICANT - See "Developer." ARCADE - A permanent, roof-like structure open to the weather on one (1) or more sides, constructed of rigid materials, which is cantilevered from the building wall, attached to and supported by the exterior building wall or supported by freestanding columns or pillars. ARTERIAL ROAD OR STREET - A route providing service which is relatively continuous and of relatively high traffic volume, long average trip length, high operating speed, and high mobility importance. In addition, every United States numbered highway is an arterial road, and every street shown or described as arterial according to the current or most recent functional classificatlon contained in the City of Boynton Beach Comprehensive Plan, as adopted and amended, is an arterial. AUTO PARTS SALES (RETAIL) - Sale of auto pans from a commercial establishment for installation and use off-premises. AUTOMOBILE - An automobile or motorcycle, as defined by the rules of the Florida Department of Highway Safety and Motor Vehicles. . AUTOMOTIVE SERVICE STATION - The use of a building or other structure, on a lot or parcel of land which includes any retail sale of gasoline or other motor fuels. AWNING - A structure made of cloth or metal with a metal frame attached to a building, when the same 1997 S-5 is so erected as to permit its being raised t9 a position flat against the building when not in use. -~ BALLOON - A container made of non-rigid material filled with air or gas and designed to be tethered. BANNER - A sign having the characters, letters, illustrations or ornamentations applied to cloth, paper, film or fabric of any kind, with only such materials for a backing. Banner shall not include national, state, municipal, civic or church flags, awnings or canopies. BAR OR COCKTAIL LOUNGE - An establishment which serves or includes the serving of beer, wine or liquor to patrons other than in conjunction with the serving of meals. BICYCLE~PArn - Any road, path or way that is open to bkycle travel, which road, path or way is physically separated from motorized vehicular traffic by an open space or by a barrier and is located either within the highway right-of-way or within an independent right-of-way. BILLBOARD - A sign normally mounted on a building wall or freestanding structure with advertising copy which refers to something other than the name and primary character of the business on the premises or is located on a remote site from service or site referred to by the sign copy. BLOCK - A parcel of land surrounded by streets, waterways, railroad rights-of-way, parks or other public space. BOARDING A.l'lD ROOMING HOUSE - A building other than hotel or motel providing lodging and where meals are or are not served, for compensation. BOATEL - Yachtel. BRIDGE - A structure, including supports, erected over a depression or an obstruction, such as water or a highway or railway, and having a track or passage- way for carrying traffic as defined in chapter 316 or other moving loads. OCT-16-~~ 10:12 AM CODE COMPLIANCE - - ~- ... . CITY OF BOYNTON BEACH - " ~ " ~ . .... 100 !. 8cIrriIan SftcIIllllUI.wwd' ".^, ' :....:.. .', .' ~Oll:II/lIftCt . "'...-.n....I'l3:W3S :.....,.,."..., ',- Q eo.ny Code ' (56t)375-f120, ~. 08 00364 .. FLORIDA UNlFORMCOOE CITATIoN. . . ,:, ,.. ~ ~ ... III ,.,,.... ___...."....... as '*- tIIIIw "'" la' =;":,10 c<16~:,{,o"J:O'+~I::~:; ~ tJi .... . . a. . _~ . R rr";,,'Yo~,""Lt;;"cI'~cJ";!.1; J"/;",~~,;,.:I ~ ~/ - .,.. ,.'" .,. A/ {' (")/1/:'f':~5' :J'90~J;4 !:;r; ,,~~ ~ '7 ... ZIp B6,";-7"'o" ~~"cJ;' ;n~::::J:3(i".J..S:~ r"'. , ..8~ "1;; r~ c" 0" c:' n '~' .r:r ~',!~'t;i~'; I::~ ~ '" -. .... '. I . . .}i::. ........_ .111 ........ .~. '~~':lr~~::/r~Y.,rr _. _ ,"". ""J~~':i';&i. 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'llIIt .',.':. ,Q All f. / / ~ c('.:) C. /',-...."'.0 .. -::'" ;J / . - -- /" - (" ~:'/G 1111.. CIllw (",,-,.;, './ t;. '/(/ ;;" I ~1_ClIIoo I'IUDW/_, .~I~~ ,ILI&ICIIot'.~ _. EXH'lBIT'IJ"., 5617426838 P.€'2 -.. ~-,. . ,~,!"~'~'''':''r.r;,'~-:~~:''';"~~,~~., " '.'. ~" ;:CITY'OF sOYNrol.iSEACH ..~.~ ;:~-~, .. -4',-4'-:f..; ;~':. -,':iOoEIIIlalliie..a,~ ,~ ~'..'. ,; '!:'r~. ~~'::OR~:u:;;:t:t:~el1i 1llI.....,...cdall N".~~~.~~~ !~~_~... tlItc 'l~'-;; .~~. '~V~'~{I'~-:2'1'; w. 1~o<?~ ~'2'r~ " ,B:;/j/i~)i-~'- ~i c... ,,~T~~/kiiJ~cl . . ... 1...,- ..... ..... . 0,1 " ....~...\.'''' .. . -. :>~';;~t:;($~:;.:;':~~ [. .A/CV'';~'~':e~:;;:: of' /),,~;;. :r~r~;~t~~'~~ :. ..~-.,-~~~ :4. I I. ,,'~.: - 1':\....... CIIuIlIcdcIn I." ....~.;:~.. ~:''':', . ;,': -.. y- '.;~~_: ~..";.:,.:" '3~:::7'f..:.~ ......paIII....t..,.piuI.c. ;;'. ' ...L- V !i!"""T..~... .~..lt.,.i1'''I'~'.J ~2 0<. ~.!: '..NOTa: T1liI............. plftUIIIt'ie-.-. 1IU'l,,..,....... ........ IIIli( ; . . ,..,..~..... iIfI1cliIft. ToIw....-n1lMlM daII_--........... 'III., ," '--w.... ....... tIId __1lIII cllIIIoII '-. -. III iii_ Ill.. 2Illl.... ' ;'. ~ Pf'D"ldId 5.m._. 71SAlG 1'laddII........... PlY ltIe........ cMI......., OfnqlMat , . """Iroft'lll'- CIIIlt "'II'- c.ut .....10 .,.1IIeII CIIlIlIlIIIIIt. .....,.. _ 10_ ;, ..'-'CllIlIOll, -......., '-..... "J'ClllIIlt Ill...,.. 0I~..... i* laIlIcaIln i _0. .. > ";'":: 'Sl .., ~:Y: :."'''' ",...;,.j '. :' ..: ,,' -::.;:;.: "; ~.'. ..~;., ,,":- ~'- ..;'. ", ~J......~(<j,:Y""(e~. ,7 ~",:,.:;f:~ ~:.>.;. .~.,~'~:~.;.:. . "Z'" --- /;, . ~ ~ .... ,,','" - ''l.'', .' DATVtWOFISSlJANCE ~: ~A.- C~' .27rf '- ,. .',.' . ........,QIIar, Ul.. ,.,. ,:.~;':';;.' ,;;'" 0 4JI /,/ -L /"" J' ~S-'.'mw ;.f!.t....T.H7 { ,cN? ....: _. ..' ~tY.t. (~.~~~f'c-r- '",/("':,__ c..v::. }""':. .,. '" CIIIeoo Mlm/Cllrft.. Y!U.OWJ...... .~~~_.~.i-- ~ " .~I~~.,~~~CIIrft~_. .,' c- o~tt~~t~D .. 'T T " If ." 1; ",. .. or L A oJ' r~~~~'o G. EXHIBIT "J" r' D.l'..~ M 12ynur. So 1/650. 7~~(J e..u~d i:J.YIU'::.la~(.~:J.lw "':lo,uh J1Jn~ 9, 2000 VIA TF.LF.FAX - 742-6259 Lusi.a Galav, AIC? Sc:nior Plannt:r Cit)' of Boynton Beach D~pa.'1:mem of Developmem Di visivn of Plan.'11ng a.'1d Zonmg 100 East Boymor. Beach Boukvard Boynton Bt:ach, FL 3342:5 Reo: Boynron Landing~ MMSP 00-033 Dea: Ms. Galav: 1 received your lener clJocc::ming BoynIon Landmgs Also ~tIachcd IS 4 City of Boymon Bt:ach Code Citallon whIch was i53ued June 6, 2000, just a day or rwo after I recen'.ed'.yOl..lT h:rt~r in the mail. . lam sure it is. the: plL.'"Pose of your Code to prohibit obnoxious, ugly ba.'11lcrs wnh words like ;'Rent Me" on them, not the very attractive stanchions located at BoynTOn LandLng, wluch include cloth decorations. . Your Code specifically excludes from the definition of b.snners . "expositional" signs. .The word "exposition" is detined in the diCTionary as something designc:d 10 co.nvey information. The cLoth anached to the stanchions at Boynton Lancing include the: words "Boynton Landing", specifically conveying information to the public. These' architectural accents are quite attractIve if you will take the time fO see The:n. r do not believe that th~)' are prohibired by your Code. they are attractive a.'1d I would rcGuc::st Uwl YOll recor:sider. SinciJ Iii ~ 1J;f. DaVid M. L~)in::.m DML/lm cc: Michael Rumpf (via telefax.) James A. Cherof. Esq. (via re!eiax..).I:l<C .!J<HK...., P.A P.ll a",. 2oo~~ ~t,T PAUl 5rAe... fLL,".".. :i'Hlo-lj(,~'J :'(.1.650. :-"'00 FA,,;6 L .65 5-6~t:! ...... ..114" ,'ulll ;';"' So...,... k.....CL.~ OK'" ;'oITt: 100 EA,.. WIUT P,L" IU:,41:h, F"JIII!>" 33-1UL "1..... Nt.... 'I:C,K~ 1\'....,"..":)...,, O.i" ^,"~..."'T\ PllIt,DEL1-"" L'hl"" C"""t:/I S^o j>,,~o f'Ollr L."~IU;Xll.... t; ~t" P,...)I Bu.... OllL...SDV T....~AH,.~H.. 8", ~ R..T,,:" TUL-17---":lc:.llo:JIU 1:::';l.1~ r-KUI'I l",.Ct:.t::t-::I-1lU v.r!:J ,.,.- --. .. . - .- - "'--r .- .', cnv OF BOYtt. - lEACH g=~al 1.:':r..t'~oa 00371 I FLORIDA UNFORII COPE ClTATJON 1lIiI .Il.'~ r............-...-,-......... --- '*- II ~lD7'1 /7..l:~;~1~.~~1 Goy~}-ro,=. I OM ~/1y S I! - ~ 30 9 A) COn9/'riS~ U C. I e:~nl ~~Cl-1 ?f ~ ! BOflner. Crr~ No T 1 \ ,ei&~}e{/ ~' _-ch~ r;~t~~ I rh -..2J A~7 _lL s~c :3 0 ..f'"i- l C;iiii"--. ~ prv-lt ~~r ~/vl&"-. Df,rJr~V?,.,,-t,y I l ... . t .............1t~,..CGe i JIIIlIIC5::( JP <.> U I JII01a: _...... ,=~1 ..... all......... ""........,... wlIICIl I .'............ ""...........................".. ' ..... ............... .,..tIII ..... . AI - _!III 2rwI __ II I ",........"...."..-~...........,.,""'.........~......, ........ : ........lII'OIIIlfl.. c::.I...............,.........,."I'Il.. --- I ...cIIIIII.~,.~..............,.*---.\l:I... ........ 1 I MSQIIEGFISI5VA.ue*. I 0- I i 1 I &\I&tc.ohQllcte t J:t/ '~ ~----. "':77 -7'"" -,'" . 1- C~A~ /' ~~~ ......... (7)uriL,~,~ c..~, '.~ 27?'l MII_ / .- I ('rLJ,. ~~Al jj;~~.~ f".- '.GlMr / t _'~'" ~~ ,.10Idtl1. ~........... -..,-.---'..- '.-' ...-."~" '--" .......... u.... ,'-' wr-.v .i. ~ .......-t. i :Mt , r.v.:J.c.. r- EXHIBIT ilK" rnTI4J p. ;r:' ~@timlf1L" DEPARTMENT OF DEVELOPMENT Division of Planning and Zoning Building Planning & Zoning Engineering Occupational License Community Redevelopment June 20, 2000 Mr. David Layman Law Offices of Greenburg Traurig P.O. Box 20629 West Palm Beach, Florida 33416 Subject: Boynton Landings MMSP 00-033 Dear Mr. Layman: I have re-examined this situation that involves ten (10) banners hung on individual poles at the entrance to the above-referenced project. I understand that no attempt was made to obtain permission from the city prior to erecting the poles and banners, and that you are now requesting that the new elements be considered as some type of signage rather than simply a decorative banner. Since the new features indicate the name of the subject apartment complex, I must agree that they represent a type of sign. Furthermore, in my opinion, the features have an attractive appearance. However, the city's regulations clearly prohibit banners as signage, and the definition for a "banner" matches the features that your client has displayed at their entrance. I also must disagree with your argument that the city's regulations are intended to address obnoxious banners or pennants rather than pure signs, as the definition of a banner refers to them as "signs" which are objects used to promote a business. Notwithstanding the definition of a banner and the prohibition of same, I must also indicate that given the fact that the new features are "signs" (as they advertise a place of business), they represent an unapproved modification to the site plan for the subject project, they represent a significant addition to the maximum sign area for the project which has not been reviewed, and are subject to the basic sign regulations such as setbacks. Furthermore, based on the argument that Planned Unit Developments (PUDs) are not subject to all regulations applicable to properties within conventional zoning districts, but may be reviewed on a case-by-case basis, you may think that the subject banners are not subject to the same America's Gateway to tlte Gulfstream 100 EOIst Boynton Beach Blvd.. P.O. Box 310 Boynton Beach. Florida 33425-0310 Phone: (561) 375-6260 FAX: (561) 375-6259 ".,-~ ( . ( EXHIBIT "L" prohibitions applicable to other zoning districts. Regardless of this position, I must indicate that staff will exercise extreme caution when reviewing a site plan modification request which represents a deviation from conventional code (and our responses to prior similar inquici.es), given the possible precedence that may be established which could unintentionally justify the approval of subsequent banners, which may not be as visually friendly as your clients features. With that explanation, and considering the investment made by your client, I suggest that you relocate the banners to the interior of your project where they would not be construed as project signage, but rather used as site decorations or enhancements for the lakefront, recreation area or sales office. If you still desire to pursue the approval of the signs where they are currently located, you have the option of submitting an application for Code Review which is a request to amend the city's regulations. If you desire the latter, please contact this office to set up a pre- application meeting with staff. Sincerely, "-J...t.. ",) .-::> /~'-<.~ Michael W. Rumpf MWRlnl Cc: Nicholas Igwe, Assistant City Attorney J:\SHRDA T AIPlanning\sHAREDIWP\PROJECTSlBoynton LandingsIL.ym.n 6-10-00.doc David M. Layman, 561/650-7990 r~ ~~[[~~[~~ ATTOR:'IEYS AT L-tW r~~~~I~ rr -J-;:1'7 r c-- C/o-uut EXHIBIT "M" ~ e-mail: laymand@gtlaw.com June 29, 2000 VIA FEDEX Mr. Michael W. Rumpf Planning and Zoning Director 100 East Boynton Beach Boulevard P.O. Box 310 Boynton Beach, Florida 33425 Re: Request for Code Review and Appeal of June 20. 2000 Determination Dear Mr. Rumpf: As you know, this firm represents CSC Boynton Landing, Ltd., the owner of the Boynton Landings Apartments (the "Property"). This letter serves as ari,application for Code Review and an appeal of the determination made in your June 20, 2000 letter regarding the signs located at the Property. We respectfully appeal the determination made in your June 20, 2000 letter on the same grounds originally set forth in our original letter to you requesting a minor modification to the site plan for the Property. Enclosed please find a check for 5200.00 for the appeal fee. We desire to pursue the approval of the signs where they are currently located and, accordingly, we also request a Code Review. Pursuant to Chapter 1, Article VII, Section 1. B. of the Boynton Beach Code, kindly forward our appeal with the documentation we previously provided you with (i.e., we had previously provided you with (4) copies of the Boynton Landings survey and photographs of the signs) to the appeal board for placement on the board's next available agenda. Please call me at 650-7927 to set up a pre-application Code Review meeting with your staff. Enclosure cc: Mr. Danny Ruda (w/o encl.) WPB/CANr.-IOF/2707S9ISsx3011.00C'6129/00i20821.0 13800 GREE:'IBERG TRAIJRIG. P.A. P.O. Box :!0629 WEST P.\DI BEACH. FLORIDA 33416-0629 561-650-7900 FAX 561-655-6:!22 www.gtlaw.com 777 SOUTH FLAGLER DRIVE SUITE 300 EAST WEST PALM BEACH, FLORIDA 33401 MIAMI NEW YORK WASIIINGTO:'l. D.C. ATU:oiTA PHILADELPH[A TYSONS CORNER SAO P,\!:LO FORT LAUDERDALE WEST PAL.\{ BEACH ORLA:'/DO T\LUHASSEE BOCA R.\TO:'l David M. Layman. 561/650-7990 o~ff~~f~o ,\TTORNEYS AT LAW r~~~~lo EXHIBIT "N" e-mail: laymand@gtlaw..::om August 2, 2000 VIA FEDEX .- 1m R (p:l ~-IT-';, \:fl ~ - f-" D 15 ~ - -.-- , \ ~~3", · - p}tm~'li:EL -1 _: Mr. Michael W. Rumpf Planning and Zoning Director 100 East Boynton Beach Boulevard P.O. Box 310 Boynton Beach, Florida 33425 Re: Bovnton Landin2s: Appeal Dear Mr. Rumpf: Thank you for taking the time to meet with us this morning. As you know, this firm represents the owner of the Boynton Landings Apartments (the "Property") and we have a pending application for Code Review and an appeal of the determination made in your June 20, 2000 letter regarding the signs located at the Property. We were shocked that you stated that our appeal had been denied because it was deemed to be untimely and were therefore unprepared to discuss this issue at this meeting. As we mentioned during the meeting, we had filed the appeal, paid the $200 appeal fee, inquired in writing as to the status of the appeal (please see my July 18, 2000 letter) and therefore reasonably thought that the appeal had been processed as the check was cashed and we had not heard anything to the contrary until this morning's meeting. As you know, Chapter 1, Article VII, Appeals, of the City's Code provides in pertinent part that: "B. FILING. Appeals shall be filed within fifteen (15) calendar days after rendition of the order, requirement, decision, or determination with the official from the whom the appeal is taken specifying the grounds for the appeal. . . ."[emphasis added] Based upon our review of Chapter 1, Article VII, Appeals, of the City's Code, we believe that your statement today that the appeal was not timely filed is incorrect. Specifically, the appeal was an appeal of the decisions made in your June 20,2000 letter. The appeal was filed on June 29, 2000, well within the 15 day appeal period. Thus, we respectfully request that this appeal be processed. In the event that your decision regarding the appeal is not changed, please provide us with the decision in writing so that we may request an appeal of that decision as well. GREENBERG TRAURIG, P.A. P.O. Box 20629 WEST PALM BEACH, FLORIDA 33416-0629 561-650-7900 FAX 561-655-6222 www.gtlaw.com 777 SOUTH FLAGLER DRIVE SUITE 300 EAST WEST PUM BEACH, FLORIDA 33401 MIAMI NEW YORK WASHINGTO'i. D.C. ATLA:>ITA PHILADELPHL\ Tyso'lS COR:>IER CHICAGO S..\U PAULO FORT LAL'DERDALE WEST PALM BEACH ORLA:'/OO TALLAHASSEE BOCA R,\TOI'i EXHIBIT "N" Mr. Michael W. Rumpf August 2, 2000 Page 2 Please call me at 650-7990 if you have any questions or need any additional information. cc: James A. Cherof, Esq. WPBiCAN1NOF!2707~91~sx30 1'.000'8102100120821.013800 The City of Boynton Beach EXHIBIT "0" 100 E. Boynton Beach Boulevard P.O. Box 310 Boynton Beach, Florida 33425-0310 Office of the City Attorney . (561) 742-6050 FAX: (561) 742-6054 August 7, 2000 David M. Layman, Esquire ~ Law Offices of Greenberg Tral1ig P.O. Box 20629 West Palm Beach, Florida 33416-0629 .... j -j~-} ;} ('~ . I :,., J ,"--.......-- '''_._ f ,( I ,1 i i i Ir i' " I ,,!_.; ~ .I" .. j J .; Re: Boynton Landings Appeal Dear Mr. Layman: This is in response to your letter of August 2, 2000 to Mike Rumpf, Director of Planning and Zoning, requesting that your appeal of an administrative decision denying your request for modification of approved site plan in the above referenced development be processed. Please consider the following: On May 18, 2000, you sent a letter to the City asking for a minor modification of approved site plan in the above referenced development. On June 1, 2000, the City officially denied the above request through a letter to you. Further, the letter advised that the proposed modification to permit banners on the premises is prohibited under the City Code. On June 9, 2000 you sent a letter to the City, asking the City to "reconsider" its administrative decision denying your request for minor modification. On June 20, 2000, the City sent you a letter denying your request for "reconsiderationll. That letter also advised you of your option to submit an application for code review. On June 29, 2000, you sent a letter appealing the June 20, 2000 letter denying your request for "reconsideration'l and also asked for code review. The City's Land Development Regulation (LOR) permits an aggrieved party to appeal an administrative decision of a city official. Under LOR, Chapter 1, Article VII (B), an appeal "shall be filed within 15 calendar days after rendition of the order, requirement, decision, or determination with the official from whom the appeal is takenll. Nothing in the City Code authorizes an aggrieved party to seek a "reconsiderationll of a decision of city official. Under Florida Rules of Appellate ''An Equal Opportunity/Affirmative Action/ADA Employer" EXHIBIT "0" Procedure, a motion for reconsideration of a decision does not toll the tim~ period for filing an appeal. In this instance, your appeal clock started running from June 1, 2000, when the City officially notified you of denial of your request for modification. As stated earlier, nothing in the Code allows for "reconsideration" of an administrative decision and thus the appeal clock could not have commenced from June .29, 2000 when you asked the City to "reconsider" its administrative decision. Therefore, it is clear that your letter of June 29, 2000, seeking to appeal the administrative decision was untimely as that letter was received more than 15 days of the June 1, 2000 decision denying your proposed modification. Please be advised that the City does not customarily hold checks and that checks are processed and cashed as they are received. Therefore, the City is currently processing the return of your $200 appeal fee. Further, staff is ready to assist you in moving forward with your request for a code review whenever you are ready. - Should you have any additional questions or comments on this matter, please contact me directly. Very truly yours, ~\ &t-L, 4~, ~ ,~ (-, L.-) '1l,L/~ Nicholas 1. Igwe, J Assistant City Attorney NII/mlr Cc: James Cherof, City Attorney Mike Rumpf, Director of Planning and Zoning Lusia Galav, Planning Coordinator Ca/dept/planning/boyntonlanding/Layman Ltr D~[[~~[~D ATTORIIEYS AT LAW l~~~~ID EXHIBIT lip" TIMOTHY w, SCHULZ WEST PALM BEACH OFFICE DIRECT DIAL: (561) 650-7971 Email;schulzt@gtlaw.com August 21,2000 Bv facsimile COpy 742-6054 and U.S. Mail -- 01,'-;' - , I . '~'-f1i'JI";,'t':' . --.......; -"'__ :.'1""''''.''''''''1' --~')r:"T' ~._---.- Nicholas 1. Igwe, Esq. Assistant City Attorney City of Boynton Beach 100 E. Boynton Beach Blvd. Post Office Box 310 Boynton Beach, Florida 33425-0310 RE: Boynton Landings Appeal Dear Mr. Igwe: I have reviewed your August 7, 2000, letter to David Layman of this office regarding the City's opinion that the appeal filed by Mr. Layman was untimely. I disagree with your assessment and would ask that the City reconsider its position and submit our appeal to the City Commission, the appropriate body to hear such an appeal. After reviewing this letter, if it is still the City's position that the appeal was not timely filed, and that the City will take no further action on this appeal, please contact me so that I may move this issue to the next appellate level. On May 18, 2000, Mr. Layman sent a letter to the City of Boynton Beach requesting a minor modification of the approved site plan for Boynton Landings. The City denied this request on June 1, 2000. On June 9, 2000, Mr. Layman sent another letter to the City requesting reconsideration of its June 1 st decision. On June 20, 2000, Michael W. Rumpf, Director of Planning and Zoning for the City of Boynton Beach, responded to Mr. Layman's reconsideration request. It was Mr. Rumpfs decision on June 20, 2000 that Boynton Landings appealed on June 29, 2000. On August 2, 2000, Mr. Rumpf and Ms. Lusia Galav, Senior Planner, met with Mr. Layman and Felix Canino of our office. It was at that meeting that Mr. Rumpf and Ms. Galav informed Mr. Layman and Mr. Canino of the City Attorney's decision that the filing of the appeal was untimely. In a letter to Mr. Layman dated August 7, 2000, you again stated the City's position that the "appeal clock started running on June 1, 2000, when the City officially notified you of denial of your request for modification." Based upon that reasoning, it is your position that our appeal was not timely filed. We respectfully disagree with your position. GREENBERG TRAURIG, P.A. P.O. Box 20629 WEST PAUl BEACH, FLORIDA 33416-0629 561-650-.900 FAX 561-655-6222 www.gtlaw.com 7.7 SOUTH FUGLER DRIVE SUITE 300 EAST WEST PAUl BEACH, FLORIDA 33401 \:.11 NEW YORK WASHINGTON, D.C. ATLANT.A PHILADELPHIA TYSONS COR:'iER CHICAGO BOSTOi'i PHOENIX WILMINGTON Los A:'iGELES DENVEIl 5,\0 PAULO FORT LAUDERDALE BOCA RATON WEST P.AUI BEACH ORUNDO TALLAHASSEE -';~ . EXHIBIT "P" Nicholas 1. Igwe, Esq. Assistant City Attorney City of Boynton Beach August 21, 2000 Page 2 Chapter I, Article VII, Section 1.B. permits an aggrieved party to appeal a decision of an administrative official by filing the appeal "within fifteen 15 calendar days after rendition of the order, requirement, decision or determination with the official from whom the appeal is taken.. ." A common sense interpretation of this provision reveals that our appeal was timely filed. We are seeking to appeal a decision of an administrative official (Michael Rumpf) and have filed such an appeal within 15 days of his decision made on June 20, 2000. We notified the City of our decision to appeal on June 29, 2000. Article VII, Section 1 itself is entitled, "Appeals from decisions of an administrative officiaL" The City Code does not specify at what level on the administrative ladder a party must appeal from. It simply provides the right to appeal a decision by an "administrative official." Literally, what Article VII, Section I.B. provides for, in this case, is an appeal of a decision by an administrative official. That is precisely what we are doing, appealing from the June 20th administrative decision by Mr. Rumpf. You also point out in your August ih letter that nothing in the City Code authorizes an aggrieved party to seek a "reconsideration" of a decision of a city official. And you note that under the Florida Rules of Appellate Procedure, a motion for re- consideration of a decision does not toll the time period for filing an appeal. First, if it is your position that there is no procedure for seeking reconsideration of a city official's decision, then the Rules of Appellate Procedure do not apply. Second, if the Rules of Appellate Procedure do apply, and I believe that they do, 1 would direct you to Rule 9.020(h) concerning rendition of an order. An order is rendered when a signed written order is filed with the clerk of the lower tribunal. Rule 9.020(f) defines an "order" as a decision, order, judgment, decree or rule of a lower tribunal. And, subsection (b) of Rule 9.020 defines "clerk" as the person or official specifically designated as such or, if no person is so designated, the official or agent who most closely resembles a clerk in the functions performed. Therefore, assuming your position is correct for the moment, and we disagree that it is, before an appellate expiration date can be ascertained, it must first be determined when the June 1 st decision was actually filed with the Clerk or person so designated. Despite your contention that no procedure for reconsideration of administrative decisions exists, a review of the June 20, 2000 letter from Mr. Rumpf to Mr. Layman shows a complete reconsideration or "re-examination" of Ms. Galav's June 1st decision. Mr. Rumpf begins his June 20th letter by stating, "I have re-examined this situation that involved 10 banners.. ."(emphasis added). That is precisely the issue that Ms. Galav was dealing with. And a Thesaurus gives the meaning of the term re-examined, and a synonym for it, as GREF.'RERC TR.\URIG -1 ~ \. .-t ... .' EXHIBIT "P" Nicholas I. Igwe, Esq. Assistant City Attorney City of Boynton Beach August 21, 2000 Page 3 reconsideration. Whatever the semantics, Mr. Rumpf clearly reconsidered Ms. Galav's June 1 SI decision. Mr. Rumpf, the Director of the City's Division of Planning and Zoning and Ms. Galav's superior, did not simply reiterate what Ms. Galav stated in her June 1 st letter. Rather, Mr. Rumpf took an entirely new look at the applicable City regulations and all documents submitted in our application for a minor modification. He determined that the "banners" represent a sign, an issue Ms. Galav did not address. He conducted an analysis of the applicable city regulations and made findings as to why these "signs" were not permitted by city regulations, something else Ms. Galav did not do. He went further and found that the "signs" represent an "unapproved modification to the site plan for the subject property," a "si~ificant addition to the maximum sign area for the project that has not been reviewed" and that these "signs" are "subject to the basic sign regulations such as setbacks," all new issues and ones not addressed by Ms. Galav. It is, therefore, very clear that Mr. Rumpf undertook a complete reconsideration of Ms. Galav's June 1 st decision. Even if City regulations do not spell out any procedure for obtaining reconsideration, they do not prohibit such actions by City officials. And it is our position that once a Division Director reconsiders or re-examines an earlier decision by a subordinate city official, that Division Director's reconsidered decision is subject to appeal within 15 days. We also take issue with the manner in which this appeal was handled and, as a result, believe the City of Boynton Beach has violated our client's right to due process. Chapter I, Article VII, Section I.B. requires that within 15 days of a decision, the appeal shall be filed with the official from whom the appeal is taken. The administrative official is to then prepare the record and forward the record and appeal to the appropriate appeal board for placement on the board's next available agenda. Subsection D.2. of Article VII provides that the "City Commission will hear and decide appeals of administrative decisions or determinations in the enforcement or administration of major/minor site plans. And subsection 4 of Article VII grants an aggrieved party the right to appeal a decision of the City Commission to the Circuit Court. In this instance, our appeal and accompanying record was never forwarded to the City Commission, in violation of Chapter I, Article VII, Section I.B. Additionally, we have never even received a written response from the City regarding our appeal. Moreover, the City Commission is the appropriate body, sitting in its appellate capacity, to have determined that our appeal was untimely filed, not the City Attorney's Office. The City Commission could have certainly asked for advice from your office, but a written Commission decision should have been issued regarding the timeliness of our appeal. From that Order we could have appealed to the Circuit Court. As it now stands, we have no written decision to appeal as the proper appellate procedures were not followed by the City of Boynton Beach. GnEENBF:RG Tn,.\lJRIG -,' ~.-.. ,.. , ..- EXHIBIT "P" Nicholas 1. Igwe, Esq. Assistant City Attorney City of Boynton Beach August 21, 2000 Page 4 I recommend the following, that the City of Boynton Beach treat our appeal as timely filed, forward our appeal to the City Commission and permit the City Commission, sitting in its appellate capacity to determine the issues on the merits. If not, we will be forced to proceed with a Writ of Certiorari to the Circuit Court and will seek all available relief allowable as a result of the City's failure to properly follow its appellate procedures and its violation of our client's right to due process. - Very truly yours, ~W. c{j~ Timothy W. SCh.{[ TWS/dj cc: Richard Schlesinger Daniel Ruda James Cherof, Esq. ../ Michael W. Rumpf Lusia Galav ISCHULZ1\306186vOl\6K9601 !.DOC\8/2I/00 GREE:\BF.RG TRAURIG The Ci-ry of Boynton Beach EXHIBIT "Q" 1 00 E. Boynton Beach Boulevard P.O. Bo%310 Boynton Beach, Florida 33425-0310 Office of the City Attorney (561) 742-6050 FAX: (561) 742-6054 August 25, 2000 Timothy W. Schultz Greenberg, Traurig PO Box 20629 West Palm Beach, Florida 33416-0629 Re: Boynton Landings Appeal Dear Mr. Schultz: We have your letter of August 21, 2000 regarding Boynton Landings Appeal. The City will process your appeal. Please submit the application and the necessary filing fee to Mike Rumpf, Planning and Zoning Director. Thank you. Very truly yours, ~dLo-fj)~ Nicholas 1. Igwe, Assistant City Attorney NII/mlr J Cc: Mike Rumpf, Director of Development James A. Cheraf, City Attorney Lusia Galav, Senior Planner David Layman, Esquire . Imr~ @ fa w ~Iml : u~ ! AUG 2 8 '" -~ .. ; ) . ! - - Jl. l"~ DII"I'~-~~'-.--l ("L..l"\h.J.~JP~G :!i'.}D ZONll~G OEPT. ... --...,...... "An Equal Opportunity/Affirmative Action/ADA Employer" o~[[~~[~o ATTOR:'lErS AT LAW 1~~~~lo EXHIBIT "R" TII"lOTHY W, SCHULZ \\'FST p.\) \.1 BEACH OFFICE DIRECT DIAL: (561) 650-797 I Email: schulzt@gtlaw.com September 12, 2000 ---- ,; f~~i "--2.._ ! i.;: Bv facsimile copv 742-6054 and U.S. Mail Nicholas 1. Igwe, Esq. Assistant Ci ty Attorney City of Boynton Beach 100 E. Boynton Beach Blvd. Post Office Box 310 Boynton Beach, Florida 33425-0310 .-.-..-......- RE: Boynton Landings Appeal Dear Mr. Igwe: I have received and reviewed your letter dated August 25, 2000, written in response to our August 21, 2000, letter regarding the above cited appeal. After reading your letter, I was unsure as to the City's position on this matter. Your letter does state that the City will process our appeal. As a result, it is my understanding that all materials already sent to the city are to be forwarded to City Counsel, who will then place the matter on their agenda and sit in an appellate capacity. However, your letter also states that we should submit the application and the necessary filing fee to Mike Rumpf. I was unsure as to whether your letter was referring to an application and fee for the appeal or some other type of application. In order to avoid confusion, please accept this letter as our Notice of Appeal from the June 20, 2000, decision of Mike Rumpf, denying Boynton Landings' request for a minor modification of the approved site plan. Enclosed is our check in the amount $200.00 for the filing of this appeal. Please have all materials that we previously filed with the City as part of our request for minor modification of the approved site plan forwarded to the City Counsel, said materials constituting the appellate record. I would suggest that we discuss an appropriate date for City Counsel to hear arguments on this matter. GREE:'lBERG TRAURIG, P.A. P.O. Box 20629 WEST PAUl BEACH. FLORIDA 33416-0629 561-650-7900 FAX 561-655-6222 www.gtlaw.com 777 SOUTH FLAGLER DRIVE S[;ITE 300 EAST WEST PALM BEACH. FLORIDA 33401 :'>11 \MI NEW YORK WASHINGTO:'l. D.C. ATLANT.o\ PHILADELPHIA TYSO!\lS COR:'IER CHICAGO BOSTO:'l PHOE!\IIX WILMI!\IGTON Los A!\IGELES DENVER S,~o PAULO FORT LAUDERDALE BOCA RATON WEST P,UM BEACH ORLA:'iDO T,ULAHASSEE EXHIBIT "R" Nicholas 1. Igwe, Esq. Assistant City Attorney City of Boynton Beach September 12, 2000 Page 2 If my understanding of your letter is incorrect, please call me in order to discuss. c- Very truly yours, \~w.SY' Timothy W. Schulz TWS/dj Enclosure cc: Richard Schlesinger Daniel Ruda James Cherof, Esq. "/Michael W. Rumpf Lusia Galav \SCHULZl'J07947vOl\6LM301 !.DOC\9/5/00 GREENBERG TRAVRIG EXHIBIT" " Conditions of Approval Project name: BOYNTON LANDINGS APARTMENTS) File number: ADAP 00-001 DEPARTMENTS INCLUDE REJECT PUBLIC WORKS Comments: NONE UTILITIES Comments: NONE I FIRE NONE Comments: I POLICE Comments: NONE I ENGINEERING DIVISION Comments: NONE I BUILDING DIVISION Comments: NONE PARKS AND RECREATION Comments: NONE FORESTERJENVIRONMENTALIST Comments: NONE PLANNING AND ZONING Comments: NONE ADDITIONAL PLANNING AND DEVELOPMENT BOARD CONDITIONS Comments: 1. To be determined. ADDITIONAL CITY COMMISSION CONDITIONS 2. To be determined. J:ISHRDATAIPLANNINGISHAREDlWPIPROJECTSIBOYNTON LANDINGS ADAP 2000lCC 12-5-00 COND, OF APPROVAL.DOC DEVELOPMENT DEPARTMENT MEMORANDUM NO. 00-200 TO: City Commission /7 /;1c;.~ THROUGH: Michael Rumpf Planning and Zoning Director ~ FROM: Lusia Galav ~& Senior Plan~ DATE: October 12, 2000 SUBJECT: Boynton Landings Appeal (ADAP 00-001) Project Name: Boynton Landings Apartments Location: 2309 North Congress Avenue Owner: CSC Boynton Landings, Ltd. Agent: David M. Layman, Greenberg Traurig, P.A. Request: Notice of Appeal from the June 20, 2000, decision of the Planning and Zoning Director, denying Boynton Landings' request for a minor modification of the approved site plan. BACKGROUND Request for Minor Modification On May 19, 2000 the Planning and Zoning Department received a request for Minor Modification from David M. Laymen, agent for CSC Boynton Landings, Ltd. The Minor Modification application requested the addition of ten (10) "architectural enhancements" located in the front setback on either side of the entrance to the Boynton Landings Apartments (see Exhibit "B" Site Plan). The letter indicated that these architectural accents had already been placed on the site. Staff reviewed the application and conducted a site visit. The ten (10) "architectural features" as described by the applicant are "banners" as defined by the Land Development Regulations Chapter 1, Article II (see Exhibit "0"). Banners are prohibited per Chapter 21, Signs, Section 3. 0 (see Exhibit "E"). A letter denying the request was written and sent to Mr. Layman on June 1, 2000 by Lusia Galav, Senior Planner. Subsequent to receipt of the denial letter, Mr. Layman addressed a letter to Ms. Galav, indicating that a code citation was issued to his client CSC Boynton Landing, Inc. on June 6, 2000 (actually June 8, 2000) regarding the prohibition of permanent banners in the City of Boynton Beach. Mr. Layman also requested that the decision for denial of the Minor Modification be reconsidered. At this time, Ms. Galav involved Mr. Rumpf, the Planning and Zoning Director, in the matter. Mr. Rumpf issued a letter on June 20, 2000, reconfirming the denial of the requested Minor Modification. It is this letter from Mr. Rumpf that Mr. Layman is addressing his appeal. Request for Appeal The appeal procedure from a decision of an admini$trative official is setforth in Chapter 1, Article VII, Sec. 1 of the Land Development Regulations (see Exhibit "F "). Staff received the request for appeal on June 30, 2000. The request for appeal is dated June 29, 2000, which is nine (9) days after the date of Mr. Rumpfs letter but 28 days after the original letter of denial from Ms. Galav. Staff requested the City Attorney to review the validity of the appeal. Mr. Nicholas, Igwe, Assistant City Attorney researched the matter. A meeting was held with Mr. Laymen on August 2, 2000 to discuss the appeal. After this meeting, correspondence was exchanged between Mr. Layman and Mr. Igwe resulting in the decision to process the appeal. Mr. Igwe made the determination that the City Commission is the body to determine the timeliness of tile appeal. The chronology of correspondence regarding this ;T,,3tter is found in Exhibits "G" through "R" attached. CONCLUSIONS The following are the pertinent facts of this case regarding the denial of the Minor Modification. 1. A site plan cannot be modified to permit a use that is specifically prohibited in the Land Development Regulations. 2. Permanent Banners are specifically prohibited in Chapter 23 - Signs. 3. The code Compliance division issued three citations to the property owner in accordance with the banner prohibition as stated in the code. 4. The banners are currently located within the 40 foot front setback required and approved for the project and within the 20 foot utility easement along Congress Avenue. 5. The owner did not apply for or receive a building permit from the city to erect the banners on the site. RECOMMENDATION If the City Commission finds that the appeal as presented is valid and meets the requirements of Chapter 1, Article VII, Sec. 1 of the Land Development Regulations, then staff recommends the following: 1. Deny the appeal 2. Affirm the administrative decision to deny the minor modification request for the banners at Boynton Landings Apartments. In addition, staff would not support a code review to permit banners under any circumstance other than those exceptions currently permitted by the code. ADAP 001 MEMO LIST OF EXHIBITS BOYNTON LANDINGS - ADAP 00-001 A. Location Map B. Site Plan C. Photos of Banners D. Definition of "Banner" E. Chapter 21 Signs - Banners Prohibited F. Appeal Procedure G. Letter dated May 18, 2000 - Request for Minor Modifi.:ation H. Letter dated June 1, 2000 - Denial of the Minor Modification Request I. Code Citation No. 08-00364 dated 6-8-00 and No. 08-00111 dated 6-22-00 J. Letter dated June 9, 2000 - Request to Reconsider K. Code Citation No. 08-00371 dated 7-17-00 L. Letter dated June 20, 2000 - Reconfirmation of Denial M. Letter dated June 29, 2000 - Appeal of June 20, 2000 Letter of Denial N. Letter dated August 2,2000 - Request for Appeal O. Letter dated August 7,2000 - City Attorney Response P. Letter dated August 21,2000 - Response to 8-7-00 Letter a. Letter dated August 25, 2000 - Second Letter from City Attorney R. Letter dated September 12, 2000 - Clarification of Appeal Request 10/17/00