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HomeMy WebLinkAbout05-11-1999 Public Hearing - Woodhill CCAGENDA FOR SPECIAL COUNCIL MEETING SET FOR TUESDAY, MAY 11,1999,7:00 P.M. ORONO COUNCIL CHAMBERS, 2780 KELLEY PARKWAY, ORONO, MINNESOTA (*) Asterisk items are considered to be routine items to be enacted upon by one motion by the City Council under the Consent Item* on the agenda. Memos regarding each of the Agenda items are available in the Public Packet - located on the counter near the sign in sheet. ROLL CALL CONSENT AGENDA 1.Approve/Amend ZONING ADMINISTRATOR’S REPORT 2.#2484 Woodhill Countiy' Club, 200 Woodhill Road - Conditional Use Permit a.Presentation by Staff b.Council Questions of Staff c.Presentation by Applicants d.Council Questions of Applicant I e.Open Public Hearing i)Public Questions Public Comments f.Close Public Hearing g.Council Deliberation CITY ADMINISTRATOR'S REPORT Declaration of Excess/Surplus Property ADJOURNMENT We, the undersigned, residents of Orono, urge the Orono City Council to deny the application for a Conditional Use Permit filed by VVi'odhill Country Club, which seeks to open a driveway leading from the Country Club through a residential neighborhood. (This application is scheduled to be heard on May 11 at 7 p.m..) Woodhill Country Club is a private social club that sells alcohol. The club hosts its members as well as numerous invited guests attending social and sporting events. Opening this driveway will dramatically inci^ase traffic and increase traffic danger, on surrounding streets, particularly Woodhill Avenue, Orono Orc.hard Road and Watertown Road. It would change the guiet, residential nature of these surrounding streets and would set a dangerous precedent for the disposition of future, similar requests by developers and private clubs and businesses. PLEASE PROTECT OUR 5TRE6TS-FOR NOV>/ AND FOR THE FUTURE NAME ADDRESS /Z7^» A- (^lAxjyLo (^tAoAiC ^ Onf\td \oS Wc, the undersigned, residents of Orono, urge the Orono City Council to deny the application for a Conditional Use Permit filed by Woodhill Country Club, which seeks to open a driveway leading from the Country Club through o residential neighborhood. (This application is scheduled to be heard on May 11 at 7 p.m..) Woodhill Country Club is a private social club that sells alcohol. The club hosts its members as welt os numerous invited guests attending social and sporting events. Opening this driveway will dramatically increase traffic and increase traffic donger, on surrounding streets, particularly Woodhill Avenue, Orono Orchard Road and Watertown Road. It would change the quiet, residential nature of these surrounding streets and would set a dangerous precedent for the disposition of future, similar requests by developers and private clubs and businesses. PLEASE PROTECT OUR STREETS-FOR NOW AND FOR THE FUTURE NAME ADDRESS 1^^ qL Cl ( , ^4-^ « % William W. and Nadine McGuire 315 Woodhill Road Wayzata, Minnesota 55391 May 6.1999 Mr. Michael P. Gaffron Senior Planning Coordinator City of Orono 2750 Kelley Parkway P. O. Box 66 Crystal Bay, MN 55323 Re: Application #2484 Woodhill country Club Conditional Use Permit Dear Mr. Gaffron: We are the owners and full time residents of 315 Woodhill Road. We are not members of Woodhill Country Club or in any way related to a member of the Club, nor do we have financial interests witli the Club. Our property is one lot (to the south) of Woodhill Avenue. As such, we are familiar with existing traffic patterns in the area and the use of Woodhill Avenue. It is our firm belief that the use of Woodhill Avenue as proposed by the Woodhili Country Club will help rationalize traffic flow relative to highway 15 and provide positive safety gains. Furthermore, we believe that this can be done without significant detriment to our property and/or others that are adjacent to Woodhill Avenue. We therefore fully support the use of Woodhill Avenue as proposed by Woodhill Country Club, as well as full time use if so desired. Respectfully, William W. McGuire. M.D.Nadine M. McGuire j J 05^il/93 15:30 MO.St.2 P002 LINDQUIST & VENNUM p.l.l.p. 42C0 IDS CeNTER In Oen'/er ec . OUTH EiOmTh STREtr UNOQJIST VENNUM & C h RISTESSEN P I lp Mr -JEAPOUS. MuwESOTa 55402-2205 BQO 1 7th Street. SU»te 1500 '•'EL2LPHONE 012-37143211 OCNNieP. COICRAOO 00202-5441 FAX. 6l2-37l4i207 TelEPhon G: 30«7«900 ATTOi.N'JVS A I* LAW J^mes P. McCarthy (612)371-3238 jmccirthy@iindqu:$tCOm May II. 1999 The Honorable Mayor Gabriel Jabbour Members of the Orono City Council 2750 Kelley Parkway Orono, MN R£: No. 2484:Woodhill Country Club Application for Amendment to 1968 Conditional Use Permit Dear Mayor Jabbour and Mcmbcn; of the City Council: Because of the volume of materials on this issue. I want to put the remarks I will make at the May 11, 1999 Orono City Council meeting in writing in advance of the meeting. This letter and my remarks respond to the City Staff Report on Woodhill’s application, the City Engineer’s Report on County Road 15. the letter of Mr. Malkerson who represents four neighbors, together with a report of his tralTic engineer James Benshoff and four letters from neighbors. The volume of materials submitted requires an extended response. I. The City Engineer's County Road 15 Study Establishes the Need for the Woodhill Avenue Access The recently completed and adopted “Traffic Management Study” by the City’s engineering firm, Bonestro Rosene Anderlik & Associates, amply establishes the dangerous traffic safety problem faced by Woodhill Club members, Orono citizens, and the general public on Highway 15 in front of Woodhill Country Club and Orono Orchard Road. County Road 15 is the City of Orono’s most Important traffic safety problem. The average daily traffic in June 1998 was 22.2.tR automobiles and Hennepin County estimates volumes will increase to 27,000 near Orono Orchard Road in future years. The City Engineer concluded as follows: “The conclusion of this analysis, given the daily volumes along the roadway, is that the facility (County Road 151 is operating^in a. congested mode today.” (page 11) Doc« MI9S04\)I 05/11/99 15:30 HO.StZ F003 LINDQUIST & VENNUM p.ll.p The City Engineer observed that the County Road 15 corridor “is in need of additional capacity” but it is understood that it “will not be considered for widening to four lanes due to its character as a scenic parkway.” As to the Woodhill Road exit serving eleven residential homes and Woodhill Golf Course, the City Engineer found that “during peak traffic hours access tp/from these roadways can become quite hazardous in that [lack ot] gaps in the traffic along eSAH 15 make it difficult to exit these roadways.” The City Engineer concluded that; “Access to (Woodhill Country Club) would be vastly improved with... the provision of a connection from Orono Orchard Poad to the golf course and residential area.” (pages 17-18) Of the four altcm.atives discussed by the City Engineer, three require extensive condemnation of private homes and property by the city, consequent displacement of many families and harm to those not displaced, and face other environmental and traffic engineering difficulties. Ihe fourth alternative, reopening the century-old route along Woodhill Avenue, is immediate and witliout any cost to Uie city. Indeed, of all of the proposals discussed in the City Engineer’s report relating to the improvement of traffic conditions along County Road 15, the restoration of vehicular access from Woodhill Country Club to Woodhill Avenue is the easiest, fastest, and least expensive to implement. II. Staff Report Does Not Raise Any Material Objections to Restored Vehicle Access The planning department staff report prepared by Michael Gaffron identifies no problems with the application that cannot be easily solved in the implementation of the access. The stall report does not dispute thai Woodhill Avenue has the roadway capacity to carry the traffic from Woodhill Country Club. It concludes that all neighborhood impacts such as dust, noise, odors, lights, visual impacts, and security can be adequately addressed. Drainage is satisfactory. The staff would appear to prefer that the easterly 75 feet of V*'oodhill Avenue be paved in asphalt rather than its current gravel condition. The neighbors appear to want the road left gravel. Woodhill Country Club believes that the gravel surface is preferable, but would be willing to bear the cost of asphalt paving. The staff report identifies no traffic safety concerns. It concludes that the paving and width of the street is not “a limiting factor for the level of traffic currently proposed by Woodhill.” The city engineer has identified that a very shon portion of the 100-ycar old driveway on the Woodhill property has a t lightly steep grade. Although this has never presented Doc«in9k&1U 2 • 05'll/99 15:31 n0.8b2 P004 LINDQUIST & VENNUM p.u u.p. a problem, the grading is simply a matter of inches and can be changed if the City Council deems it necessary. Woodhill’s CUP amendment application is unusual in that it is one of the rare cases in which a property owner has come to the city and requested the imposition of new restrictions on the applicant ’s property. Under the club’s existing conditional use permit, which does not provide any “triggers” for review, the club has a right of access which has existed since its purchase of the property in 1915. The Club’s application requests that seven new restrictions be placed on the 1968 Conditional Use Permit that would permit further review by the City Council in addition to the review provided under the ordinance. To the extent that the staff report suggests that more than those seven trigger events be added to the Conditional Use Permit, Woodhill Country Club strenuously objects. Woodhill’s proposed new restrictions already place significant limitations on Woodhill’s use of Woodhill Avenue that do not currently exist. Additional review provisions are unworkable. No useful or reasonable purpose is served by revisiting this issue on a regular basis. III. Woodhill has a Property Right of Access CooHrmed by its 1968 CUP aod Reflected in its Special Assessment The Malkcrson and BcnshofTlcttcre, neighbors’ letters, and even the city staff report make a number of statements about the historical use and legal status of Woodhill Avenue and Woodhill Country' Club’s access which are simply incorrect. The misstatements are contradicted by the testimony and documents collected over the past year. While the pressing need faced by Woodhill Country Club and by the City of Orono is traffic safety, the context in which this application arises cannot ignore the history of Woodhill’s use of Woodhill Avenue and payment for the Woodhill Avenue upgrade in 1987-1989. Contrary to Mr. Malkcrson’s misstatement that “at some point, a narrow dirtway was established by the club which led to Woodhill Avenue that was rarely used through the years,” historical facts show the road was established before the property was purchased by the club and was used extensively by the club. When citywide zoning was originally adopted by Orono, Woodhill Avenue’s use was permitted, and decade after decade of aerial photos demonsu-ale that it was never a “narrow dirtway.” Even a cursory review of the testimony, maps, documents, and city records establishes the following: 1.Woodhill Avenue has been a public street for over 100 years. Woodhill Avenue was platted as a public street in 1887 and served as the only entrance to the Fcndcrson/Kccsling/Dunwoody farm (See Affidavit of Tony Feser). It was Ooc*lll9B04M 05/11/99 15:31 IHD.Sbi P0O5 LINDQUIST & VENNUM p.l.l.p. 2. 3. used for decades by club members, their guests, club employees, commercial and delivery trucks serving current Delaney and Larson residences at Orono Orchard Road, the two employee houses located just inside the Woodhill property line, and Woodhill Country Club (See Pillsbury Aflidavit, Morrison testimony, Searles testimony, and Feser Aflidavit). Woodhill Avenue is a public street up Co the Woodhill property line. The public street known as Woodhill Avenue extends not only to the private road to the Woodhill Ridge development, but up to the Woodhill property line. The easterly 200 feet of Woodhill Avenue, as actually constructed, curved south outside of the 1887 platted right of way. This portion of the road up to the Woodhill property line was dedicated to public use by the property’s prior owners (John Pillsbury and Alfred Crosby) and was used by the public (see Pillsbury Affidavit, McCarthy letters re; dedication). As such, the road was not only a dedicated public street, it was an “opened” public street. Woodhill Country Club’s property and driveway abutted this public street and was actually used every decade since the property was purchased in 1915. The common law dedication was confirmed by official planing in 1987. Contrary to the suggestions in letters of Mr. Malkerson and his clients, once there is a dedicated and opened public street that abuts a property and provides that property access, there is only one way for a municipality to “abandon” the public street and undo the access right of the abutting property owner-street vacation and condemnation. The growth of vegetation or intermittent use by the abutting property owner does not vacate a dedicated and opened public street. Only formal street vacation proceedings carried out pursuant to statute, together with formal condeir nation to compensate the property owner for its loss of access, can change the status of the public street. The 1968 CUP placed no restrictions on use of the Woodhill Avenue access and provided for no annual or other t)’pe of review. The Village of Orono initiated comprehensive zoning in 1967 and 1968. Country clubs were specifically made permitted conditional uses within residential districts and the city granted Woodhill such a permit. Review of Woodhill’s 1968 application and permit reveals that zoning was a much simpler process 30 years ago than it is today. The application is simpler, the drawings less exacting, the conditions general. Everyone agrees, as they must, that the permit issued in 1968 remains as legally binding upon the city and the land owners as permits issued under today’s Doctf IliggOdU • 05^1i.99 15:31 MU.B’bi’ PUU6 LINDQUIST &, VENNUM p.l.lp. more exacting procedures. The 1968 CUP places no limitations on use of the Woodhill Avenue access and creates no conditions of review other than those provided for in the ordinance, i.e. a petition of 75% of the surrounding neighbors or violation of the terms of the permit. It does not provide that if “X” number of houses are built within 300 or 500 feet of the property, the Conditional Use Permit or some aspect of it may be reviewed and reconsidered. The suggestion that WoodhiH ’s decadcs-long use of Woodhill Avenue was not encompassed in the 1968 CUP is frivolous. Use of Woodhill Avenue to access Woodhill Country Club was well-knoAvn to the City Council (See .Searles testimony). A hand-drawn map attached to the application showed two driveways, one to Woodhill Avenue and one to County Road 15. While Mr. Malkcrson, his clients, and even the city staff have speculated as to what the drawing meant to the city council, none of them were at the meeting in 1968. The fonnei mayor of Orono, Robert Searles, was at the meeting and, in fact, was the City Council member who moved to grant Woodhill ’s Conditional Use Permit. In sworn testimony, Mr. Searles has stated that (1) he was familiar with Woodhill Country Club’s access to Woodhill Avenue; (2) he had personally used the access for many years; (3) he was personally involved in deteimining the zones and districts in the 1968 comprehensive zoning ordinance; (4) he understood the CUP Application drawing to include the driveway connecting to Woodhill Avenue and the driveway connecting to County Road 15; and (5) neither he nor any other member of the Council ever expressed any desire to limit Woodhill Country Club’s access to Woodhill Avenue. Mr. Searles testified as follows: Question;“As you looked at this hand-drawn portion of the Application in 1968, what was your understanding then as to what the drawing of the driveway off to the left of the page indicated?” Answer (by Mr. Searles);“Well, it was just the driveway within Woodhill property that attaches to Woodhill Avenue and that was obvious to all of us. It wasn’t even a subject of discussion.” Question:“When you moved to approve the permit for Woodhill Country Club, was it your intent to change, in any way, the access to Woodhill Avenue?” DOC# 1 I iy804\l 05/11 ^'99 15:31 no.862 FOOT LINDQUIST & VENNUM P.L.L.P Answer: Question: Answer: Question; Answer: Question; Answer: “No. there was no intent to change the Woodhill Country Club, the use of its property or its accesses, and this is a specific memory.” “Can you describe for me, when you say the word “Woodhill Counuy Club’s access” as to what you mean? “Well, 1 mean the access to 15 and the access to Woodhill Avenue. Those aie the two accesses.” “Would it be accurate to slate that in the permit that you moved approval of. there is no limitation on Woodhill’s use of - Woodhill Country Club’s use of Woodhill Avenue?” “There were no limitations." mm* “In connection with the permits that you moved approval of, did you understand that Woodhill Country Club would have to seek City approval to either raise or lower a chain across either of its driveways?” “No, there is no such • I have no recollection of any such view by the City of Orono (See Searles deposition at pages 57-59). 4.The 1968 Conditional Use Permit has never lapsed. In his “lapse" argument, Mr. Malkerson simply ignores the language of the ordinance which provides: “Should a conditional use permit lapse or cease for a period of six months...." (emphasis added) Mr. Malkerson ignores that subdivision 8 of the ordinance applies only when a “permit” lapses. The 1968 conditional use permit was for use of the property as a golf course and country club. The permit has never lapsed and has never been Withdrawn by the City of Orono. Furthermore, the permitted "use,” i.e. golf course and country club, has never lapsed. Indeed, even Woodhill Country Club's utilization of its acce.ss to Woodhill Avenue has continued from 1968 to today. Throughout the ‘60’s and ’70's, the road was used by members, guests, and employees. After imposing restrictions on regular vehicular use, the access continued to be used throughout the 1 980's. George Jcnnrich, former grounds Dor* m9S04\) 05''ll/99 15:31 MO.882 POOS LINDQUIST & VENNUM p.ll.p. 5. 6. superintendent, made sure to drive cars up and down the road at le:»<t several limes a year in addition to moving maintenance equipment. (Jennnch deposition testimony.) The access was used to transport all Woodhill Country Club traffic on several occasions when County Road 15 was blocked. In the 1 990 ’s the road continued to be used for movement of equipment. Throughout the tunc period, the access was also used for bicycle traffic and pedestrian traffic. (Fredrickson deposition testimony) Once a property owner has a driveway that abuts a public street and once a conditional use permit is granted that does not restrict the use of such access, there is nothing in the Orono ordinance or CUP that says how many times a year the property owner has to ride a bike down a driveway, walk down a driveway, drive a car down a driveway, or drive a tractor down a driveway in order to maintain the right of access both as a property right and as a right under the Conditional Use Permit. Woodhill Country Club’s property was specially assessed for the paving of Woodhill Avenue. Not only does Woodhill have a property right of access and a right under the 1968 CUP, its property was assessed for the paving and improvement of Woodhill Avenue in 1987-1989. In their letter, the Storches suggest Woodhilfs special assessment was not because Woodhill's property abutted Woodhill Avenue and was bencfitted by the improvement. That suggestion is directly contradicted by the resolution adopted by (he Orono City Council. Special assessments are assessed against land, they are not a tax on individuals or entities. State law requires that a special assessment can only be assessed against land that is actually benefitted by the improvement. In assessing 59,464.70 against PID #2-117-23-12-0001, the Orono City Council Resolution No. 2682 made specific findings that the Woodhill Country Club parcel “abutted Woodhill Avenue ” and that the Woodhill property containing the west driveway was “benefitted by tb? proposed improvement in the amount of the assessment levied against it” 1988 maintenance building CUP did not void the 1968 CUP. In 1988, Woodhill Countiy Club obtained a permit in order to construct an accessory maintenance building. The permit related solely to the construction of that structure and did not void or limit the 1968 CUP to operate a golf course and country club. Woodhill agreed not to use the Woodhill Avenue access for movement of construction machinery during the construction. There is no suggestion that W’oodhill made any !>>:■ lll9t04M J 05.'11/9S 15:31 nO.St.2 POO?LINDQUIST & VENNUM p.l.l.p. statements concerning other types of future use of the Woodhill Avenue access. Woodhill did not use the Woodhill Avenue access for construction machinery and trucks then and does not propose to do so today. As set forth in the application, all commercial and delivery vehicles will be required to use the Woodhill Road entrance. 7. Woodfaiirs reservation of its rights to use Woodhill Avenue have been clear and have been acknowledged by the City of Orono. As quoted in Woodhill’s initial application. Woodhill wrote to the City of Orono, advising the City of its decision to limit regular vehicular traffic.on Woodhill Avenue. In doing so, the Club expressly reserved its right to reopen the access anytime it decided to do so. (Morrison letter, dated June 23, 1980) Seven years after having sent that letter, the city administrator wrote a memo to the city council stating that, indeed, Woodhill could open the road at any time it elected to do so. (Bemhardson memo, dated October 6, 1987). IV. WoodhiU's Application is Consistent with the City of Orono's Comprehensive Plan 1. Woodhill is a recreational property, not a commercial property. No one has questioned that the existence of Woodhill Country Club is included in and consistent with the City of Orono ’s Community Management Plan (“CMP"). In 1968, no one suggested that Woodhill Country Club was in any way inconsistent with the then-newly conceived zoning districting plan (Scarlcs Deposition testimony). The subsequently adopted CMP also embraces Woodhill Country Club’s use of its property as consistent with and part of the overall city plan. Contrary to Mr. Malkcrson’s reference to Woodhill Country Club and its traffic as “commercial" or "business,” the CMP does not categonze Woodhill as either "commerciar or “business.” Table 2 of the CMP lists five types of land use: (i) Urban residential; (ii) Commercial; (iii) Industrial; (iv) Rural residential; and (v) Recreation open space. Doc»f I i IV304\| • 05-'ll'99 15:31 riO.St.I‘ POlO LINDQUIST & VENNUM p.l.l p. The CMP in Table 2 categorizes Woodhill as ‘‘recreation open space.” not as “commercial” or “industrial.” Similarly, Table 7 of the CMP maps out the City of Orono’s “land use plan.” It has eight categories, including various types of residential, “commercial," “institutional” and “parks,” Under the CMP, Woodhill Country Club is designated as “parks,” not “commercial” or “institutional,” Woodhill is expressly discussed in the “rural land use” area under the specific category of “Rural Recreational Facilities.” The CMP states as follows: ‘The recreational facilitie., identified on the Land Use Plan are principally large, natural, or open space areas which are compatible with their Rural Service Area location. None of the facilities draws a iarge number of users at any time one, and none of the facilities requires any municipal urban services.” • • • A significant amount of the recreation open space in Orono is that controlled by private golf and country clubs. Large acreages are owned by Wayzata Country Club, Woodhill Country Club, and Lakeview Golf Course. While technically private, these areas provide open space benefits to all nearby residents plus active recreational facilities for many Orooo and Lake area citizens. CMP 4-30, 31. The CMP docs not classify Woodhill Country Club’s use of the property for country club purposes as either commercial or urban. Neighbors’ references to Woodhill as commercial or business are simply inaccurate and inconsistent with the CMP. 2. Woodhill Avenue will remain a dead-end local street As to transportation, the CMP provides that “the basic responsibility of the City is the protection of its citizen’s health, safety, and welfare.” In terms of transponation systems, this means that a street system must be provided for “safe access to ^ developed properties wiili sufficient capacity to accommodate the expected number of trips generated by the planned land use.’’ CMP 7-2. The CMP provides the following transportation goals: 1. To provide adequate, safe transportation network sufficient to serve the needs of aU Orono residents. 2. To provide a coordinated transportation system provided alternative modes and travel choices for most Orono neighborhoods. 3. To provide a coordinated plan for Lake area transportation which will satisfy both economic and environmental concerns to achieve the above goals within the financial capabilities of the City and its citizens. D qc V II19804M 05^11/93 15:31 HO.862 Foil LINDQUIST & VENNUM p.l.l.p. Under the transportation plan, both Orono Orchard Road and County Road 15 are designated as -‘scenic parkways.” “Local streets” are defined as “local streets or public streets that functi on to providejlirect access to abutting properties . Local streets carry traffic within neighborhoods rather than through traffic between neighborhoods. Intersections with collector streets arc controlled by stopping the local street traffic.” Woodhill Avenue currently is a local Street. Under Woodhill’s proposed amendment, it would remain a dead.end street and wnulH serve only the abutting property owners, including Woodhill Country Club. Woodhill Avenue is not and will not become a through street. Contrary- to Mr. Malkerson ’s suggestion that use of Orono Orchard Road by members of Woodhill Country Club is inconsistent with the CMP, the CMP specifically provides that a “scenic parkway ” is designed to “provide access to recreational areas.” CMP 7-16. Since the CMP classifies Woodhill Country Club as a “recreational park ” area, it is fully consistent with the CMP for Orono Orchard Road to provide access to persons using the recreation facilities of Woodhill Country Club. Indeed, the vast majority, if not all, of the members who would use the Woodhill Avenue access already use Orono Orchard Road. In summary, Woodhill Counoy Club’s proposal to place new and additional restrictions on its 1968 CUP is fully consistent with the CMP. As an abutting property owner providing park and recreational facilities in the rural residential area, use of scenic parkways on a dead-end public street abutting the recreational facility is exactly what was contemplated by the CMP. As the City Engineer ’s recent report on County Road 15 makes clear, the only way the City of Orono can immediately, efficiently, and inexpensively address the CMP’s overarching goal of the health and safety of ajl Orono citizens is to grant Woodhill’s application. V. The Five Residents Opposing the Application Failed to Show Any Threat to Public Safety The silences in the letters of the residents and their attorney Malkcrson and traffic engineer Benshofl are far more telling than any of the .statements contained in the letters. It is the points that they do not dispute that are the truly relevant considerations for the city council in this matter. These concede, make no mention of, or otherwise do not dispute the following: 1. Use of Woodhill Avenue access will make for safer travel for scores of Woodhill families that live west and north of the Club. 2. Use of Woodhill Avenue will make for safer travel for thousands of motorists on County Road 15. DoeW I I 19Q04M 05/11/99 15:32 110.0^2 P012 LINDQUIST & VENNUM p.ll.p. 3. County Road 15 is overcrowded and congested seven days a week. 11. 4. Left-hand turns onto County Road 15 and off of County Road 15 at Orono Orchard Road and Woodhill Road arc difficult and hazardous maneuvers. 5. Woodhill Avenue has the capacity to carry hundreds, if not thousands, of cars daily. 6. Woodhill Avenue is wider and shorter than Woodhill Road. 7. The sight lines and signage on Woodhill Avenue are adequate or can easily be cleared of brush to be adequate. 8. Woodhill Road, like Woodhill Avenue, is a residential street and serves eleven families in addition to carrying all members, guests, commercial, and delivery traffic for Woodhill Country Club. 9. Orono Orchard Road carries an average load of 1800 cars per day, and Orono Orchard Road, between County Road 15 and Woodhill Avenue, is approximately the same width as Woodhill Avenue. 10. Woodhill Country Club traffic that would use Woodhill Avenue already travels on Orono Orchard Road. Smith and Lyman Avenues are much narrower (12 ’ to 18 ’ in width) and have no better sight lines or topography than Woodhill Avenue. These streets carry more traffic than proposed Woodhill application since they serve 19 homes representing approximately 190 trips per day. Russell Avenue and Dickinson Street serving about 17 families are similar. 12. Traffic levels at Orono Orchard Road and County Road 15 are and will remain a Level “F” (on a scale of A-F). 13. Traffic at the intersection of Woodhill Avenue and Woodhill Ridge private development road is, and w'ould remain under WoodhilPs proposal at the LOS (“Level of Service") Level “A." I I >TS<MM I 1 05'11/99 15:32 MO. 862 FnDl LINDQUIST & VENNUM p.l.l.p. The MalkcRon and Benshoff letters not only concede that traffic safety will be improved for Woodhill members and the general public in the overall area of Woodhill Road, County Road 15, Orono Orchard Road, and Woodhill Avenue, they also fail to identify an> specific way in which use of the secondary access will create an unreasonably negative impact on Woodhill Avenue or the Woodhill Ridge private road. If you wade through the Malkerson and Benshoff letters as well as those of the neighbors, the only place that they even begin to attempt to identify the alleged “noticeable adverse impacts for the existing residents served by Woodhill Avenue ” is on the bottom half of page 3 of the Benshoff report. The first identified ‘‘adverse impact” is the ability of the two houses located at the intersection of Orono Orchard Road and Woodhill Avenue “to use these driveways would be impacted” and the safety of their walking or bicycling on Woodhill Avenue would be “diminished.” No relative judgment or comparison to other streets in Orono or similar suburbs is made. Persons with driveways on Smith Avenue have more traffic coming by that impacts the use of their driveways than these two homes will ever have. These two homes at Orono Orchard were built in 1900 and 1930, respectively. When the current Woods home and the Woodhill Ridge development homes were built (50 additional trips per day), the property owners never complained that the addition of these homes maide backjng out of their driveways or waOang on Woodhill Avenue intolerable. Indeed, the Delaney home was originally the Dunwoody farm manager’s house and subsequently was the home of the original Woodhill golf pro, Norman Clark, who commuted to work daily from his home down Woodhill Avenue to Woodhill Country Club. Nor did the owner of the Larson property have any different expectation. Hot only was Woodhill Avenue in active use by the Woodhill Country Club but at the lime the house was built, the heating oil for the house was regularly delivered from Wayzata down Woodhill Avenue (See Affidavit of Tony Feser). The second “noticeable adverse impact” identified by Benshoff i.'s that “extensive trees and brush” obstruct sight distance in the southeast comer of the intersection of Woodhill Avenue and Woodhill private road. While the City StafT and the Parsons reports conclude that the sight distances and traffic signages are adequate at that intersection, the current owner of the property in the southeast comer of the intersection fully supports Woodhill’s application and has stated that he is willing to have any portion of right of way cleared that the City determines is necessary for proper sight lines. Third, Benshoff states that Woodhill Avenue is not wide enough for use by vehicles as well as bicycles or pedestrians. While conceding that there is greater traffic on narrower streets in Orono, Benshoff simply concludes that travel on Woodhill Avenue will be unsafe. No factual support is offered for the statement, because none can be. Woodhill Avenue is straighter, wider, .OocAf 111 9804.1 • 05/11/9= 15:32 M0.SS2 P014 LINDQUIST & VENNUM p.l.l.p. and clearer than Woodhill Road, Smith Avenue. Lyman Avenue. Russell Avenue. Dickinson Street, Orono Orchard Road, and numerous other residential streets in the City of Orono. Residents of all of those streets are expected to carry on their normal activities of driving, biking, and walking. Woodhill Avenue is approximately 25 feet wide. This variation from “the City’s 28 foot standard for a public residential street,** the City staff docs not view as “a limiting factor for the level of traffic currently proposed by Woodhill.” Staff Report at page 10. That is it. In nineteen pages of submissions by counsel and traflic engineer, only one-half of one page is devoted to identifying the actual problems the proposed secondary access will allegedly cause for the residents of Woodhill Avcnuc.and the Woodhill Ridge private road. However strongly felt, none of the identified impacts on the neighborhood outw'eigh the significant increase in traffic safety on County Road 15 for both Woodhill Country Club families and for the many citizens of Orono and others who travel on County Road 15. Conclusion Woodhill’s current application to amend its 1968 CUP can only be reviewed and decided in the context of Woodhill’s ownership and historical use of its property throughout this century. When Woodhill bought the property, the only existing access was through the public street then platted as Hamlet Street, and now known as “WoodhiU Avenue.” Since 1915, u has paid taxes on that property to the City of Orono. When Woodhill Avenue needed to be improved for the three new homes in Woodhill Ridge, the Woodhill property was assessed. Woodhill used the access for both foot traffic, bicycle traflic, and vehicular traffic in every decade sine 1915. When zoning was created in the 1960 ‘s, Woodhill’s use of its propeny, including its secondary access to Woodhin Avenue, was immediately permitted by the Village of Orono. As is its right, Woodhill has. from time to time, placed various gates, chains, etc. across driveways. When it decided to put a very strong chain up in 1980, it wrote to the City saying it was limiting regular vehicular traffic but reserving its ri^t to reopen the road at any time. As additional insurance, ihc grounds manager continued to drive cars and tractors up and down the road even after the chain was put in place. After buying property abutting the public road, paying taxes, paying Special assessments, using the road, and Nvriling to the City about its decision to open and close its driveway, Woodhill has both a propeny right and CUP right to use its access. Wliolly independent of Woodhill Country Club’s rights to use ilS CCntury-old access to Woodhill Avenue, the City Engineer’s repon on County Road 15 establishes the immediate need to restore the secondary access on Woodhill Avenue. The problems faced on County Road 15 are well-known to the council members personally aiid are amply quantified and described in the City Engineer’s report. The problem is getting much worse, not better. The City Engineer’s report studied and commented on ten improvement concepts and eight specific improvement 05/11/99 15:32 no.862 P015 LINDQUIST & VENNUM p.l.l.p. recommendations. Only one of these eighteen items can be implemented immediately, and without any cost to the City; the approval of Woodhill’s Application for Amendment of its 1968 Conditional Use Permit. It is a small step to alleviate the most serious traffic safety problem in the City, but it is a necessary' step in the right direction. LINDQUIST & VENNUM p.l.l.p. JPMc/klb cc: Ron Moorse Mike Gafiron Thomas Barrett ClilTord Greene Bruce Malkenson Edge Jackson es^. McCanhy DoeV 11I9B04U I I I Date Application Submitted: 4-14-99 Date Application Considered Substantially Complete: 4-30-99 60-Day Review Period Ends: 6-29-99 REQUEST FOR COUNCIL ACTION I I I I I I I I I I 1 1 I I Date; May 5, 1999 Item No.: Department Approval: Administrator Approval: Name: Michael P. Gaffron Title: Senior Planning Coordinator Agenda Section: Zoning Iteii Description: #2484 Woodhill Country Club, 200 Woodhill Road - Conditional Use Permit - Public Hearing Zoning District: RR-IB, Single Family Rural Residential Zoning Status:Golf courses, country clubs and tennis clubs are allowed as a Conditional Use within the RR-IB zoning district. Woodhill Country Club is authorized to operate a golf course and related country club activities via a Conditional Use Permit issued by the City Council in 1968. The Club has obtained a number of additional conditional use pennits for various improvements since 1968. Brief Summary of Request Woodhill Country' Club requests that its 1968 Conditional Use Permit be amended 1) to acknowledge certain basic rights of access to Woodhill Avenue; and 2) to impose certain new restrictions and conditions on Woodhill's access to Woodhill Avenue. The Club cleared and re­ graded a former access from Woodhill Avenue to the Club property in May 1998 without obtaining City approval. The Club now seeks approval to use this access on a limited basis, requiring a CUP application and review process for this proposed change in use. I #2484 - Woodhill CC May 5,1999 Page 2 List of Exhibits I. J. K. L. M. N. O. Submitted Wednesday April 14 bv Mark Albrecht: A. General land use application form, signed by Mark Albrecht, and $250 fee B. Plat map from Hennepin County used for defining areas to be notified C. 350’ Property owners ’ list from Hennepin County D. List of property ID numbers (PINS numbers) for Club properties in Orono and Wayzata E. List of Board of Trustees/Officers/Members F. List of persons to be notified regarding application correspondence Submitted bv Fax Thursday April 15: G. Legal Description Submitted Friday April 16 bv messenger from Lindquist and Vennum: H. Letter of transmittal by Jim McCarthy 9-page document detailing the request Copy of 1968 CUP application and City summary' sheet 8- 31 -98 Sathre-Bergquist survey of gravel driveway area 9- 26-88 Maintenance facility survey by Sathre-Bergquist Half section map from Ilenepin County Excerpt of half-section map with sketched site plan showing roads and buildings Plat of Woodhill Ridge Submitted Monday April 26 bv Surveyor Mark Gronberg : F. Existing driveway desigii/grading/drainage plan dated 4-23-99 (Plan ”A”) Q. Alternate driveway design/grading/drainage plan dated 4-23-99 (Plan ”B") Submitted Thursday April 29 bv Surveyor Mark Gronberg : R. Drainage area map and calculations Submitted Friday April 30 bv fax from Jim McCarthy: S. Cover letter by McCarthy and traffic study by Parsons-Brinckerhoff dated 4-30-99 Additional Exhibits Added by Citv Staff T. Referenced Municipal Code Excerpts: 6.01 Subd. 1(E,F); 6.05 Subds. 2,10; 10.03 Subd. 19-21; 10.09; 10.20 Subd. 3C CMP pp. 8-12,7-13,4-18 Letters and Comments received from Public as of 5/5/99 1. 5/3/99 Letter from Jerry & Shelly Storch 2. 5/2/99 Letter from Charles & Maria Maille 3. 5/3/99 Letter from Michael & Judy Wood 4. 5/4/99 Letter and Petition from Jane Delaney 5. 5/4/99 Letter from Bruce Malkerson including Benshoof letter of 5/4/99 Public Hearing Notice City Engineer Tom Kellogg ’s Comments 4/30/99 City Engineer ’s Draft CSAH 15 Traffic Management Study U. V. W. X. #2484 - Woodhill CC May 5,1999 Page 3 Public Hearing Notiflcation Notice of the Public Hearing was published in The Pioneer and The Laker on April 24, 1999 and May 1, 1999. Written notice to all property owners within 350' of the property boundaries and within 350' of Woodhill Avenue was mailed on Thursday, April 29,1999. Additional Permits and/or NotificationsWhich May Be Required Other permits which may be required in conjunction with the proposed driveway access include: a) permit for work in right-of-way; b) permit for land alteration; and c) CUP for land alteration exceeding 500 cubic yards The above permits will be held in abeyance pending the result of this land use CUP application. d) Minnesota Statutes require notification of fee holders when trees are to be cut within dedicated right-of-way. Application Background In May 1998 Woodhill Country Club did grading work within the Club property and within the dedicated right-of-way of Woodhill Avenue to re-open a driveway access from the Club property to Woodhill Avenue, which access had been closed by the Club since approximately 1980. The City stopped the work upon being advised it had occurred, and indicated to Club representatives that certain permits and approvals would have to be obtained by the Club in order to retain the work that had been completed and for the access to Woodhill Avenue to be used. Subsequently a number of public and non-public meetings occurred between and among Club representatives, the City Council, staff, and the immediate neighbors potentially affected by the re­ opening of the access. The City refused to sanction Woodhill's use of Woodhill Avenue without the proper CUP public review process. Woodhill refused to make such an application. In July 1998 the Club filed suit against Orono, claiming that Woodhill has a right to open and use the Woodhill Avenue access without City approval. The lawsuit proceeded with discovery through March 1999. In April 1999 Woodhill proposed a settlement procedure by which Woodhill would apply to the City for a CUP to allow opening and use of the Woodhill access on a limited basis. Woodhill filed current application on April 14, 1999. This application was deemed by staff to be substantially complete as of April 30, 1999 upon receipt of the traffic study by Parsons Brinckerhoff. I #2484 Woodhill CC Mays, 1999 Page 4 Summary of Woodhill's Request Woodhill's request is detailed on pages 1 and 2 of Exhibit 1, and is summarized as follows: 1.Requests amendment of 1968 CUP to aeknowledge the following vehieular access rights, i.e. the rights to: a) maintain unbarricaded access to Woodhill Avenue b) gate and maintain control of said entrance c) have access available at all times for Emergency Vehicles d) have access available from 7:00 am to 8:00 pm for Woodhill members and invited guests during days the Club is open (Tuesday thru Sunday, plus Monday public Holidays, closed in March) e) have access available for transporting tractors to Long Lake for repair f) have access available for general access if Co. Rd. 1 5 access is temporarily blocked (subject to notification of City and neighbors) g) have access available per 1987 easement, which grants access to Lot 3, Block 1, Woodhill Ridge over Woodhill property to Woodhill Avenue if County Road 15 access is closed or otherwise denied I I 1 1 1 1 2.Requests City agreement tliat the above rights shall not be revocable, nor for a limited period, nor be subject to further review except as provided for in Orono Zoning Code Section 10.09 Subd. 11 . 3. 4. Requests that 1968 CUP be amended to include the following 'triggers’ that will require further City review or further amendment of the Woodhill CUP: a) Conversion of Woodhill Avenue access into the main permanent Club access b) Use of Woodhill Avenue as an access for delivery, taxi, service or other commercial vehicles c) Use of Woodhill Avenue as a general public access d) Use of Woodhill Avenue access at times other than allowed in 1. above e) Expansion of Woodhill ’s driveway between the maintenance building and Woodhill Avenue f) Paving of the driveway abutting Woodhill Avenue g) Signage concerning Woodhill on Orono Orchard Road (identification or directional signage) Requests City confirmation by CUP amendment or Council Resolution that Woodhill ’s right of access to Woodhill Avenue exists independent of any CUP process and is not revocable through CUP process in regards to: a) 1987 easement agreement; and b) In the event of permanent blockage of access to Co. Rd. 15 as a result of Co. Rd. 15 alteration/improvement or resulting from closure actions related to the railroad right-of-way. (Is this a conflict with request 3a above?) I I I L L #2484 - Woodhill CC Mays, 1999 Page 5 What Woodhill is implicitly not requesting. Staff assumes the following activities, uses or improvements, by omission, are implicitly not being requested: 1. Use of the Woodhill Avenue access for Club maintenance vehicles other than tractors. 2. Use of the Woodhill Avenue access by Club employees except in relation to tractor servicing. 3. (There may be additional activities, uses or improvements which should be noted here) Staff Review and Summary of Issues A. Pertinent Sections of City Code and Comprehensive Plan CUP for Country Club Use. Woodhill Country Club is in Orono's RR-IB Single Family Rural Residential zoning district, the standards for which appear in Zoning Code Section 10.28. Section 10.28 references the R-IA district standards for conditional uses. Section 10.20 Subd. 3. The pertinent subsection which addresses country clubs as a conditional use, reads as follows: "Subd 3. Conditional Uses. Within any R-IA One Family Residential District, no structure or land shall be usedfor the following uses except by conditional use permit: ...C. Clubs, Camps, etc. Golf courses, country clubs, tennis clubs, public swimming pools serving more than one family, scout camps, YMCA camps, YJVCA camps, church camps, or private non-profit parks, playgrounds and other similar uses. The principal structure for any of the above listed uses shall be 100' or more from any abutting lot in an "R" district, and acces.sory structures shall be a minimum offifty feet from any lot line." This is identical to the language in effect at the time the 1968 CUP was applied for and issued. The City has historically required a new CUP for any new physical improvements (new buildings, extensive grading work, etc.) to an existing conditional use. The City has also required such a review when a new use or activity is proposed by an existing conditional use, and such review is especially appropriate in the context of the CUP process, when such use will have potential negative impacts on the surrounding neighborhood. Zoning Code Section 10.09, Subd.l, states in part that "...Conditional uses include those uses generally not suitable in a particular zoning district, but which may under some circumstances be suitable. When such circumstances exist, a conditional use permit may be granted. Conditions may be applied to issuance of the permit and a periodic review of the permit may be required...". The City Council is empowered to grant or deny conditional use pemiits and to impose reasonable conditions on them. #2484 - Woodhill CC May 5,1999 Page 6 With regards to the Woodhill request, it is the City's position that the re-opening of an access to Woodhill Avenue after a nearly 20-year closure, requires a new CUP (or an amendment of the existing CUP) for the following reasons: 1. The 1968 CUP was issued based on a given set of circumstances prevalent at that time. The conditions that applied when the 1968 CUP was granted have ehanged, i.e. there is now an adjacent neighborhood in whose creation the Club participated after the original CUP was granted, and which may be impacted by this change in use. 2. It can reasonably be argued that the 1968 CUP to allow the Club to operate, has not lapsed. It might also be reasonably argued that the lack of use of Woodhill Avenue as a secondary access to the Club for nearly two decades or more, might be considered as a lapse in that specific aspect of the conditional use (if in fact the Woodhill Avenue access was even covered under the 1968 CUP) as contemplated in zoning code Section 10.09, Subd. 9. 3. The conditions that applied when the 1988 maintenance building CUP was granted have also changed. The access was not proposed to be used at that time, yet neighborhood concerns were raised related to the location and use of the building even without use of the access. Additional concerns would likely have been raised if the road access had been proposed. 4. The proposed use of Woodhill Avenue by a non-residential user raises concerns of health, safety and welfare that the City is responsibile for addressing, and which are properly raised within the format of a public review process when a conditional use is involved. Permit for Work in Public Right-of-Wav . The proposed driveway within the dedicated right-of-way of Woodhill Avenue is defined in the zoning code as a "Business Driveway Approach" (Chapter 6, Sec. 6.01 Subd. IE, F). A permit from the City is required for construction or reconstruction of this driveway approach per Sec. 6.05, Subd. 2. Such permits are administered by the Public Works Director, who has the authority to approve or deny such permits. Additional sections in Chapter 6 regulate and provide standards for work and activities within the public right-of-way. I I I I I I I I I I I I I 1 I 1 1 I 1 I I I #2484 - Woodhill CC May 5, 1999 Page 7 Driveway Standards. The proposed driveway is subject to the driveway standards of Municipal Code Section 6.05. Subdivision 10 "Business Driveways, Approaches and Turnarounds". Those standards which may be applicable to the current request include: Only one business driveway is allowed per development unless approved by City - Must be paved (bituminous) within the right-of-way - Driveway approaeh to be at least 100' from a comer in a residential district - Must be 10' from side lot line The proposed driveway is a second driveway to the Club. The proposed driveway is gravel, not paved. The standard for a driveway approach being 100' from a comer has, at best, dubious applieability in this case due to the linear nature of the road and driveway layout. The proposed driveway is e.xactly 10' from the lot line abutting the property to the immediate south, and more than 10' from the property to the north. Land Alteration Permit. Land alteration in e.xcess of that authorized by a driveway permit or when not authorized in conjunction with a building permit, requires, at a minimum, a staff administered land alteration permit per Section 10.03, Subd. 19-21. When the volume of land alteration exceeds 500 cubic yards, a Conditional Use Permit is required. Staff is authorized to refer land alteration permit requests to Council for volumes less than 500 c.y. if staff concludes the work may create negative impacts or be not in keeping with the goals and policies of the Comprehensive Plan. While from all information gathered to date it appears the volume of grading in conjunction with this access work was significantly less than 500 c.y., the proposal does "potentially create negative impacts" in the opinion of staff, specifically related to drainage, noise, odors, visual impacts and public safety, all of which should be reviewed by the Council given the neighborhood concerns. Conformity with Community Management Plan. The CMP eneourages retention and continued operation of the private golf courses (Rural Park and Open Space Policy #8 on page CMP 8-12) because they provide aesthetic open space and natural vistas to the benefit of adjacent landowners and the general public. In regards to Rural Transportation Policies, the CMP in Policy #7 on page CMP 7-13 states that "Driveway locations and rural street or private road intersections will be limited for traffic safety...", the intent being to consolidate access points onto major roads. Urban Land Use Policy #6 on page CMP 4-18, states that "Commercial and industrial development will not be permitted to adversely affect neighboring residential property...". While Woodhill is not strictly a commercial or industrial use, certain aspects of its operation may have impacts that are not strictly residential in nature, and that is w hy private golf courses are a conditional use rather than a permitted use. #2484 - Woodhill CC Mays, 1999 Page 8 B.Past Use of Woodhill Avenue for Club Access 1968 CUP. There is no question that Woodhill Avenue served as a secondary access to Woodhill Country Club for many decades prior to issuance of the 1968 CUP. The 1968 CUP was not detailed, however, and does not lead to any conclusions regarding the continuing use of, or level of use of, the Woodhill Avenue access. It was unquestioned in the 1968 CUP that County Road 15 was the access to the Country Club. The 1968 CUP document identifies a request for a "Non-Conforming (sic) Use Permit for golf course", and its approval on 9-13-68 included the following minimal 'conditions' of use: "Approximately 150 acres in Orono. Club house and various buildings for entertainment. Private club." The sketch which accompanied the 1968 CUP request shows an access to County Road 15, depicts interior driveways and buildings, and shows a driveway leading to the edge of the map but not identified as a connection to Woodhill Avenue. 1980 Closure . The Club in 1980 closed off it's Woodhill Avenue driveway access to most vehicular traffic, and placed a new chain across the entrance which became accessible only if the chain was removed by the Club. The Club informed the City in writing of its intent to voluntarily close the driveway, and stated that the Club reserved the right to use the entrance should it choose to do so in the future. 1987 Subdivision and Easement. In 1987 the Club, in conjunction with a private developer, subdivided the property south of Woodhill Avenue and created the 5-lot residential plat of Woodhill Ridge. The subdivision resulted in the following actions which are pertinent to this review: 1. 3. Created a new private road to serve Lots 1,2,4 and 5, extending southward from near the east end of existing Woodhill Avenue. Resulted in expansion of the dedicated right-of-way at the east end of Woodhill Avenue, apparently to incorporate the unused driveway leading from Woodhill Avenue into the Club property, so that said driveway would be within a public right-of-way rather than within one of the private residential lots. Resulted in upgrading of existing Woodhill Avenue from Orono Orchard Road to a point Just past the intersection with the new private road serving Woodhill Ridge, ending approximately 65' west of the Club's property boundary but appaiently to provide a connection to the old chained-off driveway. I I I #2484 - Woodhill CC Mays, 1999 Page 9 4.Resulted in the Club's granting an access easement in favor of Lot 3, Woodhill Ridge (the lot which is not serv'ed by the private road) over Club property to Woodhill Avenue in the event the Co. Rd. 15 access is blocked. 1988 Maintenance Building CUP. In 1988 Woodhill applied for and w'as issued variances and a CUP for a new maintenance building to be located approximately 160' east of the Woodhill Ridge subdivision, and adjacent to the old driveway connecting to Woodhill Avenue. A portion of the old driveway bed was filled near the northwest comer of the maintenance building, in conjunction with the site grading for that building. The CUP/variance resolution does not address future use of the driveway connection to Woodhill Avenue. The only reference in the Planning Commission and Council minutes as to use of the old driveway was a negative response from the Club's surveyor to Jeanne Mabusth's question whether the V.’oodhill Avenue connection would have to be opened during maintenance building construction. During the 1988 review process the concerns of the neighborhood were addressed, resulting in a relocation of the original proposed building site (north side of old driveway, 50' from west lot line) to the final location 160' from the west lot line and on the south side of the old driveway. This placed it approximately 350' from the actual house sites of each of the two nearest residential lots, and allowed for the saving of several trees, a screening barrier to the surrounding residential properties. Tlie review process also resulted in a CUP approval condition that future complaints from adjacent residents about increased noise from the maintenance operation would allow the City to re-open the CUP for further review. I I I I Why is a Secondary Access Needed? For Whom? When? The Club was advised to define the concerns that have resulted in this request. The Club addresses this topic on pages 6-8 of Exhibit I (PLEASE READ!). In brief, the following topics are addressed: Increased traffic volume and speed on Co. Rd. 15 Temporary problems during Co. Rd. 15 improvements construction - Expected greater volumes and speeds on Co. Rd. 15 once the improvements are completed - Raised elevation of Co. Rd. 15 - Left turns difficult and dangerous for member access from west Potential to reduce access to 15, making 15 safer - No other access points available to Club without acquisition - Other potential access locations which might be acquired/developed would have greater impacts on other neighborhoods. I' #2484 - Woodhill CC May 5, 1999 Page 10 Club activity has not significantly increased since 1968 Anticipated use of access only by members who live west of Club Anticipated use is 20-30 trips per day summer weekdays, 60 trips per day on summer weekends; less in spring and fall, much less in winier D. Trafflc Safety Concerns: Impact on Woodhill Avenue Comments from the Woodhill Ridge neighborhood indicate a concern with safety, related to the conversion of Woodhill Avenue from what has functionally been a private, low-traffic cul-de-sac to a somewhat busier through road serving a quasi-commercial use. The impact of additional traffic due to Club usage of the public road is proposed to be minimized by adding new, more restrictive traffic controls. The public road portion of Woodhill Avenue will no longer function as the mere extension of a 6-family private road. The Club was advised to investigate and address the impacts of the proposed access on Woodhill Avenue and the surrounding neighborhood. The Club’s initial submittal addresses the topic of traffic impacts on pages 8-9 of Exhibit 1 (PLEASE READ!!). The Club's points are summarized as follows: The proposed access will be very limited in scope The impact on the three homes aecessing directly to Woodhill Avenue will be no greater than it was when those homes were built. The 3 homes with driveways accessing to the private road portion of Woodhill Avenue, will have no Club traffic directly in front of them, and will have no problem entering or exiting their driveways. Woodhill wll periodically remind members using the access of traffic rules and safety concerns The gravel road, 10 mph speed limit, and west-bound stop sign at the point where the driveway enters Woodhill Avenue, all will act to keep the access safe. A three-way stop could be established if the neighborhood desires. The proposed traffic controls and low level of use will yield a greater measure of pedestrian/child protection than most City street/private road intersections The proposed level of traffic is not considered high for a local residential public street - The impact on Orono Orchard Road traffic levels will be minimal since most anticipated users would otherwise use Orono Orchard Road to and from Co. Rd. 15 The Parsons Brinckerhoff traffic study submitted by the Club is summarized later in this memo. Note that although Woodhill Avenue is 24 ’ paved width rather than the City’s 28 ’ standard for a public residential street, staff does not view this as a limiting factor for the level of traffic currently proposed by Woodhill. #2484 - Woodhill CC Mays, 1999 Page 11 E. Drainage and Erosion Impacts Portions of the proposed gravel driveway have a relatively steep grade and therefore are subject to possible erosion. The easterly portion of the driveway, primarily that portion within the Club property, could be directed to drain to an existing depression north of the driveway. The existing drainage pattern generally is eastward toward Woodhill Avenue, discharging under the private portion of Woodhill Avenue through an existing culvert. The rates and volumes of stormwater runoff generated by this access driveway do not warrant a NURP pond nor other extensive stormwater management facilities. Improvements of the ditches adjacent to the driveway will be needed to ensure no stormwater impacts to the driving surface of Woodhill Avenue. A paved driveway would be less susceptible to erosion and sedimentation. Because this is a business driveway, all portions of the driveway in the right-of-way are required to be paved with bituminous material per Section 6.05 Subd. lOB. It is staffs understanding that the Club has proposed a gravel driveway rather than pavement for a number of reasons, including visual impact, traffic speed reduction, to create a public perception that it is a driveway rather than a road, etc. However, paving would decrease the potential for sedimentation; would be a quieter driving surface; and would result in avoiding the maintenance concerns of maintaining a clean transition area betw'een the gravel and paved surfaces, i.e. avoiding loose gravel on the paved surface at an intersection, which can cause noise problems, loss of traction, etc. F. Other Potential Neighborhood Impacts 1. Dust. The proposed gravel driveway will have a potential to create a dust problem during periods of dry weather. Limiting the traffic speed to 10 mph as proposed will help to limit the dust to a great extent. Periodic watering or calcium chloride treatments could also be used. Any dust problem would be eliminated by paving the access driveway. 2. Noise. The additional traffic generated by this access will have little noise impact on the neighborhood. The gravel surface will likely generate more tire noise than would a bituminous paved surface. Vegetation that had grown up in and around the old roadbed prior to its 1998 reconstruction may have provided some small degree of noise buffering to the neighborhood from the maintenace facility. That buffer will no longer be in place; however, no homes appear to be directly affected by this loss of vegetation. I #2484 WoodhillCC Mays, 1999 Page 12 3. Odors . The proposed low level of traffic and prohibition on service and delivery vehicles will likely result in no significant odors generated due to this access. 4. Lights. There is currently no streetlight at the intersection of Woodhill Avenue and the Woodhill Ridge private road, and none is proposed. Headlights from vehicles entering and exiting at the new access will not shine directly at any neighboring homes. The proposed limitation on hours of access availability of 7:00 a.m. to 8:00 p.m., and the limited usage during months where darkness occurs earlier in the evening, will also result in minimal headlight impact in the neighborhood. Any existing or proposed lighting at or near the maintenance building whose source may be more visible when the access is in place, w'ould have to be redirected or shielded. 5. Visual Impacts. Opening of the access to Woodhill Avenue results in the loss of some vegetation which in the past acted to screen the maintenance building from users of Woodhill Avenue. The maintenance building will be somewhat more visible in the winter months with the road being open. The additional proposed traffic signage and the proposed level of traffic will result in minimal if any negative visual impact on the neighborhood. 6. Security. The Club does not propose to install a gatehouse, but does propose to have a gate or chain that would have to be opened at 7 a.m. and closed at 8 p.m. The Club closed this access in 1980 due to security issues, i.e. unwanted traffic, etc. At least one neighborhood resident has expressed concerns regarding security. The lack of a gatehouse or other monitoring at this access location is a topic for further discussion. I I City Engineer’s Comments re: Proposed Driveway Design The comments of the City Engineer appear in Exhibit W and are summarized as follows: 1. Proposed driveway slope in some locations is 14%, slightly exceeding recommended drivew'ay maximum of 10%; private road maximum slope by code is 12%. 2. Erosion is a concern, needs erosion controls during/after construction. Need vegetation established in ditches. 3. Recommending typical street section for a private road; if remaining as gravel surface, dust control measures may be needed. 4. Drainage calculations acceptable. Could divert runoff from upper driveway to small existing pond north of driveway. 5. Need a retaining wall design for area near NW comer of maintenance building. ► * « I » i I I I #2484 WoodhillCC May 5,1999 Page 13 City Engineer’s County Road 15 Traffic Study Bonestroo and Associates is nearing completion of a Traffic Management Study for the segment of CSAH 1 5 (Shoreline Drive) from CSAH 51 (North Shore Drive) to Femdale Road West. This study is for the purpose of analyzing: traffic movement and access from cross streets methods to improve east-west traffic movement that could provide some relief to Co. Rd. 15 the feasibility of providing a frontage road on the north side of 15 between Woodhill Road and Orono Orchard Road the feasibility of signalizing County 15 at North Shore Drive and at Orono Orchard Road One of the conclusions of the draft study is that access to Woodhill Country Club would be vastly improved with the provision of a traffic signal at Orono Orchard Road and the provision of a connection from Orono Orchard Road to the Club. Four concepts for making such a connection were reviewed: a. Frontage road north of railroad tracks , connecting Woodhill Road to Fox Street. Would allow closure of Russell Avenue and Woodhill Road accesses to 15. A successful solution if Orono Orchard /1 5 is signalized; but downsides are high cost and wetland impacts. b. Connect from Woodhill Road to Dickenson Street. Likely high cost due to topographv, plus necessary improvement to Dickenson Street. Requires signal at 1 5/Orono Orchard. c. Woodhill Road private road connection to Dickenson. This would connect Dickenson directly to the east-west branch of Woodhill Road that serves a number of private homes. Requires signal at orono Orchard/15. d. Re-open Woodhill Avenue access to Club . This alternative would not allow closure of the existing accesses to 15, but may be least costly of alternatives. Would benefit by signal at Orono Orchard/15. This study also analyzes imd recommends various improvements to Co. Rd. 15 that would assist in making 1 5 less hazardous. Please review the excerpts from this study. Exhibit X. Parsons-Brinckerhoff Traffic Study The traffic study submitted by Woodhill is briefly summarized as follows: 1.Trafilc control improvements should be implemented including: a. 20-22' gravel driveway east of existing pavement. b. A gate at west end of Club property to be closed when access not available. c. 10 mph speed limit along access driveway, both ways. d. "No Left Turn" sign for traffic exiting Club driveway onto Woodhill Ave. e. Westbound stop sign............................... #2484 Woodhill CC May 5, 1999 Page 14 2. 3. 4. 5. 6. f.Eastbound stop sign on Woodhill Avenue at Woodhill Ridge road intersection. g. Stop sign for outbound traffic at north comer of Woodhill Avenue and Orono Orchard h. Painted bar line and painted lane dividing line at west end of Woodhill Avenue i. Vegetation clearing along east side of Orono Orchard Road south of Woodhill Ave. Proposed restrictions on use of Woodhill Avenue access driveway: a. Open only 7 a.m. - 8 p.m. b. No commereial, delivery, ta.xi or service vehicles allowed c. Only members and invited guests may use access d. Emergency vehicle access allowed at all times e. Full general use allowed when Co. Rd. 15 access is blocked Traffic sources: a. 50% of current Woodhill Road trips are staff / visitors / service vehicles which won't use Woodhill Avenue Less than 25% of members live west of Club 60 vehicles per day is estimated Club use of Woodhill Avenue access b. c. a. Woodhill Avenue capacity: Expected increase from 50-60 neighborhood vehicles per day to combined neighborhood / Club use of 100-120 vehicles per day is well within tlie defined capacity for this type/nature of residential road Intersection capacities: a. Woodhill Ave at Woodhill Ridge: - Apparent proposed stop sign for outbound Woodhill Ridge traffic? - Level of Service "A", i.e. no delays Woodhill Ave at Orono Orehard Rd: - No capacity constraints - No sight distance constraints - No added traffic to Orono Orchard Road Co. 15 at Orono 0..;hard: b. c. d. - Slight (30 vehicles per day) decrease in traffic and reduction in cross movements - Greater traffic safety Co. 15 at Woodhill Road: - Same comments as for Co. 15 at Orono Orchard Road design: a. 11 % slope on gravel driveway is not a problem for traffic movement b. Woodhill Avenue is wider than Woodhill Road c. Woodhill Avenue has suffieient capacity, better than Woodhill Road d. The Orono Orchard / Woodhill Ave intersection will have sufficient capeity and sight distance when the recommended signage, etc. are in place i I I I I I I I I I r #2484 Woodhill CC May 5, 1999 Page 15 7.Alternate Solutions a. Police traffic personnel or a semaphore at Woodhill Road / Co. 15 are not feasible b. Turn lanes on 15 at Woodhill Road do not solve high speed, limited sight distance, or "critical gap" problems c. There are no other locations where the Club owns land that abuts a public street that could be used as an access. Neighborhood Comments The City has received letters from a number of property owners in the neighborhood. Those letters are included as Exhibits U. They include a petition opposing the Club's request. Please review these submittals. Malkerson Letter and Benshoof Traffic Study Also included in the attachments are a traffic study by Benshoof & Associates, Inc. and a letter from Bruce Malkerson on behalf certain homeowners in the neighborhood. Please review these documents included within Exhibits U. » • ♦ • ♦ • Lssues for Discussion Council should consider the following questions in determining a course of action on the Woodhill request: 1. 2. 3. 4. Has Woodhill CC provided sufficient justification to warrant consideration of a second access to the property? Has Woodhill CC adequately demonstrated that other secondary access options are either not feasible or are inferior to the proposed Woodhill avenue access? Do public health, safety and welfare concerns suggest that the benefits of allowing Woodhill CC an access to Woodhill Avenue outweigh the potential negative impacts to the neighborhood? Are the Club-proposed limitations on use of the access sufficent to alleviate most or all of the concerns expressed by the neighborhood? If not, what additional limitations should be attached to City approval of the access? #2484 WoodhillCC Mays, 1999 Page 16 5. 6. 7. 8. 9. Does Council accept the Club's premise that the Club has access rights which should be formally and permanently acknowledged? Does Council accept the Club's request that once established formally, these access rights will not be subject to future review except by neighborhood petition per the zoning code? Given the large size of the Club property, should some modifier be established so that factors other than "petition of 75*^’ of all property owners within 1000' of the property" would trigger a future CUP review? Does Council agree that Club rights regarding the 1987 easement for Lot 3 and regarding blockage or involuntary closure of theWoodhill Road access to 15, must be independent of any CUP process or review? Does Council agree with the 7 "triggers" proposed by Woodhill CC that will require further City review or further amendment of the CUP?-' Does Council agree with staff that this application does not and will not address the historical ongoing country club use, but merely deals with this secondary access issue? Should the Club be required to pave the portion of the driveway within the right-of-way of Woodhill Avenue? Staff Recommendation Council must weigh the needs and the rights of both the Club and the neighborhood, against the public health, safety and welfare concerns that surround this issue. In the event that Council determines that some limited use of the access is appropriate, staff would recommend, as a starting point, that the following minimum conditions be attached to such approval: 1 . If the Club's access to County Road 15 is closed for whatever reason for an extended period other than a short term emergency situation, the City must have the right to reconsider the Club's Woodhill Avenue access CUP to allow consideration of all alternatives for provision of proper and adequate access for the Club and other potential access users, and consideration of the impacts of those alternatives. 2. The City should establish triggers which will allow review of the Woodhill Avenue access CUP, including but not limited to: those proposed by the Club; a review based on the amount of actual traffic using the access; - a review after some given time period. If Council concludes that approval of the access is appropriate. Council should direct staff to draft a CUP approval resolution with appropriate findings and conditions, for consideration at the May 24 Council meeting. I I p B>U.A Application U Date Received _ Amount Paid XY OF ORONO - GENERAL LAND USE APPLICATION PROPERTY LOCATION Site Address 200 Woodhill Road, Wavzata. MN 55391 Type of Application to be Filed Land Use Application Property Identification Number (P.I.D.) Attached APPLICANT Name Woodhill Country Club Phone (home)__ Phone fworki 473-7333 Address 200 Woodhill Road City Wayzata Zip 55391 OWNER (if different than applicant) Name __________________ Phone (home). Phone (work). Address City Zip. Date Property Acquired 1915 (month/year) I (do) (do not) also own the adjacent parcels of land. FEES - CONDITIONAL USE PERMITS - ______S 75.00 For each variance request with CUP application ____SI75.00 Residential Accessory Use S250.00 Institutional (church, school, etc.) ciubs ______$225.00 Guest House/Guest Apartments ______$200.00 Duplex Credit/Bldg ______$300.00 Commercial/Industrial Use ______$250.00 Land Alteration _____ Grading and filling - designated wetland floodpla!.-. _____ Grading and filling - 501 cu. yd. or more _____ Grading, seawall, retaining walls within 75' of lakeshore ______PRD/PID - see Fee Schedule ______$150.00 Renewal Fee (no change from original application) After-the-Fact Fee - Double Current Application Fee OTHER APPLICATIONS ______$250.00 Commercial Site Plan Review (+ consultant fees) _____ $300.00 Vacation ______$200 Easement Vacation $100.C J Easement Vacation With Subdivision ______$350.00 P.czoning (PUD - refer to fee schedule) ______$350.00 Cuitiprehensive Plan Amendment ______$100.00 Appeals Other - see Fee Schedule tU V I • ♦ ^ 4 Li i REQUIRED SUBMITTALS 1. 2. 3. Completed Application Form. Describe request in detail. Certified Property Owners List of owners within 350', labels and plat map (you must obtain this list, labels and map from Hennepin County Department. of Finance, A-603, Government Center, 348-3271). 4. 5. 6. 7. 8. 9. Certificate of Survey (signed by a licensed surveyor) - refer to handout for survey information. Attach legal description to application if not included on required survey. _ Topographic survey (existing and proposed contours) if land alterations involve changes in elevation (grades). List of the legal names (include marital status) of all persons with an interest in the property. This would include name(s) of applicant(s) if not current owner(s). Construction plan, if applicable (see staff for requirements). _ As an addendum to this application, please attach a separate list of any other persons you wish notified of this application. you ARE REQUIRED TO SUPPLY 30 COPIES OF LARGF DOCUMENTS OR COPY FOR REPRODUCTION (tl” X 17" OR SMALLER) FOR ALL DOCUMENTS SUBMITTED. (Staff will require to scale drawings of all documents, plans, etc. to be submitted.) The Applicant and Property Owner must sign this application. Please remember that your application is not complete if the above information has not been included. Certification by Clerical Department that Land Use Application is complete. Initials of Clerical Staff:__________________________ Date__________ APPLICANT'S SIGNATURE The applicant hereby agrees to provide all information required or requested by the Zoning Administrator, agrees to pay additional fees (staff time not covered by original fee payment) and/or unusual exper.ses incurred in review of this application, and certifies that the information supplied is true and correct to the best of his/r.:.* ’.L-.owledge. Applicant's signature ^ ______Date__ OWNER'S SIGNATURE The owner hereby acknowledges and agrees to this application and further authonzea reasonable entry onto the property by City staff, consultants, agents, commission members, and Council members for purposes of investigation and verification of t.'iis request. Date •A'XA.I Applicant must have all submittals into the City offices 25 days before the Planning Commission Meeting. Planning Commission Meetings are held on the third Monday of each month. 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P19SI9I1 PARE S 99 02-117-23 91 OOOl •0790 NILLSIOE DR W CMIISTOPNCR R VOLLRATH IT AL CHRISTOPNER R VOLLRATH 790 HILLSIDE OR W WAYZATA Itl 1SS91 99 02-117-21 91 •••7 fOpp AMR II790 CO RO NO 11 00(4a« THE NATURE CfWtMRVANCY NATURE CONSERVANCY O-4E/A00R ISIS STW ST S E SUITE S19 fTLS m 11919 99 •2-117-23 91 •••• ••470 NILLSIOE DR W CHRISTOPHER R VOLLRATH IT AL CHRISTOPHER R VOLLRATH 799 NILLSIOE OR W WAYZATA m 11S91 99 SS-lll-23 99 •••• ••!•• WAYZATA BLVO V CITY Of WAYZATA CITY Of WAYZATA 4C0 RICE ST WAYZATA IM 5S391 PROP AOOR OWNER NANE TAXPAYER NAME/AOOR TOTAL BATCH 192 ••••• 38 02 117 23 21 0036 ADDRESS UNASSIGNEO G KARC WHITEHEAD ET AL G MARC WHITEHEAD 305 W FULLERTON PKWY CHICAGO IL 60614 38 35 118 23-95^0016 1220 LYMAN AVE JOHN Q HUNSrCKER ET AL JOHN Q HUNStCKER 1220 LYMAN AVE WAYZATA MH 55391 • • • c ‘he a/:>t. : ^ J2-//7- ^3- I CERTIFY THAT THE FACTS REPRCSCtaCO ARE AN ACCURATE AND TRUE RCPRCSEKTATION Of INFORtUTION AS IT APPEARS THIS OATS ON THE RECORW Of THE NEIMEPIN COUNTY OEPARTHEirT Of PROPERTY TAXATION, TO THE OEST Of NY KNOWLEORf AND BELIEF DATE Nj Oi=te • • • I • \ r BATlM/ft/ff HOMiriH COUKTY fftTCmf INFOnUTION SYSTfM ritOPEITY fWMtIS LIST RtPOtl m. 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PI9S4991 PA8E S PROP Am ORNER NAME TAXPAYER NANE/Am SA 92-117-23 22 999S 9924S ORONO ORCMARO tO S VILLA0E OP CITY OP P 0 SOX 44 CRYSTAL OAT MN SSS2S SA 92-117-U 29 Aim ROOONILL JANt E DELANEY JANI E DELANEY ISIS ROOONZLL AVE RAYZATA m SSS91 9991 AVE SA 92-117-2S 29 999S 992A9 ORONO ORCHARD RO S VICTORIA N RAZCNX VZCTORZA N RAZCME 2A9 ORONO ORCMARO RO S RAYZATA 101 SU91 PROP Am ORNER NAME TAXPAYER NANE/Am Si 92-1I7-2S 29 9990 912S9 ROOONZLL AVf J V 1 V L RELSN J0I9I V A VIR0ZNIA L RELSH Itf9 ROOONIU AVf RAYZATA 101 SSS91 SA 92-117-2S 29 9999 91249 ROOONILL AVE CAN NAILS CNARLU R I MARLA C NAZLI 1249 ROOONZLL AVf RAYZATA Ml SSS91 SA 92-117-23 29 9911 91251 ROOONZLL AVE AEVERLY N OROSSNAN TIMOTHY • LAURIE MC COY 4427 PZMUCLE DR EOCN PRAIRIE MN SSS94 PROP AOOR ONN9R NANS TAXPAYER NAME/AOOR Si 92-117-2S 29 9912 91291 ROOONILL AVf 0 L STORCN ASS STORCN 0ERUD L A SMELLY S STORCN 1291 NQOONILL AVf RAYZATA 101 1U91 SA 92-117-23 29 9913 999SA AOORESS UNASSXOIED LUCY C NZTCNELL ET AL LUCY C NZTCNELL 1211 MOOONILL AVE RAYZATA m US91 Si 92-117-2S 91 9992 999AS ED9EV000 KILLS RO MARY JEAM« V iOREN MARY JIAMIS V iOVEN 3S91 RUM ROM NAPLES PL S9192 PROP Am OMMER NAME TAXPAYER NANE/Am Si 92-117-23 91 999S 91991 EOAfNOOO MILLS RO R J KSZTN JR ST AL TRUSTS*^ PREOA C KSZTN 1991 EOOEVOOO NILU RO RAYZATA m SSS91 SA 92-117-2S 91 9999 999SA Amiss UNASS19NEO MCLEOD CNTY RE0 RAIL AUTN DAKOTA RAIL INC 25 ADAMS ST N NUTCNINSON 101 1IS59 SA 92-117-2S 92 9992 •1911 EOAINOOO MILLS RO 0 ELOREDOI JACKSON III IT AL D E A X X JACKSON III 1915 lOOEROOO MILL RO MAYZATA m 11S91 m PROP Am ORNER name TAXPAYER NANE/Am SA 92-117-2S 92 999S 99959 MOOONILL RO R P PETER ROSENASR0 IT AL C P PETER ROSEM0ER0 A CECILIA N ROSENilRO 919 MOOONILL RO VAYZATA 101 15S91 SA 92-117-2S 92 9999 91941 EDCEROOO NZLLS RO 1941 EDCEROOO NULS RO RAYZATA m S1S91 SA 92-117-2S 92 9911 •9321 ROOONILL RO J L COMIER A 0 J PAULUCCZ J L COM«R A 0 J PAULUCCZ 291 1ST ST M SANTORO PL S2771 PROP Am ORNER NAME TAXPAYER NANE/Am Si 92-117-2S 92 9994 999SA AOORESS UNASSICNEO THE MATURE CONSERVANCY NATURE CONSERVANCY ISIS STN ST S I sum S19 MPLS 101 11919 Si 92-117-2S 92 9999 999SA Amiss UNASSZMEO TNS NATURE CONSERVANCY NATURE COIOERVANCY ISIS STN ST S S sum 819 NPU m S1919 39 92-117-U 92 9911 999SA AOORESS UNASSICNEO cm OP ORONO cm OP ORONO p 0 sox 44 CRYSTAL SAY Itl SSSU C\£ % ^ I WOODHILL COUNTRY CLUB I 200 WOODHILL ROAD WAYZATA, MINNESOTA 55391 •173-7333 I Orono Property ID numbers: 02-117-23 12 0001 02-117-23 13 0007 02-117-23 42 0012 Wayzata Property ID numbers: 02-117-23 11 0001 01-117-23 23 0002 01-117-23 23 0001 01-117-23 32 0002 01- 117-23 32 0001 02- 117-23 12 0001 02-117-23 13 0007 02-117-23 42 0012 P' ' V f P i Oi QA t « p I 4 I I I #7 Board of Trustees: Gordon M. Aamoth Edward N. Dayton David Delaney, Sr. Kathleen G. Farley Mama Fullerton Roger Headrick Andrew G. Hvunphrey Mary Jackley Patricia Jaffray Stephen D. Keating Rocel Kingman Jean Krogness Kent C. Larson Charles M. Moos Ede Rice Robert Simmons Roby C. Thompson Officers: D. Eldredge Jackson, III - President Charles M. Kelley - Vice President Secretary - Lili McMillan Treasurer - Betsy Massie 400 Members have an Interest in Woodhill. I have listed only the Trustees as they are the governing body. If all names are required please advise. f* BXl\ . F D. Eldredge Jackson, III, President 1055 Edgewood Hill Road Hayzata, MN 55391 Charles M. Kelley, Vice President 2720 White Oak Circle Orono, MN 55356 Lili McMillan, Secretary 1275 Lyman Avenue Wayzata, MN 55391 Betsy Massie, Treasurer 2640 Marshland Road Wayzata, MN 55391 Larry Ackman Llndc[uist & Vennum 4200 IDS Center 80 South 8th Street Minneapolis, MN 55402 Jim McCarthy Lindguist & Vennum 4200 IDS Center 80 South 8th Street Minneapolis, MN 55402 Ned Dayton 445 LeOce, #222 Wayzata, MN 55391 Mark Albrecht 200 Woodhill Road Wayzata, MN 55391 A Vi o I I I * • ! -4 • 1 J I I I I ROM : UOODHILL C. C.PHONE HO. : 6124730113 Hpr. 15 1999 09:03hM P2 m, Cr WOODHILL COUNTRY CLUB 200 WOODHILL ROAD WAYZATA. MINNESOTA 55391 473-7333 EXHIBIT A - LEGAL DESCRIPTION L C 1. 2. 3. The Northeast Quarter of Section 2, Township 117 North, Range 23 West, Hennepin County, Minnesota, except that part of said section 2 embraced within Woodhill Ridge, Woodhill Ridge 2nd Add., Edgewood Place, RLS #1596, RLS #1098, Dakota Rail right-of-way and Burlington Northern right-of-way. Part of the Northwest Quarter (NW 1/4) of Section 1, Township 117 North, Range 23 West, Hennepin County, lying south of Burlington Northern right-of- way and north of Dakota Rail right-of-way. All that part of Lot Thirty-four (34) in Auditor's Subdivision #45 lying South of Burlington Northern right-of-way and north of the Dakota Rail right-of-way. I JL I LINDQUIST & VENNUM p.l.l.p. 4200 IDS Center In D enver 80 South Eighth Street Lindquist , vennum & Christensen p l.lp. Minneapolis . Minnesota 55402-2205 600 17th Street . Suite 2125 Telephone : 612-37i^2i i D enver , Colorado 80202-5401 FAX: 612-371-3207 TELEPHONE; 303-573-5900 I I I I I Attorneys At Law James P. McCarthy (612) 371-3238 jmccarthy@Iindquisl.com April 16.1999 DELIVERY VIA MESSENGER Mr. Michael Gaffron Senior Planning Coordinator City of Orono 2750 Kelley Parkway Orono, MN 55356 RE: WOODHILL COUNTRY CLUB Dear Mike: I am enclosing several Items to supplement the Application of Woodhill Country Club to amend its 1968 Conditional Use Permit. Enclosed is a description of the amendment request and following surveys and maps: 1. 2. 3. 4. Survey of Woodhill Avenue access as of August, 1998 (three (3) large and fifteen (15) small copies): Maintenance Facility Plan, dated September 26,1988, showing maintenance facility and surrounding road (three (3) large and fifteen (15) small copies); Survey of the north half of Section 2 showing entire Woodhill Country Club area prepared by Hennepin County General Services Department (three (3) large and fifteen (15) small copies): Section map of Woodhill Country Club area with drawing to show approximate location of internal driveways and buildings. The application and supplemental materials have been submitted, although I have not yet received a signed agreement with Cliff Greene concerning the agreed terms on which the triai was postponed. Cliff has, however, made a verbal assurance that the terms are acceptable. The application and supporting materials are submitted subject to the receipt of the signed agreement concerning the postponement of the trial in the lawsuit. Doc#m3200\l LINDQUIST & VENNUM p.l.l.p. Mr. Michael Gaffron April 16,1999 Page 2 If you should have any questions, please feel free to contact me at 371-3238. Very truly yours. LINDQUIST & VENNUM P.L.L.P. mes K McCarthy JPMc/klb Enclosures cc: Mark Albrecht Edge Jackson Larry Ackman Doc« 1II3200\1 I 1 I 1 1 I - 1 • U 'J I I I exH, I APPLICATION OF WOODHILL COUNTRY CLUB This application is submitted in an effort to resolve the lawsuit between Woodhill Country Club and the City of Orono. Woodhill has agreed to submit this request for an amendment to its 1968 Conditional Use Permit without prejudice to Woodhill's position in the pending lawsuit. Pursuant to this understanding, Woodhill Country Club requests a reaffirmation of its 1968 Conditional Use Permit to use its property as a golf course and country club with a primary and secondary access to public streets. In a good faith attempt to resolve the current lawsuit, Woodhill will agree to and request that its 1968 CUP be amended (i) to acknowledge certain basic rights of access to Woodhill Avenue, and (ii) to impose certain new restrictions and conditions on Woodhill ’s access to Woodhill Avenue. REQUEST FOR AMENDMENT OF 1968 CUP Woodhill requests that Its 1968 Conditional Use Permit be amended to acknowledge expressly Woodhill ’s following rights of vehicular access to Woodhill Avenue: 1. Woodhill can maintain an unbarricaded access to Woodhill Avenue. 2. Woodhill can gate and maintain control of the entrance to the Woodhill property at Woodhill Avenue. 3. Woodhill Avenue access shall be available at all times to Emergency Vehicles (police, fire, ambulance, and utility). 4. Woodhill Avenue access shall be available for entrance and exit by Woodhill members and Invited guests between 7:00 a.m. and 8:00 p.m. during the days that Woodhill is open. (Woodhill is closed during the month of March and on Mondays, unless Monday is a public holiday, in which case the club closes on Tuesday.) 5. Woodhill Avenue access shall be available for transporting Woodhill tractors to and from Long Lake for repair. 6. Woodhill Avenue access shall be available for general access if the Woodhill Road access to Country Road 15 is temporarily blocked (subject to reasonable notification to the City of Orono and affected neighbors). 7. Woodhill Avenue shall be available for access under the terms of that certain Easement Agreement, dated October 5,1987 between the City of Orono, Woodhill Country Club and MSM Associates (“Easement Agreement"). Consistent with the other rights under the 1968 CUP, the basic rights of access listed above shall not be either revocable, for a limited time or subject to further review for the purpose of change or revision except as permitted in Orono Code §10.09, subd. 11. Doc«MII3l02\I imJ As part of its agreement that the following types of access to Woodhill Avenue can be deleted from the 1968 CUP, Woodhill requests that its 1968 CUP be amended to require further review by the City of Orono or further amendment of Woodhill’s conditional use permit in the following instances: 1. 2. 3. 4. 5. 6. 7. Conversion of the Woodhill Avenue access into the main entrance for Woodhill on a permanent basis. Woodhill Avenue as an entrance or exit by delivery, taxi, service or other commercial vehicles. Woodhill Avenue as an entrance or exit by the general public. Woodhill Avenue as an access at time periods other than those allowed in the Basic Rights defined above. Expansion of Woodhill’s west driveway between the maintenance building and Woodhill Avenue. Bituminous paving of the driveway abutting Woodhill Avenue. Signage concerning Woodhill on Orono Orchard Road. Woodhill further requests either amendment to the 1968 CUP or acknowledgment by resolution that the right of access to the Woodhill property exists independent of any CUP process in the following two circumstances. 1. 2. Under the terms of the Easement Agreement. If all access from Woodhill to County Road 15 is permanently blocked as a result of either Highway 15 alteration or improvement or because of the railroad right-of-way, the right of reasonable access to the Woodhill Property is required and is not subject to revocation through the CUP process. DESCRIPTION OF DRIVEWAY, GATE AND SIGNAGE A gravel road bed from the end of the current bituminous paving on Woodhill Avenue to the Woodhill maintenance building has been in existence for over 100 years. Between the Woodhill property line and the current asphalt, the road bed is approximately 60 feet long. The road bed has been refreshed with gravel and bladed with varying degrees of frequency over the past 100 years. Last May, Woodhill refreshed the entire west driveway and gravel portion of Woodhill Avenue with two to four inches of Class V gravel. The gravel was placed only on top of the pre-existing road bed. Two chain posts were removed and the road was cleared of vegetation and overhanging branches. Minimum sight lines were cleared. Woodhill did not change the grade level or location of the 100 year old gravel road bed. I I I Doc# llI3i02M I I I I I I I I I I I I I The following safety measures have been, or will be, implemented: 1. Stop Sign - Westbound 2. 10 Miie-Per Hour Speed Limit - Signs In Both Directions 3. No Left-Turn Sign - Westbound Signs 4. Gravel Paving 5. New Gate 6. Sight Lines 7. Landscaping 8. Uniform Hours A stop sign is placed on the westbound lane at the point where the gravel portion of Woodhill Avenue meets the bituminous portion of Woodhill Avenue. A no-left turn sign was placed to Indicate no turns onto the private road of the Woodhill Ridge development. A 10 mile per hour speed limit sign will be posted in both directions. Woodhill believes that the reduced speed limit Is an appropriate safety measure, as are the stop signs and no-left turn signs. Similarly, the gravel pavino will also serve to slow traffic and to attract less use. The gravel will be maintained on a regular basis and will provide adequate road structure for the limited amount of traffic anticipated for this access point. This type of gravel paving has been utilized at this exact location for equal or greater levels of traffic for many decades. A new gate will be constructed for Woodhill Country Club. This gate will be located on the Woodhill property ten to fifteen feet east of the Woodhill property line. The gate will be dual swinging and will be locked in the center. The lock device can be utilized by emergency vehicles. Both the post and the gate will be constructed of a sturdy material to provide adequate security. Covering materials for the gate will be chosen to blend in with the surroundings. Sight Line Cleaning and Landscaping will be undertaken as necessary, but not in a way to attract increased use of the back entrance. Since after-dark use is not contemplated, no additional lighting of the area is proposed. Woodhill proposes that the access be open during uniform daytime hours . Regular daytime hours will promote safety by creating uniform expectations for neighbors and members. Such hours will minimize turnarounds. They will not require neighbors or residents to consult watches and calendars when using Woodhill Avenue. If the City believes it desirable to have different or additional signage, different paving of Woodhill Avenue, or different paving of the west driveway between the Woodhill maintenance building and Woodhill Avenue, Woodhill is willing to discuss such alterations to the existing driveway and street. Doc#U13102\l 3 ZONING STATUS Woodhill Property currently zoned an RR-1B and was formerly zoned R-1BB. Ever since the adoption of the current zoning district system in the City of Orono, golf courses and country clubs have been conditional uses in the RR-1B (formerly R-1BB) districts. On adoption of the new zoning system, Woodhill applied for and obtained a conditional use permit in 1968. The 1968 CUP is attached as Exhibit 1. The 1968 CUP placed no time period and imposed no conditions other than operation as a golf course and country club. All current and former city staff and the council member who moved the 1968 CUP agree that the Woodhill permit was for a permitted conditional use, not a non-conforming use. The CUP permit shows both the 'A/o^dhill Road access to County Road 15 and the west driveway access to Woodnn Road. (Robert Searles, the Orono council member who moved to grant the 1968 CUP, testified that he knew and used Woodhill Avenue, believed that Woodhill Avenue access to be part of Woodhill ’s CUP application and intended the CUP to allow unrestricted use of the Woodhill Avenue access.) The 1968 CUP to operate W'oodhill Country Club as a golf course places no limitation on the use of the west access to Woodhill Avenue. The "use" authorized by the 1968 CUP - golf course and country club - has never lapsed and the 1968 CUP remains in full force and effect. Various levels of pedestrian, bicycle, and vehicular traffic on Woodhill ’s primary and secondary access have not caused the 1968 CUP to lapse. Neither the 1968 CUP nor any Orono ordinance places any minimum level or frequency of pedestrian, bicycle, or vehicular traffic necessary to retain the right of access mcognized in the 1968 CUP. Since 1968, Woodhill has obtained additional conditional use permits for the construction of three new structures (tennis courts, maintenance building, and a pump house) that were not shown or Included on the 1968 CUP application (unlike the Woodhill Avenue access) and a land alteration permit in connection with work on a driving range. The driveway on the Woodhill property that runs west from the maintenance building to the western properly line of Woodhill Country Club is not a “private road ” under the Orono ordinance k is simply a driveway located on Woodhill ’s property. The driveway abuts a public -ireet. I I I I I I 1 1 I I I Docf»ni3102\l • * H I I I WOODHILL AVENUE: A PLATTED AND OPENED PUBLIC STREET FROM ORONO ORCHARD ROAD UP TO THE WOODHILL COUNTRY CLUB PROPERTY LINE. This street was initially platted and opened as a public street in 1887. The eastern 150 feet of Woodhill Avenue has always curved to the south outside of the 1887 platted right-of-way to avoid a steep hill. Although not in the 1887 plat, this portion of Woodhill Avenue has been a dedicated and open public street since it was dedicated by common law by the prior owners of the property, John Pillsbury and Alfred Crosby. (Affidavit of John Pillsbury.) Once the street was dedicated and used, it became an opened public street that can be closed only by public vacation proceedings which have never occurred. To the contrary, in 1987, this common law dedication of the last 150 feet of Woodhill Avenue was incorporated into a formal plat, extending in a triangle line from the original 1887 plat up to the Woodhill Country Club property line. The City of Orono has a duty to maintain a platted and opened public street and abutting land owners have a property right of access. In 1988, Woodhill Avenue was widened and paved. The parcel of Woodhill Country. Club abutting Woodhill Avenue (PID No. 02-117-2312-0001) was specially assessed $9,464.70 by the City of Orono for the improvement and the bituminous paving of Woodhill Avenue. Since state law flatly prohibits the imposition of special assessments on parcels of land that are not benefitted by improvements, the Woodhill property is deemed by law to be benefitted by the Woodhill Avenue paving. HISTORICAL USE OF WOODHILL AVENUE ACCESS For many years Woodhill Avenue, formerly “Hamlet Street," was the only public street access to the farm property now utilized by Woodhill (the original farmhouse and barns were located in the general vicinity of the current barn and maintenance building). Since approximately 1917, Woodhill Avenue has served as the secondary access to the country club. The primary traveled access is from Woodhill Road to County Road 15. From 1917 until 1980, Woodhill Avenue was used regularly by club members, guests, employees, and service and delivery vehicles. Over the years, Woodhill has had various types of gates on its west driveway, which have been opened and closed at various times. Since 1980, WCC has voluntarily limited access to pedestrians, bicyclists, and very limited vehicular traffic (maintenance staff and maintenance equipment). In 1980, a new chain was run between new concrete posts which were placed to allow vehicles to pass if the chain was removed. When Woodhill voluntarily imposed the limitations on vehicular traffic in 1980, the President of Woodhill wrote to the City of Orono as follows: Doc# 1II3102M As you know, by taking this action we do not , in any way, want to limit our right to use the back entrance , should future circumstances warrant a change in this decision, (emphasis added) In 1987, the Orono City Administrator wrote to the Orono City Council stating: It is our present understanding that Woodhill could begin utilization of this access at any time they choose. Pedestrian and bicycle use has increased in the past years with the increased popularity of both bicycling and exercising. Since 1980, the driveway has been used only for the vehicles of the maintenance staff and certain maintenance equipment, when it is brought to Long Lake for repair. On at least two occasions since 1980, the Woodhill Avenue access was used as the general entrance to Woodhill because train derailment and track construction temporarily blocked any access to County Road 15. CURRENT AND FUTURE TRAFFIC AND SAFETY CONCERNS THAT REQUIRE FULL RESTORATION OF DUAL ACCESS TO WOODHILL COUNTRY CLUB Woodhill Country Club has had a dual access to its property since 1917. Woodhill Avenue has always been the secondary access, except on those occasions when County Road 15 access has been temporarily blocked. Since 1980, the traffic and safety concerns surrounding Woodhill Country Club has changed dramatically. Traffic on County Road 15 has increased greatly in both volume and speed. Daily traffic counts increased from approximately 5,000 cars per day to over 20,000 currently. The construction on Highway 15 last summer (1998) and this summer (1999) have raised special problems for use of Woodhill Road. Sight lines have been blocked and access has been very difficult. After construction is done, the improvements to County Road 15 will only foster Increased traffic and increased speeds on the highway. The raised elevation of the highway has made the approach from Woodhill Road steeper and more difficult to traverse in winter conditions. Woodhill members who live to the west and north of the Club (e.g. Lyman Avenue, Long Lake, Medina) currently drive down Orono Orchard Road, take' ,ft on Highway 15 going east, and then another left, across oncoming cross-traffic to enter on Woodhill Road. These turns can be dangerous at any time of the day. They are particularly dangerous and difficult during heavy traffic periods. The turns pose dangers to children being transported to the club and teenage and elderly member drivers. The turns are completely unnecessary if those members were able to utilize the Woodhill Avenue access to the country club. Any reduction of cross-traffic turns on Highway 15 will Improve safety, not only for Woodhill families but also for a*l Orono citizens and for the general public traveling on Highway 15. I Doc« 1I13102\I I r I I I ^ I There are no reasonable alternatives to addressing these safety concerns, other than through the long-used secondary access at Woodhill Avenue. The dangers associated with Highway 15 arise not just from the construction activity, but will continue after the road is improved. The improved road will attract more traffic which travels at a higher rate of speed. In terms of secondary access to a public street, Woodhill Avenue is the only available access. On the east, north, and south, the Club is land-locked by railroad tracks and highways. On the southwest and west sides, Woodhill Avenue is the only point where the Club owns property that abuts a public street. There is no other location that Woodhill could use without having to acquire property rights and build a road. In contrast, Woodhill Avenue is a century-old road that abuts the Woodhill property. Given the historical use of the road, Woodhill has a constitutionally protected property right of access to Woodhill Avenue. The driveway on the Woodhill property and the public street abutting the property can be used without any purchase of additional property. Woodhill Avenue also provides the shortest connection to any public street. Acquisition of property and construction of a new road through a different neighborhood would disrupt more homes and create greater construction problems than the removal of the chain on the century-old access at Woodhill Avenue. The membership size and activitv level at Woodhill Country Club have not changed greatly since the issuance of the 1968 CUP. Family memberships are kept at 400, which was the approximate membership size in the 1960’s. Many members do not actively use the club facilities. The popularity of golf has increased, however, there is a decrease in tennis activity. Horse-riding and skeet shooting have been eliminated at the club. Social activities remain approximately the same. Woodhill has fairly limited social use of the club facilities in comparison to other country clubs. For example, parties including non-member invited guests are currently scheduled on only 14 of the 153 days in the five-month period between May 1 and September 30,1999. Use of the Woodhill Avenue access will be made almost exclusively by those members whose homes are geographically located to the west and north of the club. With the westward expansion of the suburbs, more members now live to the west and north of the Club than in previous decades. The maximum number of active members who live in this limited area would utilize it on any given day is unlikely to ever exceed 50. Most days, the number of active users is more limited. Woodhill estimates that traffic will be in the range of 20 to 30 trips per day on weekdays, and possibly 60 on weekend days in the summer months of June and July. This number will be reduced in May, August, and September and will be greatly reduced during the periods of October through April. The Club is closed during the month of March. The restoration of dual access for vehicles to the Club will improve overall safety for Woodhill Country Club members, their guests, residents surrounding the Club, and the general public. Currently, all traffic from the country club (members, guests, employees, and service and delivery vehicles) is routed along Woodhill Road which Doc«M113102M 4 also serves 11 families (compared to 6 homes on Woodhill Avenue). It will improve traffic safety for everyone on County Road 15. It will also greatly increase traffic safety for those members who live to the west and north of the Club. As discussed below, it will not create any substantial traffic impact on Woodhill Avenue. WOODHILL AVENUE CAN SAFELY HANDLE THE LIMITED TRAFFIC FROM WOODHILL COUNTRY CLUB The anticipated level of traffic on Woodhill Avenue will be less than the traffic during the many decades Woodhill Avenue was a gravel road. During those decades, there was no hour limitation and no limitation on commercial or delivery traffic. It was used by members, guests, and employee families who lived in two homes on the Woodhill property near Woodhill Avenue, and their guests, as well as by numerous delivery and service vehicles, including large oil delivery trucks, food trucks, and septic tank trucks. The conditions proposed in this application severely limit the scope of the access. The 22' wide bituminous paved Woodhill Avenue is more than adequate to handle an additional 20 to 60 trips per day. Woodhill Avenue is wider than and paved as well as Woodhill Road that currently carries all club vehicular traffic. The anticipated traffic from the country club on Woodhill Avenue is not appreciably greater than the traffic on Woodhill Avenue at the time the three houses with driveways directly onto Woodhill Avenue were built. Indeed, there was probably more traffic at that time from the barn, horse stable, skeet range, and employee houses. This is particularly true of the Wood ’s residence, which was built in the late 1950 ’s. The two residences located at the intersection of Orono Orchard Road and Woodhill Avenue have a limited impact from the restoration of the Woodhill Avenue access. Approximately the same number of cars would pass by these residences since the persons who will use the Woodhill Avenue access currently pass by those two houses on Orono Orchard Road to and from County Road 15. There are currently three homes located in the Woodhill Ridge development that have driveways that access the private road, which in turn intersects Woodhill Avenue. The distance from the garage of the cul-de-sac (Mailie residence) to the Woodhill Avenue intersection of the Woodhill property line is only slightly less than the distance from Orono Orchard Road to the Woodhill property line. Given the large lots and long driveways of the three homes in the Woodhill Ridge development, these houses will have no club traffic directly in front of their houses. Given the location, width, and length of their private road, there is more than adequate distance to enter and exit their driveways safely without encountering any traffic from Woodhill Country Club. The no ­ left turn sign currently placed on Woodhill Avenue and the natural flow to Orono Orchard Road should prevent any use of the private road by Woodhill members. I I I *• • I Doc« I113102 M 8 I I I I I I I I I I I I I I i I 1 I I Furthermore, Woodhill will provide periodic reminders to club members concerning the traffic rules and safety concerning the Woodhill Avenue access. The entrance from the Woodhill Ridge private road onto Woodhill Avenue does not pose any significant traffic hazard. The 10 mile per hour speed limit, gravel paving, and stop sign will slow and then stop all traffic exiting from the country club. These three homes would yield extremely limited number of trips per day from the private mad onto Woodhill Avenue. If the Woodhill Ridge owners desire, the intersection could be turned into a three-way stop sign, although it is unclear that additional stop signs are desirable. Two neighbors have voiced concern about their school-age children. The large lot size, long driveways, and the long private road place an adequate distance between any Woodhill Country Club traffic and the children in the immediate vicinity of their homes. When children proceed down their driveways and private road to the intersection with the public street, the stop sign, reduced speed limit, and no-left turn provide greater protection than found in most intersections of driveways or private roads with public streets. While pedestrian or bicycle use by children of the public street will expose the children to a greater level of traffic on Woodhill Avenue than is present today, the level of traffic is substantially less than the level of traffic usually encountered on residential public streets in Orono and elsewhere. Traffic levels are not greater than the historical levels of Woodhill Avenue prior to the 1980 limitations on vehicular use of the access. While the anticipated levels are greater than they had been during the more recent years, the projected traffic level does not constitute a high level of traffic for a residential, public street. The opening of the access should have no effect on the level of traffic on Orono Orchard Road. Most of the anticipated usage the Woodhill Avenue access will have will come from members who would otherwise drive on Orono Orchard Road to and from County Road 15. Doc<< 'M3I02\I ?4flllage of Orono pDITIOKAl USE PERlfflTto. -*-Dsts For No&*Con£orBlng Uso I il* f f V « \% *. •. * 1 2 1 mry• •I «•« 3l A- kV ^ , •. •. . \ \ Fee Case No.__ VILLAGE OF ORONO " w:>'!tal Bay, Minnesota (Complete in Duplicate) Bn T and for retoning^**dlviding or^consolidatln® '**« permitsstreets, alleys and varianlel! parcels of land, vacating Tony Kallas Address 900 Shoreline DrwT - - - - - Applicant (other than owner): Name Phone tlT. Address ■ Engineer: Name_ _ Land Planner: Name Subdividar: Name Relationship to Owner Location (How do we find it?) Phone No. Phone No. Phone No. Legal Description: Date Acquired Date of last division of this pruperty Do you own any adjoining prcperty?^ Plat 41302T Parcel 3802_ _ _ Area (sq. ft.) ISO Ac Separate Ownership Single Ownership _Non^CgnPoralny V . • • Inspection Dept: yn 'x^dministrator: Village Council: Village Engineer: J Signature of Applicant record of action TAKEN Action r, if \viiiage Attorney: Planning Commission: jj \Village Council: ^03^ MdyOf Permit Issued: Date tEP 1 3 1908 ✓ X ■C-ond^ion of Non-Conforming Use: Approximately 150 acres in Orono. Club house and various accessory buildings for entertainment. Private club.^ • 1; ..i i Page 3 VILLAGE OH ORONO questionaire for existing non -conforming conditional use , permit application 1) Name of business and owner address of property where business is conducted COouui A2 izk^ 3) Date business began Zf^ STATUS OF BUSINESS fN MARCH 11. HS7 1) WI^ was the nature cf your business on this date^-Z^ X./ , l:(rhx/tU^ . 2) How many buildings of what type and sire, and location were used for your business on this date /L How much and what kind of equipment used for business on this date ‘VVc.4-*>*-^ /Q^x_-4L C-^ ■ /- •Kj'# ki.*. '3d~ tJLrt> STATUS OF BUSINESS ON MARCH 10, 1967 1) What was the nature of your business on this date A a > A- s fi >• •i .* ;V J? & 'M? V I . Wi ' «%r\•r; -I € JiJ- •• • Page 2 Page 4 ^) How ,.udi„*s Of wH.. ,,pe. si.o. .n, „„ ^ business on thle date 3) How much and what kind nf ' -- - - --- --kind of e,uip„„, „3., €1^- -, What was ^e condition of bnUdin.a on tMs date . J. ^ CdL-s^cXirtclaw, Hsrch U. I9S7 aXd Mf«h°lJ .'ms^'pulfi sn?e ‘dlte“ljd"i,e"“"" V ; ^ , _____ l s i gn e \ Title % ii T? .Jk K I o oo I I Ul i§8!r if EXISTING CONDITIONS EXHIBIT PREPARED FOR WOOOHILL COUNTRY CLUB SATHRE-BERGQUIST. INC. 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ON EAST SK 7 • o , / ANCHOR / ' ' POLE / ' ■ / PMP0» / /POWER /'POLE YliM.Sim \. ' . - ^ ^J-PWOPOSED ' • , • ' 10 l»>M 90N *. ' •' f k/! •' / ^ w“ / . •PROPOSED-) •STOP son/ LiJ > < Qoo WOODHILL AVENUE DETAIL FOR WOODHILL COUNTRY CLUB / / ■■■ ^ROPOSCO 'v-v • to MPH scn A'*^ SHOP K.OOR ELCV / / \ ( \ ^ POND y \ / AOe 4” CLASS s 1O0S CRUSICD UCSTOIC DQS1MC GRAVa BASE FOR A MNMM 8” 1HCKNESS. \HAMTAM DUST CONTROL OURMC CONSTRUCTION. ' ' ' ' ^\ / ' / > 'CATE WOOD ON WIST SOE ON CAST SBC 7.0, / AMCHOR // ^ •• »^ // U > < X Q Oo /•» t ---------------- 'OODHILL AVENUE DETAIL FOR i/OODHILL COUNTRY CLUB yf^Kr. H . '■■Vi Cou^-'rAT CC^^fS /?AA/a^AC<^ C/CCULATJ O/^T y-2?-99 / A / PAA^a^acc yfAf/) - aS^Zoo t Ja. -r, ^ 0.30 t aq r/r<^ of KCtt\yC. - /o ^ to ~ S. o "^/nk.. £'7. o Aan^oFf \." =: 0,v Ci,c- c LA = o.H (s.o) (0,30) = o, Local atoo - CIA - O.H (7.o)Co.3o) ^ 0.3Y CfJ 2. A/ica 2 £AA/a ^a CC /ACa - yzoo t JO.fr. ^ C?./7 t AC, r///C or C<?A^c - AO fh,^^ ^ ' 7. O "Vha /O /o<^ ^UK^afF COfF^^C/f*-'T C. ** ^ o, Y 0,/o - C£oA ~ (s.o^( o.n) “ o.3y Q/00 " CX,oaA Z (1.0) (0./7) :r O.YS^ Cf’S I I # •• i t - ! :oHint6mk«|,lH. 482Tamarack Am Longyo.lM SS35S « i I I I I I I I I I I L I I! ’ 04/30/99 15:38 NO.583 P0O2 s-1 LINDQUIST & VENNUM p.l.l.p. 4200 IDS CCNTCA IN OENVtiV 00 South EKJ hth Sthsct Lihoquibt. vem>«v;m a p Minncapous. Minnesota 55402-2205 COO i7THST«enr^Suite 2125 TcuiPMOMC: 612-371^211 OiWER. COv0AAOO60202«5401 PAX: 612471-3207 tSlfePHONC: 303-5734900 ArrORNr^'sATUw Jumcs P. McCarthy (512)3710233 jmccarlhyiRhndquisi.Ccni April 50.1999 ■ VIA FACSIMILE TRANSMISSION and FIRST-CLASS MAIL Mr. Michael Gaffron Senior Planning Coordinator City of Orono 2750 Kelley Parkway Orono, MN 55356 RE:WOODHILL COUNTRY CLUB PROPOSED AMENDMENT TO 1968 CONDITIONAL USE PERMIT Dear Mike: I am enclosing a copy of the report prepared by the Parsons Brinckerhoff firm, analyzing the traffic Impact of Woodhill’s proposed CUP Amendment. I am enclosing a copy of the original report and two copies. If you need additional copies, please contact me and I will have them forwarded to you immediately. You have also already received three engineering plans from Coffin & Gronberg. The first shows the existing access area with proposed gate and signage. The second drawing Incorporates various improvements suggested by City Staff. The third drawing shows drainage compulations. The work submitted to you by the Coffin & Gronberg engineering firm and the Parsons Brinckerhoff engineering f rm contains more detailed descriptions of the roadways and proposed signs then were In the narrative portion of Woodhill’s CUP Amendment application. Both the dimensions of roads and placement of signs, etc. contained in the engineering reports supercede the descriptions contained in Woodhill’s CUP application. If It would be helpful for either you or the City Council, I would be happy to submit an updated version of the CUP Application incorporating the details contained in the engineering reports. Please let me know how you would like me to proceed in that regard. Do<*lll74«3\t . ...mm....uuatill ' 04/30/99 15:38 MO.583 P003 I LINDQUIST & VENNUM p.l.u.p.I Mr. Michael Gaffron April 30,1999 Page 2 I If you should have any questions regarding the report or any other matter concerning the application for amendment to the 1968 CUP, please feel free to contact me at 371-3238. I look forward to reviewing a draft of the staff report so we can address any questions or concerns the staff may have. Very truly yours, LINpQUIST & VENNUM P.L.L.P, Jamfes P. McCarthy ^ ♦ JPMc/klb Enclosures cc: Mark Albrecht Edge Jackson Tom Kellogg, City Engineer f • -I Ooc# 1117463-.1 '» I I I I i _ D S'2 srsi Pmr»on9 Brtnck^rhoff •*.*w « 510 First Avenue North Suite 550 Minneapolis, MN 55403 612-371-0443 Fauc: 612-371-4410 -ICOYWAM A April 30. 1999 MAY 0 3 1999 Mr. James McCarthy Lindquist & Vennum 4200 IDS Center 80 South Eight Street Minneapolis. MN 55402-2205 Cl i V Or Oi iC’.vO Re;Woodhill County Club Traffic Access Dear Mr. McCarthy. Parsons Brinckerhoff. Inc. is pleased to present a traffic study examining the impact on traffic patterns and traffic safety by Woodhill County Club's proposal to restore regular vehicular access to Woodhill Avenue. The information contained in the traffic study was obtained from on­ site observations, the City of Orono, Hennepin County. Minnesota Department of Transportation. Woodhill s proposed amendments to its 1968 Conditional Use Permit, Woodhill’s By-Laws, Coffin & Gronberg Inc. engineering plan dated 4/23/99. and accepted pri.ndples of traffic engineering. Our report provides a review and summary of the: Existing Access Description and Issues Woodhill’s Proposed Use of its Secondary Access to Woodhill Avenue Traffic and Safety Impacts of Proposed CUP Amendment SUMMARY OF CONCLUSIONS Woodhill County Club’s CUP amendment proposal will have a minimal impact on Woodhill Avenue and the Woodhill Ridge development. It will improve safety for Woodhill families and overall improve traffic safety in Orono. on Woodhill Road. Woodhill Avenue, CR 15, and Orono Orchard Road. EXISTING ACCESS DESCRIPTION AND ISSUES The Woodhill Country Club is served by two access points. The south access (Woodhill Road) is the main entrance to the club. The west access (Woodhiil Avenue) has been a secondary access since the club was built in 1915-1917. A history of the club's use is contained in Woodhill *s CUP application. The access has not been used for regular vehicular traffic since 1980. Unlike most county clubs, Woodhill has a very defined set of rules on membership size and use of the club outside of family social occasions Family memberships have been limited to about 400 for decades, resulting in less daily activity and special social activities than most clubs As described in this section, the club places significant constraints on members using the club for any political or business entertainment purposes. These limitations result in relatively lower levels of traffic in and out of the club 0v9ra Cantury of Mnglnoorlng MxaoUeneo 10Q Woodhill RoadVtARM Geometries Wot'dhill Road is a local residential roadway connecting Woodhill Country Club and CR 15 over a distance of approximately 1200 feet. Woodhill Road serves eleven residential homes and is the main entrance to the Woodhill Country Club. The roadway is paved, curvilinear in nature, with a width varying from 18' 4" t o 21 ’ 6 ". Traffic Volumes Woodhill Road traffic volume counts we'^e taken by the City of Orono on Friday September 25th through Sunday September 27'^. Tuesday September 29''’ through Wednesday September 30“’. and Thursday October 1*' through Friday October 2"''. 1998. The traffic counts indicate an average weekday traffic volume of 20 to 40 vehicles per hour on the roadway. During the weekend, traffic averages around 25 vehicles per hour. The exceptions were a short spike on Thursday night when 160 vehicles used the roadway in one hour (6;00-7:00PM). and on Saturday night when 65 vehicles in one hour (7;30-8;30PM) used the roadway. This increase in traffic correlated to a wedding reception being held at the club. We have been informed that the club's 1999 social event calendar indicates this type of event will occur approximately 15 times between May 1 and September 30. The club‘s bylaws place unusual limitations on usage for business and civic purposes. Business and political entertaining is prohibited and civic and non-profit functions require executive committee approval: Policy if 1... The Club prohibits the use of its facilities for commercial or political purposes. Policy ff2... With prior approval of the Executive Committee, a civic or non-profit organization may on occasion use the Club facilities for social purposes if sponsored by a Family Member. Even including these higher usage periods, average weekday traffic on Woodhill Road was approximately 400 vehicles, and average weekend traffic was approximately 500 vehicles. This number will be greatly reduced during the winter months of October through April, with the club being closed in March. Intersection with CR 15 Woodhill Road's intersection with CR 15 is located on a generally level segment of CR 15. Hennepin County is in the process of upgrading CR 15 from a two-lane roadway to a two-lane roadway with a two-way center left-turn lane and right-turning lanes at driveways and roadways. In addition to the widen! ig. CR 15 is being redesigned with super-elevation around the slight curve near Woodhill Road (source; Hennepin County DPW). As a result. Woodhill Road is being raised by approximately one foot. Because of the adjacent crossing of the railroad tracks, which fixes the roadway elevation, the combination of widening and raising CR 15 increases the slope of Woodhill Road at its approach to CR 15. This creates the non-optimum situation where the vehicle must wait for a gap in traffic on the Ovar a Cantury of ttnglneerlng Mxeallanea JL I ‘ I I n.^ I tco ttA;>S upgrade of a hill. The situation restricts the exiting vehicle's line of sight due to the incline of the vehicle and may restrict acceleration during snow and ice conditions. Emergency Access Issues Woodhill Road also serves as the only access point to the 11 residential homes and Woodhill County Club for emergency vehicles. This results in several safety problems unique to Woodhill Road: Woodhill Road is crossed by railroad tracks which are occasionally blocked by slow- moving (10 mph) trains twice a day. eliminati.ng any emergency response possibilities until the train passes. Trains using the railroad tracks have occasionally derailed and blocked access. Any derailment can block access to the eleven homes and county club for several days. Emergency vehicle access to the Country Club could be cut off by an accident along Woodhill Road. The distance from CR 15 to the areas most likely to have a need for emergency medical care or fire suppression would be difficult to reach effectively in a blocked condition. While Woodhill Road meets AASHTO A Policy on Geometric Design of Highways ana minimum residential street guidelines of 18'. the roadway's width (sectiii .'j of 9 ■ lane width) could block emergency vehicle access to the Country Club i:. a stalled vehicle situation, particularly in winter snow storage conditions Woodhill County Club is served by Long Lake Fire Department and Ambulance, located northwest of the club at the intersection of TH 12 and Brown Road Emergency vehicles do not currently have any alternative access. Woodhill Avenue Woodhill Avenue has been a secondary access since the club was built in 1915-1917. Since 1980. the access has been used for transportation of club maintenance equipment to long lake, but has not been used for regular vehicular traffic. Pedestrian and bicycle access has always been maintained. Geometries Woodhill Avenue is approximately 875 feet in length and serves as a local public street to six residences and the western access to the Woodhill Country Club. The roadway is generally level and straight in nature, with a slight bend in right-of-way alignment approximately 200 feet from its eastern terminus at the Woodhill County Club property line. A private residential roadway to the south joins Woodhill Avenue approximately 90 feet west of the Woodhill property line. For a majority of its length the roadway traverses a wetland, and no driveways exist or are possible. Woodhill Avenue is approximately 24' 9 " in width throughout its length. Near the intersection with Orono Orchard Road the roadway widens to 25 ' 2 " before flaring into the intersection. Woodhill Avenue is 3' to 5' wider than Woodhill Road (18 ' 4 "-21 ’ 6 ") and approximately the same width as Orono Orchard Road (25 ’ 2 ") between CR 15 and Woodhill Avenue. Ov»r a Cantury of Mnginooring Exeatlaoeo mM- ars>- •%. 100rtAna Woodhill Avenue was substantially improved in 1988 when the Woodhill Ridge development was built. Woodhill Avenue was widened from a “ 20 foot graded and 16 foot bituminous surface ” (1987Bonestroo Rosene Report on Woodhill Avenue Street Improvement) to 25 ‘ in width and an asphalt base. Traffic Volumes Woodhill Avenue serves approximately 60 vehicles a day (based on national averages of 10 trips/household). The City of Orono performed a traffic count on December 12. 1998, indicating an ADT of 47 vehicles, confirming the general traffic volumes on the roadway. Hennepin County traffic mapping indicates Orono Orchard Road has a traffic volume of approximately 1800 vehicles a day. Intersection with Orono Orchard Road The "T " intersection is stop-sign controlled for Woodhill Avenue only. The stop sign is located on the left side of the approach to enhance its visibility to approaching vehicles. To conform to Manual on Uniform Traffic Control Device {MUTCD) guidelines. Woodhill‘s CUP amendment recommends a second stop sign on the right side of the roadway. Orono Orchard Road is signed for 30 mph and follows a generally curving alignment. Orono Orchard Road is 25' 2 " wide south of the intersection, widens to 40 ’ 3 ’’ north of the intersection, and located on a 66 foot of right-of-way. To the north of the intersection, there is a clear distance of approximately 400 feet and to the south there is a clear distance of approximately 200 feet. The 200 feet can be enhanced to 300 feet by removing five feet of overgrown vegetation in the public right- of-way. These distances are within the required stopping sight distance as contained in the Policy on Geometric Design of Highway and Street published by the American Association of State Highway and Transportation Officials for 30 mph and roadways with a 5% downgrade. To produce conservative estimates, the calculated distances assume a wet roadway surface and a vehicle with worn tires. The stopping sight d‘5*ance allows a vehicle on Orono Orchard Road to stop prior to Woodhill Avenue. County Road IS OR 15 serves as the area ’ s primary east/west roadway and connects communities along the north shore of Lake Minnetonka and further west to TH 12.1-394 and the Twin Cities to the east. The speed limit is 50 mph at Woodhill Road. Geometries The roadway is presently under construction, and will be expanded from a two-lane roadway to a two-lane plus two-way center turning lane roadway. In the westbound direction, right-turn lanes will be added at Woodhill Road. Russel Avenue, and Orono Orchard Road Following construction, the roadway will be signed for 50 mph at Woodhill Road and transition to 35 mph at Orono Orchard Road. Traffic Volumes Average daily traffic volumes on CR 15 have increased from 13,000 vehicles in 1978 to approximately 21.000 vehicles in 1998. an increase of 60% in traffic over the last 20 years, or a growth rate of approximately 3% a year. Over a Century of Englnaarlng BxccUanca "I I I I 100riAXS Fulure traffic volumes on CR 15 east of Orono Orchard Road are predicted in Hennepin County ’ s long-range Tran$:portation System Plan (TSP) to be approximately 24,500 vehicles by the year 2010, and approximately 27,000 vehicles in the year 2020. The 20 year projection constitutes a 30% increase in traffic over existing volumes. Using Mn/DOT State Aid Design Criteria guidelines, roadway between 15,000 to 30,0000 vehicles per day are typically built with four travel lanes To reflect the limited access nature of CR 15 east of Orono Orchard Road, and the environmental constraints, the roadway has been redesigned as a single through lane in each direction, with a center left-turn lane, for a three lane cross-section. intpraection with Orono Orchard Road The intersection of Orono Orchard Road is difficult for vehicles on Orono Orchard Road and dangerous for through traffic on CR 15 because of (1) sight lines, (2) speed of traffic and (3) traffic volumes. The intersection of Orono Orchard Road and County Road 15 has safety limitations because tne sight distance between the north on Orono Orchard Road and the west on County Highway 15 is reduced by the curve on County Road 15. Hennepin County has recognized the situation by planning to sign CR 15 for 35 mph in this area (source: Hennepin County DPW). However, absent constant enforcement, traffic is likely to exceed the limit, based on the 50 mph limit between the 1-394 exit and Woodhill Avenue on the similar CR 15 roadway cross-section, the improved paving of CR 15, and CR 15's proximity to a freeway exit ramp. In addition to sight distance restrictions and traffic speed, the 60% increase in traffic along County Road 15 over the past 20 years has resulted in extensive delays for vehicles entering or exiting County Road 15 at Orono Orchard Road, and created a difficult left turn situation. The increasing traffic following reconstruction of CR 15 will increase vehicle delay between Orono Orchard Road and CR 15. Levels of Service (LOS) for Orono Orchard Road left-turning vehicles are presently at LOS F during the weekday AM and PM peak hour periods and summer weekends. LOS F indicates there are insufficient gaps of suitable size to allow a side street maneuver to safely cross through the CR \ 5 traffic stream. In this case, Orono Orchard Road traffic on average waits over a minute for a gap in CR 15 traffic to turn left. As traffic continues to increase, and gaps in traffic decrease, drivers will tend to make crossing maneuvers of CR 15 that may compromise the "critical gap " safety amount, resulting in CR 15 traffic unexpectedly slowing down by applying their brakes and increasing the chances of accidents. Unsignalized intersection LOS grades are established by Highway Capacity Manual, produced by the National Cooperative Highway Research Program and the Federal Highway Administration. Grades run from “A" (little or no delay) to "F" ( very long delays - demand exceeding capacity) Woodhill Country Club members who live west and north of the Country Club must now use the Woodhill Road access. Under the existing access structure, these members currently take Orono Orchard Road to County Road 15. They then make a left-hand turn on to County Road 15 and another left-hand turn from County Road 15 onto Woodhill Road. In exiting the Club, they make a right-hand turn onto County Road 15 followed by another right-hand turn onto Orono Orchard Road The approximately 30 turning maneuvers per day per direction at this intersection resulting from Woodhill members Ovor a Century of engineering Sxoellenee t k 100rwAfis add to the dangers and increase delays, both for Woodhill members and for the general public driving on County Road 15. WOODHILL COUNTRY CLUB ’S CUP AMENDMENT PROPOSAL In its proposed amendment to its 1968 Conditional Use permit. Woodhill Country Club has proposed reestablishing regular vehicular traffic on its Woodhill Avenue access. In connection with this proposal. Woodhill Country Club has proposed the following configuration: 1 A gravel driveway approximately 20-22' in width from its maintenance building to the existing bituminous pavement on Woodhill Avenue. 2. 3. 4 A gate at the western edge of its property to be dosed when access is not available. A 10 mile per hour speed limit. Signs in both directions. A no left-turn sign at the intersection of Woodhill wenue and the private road to the Woodhill Ridge development. A stop sign for westbound traffic on Woodhill Avenue at the intersection of the Woodhill Ridge development. A stop sign for eastbound traffic on Woodhill Avenue at the intersection of the Woodhill Ridge private road, with a stop ahead sign placed in advance for eastbound Woodhill Avenue motorists. A stop sign on the north side of Woodhill Avenue at the intersection of Woodliill Avenue and Orono Orchard Road for westbound motorists. 8.A painted bar line on the western end of Woodhill Avenue to indicate the stopping position at the intersection of Woodhill Avenue and Orono Orchard Road, together with lane division line 50 ’ feet back from the bar line. Woodhill proposes the following restrictions on the use of its Woodhill Avenue access; 1. The hours of access will be limited to 7 a.m. to 8 p.m. on the days that Woodhill Country Club is open. The Club is open 6 days a week, being closed on Monday (unless Monday is a holiday, in which case it is closed on Tuesday). It is closed during the month of March. 2. No commercial, delivery, taxi, or service vehicles will be permitted access. 3. Woodhill will permit use of the Woodhill Avenue access only to members and invited guests during the hours described above. 4. Access by emergency vehicles will be allowed at all times. 5. General use of the access will be permitted if the access to County Road 15 is temporarily blocked. TRAFFIC AND SAFETY IMPACT OF PROPOSED CUP AMENDMENT Traffic Volumes Traffic counts were taken by the City of Orono on Woodhill Road in September and October of 1998. The counts indicated weekday volumes of no more than 400 vehicles, and weekend counts of no more than 500 vehicles. Over a CBittury of Kngtneoring txeolloneo i- I I I I I I I I toortAms Based on the existing roadway system, and the metropolitan area ’s population, CR 15 and Woodhill Road would be the preferred access for a majority of the club’s members and visitors. Under Woodhill's proposed CUP amendment, all trucks, service, delivery, taxi and commercial vehicles will remain on Woodhill Road. The club estimates approximately half (50%) of the weekday and weekend vehicle trips are visitor, staff, or service trips that will not use the Woodhill Avenue access Based on the club ‘ s membership list, no more than 25% of Woodhill members live west and north of the club and would possibly travel to and from home via the Woodhill Avenue to access the club. Of the 250 member related weekend trips, it is therefore estimated that no more than 60 trips (i.e. 30 members per day) would use the Woodhill Avenue access, with no access to Woodhill Avenue proposed after 8PM. Woodhill Avenue Roadway Capacity Woodhill Avenue has sufficient roadway capacity to accommodate the increased traffic. It is wider than Woodhill Road that currently carries all Woodhill country Club traffic and it is the same paved width (24' + ) as Orono Orchard Road that carries 1800 vehicles per day. While it is not unusual for two-lane roadways to carry 5.000 or more vehicles per day. residential streets typically are lower volume streets and are classified on the basis of their access and daily traffic. Historically. Woodhill Avenue has served as a residential subcollector street serving both residential properties and the club. Average daily traffic capacity for these streets is defined having 1000 or less vehicles per day. (source; Residential Street ^ Ed. American Society of Civil Engineers and National Association of Home Builders.) Presently. Woodhill Avenue is serving as a residential access street, which, in the hierarchy of residential streets based on traffic volumes, are the lowest-order and carry 250 vehicles or less per day on pavement widths between 22 ’ and 24'. (source: Residential Street 2^ Ed. American Society of Civil Engineers and National Association of Home Builders.) Woodhill Avenue's potential increase in traffic from 50-60 vehicles per day to approximately 100 to 120 vehicles per day is well within both the roadway's capacity and present classification based on traffic volumes and roadway width. Intersection Capacity Four intersections will experience slight changes in traffic volumes as a result of the restoration of regular vehicular access to Woodhill Avenue. The first is the Woodhill Avenue and Woodhill Ridge private road intersection, which is presently under unsupervised control. The three-legged intersection is proposed for all ­ way stop control to limit speeds and reflect the sight distances restrictions from Woodhill Ridge. Under stop control, the intersection will operate at a LOS “A", indicating no vehicle delays or queuing at the intersection Uniform hours of access (7AM to 8PM) are proposed for the Woodhill access. The uniformity of hours will reduce the chances of members inadvertently trying to access the club while the access is closed and will create uniform expectation of usage by Woodhill Ridge and Woodhill Avenue residents.. The second is at the Woodhill Avenue and Orono Orchard Road intersection, where approximately 30 vehicles per day will turn left from southbound Orono Orchard Road and approximately 30 vehicles per day will turn right from westbound Woodhill Avenue. Cv»r M Century cf engineering Mxceltenee i tooriAft With the proposed recommendation, no capacity or sight distance constraints were * identified at the intersection. There will be no increase of traffic on Orono Orchard Road since the vehicles using the Woodhill Avenue access would normally travel Orono Orchard from OR 15 The third intersection is at OR 15 and Orono Orchard Road, which will experience a slight daily decrease (approximately 30) in both southbound left turning movements and westbound right turning movements. The reduction in cross-movements will increase safety for both OR 15 and Orono Orchard Road vehicles There will be a slight decrease in traffic on Orono Orchard Road from OR 15 to Woodhill Avenue. It will also greatly increase safety for Woodhill members who currently are required to make left- turns onto OR 15. The fourth intersection is at OR 15 and Woodhill Road, where a similar reduction (30 trips per day) in both eastbound left-tuning movements across OR 15 and southbound right-turning movements onto CR 15 will occur. The reduced conflicts will improve safety for CR 15 vehicles, and significantly improve safety for Woodhill members who are currently required to make the turn on and off CR 15 (50 mph). Geometric Design Issues Woodhill Country Club and Woodhill Avenue The design of the driveway on the Woodhill property and of Woodhill Avenue from the Woodhill Country Club property line to the current asphalt pavement does not present any traffic safety or design problem. The roadbed is the same grade and width as the road in place and used for many decades. The engineering drawing prepared by Coffin and Gronberg shows a gravel surface from the maintenance building to the property line and from the property line to the existing asphalt on Woodhill Avenue. Gradients on local streets should be less than 12 percent except in unusual conditions, (source; Residential Street 2^ Ed). The grade on the Woodhill Avenue public right of way from the stop sign to the property line is approximately 3%. The grade from the stop sign to 160 feet east is approximately 5%. On the Woodhill property between the maintenance building and the property line, there is on 50-60 foot section of the driveway that has an approximate 11-12% grade. Given the posted speed limit (10 mph), gravel paving (which slows down traffic) and approximate 160 foot distance from the western end of this driveway section to the stop sign, this grade section does not create any traffic safety concerns at the Woodhill Ridge private road intersection or on the driveway. Woodhill Avenue As presented in the Comparison of Access table below, the Country Club's Woodhill Avenue access provides a wider roadway surface, fewer driveway locations along its length, and connects with a roadway with lower speeds and traffic volumes than the present Woodhill Road. Over a Cantury of Mnginooring Kxeollonco 8 L I I o 4 ^ 4 •-1 J I I I 100 rtAitm - i Comparison of Access Woodhill Road Woodhill Avenue Roadway Length Roadway Width 2" Number of Private Driveways Existing Weekday and Weekend Traffic Connecting Roadway Name Speed Daily Traffic 1,200 feet 18 ’ 4 " to 21 ’ 6 400 vehicles 500 vehicles CR 15 50 mph 21,000 vehicles 875 feet 24 • 9 ” to 25 ■ 60 vehicles 60 vehicles Orono Orchard Road 30 mph 1,800 vehicles All these factors indicate Woodhill Avenue has sufficient capacity and design geometries to safely accommodate the anticipated traffic with the CUP recommendations. Orono Orchard Road and Woodhill Avenue As described previously, the proposed intersection modifications (stop signs, stop line) can produce the necessary intersection definition to allow for sufficient sight distance requirements and intersection capacity. Alternative Solutions to Traffic and Safety Problem The traffic design and safety problems created by the increased traffic volume and speeds on CR 15 and the safety concerns at the Orono Orchard Road and Woodhill Road intersections identified above can be improved by the Woodhill CUP amendment proposal. The restoration of regular vehicular traffic (subject to the restrictions contained in the proposal) on the club’s secondary access to Woodhill Avenue will improve the traffic situation for Woodhill members wfio live west and north of the club and will improve conditions on CR 15. There is no better method of achieving this result. The placement of policemen or traffic lights on CR 15 is not feasible for a variety of reasons. Hennepin County would not realistically allow traffic signals at CR 15 and Woodhill Road, due to the low traffic volumes on Woodhill Road and delay added to CR 15 traffic. Use of human personnel is not feasible on a long or short term basis for the same reason as a traffic light. In addition, the high speed of traffic on CR 15 creates safety concerns for both the individual controlling traffic and CR 15 vehicles subject to random periods of access control. The turn lanes built into the new CR 15 design do not solve the high speeds, limited sight distances, and “critical gap " condition on CR 15 for the reasons discussed Ovor a Century el Engineering Exeellenee £L:-S g "too above. While CR 15 is being improved, the “new " CR 15 will still present the serious problems for club members that can be easily resolved through restoration of the secondary access. Woodhill Country Club owns the property abutting Woodhill Avenue and has an existing driveway connected to Woodhill Avenue. There is no other point on the Woodhill property where Woodhill owns property abutting a public street Nor is there any location where acquisition of property, even if possible, would result in a better location for a secondary access point. Woodhill is bounded by railroad rights of way and highways on the east, north and south. Wetlands, existing homes and the golf course limit access points to the west. Woodhill Avenue is the shortest length of road and is where the public road access has been located for over 100 years. Neither Lyman/Smith Avenues nor Dickenson Street can serve as either realistic or preferable alternative routes. CONCLUSION Implementation of Woodhill* s CUP amendment proposal would have a positive impact on traffic design and overall traffic safety in the Woodhill Avenue. Woodhill Ridge private Road. Woodhill Road. County Road 15. and Orono Orchard Road area. The proposed use of Woodhill Avenue access would enhance traffic safety at Woodhill Road. County Road 15, and Orono Orchard Road by reducing unnecessary and potentially dangerous traffic turns to and from County Road 15. The proposal would enhance the safety of travel for the families who are members of the Club and live west and north of the Club, and the general public on CR 15 At the same time, the proposal is structured to have minimal impact on Woodhill Avenue and on the Woodhill Ridge private development. The proposed type and volume of traffic is well below the traffic capacity that Woodhill Avenue can safely accommodate. On balance, the traffic impact on the City of Orono is favorable and will increase traffic safety in the City and will improve traffic flow. The west access will also provide a needed alternative access for emergency vehicles and will enhance overall safety for families and club members in the area Please feel free to contact me at (612) 677-1205 to further discuss these or other traffic issues related to the CUP amendment. Sincerely. Parsons Brinckerhoff Quade & Douglas, Inc. Edward W. Axt, Jr. P.E. Senior Transportation Engineer Over • C0niL'ry of Knginooring MxeoUoneo J_ I I I I I I I I I I ] J I I J J a I I I - CHAPTER 6 STREETS AND PRIVATE ROADS (THIS CHAPTER CONTAINS PROVISIONS AS TO DEFINITIONS, APPLICATION AND SCOPE RELATING TO CHAPTERS 7 AND 8 AS NELL AS THIS CHAPTER) SECTION 6.01. DEFINITIONS. Subd. 1. Except as otherwise defined in the City Code, or where the context clearly indictes a contrary intent, the words and terms defined in Minnesota Statutes, Chapter 169, shall be applicable to the City Code, Chapters 6, 7 and 8. The following words and terms, when used in this Ordinance, shall have the following meanings, unless the context indicates otherwise: A. "Corner" means the point of intersection of the extension of lines of two public or private curb faces. B. "Curb Cut" means the opening along a street curb line or pavement edge for the purpose of motor vehicle ingress and egress from a roadway. Curb cut width shall include the width of the driveway approach and of the curb returns, if any. C. "Curb Return" means that portion of a curb next to a driveway approach which includes the radius or curvature or the ramp-type lug on commercial or industrial type pavements and which connects the driveway approach to the public or private road curb. D. "Driveway" means a paved or otherwise delineated area on private property for the operation of automobiles and other vehicles, f E. "Driveway Approach" means a paved or otherwise delineated' area, on the right-of-way between the roadway of a public or private road and private property, intended to provide ingress and egress for vehicles from a private or public road to private property. A driveway approach must provide access to a parking area, a driveway, a door intended and used for the entrance of vehicles, or other similar structure or facility. Driveway approaches shall be of two classes: a) resident driveway approaches;^and b) business driveway approaches. —F. "Business Driveway Approach" means a driveway approach rrom any public right-of-way providing motor vehicles with ingress and egress from the public or private road to any property other than a single family dwelling. G. "Resident Driveway Approach" means a driveway approach from any public or private right-of-way providing ingress and egress for motor vehicles from the public or private road to a single family residential dwelling. ORONO CC 140 (7-25-88) E § 6.05 Subd. 2. Requirement and Application for Permit. It is a misdemeanor to construct or reconstruct a sidewalkr curb and gutter, driveway, driveway approach, driveway turnaround, curb cuts, roadway surfacing or any other private improvement in any public road or other public property in the City without a "permit in writing from the City. Application for such permit shall be made on forms approved and provided by the City and shall sufficiently describe the contemplated improvements, the contemplated date of beginning of work, and the length of time required to complete the same, provided that no permit shall be required for any such improvement ordered installed by the Council. Such application shall also contain information showing the type of construction, the width and the location of an improvement on the parcel of land and the lot and block number or the parcel number and the street and house number and a profile of the proposed improvement, if necessary, and other such information as may be required by the Public Works Director. The application shall be filed by the property owners desiring to construct such a driveway approach, driveway turnaround, sidewalk, curb and gutter, driveway, curb cut, roadway surfacing or private improvements in any public xoad or any property in the City, or by his or her duly authorized agent. All such applications shall contain an agreement by the applicant to be bound by this Chapter. A permit from the City shall not relieve the holder from deutiages to the person or property of another caused by such work. These regulations shall apply to all City, State and County Roads. Subd. 3. Issuance of Permit. Such permit shall be issued by the Public Works Director, if he or she has determined that the applicant has complied with the terms of this ordinance, the permit fee hereinafter specified has been paid and the Public Works Director has approved the driveway, driveway approach, driveway turnaround, sidewalk, curb and gutter, curb cuts, roadway surfacing or private improvement in any public road or other public property in the City as requested or with stipulated changes. The Public Works Director shall have the authority to refuse to issue a permit when, in the judgement of the Public Works Director, the requested construction would impose an unreasonable hazard to the public. Such decision may be appealed in writing by the applicant to the City Council. The City Council shall have the power to affirm, reverse or modify the decision of the Public Works Director. Subd. 4. Permit Fees. The fees for permits for the construction of improvements as outlined above, shall be as set forth in the City's Fee Schedule which may be amended from time to time. ORONO CC 140-3 (7-25-88) I I I 1 1 I 1 I § 6.05 I I F. For residences hereafter constructed, the driveway approach and that part of the driveway and turnarounds which drain to the public road shall be paved with bituminous concrete blacktop or equivalent paving. Where it has been determined by the City's Public. Works Director that an eoc-isting driveway and/or driveway approach is causing a maintenance problem on the public road, including, but not limited to, the washing of dirt and gravel into the public road, the Public Works Director shall order that the property owner pave such portion of the driveway and/or driveway approach as is necessary to remove the maintenance problem. Portland cement concrete will only be allowed from the driveway up to the public right-of-way. This requirement shall not be construed to reduce paving otherwise required by performance standards in the Zoning Code or required as a condition to the granting of a Conditional Use Permit, lot division, subdivision or as designated in the approved site plan. G. Driveway turnarounds shall be required on all driveways or driveway approaches entering onto a State highway. County road or collector roadway as determined in the Comprehensive Plan, and on all entrances to public roads within the City where deemed necessary by the Public Works Director, based on traffic counts, sight distances, street grades and other relevant factors. If a driveway turnaround is required by the Public Works Director, such requirement shall be stated on any permit issued by him or her \ pursuant to this ordinance. ________________________________ Subd. 10. X Turnarounds. Business Driveways, Approaches and A. Only one business driveway shall be allowed per development unless a greater number of driveways are approved by the City, or approved as part of the site plan review. The business driveway approach shall not exceed the width of the access road or 32 feet at the property line, whichever is less in a business or industrial district. The curb cut shall not exceed the width of the driveway approach at the property line by more than 20 feet unless approved as part of a site plan. In a residential district, the curb cut shall not exceed the width of the driveway approach at the property line by more than 10 feet unless approved as part of the site plan. B. All business driveways and driveway approaches shall be paved with asphaltic concrete or equivalent material. Portland cement concrete will only be allowed outside of the public road right-of-way. C. Loading docks, ramps and vehicular entrances shall be located in such a manner that backing onto and maneuvering within the public road right-of-way is eliminated and in such a manner that driveways greater in width than that specified by this chapter shall not be required. ORONO CC 141-3 (7-25-88) § 6.05 D. No portion of a driveway approachr except the curb return shall be constructed within 100 feet of a corner in a business, commercial or industrial area, or within 100 feet of a corner in a residential district. E. Driveway turnarounds shall be required on all driveways or driveway approaches entering onto a State highway. County road or a collector roadway and on all entrances to public roads within the City were deemed necessary by the Public Works Director based upon traffic counts, sight distances, street grades and other relevant factors. Such requirements shall be stated on any permit issued by the Public Works Director pursuant to this ordinance. F. Driveways must be 10 feet from the side property line of a parcel of land except if driveway is shared by two parcels of land. _ _ __ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _-_ _ _ _ _ _ _ _ Subd. 11. Maintenance and Removal. Every driveway approach or entrance to abutting property shall be maintained and kept in a safe condition by the owner of the abutting property or by the Homeowners' Association, and any such driveway approach which shall not be so maintained and kept in a safe condition or which shall interfere with or obstruct the drainage carried by the adjoining public road or interfere with or obstruct the use of the adjoining public road for purposes of travel shall be repaired to conform with the specifications of this ordinance and the City's requirements or it shall be removed by the owner of the abutting property or the Homeowners' Assocation. Upon removal of such driveway approach, that portion of the street or right—of—way occupied by the owner or Homeowners* Association shall be restored to its former condition and all curbing shall be replaced to its former condition by the owner or Homeowners' Association of the abutting property at their expense. If such removal and restoration is not accomplished within ten (10) days of the receipt by the abutting property owner of written notice of the City to remove the driveway approach and restore the public curbing and right-of-way to its former condition, the City shall remove the driveway approach and restore the public road, curbing and right-of-way and assess the cost of such removal and restoration against the abutting property. The property owner may appeal the order to remove and restore in the manner set forth in Section 6.05, Subd. 3 of this ordinance. Further time for removal and restoration may be authorized in writing by the Public Works Director. I 1 1 ] 1 ORONO CC 141-4 (7-25-88)I J 1 I I I §10.03 C. Products produced on the farm may be sold at retail. One temporary foadside stand may be established for conducting such business. One temporary business sign not over eight square feet in area may be located in the front yard during the period when products are for sale. Off-street parking must be provided for. Source: Ordinance No. 172 Effective Date: 1-1-75 T' Subdivision 19. Land Alteration; Prohibition. It is unlawful for any person to perform or nave performed the following land alteration activities without a conditional use permit issued by the Council: A.Remove, fill, use for fill, dredge, store or excavate rock, sand, gravel, dirt or similar earth material within the limits of the City. B.Fill or reclaim any land by depositing such material or by grading of existing land to elevate or alter the existing natural grade. C.Build, alter, or repair any seawall, retaining wall, or otherwise change the grade or shore of lakeshore property. All of the above-referenced land alterations involving filling and grading shall be performed only with "clean fill" as defined in Section 10.02. Granting of such permits is subject to other regulations and prohibitions of the City Code, and other applicable statutes or ordinances of other governmental bodies. Source: Ordinance 163,2nd Series Adopted: 12-8-97 Subd. 20. Permit. An application for such permit shall be accompanied by a drawing made^by a registered surveyor or other comuetent person showing the location of the proposed excavation or storage and shall state the amount of material which is to be removed, excavated or stored, filled or graded, and such other information as the Council may require from time to time. Applications shall be filed with the City Administrator and shall be accompanied by a deposit to be determined by the City, which will be used to offset the cost of processing the application. Any unused portion will be refunded to the applicant. Subdivision 21. Land Alteration; Exception. The requirements of Subdivision 19 are nof intended to govern the following land alteration activities: 1 . Normal and customary grading in the area of an existing or a newly constructed building, or the grading of the driveway serving such building. ORONO CC 258 (4-1-84) § 10.03 2. Any earth movement imder 500 cubic yards which does not adversely impact the existing drainage. Source: Ordinance 163,2nd Series Adopted: 12-8-97 3.Grading, filling or excavating of 10 cubic yards or less within the Shore Setback Zone of all lakes enumerated in the Shoreland Management section of the Zoning Code. Source: Ordinance 171,2nd Series Adopted: 3-23-98 Such grading and earth movement shall be subject to approval by the Building Inspector at the time of issuance of a building permit, provided that a plan showing proper drainage ^d protection of adjoining property has been submitted. Where such earth movement is not being performed in conjunction with a building permit, a separate land alteration permit shall be required. Any uni^ land alterations including earth filling, removal or grading proposed by a builder shall be subject to a Conditional Use Permit as provided for in this Chapter. TTie following land alterations shall be considered as 'unusual land alterations': A. All excavations for foundations in excess of 12 feet average depth if any amount of the excess material removed below 12 feet depth is to be stockpiled on the site. B. Any additional fill brought on site in excess of 500 cubic yards except for fill required to raise grade for adequate frost footing protection; the intent being that structures shall not be artificially raised above the pre-existing surrounding topography. C. Grading or alterations that that would propose any changes in elevations within 5 feet of adjacent residential lot lines except for drainage swales and ditches. The Building Inspector shall have the authority to refer any requests for land alteration permits to the City Council for review and approval in instances where said land alteration appears to potentially create negative impacts or be not in keeping with the goals and policies of the Orono Community Management Plan. ^ Sources: Ordinance 163,2nd Series, Adopted 12-8-97 Ordinance 171,2nd Series, Adopted 3-23-98 Subd. 22. Rip-rap Defined. Rock placed at water level of lakeshore to prevent erosion of shoreline by water action. ORONO CC 258-1 (4-1-84) I I I 1 1 1 1 1 .1 1 I I 1 - us. I I I I 1 I § 10.08 Subd. 7. Variances: Violation of Conditions. A violation of any condition set forth in granting a variance shall be a violation of the Zoning Chapter and automatically terminates the variance. Source: Municipal Code Effective Date: 9-14-67 Subd. 8. Variances: Expiration. Variances shall expire one year after the date of Council approval if not used. Any change in use of the property shall require a new variance. Source: Ordinance No. 172 Effective Date: 1-1-75 Subd. 9. A certified copy of every variance granted under the provisions of Minnesota Statutes, Sections 462.358 and 462.359 shall be filed with the Hennepin County Recorder. Variances filed with the County Recorder pursuant to Minnesota Statutes, Section 462.36, Subd. 1, do not constitute encumbrances on real property. The order issued by the City shall include the legal description of the property involved. Failure to file a variance shall not affect its validity or enforceability. !/ ’ SEC. 10.09. CONDITIONAL USES. Subd. 1. Conditional Uses: Purpose. In order to give the district use regulation the flexibility necessary to achieve the objectives of the Zoning Chapter, in certain districts, conditional uses are permitted, subject to the granting of a use permit. Conditional uses include those uses generally not suitable in a particular zoning district, but which may under some circumstances be suitable. When such circumstances exist, a conditional use permit may be granted. Conditions may be applied to issuance of the permit and a periodic review of the permit may be required. The permit shall be issued for a particular use and not for a particular person or firm. Because of their unusual characteristics, conditional uses require consideration so they may be located properly with respect to the objectives of the Zoning Chapter and the Comprehensive Municipal Plan and with respect to their effects on surrounding properties. In order to achieve these purposes, the Council is empowered to grant and to deny applications for conditional use permits and to impose reasonable conditions upon the granting of these permits. Source: City Code Effective Date: 4-1-84 Subd. 2. Conditional Uses: Reference to Planning Commission. Before the Courcil may grant conditional use permits for such conditional uses as prescribed in the district regulations of the Zoning Chapter, the request therefor shall be referred to the Planning Commission for study concerning the effect of the proposed use on the ordinance and on the character and development of ORONO CC 267 (4-1-84) .............. r § 10.09 the neighborhood and for recommendation in regard to granting such conditional use and the conditions thereof, if any, or for the denial of such conditional use. The Council may by unanimous action waive reference to the Planning Commission. Source: Municipal Code Effective Date: 9-14-67 Subd. 3. Conditional Uses: Application. Whenever this Zoning Chapter requires a conditional use permit, an application therefor in writing may be filed with the Zoning Admimstrator together with such filing fee as may be established by the Council and shall be accompanied by a site plan and such information and showing as may be necessary or desirable, including, but not limited to, the following: A. Site plan drawn at scale dimensions with setbacks noted, B. Location of all buildings, heights, and square footage. C. Curb cuts, driveways, parking spaces. D. Off-street loading areas. E. Drainage plan. F. Type of business, proposed number of employees by shift. G. Proposed floor plan with use indicated and building elevations. H. Sanitary sewer and water plan with estimated use per day. I. A lighting plan showing the lighting of parking area, walks, security lighting and driveway entrance light. J. A landscape plan with a schedule of the plantings. K. An abstractor's certified property certificate showing the property owners within 350 feet of the outer boundaries of the property in question. Source: Ordinance No. 172 Effective Date: 1-1-75 ORONO CC 268 (4-1-84) I I I I I ] 1 1 1 i I I I § 10.09 Subd. 4. Conditional Uses: Failure of Planning Commission to Act,' If no recommendation is transmitted by the Planning Commission within sixty (60) days after referral of the application for conditional use to the Commission, the Council may take action without ftirUier awaiting such recommendation. Source: Municipal Code Effective Date: 9-14-67 1 I I I I I 1 Subd. 5. Conditional Uses: Hearings and Notice. The Planning Commission or Council may hold a public hearing or hearings on each application for a conditional use permit. Notice of the public hearing shall be given not less than ten (10) days or more than thirty (30) days prior to the date of the hearing by publication in the official newspaper for the City. Such notice shall contain the description of the land and the proposed conditional use and the time and place of the hearing. At least ten (10) days before the hearing, the City Clerk shall mail an identical notice to the owner and to each of the property owners within 350 feet of the outside boundaries of the land in question. For the purpose of g' ring mailed notice, the person responsible for mailing the notice may use any appropriate records to determine the names and addresses of owners. A copy of the notice and a list of the owners and addresses to which the notice was sent shall be attested to by the responsible person and shall be made a part of the records of the proceedings. The failure to give mailed notice to individual property owners, or defects in the notice shall not invalidate the proceedings, provided a bona fide attempt to comply with this Subdivision has been made. At the public hearing the Plaiming Commission or Council shall review the application and the statements and drawings submitted therewith and shall receive pertinent evidence concerning the proposed use and the proposed conditions under which it would be operated or maintained. Any party may appear at the hearing in person or by agent or attorney. Subject to such limitations as may be imposed by the Council, the Planning Commission or Council may adopt rules for the conduct of proceedings before it. Such rules may include provisions for the giving of oaths to witnesses and the filing of written briefs by the parties. The City shall provide for a record of the proceedings which shall include the minutes of the meetings, the findings, and the action taken on each matter heard including the final action. Subd. 6. Conditional Uses: Granting of Permit. A. The Planning Commission may recommend and the Council may grant a conditional use permit as the use permit was applied for or in modified form, if on the basis of the application and the evidence submitted, the City makes the following findings: 1. That the proposed location of the conditional use is in accord with the objectives of the Zoning Chapter and the purposes of the district in which the site is located and Comprehensive Municipal Plan; 2. That the proposed location of the conditional use and the proposed condition under which it would be operated or maintained would not be detrimental to the public health, safety or welfare, or materially injurious to properties or improvements in the vicinity; and, ORONO CC 269 (4-1-84) I § 10.09 3. That the proposed conditional use will comply with each of the applicable provisions of the Zoning Chapter. B. A conditional use permit may be revokable, may be granted for a limited time, or may be granted subject to such conditions as the Council may prescribe. C. A conditional use permit shall remain in effect as long as the conditions agreed upon are observed, but nothing in this Section shall prevent the City from enacting or amending official controls to change the status of conditional uses. D. A certified copy of any conditional use permit shall be filed with the County Recorder or Registrar of Titles of the county or counties in which the City is located for record. The conditional use permit shall include the legal description of the property included. Source: City Code Effective Date: 4-1-84 Subd. 7. Conditional Uses: Denial of Permit. The Council shall set forth contemporaneously in writing and in detail all the reasons for the denial of the conditional use permit application. No application for a conditional use permit which has been denied wholly or in part shall be resubmitted for a period of six months from the date of said denial, except on grounds of new evidence or proof of changes of conditions found to be valid by the Planning Commission. Source: Ordinance No. 172 Effective Date: 1-1-75 Subd. 8. Conditional Uses: Lapse of Permit. A conditional use permit shall lapse one year following the date on which it became effective, unless prior to that time a building permit is issued by the Building Inspector and construction is commenced and pursued toward completion on the site which was the subject of the conditional use permit application. A conditional use permit may be renewed for an additional period of one year provided that the request be filed prior to the expiration of one year from the date when the use permit is filed with the Zoning Administrator. The Council may grant or deny an application for renewal of a conditional use permit. Subd. 9. Conditional Uses: Lapse of Use. Should a conditional use permit lapse or cease for a period of six (6) months, future use shall be in conformance with the terms of the Zoning Chapter unless such lapse or cessation is determined to be due to illness, natural disaster or acts of war. Source: Municipal Code Effective Date: 9-14-67 ORONO CC 270 (4-1-84) 1 1 I J I I I J I Ji I I I § 10.09 Subd. 10. Conditional Use Peimits for Non-Conforming Uses. All non-conformmg uses actually and legally existing on December 1,1974, shall be issued a conditional use permit upon application therefor not later than January 1,1976. Such conditional use permit shall allow the continuation of the non- conforming use to the same extent and degree as then existing on December 1,1974. Such permits shall be granted without application fee and the Council shall be limited in such permits to the full and accurate statements of the conditions pertaining to the existing uses. Such permits shall not be subject to periodic review. Source: Ordinance No. 172 Effective Date: 1-1-75 Subd. 11. Conditional Uses: Review Upon Neighbors' Petition. Conditional use permits shall not be subject to periodic Council review for the purpose of change or revocation, unless such a review is one of the conditions of the original permit, or, unless the actual land use is determined to be in violation of the terms of the permit, provided that, upon petition of 75% or more of the adjacent property owners (defined here as those whose property lies within 1,000 feet of the property subject to the conditional use permit) the Council shall hold a public hearing on the continuation of the permit. The Council shall determine, after such public hearing, whether the continuation of the conditional use in question is consistent with the health, safety, and general welfare of the residents of the City. The Council may, after such petition and hearing, continue the conditional use permit unchanged, approve a new permit with such additional conditions as may be necessary to protect health, safety or general welfare, or terminate the existing conditional use permit. Upon termination of a conditional use permit, the Council may allow the former conditional use permit to continue for such period not in excess of one year as may be required to provide time to move or otherwise relocate in a zone where such use is permitted. Source: Municipal Code Effective Date: 9-14-67 permit. Subd. 12. Unlawful Act. It is unlawful to violate any condition of a conditional use Source: City Code Effective Date: 4-1-84 SEC. 10.10. GENERAL REQUIREMENTS. At any time after the adoption of a land use plan for the City, the Plarming Commission, for the purpose of carrying out the policies and goals of the land use plan, may prepare a proposed zoning ordinance and submit it to the Council with its recommendations for adoption. Subject to the requirements of this Chapter, the Council may adopt and amend a zoning ordinance by a two-thirds vote of all its members. Subd. 1. Public Hearings. No zoning ordinance or amendment thereto shall be adopted until a public hearing has been held thereon by the Planning Commission or by the Council. A notice of the time, place and purpose of the hearing shall be published in the official newspaper of the City ORONO CC 271 (4-1-84) § 10.20 SEC. 10.20. R-IA ONE FAMILY RESIDENTIAL DISTRICT. Subd. 1. Puipose. The "R-1 A” One Family Residential District is intended to provide a district which will allow a combination of low density residential development and limited agricultural activity. Planned residential developments may be allowed by conditional use permit. The district shall have immediate access to highways and public sanitary sewer. Subd. 2. Permitted Uses. Within any "R-lA" One Family Residential District, no structure or land shall be used except for one or more of the following uses: A. One family detached dwellings. B. Public owned parks and playgrounds. C. Municipal buildings. Subd. 3. Conditional Uses. Within any ”R-1 A” One Family Residential Distnct, no structure or land shall be used for the follovdng uses except by conditional use permit: A. Schools. Public schools and parochial or private schools which teach a curriculum similar to a public school provided no building shall be located within fifty feet of any lot line of an abutting lot in an "R" District and that a fence be erected fifteen feet or more from all street lot lines where the abutting use is for open play, and nursery schools providing fifty square feet of playground space per pupil. 1. Uses Accessory To A High School. The following uses are accessory to a High School use and require a separate conditional use permit: a. Indoor Ice Arenas. All such facilities and structures shall be located on the same tax parcel as the principal High School Use to which they are accessory. No such structures shall be located less than 50 feet from any lot line of an abutting lot in an "R" District. Such facilities shall not be separated from the principal High School use by a public road. All such facilities shall be owned and operated by the school district, or by a non-profit organization under a land lease arrangement with the school district. The developer of such a facility, prior to final Conditional Use Permit approval by the City Council, shall demonstrate financial capability to complete construction of said facility, by providing suitable documentation that at least eighty percent (80%) of the estimated project costs are in the contiol of the school district or non-profit lessee. Source: Ordinance No. 145,2nd Series Effective Date: 3-11-96 ORONO CC 279 (4-1-84) I I I ♦•a • I » t • I •*» ♦ f ; f ! ! I I I I *■ • t • c § 10.20 B. Churches. Churches including those related structures located on the same site which are an integral part of the church proper, convents or homes' for persons related to a religious function on the same site provided no building other than a residence shall be located widiin fifty feet of any lot line of an abutting lot in an "R" District. c. Clubs, Camps, etc. Golf courses, country clubs, tennis clubs, public swimming pools serving more than one family, scout camps, YMCA camps, YWCA camps, church camps, or private non- profit parks, playgrounds and other similar uses. The principal struc^e for any of the above listed uses shall be 100 feet or more from any abutting lot in an "R" District, and accessory structures shall be a minimum ofiifty feet from any lot line. D. Public Service Structures. Public service structures, including but not limited to electric transmission lines, buildings such as telephone exchange stations, booster or pressure regulating stations, wells, and plumbing stations, elevated tanks, lift stations and electrical power substations, provided no building shall be located within 50' from any lot line of an abutting lot in an "R" District Prior to granting such permit it shall be found that the architectural design of service structures is compatible to the neighborhood in which it is to be located and thus willservice structures is compatible to the neignoornooa m wmen u is lo oc locaicu aim mua promote the general welfare. Public service structures as defined above that have been approved by the City at required public hearings for public improvement projects shall not require a condition^ ....-I ktit cn/'ti etnirhirp*! shall be subiect to all other aoDronriate standards set forth in this the City at requirea public nearmgs lor puoiii; uupiuvciuciu piujsi«.u> anon uwi, use permit but such structures shall be subject to all other appropriate standards set forth in this section; amendments to approved plans involving design and/or placement of these structures will require written notice by the City to all affected property owners 14 days prior to the adoption of the amended plans by the Council. Personal wireless services and commercial broadcasting antennas and towers shall not be considered public service structures. Source: Ordinance 29,2nd Series Adopted: 2-23-87 Source: Ordinance No. 161,2nd Senes Effective Date: 5-27-97 E. Greenhouses. Commercial greenhouses provided all outside storage is fenced in such a manner so as to screen the stored material from view when observed from the public street or adjoining lot. Commercial greenhouse structures shall not be located in a required yard area, and are subject further to the general zoning code requirements pertaining to accessory structures. Source: Ordinance 72,2nd Series Adopted: 8-14-89 ORONO CC 280 (4-1-84) j i LAND US^ / 7. JUNE, 1980 — I 6. COMMERCIAL AND INDUSTRIAL DEVELOPMENT WILL NOT BE PERMITTED TO ADVERSELY AFFECT NEIGHBORING RESIDENTIAL PROPERTY. The location and scale of commercial and industrial development will be controlled so as not to encroach upon the primary residential land uses in Orono. Wherever possible, natural land forms or buffers will be required between different land uses. -I mn 1 PUBLIC URBAN SERVICES MUST BE AVAILABLE FOR ALL FUTURE COMMERCIAL, INDUSTRIAL AND URBAN-RESIDENTIAL DEVELOPMENT. Commercial, industrial and urban-density residential uses will be permitted only where municipal sanitary sewer, adequate transportation, police and fire protection services are available. In addition, commercial, industrial and multi-family residential development will be permitted only where a municipal water system is available for adequate water supply and fire protection. 8. URBAN DEVELOPMENT WILL UTILIZE THE CAPACITY OF EXISTING PUBLIC FACILITIES. New land uses and development will be allowed to infill existing vacant properties within the urban service area consistent with environmental limitations and with the existing capacities of water, sewer, drainage transportation and recreational facilities. New development will not be permitted to overburden these services at the expense of the existing users. New urban development will not be permitted if it requires additional unplanned local or regional facilities capacity. 9. THE EXISTING URBAN AREA WILL NOT BE EXPANDED. Orono*s Community Management Plan is not a staged growth plan. The urban service area will not be expanded into the rural area and urban services and facilities will not be extended into the rural area for purposes of fostering or allowing increased development in those areas. 10. THE DESIGN AND DENSITY OF URBAN DEVELOPMENT WILL BE CONTROLLED TO ASSURE PROTECTION OF LIGHT, AIR AND SOLAR ACCESS FOR NEIGHBORING PROPERTIES. Requirements for minimum lot size, amounts of open space, minimum yard setbacks, and maximum building heights will be designed to assure protection of these values for all urban residents. I I I I I I 1 1 I I I I CMP 4-18 ll * I TRANSPORTATION JUNE, 1980 ii I 1 1 I L C 8. 9. f 7. DRIVEWAY LOCATIONS AND RURAL STREET OR PRIVATE ROAD INTERSECTIONS WILL BE LIMITED FOR TRAFFIC SAFETY. Rural traffic speed is generally faster than that in urban neighborhoods requiring greater sight distances and a lesser number of intersection conflicts for the same degree of traffic safety. Joint use of carefully located private roads will generally be preferred over direct access onto public highways from separate properties -- - - - --- - RURAL TRAILS ARE AN INTEGRAL PART OF THE TOTAL ALTERNATE TRANSFORATION SYSTEM. Rural trails offer access to the Hennepin County Park Reserve Lands from all areas of the City. Rural trails offer horseback riding as well as walking and bicycle opportunities. The City will encourage completion of the planned bike-hike trail system and the private development of rural trails connecting the public trail system with individual rural properties. The City will continue to restrict motorized use of trails within Orono as inappropriate to the trail's basic purpose and as incompatible with adjacent residential properties. THE CITY WILL NOT PROMOTE MASS TRANSPORTATION SERVICES FOR RURAL ORONO. The planned rural land use density cannot economically support public transit services. Existing bus routes pass through the rural area enroute between Long Lake, Wayzata and urban Orono. These routes are sufficient to serve Orono*s rural needs and will in fact provide additional rural service as the need for additional urban service increases. No new route locations are necessary as rural residents desiring to use transit services will use the established park and ride locations in Navarre and Wayzata. CMP 7-13 k , I PARKS JUNE, 1980 r 5. 6. 7. 8. |i THE CITY WILL ENCOURAGE THE PARK RESERVE TO COMPLETE ACQUISITION AND CONTROL OF THE LAKE MINNETONKA ISLANDS. As discussed at length in the Land Use Plan, Chapter 4, Orono does not have the capability of providing public services and facilities to residents on the islands. The City encourages eventual public ownership of the islands as recreational resources for general lake users. Orono encourages the Park Reserve to continue an active program of land acquisition as it becomes available, but not to encourage condemnation or forced conversion. Orono will work with the Park Reserve in preparing a long range plan for use and management of the islands. THE CITY WILL ENCOURAGE THE STATE DNR TO RESTRICT USE OR ALTERATION OF WOLSFELD WOODS. This is a unique nature area that should not be developed for active use, but should remain in itt natural state. In addition, access and traffic control is extremely limited from County Road 6. • THE CITY WILL ENCOURAGE THE STATE DNR TO MAINTAIN AND IMPROVE Tp LUCE LINE TRAIL, AND TO MANAGE ITS USE CONSISTENT WITH THE RURAL RESIDENTIAL AREA IT TRAVERSES. The City will encourage extension of the trail, especially on the eastern ep, and interconnection with other city or regional trails to provide a coordinated linkage between a wide variety of recreational facilities. The City will encourage the DNR to limit motorized trail usage to west of HcCulley Road and the n^w trail access area. - - - THE CITY WILL ENCOURAGE RETENTION AND CONTINpD OPERATION OF THE PRIVATE GOLF COURSES. These private facilities provide major active recreation in the City and in addition provide aesthetic open space and open vistas to benefit of all adjacent property owners and the public alike. The City will discourage conversion of these facilities into non-recreational land use because of the benefit of this recreational opportunity and because the City has limited publxc services necessary for accommodating any other use. ► I ♦ I m CMP 8-12 I I I MAY 0 3 1999 Deor AAoyor Jabbour and City Council Members,CITY OF C.^O.'y'O We arc writing in opposition to the application for an amendment to Conditional Use Permit filed in Orono by VVoodhill Country Club, which seeks to open a driveway leading from the Country Club through a residential neighborhood. Our objections and concerns fall into two general catagorics: Safety and Equity. While we recognize the ambiguous legal obstacles put forth by the Club, we believe we can offer practical ways to address them. SAFETY CONCERNS PREMISES THAT SELL ALCOHOL SHOULD NOT ACCESS THROUGH RESIDENTIAL NEIGHBORHOODS Woodhill Country Club is a private social club, which sells alcohol. The club hosts its members, as well as numerous other invitees attending social and sporting events. The club has liquor permits both from Wayzata (for the clubhouse) and from Orono (for the barn). While it is true that many people live on roads more heavily travelled than ours, they chose to do so and very few people live on roads accessed by a bar. We feel very strongly that for this reason alone, Woodhill Country Club should be denied access through our neighborhood. Alternatively, should they gain such access, Orono should revoke the club's liquor permit and should ask Wayzata to do the same. WOODHILL AVENUE IS HEAVILY TREED, WITH NO LIGHTING AND POOR SIGHTLINES The sightlines on Woodhill Avenue as it intersects Woodhill ridge are very poor and provide no odvance warning os to what may be coming from around the corner. Despite the club ’s claims, this is one of the things that distiguishes Woodhill Avenue from their current access on Woodhill Road. Cars coming down the club's proposed road onto Woodhill Avenue will not be visible to drivers turning left from Woodhill Ridge onto Woodhill Avenue until they ore both In the middle of the intersection. The same is true for cars driving up Woodhill Avenue toward the club. These cars will be Invisible to drivers exiting Woodhill Ridge until it is too late. Further, cars exiting Jane Delaney's driveway, at 1315 Woodhill Avenue (corner of Woodhill and Orono Orchard) has no warning of traffic turning right from Orono Orchard onto Woodhill. The dramatic increase in traffic proposed by the club would increase this danger. WOODHILL AVENUE IS BUILT TO SUBSTANDARD WIDTH AND CANNNOT ACCOMODATE A DRAMATIC INCREASE IN TRAFFIC Before the Woodhill Ridge subdivision was built in 1988 Woodhill Avenue was 16 feet wide. As a condition of approving the subdivision, Orono required that the road be widened, for safety reasons. Although the Orono Subdivision Code calls for a subdivision of 7 or fewer units to be served by a road at least 24 feet wide plus 3 foot shoulders on each side, the neighbors, developer and Woodhill Country Club, as seller of the subdivision land and Co-Applicant to the subdivision process, did not want the road widened to meet the standard. The City agreed to compromise at 22 feet, expressly because only four units were being built and the change in volume of traffic would be minimal. This reasoning is expressly stated in the City Council minutes of June 15, 1987. The City further provided that the subdivision would not be approved until agreement could be reached on how the improvements to Woodhill Avenue would be paid for. Woodhill Country Club eventually sold the land on which Woodhill Ridge was built to its developer. However, the finalization of that sale was conditioned on the City's approval of the subdivision. As a result, Woodhill Country Club had a financial stake in seeing the subdivision approved. They paid 3/16ths of the improvement cost, $11,565. Although their current application claims that this payment was an assessment that entitles them to use Woodhill Avenue, they have already received the benefit of this I I I I» c I r ♦ • I I i ! : assessment: i.e. the price they received for the sale of the land. They were simply spending money to make money. According to the Club's own estimate, of 50-60 cars, each travelling back and fo. ih, for the proposed hours of operation, opening the road would mean an additional car travelling down Woodhill Avenue EVERY 6 MINUTES. The Club's estimates are wholly unsubstantiated and one wonders why they have fought so hard to gain access to a road that they say few people would use. We believe their estimates to be dramatically low. Woodhill Avenue, at it's substandard width is wholly inadequate to handle this overwhelming increase in traffic. The City must consider the danger this will pose to all users of Woodhill Avenue as well as potential liability exposure should someone get hurt. OPENING THE BACK ROAD WILL PRESENT THE SAME VANDALISM AND SAFETY CONCERNS AS WERE REALIZED IN 1978 In 1978, the Club closed the road voluntarily because of fears of vandalism and neighbors' complaints about speeding cars. There is no eason to belive that this will not repeot itself. EQUITY CONCERNS DUE TO ITS OWN ACTIONS, THE CLUB HAS CREATED A CHANGE OF CIRCUMSTANCES THAT NECESSITATES REVOKING THEIR 1969 CUP AND RE-ISSUING IT WITHOUT THE BACK ENTRANCE The club asserts that their 1969 Conditional use permit gives them the right to use the back entrance onto Woodhill Avenue. Their contention seems to rest on the inclusion of a hand drawn map included with their 1969 CUP application. However, this map was not referenced in the CUP, and is therefore only part of the club's application- not the granted CUP. The club admits this in their current I •r application when they say the road was not specifically referenced in the 1969 CUP. Additionally, this map was hand-drawn, is out of scale and was prepared without the benefit of a survey. Consequently, the City cannot have been granting use of the back road with this CUP, as the application was vague and gave the City no clear Indication of the extent of this road or any claim relating to it, nor any indication of what exactly they were granting the club. Moreover, the club was properly a non-conforming use, not a proper subject for a Conditional Use Permit. Even if the 1969 CUP had included the road, the club created a change of circumstances that now necessitates Its revocation. By selling the land for Woodhill Ridge to our developer, the club not only benefitted financially, but by Its own actions, caused the creation of a subdivision. The subdivision, conceived of well after the 1969 CUP, constitutes a change in circumstances. In fact, it is likely that had the Woodhill Ridge subdivision existed in 1969, the 1969 CUP would have specifically denied Woodhill Country Club access via Woodhill Avenue. Therefore, the City should now revoke the 1969 CUP and reissue it with a specific denial of the club's use of the back road and Woodhill Avenue. Under Minnesota law, this is perfectly acceptable and, as long as the City lays out its reasoning and has a rational basis for its action (in this case the change of circumstances and its accompanying safety concerns) a court will defer to the City Council's decision. See, Arcadia Development Corp. v. City of Bloomington, 267 Minn. 221, 226 (1964); Molnar v. County of Carver Board of Commissioners, 568 N.W.2d. 177,180 (Minn. App. 1997); and Honn v. City of Coon Rapids, 313 N.W.2d. 409 (Minn. 1981). WHETHER OR NOT THE CLUB'S LAND ABUTS PUBLIC PROPERTY, THE CLUB HAS RELINQUISHED ACCESS TO WOODHILL AVENUE The club also claims that due to the recently stated Intentions of John Plllsbury when he owned the land on which the back road is locoted, the back road is a public roadway. This assertion is I I I » « . I :i :i I I I I I I I I I t t t t I t contradicted by the club's own staten\ents over the past year and by the very fact that they put a "Private Road" sign up at the end of the back road, on city property. Since the club owns the property on the back road starting approximately 80 feet east of the paved portion of Woodhill Avenue, this claim affects the classification of only the last 80 feet of this bock road. Many people own property that abuts public property. However, this does not give them an unquestioned right to create an access to that public property. When it is Improper, dangerous or not necessary, the City will deny such access. Here, while at one time the club did access public property via the back road, they do not retain a right to use it forever, no matter what they do or what changes. The club first gave up its right to this access when It voluntarily closed and bermed the road in 1978. They confirmed their intentions to relinquish access in 1987, when they sold the Woodhill Ridge land to our developer, expressly for development as a cul de sac. At numerous points in the Planning Commission and City Council minutes when the subdivision was debated, situations that would adversely impact the club's future ability to access Woodhill Avenue were discussed. At no time did Woodhill Country Club, present as a co- opplicant to the subdivision, ever raise any concern or signal in any way that they intended to reopen the back road or felt they had the right to do so. The reason is clear- they wanted the subdivision to go through so that they would profit from the sale of the land. They cannot have it both ways- they sold their access and should not now be allowed to take it back. Finally, in 1988 when they applied for a varience and CUP to build their maintenance shed, representatives of the club told Jeanne Mabutsch, then the Zoning Coordinator, that if they received the CUP, they would no longer use the back road. This was discussed at City Council on October 3,1988. Mr. Sathre, the surveyor hired by the club stated that there was no reason to use the road in the future- no one from the club spoke up to challenge this. In short, regardless of the classification of the last 80 feet of the back road, the club long ago gave up the right to access it. I THE CLUB HAS NOT APPROACHED THIS MATTER IN A FORTHRIGHT MANNER AND SHOULD NOT NOW BE REWARDED FOR THEIR ACTIONS When the club first cleared this road in May of 1998, they promised the City and the residents that they would only use the road during the construction on County Road 15, that it would be one way, for members only and that it would be closed as soon as the construction was over. They played one neighbor off another, nKiking false assertions about other neighbors' support of their intentions. These tactics allowed Woodhill to create a fait accompli- building the rood without City scrutiny and before the City could stop them. When the matter finally reached City Council, all parties agreed to study the matter further. Instead, the club hired a public relations firm, issued a press release and sued the City. Their attitude toward City ordinances and toward the residents has been manifested in other ways also. It has committed several potential violations to the 1988 maintenance shed CUP. They have installed an accompanying above ­ ground fuel tank in a residential area, installed halogen lights on the side of the shed that faces the neighborhood, and built a garage structure with a concrete floor, not called for in the CUP. Merely by clearing trees last May to build the back road, they have violated the spirit of the 1988 CUP by making the shed far more visible to the neighborhood. We are relating these issues to you not to stir up any undue animosity, but rather to demonstrate why we are leary of taking future promises by the club at face value. THE CLUB HAS NO NEED FOR ACCESS THROUGH WOODHILL AVENUE I I I .. I » ♦ • I I I I I I I I I I r I r i c Now that the construction on County Road 15 has substantially ended, any justification for even temporary access to Woodhill Avenue has evaporated. Of course 15 is busier than Woodhill Avenue. Woodhill Avenue is a residential zone. The patrons of Woodhill Country Club do not face a different situation from the patrons of any other business or from anyone else who must acces 15. To allow business patrons of the club to access a residential area simply so that they can avoid traffic, flies in the face of the very reasons for zoning laws. Any patrons who wish to go west on 15 need only turn right out of the club. Those wishing to find a shortcut to 12 should not be allowed to measure about a minute of their time against the safety of an entire neighborhood. (We might point out that much of the donger ensuing from poor sight lines and width concerns would also fall on club members who use the back entrance). On entering the club from 15, patrons have the benefit of a turning lane. There Is simply no justification for opening this access and creating the precedent that zoning laws can be disregarded for mere convinience. We appreciate the effort that the City has put into keeping this access to Woodhill Avenue dosed. Please continue that effort by denying Woodhill's application for these amendments to Its CUP. Thankyou, Jerry Scorch and Shelly Storch Woodhill Avenue, Orono cc. Thomas Barret Ron Morse Mike Saffron MAY 0 6 1999 CITY Or OnOj\'o 1260 Woodhill Avenue Wayzata, Minnesota 55391 May 2.1999 Dear Mayor Jabbour and Members of the Orono City Council, We are writing to ask that you deny the request of Woodhill Country Club to open an access road to the Club off Woodhill Avenue. As residents of Woodhill Avenue, we have very strong concerns for the safety of our children who bicycle, rollerblade and play on that street. Moreover, our mailboxes are located at the corner of Woodhill Avenue and Orono Orchard Road, and our children often bicycle to the corner to pick up mail. If the Club is granted its request, traffic on Woodhill Avenue would markedly increase. Any increase in the traffic on Woodhill Avenue would significantly endanger the lives of our children. Woodhill Avenue is a residential street and as such should only carry residential traffic. We look to you to protect our neighborhood and. most importantly, to protect the safety of our children. We urge you to reject the request of Woodhill Country Club to open this road. Respectfully, Charles W. Maile, M.D. Marla C. Maile I I » • 1 - i " ! I I I i /'yj'. !/- R WOOD. FRANCHOE,L\C Michael D. Wood May 3,1999 Mayor Gabriel Jabbour and City Council City of Orono 2750 Kelley Parkway OronO/ Minnesota 55323 Dear Mayor Jabbour and City Council: We are writing to you in regard to the request from Woodhill Country Club to open a back entrance to the club from Woodhill Avenue in Orono. We reside at 1230 Woodhill Avenue in the home that would be most directly impacted since the proposed new access would connect to Woodhill Avenue at the east end of our property. We remain strongly opposed to opening this road for the following reasons: 1. Opening this road would have a severe negative impact on the lovely, quiet residential nature of our neighborhood. Orono has acted in the past to preserve the unique nature of its residential areas, and it is our hope that you would continue this policy in this case. 2. It is our understanding that opening this road would be contrary to Orono ’s Comprehensive Municipal Plan of protecting quiet neighborhoods from increased commercial traffic. We are aware of a recent decision consistent with this precedent in which the Council denied a new golf club's request to utilize an Orono residential road to access their property. This was a much smaller club than Woodhill and the resulting increase in traffic would have been also much smaller than in this case. EXECUTIVE SEARCH . MANAGEMENT COUNSEL 1550 Utica Avenue South • Suite 425 • MiimeapoUi, MN SS416 • (612) 516.6997 • Fax (61^ 516.6743 j1 \ •r ■\ Mayor Gabriel Jabbour Orono City Council Page 2 3. We are gravely concerned about the issues of safety, increased traffic flow, noise, dust, security and vandalism. Woodhill Avenue is certainly not fit for heavy traffic, and the safety concerns of a road intersecting it at the proposed juncture are numerous. We are aware that the reasons for the club’s closing this back entrance in 1980 included breaches of security, incidents of vandalism, and greatly increased noise, resulting in numerous complaints from the affected residents. 4. We believe, and an expert consultant has verified, that opening this road would have a significant negative impact on the future resale value of our home. Again, we know that this is an important consideration in Orono's Comprehensive Plan. We are pleased that Woodhill Country Club has finally decided to follow proper procedures in seeking an amendment to its condition^ use permit. It is our hope that you will remain firm in protecting another beautiful, peaceful Orono neighborhood from this unnecessary intrusion. This back entrance has been closed for nearly twenty years. To reopen it now for the convenience of some of their members is unreasonable and seriously detrimental to the neighborhood ’s character and safety. We hope you will give careful consideration to this matter. Yours truly. /7 Michael D. Wood Judy D. Wood MDW/JDW:ah I I I 1 •-4 I I •*-> « May 4, 1999 JANIE DELANEY 1315 WOODHILL AVE. WAYZATA, MN 55391 TEL: 612.473.4666 • FAX: 612.473.2051 E-MAIL: NORMALHGTS®AOL.COM City of Orono 2750 Kelley Parkway Orono, MN 55356 To: Mayor, Council Members, City Staff Re: Woodhill Country Club Access Road Dear Mayor, City Council Members and City Staff, I would like to thank the city for the attention and effort it has given the residents on Woodhill Avenue concerning Woodhill Country Club's position on opening an access. However, this past week as I canvassed the neighborhood -1 soon realized the majority of residents in the area had no idea what this issue meant or how it could impact them. Along the way I met passionate people - adamantly opposed to this road • many of whom wanted to know where this issue had been and why the public at large had little or no knowledge of it. This is not an issue raised by a few residents on Woodhill Avenue. It impacts countless other families and their children in this city by allowing commercial traffic to ingress and egress into quiet residential neighborhoods thereby creating dangerous traffic situations. Please remember the club serves alcohol both at the barn and the main clubhouse. Please preserve Orono's zoning code and Comprehensive Plan by opposing the application for a Conditional Use Permit for Woodhill Country Club. Sincerely; P.S. If a tractor drove from the Woodhill maintenance shed to Woodhill Avenue in the last fourteen years - it had wings. I We, the undersigned, residents of Orono, urge the Orono City Council to deny the application for a Conditional Use Permit filed by VVoodhIII Country Club, which seeks to open g driy^way Iggding from the Cogntry Club through a residential neighborhood. (This application is scheduled to be heard on May 11 at 7 p.m..) Woodhill Country Club is a private, social club thgt sells glcghgl. The clgb hosts its members gs vyell a.s numerous invited guests attending social and sporting events. Opening this driveway will dramatically increase traffic and increase traffic danger, on surrounding streets, particularly Woodhill Avenue. Orono Orchard Road and Watertown Road. It would change the quiet, residential nature.of these surrounding streets and would set a dangerous precedent for the disposition of future, similar requests, by developers and private dubs and businesses; PLEASE PROTECT OUR STREETS-FOR NOW AND FOR. THE FUTURE I I I NAME ADDRESS ■ ■ .’A'm } y\ ’ -------------------171 m^epilDDc^ £ uPoodhiH yfyg; Of7>n£> ess At « 1/Il 3 CVva/>fMo iD V?^«rA..QL [j!orJ4s// Av^7 CDIH^iTa A/c ^ ^ •n 1iiarsiH I I I I [ I r I I I E We, the undersigned, residents of Orono, urge the Orono City Council to deny the application for a Conditional Use Permit filed by Woodhill Country Club, which seeks to open q driveway leading from the Country Club through a residential neighborhood. (This application is scheduled to be heard on May 11 at 7 p.m..) Woodhill Country Club is a private social c)ub that sells.atcpho|. The club_hosts its members as well as numerous invited guests attending social and sporting events. Opening this driveway will dramatically increase traffic and increase traffic danger, on surrounding streets, particularly Woodhill Avenue, Orono Orchard Road and Watertown Rood. It would change the quiet, residential nature of these surrounding streets and would set a dangerous precedent for the disposition of future, similar requests by developers and private clubs and businesses. PLEASE PROTECT OUR STREETS-FOR NOW AND FOR THE FUTURE NAME ^ADDRESS ^ CJ/xcA^cii 1 2 AO u/ CoJ [w [\ ft' VH> U • / / \ : • • * • tk j i Ld.^td/\.|l Atti /2 r 5r,y. Wy Ao^.. ij2/urvco Tvii( ----- [1S2 tj),-hk(hjL^^CiA^ j U__ \yi nUAckru.r' _____________________ /oo o/co/\yj / i We, the undersigned, residents of Orono, urge the Orono City CouikiI to deny the applicotion for a Conditionol Use Permit f iled by Woodhil! Country Club^ which seeks to open a driveway leading from the Country Club through a residential neighborhood. (This application is scheduled to be heard on May 11 at 7 p.m..) Woodhill Country Club is a private social club that sells alcohol. The club hosts its meml^rs vyell gs numerous invited guests attending social and sporting events. Opening this driveway will dramatically increase traffic and increase traffic danger, on surrounding streets, particului .y Weodhill Avenue, #ren# Orchard Road and Watertown Road. It would change the guiet, residential nature.of these surrounding streets and would set a dangerous precedent for the disposition of future, similar regu€ developers and private clubs and businesses. PLEASE PROTECT OUR STREETS-tFOR NOW AND FOR THE FUTURE NAME 1 ADDRESS 'rJ- U'i.O I^ O'O —z.q/^ Js-?j ICori/^Q(%^o Pn.Hro;J) X-O'% ^ » i I I Ir» 1 Wc, the undersigned, residents of Orono, urge the Orono City Council to deny the applica^ion for a Conditional Use Permit filed by VVoodhill Country Club, which seeks to open a driveway leading from the Country Club through a residential neighborhood. (This application is scheduled to be heard on May 11 at 7 p.m..) Woodhill Country Club is a private social club that sells alcohol. The club hosts its members as well as numerous invited guests attending social and sporting events. Opening this driveway will dramatically increase traffic and increase traffic danger, on surrounding streets, particularly Woodhill Avenue, Orono Orchard Road and Watertown Road. It would change the guiet, residential nature of these surrounding streets and would set a dangerous precedent for the disposition of future, similar requests by developers and private clubs and businesses. PLEASE PROTECT OUR STREETS--FOR NOW AND FOR THE FUTURE NAME ADDRESS jV * 4 Malkerson G illiland Martin up HiY 0 5 1599 QV7Y Cr Qn0i\0 Suite 1500 ATaT Tower 901 Marquette A venue M I N N E A PO LI 8, M I N N E S O T A 55402-3<J05 Telephone 6I2-344-iiii Facsimile 612-344-1414 Bruce D. Malkerson, Esq. Direct Dial (612) 344-1699 May 4,1999 Mayor and City Council City of Orono P.O. Box 66 Crystal Bay, MN 55323-0066 Re: Woodhill Country Club -- Residents on Woodhill Avenue To be Heard on May 11,1999 Dear Mayor Jabbour and City Council: A. Introduction. I represent Shelly and Jerry Storch, Jane Delaney, Reed Larson, and Charles and Marla Maile. They are Orono residents who live on Woodhill Avenue who would be directly and adversely impacted by any temporary or permanent use of a proposed newly constructed access road by Woodhill Country Club (the “Club”) which exits upon the quiet, dead-end residential street that provides the only access to their homes. The purpose of this letter is to provide an overview of the relevant facts and applicable law related to the issues presented by the Club’s application for a conditional use permit for the proposed use of this proposed access road. Before proceeding, my clients asked that I thank you for having required last year that any proposal for access by the Club should be addressed in the context of an application by the Club for an amendment to the Club’s existing conditional use permit (issued in 1968). As we know, at the Council meeting on May 26, 1998, Mr. Dayton, as President of the Club, stated that he could see the direction that this matter was going and asked that the City Council take no further action. He stated that the Club would proceed to try other traffic control measures at the intersection of County Road 15 and Woodhill Road, which is the access to the Club, and return to the Council at a later date. The Mayor and City Council also stated that the Club could hire an off-duty police officer at the Orono rate for other cities, which is approximately $39 per hour. Mr. Dayton stated that 26025 Mayor and City Council May 4,1999 Page 2 the Club would proceed with the hiring of an off-duty policy officer during the rush hour period, if needed. I do not believe the Club ever did so. Instead, unfortunately, the Club chose to serve a Complaint and Petition for Alternative Writ of Mandamus against the City on July 1, 1998, and sought a Court decision that the Club need not obtain any permits of any kind from the City to build the access road and *' use it as the Club deemed appropriate. Fortunately for my clients and many others who would t. adversely affected if the Club prevailed, the City vigorously defended its right to require the Club to use the conditional use permit process to see if access of some type should be allowed. The Club has finally submitted an application while still claiming it has a right to do whatever it wants as outlined in its allegations in the Complaint. It is unfortunate that this application must now be reviewed and acted upon while the litigation is still pending, albeit temporarily on hold by the Club. In most other cities, I would be afraid that in such a situation, the City would capitulate to the demands of a litigant in its subsequent deliberations. I have no such fear in this case. Additionally, since my clients have personal and business relationships with members of the Club, no one wants to be in this situation. I am sure all parties wish they could turn back the clock of time to a date before May 5, 1998 (when the Club built the access road) and start the process over in a different way. However, my clients have no choice now, as was the case last May, but to try to protect their children, themselves and the neighborhood from the proposed use of the quiet, narrow, poorly paved road serving dieir homes, by numerous vehicles coming to and from the Club. B. Preliminary Review of the Facts. 1. The Club was built in approximately 1915 to 1917. 2. The main access to the Club was provided by a road (Woodhill Road) constructed to County Road 15. 3. That road has adequately served the Club since then. 4. I do not know what the zoning was for the Club’s property at the time of construction. For now I will assume that there was no zoning ordinance then or that the zoning ordinance permitted construction of the Club. 5. At some point, a narrow dirt way was established by the Club which led to Woodhill Avenue. No one seems to know when it was first used by the Club or whether the necessary zoning permits were obtained. The way was used rarely through the years. 6. On May 23, 1968 the Trustees of the Club indicated that the Club decided to bar I I I . 1 26025 I I I c Mayor and City Council May 4,1999 Page 3 vehicular access to its property from Woodhill Avenue (see Response No. 17 by the City to the Club’s Request for Admissions). The Club then applied for a conditional use permit on May 31, 1968. On September 9,1968, the Village of Orono approved a conditional use permit for non- conforming uses for 150 acres of the Club and the conditional use permit was issued on September 13,1968. The hand drawn map attached thereto does not show any proposed use of Woodhill Avenue. This lack of connection is confirmed by Response No. 13 by the City to the Club’s Request for Admissions. 7. Apparently at some point the zoning ordinance was amended to allow golf courses as a conditional use permit in this district. However, the Club has never applied for a conditional use permit for the entire 214 acre site, including use of any proposed access road to Woodhill Avenue. 8. The Club has from time to time applied for conditional use permits for specific new buildings and/or uses on the property which were processed as conditional use permits by the City. However, the Club has not sought a conditional use permit for the property as a whole (214 acres) or for this proposed access road. The Club is now seeking a conditional use permit for the proposed access road to service the entire 214 acre site. 9. Prior to 1978 the Club had closed and not used the way mentioned above. In May, 1978, the Club opened the gate to that way and there were numerous problems in my clients’ neighborhood relating to speeding cars, noise and safety. The City Council reviewed the issues on November 14, 1978. The Club thereafter locked off the way from further vehicular use in the fall of 1978. In 1980, the Club decided to keep the way closed and it has been closed since 1980 other than possibly to drive a tractor down it in 1990 and again in 1997, so the tractor could be driven to Long Lake for repairs (see deposition of Richard Fredrickson, the golf course Club’s superintendent from 1989 to the present). From 1980 until presently, the pathway was used otherwise only for bicycles and pedestrians. 10. Ini 988, the Club applied for and was granted a conditional use permit for a maintenance building on top of the hill overlooking Woodhill Avenue. At that time representatives of the Club represented to the City staff that the way to the west to Woodhill Avenue would not be opened. Jeanne Mebusth stated in her deposition on page 95: Part of my review would have to know if they ’re going to use Woodhill Avenue for access to that maintenance facility. That would be very crucial thing. They told me no. All access would come from the east from the existing road system they have. I said fine. Now I wanted to get into the temporary uses. So, was it going to be used during construction. No. 26025 .? < 11 I: r Mayor and City Council May 4,1999 Page 4 11. In early May, 1998, the Club expanded the way into a wider gravel road, removing numerous trees and vegetation and graveling the area. No permits were sought by the Club prior to the work. The Club did not apply for a conditional use permit for the construction of the gravel road or a permit to extend the gravel road onto a public street. C. niscussion of Relevant Parts of the Club’s Application . The Club, in its application, provides its version of the history of the ownership of property, permits for the Club, special assessments, and historical use of the way to Woodhill Avenue. A review of the depositions in this case and the City ’s Responses to Request for Admissions and Answers to the Club’s Interrogatories shows that the City and Club do not agree on the relevance and veracity of many of “facts ” alleged by the Club in the application. The Club can debate what are the facts for some time. However, what is not debatable is that the Club must obtain a conditional use permit and other permits to construct and use a access road to Woodhill Avenue, for one of several different reasons: 1. The 1968 conditional use permit did not show a connection to Woodhill Avenue and it did not indicate the public would be using Woodhill Avenue. 2. If it is found that the Club did obtain some sort of approval for access to Woodhill Avenue, the Club lost that use due to the non use of the way to Woodhill Avenue for at least the period from 1980 to the present (if not before 1980). The City Code states in Section 10.09: “Subd. 9. Conditional Uses: Lapse of Use. Should a conditional use permit lapse or cease for a period of six (6) months, future use shall be in conformance with the terms of the Zoning Chapter unless such lapse or cessation is determined to be due to illness, natural disaster or acts of war.” This purposeful lapse of use was repeatedly reinforced by the Club, including the representations made by the Club to Ms. Mebusth in 1988 related to the conditional use for the maintenance building. 3. In any event, the proposal now by the Club for permanent vehicular use of this proposed access road for the entire Club area of 214 acres is a dramatic expansion over the very limited prior use and represents the very reason why such uses need to be treated as conditional use permits. Instead of focusing on disputed history, the City correctly is focusing on the standards in its ordinances. There are two real but unspoken reasons for the Club’s desire to open the I I I 1 I I 1 I 1 :i 26025 I I I r [ r r i: r. i: r i; i: i; i: L Mayor and City Council May 4,1999 Page 5 vehicular access to Woodhill Avenue for its members and guests. First, the Club believes Woodhill Avenue would be more convenient for some of its members and guests. The members and guests may be able to save a minute or two during rush hour traffic times on County Road 15. However, convenience is not a test under the City ’s ordinances. Secondly, the Club by engaging in this access fight in Court has painted itself, it thinks, into a comer. If at some point the Club loses the access onto County Road 15, on a temporary or permanent basis, the Club wants to make sure that the Club’s actions now will not limit the possibility of the City ’s approving full vehicular access onto Woodhill Avenue in the future. The Club’s fears are unfounded since the City always retains the right to grant permission to access a public road under appropriate conditions. Indeed, if the Club lost all access to County Road 15 at some time in the future (which is highly unlikely), the City would want to provide a new replacement access to the Club. Such a new replacement access may be legally required. However, that is not the issue before the City presently. To provide comfort to the Club, the City Council need only reserve the right to revisit the access to Woodhill Avenue in the future if conditions warrant it. D. The Standards for issuing a Conditional Use Permit. The approval of any application for a conditional use permit or amendment thereto must meet the standards of the (^ity Code. The Club has not and can not show that it meets the applicable tests. Test! “That the proposed location of the conditional use is in accord with the objectives in the Zoning Chapter and the purpose of the district in which the site is located and Comprehensive Municipal Plan ” Section 10.09, Subd. 6, A, I The Club and the area adjacent to Woodhill Avenue which will be impacted are zoned RR-IB. The objectives of the RR-IB zone are as follows: “Subd, 1. Purpose. The “RR-IB” One Family Rural Residential District is intended to provide a district which will allow a combination of low density residential development and limited agricultural activity.” Although golf courses are a conditional use permit in this district, the use of a residential road such as Woodhill Avenue for commercial purposes as proposed by the Club obviously does not fit with low density residential uses or agricultural use. Any application for any after the fact permits by the Club for permits to use this newly 26025 Mayor and City Council May 4, 1999 Page 6 built access way needs also to be analyzed as it relates to the City’s Comprehensive Plan. The City’s 1980 Comprehensive Management Plan (CMP) Prohibits a Temporary or Permanent Commercial Access Road to Woodhill Avenue. 1. The Woodhill Avenue area is in the rural residential area (see Exhibit D). 2. Page 2-7 states: Rural neighborhoods will be reserved for low-density residential uses ... No new commercial ... activities will be permitted ... 3. Page 4-12 states a land use goal is: 4.to protect neighborhoods from encroachment of incompatible land uses. I I I « I < » f i 4. Page 4-20 states as to rural areas: Urban services are not compatible with rural land use. ... extensive public road maintenance ... camiot be economically justified or easily provided 5. Page 5-13 states: No new development will be permitted to conflict with or adversely affect the established neighborhood character. 6. Page 7-2 states: ... a street system must be provided for safe access to all developed properties vvith sufficient capacity to acconunodate the expected number of trips generated by the planned land use. 7. Page 7-16 states: Local streets are public streets that function to provide direct i*,ccess to abutting properties. Local streets carry traffic within neighborhoods rather than through traffic between neighborhoods. 8. Page 7-17 states: 26025 «- «■ J J I I I r r t f I i [ \ r [ I 1 I 1 1 I Mayor zind City Council May 4,1999 Page 7 Private driveways shall be subject to access permits according to the classification of the abutting street. Maximum service: 1 residence typical 9.Orono Orchard Road, which services Woodhill Avenue, is a scenic parkway. Page 7-16 states: High volume through traffic and commercial traffic is not appropriate on scenic parkways ... Test 2 “That the proposed location of the conditional use and the proposed condition under which it would be operated or maintained would not be detrimental to the public health, safety or welfare, or materially injurious to properties or improvements in the vicinity.” Section 10.09, Subd. 6. A, 2. The increased commercial traffic on Woodhill Avenue, a residential street, will obviously be detrimental to the public health, safety and welfare of those living in the area and their guests, including but not limited to the five children living there. The enclosed report by Mr. Benshoof, a traffic consultant, confirms that conclusion. Summary The above sections of the CMP and City ordinance clearly do not support, and in fact oppose, any temporary or permanent use of Woodhill Avenue to provide access to the Club. A recent change in state law makes it illegal for a city to grant any permits for a use that is contrary to a city ’s comprehensive municipal plan. I understand the City Council last year denied an access to a residential street for another golf course for similar reasons. E. Other Applicable City Ordinances 1. The Club must also obtain a permit from the City before it can construct or reconstruct any driveway, or any driveway approaches, or curb cuts (Section 6.05). To do so without a permit is a misdemeanor. The Club has proceeded to do so without such a permit. The ordinance provides that a permit may be issued if the resulting use would not impose an unreasonable hazard to the public and if the other requirements are met. The Club is clearly a business. Section 6.05, Subd. lOA states: 26025 i Mayor and City Council May 4,1999 Page 8 Only one business driveway shall be allowed per development unless a greater number of driveways are approved by the City, or approved as part of the site plan review. Paragraph D states: No portion of a driveway approach ... shall be constructed ... within 100 feet of a comer in a residential district. My clients believe that any temporary use or permanent use of Woodhill Avenue by commercial traffic from the Club would create such a hazard and woi'ld not comply with the above standards. 1 understand that the City of Orono issues a liquor license to the Club annually for activities at the “Bam ”. My clients ask that when the liquor license is up for renewal that the review of the license take into effect the vehicular access, if any is approved, to Woodhill Avenue. There may be other applicable ordinances of which we are unaware, F. The Factual Reasons for Denying the Temporary or Permanent Use of Woodhill Avenue as an Access to the Club Are as Important as the Legal Reasons 1. Woodhill Avenue is unlighted, narrow, poorly maintained, with blind intersections. It is not suitable for conunercial traffic. There is no sidewalk or pedestrian walkway or bikeway. All pedestrians and bikes must use the street. 2. The use of the road by commercial traffic will endanger the children, homeowners and their invitees in the area. 3. The commercial traffic will include some patrons of the Club who have been consuming liquor before using the road. 4. Any traffic in the evening will be more hazardous because Woodhill Avenue is not lighted. 5. Orono Orchard Road, a scenic parkway, is not constructed or maintained to handle more commercial traffic. 26025 I I I £ t I \ ► f » I I I I I I r r r r I I I I I i; i; t t li Mayor and City Council May 4,1999 Page 9 6. The intersection at Orono Orchard Road and County Road 15 is already dangerous, and will become more dangerous with more traffic from the Club, because of the curve in the road to the west, limiting visibility. 7. The Club’s access onto County Road 15 is safer than the use of Woodhill Avenue and/or the intersection of Orono Orchard Road and County Road 15 because: A. The Club members are familiar with its use. B. County Road 15 at that location is straight and there is better visibility. C. There are no children in the immediate area or homes facing upon that intersection. D. At County Road 15, there is an existing eastbound left turn lane into the Club and there will be westbound right turn lane into the Club. E. Woodhill Avenue is inadequate for such use for reasons discussed above. 8. Any perceived problem at County Road 15 for the Club members or others using County Road 15 can be addressed in several ways, including but not limited to: A. Moving the temporary visual barriers; B. Lowering speed limit on County Road 15 during construction; C. Club’s hiring of a flag person or off-duty policy officer during peak traffic hours, if ever needed; D. E. Members learning to access Club during non-rush hour. Adding cautionary signage. itv Council decides to approve the VehicGL In the event th&-Citv Council decid^ sh^diif^tlWUfld^ folfawsr " ^^ ess then the Council The Club shall install a gate across the road which shall be locked at all times (this is Club’s request numbers 1 and 2 with a clarification), except when used as follows: A. Use of the road by emergency vehicles (police, fire, ambulance and utility). (This is Club’s request number 3, page 1). 26025 I Mayor and City Council May 4,1999 - Page 10 B. Use of the road for transporting Club tractors to and from Long Lake for repair. (This is Club’s request number 5, page 1). C. Use of the road for general access if V/oodhill Road access to County Road 15 is temporarily blocked (subject to reasonable notification to the City and affected neighbors), but only during the period of such temporary blockage. (This is Club’s request number 6, page 1). ' D. Use of the road under the terms of that certain Easement Agreement, dated , October 5,1987 between the City, the Club and MSM, which benefits one residential lot \ / if County Road 15 access is blocked. (This is Club’s request number 7, page 1). ^\The only request of the CMub which must not be approved is number 44hat states: tdhill Avenue access simi be available for entrance a^exit by Woodhill members and in^ked guests between 7:0Q a.m. and 8;00 p.m. during tnM^s that Woddhill is open V City ^o^d li TTiij^ove apprdv^uses would be g^ed “Basic Rights,’’ a term used by the Club. The ermit ter 4iftrp8Qrto (ntermine what problems there were in the prior year^ right to rev elw^the permit or add conditions ’’ ^ ’ Section 10.09, Subd. 6, B. f7 On page 2 of the application, the Club stated the City can delete the following uses from the 1968 conditional use permit. The following uses however, are not part of the 1968 conditional use permit. In any cnt the Club can always apply for an amended conditional use permit in the future to include these items the Club agrees should not be part of any conditional use permit at this time. 1. Conversion of the Woodhill Avenue access into the main entrance for Woohill on a permanent basis. 2. Woodhill Avenue as an entrance or exit by delivery, taxi, service, or other commercial vehicles. 3. Woodhill Avenue as an entrance or exit by the general public. 4. Woodhill Avenue as an access at time periods other than those allowed in the Basic Rights defined above. 26025 I I 1 t I ♦ <4 ri * I Mayor and City Council May 4,1999 - Page 11 5. Expansion of Woodhill ’s west driveway between the maintenance building and Woodhill Avenue. 6. Bituminous paving of the driveway abutting Woodhill Avenue 7. Signage concerning Woodhill on Orono Orchard Road. The Club further requests either amendment to the 1968 conditional use permit or acknowledgment by resolution that the right of access to the Woodhill property exists independent of any conditional use permit process in the following two circumstances: “1. Under the terms of the Easement Agreement.” That agreement, and the duties of parties thereunder, speaks for itself and need not be part of any conditional use permit at this time but since it benefits only one lot it has a minimum effect on safety. “2. If all access from Woodhill to County Road 15 is permanently blocked as a result of either Highway 15 alteration or improvement or because of the railroad right- of-way, the right of reasonable access to the Woodhill Property is required and is not subject to revocation through the conditional use permit process.” If that situation ever develops, the Club must apply for a conditional use permit so the City can decide if such use is warranted and if so, what conditions must be imposed in order to protect the health, safety and welfare of the citizens in the area and the users of the roads. Moreover, there may be other solutions to such a theoretical future problem as to access onto County Road 15. For example, if the railroad ever lawfully closes the access to County Road 15, the City could condwtui the access as a public road to a point where the road enters upon the Club’s property. H. If the City decides that Access should be allowed onto Woodhill Avenue now, in addition to the Access set forth in Section G above, the City should require the followine: 1 . Access on the Club’s driveway will be for members only, and only on the basis o f one way, fro tnwgst to ea^TheUlq^ claims it needs access for the convenience of its members who live to the west and northwe^tof the Club. Ho^teVer those members who leave the Club on Woodhill Road at County^ldad 15 have an easy^ri^t turn on County Roddfl 5, then an e^y right turn on Orono Orcharji^Road, which then pa^«« Woodhill Avenue. There is no needfo use Woodhill Avenup^'^l^en those member^/dpproach from the norpiwest or west, wifnout access to Woodhill^v^nue, they take a left frqjrfurono Orcha;d Road,.0fuo County Road 1 5 and then a left (on ileft turn lane) into the Club. That is a very gbocKvay of access^/Hbwever, if the 26025 Mayor and City Council May 4,1999 Page 12 ^ Council believes ^at those members/need a more^ionvenient access, then limit that access to a one way up the^cess road, since the exiting to the west from the Club on Woodhill Avenue at County Road p is an easy exit and there is no need to use Woodhill Avenue. 2. / Th€"g^ at the acces^O^ should be apardl[Ce|ess gate so oiily^ublnem^ers can use xi^tiaso the^lub’sjpxjfclsortn]p use^^n-iliow theejttent^t«tlcn a use and by whom, and the^l^e reduces le use shouljikb^limi|ed to 20-30 c^Mfips per weekday (Qub^s estimate) and 50 car trips faef weekend day^Club estiniates 50-6^)^ mis is also the estiotdte provided by the Club’s,.tT^c cqnsult^nt^d is the bj^is fqpttte consultant ’s stateWnt that such use would not be harqmil. ___ 4. The Club should install three way stop signsatibe interse<^mof Woodhil Avenue where it extends to the so^^, . , \Tu /^/L 5. Th^jCTuQsn^uldmst^l bumps along the^'Oodhill\Kvenue .*^These are used effectivelyTn Minneapolis iijjesiHmtial arejas. SnowjjlowTfiaveno problems^ plowing over them. Postd^speedsi^ ,, ^ i, 6. The access road ohould retna|^ grov el to assis t In sluwing cai i / (A/ V^ The City should limit tji^ permit litve^etri to determine what problems there were in •ight to ici^kj^he permit or impose additional I. If the City decides to allow Access in both directions to a greater degree, then the City should do so only as follows : 1 . Access only between 4:00 p.m. and 6:00 p.m. on weekdays in the summer since that is the rush hour time period on County Road 15. Few members access the Club during morning rush hour. Even in that situation, there is a left turn lane when heading east at the entrance to the Club at County Road 15, and there is little oncoming traffic from the east. The access from the east is always an easy right turn. 2. The gate at the access road should be a card access gate so only Club members can use it, and so the Club’s records of the use can show the extent of such a use and by whom. 3. The use should be limited to 30 cars per day (one trip in, one trip out per car = 60 trips). The Club’s traffic consultant assumed that is the maximum use. I I • I i I » f » I ^ I » I 26025 I I I r r r I i I I I I I I I I I Mayor and City Council May 4,1999 Page 13 4. The Club should install three way stop signs at the intersection of Woodhill Avenue where it extends to the south. 5. The Club should install three speed bumps along the Woodhill Avenue. These are used effectively in Minneapolis in residential areas. Snow plows have no problems plowing over them. Posted speed signs are ineffective. 6. The access road should remain gravel to assist in slowing cars down. The City should limit the permit for one year to determine what problems there were in the prior years and the City should maintain a right to revoke the permit or impose additional conditions, as allowed by Section 10.09, Subd. 6, B. Conclusion All parties should be afforded procedural due process by having enough time to analyze the issues presented. If the Club submits evidence other than in its application on file with the City, we ask the City Council to continue this matter until all of the new evidence can be analyzed and addressed. Only then should the City Council make a decision. For example, the Club filed its application on April 21, but the Club did not file the traffic consultant ’s report until Monday, May 3, leaving City staff and my clients and their traffic consultant little time to review and respond to it. Thank you for this opportunity to comment on this very important issue. Please call me or my clients with any questions or if you need any additional information. If you can, please inspect Woodhill Avenue prior to the meeting. Very truly yours. Bruce D, Malkerson Enclosures cc: Ronald Moorse, City Administrator Mike Gaffron Gary Cheswick, Chief of Police Tom Barrett, City Attorney Shelly and Jerry Storch (476-1273) Jane Delaney (473-4666) Reed Larson (473-1696) Charles and Marla Maile (475-1885) 26025 i r^Y-04 “1999 14:57 BENSHQOF & RSSOC.bl£i IbVl IQ!^ BENSHOOF & ASSOCIATES, INC. - TRANSPORTATION ENGINEERS AND PLANNERS hy}' • U ' 5" B I 1(H17 EXCELSIOR BOUIEVARD. SUITE TWO / HOPKINS. MN 55343/(612) 238-1667/FAX (612) 238-1671 I r F F F F F 1: 1: t C t t c 1: May 4,1999 n2Z2rs2D REF=ERTORLE:98-39 \m 0 5 1999 Woodhill Avenue Residents do Kfr. Chiles Maile 1260 Woodhill Avenue . Orono, MN 55391 Ci i Y Or Cri0i\’0 RE: Updated Traffic Review of Possible Access Connection to Woodhill Avenue from Woodhill Country Club Dear Residents: PURPOSE This letter is to update the review we performed about a year ago regarding the traffic impacts of the access connection that Woodhill Countty Club has proposed to establish to and from Woodhill Avenue. The results of our prior review were documented in a If ner to you dated May 26.1998. Recently, the Woodhill Countjy Club submitted to Ae City of Orono an application for a conditional use permit amendment. The two principal purposes of this amendment are: 1) to acknowledge certain basic lights of access for the Countiy Club to Woodhill Avenue and 2) to impose certain restrictions and conditions on the Country Club’s proposed use of an access connection to Woodhill Avenue. We have carefblly reviewed the Woodhill Countiy Club’s current application. In addition, we have reviewed the letter submhted by Edward Axt of the Parsons Biinckerhoff firm to James McCarthy of the. Lindquist A Vennum firm dated April 30, 1999, which documents a traffic study performed by the Parson firm of the proposed /aaccess connection to Woodhill Avenue. In evaluating the traffic impacts of the Country Club’s application, we also have accounted for the following items: information that we established a year ago. current observations on Woodhill Avenue and at the intersection of County Highway 15 and Woodhill Country Club Road, and information from Hennepin County regarding improvements to County Highway 15. The results of our current traffic review are presented in the following sections: • Insufficient study regarding adequacy of access on County Highway 15 • Negative impacts caused by Country Club use of Woodhill Avenue • Possible option of one-way in only access • • Recommended conditions if City Council approves access • Conclusions t¥iY-04-1999 14:57 BENSHOOF & RSbUC.blei IbYl t-'.eU/'kJY Woodhill Avenue Residents May 4,1999 INSUFFlCa:NT STUDY BEGABDING ADEQUACY OF ACCESS ON COUNTY HIGHWAY IS In my earlier review letter tn you dated May 26,199S, we nused a seiious issue that the Country Club had not submitted to the City prior to that date any report justifying their proposed access to Woodhill Avenue. For land uses like the Country Club that generate significant traffic volumes, we indicated that when an access change is proposed, it is standard practice to complete a traffic study to address the needs and implications of such an access change. Five key questions which need to be addressed and which I stated in my May 26.1998, letter are: • What are the principal issues and needs influencing the potential change in access? • What are the possible solutions to fulfill the needs? In evaluating the candidate solutions, what factors are p^eularly importwt to address in terms of potential impacts on users of the development, on nearby property owners, and on the public roadway system? • What are the advantages and disadvantages of the candidate solutions in terms of the pre%dously identified factors? • Can any of the candidate solutions be implemented in a manner to benefit users of the development and to avoid significant negative impacts on nearby property owners and/or the public roadway system? If so, what is the preferr^ solution? • , • Materials included with the Country Club’s current application, including the traffic study report by the Parsons firm, provide a partial response to ffie above questions. These items, however, fall for short of a complete response to the questions listed above. Three serious weaknesses of the traffic comments provided by the Country Club are; I I I * I ! t i 1. The Country Club’s application does not acknovdedge the benefits that will be accomplished to their access on County Highway 15 through the improvements presently being construaed on County Highway 15. These improvements include an eastbound left turn laiie and a westbound right turn lane so that all motorists turning into the Country Club from County Highway 15 will have a protected turn lane. .2. Neither the Country Club’s application nor the Parsons report provide any actual data or technical analyses regarding the level of service for their users to gain access to County Highway IS at Woodhill Road. In other words, they have not documented whether serious delays actually are encountered in . gaining access to County Highway 15 during any particular hours or days. 3 . The Parsons report refers to traffic counts conducted on Woodhill Road at the end of September and beginning of October 1998. It is important to recognize that this is an off-peak period for the Country Club. As such, we believe that it is invalid to rely upon such off-peak data for the purpose of evaluating the impacts of the proposed access to Woodhill Avenue. • I V I r t ► < I • f rWY-04-1999 14:57 BENSHCXDF & flSSOC. I I I ' • >V^ •« ' Woodhill Avenue Residents bl2 2;J0 IbYl K.k34/'0Y May 4, 1999 NEGATIVE IMPACTS CAUSED BY COUNTRY CLUB USE OF WQODHILL: AVENUE The Country Club’s application includes their estimation that their tr^c use of Woodhill Avenue “will be in the range of 20 to 30 trips per day on weekdays, and possibly 60 on weekend days in the summer months of June and July.” Page seven of the report corroborates the preceding weekend projections through their statement that ..it is therefore estimated that no more than 60 trips (i.e. 30 members per day) would use the Woodhill Avenue access...In our judgment, the Club would have to exercise very stringent controls to limit the usage of Woodhill Avenue the volumes cited in their application. The reason for this comment is that their pi ,4Cted volume usage represents only five to eight percent of the total daily trip generation for the Country Club. Thus, for purposes of addressing the impacts of the Country Club access on Woodhill Avenue, we have utilized the Club’s projections that ^e volumes on Woodhill Avenue would increase by 20 to 30 vehicles per day on weekdays and by 60 vehicles per day on weekend days in the summer. Considering that Woodhill Avenue presently serves just six homes, the effects of the Country Cliib access would be to cause a 50 percent increase in the tot^ volume using Woodhill Avenue on weekdays and to cause a two-fold increase in the volume on weekend days. In our judgment, this expected magnitude of traffic increase would cause noticeable adverse impacts for the existing residents saved by Woodhill Avenue. In this regard, we take exception to three points ei^ressed on pages 8 and 9 in the Country Cjub’s application, which suggest that no traffic difficulties would be experienced. These three points and our responses are as fellows: • • a) T7te two residences located at the intersection of Orono Orchard Road and Woodhill Avenue have a limited impdetfrom the restoration of the Woodhill Avenue access. The driveways for these two homes are on Woodhill Avenue. Their ability to use these driveways would be impacted by the motorists traveling to and from the Country Club. Further, the safety of these residents to walk or bicycle along Woodhill Avenue would diminished. b) The entrance from the Woodhill Ridge private road onto Woodhill Ayenue does not pose any significant traffic hazard. To the contrary, we believe that a serious safety hazard would exist because extensive trees and brush obstruct sight distance in the southeast comer of this intersection. c) While pedestrian or bicycle use by children of the public street will ej^Hfse the children to a greater level of traffic on Woodhill Avenue than is present today, the level of traffic is substantially less than the level of trtzffic usually encountered on residential public street in Orono and elsewhere. This comment overlooks the point that Woodhill Avenue is just wide enough for two traffic lanes and does not have a sidewalk or bike path. The Club’s • application and the Parsons report conflict with each other regarding the width of Woodhill Avenue. The application indicates that Woodhill Avenue is 22 mY-04-1999 14:58 BENSHOOF & OSSOC.bl2 23B IbVl P.05/07 Woodhill Avenue Rwidents May 4,1999 feet wide, whereas the Parsons report states that the width is 24 feet, nine inches. In any event, the width of Woodhill Avenue is not sufficient to acconunodate a motorist traveling in each direction plus a pedestrian or bicyclist traveling in one direction. . POSSIBLE OPTION OF ONE-WAY IN ONLY ACCESS Our preferred outcome at this time is the same as expressed in our May 26,1998, letter, namely that no access for the Woodhill Country Club should be approved on Woodhill Avenue at the present time. One reason is that such access would cause negative impacts on Woodhill Avenue. The second reason is that the Country Club has not presented a factual analysis which demonstrates that the access on County Highway IS does not meet normal performance standards and which demonstrates that access on Woodhill Avenue is the most prudent solution to provide adequate access for the Country Club. 1^ in spite of the preceding points, the City Council is inclined to consider potential access for the Country Club on Woodhill Avenue, we would raise the possibility of one ­ way in only access. Two principal characteristics of this option are: a) The traffic impacts on Woodhill Avenue would be just half of the impacts with full two-way access. b) One-way in only access would meet the principal need expressed in the ■Country Club’s application.and in the Parsons report namely to accommodate persons coming to the Club from the north on Qrono Orchard Road. If access were available via Woodhill Avenue, these users would not have to turn left onto County Highway IS at Orono Orchard Road and then turn left off County Highway 15 at Woodhill Country Club Road. The return movement for these users could be accommodated readily without using Woodhill Avenue by making a right turn onto County Highway IS at Woodhill Country Club Road and then another right turn onto Orono Orchard Road. I I I I 1 1 1 1 M RECOMMENDED CONDITIONS IF CTTY COUNCIL APPROVES ACCESS As previously expressed, we believe, that the most prudent action at the present time would be to maintain the current prohibition regarding Woodhill Country'Club access on Woodhill Avenue. However, if the City Council is inclined to consider some access arrangements, it is highly important to establish a series of conditions that will limit the negative impacts on Woodhill Avenue. If the City Council is inclined to approve a one ­ way in only access, we would recommend that siich approval action be contingent on the following conditions: 1. Woodhill Avenue shall not be used as the main entrance for the Country Club. 2. Woodhill Avenue shall not be used as an entrance or exit by delivery, taxi, service, or other commercial vehicles. • t •i • I rjHY-ew-iyyy 14: sa tjtrtoHum- Jt Haauc.oiti eioa io«x r.kJb/ur I I I n r r I I I 1: t I I 1 I I Woodhill Avenue Residents Mey4,1999 3. Woodhill Avenue shall not be used as an entrance or mt by the general public. 4. Use of the Woodhill Avenue access shall only be allowed during the hours of 7:00 a.m. to 8:00 p.m, 5. The Countiy Club shalI not expand its west driveway between the maintenance building and Woodhill Avenue. 6. The Country Club shall not install any bituminous paving on its driveway connection to Woodhill Avenue. 7. The Countiy Club shall install a card controlled gate system on the driveway connection to.Woodhill Avenue, which limits access to card holders and which records every vehicle using the driveway. 8. On a monthly buis, the Country Club shall furnish to the City a complete and accurate report from the card reader system, which documents the actual number of vehicles using the driveway each day of the month. 9. If the average weekday use exceeds 1S vehicles per day of if the average weekend day use exceeds 30 vehicles per day, the Countiy Club commits to initiating immediate actions to reduce volume usage to the limits of 15 vehicles per day on weekdays and 30 vehicles per day on weekend days. 10. The City shall review the conditional use permit granting this access approval on an annual basis. If the Club's usage of the driveway exceeds the limits defined in condition 9. on two or more months or if other problems develop, the City has the flill and complete authority to impose other conditions or to revoke the access permit and completely prohibit the Countiy Club from using Woodhill Avenue 11. The City shall install two bituminous speed humps on Woodhill Avenue, with the costs to be reimbursed by the Countiy Club. We would suggest using the City of Minneapolis standard, which is a hump three inches high, 12 feet long, and across the full width of the roadway. The most westeily hump should be 250 feet east of Orono Orchard Road, and the second hump should be 250 feet farther to the east. 12. The City shall install a stop, sign on eastbound Woodhill Avemie at Woodhill Ridge. .13. The Country Club shall install *‘do not enter" signs on the driveway within their site to clearly inform Country Club users that the driveway cannot be used for exiting purposes. 14. The City shall implement the folldwing three changes to enhance.the safety for residents traveling westbound on Woodhill Avenue to Orono Orchard Road; Trimming the branches that overhang the westbound portion of Woodhill Avenue from the evergreen trees for the home at 190 Oiono Orchard Road. Installing a stop sign in the northeast comer of the Orono Orchard Road/Woodhill Avenue intersection for westbound traffic bn Woodhill Avenue.• • • Trimming the brush for a distance of about 10 feet in the southwest comer of the Orono Orchard RoadAVoodhill Avenue intersection nqY-04-lJ99 14:59 BENSHOOF & ftSSOC.bl^ dJti IfaVl K.kr('/k3Y Woodhill Avenue Kesidents Mey4,1999 If the City Council is inclined to approve some arrangements for two-way access, . changes are needed to four of the preceding conditions plus one new condition should be added as follows: 6. This condition specifies no bituminous paving of the driveway connecting with Woodhill Avenue. If two-way access is approved, we would recommend bituminous paving to the eastern edge of the City right-of-way. This recommendation to extend the bituminous paviiig to the east is made in order to prevent the tracking of gravel into the Woodhill Avenue/Woodhill Ridge intersection. 9. If the average weekday use exceeds 30 vehicles per day or if the average weekend day use exceeds 60 vehicles per day, the Country Club commits to initiating immediate actions to reduce volume.usage to these maximum levels. 12. The City shall install stop signs on eastbound Woodhill Avenue and on the westbound driveway at the Woodhill Ridge intersectioru 13. This condition would need to be deleted. 1S. At the expense of the Country Club, the City shall clear the brush in the southeast comer of the Woodhill Avenue/Woodhill Ridge intersection for a distance of about-25 feet from the intersection iri both the east and west directions. CONCLUSIONS• • • * • * • * Through the updated traffic review, presented in this letter, I have attempted to express our continuing concerns regarding Averse impacts.that would occur bn Woodhill Avenue if the Woodhill Country Club is allowed to establish an access connection to this local roadway. Given these negative impacts and given the lack of sufficient documentation from the Country Club that the Woodhill Avenue access is necessary, we continue to favor an outcome whereby the Country Club is not allowed to gain access to Woodhill Avenue. If the City Council is inclined to approve some access arrangements, we have presented a series of conditions that we believe are necessary to avoid serious impacts on Woodhill Avenue. Let me know if you have any questions about items addressed in this letter. • • Sincerely, * • • • ^ • BENSHOOF & ASSOCIATES. INC. les A Benshoof I I I 1 n 1 1 H 1] M •b TOTAL P.07 J I I I t D 0 •V CITY OF ORONO 2750 Kelley Parkway, P.O. Box 66 Crystal Bay, MN 55323 Phone (612)249-4600 Fax 249-4616 NOTICE The City Council will hold a public hearing in the Orono Council Chambers at 2780 Kelley Parkway on Tuesday, May 11,1999 at 7:00 p.m. on the matter of application #2484, a request by Woodhill Country Club, 200 Woodhill Roa^ for a conditional use permit amendment. Woodhill Country Club requests that its 1968 Conditional Use Permit be amended 1) to acknowledge certain basic rights of access to Woodhill Avenue; and 2) to impose certain new restrictions and conditions on Woodhill's access to Woodhill Avenue. All persons wishing to be heard will appear at this time. Written comments are solicited. A copy of Woodhill Country Club's application is available in the City offices for review. City of Orono By: City Council Michael P. Gaffion, Senior Planning Coordinator To be published the weeks of April 24 and May 1,1999, . ((j Bonestroo Rosene Anderlik & Associates Engineers & Architects April 30,1999 Mr. Michael P. Gaffron, Senior Planning Coordinator City of Orono Post Office Box 66 Crystal Bay, Minnesota 55323 Re: Woodhill Country Club File No. 139-2484 Bonestroo. Rosene. Anderhk and Associates, tnc. is an Affirmative Action/Equal Opportunity Empi Principals Otto G Bonestroo. PE • Joseph C Anderlik. PE • Marvin L. Sorvala. PE • Richard E. Turner. PE • Glenn R Cook. PE • Robert G Schunicht. PE • Jerry A Bourdon. PE • Robert W. Rosene. PE and Susan M Eberhn. C PA . Senior Consultants Associate Principals Howard A. Sanford. PE. • Keith A. Gordon. PE • Robert R Pfcfferle. PE • Richard W. Foster. PE • David O. Loskota. PE • Robert C Russek. AI A. • Mark A. Hanson. PE • Michael T. Rautmann. PE. • Ted K Field. PE • Kenneth P Anderson. PE • Mark R Rolfs, PE • Sidney P Williamson. PE . L S • Robert F Kotsmiih • Agnes M Ring • Michael P Rau. PE. • Allan Rick Schmidt. PE Offices St Paul. Rochester. Willmar and St Cloud. MN • Milwaukee. Wi Website WWW bonestroo com !.! \Y 0 5 1999 . ^ ■ I ■ I I Dear Mike, We have reviewed the preliminary grading plan, drainage area map and drainage calculations for the proposed westaly access to Woodhill Country Club. The access is located at the west end of WoodhUl Avenue in the north half of Section 21. The following is a list of engineering issues that should be addressed as part of the plan review process. • The proposed roadway is shown as steep as 14% in some locations. City code specifies a maximum allowable grade of 12% for private streets. Driveway grades exceeding 10% are typically discouraged. • The proposed street grades may be an erosion issue. Bale checks or some other erosion control measures will be required during and afier construction. Vegetation will need to be established along the roadway to prevent scouring in the ditch sections. • Final plans should include a typical street section in accordance with City standards for a private roadway. • Tlie proposed road surface is gravel. Dust may be a problem depending on the amount of daily traffic. Some type of permanent dust control measures may be required. • The drainage area map and drainage calculations appear acceptable. It appears that water east of the 976 contour could be diverted to the existing pond shown on the plans. Storm water runoff and erosion potential could be minimized if some flows could be routed to the existing pond. • Retaining wall design and details should be submitted for review. Please contact me at 651-604-4863 if you have any questions regarding this matter. Yours very truly, BONESTROO, ROSENE, ANDERLIK & ASSOCIATES, INC. Tom Kellogg \£^ 11 »i •1 •4 ri • I M • i ♦ f cc: Greg Gappa, City of Orono » i • t 2335 West Highway 36 • St. Paul, MN 55113 ■ 651-636-4600 • Fax: 651-636-1311 I I I i DRAFT CSAH 15 I X TRAFFIC MANAGEMENT STUDY Bonestroo File No. 139-98-805 April 30,1999 f Table of Contents r. INTRODUCTION II. EXISTING CONDITIONS A. Functional Classification B. Traffic Operations Characteristics C. Traffic Volumes D. Accident Experience E. Level of Congestion III. IMPROVEMENT CONCEPTS IV. CORRIDOR IMPROVEMENT RECOMMENDATIONS V. EAST-WEST TRANSPORTATION NEEDS VI. WOODHILL ROAD AREA IMPROVEMENTS Figures 1. CSAH 15 Corridor 2. Traffic Lane Availability 3. 1996 Average Annual Daily Traffic 4. Average Weekday Peaf: Hour Volume 5. A.M. Peak Hour Volumes 6. Number of Accidents - 1995 through 1997 7. Roadway Improvement Concepts 8. Two Way Left Turn Lane 9. Fox - Orono Orchard Road Connection 10. Wcodhill - Orono Orchard Road Connection Alternatives Page Number 1 1 1 1 4 4 11 11 13 17 17 2 3 5 6 7 8 15 16 19 20 I I I 3 J 1 I I I I I 1 I [ I t r i: i: I I t i; t 0 Tables 1. Average Daily Traffic Volumes on CSAH 15 January through June 1998 2. CSAH 15 Accident Types - 1995 to 1997 3. Intersection Accident Rates 1995 to 1997 4. CSAH 15 Segment Accident Rates 9 10 10 10 . 1 t 1.INTRODUCTION The City of Orono has expressed concern with regard to the traffic movement efficiency and the accessibility to/from County State Aid Highway (CSAH) 15 between CSAH 51 and Femdale Road West. This roadway is also called Shoreline Drive. The location of this corridor is shown on Figure 1. The study segment is approximately one and three-quarters of a mile in length. The City of Orono has ordered a study of this segment of roadway for purposes of analyzing the following: Analyze the CSAH 15 corridor between CSAH 51 and Ferndale Road with regard to traffic movement and access from cross streets. Analyze methods to improve east-west traffic movement that could provide some relief to CSAH 15. Analyze the feasibility of providing a frontage road on the north side of CSAH 15 between Woodhill Road and Orono Orchard Road. Analyze the feasibility of signalizing the CSAH 15 intersections with CSAH 51 and with Orono Orchard Road. This document provides the findings and conclusions of the analyses conducted to respond to the above stated study elements. II. EXISTING CONDITIONS This report chapter provides a discussion of various existing conditions along the CSAH 15 corridor including lane conditions, functional classification, traffic volumes, and accident occurrence. A. Functional Classification The Metropolitan Council Transportation Systems Map classifies CSAH 15 as an “A” Minor Arterial - Expander. The Metropolitan Council Transportation Policy Plan defines an “A” Minor Arterial as a “roadway within the metropolitan area which is more regionally significant than others.” An expander is a route which provides a way to make connections between developing areas outside the 1-494/694 ring. These roadways are to serve medium to long suburb-to-suburb trips. Improvements focus on preserv'ation of or obtaining right-of-way. The Hennepin County Transportation plan also denotes CSAH 15 as fc-' “A” Minor Arterial Roadway. B. Traffic Operations Characteristics CSAH 15 is a two-lane roadway with some exclusive turn lanes provided at certain intersection locations. The roadway provides a connection to Highway 12 on the east end thus making it an attractive commuter route for this area of the western suburbs. The roadway winds its way through Orono and extends west serving other Lake Minnetonka area communities and proceeds through Minnetrista into Carver County. The traffic lane availability is shown on Figure 2 for this corridor. 1 I I I ( I •H 9' r I mi »I \ •I ♦ I s I I I r r r r r r r r. i: i: c t i: t i I Figure 1 - CSAH 15 Corridor CSAH 15 Traffic Management Study Orono, MN 139806f2.dwg m Bonestroo Rosene Anderlik & Associates Engineers d Architects ! Figure 2 — Traffic Lane Availability CSAH 15 Traffic Management Study Orono, MN 139806f10.dwg I I I • i m n4 » • » ♦ l/jBoneatroo — Rosene H Anderlik & |\J| Associates _ Engineera & Architect! I I I C. Traffic Volumes Traffic volume information for CSAH 15 was obtained from MnDOT and from Hennepin County. The traffic flow maps provided average annual daily traffic volumes for the area roadways. These AADT volumes are illustrated on Figure 3. The Minnesota Department of Transportation has a continuous traffic count station located on CSAH 15 northeast of the intersection with CSAH 51. This station provides continuous hourly traffic volume data on CSAH 15 for every day of the year. Review of the January through June data of 1998 at this count station illustrates the volume variation that occurs along this roadway. Table 1 illustrates the daily averages for each day of the first 6 months of 1998. Review of the volumes on Table 1 makes it apparent that volumes increase quite dramatically during the summer months when compared to January, February, and March volumes. The weekday volumes in May and June are over 20,000 vehicles per day. It could be e.xpected that July and August volumes are similar to June volumes. When looking at peak hour volumes from the count data, the morning peak hour occurs from 7*8 a.m. and the afternoon peak hour occurs from 5-6 p.m. The average weekday peak hour volumes from the month of June 1998 have been calculated and are shown on Figure 4. Those volumes reflect a directional split of 80/20 in the morning peak and 70/30 in the afternoon peak thus indicating the home-work character of the trips during these peak hours. In order to make a determination as to whether peak hour traffic signal volume warrants at the intersections of CSAH 15 at CSAH 51 and at Orono Orchard Road are met with today ’s traffic levels, intersection turning movement counts were conducted during the 6-9 a.m. time period on a weekday in January 1999. The resultant peak hour of these counts is depicted on Figure 5. The peak hour volume warrant is satisfied at the intersection of CSAH 15 and CSAH 51. The peak hour volume warrant is not satisfied at the Orono Orchard Road intersection with CSAH 15, but it is quite close to satisfying the warrant. Remembering that the count was conducted in January, and that the summer volumes are higher, the peak hour warrant could be satisfied during the summer time period. D. Accident Experience Accident data for the three-year period of 1995 through 1997 was obtained from the Hennepin County Department of Public Works. During this three-year reporting period, a total of 63 accidents were reported to have occurred on the CSAH 15 segment from CSAH 51 to Femdale Road West. Of that total, 30 were attributed to the four intersections of CSAH 15 with CSAH 51, Brackett ’s Point Road, Orono Orchard Road, and Femdale Road. Figure 6 shows the number of accidents at the four intersections and along these segments between these intersections for the 1995 through 1997 reporting period. 4 \ i ,1 ♦ ♦ Figure 3 — 1996 Average Annual Daily Traffic CSAH 15 Traffic Management Study Orono, MN 139806f8.dwg ^ISonestroo Rosene Anderlik & >« |\]| Associates ^ Englneera & Architects * t I I I I I I I I I I i II Figure 4 — Average Weekday Peak Hour Volume Bonestroo CSAH 15 Traffic Management Study Orono, MN 139806f7.dwg Rosene Anderlik & |\|| Associates Engineers & Architects j. Figure 5 — A.M. Peak Hour Volumes CSAH 15 Traffic Management Study Orono, MN 139806f6.dwg J/lBonestroo ^ Rosene Anderlik & |\|| Associates ^ Engineers d ArchllecU I I I I r 1 r [ r. I I I I I I i i: L No Scafe • - INTERSECTION ACCIDENTS ACCIDENTS BETWEEN INTERSECTIONS ACCIDENTS ARE FROM 1/1/95 THRU 12/31/97 Figure 6 — Number of Accidents — 1995 thru CSAH 15 Traffic Management Study Orono, MN 139806f5.dwa 1 997 if i Bonestroo Rosene Anderlik & Associates Engineers & Architects I 1 ■i Table 1 Average Daily Traffic Volumes on CSAH 15 January Through June 1998 CSAH 15 Average Daily Traffic Volumes Month Monday Tuesday Wednesday Thursday Friday Saturday Sunday January 16,553 17,369 16,965 16,193 18,302 14,996 11,067 February 17,101 17,913 17.984 1.134 18,761 15,566 12,533 March 17,310 17,715 18,006 18,104 18,422 15,845 11,921 April 19,237 19,860 19,762 19,826 21,083 18,258 14,470 May 20,027 21,952 22,447 22,412 23,028 20,215 17,547 June 22,208 22,845 23,075 23,098 24,252 21,368 18,826 The data provided by Hennepin County allows for a review of the type of accident occurring during the 1995-1997 time period, l able 2 provides a compilation of those accident types at various intersection and roadway segments. The accident types that occurred most frequently were the one vehicle accident and the rear end accident. The one vehicle accident comprised 41 percent of the total accidents while the rear end accident type was 27 percent of the total 3-year accidents. These two types provided 68 percent of the accident types along CSAH 15 from CSAH 51 to Ferndale Road. These types of accidents are prevalent along a roadway that is narrow, congested, and lacking in turn lanes. The intersection accidents at the four primar>’ intersections along the study corridor have been tabulated and the accident rate has been calculated. The rate is compared to the 3-year county average for tee and 2-way stop controlled intersections. These data are provided on Table 3. The accident rate for the roadway segment between CSAH 51 and Orono Orchard Road can be calculated for the three-year period. This segment excludes the intersection accidents at CSAH 51 and at Orono Orchard Road. The number of accidents along this 1.37 mile segment and the accident rate (accidents/million vehicle miles) is shown on Table 4. J. I I I • « • » t i •»4 t f • I •-4 f • « • ♦ I I I r r r t t t I I I I I I I I I I Table 2 CSAH 15 Accident Types - 1995 to 1997 Accident Location Accidents By Group (1995-1997) Rear End Head On Left Turn Right Angle Side Swipe One- Vehicle CR51 Intersection 1 2 J 2 CR 51 to Bracketts Pt.9 1 8 Bracketts Pt. Intersection 1 1 5 Bracketts Pt. To Orono Orchard Rd.2 1 1 1 8 Orono Orchard Rd. Intersection 3 1 1 2 2 Orono Orchard Rd. to Femdale /Russell 1 1 Femdale/Russell Intersection 1 3 1 1 Total 17 2 3 8 7 26 Table 3 Intersection Accident Rates - 1995 to 1997 Accident Location No. of Accidents 3-Year Average Accident Rate' 3-Ycar County Average^ CR51 Intersection 8 0.37 0.43' Bracketts Pt. Intersection 7 0.34 0.43' Orono Orchard Rd. Intersection 9 0.40 0.70" Ferndale/Russell Rd. Intersection 6 0.27 0.70" * Accidents per million vehicles entering intersection ^ 3 years from 1995 - 1997 ^ Average for tee intersection Average for 2-\vay stop intersection Table 4 CSAH 15 Segment Accident Rates Number of Accidents*Accident Rate^Three-Year Average 1995-10 1995-1.05 1996-10 1996-1.09 1.35 1997-18 1997-1.90 ‘ Excludes intersection accidents ^ From CSAH 51 to Orono Orchard Road The 3-year county average for two-lane undivided county roads is 1.53. The three-year average accident rate for this segment of CSAH 15 is less than the county average. The 1997 rate is greater than the county average. E. Level of Congestion m The Metropolitan Council, in determining levels of congestion for regional roadways, has established vehicle per hour capacity values for various roadway types in the metro area. The lane capacity for an undivided arterial ranges between 600 and 900 vehicles per lane per hour. Considering data from the continuous count station, where morning and afternoon peak hour values range from 1200 to greater than 1500 vehicles per hour in the peak direction, the volume to capacity ratios are ranging from 1.33 to 1.72 for the peak flow direction. This indicates a congested condition for this roadway. The Hennepin County Transportation Plan indicates, for the year 2000, that there is a potential shortfall in corridor capacity along most of CSAH 15 with a probable shortfall along the segment of CSAH 15 near Highway 12. The conclusion of this analysis, given the daily volumes along the roadway, is that the facility is operating in a congested mode today. Hennepin County, in their transportation plan, has prepared traffic volume projections for the years 2010 and 2020. The year 2020 daily volumes along CSAH 15 are projected to be 22,000 near CSAH 51 and 27,000 near Orono Orchard Road. These reflect increases of 19 percent and 35 percent respectively, when compared to the e.xisting average daily volumes. A two-lane arterial facility such as CSAH 15 is usually considered to be congested when the daily volumes reach 13,000-18,000. CSAH 15 is not operating efficiently and the projected volume increases will cause further deterioration in the operations along the roadway. III. IMPROVEMENT CONCEPTS There are some improvements that can be made to the CSAH 15 corridor that will improve the capacity and safety along the study segment. The roadway is in need of additional capacity, but it is understood that the roadway is not to be considered for widening to four lanes due to its character as a scenic parkway. There are a series of improvement concepts that have been considered for this corridor. These concepts are listed below: # # Improve the entire corridor to provide a three-lane section consisting of one through lane in each direction plus a center two-way left turn lane. Provision of exclusive right turn lanes at public street intersections. Provision of left turn lanes at public street intersections. Provision of bypass lanes at public/private driveway locations. Access management. Provision of a traffic signal system at the intersection of CSAH 15 with CSAH 51. Provision of a traffic signal system at the intersection of CSAH 15 with Orono Orchard Road. Provision of alternative access to the Woodhill Golf Course. Provision cf adequate shoulders along CSAH 15. Provision of a three-lane section along CSAH 15 with the center lane used as a reversible lane during peak traffic hours. I I I I • I • I •-‘4 I » I •I • I • • I • ♦ -j ^ I I I I i * ? 4 i I f * ^ «r • • *4 » « * • » 4 » f r The key to the analyses has been providing an improvement package that will improve the safety and capacity of the CSAH 15 corridor and at intersections throughout the corridor. The following provides a brief discussion of the improvement concepts with regard to some of the positive and negative aspects of each. Provision of a Center Two-Way Left Turn Lane - The provision of a center two-way left turn lane (TWLTL) provides an increase for through movement capacity, and improves safety, particularly a reduction in rear end accident potentials. Such an improvement would require the provision of a TWLTL that would range in width from 12-feet (minimum) to 16-feet (desirable). This treatment could be provided for the entire length of the study corridor or only at locations where multiple access (public street or private drives) is present. Provide Exclusive Right Turn Lanes at Public Street Intersections - This lane provision reduces accident potentials at the intersections and increases the intersection capacity. The storage length of such lanes would depend on traffic demands but it is envisioned that storage lengths would not be less than 100 feet. A taper length of between 35 and 40 to one should be provided for each right turn lane. Provision of Left Turn Lanes at Public Street Intersections - This improvement type also reduces certain accident types such as rear end and sideswipes while providing an improvement in the intersection capacity. Turn lanes should not be less than 100 feet. Provision of Bypass Lanes at Private Driveways - A popular treatment along two-way roadways, one that increases safety and decreases delay, is the provision of a bypass lane for through traffic at a driveway location. Such bypass lanes are also used at low volume public street intersections. Access Management - Any improvement to CSAH 15 should consider the consolidation of access in order that the number of access openings can be reduced. Studies have indicated that roadways with fewer access openings have an accident rate that is less than a similar roadway with more access openings. Provision of a Traffic Signal at CSAH 15 and CSAH 51 - The peak period traffic count that was conducted at this intersection indicates that the peak hour traffic signal warrant is satisfied. The morning hours delay in negotiating a left turn from CSAH 51 to CSAH 15 is quite lengthy given the volumes on CSAH 15. It needs to be noted that from the CSAH 15 signal with CSAH 19, then proceeding east and north along CSAH 15 to Highway 12, CSAH 15 traffic flows unimpeded. CSAH 15 traffic does not encounter a signal or stop sign along this segment length of approximately 5.3 miles. A segment of such length does not allow vehicles to be in a platoon, thus decreasing the amount of gaps that would be available for traffic to access CSAH 15. Provision of a Traffic Signal at CSAH 15 and Orono Orchard Road - The peak hour counts did not satisfy the peak hour volume signal warrant. However, it could be possible that summer counts at this location would satisfy signal warrants. A signal, with some access management, may be an advisable project at this location. ♦ Provision of Alternative Access to The Woodhill Golf Course - The only access to the Woodhill Golf Course is via Woodhill Road from its intersection with CSAH 15. As with many intersections along CSAH 15, left turn movements onto CSAH 15 can be unsafe. Alternative methods of access to this golf course have been reviewed. Provision of Adequate Shoulders Along CSAH 15 - The shoulders along CSAH 15 vary from non-existent to a 5-6 foot bituminous shoulder. The strong majority of the route has very inadequate should widths upon which disabled vehicles can pull off the read or upon which police vehicles can “pull someone over ” for an infraction or to assist someone in need. Any improvement to this roadway warrants consideration of more adequate shoulders commensurate with county state aid standards. Provision of Reversible Center Lane - The provision of a reversible center lane provides two lanes in the predominant flow direction during peak hours of 6-9 a.m. and 3-6 p.m. During the off-peak, the center lane is used as a left turn lane. This concept would require a series of overhead lane control signals to operate. The negative about this system is that a long period of motorist acclimation would be necessary and the safety effects are minimal. IV. CORRIDOR IMPROVEMENT RECOMMENDATIONS The improvements along this scenic corridor should involve a combination of some of the alternative concepts described above. It is recommended that the following improvements ue considered for implementation: 1. 2. 3. 4. 5. 6. 7. 8. Provision of a center two-way left turn lane in area.'; where numerous access points are clustered. Provision of left turn lanes on CSAH 15 - Left turn lanes are presently provided at CSAH 51, Orono Orchard Road, Russell, Femdale, and Woodhill Roads. Additional left turn lanes need to be considered at all remaining public streets, which include Spates Avenue and Heritage Drive. Provision of right turn lanes on CSAH 15 at all public street intersections. Provision of bypass lanes at private access drives, other than those areas where a two- way left turn lane is recommended, should be considered on a case-by-case basis. Consolidate access drives wherever feasible. Each area with multiple drives will need to be evaluated to determine if access drives can be consolidated. The CSAH 15 study segment should, wherever possible, be provided with shoulders that are adequate for vehicles to pull out of the through lanes. A traffic signal should be installed at the intersection of CSAH 15 with CSAH 51. This will require the conduct of a 13-hour turning movement traffic count and the preparation of a signal justification report. Such documentation will be required to follow Hennepin County procedures. Installation of a signal would require some roadway construction at the intersection with regard to right turn lane provisions and possibly some left turn lane work on CSAH 15. There are public and private street intersections with CSAH 15 that could be closed and safety along CSAH 15 would be improved. These are discussed below: Spates Avenue - This street has access to CSAH 15 and to CSAH 146. The provision of a traffic signal at CSAH 15 and CSAH 51 would allow the closure of Spates at CSAH 15. I I I 1 I 1 I 1 1 1 1 1 I I I • 4 Traffic on Spates would use the Spates access at CSAH 146, then travel on CSAH 146 to arrive at CSAH 51. Access to CSAH 15 would be much safer at the signalized intersection of 15 and 51. Heritage Drive - A closure of Heritage Drive at CSAH 15 would provide similar safety benefits as the Spates Avenue closure. A connection from Heritage Drive would have to be built to CSAH 146 and that would require crossing of the rail trackage. Permission for crossing the rail lines may be difficult to obtain. Private Access South of CSAH 51 - There is a private access to CSAH 15 that is situated along CSAH 15 south of CS.AH 51. If a connection of this private road to Bay Ridge Road, another private road, could be implemented, then the access to CSAH 15 could be closed. Traffic would use Bay Ridge Road to access CSAH 51, then use the signal at 15 and 51. Since these are private roads, property owners would have to agree with this connection and closure. Concept drawings of two-way left turn lanes, bypass lanes, and shoulder treatment are provided TWO-WAY LEFT TURN LANE TYPICAL SECTION TWO-WAY L£FT BYPASS LANE 12* £ Q i I I ■ SHOULDBfi THRU TURN LANE THRU SHOULDER w i«- - -a*- - - f I f 4 t I » 4 • I • I • I 9^ Figure 7 — Roadway Improvement Concepts CSAH 15 Alternatives Orono, MN 139803f3.dwa I 1/1 Bonestroo Rosene Anderiik & < |\|| Associates j Englneera & ArcNtactf iI i ! V. EAST-WEST TRANSPORTATION NEEDS The physical features and topography of the City of Orono have made it difficult to provide for east-west movement within the City. At the present time, east-west movement in the City is accommodated along CSAH 15 from Spring Park to Highway 12; along CSAH 51 from CSAH 19 to CSAH 51; and along CSAH 84 - Fox Street from CSAH 19 to the CSAH l5/Orono Orchard Road area. East-west travel in the north part of the City, that area above Tanager Lake, Maxwell Bay, and Stubbs Bay have available the Fox Street - CSAH 84 Corridor; the Watertown Road facility; or travel north to arrive at the Highway 12 area. The construction of the Highway 12 super-two facility should help to provide for east-west Highway 12 travels that is an improvement over the present day Highway 12 roadway. Access to this new roadway will be available at CSAH 6 on the west and from Wayzata Boulevard on the east. CSAH 15, from CSAH 51 to Highway 12, presently accommodates approximately 20,000 vehicles on an average annual daily basis. During the summer months, these daily volumes exceed 23,000 and 24,000 along CSAH 15 in the study area. The future year 2020 average daily volumes have been projected, by Hennepin County, to be 27,000 in the Orono Orchard Road area. This volume could exceed 30,000 vehicles daily during the summer months. The increase in volumes along CSAH 15 will create additional accident potential and congestion for those using that roadway. It is possible to divert some of the CSAH 15 traffic to the Fox Street corridor by creating a smoother, more direct connection to CSAH 15 in the Orono Orchard Road area. This concept is shown on Figure 9 and involves providing a Fox Street/Orono Orchard Road connection on a curve rather than the present day 90 degree tee intersection. Fox Street, west of this connection, would require some improvement to create a roadway with adequate two-way width. The key to drawing some of the trips from CSAH 15 to the Fox Street Corridor is the provision of a traffic signal at the intersection of CSAH 15 with Orono Orchard Road. This will allow traffic from the central and north parts of Orono to use the CSAH 84/Fox Street corridor to access CSAH 15 to then proceed northerly to Highway 12. These improvements could be expected to reduce the traffic demand on that section of CSAH 15 south of Orono Orchard Road by approximately 1,500-2,000 vehicles per day. This improvement, in conjunction with the signalization of CSAH 15 at CSAH 51, will help to reduce the volumes on CSAH 15, thus helping to reduce the number of accident occurrences. VI. VVOODHILL ROAD AREA IMPROVEMENTS The access to/from properties on the northerly side of CSAH 15, east of Orono Orchard Road is available at Russell Avenue and W'oodhill Road, which is a private roadway. The Russell Avenue connection serves a residential area that is also served by Orono Orchard Road. The Woodhill Road access serves some residential homes and the Woodhill Golf Course. During peak traffic hours access to/from these two roadways can become quite hazardous in that gaps in traffic along CSAH 15 make it difficult to exit these roadways. I I I f i • i • I j •I • I m4 • I » « I I I t I t 4 I « » « t 4 II I tt II i: C Access to these areas would be vastly improved with the provision of a traffic signal at CSAH 15 and Orono Orchard Road and the provision of a connection from Orono Orchard Road to the golf course and residential area. Three concepts for improving this access are shown on Figure 10. 1 4 J L Figure 9 — Fox — Orono Orchard Road Connection J/| CSAH 15 Traffic Management Study Orono, MN 1 7Q«nRfQ Huin Bonestroo Rosene Anderlik & Associates I I I ►•1 ♦ I 9^ * I Engineers & Architects Figure — Woodhill — Orono Orchard Rd Connection Alternolives CSAH 15 Troffic Monogemcnt Study Orono, MN 1 'VOAnRf 1 1 Mmn COMM Bonestroo Rosene Anderlik d Associates Bngln««r« 4 ArcMtvcU Alternative Concept A proposes the construction of a frontage road connecting WoodhilfRoad to Fox Street. This frontage road would be located on the north side of the rail trackage that is adjacent to the north side of CSAH 15. This concept would allow for the closure of the Russell Avenue and Woodhill Road connections at CSAH 15. This, of course, would increase the safety along CSAH 15 and for traffic using Russell Avenue and Woodhill Road. This concept succeeds if a signal is installed at Orono Orchard Road and CSAH 15. Negative aspects of the concept include the wetlands that would be affected and the length of the improvement is more costly when considering other alternatives. Alternative Concept B provides a connection from Woodhill Road to Dickenson Street, which in turn connects to Orono Orchard Road. This connection would also allow for the closure of Russell Avenue and Woodhill Road at CSAH 15, thus improving safety. The topography, with regard to the difference in elevation between Dickenson Street and the new frontage road connection, is quite severe and may cause this to be an expensive connection. Dickenson Street would probably have to be improved as the roadway width is very narrow. This concept also requires a signal at CSAH 15 and Orono Orchard Road. Alternative Concept C provides a connection from a private road to Dickenson Street. This private road intersects Woodhill Road north of CSAH 15. This concept would also allow for closure of Russell Avenue and Woodhill Road at CSAH 15. A signal would be required at CSAH 15 and Orono Orchard Road. This concept would require connection to a private road. Alternative Concept D provides a connection from Woodhill Avenue to the golf course circulation area. This connection would not allow for closure of existing access along CSAH 15. This connection may be the least expensive of the alternatives given the distance to construct. This alternative would also benefit greatly from a signal at CSAH 15 and Orono Orchard Road. I I I .1 * I t i f 1 APPLICATION FILE NO. 2484 Woodhill Country Club Application for Amendment to 1968 Conditional Use Permit MATERIALS REFERENCED IN WOODHILL COUNTRY CLUB’S PRESENTATION AT PUBLIC HEARING IX)C« 11200J0 1 I 1. 0 4m • 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. INDEX OF MATERIALS HISTORICAL USE OF WOODHILL AVENUE 1887 Plat of Minnetonka Bluffs 1924 Plat of Orono Orchards Afildavit of Tony Feser, dated May 10, 1999 Excerpts of Deposition Testimony of John Morrison, George Jennrich, and Rick Fredricksen Letter of John Morrison to Mayor of Orono, dated June 23, 1980. DEDICATION OF WOODHILL AVENUE AS PUBLIC STREET Affidavit of John S. Pillsbuiy', dated November 12, 1998 Letter from James P. McCarthy to Cliff Greene, dated November 20, 1998 Letter from James P. McCarthy to Cliff Greene, dated January 26, 1999 with attachments 1968 CONDITIONAL USE PERMIT FOR WOODHILL COUNTRY CLUB 1968 Conditional Use Permit Application and Permit Minutes of Orono City Council, dated September 9, 1968. Excerpts of Deposition Testimony of Robert Searles SPECIAL ASSESSMENT OF WOODHILL PROPERTY FOR IMPROVEMENT OF WOODHILL AVENUE Notice of Hearing on Proposed Assessment to Woodhill Country Club, PIDNo. 02-117-23-12-0001. Orono City Council Resolution No. 2682, adopted August 28, 1989. Woodhill Avenue’s Special Assessment Certification Roll, from Hennepin County, Division of Property Tax 1987 EASEMENT AGREEMENT RELATING TO ACCESS ON WOODHILL AVENUE Memorandum of Orono City Administrator, from Mark Bemhardson to Orono City Council, dated October 6, 1987 re; Easement Agreement. Easement Agreement between City of Orono, Woodhill Country Club, and MSM Associates, dated October 15, 1987. \ i Doci» II20030M ; I I I r r r r r j n j 0 f 17. 18. 19. 20. 21. 22. 23. MAPS Quarter Section showing roads and residences Zoning Map Survey of Woodhill Avenue / Woodhill Country Club access, dated August 31,1998 AERIAL PHOTOGRAPHS 1945 1951 1962 1989 CHART 24. Comparison of Woodhill Avenue and Woodhill Road: Roadway surfaces, users, and trips per day. Doc<* 1120030'1 I I I f r i: c ti r I I I I t I I I 1. 1887 Plat of Minnetonka Bluffs —*---------- I A' i! I: ///i ■Vfr /// 1 » 1 ' I < i. ‘ ‘< 1 V ^ t » 1 • ( 1 ' ' «p ~• 0 1 1 «i 9 • ^ « *# 11 *0 ^ 1 ^rr ' ^ 1 0 ^ f f \ *%1 f 1 f t1 « 1 m m t C m « ^ 1 0 1 ^ ^ •w -I J t* «• .•I f * n tt I /• i"' r* m c 0 m 0 i~:-\tz; . « • f.« ta T ! -JL-, •4 . •< m 1 0 1 « A 4 I fO00£gT sfMtir if~n ^ ' 1 II • < ^ II i f 1 IT • < 1 u r < # 4\ 0 i m '1 4 ^ /I r 4 • ^1 « i V'4 ^ \ M \ # 4 4 4 aaer- f^ll'1 < 1 H A < \ u A ^ t m # 4 ^ 4 A 4 1 * \ •. 1 k m ' r ‘ * “ 1 15 • 4 1 4 A 4 t 4*4 4 1 4 4 ^ 1 4L ^ 4 r4so4S0Cmi r^1*iu4 1 M A 4 1 II 1 “5 1 M • 4 \ 4 4 4 L FJ 1 4 ^ ;_J f 1 1 4 f 4 1 4 ! i ^ 4 4 A 4 i ^4 ] m FT I 1 4 A .( 1 4 • • 1 4 • 1 t 4 A < ^ 4 t « 1 4 A < ‘ 4 A 4 1 m ( A < 4 4 1 -4 < 4 4* , 1 « < 0 « 4_ ^ 4 m ArmAr A 4 1 m A < 4 AA A < 4 4 f 4 L ^ 4 4 i i 4 4 A. ( 1 4 A; < 1 m A 1 • 4 •A 4 !—^ikA* 4 1 srmstr I:4 0 A ^ 4 4 i 4 4 4 # 4 1 4 1 . ^ ^ 1 4 1 ^ 1 1 1 4 A 4 1 4 • 4 > A 1 k • ( I 1 AA A 1 M A • 1 4 A < 4 Ai # 4 4 4 $f 4 4 A 4 A » 4 1 4 A . 4 A A • 0 4 4 4 4 A 1 t 2^ r ■; I . --------------- '• iM-•'Y< ?i !.' f • ■ • • MINNETDNKA.BLUFF.S. ' Jr««r*/r ■___________‘ * • • • • • % w ^.4. 0^^. i • —M m 0 ^ A • •■» « «•» ■ » •‘•A.— ■'v-• « •Ai? %•« • #/• X *^ut^ "zizrk^rK I*. f —iMJGfi' I > •A ^0 %i00T ^ 9^ J0ii0% y^*«A •%/ t# St. 2. 1924 Plat of Orono Orchards • r Z7 Orono Orchards HElNjrvjEPiN. CO. MIM k;. II .— i:^ >Mr •, /c'f /^^ ^4^rnm . i!t1*J•« » « j.1 ^'<b-------L_:S*_______!“•-rn 'Cmmm 'r.' ^ £U>g.)kM%^ I O,'.imt^' X^ \ I I I f: I . r I « I 3. Affidavit of Tony Feser, dated May 10,1999 » f I I STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT OTHER: CIVIL Woodhill Country Club, a Minnesota non-profit corporation, Court File No.: MC 98-10541 Plaintiff, V.AFFIDAVIT OF TONY FESER City of Orono, Gabriel Jabbour, in his official capacity as Mayor of Orono, and Ronald Moorse, in his official capacity as Orono City Administrator, Defendants. * STATE OF MINNESOTA COUNTY OF HENNEPIN ss. I, Tony Feser, being duly sworn, state as follows: 1.I am a resident of the state of Minnesota and currently reside in Wayzata, Minnesota. 2. I am currently 86 years old and, except for military service, have lived my entire life in Minnesota. 3.My father moved to Minnesota around 1900. Staring in approximately 1910 he worked at the Criss-Cross Farm. As part of his duties, he would make deliveries of farm produce to families along the Minnetonka shore in what is now Wayzata and Orono. As a young boy, I would ride with him. At that time there was no County Road 15. We would proceed up what is now called West Femdaie to Russell Avenue, then west on Dickinson to Orono Orchard Road. To proceed around the lake, we would then go south on Orono Orchard Road. Going north on Orono Orchard Road led us to Woodhill Avenue. Woodhill Avenue was the west entrance of Woodhill Country Club. Doc* 1119616M 4. 5. 6. 7. 8. 9. 10. Woodhill Avenue entered the Woodhill property near the original bams and farmhouse. Woodhill Avenue was the original entrance into the farm. My cousin, Leo Feser, worked initially at the Orono Golf Course and then worked at Woodhill Country Club from the 1920's to the early 1950 ’s. I began working with Leo at the Orono Golf Course as a teenager and then continued to be employed by the Orono Golf Course until December 1941 when I enlisted. In the 1930’s, I worked on rebuilding one of the barns at the Woodhill Country Club that had burned. It is my understanding that the barn was built by the Fendersons, who were the original owners. The Fendersons sold to Keesling who sold to Dunwoody. The barn that I rebuilt In the early 1930's is the bam that still stands today. Throughout my work at Orono Golf Course and the Woodhill Country Club, I regularly traveled on Woodhill Avenue. Woodhill Avenue was regularly used by Woodhill members and guests, as well as by commercial and delivery vehicles. Woodhill Avenue today from Orono Orchard to the Woodhill Country Club bam follows the same route as it did in the period from the 1 920’s to the 1970*s. Norman Clark was the original golf pro at Woodhill Country Club. He lived in the house on the southeast comer of the intersection of Orono Orchard Road and Woodhill Avenue. Every day he would commute from his home to Woodhill Country Club using Woodhill Avenue. Once inside the Woodhill property just east of Woodhill Avenue, there was a stable master’s house and then the original farm house. Over the years, both houses were occupied by various Woodhill Country Club employees and their families. Woodhill Avenue was the common way of access to both houses. After the war, I was employed by an oil company in Wayzata. I worked there until my retirement. As part of my duties for the oil company, I delivered fuel oil to Woodhill Country Club. As part of my regular route, I would drive to the Club and then drive the delivery truck out Woodhill Avenue to the two houses at Orono Orchard Road and Woodhill Avenue. After filling the Norman Clark house. I filled the house on the north side of Woodhill Avenue at Orono Orchard Road. I also recall seeing lumber trucks and bread delivery trucks on Woodhill Avenue. Doc« U19616\l DATED; //-» C7 Tony Feser iy \ Subscribed to and sworn to before me this //-fA day of May, 1999. Notary Public in andfoMh^ State of ^Minnesota uicNAas.somBiinBi Nowwiir ywciott Mr CWMMW Eqlm «n n. nii DOCK 1119616M I I I r r r I r \: r r I i: i 1 L ( L 4. Excerpts of Deposition Testimony of John Morrison, George Jennrich, and Rick Fredricksen I iy I r I r r I I I I I I I I I V I I 1 2 3 4 5 6 7 8 9 3 11 12 13 14 15 16 17 18 19 20 2 1 22 23 24 25 JOHN W. MORRISON south, Woodhill Avenue and Woodhill Road. THE WITNESS: Well, Woodhill Road, I think, is a privately owned road. MR. MCCARTHY: Well, we're going to get to that, and you're correct, those are distinctions. BY MR. MCCARTHY: Q. Now, during the period of time of time that you socialized with your future wife and her family, how would one exit the club to go visit her in Long Lake? A. Well, the shortest and most direct route would be to go out the driveway that exits onto Woodhill Avenue, the back road so to speak. gets to Orono Orchard Avenue, and goes directly over to Long Lake. That would be the most direct and quickest. Q. And in fact that's a route that you took on occasion to visit your future wife, I take it? A.Sure. Yes. Q.And at the time that you traveled that road in the 1930s, 1940s, was it a passable road? A.Oh, sure. PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) I I ■4 "7 3 • I ;if Uc S ni ! 4 :» I 1 2 3 4 5 b 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2 1 22 23 24 25 JOHN W. MORRISON Q. A. Was it a — how was it paved? Well, my memory isn't terrific on that, I think it was a gravel road all the way to Orono orchard. i think. That's my recollection. Q. Your use of this road spanned a number of years? A.Sure. to the road? Q. And was it your experience that the road remained passable? MR. GREENE: When you're referring MR. MCCARTHY: Excuse me, thank you. Cliff, I should have given the nomenclature here, I should be more careful. BY MR. MCCARTHY: Q. When you used Woodhill Avenue, the road that was gravel, did it remain passable? A .Yes. Q. And how were you traveling on Woodhill Avenue, was it on foot, with an automobile? A.Automobile. Q- Do you know whether other people had occasion to travel by automobile on Woodhill Avenue back prior to the time you married your PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) I I f I I I I 1 2 3 4 5 6 7 8 9 10 11 19 20 2 1 2 2 2 3 2 4 25 JOHN W. MORRISON wife in 1942? A. Yes. Her parents who also belonged to the club used it. Her sister who was — no, wait a minute, that was after the war, in the 30s. I don't remember offhand, but I'm sure there were, I just don't remember. Q. At any time prior to the time of your marriage 1942 did the then Townsnip of Orono ever blockade the road in any way? A. Not to my recollection. Q. To the best of your knowledge were 12 you ever informed or ever learn of any 13 limitations that the Township of Oroi > put on 14 use of that road? 15 A.No.At that t ime? 16 Q.Yes,at that time. 17 A.No.No. 18 Q.Did you have an understanding at that time prior to the marriage, your marriage in 1942, as to whether that Woodhill Avenue was a public street or some sort of private driveway? MR. GREENE: I am going to object on the grounds that it calls for a legal conclusion and lacks foundation. You can answer. THE WITNESS: I guess I had — PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) \ I I I r I I I I I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2 1 22 23 24 25 JOHN W. MORRISON repeat the question. BY MR. MCCARTHY: Q* Sure. Did you have any understanding at that time as to whether woodhill Avenue was a public street or some sort of private driveway? A.I guess I -- I assumed it was a public street, but that connected with Woodhill property and didn't go all the way out to Orono Orchard Road. Q. You were aware that the Woodhill property stopped before Orono Orchard Road; is that correct? A.Yeah. At that time I didn't know where the property was, but I knew it was somewhere. Q.Did you have occasion to travel _ this is again prior to 1942, travel on Woodhill Avenue in the winter coming out from the skating rink with your wife and family? A.Sure. Yes. Q. So is it fair to say that Woodhill Avenue was kept open through the winter back in the 1950s? A.To my recollection, yes. I don't PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) t B ^ [ I • V JOHN W. MORRISON 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2 1 22 2 3 24 25 ever remember it being closed. Not the avenue, I mean the driveway. Q. A. But I mean Woodhill Avenue? Yeah, it was always open as far as I know. Q.And let me now go to the period of time when you moved to Long Lake in 1950. At that time your son was about five years old; is that correct? A. Q. Yes. And your daughter was born two years after you moved into Long Lake? A. Q. That's right. Could you just explain for directional purposes where Long Lake is located in relationship to the Woodhill Country Club? A.It would be northwest I think. you exited the Woodhill property on Woodhill Avenue, which goes roughly east and west I believe, you would turn right on Orchard Road, and that road winds around and generally goes north, you would run right into the lake. Long Lake. The City of Long Lake is just to the -- about a half a mile left on Highway 12, and our house was about half a mile to a mile to the PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) JOHN W. MORRISON 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 0 2 1 22 23 24 2 5 right on -- just off of Highway 12. Q.Okay. So you would take Orono Orchard Road up, and then where that would intersect would be with Highway 12? A.Yup. I go left and go to the Lewis house, and then -- I'm sorry. I'm jumping ahead. Q-So your house was on Long Lake to the right of where you once came out on Highway 12? A. Q. Yes . Did you travel on Highway 12 to get to your house or did you cross over Highway 12? A. Q. A. We're now in the 1950s? Yes. Yes. You travel on Highway 12 for about half a mile I guess. Q.So in 1950, and I take it you lived in that house from 1950 to 1960; is that correct? A. Q. Um-hmm. To travel from your home to the Woodhill Country Club you would come out onto Highway 12? A. Q. Yes. Come out onto Highway 12, go west to the intersection with Orono Orchard Road? PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2 0 2 1 22 23 24 25 JOHN W. MORRISON A. Q. Yup. And then take Orono Orchard Road down to Woodhill Avenue? A. Q. Correct. You would then proceed east into the Country Club along Woodhill Avenue? A. Q. A. Right. And the same route going back home? Yeah, you -- you could go the other way, and we did, we did both. Q. A. The other way being which way? The other way would be going in towards Wayzata. Q. A. On Highway 12? On Highway 12, and then taking a right and going all the way down to Highway 15. Q.Down to Highway 15 and then Highway 15 over to the Woodhill Road entrance? A .That's right, you could do that. It was a little longer. Q.Now I would like to go through that time. During that period of time when you were living with your young family and living in Long Lake, I would like to understand the types of activities that you and your family would be I PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) I JOHN W. MORRISON 28 Woodhill Avenue entered the property; isn't that correct? A.That's right. Q. And did you have occasion to use the skeet range? A. Yes, I did. Q. Now, were there ever dances or social activities at the club? A. Yup. Q. Did you and your family participate in those? A. Yes, from time to time. Q. Did you ever use the dining facilities at the club? A. Yes. Q. Did you and your wife ever attend parties put on by other people at the club? A.Yes, we did. Q. And this was an activity that you engaged in in a pretty constant pace from 1950 to 1960; is that correct? A. Yes. Q. Now, when you engaged in these activities would you go to the club by automobile? PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JOHN W. MORRISON A.Yes . Q.Were you ever in walking distance? A.No. Q.So the activities we talked about you and your children would get -- you would either transport yourself or transport your children by automobile? A.That's right. Q.And when you would go to these activities, would you regularly use the Woodhill Avenue entrance to the club? A.Yes . Q.And during the decade that you used the Woodhill Avenue entrance was the road paved with gravel or some other substance? A.I don't -- not to my recollection. I think -- oh, it was gravel, yes. Q.Gravel? A.It was gravel I believe. MR. GREENE: Let me make sure I understand. Your answer is there was gravel but not pavement? THE WITNESS: I don't think there was pavement. I don't remember for sure. MR. GREENE: Thank you. PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JOHN W. MORRISON A .I really don't know, but I would assume it is. It certainly looks that way because the skeet range would be —— they wouldn't have the skeet range on somebody else's property. So it would have to be right next to the property line. Q.And that house that was up to the right on that road, that was also on Woodhill property? A.Yeah. I understand that was the original farmhouse. Q.All right. Is this depiction of Woodhill Avenue shown on this photograph an accurate depiction of what you recall driving on between 1950 and 1960 when you drove into the Country Club? A .Yes, that's for sure. Q.And the photograph shows a uniform width and surface? MR. GREENE: Object. I am going to say that that's leading. BY MR. MCCARTHY: Q.Could you describe for me the -- let me step back. Does looking at this photograph refresh your recollection of what the width and PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (V22) i I I I I I I I I I I I I I 1 2 3 4 5 el 7 8 9 10 11 12 13 14 is! 16 17 18 19 20 21 22 23 24 2 5l JOHN W. MORRISON surfacing of the road was at the time you drove on it in the 1950s? A.looking at the photograph it doesn't. But as I recall, as you turn off the Orono Orchard Road on Woodhill Road -- onto Woodhill Avenue it was a, you know, a straight shot for a while and then curved a little bit. then went into the club property. Q.Do you recall any change in the width or surfacing of the property where it went through that little curve before you went onto the Woodhill property? No. It think it was narrowed a little bit when you got onto Woodhill property. but I don't recall that there was any change in the width of the road prior to that time. Q. And I would like to draw your attention specifically to that area of Woodhill Avenue between where it first curved to the south, in this photograph down to the right A.Yes . Q. property. And where it enters on Woodhill A. Q. Yeah. In that section, do you recall any PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) i5- I I I I I I I I I I I I I I I I I I I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2 1 22 23 24 25 JOHN W. MORRISON Q.All right. Do you recall communicating in any way to the Mayor whether Woodhill reserved any rights to reopen the -- its driveway to the west co vehicular use? MR. GREENE: Objection, leading. THE WITNESS; Well, yes. Clearly I remember all through this process we wanted to make it absolutely clear that we reserved the right to open that road —— to open that road to cars and use it. BY MR. MCCARTHY: Q.In the last sentence of your letter. if you could read that, please. A. Q. Okay. Could you tell me, it says, “As you know, by taking this action we do not in any way want to limit our right to use the back entrance should future circumstances warrant a change in this decision." A . Q. A. That's right. What did you mean by that? I meant if we ever felt, for whatever reason, that it was desirable or necessary for us to allow cars to use that back road, that we would reserve the right to do PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) / r I I I I I ( I I I I JOHN W. MORRISON And we didn't want to give up that right, incidentally i never heard anything objecting to that sentence from the Mayor at that time. Now, up to this time you had been communicating, had either the Mayor or anyone from orono ever told you that the club did not have a right to use that west entrance? Never. Did the Mayor or anyone else from the city ever tell you that some type of conditional use permit or other permit from the City was needed to use that entrance? Never. Did the Mayor or anyone else from the City ever say that they could if they wanted to shut down that road? Never said that. if they had I would have objected to it. Q- After you communicated, sent this letter to the Mayor, did you ever hear back from the Mayor anyone else at the city saying that they disagreed with your last sentence? No . Q.Do you know whether oil or gasoline or food or other service deliveries were made to PAT CARL & ASSOCIATES (612)591-0535 OR 800-591-9PCA (722) jroige Jenniich Condenselt F4q« I 1 2 1 4 i 4 7 • 9 10 11 12 U U u u I ’ li , u :o I2J 2i Z'i STATE or HINNCSOTA COUMTt or HENNCriN 01STRICT COURT rOURTH JUDICIAL OISTMCT HoooMU Country Ctu». « Hifxnofot* non-profit corporttlon* PUlntirC. riu no. RC fl-l0S4l City or Orono, CARrloi JARteur. in hif otriclAl capoelty «« luyor of Orono# AAO Ronoia Moerto. lo Rit efficl«l CApocity At OeoAO City AMniitrAtor. DAfonOAiitt. TRa UApotiUon or CEORCE JENNRICM. poKiwAiti VC. Noticv of TAfcinq OApotition. tAton ootor# Ann Raci* NoilAnd. a oetAcy ?uollc in ona tor tlio County of WAtninqton. StAt# of HlnnoaotA* tAton on tl»o ntn 4Ay Of fAbcuACy. IfW. At 4200 IDS Conttr. to SouUi Eiqntn Strtot* mnnAApoll*. RlnnototA. coRRoncinq At «pproBlOAt«1y 12*0 p « Depo-Squish Page 3 GEORGE JENNRICH, the Wit?v?c above^titled tnatter after having been ftrst duly sworn deposes and says as follows: CROSS-EXAMINATION 7 BY MR. GREENE: 8 Q. Would you please state your name? A. George Jemirich. Q. What is your address? A. 10610 32nd Avenue North, Plymouth SS441. Q. Would you please give the Court Reporter your name phone number? A. (612) 546*7648. Q. Would you give her your work phone number? A. (612) 561-3239. . Q. Where do you work? A. 1 work at Cenierbrook Golf Course. It is owned 19 by the City of Brooklyn Center. Q. What IS your title there? A. 1 am golf course superintendent. Q. Would you please provide us with a summary of 23 your education, starting with high school? A. 1 graduated from high school. I went to 25 college at the University of Minnesota. I graduated in 9 10 11 12 13 14 15 16 J7 18 20 21 22 I I I I I * 4 3 6 7 U V lU II 12 I) 14 15 16 17 U IV 2U 21 mm 23 24 25 AfREARANCES: JAME5 P Mc I ARTKY esquire , of iht Uw FifW ul UNUgUlST 4 VEHNUK f LLR. 4200 IDS Cttm, SO South Eighth SUACt. MifW«ApPlt4. Minwo ti 55402. appetfud lo» and on bchal/ of the Plairiifl. C UFFORD GREENE. ESQUIRE, of the Uw Hirm of GREENE tSPEL P L Lf. i hJD Mettopoliun Cenire. 3)3 South Scyc««hbuuet.MtnnBjpo4iA,MinnBaou 55402. .appeared for and on behalf of the Ofendanto, * rhc OnginAl n m the puAacAgion of ADomry Clifford Orume * Alao preaenL Sharon C Fnteti. ParalifaJ • • • GEORGE JENNRICH CroifEAaminaiion by Mr. Grume................... Oircci Examnaiion b^ Mr. McCarthy .................Paft 56 KocroaA*E.xaminaiJon by M/. GeHoe.................Fy J) Kadtrtct fcjiaounaiion by Mr. McCarthy ...............Pdf* ExhilNCl53Marlwd.M^ Fag*6 Eahibn l54M«1to4.Map .........................Fy 2 E.xhibit 155 Marted, Map.........................Fafe^ Exhibii 156 Marhod, Copy of ra»olyiion..... Faff 20 fcOubii 157 Marted. Uoc4»oi«mdand 5/16/71 . .. FdftTl Kirby A. Kamedy & Aefociates (612) 922-1955 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 4 '69. After I got my degree in '69, my Bachelor of science, i spent two years in the service, and did some postgraduate work after 1 got out of the service in '71 and '72. Q. What was the field of your academic focus? A. It was turf management. Q. Can you summarin: your employment history, focusing on full-time employment, if you would? A. Okay. Full-time was after I got out of the service, I worked at — I worked installing irrigation systems for a company called Custom Turf in St. Paul. It was around '72. 1 then worked at Town & Country Golf Course for a year. Then I went on to Cannon Falls, as the golf supcnniendeni lor a year. Then in '71,1 spent from *71 to 1990 I was at Woodhill Countfy Club. Q What position - go ahad. A. 1 was an assistant at Woodhill one year, and then, 20 years the superintendent. Q. Can you describe the functions that you were responsible for at Woodhill Country Club? A. Sure. Yeah, 1 was responsible for all of the grounds, all of the out buildings, which include the bam, the winter sports center they call it, the swimming pool, pro shop, tennis courts. We bad ten hard court tennis couru. and. of course, the golf courre. And in the winter, we took care of the icerinks age 1 ’ ige 4 George Jcimrich 1 Condenselt Pepo-Squish 1 2 3 4 5 6 7 8 9 lU 11 12 13 14 15 16 17 18 IV 2U 21 22 23 24 25 Page 41 I am going to sliow you a document that has been marked deposition Exhibit 37. These are minutes of the Board of Trustees of Woodhill Country Club, June 30, 1977. 1 am going to ask you to read the first sentence. I will read it into the record so we know what we are talking about. "The president also reported that David Crosby (who could not be present), and others have urged that the back entrance road from Orono Orchard be reopened." Do you see that portion that 1 read? A. Yes. Q. Was it your understanding that prior to 1977 there was a period of time when the back entrance road from Orono Orchard had been closed? MR. MCCARTHY: Same objection as to the use of this document as to the previous. The witness didn't author it, didn't attend the meeting. MR. GREENE I am not asking him about this document I think my question can stand on its own. MR, McCAR i HY That IS part of the objection I have, showing a document and asking a question that IS not based on the document. MR. GREENE: Ttus is the document I am asking this witness who is responsible for maintaining the roads whether there was a period of time in his mind where Page 42 1 the roads had been closed prior to June 30.1977. That's 2 all 1 need to know, so the record is clear. 3 MR MCCARTHY I objcct as to vague. He 4 indicuiod at uines lhai gale was locked. By closed, do you 5 mean whether the inembos had keys or not? 6 MR GREENE, t Can ask him all of those 7 questions 8 MR. MCCARTHY aU right. 9 A. Could you rephrase your questioo again? 10 Q. Sure 11 BY MR GREENE 1 2 Q Was then; any penod of lime prior lo June 30. 1 3 1 977. whoe ihe Board of Trusioes had communicated to you 1 4 the fact of their dtieciion that the back entrance road from 1 5 Orono Orchard must be closed? 16 A. I can't really recall. 1 can't recall. That 17 IS a long lime ago As far as I know, it was most of the 18 time It was open for traffic lo go through the pte. I 19 can't recall It ever being closed. 1 am sure they didn't 20 want people to go through it on a regular basis. 21 Q. Let's go back to the period of time between 22 1978 and 1979. 23 Were you familiar with a dispute lhai arose 24 bctvreen Mr. Momc Wagnv. who lived off of Woodhill Avenue. 25 by off of Woodhill Avenue. 1 ihink his addicu is a Woodhill Page 43 1 Avenue address, and the club concerning traffic to and from 2 the club on Woodhill Avenue? 3 A. Yes. 4 Q. What do 'you know about that incident or that 5 series of disputes? 6 A. I know ** I believe Morrie wrote at that time 7 a letter to the club. I am not sure. But, Morhe used to 8 talk to us all of the time and we were *- myself and my 9 assistant, Rick, we were friends with Morrie, and Monie 10 wanted to. I believe he wanted the road closed. That's why 11 it was never used very often at that time, so we didn't 12 offend Morrie or anybody. That's kind of all I recall. 13 1 don't know. I heard he may have wrote a letter to the 14 Board of Directors to have the road closed. 15 Q. Was there a period of time in 1978 and 1979 16 where there was more traffic than was typical over Woodhill 17 Avenue to and from the club? 18 A. I can't recall that. 19 Q. bo, you don't recall whether Mr. Wagner 20 was protecting a change in conditions in 1978 and 1979, 21 reflecting his perception that traffic to and from the 22 club over Woodhill Avenue was more intense or frequent 23 than it had been earlier in the 1970's? 24 A. I don't believe so. 25 Q. You don't believe so? Page 44 1 A. I don't believe he was prottiing the increase 2 in traffic. I guess what I am testifying, I don't think 3 there was an increase in traffic. 4 Q. Again. I would like to know in your own words, 5 bow much traffic came m through that back road during a 6 typical day in the 1970‘s? You mentioned bringing vehicles 7 u> be serviced in Long Lake? Is that where you went? 8 A. WeU. in the early sevenlies. I know for sure 9 we had employees coming in throu^ that pie that lived over 10 in the area, and they ucre Frank VoigbL the tennis pro. 1 1 Kip Eisener: Ed Clampy (phonetic): and soenetiincs it was 12 Rick Engman that would come through that pie on a daily 13 basis. Besides that, a few memben would use it but just 14 a few. It wasn't many. It probably wasn't ow ** it was 15 probably less than ten cars coming ihrougb there a day. 16 Q. So. almost all of the iraffic coming to and 17 from the club used the Woodhill Road access point? 18 A. Instead of Woodhill Avenue, right 19 Q. And that was the case ifarougbout the 1970's? 20 A. Yes. 21 Q. In 1980, in the period just a few years beyond 22 1980, did you construct a berm, a thiee*foot high benn 23 across the Woodhill Avoiue driveway within Ihe club's 24 property? 25 A. This is before 19807 Kirby A. Kennedy A Associates (612) 922-19SS 8ge 41 - 8ge 44 I I I F Georec Jemuich Condenselt r L Dqio-Squish Page 49 1 Q. Yes. Through the club. 2 A. Yeah. I didn't notice any changes. i MR. MCCARTHY: Have wc established that 4 the homes were built while he was there? 5 BY MR. GREENE: 6 Q. Were any homes built or in the process of 7 construction while you were there? 8 A. I think there was some clearing action up 9 there. I don't know if there was any homes actually built or 10 not. It was real close to the time that they were built, 11 so. 12 Q. Did you have any occasion to secure pennits 13 from the City of Orono for alterations that were made to 14 the buildings and grounds, including the golf course, at 15 Woodhill? f6 A. No. 17 Q. If such approvals were needed, who at the club 18 would be the person most likely to have the responsibility 19 for dealing with the city? 2U A. 1 think the manager would be, the general 2! manager 22 MR. GREENE: Off the record. 23 (At this tune a discussion was held ofT the 24 record.) 25 BY MR. GREENE Page 50 1 Q. Your counsel has indicated that you may have 2 some testimony to give concerning situations when Woodhill 3 Avenue was the exclusive means of accessing the club. 4 When were those situations? 5 A. I can't give you the exact dates. I can tell 6 you what they were. Probably in the seventies and eighties. 7 there was one load of something heavy in a railroad car and 8 It spread the tracks and it tipped and it blocked off our 9 entranceway, so all of the traffic had to be routed through lU Woodhill Avenue. And another tune ■* I think we had two 11 railroad incidents And another tune, they V<ad to fix the 12 track in the roadway, the railroad uack, and blacktop it. 13 They could run no traffic across that blacktop and it had 14 the rails all dug up and stuff, so they came through 15 Woodhill Avenue lb Q Let me ask the question with reference to 17 the fust incident, the rail spill. How many days was it 18 necessary to use the Woodhill Avenue access to the club as 19 a result of the derailment'’ 2U A. i think it was a couple of days. I am not sure 21 of that. But. It was more than one. I believe. 22 Q. More than one day and less than a week? 23 A Yes. 24 Q. How about the second incident that you recall, I when there was repair work being done on the trades; is that Page 51 1 correct? 2 A. Yeah. 3 Q. How many days was it necessary to use the 4 Woodhill Avenue as an alternate access? 5 A. It was a day or two. 6 Q. Are there other circumstances that you can 7 recall? 8 A. There is two railroad circumstances I know of, 9 and repairing that blacktop and taking out ** and putting ic 10 new rails. That's all I can recall. 11 Q. Just those two railroad circumstances? 12 A. Uh-huh. Yes. 13 MR. GREENE: off the record. 14 (At this time a discussion was held off the 15 record.) 16 BY MR. GREENE: 17 Q. You indicated that in the 1970's there was 18 a gate that was padlocked shut at some points and open at 19 other points: is that correct? 20 A. Yes. 21 Q. Who had keys to the padlock? 22 A. Gro<mds crew. Not all of them, but the 23 full'ume grounds crew usually had keys to the padlock. It 24 might have been the tennis pro, too. 25 Q. H'^w many people would have keys? What number Page 52 1 of people would that be? 2 A. About five or six. 3 Q. So, if someone came in at night and found the 4 gate locked and they had a key, they could open it, is that 5 what you are saying; one of those five or six? 6 A. Yes. 7 Q. Is it your testimony that the grounds crew 8 regularly used Woodhill Avenue to access their jobs and they 9 had keys to open and close the padlock? 10 A. In the seventies, yes. 11 Q. What about in the eighties? 12 A. Not •• the question is regularly? 13 Q. Yes. 14 A. Not regularly. 15 Q. So. the times that the chain across the barrier 16 poles that you described earlier would be removed bad more 17 to do with taking the tractors to be serviced, that sort of 18 thing? 19 A. Yes. 20 Q. How often during the course of a year would 21 the tractors be taken across Woodhill Avenue to be 22 serviced? 23 A. Three or four times, I would suspect. 24 Q. Each tractor? 25 A. Oh, no. Three or four times a year probably. Kirby A. Kennedy & Associates (612) 922-19SS 49 • 52 ft>qK>-Squish Condenselt George Jennrich II II i 8 II li' 10 1] 12 13 IE IE IS 6 7 18 9 IE If 3 24 5 1 II3 li 11: 10 i 16 T>9I L25 Page 53 Q. So, three or four tunes a year the club would have occasion to run a vehicle through the open barrier so it could get to Long Lake '0 be serviced? A. Yes. MR. GREENE: I ani going to show you another copy of 90. MR. McCARTlri': Off the record. (At this time a discussion was held off the record.) MR. MCCARTHY: It is Exhibit 153. BY MR. GREENE: Q. Earlier, you mentioned that there was a stretch of road that you did not surface with aggregate as part of regular maintenance. Can you circle the area of road that you are referrirtg to or shade it in or in some way designate it on this exhibit? A. Is this western property line, is that where the power lines run through? How accurate does this have to be? Q. This doesn't have to be accurate like a surveyor, we are just trying to get the general area to which you did not apply aggregate surfacing. MR. MCCARTHY: On a regular basis. A. On a regular basis. Yeah, we did throw some materials in there. (Marking.) Page 54 Prior to what? There is a curve in the road. Well, something like that. MR. MCCARTHY: The witness asked about the curve. There is a curve. This is a more detailed blowup, the road continues after that point If you need a different map to show a longer road, you could do that. THEWTTNESS Well, ycah. MR. MCCARTHY The witncss can take a look at Exhibit I S3. MR. GREENE: Or even 154 MR. MCCARTHY: Right, or 154. A. It went down to about where the curve was. (Marking.) BY MR. GREENE: Q. So, the area that you have indicated on Exhibit 153 with hash marks is an area that was rruuntained differently from the other gravel or aggregate surfaced roads within the club property; is that correct? A. Yes. MR. MCCARTHY: The record should reflect that the witness has indicated that on Exhibit 155 that point continued to about the curve south of the road, past what is now shown as a new maintenance building; is rhat correct? It wasn't there at the time. THE WITNESS: YCS, it WCnt past. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 55 BY MR. GREENE. Q. Let me ask this question. You may noi have a recollection, but I am going to be very specific. During the calendar year 1989. did you perform or are you aware of having performed any mainteiuince on the section of intenor oriveway that would have been west of the site of the maintenance building? Again. I am just asking if you have any recollection of having done so during 1989? A. I am sure we did. yes. Q. What is that recollection based upon? A. I am sure we back bladed the road. Q. Where would you back blade the road to? A. Well, we would have done the whole thing (indicating). Q. Who typically did that at the club? A. Oh. it could have been myself, it could have been'one of my employees. Dean Peikey or Rick Rngman. or whoever was a fuU*time employee. Dan Kavcm (phonetuj. Q. My question was a very specific cne. Do you have any specific recollection of that having been done in 1989? A. No. but we did il on a yearly basis Q. The back blading? A. Right. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 56 0. What docs back blading mean'* A. Well, you have a blade in back of a tractor and you scrape the gravel, and it fills in the ruts and the road, it smooths it off, you know If you don't do that on a yearly basts or three or four times a year, the road would become unusable. MR. GREENE. Thank you. That is all I have got DIRECT EXAMINATION BY MR. MCCARTHY: Q. On this Exhibit 153, you marked in the back hash marks to show where. I take it, in the I980's you didn't do the same type of annual mainteruuioe that you did on other portions of the internal roads; is that right? A. Right. Q. Now, the area that you have marked, tras that a gravel rvi.al? A Yes. Q. During the 20 years that you were there would you from time to time put fresh aggregate or gravel on there? A. Yes, we did. Q. And the back blading is something that you did annually?r;c 53 " age 56 Kirby A. Kennedy & Ataocintes (612) 922-I9SS I George Jeimrich Condenselt Depo-Squish Page 57 Page 59 1 A. Uh-huh.1 A. No. 2 Q. Would you in the winter plow down to the 2 Q. You ulked about the keys that were available 3 Woodhill property line? Not you, would you have it done.3 during the 1970's to open the chain on the Woodhill dnveway 4 you or your stafP?4 that tied into Woodhill Avenue. I would like to ask you a 5 A. Yes.5 rouple of questions about that 6 Q. Showing you Exhibit 155, the 1992 topographic 6 Did the bartender have a key? 7 map, you previously testified about other gravel and a^halt 7 A. Yes. 8 areas of the road; is that nght? OF the internal road 8 Q. Why was that because the banender would close 9 system of Woodhill?9 up the club? 10 A. What was the question again?10 A. Yes. II Q. There were other gravel internal roads?11 Q. There were two bouses out in the western 12 A. Yes.12 portion of the club propeny, tighr? The old subie 13 Q. You indicated that those were in the circular 13 manager's bouse? area around the paddock, and then, from there up to the 14 A. Yes. IS maintenance building?IS Q. And there was an old farmhouse as well in the 16 A. Yes.16 vicinity of the mnioienance building? 17 Q. The other portion of the internal roads that 17 A. Yes. 18 went around the tennis courts and the clubhouse and out to -18 Q. Old maintenance building. 19 County Road 15 were paved with asphalt?19 Were cither of those bouses ever occupied :o A. Yes 20 during dc 1970’$ or I980's? 21 Q. Did you have cxxaston from time to tune to 21 A. Yes, they were occupied during the whole time. 22 resurface the asphalt?22 Q. Old the people who bved in those bouses have 23 A Yes.23 keys IO that back gaie? 24 (j. Did the city ever suggest to you that the club 24 A. Yes, they also worked for me. 25 needed u permit?25 Q. You said the lenms pro had keys? Page 58 Page 60 1 A. No 1 A. Uh-huh. Q. Every year you brought ir, loads of gravel lo 2 Q. Did any of the waitresses have keys? 3 spiead on ^he iniemal roads: is that nght?3 A. 1 don't know. ns A. Yes 4 Q. Did the club manager have a key? 5 Q. Did the cicy ever -5 A. I am sure he did. Yes. 6 MR. GR££NE objecuon on the grounds of 6 MR. GREENE^ SO I understand, during 7 Ijck of foundation based upon his lesttmony pirviously about 7 the period of time of the seventies we are talking about? 8 bis lack of contact with the city and pemuis.8 MR. MCCARTHY: Right During the 9 BY MR. MCCARTHY 9 seventies. iO Q Did you ever hear from anyone that the city 10 1 THE WITNESS: Uh-huh. II look the position th»' the club needed o pennit lo haul in II BY MR. MCCARTHY 12 the loads of gravel ii did every year?12 Q. So, the people that lived in the bouse, the 13 A. Could you rephrase that again ’11 grounds crew, tennis pro, bartender, club manager and you 14 Q Suxe. Did you ever bear iron anyone, whether 14 were all people that had keys? 15 from the city dmxUy. from the grounds chairman, from the 15 A. Yes. 16 manager or anyone else that the City of Orono thought that 16 Q. So. any one of you could, in fact, open it up 17 Woodhill needed j permit for the loads of gravel ii brought 17 and drive through? 18 in to spread on its roods every year ’18 A. Yes 19 A. No.19 Q. So, if someone left it open, it would be open 2U Q. Did you bnng in vuckloads of earth to spread 20 for anyone to go down the road? 21 on the golf course every year?21 A. Yes. 22 A. Yes.22 Q. Did that happen from time to time? 23 Q. Did anyone ever leil you that the Cicy of Orono 23 A. Yes. 24 thought that any type of pennit was necessary to bring in 24 Q. It is also possible that if someone happened 25 the truckloads of din every year?25 to lock the gaie. then unless you had a key, you would Kirby A. Kennedy & Associates (612) 922-1955 %e 57 - iige 60 ft>q>o-Squish Condenselt Page 6] 1 encounter a chain across the road, a chain or a gate? 2 A. Yes. 3 Q. Do you recall from the time you started until 4 say 1978, wheLher what was across the driveway was a chain 5 or a meul gate? 6 A. I think it was a chain. 7 Q. Then you testified about a metal gate that 8 preceded the chain you installed in 1980. So, at sometime 9 that chain was changed to a metal gate? 0 A. Right. 1 MR. GREENE; I think you said that 2 backwards. 3 Q. Let me clarify it. First was a chain, then a 4 gate? 5 A. Then a gate. 6 . Q. And then a chain was put around the gate? 7 A. Uh'huh. 8 Q. Then the structure was put in in 1980 with the 9 ' concrete posts and the chain? 0 A. Uh'huh. 1 Q. After you put in the posts with the metal 2 chain, and you were there for a decade afterwards, was that 3 chain lowered and vehicles driven down every year? 4 A. After the eighties? 5 Q. In 1980 you put up the concrete post and the George Jennrich Page 63 1 2 m 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 were still employed at Woodbill? A. Yes. Q. When you drove through there in the 1980‘s. did you receive any complaints from any neighbors? A. No. Q. Did you receive any complaints from the City of Orono? A. No. RECROSS-EXAMINATION BY MR GREENE Q. I am showing you a blowup Mr. McCarthy has had made of a potlion of the Woodhill Avenue, Orono Orchard Road inienection, and the club is there as well. Do you recognize this blowup? MR. MCCARTHY FOT the lecord. I will say this is an aerial photograph from 1951. It is deposition Exhibit Number 7 and this is a blown up version of a portion of Exhibit 7. I think when you say "club." I think you misspoke. Cliff. It doesn't show the clubhouse. You arc ulking about some portion of Woodhill Country Club. MR. GREENE: of Woodhill Country Club, that's correct. BY MR. CREENE; Q. Do you recognize the area depicted in this 8 Page 62 chain? A. Right. Q You istified that tractors would be taken through there ’ A Yes. Q. Was anything else, other than tractors? Did you ever drive a truck or vehicle through there? A Yes Q. You. personally? A. Yes. Q. Did anyone else besides you drive vefaicks through there? A. I am sure my grounds staff did. Q. The train incidents that you described, did any of them occur after the concrete post was put in. so you would have hod to lower the chain for the people to drive through? A. You know. I can't recall. Q. Is it possible tha' it was during that tune? A. Yes. Q. If itcords would show the derailment occurred sometime after 1980? A. Y’es. Q. Were vehicles driven through that gate down onto Woodhill Avenue every year during the 1980's while you Page 64 1 photograph? 2 MR. MCCARTHY: For example, do you 3 recogntze Orono Orchard Road? 4 Q. I will represent to you that on the left-hand 5 side of this photograph that ts Orono Orchard Road. Do you 6 see Woodhill Avenue now? 7 A. Yes. 8 0 Can you orient yourself to where the country 9 club is located? 10 A. Yeah. Yeah, there is an old skeet range, okay. 11 Q. You see the old skeet range? 12 A. Uh-huh. 13 Q. In sort of the upper right portion of the 14 photograph? 15 A. Yes. 16 Q. Just so that I understand, since you arrived in 17 1971, were there any changes of significance in your mind to 18 Woodhill Avenue between 1951 and 1971, or is that a pretty 9 good approximation of what Woodhill Avenue looked like in 20 1971? 21 A. What dates did you say? Did you say '51? 22 Q. Yes, this was taken in 1951. I want to know 23 whether this photograph of Woodhill Avenue illustrates what 24 Woodhill Avenue looked like in 1971 as well, or were there changes? I e 61 • age 64 Kirby A. Kennedy & Associates (612) 922-19SS Richard FiedericI I ) Condenaelt^ raf« 1 1 2 3 4 5 « 7 f 10 11 12 13 14 15 li 17 II If 20 21 22 23 24 25 STATt Of MtMWUOTA COUNTY or NAIflftflH oinmirr oovrt POimTII JUDICIAL OtSTmCT MooAMil Country Cluo, • Nlnnoaota non-profit corporation, Plfintm^ va.rila HO. NC ff-10541 City of Orono, Cabrial Jabbour, In Mi official capacity ai Mayor of Orono, and Aonald Moon#. In Mi official capacity as Orono City AOMinlatrator, oafanaanta. Tha oapofition of aicmaao nuLOtaiCRSAH. taian pursuant to Hotlca of Taalnq Oapotition. latan bacora Ann Maria Holland, a Notary Public in and for tna County of Maaninqton. Siata of Minnaiota. tafean an tha 27th day of January. Ifff, at 1700 Metropolitan Caatra. 333 South Savanth Itraat. Minnaapotta. Mtnnaaota. canMnclnq at approalMa'.aly 1:45 i.« 1 2 3 4 5 6 7 8 9 10 II 13 13 14 15 '6 II 19 20 21 22 23 24 25 AP2£AAANCES: P^2 IA50S f MCCARTHY. ESQI/tRR. of the Law Firm of UNOOUIST A VRMWUM. f LLf . 42U0 m Ccmcr. 80 South Eighth Sifoct, Mifwapolii. Mmnaou 55402. appeared for and on behalf of the Plaaniiff CUFFORD CR££NE. ESQUIRE, of the Uw Firm of GRERNB ESfEU P LLR, 1700 Meoopoiitm Ccnuc. 333 SoadiSryaMhSM, Minnelli. Mirvnou 55402. appeared for and on behalf of the Oefmdanu *Tha Ongmil u m Uw potmmnn of Attonpy QJTord Graene.* AkopTHenL ShmCFn«tl.Pvai«Al ... UOtAU) nttOUUCXStN: Ir-OraM.....................Pm) bpMr.McCattiy........................?«. IM kpMr.GiM.................. bhiM70Mi,M,Mip.........................P^« eUiilM72M.M.GM>UI^U«4vlic2n. Pm27 EidMbil7)-77H.M.OocMMM .........1^27 eiiiyb«l7t-MM«lMt.OooMMM...............PmJ5 RiWhil 7t MafcU. WMitw ii.....................Pm)S F.khi 17 Malat. Diiiltin Pr.M ipptirwiiii.. Pm4) bdiibitMM«M.Mi.> .7.........Pv)7 eUiArt at Mart.4. .........................Pm tO EiiMMMMaM.Mi^ .......................Pm 101 Kirby A. Kennedy and Associates (612) 922-19SS Dqio-Squish Page 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UCHAllD FSEDemeXSeN. de Witms in the ibove^titled natter after having been fint duly sworn depoaes and taya as follows; CROSS-EXAMINATION BY MR. GREENE: MR. GREENE: Let's pietnark this as Exhibit 70. (At diis time FREDBRlCKSEN Deposition Exhibit Number 70 was marked for identification by the GMiit Rqiorter.) BY MR. GREENE: Q. Would you please state your full name and residential addresi? A. Richard OonJon Frederickaen. 2093 Nielson Avenue, Long Lake, Minnesota. Q. Where do you work and what is your job title? A. 1 work at Woodhill Country Club and I am the golf come superintendent Q. Before we get into the details of your position at Woodhill and the substance of the deposition, fust of alL let me thank you for coining here on an icy morning. We will do our best to make this experience no longer than it needs to be. I appreciate your ooopention. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 Page 4 1 would imagine you have had a chance to talk to Mr. McCarthy about the protocol for a deposition; is that correct? A. 1 have. Q. Have you had a deposition taken of you before? A. No, I haven't. Q. Well, let me probably repeat just a little bit of what Mr. McCarthy said to you. It is very important to me that you are comfortable during this deposition. If at any time during the deposition you feel the need for a break, just ask me and we will take such a break. Similarly, it is very important for me to know that vou have understood my quettion. If at any time any of my questions seem unintelligible, and there have been those times in my experience, I need you to say to me, "Mr. Greene, would you please rephrase the question?" Would you do that for me? A IwUl. Q. If at any time you are aware of a document that exists that might provide the answer to a question or might refresh your recollection, would you so advise, and we will attempt to locate that document for you. b that agreeable to you, also? A. Yes. Q. Good. Page 1 - Page A Richafd Fredericl CoBdenif.itPage 65BY MR. GREENE;Q. Then just write ■Wood."Are you indicating where the property is or where the house is?A. 1 are indicating where the property is.(Marking.)Q. Why don't you put under "Wood." the word "property"? A. (Marking.) Q. Now, let's return a moment to the maintenance shed. Are there machines in operation at the maintenance shed from time to time? A. Yes. Q. What kind of machinery is housed in the maintenance shed? A. All of our mowers and most of our tractors. Q. Are the mowers and tractors serviced at the maintenance shed? A. Yes, they are. Q. So. the mowtrs and the tractors are brought to the maintenance shed over the roadways within the club's property? A. That's correct. Q. Can you describe in any greater detail the type 2S of servicing you do to this equipment at the maintenance Page 67in any discussiom at the club or elsewhere during which the subject of opening access from Woodhill Avenue to the club was discussed?MR. MCCARTHY: YOU mean not for tractors going back and forth, l.ut on a regular basis for cars and trucks? Is that what you mean?MR. GREENE: Right. BY MR. GREENE: Q. Other than the two occasions in '90 and '97 when you took the chains down so tractors could get serviced, were there any other occasions where you had HisruMBd removing the bamers anu making access from Woodhill Avenue permissible? A. I had limited discussion with Mark Albrecht previously to that, but it was more in passing. Be it lunchtime, we would have discussions discussing the condition of the golf course, and I ioiow the issue had come up, but nothing in the ofTicial capacity. Q. From your standpoint, as the greens superintendent of the golf course, was it your preference to sec that barrier stay in place to prevent vandalism to the golf course? A. I didn't have a preference one way or the other. Q. From 1989 until May 5. 1998, did the club Page 66 shed? A. They are gassed up, refueled, oil changes, movrers are adjusted. Any type of maintenance work, repairs (lone on them arc done there. MR. MCCARTHY: I have given you wide range of discovery in this case, but how lawn mowers are serviced in the maintenance shed do not appear relevant to the issues in the lawsuit. BY MR. GREENE Q. Do you service golf carts there, aiso? A. No, we don't Q. What other types of services are performed at the maintenance shed in addition to servicing the vehicles that you described? A. We do our staff training there, orienution. It is where our lunches are. All of our personnel services are done there. Q. Do you know what was at the maintenance shed previously? A. In the new oik ? Q. Yes, the new maintenance shed, what was there before it was built? A. It is my understanding that there was a house in the area. Beyond that, I don't. Q. Prior to May 4, 1998. had you ever participated Kii'by A. Kennedy and Associates (612) 922-1955 Page 68 perform any maintenance in the vicinity of the gravel roadway to the west of the chain barrier all of the way to the pavement of Woodhill Avenue? A. We performed some tree trimming along the edges, along the road coming up from the asphalt pcnodically, so you could entet and access that on bike; otherwise, no. Q. So. let me sec if 1 understand Other than tree trimming to facilitate bike access, the club did no maintenance on the gravel roadway in the area that you have shaded in in pink on deposition Exhibit 88? A. That is correct. Q. During this period of time, did vegetation, underbrush, saplings, trees, whatever, grow within U k area that had formerly been a gravel roadway? MR. MCCARTHY: I object 8s Compound. You have about 12 questions there. MR. GREENE: I will let him describe it. 1 am trying to give him the universe of what I am looking for here. A. Your question is? BY .MR GREENE: Q. Can you describe what had grown up in the vicinity of this pink shaded area on Exhibit 88, what type of vegetation during the period from 1989 to May of 1998, Page 65 - Page 6 -Squish Coadt^t” _________ Riclafd >rt»w«prton«)7 21 about? Q. Other than the maintenance you testified to? A. Coma. Along the edges there were some Boxelder saplings that were growing up, other than that, it was general crabgrass growing in the path of the roadway. Q. Was the roadway in the condition where cars and trucks could use it to access the club from WoodhUl Avenue without the need for roadway improvements, which might include clearing off of vegetation and brush, grading and resurfacing? A. It is my belief you could get up and down that, if you wanted to. Q. What do you mean by that, "if you wanted to"? A. If you wanted to take a vehicle up that road or come down that road, you could have, if you removed the chain. Q. Would there have been any problems or complications associated with doing so? A. We didn't have any problems when wc took our tractor down there. Q. Suppose you are driving something other than a tractor, are you encountering vegetauon and underbrush? Page 70 We have referred to that from time to tunc. Was that there? A. You wouldn't be driving over brush. The center pan of the roadway was clean still. We ined to maintain that. But, the sides had the Boxelder saplings growing up along the edges. Q. How thick were the circumferences of the Boxelder saplings? A. One to throe inches. Q. When you say, "the edges," were these growing on the roadside, in other words, the area of the road that would not be uaveied, or were they on the edges of the traveled road area? A. It would be on the edges of the traveled road, so the center pan, you could still get a tractor or a vehicle up and down the center. Q. Can you provide me with a more detailed picture of what the area you have shaded in pink looked like on May 4, 1998, the day before improvements were do.ie? A. There were Boxelder «apiing« growing along the edge of the road and there were branches hanging from the mature trees forming up a canopy, not a canopy across the road, but a canopy to the edge of the road, to best describe 1 •It 24 Q. Would these trees obstnict the vision of traffic or otherwise need to be pared back in order to 69-Page 72 " I —W /w ISaEKII be desirable or would absolutely have to be done to be navipied? Ma.OReeNE: oesirabie. SYMILCReeNE: Q. 1 am trying to get a sense of bow me bows related to the need to improve the roadway. A. It would be desirable. Q. Why is that? A. If you ame going to pass two cars on the roadwiy, you would hnve the ears pushii« up ogninstd* branches, if we didn't trim !>■*— back. Q. So kt OK see if I understand sort of the gist of your testanony regarding mainienaaoe of U b ana wUcb you have shaded in pink on Exhibit 88. - From Oecamber of 1989 to May 4 of 1998, the only mainioiance performed by the club in the vicmiiy of the area shaded in pmk involved sook tnnuning or removal of trees to faciliUK bicycle access lo the club? A. And any of our vehicles, our tractors. Q. Did you have to do nuuiienance to this arm of the gravel road in conjunction with your desire to move the tractor to the repair dmien in 1990 or 19977 Page 72 A. I can't answer that I don't know Our goal was to keep the arm open so you could access it with a tractor and access it with a bKycle. Q. Had you read any depostuon iienscnpu in this case? A. 1 looked at Mr. AJbiecbi's. Q. Did you rrad Mr. Albiechi's deposition? A. I did. Q. Is iboe any aspect of Mr. Albiecld's account of events on May 4tb with which you disagree? A. No Q. Let me understand then in your own words, how It was that you learned that the club wanMd to make mad improvonenu that would enable pa ssag e to occur beivreen the paved potuon of Woodhill Avenue and the country club. A. 1 leceived a call from Mr. Albrecht asking that we mem at L-OO on Monday with Mr. Dayton to V mA at the road, and that's how I learned of it. Q. What happohxl nea? A. Wemesat 1:00 on Monday. U k 4th. 1 believe it is. We walked the road. They asked me if I could do this job. and 1 told than that the time constraint was my staff, being that thoe was the opening pan of our golf *eason. wc didn t have the staff to do it, but we would have so mebo dy come in and help us. A. Kennedy and Associates (612) 922- % ) ) I I i I f f I I I I I I I I I I I I I Awhard Fredericksea Condenielt 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 5 6 7 8 9 10 11 i: 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 105 A. Y«. Q. Wts thoe in Evogrsai tomewbae adjacent to the maintenance facility? A. That's comcL There are two. Q. How tall are these trees? A. They would be, approximately. 10 to 12 feet Q. We have been talking about the existence of 8 pavonent on Woodhill Avenue, and you told me that the 9 that is paved with bituminous on Woodhill Avenue has not been changed during the period that you have been at Woodhill Country Club, correct? A. That is my best recollection. Q. lo the course of discussing maoen with Mr. Efigman or anyone else, have they told you that the paved portion of Woodhill Avenue has changed over the years or not? MJC MCCARTHY: I object to the extent that your answer would be based upon any conversations with counsel. To those, 1 would object on the grounds of anorney/client privilege. To the extent you have knowledge apart from conversations with counsel, feel free to answer. MR. GREENE txt's do it this Way, because 1 am not sure how significant the response is. A wiuiess who receives facts from whatever source, including his attorney, can convey those facts as a fact witness. This is Dcpo-Squisb 1 not legal advioe. 2 BY MR. GREENE: Page 106 Q. However, without waiving that objection, have you had discussions with Mr. Engman or anyone else that would lead you to believe that the pavement, the paved area of Woodhill Avenue has changed from time to time or at any period pnor to your arrival at Woodhill Country Club? A. Our discussions never cenicred around that. Q. So. all you know about this is information that you may have heard from counsel: is that correct? A. Pertaining lo? Q. The location of pavement on W'oodhill Avenue? A. I don't follow your question. Mr. Greene. Q. Let me direct the question to Mr. McCarthy. MR. GREENE: It IS my understanding that this witness does not have testimony on that point to give? MR. MoCARTIfY: That's correct. MR. GREENE: YOU may cither ask questions or instruct the witness. MR. MccARTinr: I just havc a couple of questions lo follow up on. CROS.S- EXA M IN ATION BY MR. MCCARTHY: Q. The tree that you discussed, the Evergreens A. Kennedy and Associates (612) 922-1955 Page 107 bong planted concerning the light that you discussed? A. Correct. Q. Was the person who asked you to do that Mr. Michael Wood? A. Yes, it was. Q. At the time that he asked you to do that, did he have any position with Woodhill? A. He was president of the club. Q. So, you were responding to a direction from the president of the club when you planted that tree? A. That's correct. Q- You discussed having tractors driven out to I'OnS Lake down the gravel road onto Woodhill Avenue, you mentioned two instanoes. How did you nguie out that, that there were these two instanoes with the tractors? A. These were the two instanoes that I could find invoices for the work that had been done. Q. What is your best recollection as to whether tractors were driven mote than those two times? A. They had probably been driven more often. Every couple of years, every few years. Q. So, when you say the tractors were driven 24 tvnoe, those refer to just the ones that you happened to 25 keep invoices? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 108 A. That I could find invoices on. Q. Is it your best recollection the fact that tractors drove down that road more frequently? MR. GREENE: Objection on the grounds of foundation. Asking him whether he saw that, as opposed to speculating, would be helpful to me. BY MR MCCARTHY: Q. What is your best recollection about Woodhill's tractors using that road? MR. GREENE: Same objection; lack of foundation. Q. Same question. A. Every two to three years. Q. What do you base that on? A. We have several tractors, maintenance work that needs to be done on them that can't be done in-house. Q. Did you ever encounter any difficulties with gening the tractors out the gravel road to Woodhill Avenue? A. No Q. Did you ever receive any complaints from any neighbors? A. No Q. Did you ever receive any complaints from neighbors about the maintenance of the road that you testified? V \ Page 105 • Page lOJ ' A. No, I baven-t ^agc 109 j =£:==:S “ — l« orboU,? “ or men*« THE WITNESS. Both. " r;“^~ s,“:ntr' I ss;f^~~=S; I O..J,,"Xoldr ,b«.., half of ’ 8olfcLt''^'™“'''™**-“^'™'"‘0Wo»» MR. GREENE. Objection; leading ■«« on our ffolf r ^ ^ 'w: n „ * u'**«y vehicles if or'.„uT!^r op 0. *„,„, „, A. Never. ■ A. We do ■nion, Iheveoofunhe, l»ot eovuZ ■“ '•*“»»■ too* «racm,m«:u«overUKWo«|biliAvnuera«e. iopp^rm Page no Um on two ”™‘“rLr^““u.n,dww««d,.Aj:::::.’n:j:r A. That*s correct. Q. And beyond reading those two invoi«.« ^y.ow««w.dw.tsdwron.a„.n::^- A. Yes, I am. n di^n'Lf^ *8 b«ck«ratoWoodhiU^JJ«‘^‘‘‘*‘^'^°'^‘*“‘ «9 the dealer? ^ng serviced by ^21 ***”8 serviced or leased. Welo^ 24 WbUyouh.«^^CnilJ^Uno^ri!Z''^''**‘“'^ I ; ;^,>'~™«o"«>oUI«Woodbi,,A«nneJl''- ' «n»on then. m«eir UosoutwrtK,^., occasion to uUlia: A How many n.ctom do wn ha« i„ our n=«4 scoss. ’*>'*oold use that —‘a'li-sor""-'*'™2X-=:.r:srr:~“route to the dealer? woodhill Avenue A. It is possible. us with an inlcaU^f Ihl 18 vehicles nughthawtlJ^ *^*^*^'^ WoodhillAve^I 20 A. I did. Q. And you didn’t find any? A. I did find them. I found two 24 A 1^ ^ «y others'^ ^om»y A. KcMccy ua Aa»ciue> (612) 922-1955 % 9 I Richa rt FicacncMcn ______________—^ Q this gravel road ftom the dub 10 WoodhiU Avenue for ihe purpose of taking traciois out to WoodhiU Avenue to get serviced, every two or three ye«s, were there any other circurnstances when that rowtway was used from the tune that you got to the club in December of 1989 to May 5.1998. by cars or trucks? A. No. that 1 am aware of. MR. OREENE: I have no further questions. MR. MCCARTHY: YOU have the right to review and read your deposition or you can waive that. I suggest that you esercise your right to review it. THE WITNESS: 1 would like to read it. (Whereupon, at 12:15 p.m., January 27, 1999, the taking of the deposition of RICHARD FREOERICKSEN was concluded) rdfc liJ Till 11 - —■ -— “***1^!;““ “ TVtf WIM* hdiw* ^icUMlo It t ime rwori of tottkcMof ny WTTH1S5 MY MAHO AND SEAL tfui 3llt day of J.¥«itr>. A miM. Hollini CoMtiUpontr 25 fUPON COMfLETIOH. forwtrd ttMt onciMi R mEiih ijM CfftiTicjM lo Attorwy QJford Ijraent. alftady lut iht Page 114 Sntf4 Onfuul.) tIOWU) PPfDlMCIlO* I.wchaadpwbmuoiio - 4ohmby cmifyEoi I have fud the fof«to«os ramcnpi of my Orpotuion ind believe the ume to be tnd wneci Cor. eacepi * follow.. noiu« Ihe fugc Ihf h* iwmbtr of Che clun»r or od4moo4i*ifPdendiheitM»» whyi faff Line Oueife of Addic»ort Rcteon liot_____4oy«^ 1 Kirby A. Kennedy and Asiociatca (612) 922-1955 Page 113 - Page 115 I I I I I m •• 4.: •i-f •V- i A.* • WOODHILL COUNTRY CLUB :00 WOODHILL ROAD WAYZATA. MINNESOTA 55391 473-7333 • rso Cr. GROr^Q June 23, 1980 r I I I I t I I L I! ■ O Honorable Crad Van Nest Mayor of the City of Orono Post Office Box 66 Crystal Bay, Minnesota 55323 Dear Brad: At its ir.ost recent nteeting, the Board of Trustees of l.'oodhill* decided to keep the "back entrance" to the Uoodhill Club property closed at all tirnes except in emergencies. This action was taken for t'.;o reasons — first, as a matter of security to the Club property itself, and second, because of the strong desires of the City of Orono to limit public traffic on Uoodhill Road through l.’codhill property by members of the general public. It is con- tc.T.plated that a secure gate arrangement will be constructed on the back entrance which will prevent cars__and trucks from using the entrance, but will allow bicycle traffic. As you knev;, by taking this action v;e do not in any way v;ant to limit our right to use the back entrance should future circumstances warrant a change in this decision. Sincerely, JoT.ii U. Morrison President cc: Mr. l.'altor Garry, Jr. tir. Charles S. Cellovjs Mr. Tlicmas M. Crosby, Jr. Mr. /‘jithony Kallas I exhibit I I I 6. Affidavit of John S. Pillsbury, dated November 12,1998 I**" n Gl ; I I I 3 ;4 ip>»wpi roT; 1.1 I '• ■~1 « t * —I f n r ir lJ D STA'ri£ OF MINNESOTA ) ) ss. COUNTY OF HENNEPIN ) AFFIDAVIT OF JOHN S. PILLSBURY, JR. I. John S. Pillsbury. Jr., being Inst duly sworn, depose and slate as follows; 1 . I have lived in Orono, Hennepin County, Minnesota nearly all of my life. 1 graduated from the University of Minnesota Law School in H)41. I am now retired. 2. In 1946 I purchased the Albert and Esther Crosby house and land. I reeeivetl the deeds attached hereto as Exhibit A. Attached hereto as l:\hibit B is a diagram showing the location of the land 1 purchased. I lived in the main house until I sold it in I9S6 to John Prudden. Following the sale to Prudden. a second portion of my land was sold to John McDowell and subdivided into lots called “Woodhiil Ridge.” The third portion of my land, along VVoodhill Road on the south and east, was .sold to ^\’oodhill Country Club. 1 was aware of the fact that the northernmost portion of the land 1 purchased Irom Albert Crosby was bordered on the north side by Woodhill Avenue and on the cast side by land owned by the Woodhill Country Club. When I bought the land, horses were regularly kept at Woodhill Country Club in two large barns and various paddocks and pastures northerly and westerly of the barns, and northerly of my house. 1 know that the barn manager’s house was on the top of the hill behind the present maintenance building and that there was another residential dwelling for club employees further south near the I07i:(i5vl I I I r E E E E E f I I 1 I I I I bams and the pond. There was always a back road out of the club from the area of the pond and the bams pro:eeding westerly to Woodhill Avenue. 4. When I purchased the property in 1946.1 knew that Woodhill Avenue was a publie street. While I did not survey the land 1 purchased from Albert and Esther Crosby, I could see that my northerly boundary line on the western poilion of my property was Woodhill Avenue as it e.xistcd. Exhibit C is an aerial photograph showing Woodhill Avenue and my property about 1951. It accurately depicts the location of Woodhill A\ enuc as it was maintained and traveled during the period I owned my property from 1946 to 1986. From the fence lines on the north side of Woodhill Avenue for the Woodhill Country Club horse pasture, and the path cut through the trees southerly of Woodhill Avenue for Northern States Power Co. power lines to my house. I always knew w here the westerly boundary of the Woodhill Country Club property lay in the vicinity of \\ oodhill Avenue and my property. D.I know that Northern States Power Co. ran its power lines along Woodhill Avenue and thence easterly to Woodhill Country Club. A branch of the Northern States Power Co. power line ran southerly to my house along the property line dividing my property from Woodhill’s property south of Woodhill .Avenue. 6. During the 40 years I owned the property, 1 knew there was an established public street known as Woodhill Avenue that connected Orono Orchard Road and Woodhill Country Club. Throughout my entire period of ownership it was my position IXk-3 |07I2(>5M WfeiliritltittilliiiiTir f ■J.«»■■ UU^ -y^'' tvz -r^ . I I I u n ‘ 'i S'- : 1 u ^ ; i f : ! t' i i , i LJ n L that the public had the right to use Woodhill Avenue from Orono Orchard Road easterly to the Woculhill Countr>' Club property line and that the entire length of Woodhill Avenue up to the Woodhill Country Club property line was a public street. At no time did 1 ever object to or try to restrict use of Woodhill Avenue by the public. 7. When I purchased my house in 1946, there were only three driveways that used Woodhill Avenue: the two homes at the corner of Orono Orchar;? Road and Woodhill Country Club, in the late 1950's or early I960's, a house was built on the north side of Woodhill Avenue fuilhcr cast. On August 14, 1979,1 sent the attached letter (Exhibit D) to the Village of Orono. Orono responded to me by acknowledging that Woodhill Avenue was a public street, that it had been and was maintained by Orono. and that the vehicles were illegally blocking a public street. A copy of the August 17. 1979 letter I received from the City of Orono is attached as E.xhibit E. The same day the Orono police chief wrote to Mr. Wagencr and advised him to remove his trucks so that Woodhill Avenue could be used as a public street by the public. A copy of the letter is attached as Exhibit F. S. I understand the current position ol the City of Orono is that the portion ol Woodhill Avenue cast of Mr. Wagoner’s driveway up to the Woodhill Country Club property line is simply a “private casement” over my property. The City’s position is incorrect. At all times during my ownership, 1 did not consider that portion of Woodhill Avenue to be a private casement on my property in favor of Woodhill Country Club. As I Doc» I07I26.SM •i I I I u i u rr ♦ Li f I • 4u m.’ ! . » ;/'wJ L n ti 1 i r'.; • f * ri I 1 1 ti described in my August I4, 1979 letter to Orono (Exhibit D^l. I believed and intended that Woodhill Avenue was a publie street up to the Woodhill Country Club property line. Woodhill Avenue was, in fact, open to and used by the public. 9. During the period 1 owned my property, Woodhill Avenue was traveled by club members, club employees, service vehicles and guests of members. Several employees and 1 assume their families lived in the two residences located near the current maintenance building, bam and pond. Woodhill maintained an active hockey and skating program on its pond throughout the winter. It also hosted an annual horse show throughout the 1930*s, 1940's and 1950's. Woodhill Avenue was open to and was used by the public that frequented those activities. FURTHER. AFFIANT SAYETH NOT. John S. Pillsbury, Jr. Subscribed and sworn to before me this /^- day of November. 1998. / Notary Public ^ ^ ^ ROOERTaiiTCHEli.JR.miiMnmuc-ummmk HENNEPIN COUNTY 4 Doc<^ I071265\! K' - I ; - ‘ ;V ,4 r. ‘, V‘.it . ^ ■■ _ :-■ ■ •; -?^:^ - * >' - ■ -vr/^r. •« i-^I U-'/: f . ■'■<: I 'i" I I I -7;:< • t I I I ^v' '.r^' t I I ^ V •■>. . t 4 |] t s m G r D D p B ■I M ••■.i •B Ms. M«.|. ■ ■■■ --------- r#9fti iVv. loak.!8|3-Pase :.»:»«< smmouh i5Mliib^«re. .#.i» ■/... vtaualtte—« ^ ^____________ « M« |M pgrf, nii4 ^ .HfpiMpin 4»md $tsi§ ^ ClOlltMtil. ffl M ft ft ---------- - m_.Jotaa^..PlUabnry« *t l*« CMtafy i/.. _JlMll)*ptii M>« t »md~MM0 «/-------VtlHIMOt*! iMm IM mm 0f0«ft •001 ..ftfici elhtr.cood. tna.„.vftiiiAbXft .eMiioftratifta._______ M nftr -------.<• ?-r. * •*' m. •—---------- «» MM liftrt J-----P/ mm4 mH. 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Cati ly #/,Jitnusifi.h Bdok-1613-Paee 0» tMi_____ •--------------Iota XU tUR zj:» ___fggWtf ■ XU4UI ________JL*_6texbiu_xiattt IMIMI4 • • •Vr mmmUrimm !%»«»<••• f^!*RnKSrtwni» iTcwsUwa xawf»/? • . n. . *r ■■: ' ~ . V*--- r..--\. i. I m I I I f r G c r 543 *rr. ••.9*4 «M9«F«rffn N«. 3«M*«». f<n. Mim. tCIjitf Snbenture. a<*Afl _ Suv Acr..V.._C rjp3ry,.-aMo-j. •lonnut«tn•/ C4«II#V «/ f?A»i y------^ 1/4^ ;|r#| par#, •ii«l .*?!«* • »»f LHiinocotu j lllahiify ^ Jr. •/ lju CiMiify #/___Ucitfionin. pmH..U.-.^9/ uMmd fiirf. .^imil SimU 0f I’lniV;#aoto •• •# ■ * • GNhiCifCt), fl^l t9u #«I»I licriy^^ . •/ lAt fni iMrf, J« pf III# i*in« {^,1^00) mid fttiigg gncA aaa^VttluAblc.,eoa^idaraLloa— aUkm; t% l^ntl wmid hv #*• ••id ^ •/ fl»« •••••il #•••♦, iht Pn^fi/4 irA#w*/ I# d# . V9 ik#r«#v Omfif. Mf. CMr^ar M«r# tht ?mi^ f«iH.Jf._________ pf ikp 99t*p4 fnirl.___lliU__heir§ And •••##•«. mU iMp «r pMVfl ^ #/ fMd l^a# •ltd $ptmf im ihp c«uiUr #A-__ilo:i:*ox:lu Lmpp, iP tHi: ,mmd Stmtp pf Afimppppim, dwHicil «• tot 11 onct Lot 12• AuditorSubdivision Mo* S07p Uonnopln County rinnosoto* eneoptific that part or Lot 11 doserlbod aa follcava: Def.ln* at t*.*.s Southoaat corner cf Lot 0 in a aid Audi tor *s Lubdlviaion i*o« 307: th«* lac East SLlenr. tho oxtonalen of tho ^uth lino of said Lot IS a Ola^snee of 4G*6 foot: thonco llortn nornllol with the North and South cantor lino of Soetlon Z • Tovnahlp 117, noi^eo 23 a dlatanee or 352*01 foot to a point in tlio oxtonolon of tho Uorthorly lino of oald Lot I); thane a bciuthwoaterly alen^ amid oxtondod Ncrthoriy lino a dlotaneo of <0M foot to tho ^orthoaot eornor of oald Lot 6; thonoo South aionc tho East line of said Lot d a diataneo of 310 foot to tho point cf bocinnln^. Also, cxsnptinr. that part jf Lot 12, dodcribod aa folloaa: ilodin* nlnri nt V\e rolnt of ir.torsootion cf tho Korthorly lino of Lot 0 in sale; Aiiditor‘*a Subdivialon !lo* 307 with tho North and South eontor line of Section Yornahip 117, llan;:o 23; thonco Soutitaooterly olonn tho rorf'orly lino of aold Lot S to tho an«lv oolr.t In tho ?lorthor|y Una er atid lot* said pdiiit boln{* 25.5 foot oaat ef the seat Woaterly eornor of sold Lot Os thonoo Northoootorly 32.2 foot to o point 29i.74 foot :*cuth%Toator!y frors tho point of bossinnlnns thonee Northoootorly S04.74 Tett to tho point of beninnine.; et a .in-.; c.rncptlnj that nnrt of !.ot If doserlbod oa folloess *>ocir«ilnc nrint !n tho dividing I'.no butwcon Lots 3 and 12 in said Auditor*u Sub««lv*jlcn ;-09 307, which no-nt is 41,1 foot i?orthorly fron the -ortli- eeott.rly corner of :.os < In ctau «^iibdlvlalon; thonco ^ortliorly alonr. Shu -ilvluinc line liotwaon nforaaoid i.ota 3 and 12 a dlotaneo of 7U**J feet to en ancio iiolnt in oald dividing, lina; thanea at o rlRht anj^le ;trly alonr the dividing lino botwoon aoid Lota 3 «ul 12* a diotnn?<7.ast'of L7 foot to another anp.lo point in said dividing lino; thonoo sr.iith- *.7cactrj7 in a otralgtit lino 37,3 feet more or leoa* to tho point ofir.-, eceordin^ to tho olat thereof on Mle and of rooorU in the o*r tho Ronletrsr of Tltloo In and for tho County of Monnopin* *.Tco«trj!f be‘*lnr.i offlct r.tr.te r.f **:r.n9soto; .•.ai'i iironisca rtro itoroby ccnv.^yoii toijothrr with tho eaae.scnt re- u'lrvc** tr. rovnr of .*iaid pro?siaos by t!iot eertnin doou dated AuiVJnt 7, Ih**. irid f'lod In tho offie*.'» of tiio Uor.istrar of fltlos on ^optonbor *. C , i:*-*C aa dead Doounant ::u* i llao of tho Ke^lotrar of • Itio*: is; and for dannopln County* L'lnnosota: fnhjcet oa to a part t»r T,ct ii* Audltor*o Subdivialon *r.o* 30*^* to *:ho rlr/tta of eoooisor.t and of roptirohaso roaorrod in deed of roeosnl Im PooU 1U32* pa#.a 470 in tha offico of tho Rofiiotor of Doodo In and •'or '<onr.enSri County, i!lnnaoota* snd irlthcut projudieo to tho oaaoeient •Tcrtcd l»v deed in fover of oald !.ot 11 ond tho oonarn thereof In **f*»t-»<*« ni*fj** 'end t'narcln iioacrlUod; ..!-? M'ljoct to tho conditlrns cot^.f.lnod in t*'.ut cert:i?M cr.ri**:-.•cni •tatvJ •a;/:n:v/ a, ISIS, a:id filed In the office of the iia-.letrnr ct T-'.Jr*;; #.m Vcntenhev 24 * 124*1, oa iNic^c-ont :<o* :‘:2^1C(I9 , ; lou r.|* U:o -,trnr Ylnl»ja -ti and for nonnoeln ^o*!nly, "Sniia-tnia, ■ .It; :A -■y. I '*1 Iu J f y sCo IUAUC mb to {Dotb I^C froinc* TnfgUtf^ uUh all ths hevetlitamentn ofui •tpfutrtfnancti #• betoHjim^ or in anyiMc# nppirtainimg, to the eaid part 'J ____<>/ the etror,,* hi3 heir$ nIII/ nmi^hj, Fcrrrer. .4nd ike eaUi_______Ii3.th0T. ..V «. .-Cruab;* , . Atl ciOW ----- —- -w. V. W«« w • -. .. •• • • • »•*•« «• fcrt.y the firet part, /<^«ilOCflalXL#-hOP-r.teeutore omj art fu tm Let ra tore, tlo^P'J ooifennnt ii\ih the euid part.y^__of 0io eeromd |taK^.ilLs __helre enJ eeetfme, that__3*10—__%relt ,ihe IUh of all ampaid n^eial a^uBmeaU uad inUm* thereon. e!iul Ute abm>e b^renined and tntnted lands and premuee, in o-tUt and peaceabU pouufion o/^the afh: -y.™ c/ C».# e^onnd part.------------bla ----------------------hrire and neetfnr. ofntnst nil prrtone tau- fullo sia^mtmf i*r to oUtltn the uhoU or onp part thereof. subfret to tnrumbr^nrs 3 . . tisrelnbefo^ mentioned, the eatd fvirf-JE_____of the first part arill R'amnK and Defend Jn c.C5!(*no?ip CDbcCfcC. The oald pari of the first pari fut 3. hereunto m/... hor... dap and pear firot abaoe uritten. tn Preeenee ef ..._g ------- --------- _______ .eosfssm • » li 3 I I !i I I • I : I . J I D r i] c r I i f I I I I I s»tAte of fHinnesotti, ) Ca'*niy #/ , . . ___- ) Cm iki§ , ^ #/ . .. u . ------ , lXtit!iry—l.ttblic^^__ ^ mHOUm mtut §mhl Cmun^f, p§wmmmlip mwfmmrmd • 19. jlG, If/tfr* mtf. .^ -ipr;/._cno9oy.^ j^x^Assfu_____ ta wmm Irn^ift r# he tk§ penam ----dasaaitad im, and %aSa ajtaauUd ihs faaiialmi imatwuimHU, »■ ■—■»■ ■ mmd mtknmahdgad rrrnrffrf tha Mm« 410... hpr_... . faaa m:i aiid daad,. Cte Mff •! ---------------------------------------------------------------------------- A*«Ury fuUU —ltCOflep*.n.. -----------Cmmt^. Jflait. My arnmumiaaiam a^rpifti ___ MMCi f%* %**a Umm •m»«A *•« Msm* •••«•>«■• mam m» tmmummm* to «m •r m *i !• ImW in inui CM 1 Itr.•• •" 1 iz V. •*. • • •• {ni ''«l4n •* ■ 5 .^1 V *: ?•xr. « I iti U2 « i 5 Z < .1 c? 1" ♦ iff * 'I >•u. M • •• • 4 d I 5tot • •5^ •58 «*•. 5! - •2| u e - ii 'l a ?• •4 s 55 I.•• 4: tiu. -Ik *• •« • ••I w i tolc JmUm ir Jit r • f. * J.’' I .iv '•s. / 1.- v’' ‘h -w •o 9 .V. U -1^ jL |I f-* ■I EXHIBIT & \ ' *>-•'***.• it* .'-r.^?-:i'«- ■.. •.•r-v.> iS5- '. r - -■ ' • i toilfei SV15 BS-/ ': ■'L^s- Ml # *V<^'. • \ *. fflmP r *. %w*» ..V* » '■* «^_______ ^-r^,* ’,^^m■4i..'c aV •'•.T^— »» ^^isc'>Tf:i^:'-: M ^4'i^_ 555*:'^^ Ezza ■^-^--------------------S'*®' 13 ‘100 68th Avenue North f.l'nneapoiiS'Maple Grove. MN 5531 1 (612)420-9606 ORDER NO. Cf*________ NEGATIVE NO. /3 ^ " PJL. DATE FLOWN f APPROX. SCALE n:^ I CERTIFY THAT THE ABOVE CHARACTERISTICS ■R£ ACCURATE AND CORRECT. - C -3c > ' 9^ NAME DATE - H. V A’ ' - -.I'*'.:?* ‘Vi ,v-. «’. <•:•.•* •-. .; • IS3 in MBml 7'% mo I I li I II ,-Vtr.''\vxs-v, c <.. .ty v's, yy\^: 9-:Kl^rAs.,.vf ■■.-’'■•.-.<*->3rsS® AUG 1C 1979 . -S’ .;;: ••v,'.-;;•. JOITK 8. PIZX8BURY* Jll« •M i»Am rowM MI8!«BArOLM. MDOr CITY. OF. ORONO August 14, 1979 v; . r The Village of Orono Crystal Bay Minnesota 55323 Gentlemen:' •* * • % • , *• . » , • • . * • On August 8 I had occasion to check'th« north side of iry property in connection with a survey I had .recently v '• > ordered to be made. The ordering of this survey»"1nc1den* '’.•.'V-.-. tally, had nothing at all to do with the.controve»4y-that . C " has developed with respect to the use of Woodhil It Avenue.1 w*i * • * ^ I any event I found Woodhill Avenue-east’of'Mr. Wagener's driveway completely blocked by two large trucks which apparently belong to him. ‘ -v. * •* . •» «'.m .• • While I spoke briefly to his wife and indicated tnat I did not think that Hr. Wagener should block the rood, I did not ask her to have the cars moved because, frankly, that seemed to me to be an Inappropriate way to handle the matter. V If a public road is blocked, I do not think that a member of the public, and particularly an owner of abutting land, should have to ask an individual who Is blocking the road to unblock it and justify to that Individual the rea­ son he wants it unblocked. If an individual is allowed to control this, he Is In effect being permitted to take a governmental function Into his own hands. It seems to me that ai\y such request should be directed to the governmental authority which In this case is the Village of Orono. I therefore respectfully request you to Inform Mr. Wagener that he can not block this road and that you follow through to see that he remains 1n compliance with your mandate. JSP:bp Sincerely yours. ■ wt TS EXHIBIT D i I I HiKSKAViKULBERTSON FRi) 5.22'98.12:35/81 12:16A'0.3760036857 P 38 1 I I I L-I Lil^ n"‘ •' •A>'■'•■•■.■.; ■■ " '•■'■*• :-pr «: UL «■-*• .••• rv* • 4*»• -• o • ;• .•(/.' •■ i y. * : vi’ V/- •• !y. *. m§ €sm:0m^m( '•• •% A«tru*t 19, 1J9> • • ••.'.• :? ' . .rr»» Mr. Jo^ 8« Fill*bury, Jr, 530 ttain Tewsr ^ilCACCp9ll»^ JClniiOBC-tO 5 3-5 01 • • • • D«ar Mr, Pillcburyi • •* ^JvaaJc you foe your Ictvor rog&rila? ?i:csi3iill Avoitia r.:*r «tis ocattt>3 03 c pv±)lic ctroot. piSSSi- s- thm .afoty, health, an<3 »>alfar« of tho Sla. ^ h^flo4 Chiaf Kili>o, .uj^arvl.cr o? Um On.ao P^io* Daivart- Uoatlfy th« vahlcl.a in tjn.atlon blocking Wjodklll Ava^ ^ »50 to4. If thay ar« not wwry will b« toinid away at tha oimare Myanaoio -* boon lafomad tK«t * ^rioata road alcra hao b««n irkstalltii* •%j woodnill Avanua at tha Ofom Orchard Aoad, ^<W^fcoly. If tYAffio frtM SI WoodhUl vill S ^ r X>>mn t^mt problajn atriaS^ aapaxaj^ly, .r«th»r that blocking thaor saaignatlng it aa a prirata atr»at. • • Inforalng ua of your ooncyorwt and X can aiaurc ^u that tharw ia not a contrwaray bafora tha City Council raoardln<i tha atatui of Woodhlll Avanua a« a public atraat, rfigmx<Un<j • . • b .l‘A"*.* .* • •• I X,- t^-*. i .'rl iv S H.ViV ii C U L B E ET S 0 N [ t t t IFRI) 5. 22;,98il2:36/ST. 12:16/NO. 3760036857 P 39 • -.V.-V. •.;-T. •• • ; . «• *• • .* 2 fpM to coll My ^otloo*. ;■”■•'•.•■*'. ■•• r.-.v ^:'.•;.. •I • I •.t ;•' i-! ‘ . • i •». • • ;*jo V: t * • * «t BJ c£<lta..«7J-7SST, u y6.j » • ■t: ; Kaurleo tta^wRar, lljo s«k2?i1U * •. *>•) •/; •* •' :.. > . »•* V .r • • *:• 'j . • • .*^.^;i.v ’ ■ *'• • /-. 'V • • • . * • ■ » • * •• ••« •'. *. • . • •«••* I ; •• e • i •A * • • \ • • ‘' • I. . • • « ♦ •« r * V*-. 1 I •iI I a I Si­ lt^-f- ^ .»,'t *• “ •'* 'f « .. . /./‘ V'r*'4 '.'".v^** I I I I ii I II I I I I I I I I I I I I * • • • t W i M ?:? ..*1 *«v« T *•» •I :2 •;4a •-I ■.S r< fc' ?>••s • "a.v/ULL'i.'iiCjja (rHI) 5. 22-9S 12:35/.'’ 12:16A-0. 3760036857 f .•t ay Cfity of OMiOiNO - to I*. ««» too Bsgwartmom .'>V t.o<; C*-4** R^J <‘'-) V -.4 » ^. ^ f«) . **.«. ttUM f'wst; w ka,v. Au«u«t 17» 1979 J, V*ffone-AvJSr • fUnn. 55591 ' t • . Mr. Waffimor, i>l<wk«d «c?cao''orwoidhj\rAicnu^.^^T^ cn occasion “ «?>■ ■•> |.lo'. Ml thot lndlcnt« - you have any quontlnna, ,a*‘n-c- ntKll ^r I * <i-t r.o^i ao ot h75-77io, "'ir.corcly, • I ... A/ « /' .• ^Ivin K. Chirr of pQlie,. W^K/n»w rim • .1 7. Letter from James P. McCarthy to Cliff Greene, dated November 20,1998 I 1 LINDQUIST & VENNUM p. I r r 1 [ n I►. t I i i P.L.L.P. IN Denver 4200 IDS C enter U noquist . vennum & C^iR stensen 80 SCw'^H Eighth S'R£E* PLLP Minneapolis Minnesota 5S402-220S 600 17th Street . Suite 2125 Telephone 6i2*37i.32ii Denver .C olorado 80202*5401 A ttorneys A t Law James IV McCarthy ((»I2)37|.323H jmccanhyiu lindquist com November 20.1998 Clifford M. Greene. Esq. Greene Espel 333 South Seventh Street Suite 1700 Minneapolis, Minnesota 55402 Re: Woodhill Country Club v. City of Orono, et at. Court File No. 98-10541 Dear Cliff: I am writing to follow-up on our telephone conversation of last week. You had inquired about a stipulation as to certain documents and facts. While willing to stipulate to facts, I also inquired whether the issues in the lawsuit could be narrowed. At the commencement of the action. I understood that the parties disagreed as to the requirements of the conditional use permit ordinance. I believe that continues to be the only substantive issue between the parties. I was surprised to find Orono taking the position that Woodhill Avenue has never been a public street up to the Woodhill property line. My client is aware of no facts which support that position. Since the City has raised the issue. I have looked into both the law concerning the topic and begun the process of gathering evidence. I strongly believe that, if you review that law and information, you will agree the issue should be dropped from the lawsuit. Rather than just leave a few cites on your voice mail, I thought it may be productive to share my legal and factual research in almost memo-like form. Docs IO74480M I I I I I f I f I I I I I I I I 1 1 LINDQUIST & X'ENNUM p l l p Letter to Clifford M. Greene. Esq November 20. 1998 Page 2 The defense asserted by the City arises from the fact that the easterly portion of Woodhill Avenue as traveled deviates from the straight line shown in the 1887 Plat of Minnetonka Bluffs and the 1924 Plat of Orono Orchards. The City’s position appears to be that because this portion of the traveled road deviated slightly from the plats (in order to curve around the hill) that it is not a public road like the rest of Woodhill Avenue. However, a street can become a public street not only by being platted, but also through common law dedication and the statutory dedication under Minn. Stat. § 160.05. In the present case, Woodhill Avenue did become a public street to the Woodhill property line both through common law dedication and statutory dedication. The elements of a common-law dedication of a roadway are (1) the land owner’s intent - express or implied - to have his land appropriated and devoted to public use; and (2) an acceptance of that use by the public. Benoston v. Villiaoe of Marine on St. Croix, 246 N.W.2d 582, 584 (1976) (citing Daugherty v. Somers. 68 N.W.2d 866 (Minn. 1955); Keiter v, Berae. 18 N.W.2d 35, 38 (Minn. 1945)). “A dedication rests upon assent and not prescription." Bengtson. 246 N.W.2d at 584. A land owner’s intent is expressed when he "asserts that the road is public, and thus his intent is unquestionably to dedicate it." Bengtson. supra at 585. In Sackett v. Storm. 480 N.W.2d 377, 380 (Minn. App. 1992), a lakeshore property owner sought a court determination that the disputed roadway v/as dedicated to public use against an adjoining property owner (Storm) who had erected gates preventing plaintiff's use of the roadway. ]d. at 379. Evidence of intent was found based on an affidavit of a prior ov/ner of the Storm property. "Henry Loxtercamp, the immediate predecessor in interest to the Storms, stated by affidavit that when he bought the property in 1968 he knew there was a long established roadway that he assumed all had the right to use. Loxtercamp also stated that he ’intended that the roadway be dedicated, used and maintained year-around for the general use of the area cabin owners and the public.’" id. at 380. See also Keiter v. Beroe. 18 N.W.2d 35 (Minn. 1935); Anderson v. Birkland. 38 N.W.2d 215 (Minn. 1949); Metalak v. Vasmussen. 238 N.W.2d 478 (Minn. 1931); Carpenter v. Gantzer. 204 N.W.2d 550 (Minn. 1925). Acceptance of a common law dedication may be shown either by public use or by maintenance. "Acceptance of a dedication by the public may be shown by public user, as by travel, or by acts of public officers in improving and maintaining the road." Daugherty v. Sowers. 68 N.W.2d 866. 868 (Minn. 1955). “Common user by f)4»C« I0744S0 I t LINDQUIST & VENNUM p l lp Letter to Clifford M. Greene. Esq November 20, 1998 Page 3 the public is the very highest kind of evidence of public acceptance of a dedication." Benatson 246 N.W.2d at 584. “A public user may be established by a comparatively small number of persons." Id. “Among the differences between statutory and common-law dedication,... is that no specific time period of public use and maintenance is required for a common-law dedication. All that is required is that intent and acceptance coincide, and thus dedication may be made instantly." Woiahn v. Johnson. 297 N.W.2d 298, 308 (Minn. 1980) (citing Benatson. supra at 584). In our conversations, Tom Barrett suggested that "public use" of a cul-de-sac road cannot be established through use by the “end of the road" property owner or his or her invitees. That proposition is, however, incorrect. Minnesota courts have routinely found “public use" under both statutory and common-law dedication to arise based on the use of the road by an "end of the road" land owner and his or her invitees. As recently as April 14. 1998, the Minnesota Supreme Court affirmed a Court of Appeal's decision that held use by a property owner and its invitee’s constituted “public use." In the Request of Lafayette Development to Open 18'^ Avenue South . 567 N.W.2d 743, 745 (Minn. App. 1997), aff’d, 576 N.W.2d 740 (Minn. 1998). In Lafayette, "the record indicates that respondent, its tenants, their invitees, and adjacent land owner have used the end of 18'^ Avenue to access their property for many years." Such use was sufficient for dedication; Use by a 'comparatively small number of persons’ may establish use of a roadway. Flynn v, Beisel. 257 Minn. 531, 541, 102 N.W.2d 284, 292 (1960) (establishing public use under common-law dedication); Anderson v. Birkeland. 229 Minn. 77. 82. 38 N.W.2d 215, 219 (1949) (establishing n jblic use under statutory dedication and common law dedication); Henlv v. Chisaoo County. 370 N.W.2d 920, 923 (Minn. App. 1985) (establishing public road under common law dedication). And a use primarily by respondent, its tenants, and their invitees does not defeat a finding of public use because “[i]t is the right of travel by all the world, and not the exercise of the right,” that makes a roadway public. Anderson. 229 Minn, at 82, 38 N.W.2d at 219 “holding with seasonal use of road by cottage owners, friends, and tradesmen sufficiently establish public use)." IX>C» I0744SU I LINDQUIST & VENNUM p l.l p. I t 1 f i Letter to Clifford M. Greene. Esq November 20, 1998 Page 4 Lafayette . 567 N.W.2d at 745 (emphasis added). In a case that is strikingly similar to the Woodhill situation, "public use" was established solely through use by a country club property’s prior owner and his invitees. Leeper v. Hampton Hill, Inc.. 186 N.W.2d 765 (Minn. 1971). Leeoer held that an access road that dead-ended in a country club was a public road based on use by the prior owner of the country club property. Like Woodhill. the road in question connected the country club to a larger public street (County Road No. 47). The road, Juneau Lane, passed over plaintiff ’s property. The plaintiff in Leeper agreed that Juneau Lane from County Road 47 up to his driveway was a public road, just as Orono agrees that Woodhill Avenue prior to 1988 was a public road only up to the point Woodhill Avenue curved to the south. “However, they [plaintiffs] contend that the trail from their driveway to the Winkler property [now Hampton Hills Country Club] was never established as a public road but as merely a part of the private property.” 186 N.W.2d at 766-67. The Court found that the disputed portion of Juneau Lane was established as a public road in 1955 before plaintiffs purchased their property because it was used by was “the various occupants" of the country club property and "any person desiring to visit such occupants or to do business with them." Id. at 767. I have enclosed a copy of the Affidavit of John Pillsbury. Mr. Pillsbury owned the property subsequently developed into Woodhill Ridge from 1946 through 1988. Mr. Pillsbury’s affidavit establishes that he knew of the existence of Woodhill Avenue and knew that it was used openly by the public. He raised no objections to use by the public. He intended for the road to be used as a public road up to the Woodhill property line. He knew the road had been used as a public road to Woodhill before he purchased his land in 1946. Further. Mr. Pillsbury’s correspondence which we obtained from the City’s files on Woodhill Avenue confirms his intent to dedicate Woodhill Avenue as a public road. In 1979 he wrote to the City complaining about the trucks Mr. Wagener had parked on that portion of the road east of Mr. Wagoner ’s driveway (i.e., the portion of the road that curved south of the platted road). Mr. Pillsbury informed the City that it is the City’s responsibility to exercise its "governmental function” to take care of trucks blocking a public roadway. Both the City Manager and the City Police Chief agreed. The City Manager acknowledged both the historical maintenance of Woodhill Avenue by the City of Orono and the status of Woodhill Avenue as a public street. The Police Chief, at the request of the IXk« I0744S0 I L 1 LINDQUIST & VENNUM p.llp. Letter to Clifford M. Greene, Esq November 20, 1998 Page 5 City Manager, proceeded to have vehicles removed from the portion of Woodhill Avenue between Mr. Wagener’s driveway and Woodhill Country Club. The record of Mr. Pillsbury’s dedication of the road up to the Woodhill Country Club property line could not be more clear. Similarly, the evidence of acceptance of that dedication by public use is well known to Orono and is established in the testimony of John Morrison and John Pillsbury’s affidavit. Through the years that Mr. Pillsbury owned the property, Woodhill Avenue was used on a regular basis by Woodhill members and their guests. It was used by the those families that lived in the original farmhouse and the barn manager’s house which were located near the western entrance next to Woodhill Avenue. It was used by their guests. The road was used by service people making deliveries both to the club and to the families living near the west entrance. For many decades, a ho-se show was held annually at Woodhill to which the public was invited. The show was publicly advertised by a billboard and was sponsored by the Minneapolis Junior League. Woodhill Avenue was open to and used by horse show attendees. Families who were not members of Woodhill but who rented boarding space for their horses at the stables also used Woodhill Avenue. Similarly in the 1950’s and 1960’s Woodhill teams participated in a youth hockey league. Members of the public participating in those league games used Woodhill Avenue. Families that lived on Woodhill Road, their guests and service people used Woodhill Avenue. We also have evidence of numerous people who were not club members who simply used Woodhill Avenue to cut-through to Woodhill Road and County Road 15. Both the quant* *^ d ve . ty of use of Woodhill Avenue far exceeds the type of use normally found V to constitute “public use” for purposes of dedication. In addition to common-law dedication. Woodhill Avenue up to the Woodhill Country Club property line is also a public road through statutory dedication pursuant to Minn. Stat. § 160.05, subd. 1. "The requirements of the statute are met with the showing of use by the public and maintenance at the expense of an appropriate agency of government over a continuous period of at least six years." Town of Bell Prairie v. Kliber. 448 N.W.2d 375 (Minn. App. 1985). For the reasons discussed above, sufficient public use is present for statutory dedication. As for maintenance, "it is not necessary ... that every part of tne road be worked at government expense or that any particular part receive attention every year of the six year period,” Kliber. supra at 379, but, ”[t]he maintenance must of a quality and character appropriate to 1074480'I LINDQUIST & VENNUM p.ll.p Letter to Clifford M. Greene, Esq November 20, 1998 Page 6 an already existing public road." As evidenced by the 1979 letter of the Chief of Orono Police, Woodhill Avenue, including that portion of the road that dips south east of the Wagener driveway, was policed by the Orono police. Both for decades before and after the construction of the Wagener house in approximately 1958, Woodhill Avenue was plowed through the winter. Decade after decade the gravel road was maintained and graded. Aerial photographs from the 1940's to the present demonstrate the uniform maintenance and surface treatment of the road up to Woodhill's property line. Indeed, Orono ’s own “Official Zoning Map" as revised through June 10, 1998, shows Woodhill Avenue extending to the Woodhill property line. Thus, both maintenance by public authorities and public use establish Woodhill Avenue as a public street up to the Woodhill property line. It would be useful to determine what issues can be narrowed and what facts can be stipulated to prior to embarking on numerous depositions. After you have had an opportunity to review these cases, Mr. Pillsbury's affidavit, and the facts, we should talk. I have begun to assemble various plats and surveys that we discussed so we can come to an agreement on those documents. I am enclosing a set of dated maps showing the parcel locations and assessment numbers of the relevant parcels. I would appreciate it if the City would review these and stipulate to their accuracy. Sincerely. LINDQUIST & VENNUM P.L.L.P. \/\r-— James P. McCarthy \ JPMcilms enclosure DiKtt I0744S01 I I I > ' I • ♦ f -V#u u r i r r 8. Letter from James P. McCarthy to Cliff Greene, dated January 26, 1999 with attachments LINDQUIST & VENNUM p.l.l.p. In D env 'ER 4200 IDS Center U ndouist . Vennum & ChRiStensen 80 Scxjtm Eighth Street pllp Minneapou S. Minnesota 55402-2205 600 17th Street . Suite 2125 Telephone 612-371-3211 D enver . Coloracx ) 80202*5401 AnoHNEYS A t Lav. James V. McCarthy (612)371-3238 jmccarihy^t lindquist com January 26.1999 Clifford M. Greene. Esq. Greene Espel 333 South Seventh Street Suite 1700 Minneapolis, Minnesota 55402 BY MESSENGER Re: Woodhill Country Club v. City of Orono, et at. Court File No. 98-10541 Dear Cliff; In our recent discussions concerning the "public street" issue, I had asked you to focus on the John Pillsbury correspondence in the summer of 1979 and the statements and actions of the City of Orono in response. As I indicated, the “intent" of the landowner to dedicate the street to public use is quite clear in Mr. Pillsbury’s letters. Further, the "use" of the road by the public has been admitted by the City and is clear from Mr. Pillsbury’s letters, the petitions and letters of neighbors and the recollection of members, employees and area residents. Further, the City of Orono ’s "acceptance" of that dedication (which I believe the law does not require separate and apart from use by the public) is clearly shown by the City of Orono ’s response to Mr. Pillsbury’s concerns about vehicles being located between Mr. Wagener ’s driveway and the entrance to the Club. As a backdrop to this discussion. I am again enclosing a copy of the 1987 survey of Woodhill Avenue and have highlighted the location of the driveway to the WagenerAA/ood house. I believe you had an opportunity recently to confirm in person the location of this driveway. I visited the site last week and confirmed that no truck could be parked east of the Wagener driveway without being outside of the 1887 platted right-of-way and on what the City of Orono has termed the "Pillsbury easement". UKtf IO‘»01.S2 I I I I f I r f r r r. r L. r LINDQUIST & VENNUM p.l.l.p. Clifford M. Greene. Esq. January 26, 1999 Page 2 f ' \ The July 30,1979 letter from John Pillsbury to John Morrison as president of the Country Club (Bates # ORO 820-823) sets forth Mr. Pillsbury’s understanding that all of Woodhill Avenue is a public road and his specific concerns that the road be considered and treated as a public road wholly apart from any access to the Woodhill Country Club. First. Mr. Pillsbury was very precise about his understanding of the location of Woodhill Avenue. He stated that: "Woodhill Avenue, extendfs]... to the westerly boundary of the Woodhill Club property." Mr. Pillsbury stated that the gate constructed in 1978 is "at the eastern extremity nf Woodhill Avenue. That the eastern end of Woodhill Avenue was the property line of the Woodhill property was fully understood by all parties at that time. Both the point where Woodhill Avenue ended and the location of the Woodhill property line are described in the letter of Charlie Bellows, president of Woodhill. to the attorney for Mr. Wagener in a letter dated July 21. 1978 (Bates # ORO 809). Describing the gate that was put up in 1978 in connection with the establishment of hours on the use of Woodhill access. Mr. Bellows stated "the gate itself and the barrier are 8-10 feet East of Woodhill ’s westernmost boundary line which also is at the point at which Woodhill Avenue terminates." Similarly, the City of Orono officer that visited Woodhill Avenue in July. 1978 stated that the "east end" of Woodhill Avenue was where "a metal gate had been installed and was open at the time." (Bates # ORO 809). The record is clear that up to 1979, Mr. Pillsbury. the City of Orono and Woodhill knew where Woodhill's line was located and each clearly understood that the east end of Woodhill Avenue extended to the Woodhill Country Club property line. John Pillsbury was unequivocal as to his belief that this stretch of road up the Woodhill property line was a public road. I have always understood that Woodhill Avenue is a public road and know of my own knowledge that it has been used going back at least prior to 1920 for access to the Woodhill Club property." Mr. Pillsbury identified several reasons why he had a strong interest in maintaining Woodhill Avenue’s status as a public street. First, the utilities for his property ran in Woodhill Avenue up to approximately the Woodhill property line and then ran back to his house parallel to the Woodhill property line. Mr. Pillsbury was concerned that any utility company trucks must gain access over Woodhill Avenue to the eastern extremity of that street iust short of the Woodhill gate." (Indeed the utility poles run along the side of Woodhill b I LINDQUIST & VENNUM p.l.l.p, Clifford M. Greene, Esq. January 26. 1999 Page 3 I Avenue and serve not only the Pillsbury property but also Woodhill. There is a recorded 10 ft. utility easement running south from Woodhill Avenue along the Woodhill property line to the Pillsbury house. There is no separate east-west utility easement along Woodhill Avenue. The utility poles were placed in the public right-of-way up to the Woodhill property line.] Second, Mr. Pillsbury was contemplating development of his property and was concerned that Woodhill Avenue was a public road up to the Woodhill property line. Mr. Pillsbury cites that on two occasions. Sunday, July 29 and Monday, July 30, 1979, he observed “two large commercial looking trucks ... parked on Woodhill Avenue so as to totally block it." Mr. Pillsbury noted that the trucks were “immediately to the east of Mr. Wegener’s driveway ." Both the survey map and a walk of the site establishes that trucks could not be parked east of Mr. Wagoner’s driveway without being outside of the 1887 right-of-way and on what the City refers to as the “Pillsbury easement.” Mr. Pillsbury emphasized that the location of the vehicles blocked public access to the public street even though Woodhill ’s driveway was closed by a gate at the time: “I also don't know whether these cars are parked there merely for the convenience of Mr. Wagener and because he assumes that with the Woodhill gate locked, no one wishes to travel further east or whether he has positive permission from the Village of Orono to park the vehicles there. I do know that with the vehicles parked there it would be impossible for utility trucks serving my utilities to reach the point where they would enter my property." Mr. Pillsbury noted that whether or not the Woodhill Club keeps the gate closed is a matter of Club policy" with which he is not concerned. He was however, "very concerned about his legal rights as a member of the public.” On July 31. he sent a copy of his July 30 letter to Mr. Morrison to the Village of Orono and asked for "an acknowledgment of this letter" and assurance that "no action in respect to Woodhill Avenue which might affect the public rights to the road" will be taken without notification to him. (Bates # ORO 819) On August 14. 1979. Mr. Pillsbury again wrote the Village of Orono describing the fact that he found "Woodhill Avenue east of Mr. Wagoner's driveway completely bio~ked by two large trucks which apparently belong to him.” (Bates # ORO 815) Mr, Pillsbury told the City that "if a public road is blocked, I do not think that a member of the public, and particularly an owner of abutting land, should Does um)\>2 \ i "I fl LINDQUIST & VENNUM pl.l.p I r n n n r n 1 r I i L L c Clifford M. Greene. Esq. January 26.1999 Page 4 have to ask an individual who is blocking the road to unblock it.."If an individual is allowed to control this, he is in effect being permitted to take a governmental function into his own hands. It seems to me that any such request should be directed to the governmental authority which in this case is the Village of Orono. i therefore respectfully request you to inform Mr. Waaener that he cannot block this road .. " As you know, the City of Orono responded to these three letters from Mr. Pillsbury. They responded by writing to him stating that the Woodhill Avenue was a public street and by the police chief informing Mr. Wagener that the trucks had to be removed. Contrary to the position now taken in its response to the Request for Admissions, the City did not inform Mr. Pillsbury that Woodhill was a public street up to Mr. Wagoner's driveway, but a private road on Mr. Pillsbury’s property east of Mr. Wagoner's driveway. There was no suggestion from the police department that removal of the trucks fell outside of its jurisdiction. I think that these facts call for the City to re-evaluate its denial of request for admission No. 8. The City’s explanation for its denial states that: “the unpaved gravel road was not intended to be dedicated as a public road, and the unpaved road was treated by Woodhill Country Club as part of its private property." This response is incorrect as to Mr. Pillsbury's intent, irrelevant as to Woodhill’s intent, and vague in its references to "unpaved gravel road." I believe that the statements of Mr. Pillsbury not only in his 1998 affidavit but in his 1979 correspondence with Woodhill and the City of Orono clearly establish his intention with respect to the status of Woodhill Avenue as a public road The City’s response suggests that it was the intent of Woodhill rather than the intent of Mr. Pillsbury which is determinative of common law dedication of the road over Mr. Pilisbury's property. Since Mr. Pillsbury was the underlying fee owner, it was his intent to dedicate the road that is the relevant evidence on this issue. Finally, the reference in the City’s response to "unpaved gravel road" is confusing. Mr. Pillsbury owned the property from 1946 through 1988. For most of that time, the entire road from Orono Orchard Road to the Woodhill line had only gravel paving. It appears that at some point a coating was placed on the road past the Fox/WagenerA/Vood driveway and past the 1887 platted right-of-way. See Request for Admission Exhibits 15 and 16 (attached). In particular Exhibit 16 shows “existing bituminous" extending beyond the 1887 right-of-way. After Mr. Pillsbury sold his i)oc« i I I I LINDQUIST & VENNUM p.l.l.p. Clifford M. Greene, Esq. January 26, 1999 Page 5 \ * i i « . t « . * I property, new bituminous paving was done in 1988 and extended up to approximately 50-60 feet from the Woodhill line. As to the second element for common law dedication, "acceptanre ” of the dedication may be shown either by public use or by governmental maintenance. The City has admitted that prior to 1968 use was made of Woodhill Avenue by the public and that this public use extended up to the Woodhill property line. However, both in the response to request for admission and In our discussions, the City has suggested that the law requires not just “public use" but some other step by the City in order for there to be "acceptance" of a common law dedication. “Acceptance of a dedication by the public may b( shown by public user , as by travel, or by acts of public officers in improving and maintaining the road." Daugherty v. Sowers . 68 N.W.2d 866, 868 (Minn. 1955). The Court has repeatedly recognized that “common user bv the public is the y^ery highest kind of evidence of public acceptance of a dedication." Benqtson v. Village of Marine on St. Croix. 246 N.W.2d 582, 584 (1976). I have found no cases which have suggested that the “acceptance ” element of common law dedication requires both public user and maintenance by a governmental body. The final paragraph of the City’s response discusses the platting of the right-of-way in 1988. The platting of the right-of-way in 1988 is not really responsive to the request which only asked about existence of a public street prior to 1968. Request No. 8 does not ask the City to take a position on any event or occurrence after 1968 or on the status of the road after 1968. I think that for each of the reasons set forth above, the evidence is uncontroverted that Woodhill Avenue up to the Woodhill Country Club property line was a public street by common law dedication prior to 1968. Mr. Pillsbury knew his boundary lines, knew the location of the road and intended that all of it be dedicated to public use. It was, in fact, used by the public - the highest form of evidence of public acceptance. In addition, the area of Woodhill Avenue east of Maurice Wagener ’s driveway was accepted as a public road by the City officials in 1979 and actively policed as evidenced by the police chiefs letter to Mr. Wagener and the official removal of the trucks. t IXk.- L I f LINDQUIST & VENNUM p.l.l.p. I I Ui n I * Clifford M. Greene. Esq. January 26. 1999 Page 6 I hope that this additional information and analysis will assist you in a speedy determination on this issue. It will cut down on the expense of trial preparation of both sides if this issue can be resolved as soon as possible. Sincerely, LIND □UlST & VENNUM p.l.l.p I • \ James P. McCarthy JPMcilms cc: Ned Dayton Edge Jackson l)iK« I •i PRIVATE DRIVEWAY PC.oPot>e.D C-NAP I I I r r r r r r r r r i i I I i I t PROJECT DATA ROSS AREA 17.52’ ACRES NUMBER OF LOTS 5 All/of i4>i n. •ilrvA^soLA. “ Au1tU>r*« SuhdlviBicyi 3C?. Ii«v»^pin Corrly. t/jtt :nr* dPAcrltwl mi folIrM*; fWfinrtrv^ aI Ih# »ri«l r*»rLf.»-»trr4 » of said l^l 13 JwtufA nom^r It «I m> iPe • «.r t r.«>*kjitrr. 7 imitTwr r.f Lot 1 of Mild Ai*Jllor*t SmI iII vi»|nnl; |jv»i u»« North )lr»« of tmrl l/»l 13, • di«tAnrfi of Ji frt-i. Ihrnc-* South 1ST.75 ft«i: thtnr* Wrti 25 fr«l. ■orr of l»t«. to th« «AAl Jine of tAld Lot I of told Ai*3iU)r’t SutsSlviaion. »hrnro MTrt^ tior^ told tttl line 157,75 fr«t, w^rr or Irta, lo •/.« jr>»nt of U'tirjilhd, til tooordlrvl t/j the rrcor\l»yJ plat t/llTT^lf . All of i/>i 12. Nirviraoto. ALAiltor*t Sul*3lvitlon Muaber 307, llchiiepin C<Ktiir. Ijiiypl • iriMittler tract of 1m»1 In told Lot I2» detcribtd to f.illcwv r>fkrvoir\t el t point In tht dtvldlnf line bel*«*«n Lott 3 Mki 12 in aeid Auditor's Subdlvitlon I^Jtber 307, Uilch point It I feet northerly frot IKt northattterly oomer of lot 4 in told *lulAJlvi8lcwi. thence Northerly alnnd t7»e dividing het*t»en afnrratid lott 3 and 12, * dialAnct of 7S.9 feet to tn tnila point in atid divldind line; thence tt t right angle eaaterly along the dividing I lee between aald Lott 3 and 12, a ditttnoe of 57 f^^t to tnoihrr angl<* point In aald dividing line; thenra .Vajth««tterly In airtight line 97.3 feet, aora of leee, to the point of r^glnnlng. ,l.n ..»pl Ml tart of Mid tot i:. "« •"“‘'“■'••l' of Oi. fol lowing Ocacritnl line; rrenencing at a Jitllclal Laivtert on the aoilherly teralnua of •« vaeterly lir« of aald Lot II. aho»e» aa baing 5B0.60 feet in langih aald Aiflilor'a SwUllvialan plat; thence on an aaa»jeMl baaring North 0 drgreea 34 alnutaa 29 aaoenda Waat along aaid eaaterly lira- to a Julioial teretaMTii on lha northerly tar^nut of aald eaaterly line, tharvaa South 39 dagrrea 48 einutea 42 aeoonda Neel* a diatance of 330.88 feet; thenca aouth 77 degrre* 04 elnutre 0' a«c<y«la veal, a lilatancc of 833,63 feet to the reeierly line ®* 6, "Aialitor'a SubJUlalon Itaber 307, Hennepin Co^lf* Ninnraota ; ihrnre North 0 degrect 08 alnutea 54 eeoonda M-*).* t«»ierJy line, a dlatance of 115.52 feet to ^ 111 OQ I LU QC X H < A CO < a q! QC < .i lUoc 0. aoo ( I f I -r > i 9. 1968 Conditional Use Permit Application and Permit i • 4 4 r I :: ^ • ’T-VHIsge of Orono Mim USE PERMfT W6.. * *•»•*» For Non*Co&forBlog Uso V. . 'v t i V } '* V Feo Case No. VI LUGE OF ORONO Crystal Bay, Minnesota (Complete in Duplicate) applications for conditional use permits Type of Application_M^^p^„f^^_|^^ innate S-71-6B Owner of Property: n..w Phone No. 473-6031 Tony Kallas Address POO Sherelina Drive ~ Applicant (other than owner); Name Address Phone No. Engineer: Name_ _ Lend Planner: Name Subdividar; Name Relationship to Owner Location (How do we find it?) Phone No. Phone No. Phone No. Legal Description; L«t ? rt iit Plat 413027Parcel 3B02 ' Date Acquired^^aj^_ _ _ _^Area (sq. ft.) ISO Ac Separate Ownership Single Ownership_j Date of last division of this property Do you own any adjoining property? ——————— Action Requested_]jfln.confQrmln> U«T~Parmlt far ,oif Inspection Dept: ^ 'v.^dministrator: Village Council: Village Engineer: Signature of Applicant RECORD OF ACTION TAKEN Action village Engineer: ^ yp \Village Attorney; TT Manning Commission: u n . V,vi:i.ge Council: R«»r^or Permit Issued: Date ttP 1 3 668 - - - - - OR0126 "Coxidition of Non-Conforming Use: Approximately 150 acros in Orono, Club house and various accessory buildings for entertainment. Private club.» I Page 3 VILI.ACE OF ORONO QUESTIONAIRE FOR EXISTING NON-CONFORMIKG CONDITIONAL USE PERMIT APPLICATION 1) Name of businesj and owner_ _ _ _ _ ejL^ «ii<iress of propertir where buiiness is conducted Z) 3) Date business began STATUS OF BUSINESS fN MARCH 11, 1§S7 was th^ nature cf your business on this date^ .7^U-OVlA-^Vt-*.zs/c. ■2)riow aany buildings of what type and site, and location were used for your business on this date "7— How much and what kind of equipment used for business on this date . a .r tvb, * 4• • u fe* (LXX f:I i*i ’^1? STATUS OF BUSINESS ON FURCH 10. 1967 What was the nature of your business on this date _ _ _ _ _ _ _ _ _—' OL^.i-i r:^: r i I. I •J • • « ■ v''m L. 1w • *. • .. Pa«e 2 Page 4 How many buildings of what type aUe .oh , business on this date j; ^ —-- - - - - - - - - - - - - -- - - -- »l»ch n. 1,S7 “t«e^SIt^I„‘d"ia^'’'”" « • Signed r )■ '• \. .\-\ - I A I I I I r r I I I I I I I I I I I I I 10. Minutes of Orono City Council, dated September 9,1968 I I r r r r r I I I I I I I I I I I 05 22 -9*» FRI 13:44 FAX 6123441366 tin UKUNU e o ic*tr iw)ULKERS0N GILLIUNR I Regular ^ |tln|^o VILIAGE OP ORONO ting of the Village Council* The Village Council met on the above date with the following membere present: MayorBi -Ross, Councllmen Butterfield* Franzel* Searles, and Stubbs. Sesrles moved, Stubbs seconded, that the Minutes of the Regular Meeting of August 26, 196B* be approved. Motion* Ayes (S) - Nays (0). The following appeared: K. Andrus concerning Review Publications. V. Bi Sdwards concerning Pure Oil Building Permit. R. Dunn concerning variance. Butterfield moved, Stubbs seconded, that an amendment to the Non'Conforming Use Permit Section of the Village Code setting application date at November 1* 1968* be approved. Roll Call* Ayes (2) Nays (3). (Franiel, Scarles, and Mayor Ross voting Nay). Searles moved Franzel seconded, that the Conditional Use Permits for Non-Conforming UseSj Administrative nemo of September S* 1968 as excepted, be approved. Roll Call. Ayes (3) - Nays (2). (Butterfield and Stubbs voting Nay), Searles moved* Stubbs seconded, that a Public Hearing, October 14, 1968, at 7:30 P.M., CDT, concerning the renaming of certains streets that extend into the Village o£ Medina, be ordered. Motion, Ayes (S) • Nays (0). Frantel moved, Searles seconded, that the request of H, Johnson for a Registered Land Survey including a cul«de*$BC at loss Concordia Street* be approved. Motion, Ayes (S) - Nays (0). • I • “|W IJ- 9 mm /r ^ 7.*S0 P. M. MINUTES AMENDMENT NON-CONFORMING USE ORDINANCE CONDITIONAL NON-CONFORMING USE PERMITS PUBLIC HBARING Renaming of Streets • *» ... a REGISTERED LAND SURVEY 1635 Concordia Street OR0498 /<■ I I I r r r I I I I I I I I I I I I I 11. Excerpts of Deposition Testimony of Robert Searles EXCERPT OF DEPOSITION TESTIMONY OF ROBERT SEARLES Question: “As you looked at this hand-drawn portion of the Application in 1968, what was your understanding then as to what the drawing of the driveway off to the left of the page indicated?" Answer (by Mr. Searles): “Well, it was just the driveway within Woodhill property that attaches to Woodhill Avenue and that was obvious to all of us. It wasn’t even a subject of discussion." Question: "When you moved to approve the permit for Woodhill Country Club, was it your intent to change, In any way, the access to Woodhill Avenue?” Answer: “No, there was no intent to change the Woodhill Country Club, the use of Its property or its accesses, and this is a specific memory.” Question: “Can you describe for me, when you say the word “Woodhill Country Club’s access" as to what you mean? Answer: “Well, I mean the access to 15 and the access to Woodhill Avenue. Those are the two accesses.” Question: “Would it be accurate to state that in the permit that you moved approval of, there is no limitation on Woodhill’s use of - Woodhill Country Club’s use of Woodhill Avenue?” Answer: “There were no limitations.” Question: "In connection with the permits that you moved approval of, did you understand that Woodhill Country Club would have to seek City approval to either raise or lower a chain across either of its driveways?” Answer: “No, there is no such -1 have no recollection of any such view by the City of Orono (See Searles deposition at pages 57-59). I I I I f I I f r I r I I I I L I L L 1 2 3 4 3 6 7 8 9 10 I I 12 13 14 15 16 17 18 19 20 21 22 23 24 23 STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPFN FOURTH JUDICIAL DISTRICT Court File No.: MC 98-10341 WOODHIEL COUNTRY CLUB. PlaimilT. V». CITY OF ORONO. Defendamt. DEPOSITION OF ROBERT SEARLES Couniel for Plaintiff: MR. JAMES Mc C arthy (via phone) Lindquist St Vennum, P.L.L.P Attorneys at Law 4200 IDS Center Minneapolis. Minnesota 33402 Counsel for Defendants: MR. CLIFF GREENE (via phone) Greene Espel Attorneys at Law 333 South 7th Street. Suite 1700 Minneapolis. Minnesota 33402 Mary Jo Armour McGill. RPR February 17. 1999 1 STATE OF MINNESOTA DISTRICT COURT COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT 2 Court File No.: MC 98-10341 4 WOODIIILL COUNTRY CLUB. Plaintiff. 6 vs 7 CITY OF ORONO. 9 10 11 12 13 14 13 16 17 18 19 20 21 22 23 24 23 Defendants. DEPOSITION OP ROBERT SEARLES PURSUANT TO NOTICE for the taking of the deposition of ROBERT SEARLES. upon oral examination in the above-styled cause, at the instance of the Plaintiff, for the purposes of discovery or use at trial or both, pursuant to Minnesota Rules of Civil Procedure, proceedings therefor were held before Mary Jo Armour McGill. Registered Professional Reporter and Notary Public in and for the State of Florida at large, at Seaboard OfTice Park. 3 12 East Venice Avenue. Venice. Florida, on February 17. 1999. commencing at 10:43 a.m SCXAFANI WILLIAHS COURT REPORTERS. INC. SARASOTA. FLORIDA (941) 934-0020 1 2 3 4 3 6 7 8 9 10 11 12 13 14 13 16 17 18 19 -20 21 22 23 24 23 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX WITNESS PAGE Called by the Pt.inlifT; ROBERT SEARLES DIRECT EXAMINATION BY MR. MCCARTHY................ 12 CROSS EXAMINATION BY MR. GREENE.................... 64 REDIRECT EXAMINATION BY MR. MCCARTHY............. 96 SIGNATURE PAGE.......................................... 108 CERTIFICATE OF REPORTER OATH...................... 108 REPORTER'S DEPOSITION CERTIFICATE................ I lO EXHIBITS Eichibil Noi. I42throu8h 132 ........................ 4 SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 934-0020 4 THEREUPON, the following prcTceedings were had and taken: (Exhibit Nos. 142 through 152 were marked for identification.) ROBERT SEARLES. called as a witness bv the Plaintiff, having been first duly sworn, testified as follows: MR. Mc C arthy : This is a deposition being taken in the case of Woodhill Country Club versus the City of Orono, et al., in an action pending in Hennepin County District Court. I am James McCarthy. I represent the plaintiff. Woodhill Country Club. We are taking the deposition of Robert Searles. The deposition is being taken by telephone. I and Mr. Green, counsel for the defendants, are in Minneapolis. We are on telephone to Florida, I believe in Venice, Florida. Mr. Searles is appearing before a Florida court reporter in Florida, and has been sworn in by the court reporter in Florida. They are on a speaker phone in a conference room located in Venice. 1 believe it's Venice Florida, is that correct? SCLAFANI MILLIAHS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 I 1 I I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2J 22 23 24 25 A. Robert L. Searles, 535 Harrington Road, Wayzata, Minnesota. Q. Mr. Searles, do I understand that you are a former mayor of the City of Orono and former city council member of the City of Orono? A. That's right. Q. And that you have been involved over the years in the grain business in the twin cities, is that correct? A. That's correct. 0. And that you have been a member of tha Woodhill Country Club since shortly after World War II? A. That's correct. Q. And that you were an Orono resident for 32 years, approximately? A. Exactly right, yes. Q. Could you, for the Court, Just go back and first of all give me a brief background of your education and employment?. A. Well, I went to --1 was living in Leone, New Jersey growing up. I went to the Englewood School for Boys in Englewood, New jersey. 1 graduated in 1936. 1 went to Princeton University, graduated in 1940. And that completes my SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Grain Traders Association? A. That's right, yes. Q. Is that the line of - In terms of your business activities, did you stay in that line of business until retirement? A. That's t'’ue. yes. Q. And approximately when did you either retire or begin to scale back your business? A. Well. I began to -- you used the right term. 1 began to scale back when 1 was elected into the legislature in 1976. \nd I found that I couldn't fulfill both jobs at the same time, so 1 had to concentrate on being in the state capital. Q. Now, after World War li when you moved to Minnesota, where did you move to? A. I lived in a property that is half in Wayzata and half in Orono, known as Summit Park Farm, and we lived over the garage there. And we lived there off and on for about four years. Part of the time Cargill moved us to New York for a year and back again. In 1950, or in *51, we decided to build our own home, which we did in Orono, at 575 North Femdale. And we built a home there and lived there for 32 years. SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 2 3 4 5 6 7 8 9 10 11 ► * education, although I've tried to learn something in the meantime. Q. I take it you then - after 1940 -- A. I was in the Navy for five years. Q. Served in the Navy for five years? A. That's right. Q. And then after your service in the Navy during World War II, did you then move to Minnesota? A. I did. I got a job with Cargill and worked with them as a trainee, and went into 12 business - that's in 1946. I went into business 13 for myself in 1950. 14 Q. And what was the nature of your business? 15 A. 1 was a futures broker and trader on the 16 Minneapolis Grain- 17 Q. At the Minneapolis Grain Exchange? 18 A. - Exchange. That's right. 19 I was on that board, and I was president 20 of the exchange at one time. And on the National 21 Grain Trade Council, I was on that board and was 22 president of that, too. 23 Q. And so your business career centered 24 around the grain trade and your positions with both 25 the Minneapolis Grain Exchange and the National SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 2 3 4 5 6 7 8 9 10 11 12 13 Q. And I take it during that entire time you ■* were married? A. Thai's right, yes. Four children. Q. And during that same period of time, did you become a member of the Woodhill Country Club? A. Yes. This is a family thing. My wife’s family were members, so 1 just sort of backed in as the husband of a member. Q. So from the time you moved here after the war until today, you have remained an active member of the club? A. That’s right. Q. And sometime in the 1980s, I take it you 14 sold your home in Orono? 15 A. That's right, in 1983. And as we built 1 6 this - built another home in Wayzata and moved 17 into that in mid 1984, and we've lived there since 18 then. 19 Q. I would now like you to walk me through 20 your involvement with any groups, city government 21 in Orono, beginning with your first involvement, 22 which I believe you indicated prior to the ?3 deposition was a stint with the Orono Planning 24 Commission, is that correct? 25 A. That's true. Orono was incorporated in SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 I I I 1. L i: L 1 the mid'50s. I think it was '54. And at that 2 point I was asked to serve on the planning J commission, which I did for a number of years. ♦ And then in the mid '60s I ran for the 5 council and was a member of the council. And in 5 the early '70s I retired from the council, went 7 back on the planning commission for a couple of J years, and then ran for mayor. I was mayor from 7 '73 to '76. 0 In '76 I ran for the House of 1 Representatives, was elected, and was there for six 12 years. 13 Q. And that was the Mi.nnesota House of 14 Representatives? 15 A. That's correct. 16 Q. And wa.s Orono a portion of the district 17 that you represented? 18 A. Yes, 42B at that time. 19 Q. So you were on the - I take it back then 20 it was probably a village, the Village of Orono 21 Planning Commission in 1 950 or the early '50s? 22 A. No, it'd become -- when the planning 23 commission was set up, it was set up because of 24 incorporation. 25 Q. I sec. SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA 1941) 954-0020 1 Orono from 1 973 to 1 976? 2 A. That's right. 3 Q. And you stepped down after six years in 4 the legislature. That would be about 1982. is that 5 right? 5 A. That's right. I ser\'cd through 1982. and 7 at the end of'82 I stepped down. S Q. Have you held any other governmental 9 elected or appointed positions? 10 A. Yes. In the '60s, about 1967 the Lake 11 Minnetonka Conservation District was created by the 12 legislature. 13 I went on that representing Orono. and 14 Orono being the largest shoreline on 15 Lake Minnetonka. And 1 was on that board for !6 several years. I was chairmaii of it in the early 17 '70s for abou; three years. And that would be 18 relevant. 1 suppose, to anything you were 1 9 discussing here today. 20 COURT REPORTER: Excuse me. Counselor. 21 MR. Mc C arthy : Yes. 22 COURT REPORTER: Was there an objection to 23 that question? 24 MR. Mc C arthy : N o. 25 COURT REPORTER: Okay. 1 thought 1 had SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 And you served on that commission in the 2 '50s and '60s? 3 A. That's right. 4 Q. And then do you recall approximately when 5 it was that you were elected to the City Council of 6 Orono? 7 A. Oh, it's in the mid'60s. I'm sorry 1 8 don't have those records right here, but it's the 9 mid '60s. 10 Q. Then you indicated you served on the 11 council, and I take it you served several terms, at 12 least? 13 A. That's right. 14 Q. And then you, in the 1 970s, you retired 15 from the city council? 16 A. For two years. 1 we... back on the 17 planning commission. 1 elected to do this. Idid 18 it. and then I elected to run for mayor. 19 Q. So if you were mayor from '73 to '76, it 20 was about '71 when you stepped down from the city 21 council and went back on the planning commission? 22 A. Yeah. And I'm sorry about not having 23 those records with me here. 24 Q. That's no problem. 1 understand. 25 And then you were mayor of the City of SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 heard something, but I wasn ’t sure. Thank ! you. MR. Mc C arthy : AII right. Feel free to ask at any time. MR. GREENE: Let me just remind you of my ' voire here, so you can associate it with any potential objections. But I did not say anything. Can you hear me okay? ) COURT REPORTER: Yes, sir. I MR. GREENE: Okay. 12 BY MR. Mc C arthy : 13 Q. In connection with your being on the 1 4 planning commission and city council and being the 1 5 mayor from the mid '50s through 1976, were you, 1 6 during that period of time, familiar with the 1 7 zoning and building requirements in the Village of 18 or City of Orono? 19 A. Yes, relatively so. I was familiar with 20 them. 21 Q. And 1 take it that you participated in the 22 codification of the Orono zoning code which 23 occurred in 1967, is that correct? 24 A. That's correct. 25 Q. And you were familiar with the zoning SCLAFANI WILLIAMS COURT REPORTERS, INC. SARA.S0TA, FLORIDA (941) 954-0020 I I I f r r r r 1 requirements and zoning areas under the 1967 2 codification that came into effect in 1968? 3 A. Correct. 4 Q. I would now like to turn to some of the 5 exhibits. So if the Court Reporter would make 6 available for your review some of the exhibits, and 7 I'll ask several preliminary questions. 8 First of ail, during the period of time 9 that you were, say, from World War II through 1967, 10 during that period of time, did you become familiar 11 with the roads and geography around the City of 12 Orono? 13 A. Well, yes. 1 wouldn't say 1 knew every 14 one very well, but 1 became familiar with the City 15 of Orono, yes. 16 Q. And you became familiar enough in 17 connection with that to recognize the different 18 areas that were zoned in the '67, '68 codification? 19 A. Yes. As a matter of fact. I was a 20 participant in the selections of zones. 21 Q. In - 22 A. That doesn’t mean -- excuse me for adding. 23 That doesn't mean I have a specific, accurate 24 recognition of all the zone lines at this time. 25 Q. No. 1 understand there has been 30 some SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 years that have passed since then. 2 A. Exactly. 3 Q. But at that time you, 1 take it, were 4 involved in determining which districts to have and 5 the location of those districts? 6 A. Exactly. 7 Q. And during that time, were you also 8 familiar with Woodhill Country Club and its 9 property? 10 A. Yes, 1 was. 11 Q. And is that something that, as a member, 12 you used on a regular basis? 13 A. Fairly regular basis, yes. 14 Q. I would like to have you take a look at 15 Exhibit 142. It is an aerial photograph of a photo 16 taken in August 1945 by Markhurd >• that's one 17 word. M-a-r-k-h-u-r-d - aerial photographers. 18 MR. GREENE: This is Mr. Greene. Let me 19 just correct what may have just been simply a 20 misspeaking. 21 This is not a photograph of an aerial 22 photograph. It is a xerox copy of an aerial 23 photograph. Is that correct? 24 MR. Mc C arthy : That's correct. 25 COURT REPORTER: Counselor? SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 I 1 I I 1 MR. MCCARTHY: Yes. 2 COURT REPORTER: If you could refer us to 3 the tab number, that might help. Is it tab 1 ? 4 BY MR. Mc C arthy : 5 Q. Exhibit 142 appears at tab I •• 6 A. 1. 7 Q. - the materials sem down for 8 Mr. Searles' depo. 9 A. Yes. And 1 have the folder you sent me. 10 and 1 have identified it. 1 1 Q. All right. And I understand that because 12 it is a xerox and not a photograph, the quality of 13 the image is not as good as a photograph? 14 A. Exactly. 1 5 Q. Taking a look at Exhibit 142. can you 16 identify Orono Orchard Road on this photograph? 17 A. Oh, yes. Orono Orchard Road makes almost 18 a 90 degree turn right where Woodhill Avenue joins 19 it. 20 Q. So that we orient ourselves the same way, 21 is Orono Orchard Road on the right side of your - 22 as you are looking at the photo? 23 A. Well, it's on the left side as I'm looking 24 at it, because I'm holding the north - 25 Q. All right. So looking at Exhibit 142 with SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 Orono Orchard Road on the left side — 2 A. Right, that's -- 3 Q. - on the left would be west, is that 4 correct? 5 A. That’s right. And north is the upper end 6 here. 7 Q. North is the upper end? 8 A. Right. 9 Q. All right. And can you identify 1 0 Woodhill Avenue in this photograph? 1 1 A. Yes. it’s very clearly delineated in this 1 2 picture. 1 3 Q. And if you could just give a verbal 14 description. 15 A. Well, it's - it looks, from this 16 photograph, it looks paved and ~ 17 Well, it looks - 18 1 don't know if it's paved or not, but it 19 looks maintained. 20 Q. Is it in the center of the photograph on 21 the- 22 A. Yes, it's in the center of the photograph, 23 yes. 24 Q. And you had occasion, or did you have 25 occasion between 1946 and 1951 to travel Orono SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 I I I r [ I I I I I I I I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1$ 20 2J 22 23 24 25 Q. ~ that has a star next to it. and the title says, conditional non-conforming use permits. Do you see that? A. Uh-huh. I'm following you. Q. And it says, Searles moved, Franzel seconded, that the conditional use permits for non-conforming uses, administrative memo of September 5, 1968 as accepted, be approved. Do you see that? A. I do, I see that. Q. And that motion would have been your motion to approve the conditional use permit for Woodhill Country Club, is that - A. That's right, yes. Q. And you did, in fact, move in favor of it and voted in favor of it? A. That's right. Q. I would like you to turn to tab II, and that is Exhibit 148. A. All right. Here we are. I’ve got it. Q. This is a document that is the application and permit for Woodhill Country Club as a conditional use for a golf course. And it consists of four pages here with Bate's numbers 0R0126 through ORO130. Those are the stamped numbers on SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 n 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1 9 20 21 I 23 25 I Q. Now, could you take a look at the last page of this application? A. I'm looking at it. Q, It is a hand-drawn sheet with a Bate's number of 130, is that correct? A. Right. Q. And it has the date at the bottom of May 31, 1968? A. Exactly, yes. Q. And I would like for you to describe to me what you understood about this drawing as it relates to driveways and road access. MR. GREENE: I am going to object on the grounds of lack of foundation and ambiguity. I have no problem, if you want to ask the witness how he interprets this in 1999. But I don't think a foundation has been laid regarding what he remembers, if anything, of his interpretation of this back in 1968. So I would object to the form of the question and object on the grounds of lack of foundation. MR. Mc C arthy : you can go ahead and answer, Mr. Searles. A. All right. Although this is conceptual SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 2 3 4 5 6 7 8 9 10 11 12 13 the bottom of the page. A. Right. Q. And the application is dated May 31, 1968 - A. Uh-huh. Q. — is that correct? A. Yeah. I'm looking for the date. Q. On the front -- A. Yes, May 31, '68, correct. Q. On the third page of the exhibit, it is again dated in handwriting. May 31, 1968? A, Exactly, right. Q, And the fourth page of the exhibit, the 14 one that has page 129 on the bottom, is signed by 15 Tony Kallas? 16 A. Right. 17 Q. Was Mr. Kallas the manager of Woodhill 18 Country Club at the time? 19 A. Yes, that's correct. 20 Q. And you knew Mr. Kallas at the time? 21 A. Yes, 1 “ I've known all. yes. Q. And he would have been available to answer 23 any questions that you had regarding this 24 application? 25 A. Yes. that's true. SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 56 1 0 3 4 5 6 7 8 9 10 11 and not accurate, it does describe the access, showing a main entrance off 15, going up and circling the clubhouse and tennis court.*;, ard also, the road branching off and going out and attaching to Woodhill Avenue. And it appears to me that in drawing it, he put two distinct lines at the end of this as it goes off, which indicates that's where it goes into a city street. Q, Mr. Searles, in 1968, would it have been your practice to review the application for 12 Woodhill Country Club for a property of this size 13 in moving for a permit? 14 A. There was such a - at that time, there 15 was such a consistency of thought that the 16 continuance of Woodhill and what it has been doing 17 in decades before should be approved, that there 18 wasn't a lot of debate. There wasn't any debate 19 about it. There was general approval. MR. GREENE: Excuse me. Could the Court Reporter read back the question to which that response was posed? (The question was read by the Reporter.) MR. GREENE: I need to put an objection on the record that Mr. Searles' answer did not SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 20 21 22 23 24 25 I I I r \ I I I I I i t I 1 respond to the question as asked, so I was not 2 able to anticipate an objection. I move to 3 strike that answer as nonrcsponsive. 4 BY MR. Mc C arthy : 5 Q. Mr. Searles? 6 A. Do you want me to explain my answer? 7 Q. Mr. Searles, let me ask some questions 8 here. 9 A. Okay. Go ahead. 10 Q. The Woodhill Country Club in 1968 11 constituted a property in excess of 150 acres, is 12 that right? 13 A. Yes. 14 Q. And in moving for its conditional use 15 permit, would it have been your practice as a 16 council member to review its application? 17 A. Yes. And I believe it was reviewed in a 18 conceptual manner at that time. And this is my 19 recollection of it. 20 Q. And 1 want to ask you. as you looked at 21 this photograph •• not photograph. 2 As you looked at this hand-drawn portion 23 of the application in 1968, what was your 24 understanding then as to what the drawing of the 25 driveway off to the left of the page indicated? SCLAFANI WILLIAMS COURT REPORTERS, INC, SARASOTA, FLORIDA (941) 954-0020 1 conditional use permit for Woodhill Country Club to 2 function as golf course and country club, you then 3 continued to serve on the council until *71, and 4 then on the planning commission from 71 to 73, 5 and mayor from 73 to 76. is that right? 6 A. That’s correct. 7 Q. Did you. when you were on the council or 8 when you served as mayor or when you were on the 9 planning commission, ever suggest that Woodhill 10 Country Club needed an amendment to its conditional 11 use permit to either discontinue use of 12 Woodhill Avenue access or to open use of the road 13 to Woodhill Avenue access? 14 A. 1 have no recollection of the subject ever 15 having come up. 16 Q. Was it your - 17 In connection with the permits that you 18 moved approval of, did you understand that the 19 Woodhill Country Club would have to seek City 20 approval to either raise or lower a chain across 21 cither of its driveways? 22 MR. GREENE: Objection, calls for 23 speculation, lack of foundation. 24 A. No, there's no such - I have no 25 recollection of any such view by the City of Orono. SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 1 2 3 4 5 6 7 8 9 10 11 12 A. Well, it was just the driveway within the Woodhill property that attaches to Woodhill Avenue, and that was obvious to all of us. It wasn't even a subject of discussion. Q. When you moved to approve the permit for Woodhill Country Club, was it your intent to change in any way the access to Woodhill Avenue? MR. GREENE: Objection, lack of foundation, legislative intent. A. No, there was no intent to change the Woodhill Country Club, the use of its property or its accesses. And this is a specific memory. 13 BY MR. Mc C arthy : 14 Q. Can you describe for me, when you say the 15 word "Woodhill Country Club's access." as what you 16 mean? 17 A. Well, I mean the access to 15 and the 18 access to Woodhill Avenue. Those are the two 19 accesses. *20 Q. Would it be accurate to state that in the 21 permit that you moved approval of, there is no 22 limitation on Woodhill's use of - Woodhill Countiy 23 Club's use of Woodhill Avenue? 24 A. There were no limitations. 25 Q. Now, following the approval of the SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 BY MR. Mc C arthy : Q. Did the City of Orono ever tell Woodhill Countr>- Club, during the period that you were involved in the city government, that it had to use either one of the driveways a certain number of times per year or decade in order to continue to use the road? A. I don't have any recollection of such a communication. 1 •7mm 3 4 5 6 •7 / 8 9 10 Q. Did you ever tell that — 11 Are you aware of ever having told that to 12 any property owner in the City of Orono during your 13 years in city government? 14 A. 1 don't have any recollection of such an 15 action. 16 Q. After you left city government in the late 17 1970s- 18 In this lawsuit we have had various 19 witnesses and looked at various documents, which 1 20 think I could fairly summarize as some complaints 21 from Mr. Wagoner, who owned property next to 22 Woodhill, about use of Woodhill Avenue in the 1978 23 to 1980 time period. 24 And my question is: Were you personally 25 involved in any of those discussions? SCLAFANI WILLIAMS COURT REPORTERS, INC. SARASOTA, FLORIDA (941) 954-0020 I I I r 12. Notice of Hearing on Proposed Assessment to Woodhill Country Club, PID NO. 02-117-23-12-0001 I I I I I I I I I I I f I I I I I I I I >c> . iCITY‘S - ; “ ■ ' _______• • ’4 ; “OF '■ aRONOr CITYofORONO Post Office Box 66«CryiUl Bay. MinnesoU S5323 • Municipal Offices On the North Shore of Lake Minnetonka 02-117-23-12-0001 Woodhill Country Club 200 Woodhill Road Wayzata, MN 55391 Attention: Mr. Mark Albrecht NOTICE OF HEARING ON PROPOSED ASSESSMENT TO WHOM IT MAT CONCERN: •7 nn Notice is hereby given that the Council will meet at O" Monday, August 28, 1989, at the Council Chambers of the City of Orono, 1275 Brown Road South, to pass upon the assessment for the Woodhill Avenue Street Imoriveraent. Tne following is the area proposed to be assessed: Property abutting Woodhill Avenue and Lots 1 through 5 Woodhill Ridge in the north 1/2 of Section 2, Township 117, Range 23 West, Hennepin County, Minnesota. The amount to be specially assessed against your particular lot, piece, or parcel of land is $ 9,464.70 ^ You may at anytime prior to certification of the assessment to the county auoitor,^ pay the entire assessment of such property with interest the City of Orono. No interest shall O- cna.ged i^ v.he entire assessment is paid within 30 days from assessment. You may at any time thereafter, - . , City the entire amount of the assessment remaining unpaic, with interest accrued to December 31 of the year in which sucn paj^ent is made. Such payment must be made before November IP or interest will be charged through December 31 of the hofoi^afdecide not to prepay the assessment c-fore tne date given above the rate of interest that will apply IS 8 percent per year. The right to partially prepay‘the assessment is not available. JILDINC a ZONING - 473-7357 ASSESSING ADMINISTRATION A FINANCE - 473-7358 PUBLIC WORKS - 473-7359 I I I r r F r I I I I I I I I I I I I The proposed assessment roll is on file for public inspection at the City Clerk's office. The total amount of the proposed assessment is $49,814.19. Written and oral objections willbe considered at the meeting. No appeal may be taken as to the amount of an assessment unless a signed, written objection is filed with the clerk prior to the hearing or presented to the presiding officer at the hearing. The council may upon such notice consider any objection to the amount of a proposed individual assessment at an adjourned meeting upon such further notice to the affected property owners as it deems advisable. If an assessment is contested or there is an adjourned hearing, the following procedure will be followed: 1.The city will present its case first by calling witnesses who may testify by narrative or by examination, and by the introduction of exhibits. After each witness has testified, the contesting party will be allowed to ask questions. The procedure will be repeated with each witness until neither side has further Questions. 2.After the city has presented all its evidence, the objector may call witnesses or present such testimony as the objector desires. The same procedure for questioning of the city's witnesses will be followed with the objector's witnesses. j. 4. The objector may be represented by counsel. Minnesota rules of evidence will not be strictly applied; however, they may be considered and argued to the council as to the weight of items of evidence or testimony presented to the council. 3 . 6. The entire proceedings will be tape-recorded. At u•■he close of presentation of evidence, the objector may make a final presentation to the council based on the evidence and the law. No new evidence may be presented at this ooint. A.n owner may appeal an assessment to district court pursuant to Minnesota Statutes Section 429.081 by serving notice of the appeal upon the mayor or clerk of the city within 30 days after the adoption of the assessment and filing such notice with the district court within ten days afcer service upon the mayor or clerk. Under Minnesota Statutes, Sections 435.193 to 435.195, the council may, in its discretion, defer the payment of this special assessment for any homestead property owner by a person 65 years of age or older for whom it would be a hardship to make the payments. When deferement of the special assessment has been granted and is terminated for any reason provided in that law, all amounts come due. Any assessed property owner meeting the requirements of this law and the ordinance adopted under it may, within 30 days of the confirmation of the assessment, apply to the city clerk for the prescribed form for such deferral of payment of this special assessment on his property. /s/ Dorothy M. Hallin City Clerk 4 13. Orono City Council Resolution No. 2682, adopted August 28,1989 I I I I I I I I r r r i t f I I i I I I I I I I 81689.2 - ■ ■City of OROrVO RESOLUTION OF THE CITY COUNCIL NO. 2682 A RESOLUTION ADOPTING HOODHILL AVENUE ASSESSMENT ROLL WHEREAS, pursuant to proper notice duly given as required by law, the council has met and heard and passed upon all objections to the proposed assessment for the improvement of Woodhill Avenue, legally described as follows: property abutting Woodhill Avenue and Lots 1 through 5 Woodhill Ridge in the north 1/2 of Section 2, Township 117, Range 23 West, Hennepin County, Minnesota, NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF ORONO, MINNESOTA: 1. Such proposed assessment, a copy of which is attached hereto and made a part hei;;eto, is hereby accepted and shall constitute the special assessment against the lands named therein, and each tract of land therein included hereby found to be benefitted by the proposed improvement in the amount of the assessment levied against it. 2. Such assessment shall be payable in equal annual installments extending over a period of 5 years, the first of the installments to be payable on or before the first Monday in January, 1990 and shall bear interest at the rate of 8 per cent per annum from the date of the adoption of this assessment resolution. To the first installment shall be added interest on the entire assessment from the date of this resolution until December 31, 1990. To each subsequent installment when due shall be added interest for one year on all unpaid installments. 3. The owner, of any property so assessed may, at any time prior to certification of the assessment to the county auditor, pay the whole of the assessment on such property, with interest accrued to the date of payment, to the city treasurer, except that no interest shall be charged if the entire assessment is paid within 30 days from the adoption of this resolution; and he may, at any time thereafter, pay to the city treasurer the entire amount of the assessment remaining unpaid, with interest accrued to December 31, of the year in which such payment is made. Such payment must be made before November 15 or interest will be charged through December 31 of the next succeeding year. I I v ;- 0-7 c , CITY City of OROIVO ^ OF ORONO RESOLUTION OF THE CITY COUNCIL NO. 2682 4. The clerk shall forthwith transmit a certified duplicate of this assessment to the county auditor to be extended on the property tax lists of the county. Such assessments shall be collected and paid over the same manner as other municipal taxes. Adopted by the council this 28th day of August, 1989. ATTHS Tothy M<THaiiin, City Clerk I I I r r n r ^. <'' r. G3 \rn CN \ CD o r- z O <u M Cl4 M o ►H U CO I 3 > < Q OO 3: CO COuc: Q Q < CO 2 < <HO H CO E- < COucr: <a Q Ma TDI inm in in -S c•H -H V) (V *—Ias m CNm in in s in 0) f—HQ in N 'H >t ro fTi o iXJ N Om N >.rrt •§ - it ffi CD 4J A fA O *-M (V Z » I ly •H 3: V.J CTV iH §rH ru 12 o o. & % % §%Xr\r? 11 a u wj0) 1 1 U ij §(2 § % 9 CO •H -9 Mro (U &8 §u 0 t A C •H . T S rH o U il/J 2!v9 •rH o inc^ incr* 00 CMco­ incr* incr* GO CN<o- r-ooo 04 m CN rl o5ro > 8 (D § r- TT o vO VO O ‘O VO o VO vO O VO VO •-H O O O cr*ooo rsj iNro m CN ri ro CN I CNo I CNo M o VO VO o VO VO ooo •-H CN ro CN rl rH ICN O Or- "cr VO o vO n o HH CO wQ M o O o o CN <o ''W ••O VO vO CO GO m n rH rH C4 CN *—Hi-J < ooo m CN ri I CN O 1 •HU CN rH• CN % m CN I I I i r t r c 14. Woodhill Avenue’s Special Assessment Certification Roll, from Hennepin County Division of Property Tax L ru C I » I I I f HC 1210 (1-79) SPECIAL ASSESSMENT RATE CARD ADD CHANGE DELETE MUNICIPALITY Orono DOCUMENT # MUNIC CODE AUTH. BY DATE LEVY NUMBER 11553 PROJECT NUMBER LEVY DESCRIPTION Wpodhill Ave Street Imp TOTAL PROJECT ASSESSMENT $3.320.94 SERVICE CHARGE yes . . LUMPED/SPREAD CODE spread INTEREST RATE 8% COST PER UNIT NO. YE/\RS PAYABLE FIRST YEAR P.\YABLE —90 .*•‘.0. INT. FIRST YEAR 16 FIXED CHARGE PEPJ-'.. SPEC. CODE I CERTIPr' that THJS DOCUU6KfT IS A TRUE COPY OP THE ORIGINAL ON RLE IN THIS OFFICE, DIVISION M.ANAGER OF TAXPAYER SERVICES HENNEPiN COUNTY, MN QY_i^ il ' A - • .r DEPUTY I I 15. Memorandum of Orono City Administrator, from Mark Bernhardson to Orono City Council, dated October 6,1987 re Easement Agreement I j I I •'•r'H\r .*j ./N-. T r/ irw f4m? i: ■n| ««4 k'*». , * -1 ^ 4V1K'fii t ^ 73 •;J ••V ^ L’ '**' ' .N - . *v .* •'•r;.xr •-. -T»i '•# ♦ *1 ;/^i‘ •i *1V^ ^'s-.* T iyii ; «i ii •#t •) g'.y ' ■.il-*/- h ; .. ^ ■'- j ' - ■ ^ . ! rT/ •l^- "-*''••4.* i.r.: *'•••* 10787.4 # • •• • I * 4• ■•• » m 0 t • •• T •i*J -r Lni/.V^ TO: Mayor .„d city Council Hark B4fnhaidaon. city Adaiinl.tratojfvl^ OAW: October 6, 1987 SOWect; Woodhill/Lot 3 Access - ••ment A9rceaent Dated 10/S/87 S H:^‘^LV£‘£"^ira IHairS*—:«n:’ -:s. Ourino t\. r*ilro«5 tfrfk."^'® *®«hi’£v.v.7.'/;A\£“i I; Lot 3 would nood construction £lnnnf?<* negotiated between w^i^h^"?** access. This Iiti^.e*'**®*** '***^ woodhili Avenue. and McOovell anS would .cm%*,”oJ!J SiSCUSSIOM - As vou ... /r u*"^..*"** citt! tJ ’',•.•■•"*’ between ------- • » ir vnvir? RECOMMENOATIOM - ri 1. I . V*, ***''‘«*^«<*-Off .,V <^*terainin9 tht costl'i^^f * Partial aha^ri ”«pf'?h?”i™,;„ ""*? -' •««<«• '■ ■' th« th^ c ‘■'-^ I I nays 16. Easement Agreement between City of Orono, Woodhill Country Club, and MSM Associates, dated October 15,1987 I I I I I I I I i I I I I I I I I i easement agreement Ocfol'UA v'f’’ r THIS AGREEMENT is made as of ^ » 1987, by and between Woodhill Country Club, a Minnesota nonprofit corporation ("Woodhill"), and MSM Associates, a Minnesota general partnership ("MSM"), and the City of Orono, a municipal corporation under the laws of the State of Minnesota ("the City" ). RECITALS: A. By warranty deed of even date herewith Woodhill has conveyed to MSM Lot 3, Bloc)^ 1, Woodhill Ridge ( Lot 3 ). Woodhill has also deeded to MSM a non-exclusive driveway easement for the benefit of Lot 3 over certain property contiguous to Lot 3 and over the private driveway easement commonly )?nown as Woodhill Road. B. Woodhill Road provides access to County Road No. 15 after crossing the railroad right-of-way now owned by Da)cota Rail, Inc. (the "right-of-way"). C. Woodhill has no record title to an easement or other right to cross the right-of-way. However, Woodhill does own certain property lying between Woodhill Road and Woodhill Avenue, a public street, which property is legally described as the Southwest 1/4 of the Northeast 1/4 of Section 2, Township 117, Range 23, Hennepin County, Minnesota, and which property can be used to provide an alternative w’ay of access to public roads for the benefit of Lot 3. (The property described herein is hereinafter referred to as the "Easement Property".) D. Access to Woodhill Avenue from the Easement Prcoertv is oreser.tlv obstructed bv a barrier placed on Woodhill Avenue by or with the permission of the City. E. Woodhill is willing to grant MSM, for the benefit certain easement rights over the Easement Property, so as to orcvide Lot 3 access from Woodhill Road to Woodhill Avenue. —-t 3. XT A •Woodhill and the City are both willing to cause the removal of any obstruction located on Woodhill Avenue or on the Easement Property that prevents or impedes access to Woodhill Avenue from the Easement Property upon the closing or denial of Lot 3's right to use the access to County Road No. 15 over the right-of-way by the owner thereof. NOW, THEREFORE, in consideration of the foregoing premises and other good and valuable consideration, the receipt and sufficiency of which the parties hereby aclcnowledge, the parties hereby agree as follows: Woodhill hereby transfers and conveys to MSM for the benefit of, and as an appurtenance to. Lot 3 a driveway easement 24 feet in width over the Easement Property so as to provide Lot 3 access from Woodhill Road to Woodhill Avenue. Notwithstanding the foregoing grant of easement, MSM and the subsequent owners of Lot 3 agree nor to use the easement hereby granted unless and until access to County Road No. 15 over the right-of-way is closed or otherwise denied the owner of Lot 3 bv the owner of the right-of-way. 1:r• • n r 2. 24 foot wide driveway easement shall be at such location within the Easement Property as Woodhill may determine from time to time. At any time, and from time to time, Woodhill may record a declaration establishing or amending the location of the driveway easement over the Easement Property, and such declaration shall be binding upon Lot 3 and the owner thereof. 3. The easement shall be for the sole purpose of providing alternative access to a public street, namely, Woodhill Avenue, from Lot 3, and the use thereof shall be consistent with the use of a driveway by a single family residence property. Further, the use of the driveway easement shall be subject to such reasonable rules and regulations as Woodhill may impose from time to time. 4 All maintenance costs, snow removal expense and other costs associated with the driveway easement hereby contemplated shall be borne by Woodhill. In addition, im.T.ediately upon the closing or denial of Lot 3's right to use the access to County Road No. 15 over the right-of-way by the o*%ner thereof, Woodhill shall maintain and keep open an actual driveway located within the easement to at least the standard of tne driveway now connecting Woodhill Road and Woodhill Avenue. 5. Upon the closing or denial of Lot 3's right to use the access to County Road No. 15 over the right-of-way by the ow.ner thereof, the owner of Lot 3 shall notify the City, and the City shall, as soon as practicably possible, independently cetermine whether Lot 3’s access to County Road No. 15 over the ■ been closed or denied. The owner of Lot 3 and Woocnill shall promptly provide to the City copies of any documents relating to such closing or denial and such other in.ormation or proof as the City may reasonably require. If the City determines that Lot 3's right to use the access to County Road No. 15 over the right-of-way has been closed or denied by the owner thereof, the City shall consent to the removal of any oostruction located on Woodhill Avenue or on the Easement Property that prevents or impedes access to Woodhill Avenue from the Easement Property, and Woodhill and the City shall cause, at Woodhill’s sole expense, the removal of any such obstruction. 6. This Agreement and the rights hereby created shall e appurtenant to Lot 3 and the Easement Property, shall run with »- •-2- I title to said properties, and shall be binding upon and inure to the benefit of the successors and assigns of the parties hereto. Notwithstanding the foregoing, this Agreement shall terminate and no longer be binding upon the parties hereto at such time as (a) Woodhill or the owner of the right—of~way conveys to the owner of Lot 3, as an appurtenance to Lot 3, a legally enforceable, perpetual and non-exclusive easement to cross the right-of-way from Woodhill Road to County Road No. 15, or (b) the public acquires by eminent domain proceedings, or by voluntary conveyance in lieu thereof, such right of access to Co»inty Road No. 15, whichever first occurs. Upon such termination the owner of Lot 3 agrees to execute in recordable form a release of its rights in the Easement Property as created by this Agreement. 7. Each of the parties hereto and their respective successors and assigns shall have the right to enforce their rights hereunder by injunction or other equitable relief, it being understood and agreed that there is no adequate remedy at law for the breach hereof by any party hereto. No provision of this Agreement shall be construed to limit any right Woodhill may have to use Woodhill Avenue. IN AGREEMENT, the parties have executed this Easement Agreement as of the year and date first above written. WOODHILL XO'JNIRV CLUB MSK ASSOCIATES •Vly / V ' :\ f-S 1 Pawner OF ORONO .“.eviewed for Administration - ts -3- 4 1 t TATE OF MINNESOTA) I ) ss. UNTY OF HENNEPIN) foregoing was ac)«nowledged before me this E -Septemberr 1987, by Z—V AC^ffYlA^^_ _ _ _ _ _ _» _ _ _ _ _ _ _ _ _ _ _^of Woodhill Country Club, a nonprofit corporation nder the laUs"of Minnesota, on^Jiehalf^of the corporation.nder the law I I the day Public ... . . . . . . . . . . . . . . . . . ... JOHN B. WINSTON * r ATE OF MINNESOTA) ) ss. .<• N’ ^ -/Vt^ noiabv public . minneso’u i i ? HENNEPIN COUNTY { J Commitnon E>pitc» f eo. 23 1939 % ............................................................................. OUNTY OF HENNEPIN) ■ foregoing was acknowledged before me this day •f ^gp^ml^r, 1987, by t 7;:r/,„ /^, , a partner of MSM ssociates, a Minnesota general partnership, on behalf of the partnership I I Notary Public /P==^ CATHARINE BOSCHEI :tw’^ NOTARY PUBLIC-KIKNESOT A HENNEPIN COUNTY My Commission Eipnes Jan 19 1993 TATE OF MINNESOTA) I I I I I ) ss OUNTY OF HENNEPIN) Oc~obe’^^- foregoing was acknowledged before me this 5th day f Sepvet?beT, 19 67 by_ _ _ _James R. Grabek_ _ _ _ _ _ _ and by and they.ark E. Berr.harcscr.the Mevor Cl tv Administrator_ _ _. respectively, of the City of Orono, a ur.icipal corporation under the laws of Minnesota, on behalf of he municipal corporation. DOROTHY M. HALLIN MOTARV RueUC t^niEBOTA HENNEPIN COUNTY '{^1 Cl \9 D1 • r*/Notary Pub^c ' U HIS INSTRUMENT WAS DRAFTED BY; Lindquist A Vennum (JBW) |200 IDS Center 'Minneapolis, MN 55402 I I -4- 1 I I I I I I I 18. Zoning Map i Official Zoning Map City of Orono, Minnes R*1A On# Fjm«ly Residential Ostrct 1 Acre R*10 One Family Residential Oistricl 1/2 Acre LR*1A One Family Lakeshore Residential Oisfric- LR*1B One Family Lakesho^e Res*dential Oiftric I I I r r r r r n r: I i: I t L* i: i c 19. Survey of Woodhill Avenue / Woodhill Country Club access, dated August 31,1998 1 amo AHiNnoo tiihooom 1IBIHX3 SN0UI0N03 0NUSIX3 ll in Bi! i matwi zUl s fiu I i*r| Vw X ' /• y • / / / , - y ,' 3 .♦Z.COoOO N 1 ' • ' • 9«ZB^ 3 s VIfc*ozwo M’. r -N LtkOXL 1 20. 1945 Aerial Photograph r -1 'V m |V ,i iK/i: '.oV-^Av''. 1V III • "k '-v mk"M rps h \-^ ‘y\ llV '.ii ^1 m s >I't>v»v.^a,->-T\ ^ i V.'* ,.U I^ --s' .^J'>- -sA-• Tv-^ • > * r V *!t" ‘V' V-- ^t .ila *v; l< * i\ rk:^ ' ^ *% -r. vf ^ «i ;a ^-c ^ !*- ■ - -r* • > V «r.> i' it •' I I I r r r Fj r fj c 21. 1951 Aerial Photograph t f i if^<C IE >^ JD i#P >rwm YnWt,fiAir.TTLi o> 1 2 J* •5>' ,V : \ w ( ' ^^T5*c> ; . V ^ iW<i W --: V r>ib-'%^s EII. 1^ w-r^^ ■'■'.« sSni\ \ y^ ''^ • -. “• E^ - ‘-jiJ^ '--V • I tVC=' ■• v-4 •,. m > < IS iirv^- i.V-' N V -fl l;;,i... » . . 'r:j^,ry^ I-...Av r'\:£^ji' •C';wrALI«3|M5^r2 • - »• L%rt 1:. VJM .lSSiS»?5i.v J ;1 SW li 2TI r 'AV' \ f'r* rr k. r-1^ i Ws W^4 mmm%> I I I I I I I I I I I I I I I I I I I 22. 1962 Aerial Photograph J^t^: ■■' fe ■ ••' F' ", -i¥?l -- pi^' t ' j -' 'i . • VvS SI '-J A?' “ '.-ii he j.lit i> V fij v'i>* . y-.:"! ^ ^ ■'m '■'» i-i«4; fj.tT ''^'^*^1^''^ ' \ Rvv ''/ ■ ■ -jK/' . >T-^ VA. '• V. .yr. * .'■“ rn*.^>.v. 'W’ *-... • l 23. 1989 Aerial Photograph 'fi mm \. -' m i * v r I4f>.% •* * **'.*4 ^ry • ■ • ^v. 'i - -> -jj c-:>>a ^ . ^ , 'V, .'V'S! r //< - 'v>i> > QVv-^< ' \ ''. 11' K- »r^>. .,v - '^KiBlI . :-‘ i. '. >•• • “ J-%M m‘Mmic. \v 1S-SJ B1 ■^ V/ w^. ■h J^.v i .*•5^ f p wm »•% f %'i Vp^jjL^^y /; *i.. y. 19^m Fv'”' '^1-7 ^VS'^'i s^yp^Sv^s Nk- av ' ‘t ■V»‘ -‘••1- ■" ^-'t' ISLi. {.7 ~ '■m J * i ^ ^ J f6^ }•( • .-w, £S6^#;1 24. Comparison of Woodhill Avenue and Woodhill Road: Roadway surfaces, users, and trips per day [ "Wlkr --rm REQUEST FOR COUNCIL ACTION Date: May 11,1999 Item No: 3 Department Approval:Administrator Reviewed:Agenda Section: Name: Title: Gary Cheswick Chief of Police Item Description: Surplus Property Exhibits:None DISCUSSION As a result of three new squads being put into service, three old cars are available to be sold. The vehicles to be sold are: #170 1993 Ford Crown Victoria, 4-door, 111,000 miles, approx, value $1500 #175 1996 Ford Crown Victoria, 4-door, 117,000 miles, approx, value $4000 #176 1996 Ford Crown Victoria. 4-door, 119,000 miles, approx, value $4(III! COUNCIL ACTION REQUESTED Request permission to dispose of old squad cars. REQUEST FOR COUNCIL ACTION DATE: May 11, 1999 ITEM NO.: 3 Department Approval: Name Gregory A. Gappa Report Title Director of Public Services Administrator Reviewed:Agenda Section: Administrator's Item Description: Sale of Water Pressure Tank The City of Monticello has submitted an offer to purchase the second water pressure tank from the Highway 12 water plant for $4,000. The plant was constructed before the new water tower and used an air compressor and two pressure tanks to pressurize the system. With the construction of the water tower, the pressure tank system is no longer needed. Also, the water system interconnection with the City of Long Lake may be used to pressurize the system if water tower repair or maintenance is necessary. Hie City of Medina purchased the first tank several years ago, and the air compressor has been moved to the Navarre water plant for operation of the new automatic air control valves. The first tank was purchased by the City of Medina several years ago for $4,000. The City code requires that the Council declare the tank surplus property and that an advertisement for bids be placed in the official newspaper. An ad for bids was placed and only one bid, from the City of Medina was received. We are recommending that the Council decL.. w.-icr pressure tank, from the Highway 12 plant, water plant surplus property and authorize advertising for bids for sale of the tank. COUNCIL ACTION REQUESTED: Motion to declare the water pressure tank, from the Highway 12 water plant, surplus property and authorize advertising for bids for sale of the tank. I REQUEST FOR COUNCIL ACTION DATE: May 11, 1999 ITEM NO.; 3 Department Approval: Name Gregory A. Gappa Report Title Director of Public Services Administrator Reviewed:Agenda Section: Administrator's Item Description: Sale of Water Pressure Tank The City of Monticello has submitted an offer to purchase the second water pressure tank from the Highway 12 water plant for $4,000. The plant was constructed before the new water tower and used an air compressor and two pressure tanks to pressurize the system. With the construction of the water tower, the pressure tank system is no longer needed. Also, the water system interconnection with the City of Long Lake may be used to pressurize the system if water tower repair or maintenance is necessary. The City of Medina purchased the flrst tank several years ago, and the air compressor has been moved to the Navarre water plant for operation of the new automatic air control valves. The first tank was purchased by the City of Medina several years ago for $4,000. The City code requires that the Council declare the tank surplus property and that an advertisement for bids be placed in the official newspaper. An ad for bids was placed and only one bid, from the City of Medina was received. We are recommending that the Council declare the water pressure tank, from the Highway 12 plant, water plant surplus property and authorize advertising for bids for sale of the tank. COUNCIL ACTION REQUESTED: Motion to declare the water pressure tank, from the Highway 12 water plant, surplus property and authorize advertising for bids for sale of the tank. REQUEST FOR COUNCIL ACTION Date: May 11,1999 Item No: 3 Department Approval:Administrator Reviewed:Agenda Section: Name: Title: Gary Cheswick Chief of Police Item Description: Surplus Property Exhibits:None DISCUSSION As a result of three new squads being put into service, three old cars are available to be sold. The vehicles to be sold are: #170 1993 Ford Crown Victoria, 4-door, 111,000 miles, approx, value $1500 #175 1996 Ford Crown Victoria, 4-door, 117,000 miles, approx, value $4000 #176 1996 Ford Crown Victoria. 4-door, 119,000 miles, approx, value $4000 COUNCIL ACTION REQUESTED Request permission to dispose of old squad cars. i t *r S