HomeMy WebLinkAbout3rd Draft AppealMay 20, 2021
ITEM NO. 2 Z-9500-A
1
File No.: Z-9500-A
Owner: Gary S. & Andrea R. Goodwin
Applicant: Andrew V. Francis, PA; Barber Law Firm, PLLC
Address: 3708 Garrison Road
Legal Description: On file
Zoned: R-2 (Single-Family District)
Variance(s) Requested: An appeal of the City's denial of a Business License for Home
Occupation Accessory Use.
Justification: The applicant’s justification is presented in attached letter
dated March 16, 2021.
STAFF REPORT
A. Planning and Development Civil Engineering:
No Comments.
B. Landscape and Buffers:
No Comments.
C. Building Codes:
No Comments.
D. Staff Analysis:
Rezoning Application and Appeal -
3708 Garrison Road, aka Goodwin Manor, lies within the City of Little Rock extra-
territorial jurisdiction (ETJ), outside the City limit, and is zoned R-2 Single-Family
district. The property has been the residence of the Goodwin family for
approximately 25 years. The Goodwins advertise and rent/lease the property (indoor
and outdoor portions of the residence and grounds) for weddings, charitable
functions, and similar events.
Initiated via complaint by a nearby resident, in October 2019 the City issued a Zoning
Violation Notice, stating operation of an event center is not allowed in the R-2 zoning
district. The owners subsequently communicated extensively with City staff in hopes
of resolving the violation. While the owners objected to a “commercial” designation,
staff then knew, and presently knows, of no alternative to commercial usage,
because Goodwin Manor operations includes the following:
- Advertising in a variety of publications and host sites, including own
website.
- Advertised rental of the venue.
- Stock in trade including advertised round tables, rectangle tables, chairs
and linens. (On-site or off-site source, type and quantity of equipment is
presently unknown.)
May 20, 2021
ITEM NO. 2 Z-9500-A
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- Musicians, bands and/or DJs for ceremonies, receptions, and parties.
- Food service personnel including caterers, servers and bussers.
- Other vendors including photographers, florists, bridal consultants, etc.
- Associated assembly, breakdown, equipment and facility maintenance
personnel.
- Equipment haulers, trash disposal, etc.
- Security provided on-site.
- Associated vehicles and parking.
In April 2020 the applicant filed an application to Little Rock Planning Commission
for rezoning of the property from R-2 to Planned Commercial Development (PCD).
Approval of PCD zoning would allow “events” or “events center” as an accessory
use at the Goodwin residence. However, the request was denied by the Planning
Commission by a vote of 4 ayes, 5 nays and 2 absent.
The applicant then filed an appeal of the Planning Commission denial of rezoning to
the Little Rock Board of Directors. In December 2020, the Board denied said appeal
by a vote of 4 ayes, 3 nays, 2 absent and 1 present (6 “aye” votes are required for
approval.)
Later in December 2020, the Goodwins filed an appeal of the Board of Directors
denial of rezoning with the Pulaski County Circuit Court. That appeal is pending
hearing by said Court and is not relevant to this Business License application appeal
to the Board of Adjustment.
Business License Application Denial and Appeal –
Following denial of rezoning by the Planning Commission and Board of Directors, in
March 2021 the applicant applied for a business license as a “Home Occupation
Accessory Use.” Per Section 36-253(b)(6)(d), Planning and Development
Department is the authorizing agency for granting or denying and accessory use
permit, and the permit application was denied by Planning and Development
Department on the following grounds (additional staff comments in italics.)
Sec. 36-253(b)(6)a. Home occupations shall be permitted that will not:
2. Generate traffic, parking, sewage or water use in excess of what is normal
in the residential neighborhood.
Event activity at 3708 Garrison Road has proven to generate excessive traffic
in the neighborhood, and sewage and water usage will inevitably exceed
normal residential neighborhood use during events. As evidenced in
numerous statements from the property owner, the property will
accommodate 200 guests; site plans submitted by the applicant portray
delineated parking for approximately 80 vehicles.
3. Create a hazard to persons or property, result in electric interference or
become a nuisance.
Numerous complaints from adjacent and nearby residents indicate events
and/or directly associated activities are perceived as a nuisance.
May 20, 2021
ITEM NO. 2 Z-9500-A
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7. Limited to five hundred (500) square feet in area, but in no case more than
forty-nine (49) percent of the floor area in a dwelling.
Although floor area square footage used for events has not been plainly
disclosed by the applicant, event activities are virtually certain to occupy more
than the 500 square feet maximum allowable by Code. For example, the
owners’ February 3, 2020 letter to staff states, “Five or fewer rooms of our
home are utilized…” In order for the allowable 500 square-foot area to be
adhered to, these five rooms would have to average 10’ x 10’ each – which,
separately or in total, would not accommodate 200 guests and/or 80+
automobiles expressed by the owners. In addition, space for
office/administration of the operation, dressing rooms for bride, groom,
wedding party and family, equipment and material storage, food preparation,
etc. is likely to occupy more than the 500 square feet allowed by Code (500
s.f. = less than 23’ x 23’.) Also, the Goodwins’ September 4, 2020 letter to
neighbors states, “No additional permanent structures are allowed other than
the single [40’ x 80’] proposed outbuilding shown on the site plan…” Said
3,200 s.f. outbuilding itself would be greater than eight times the square
footage allowed by Code for a Home Occupation Accessory Use. Finally, the
March 2, 2021 Application for Business License submitted by the owner
states, “Floor Area Used: Typically, no more than 3 rooms of the home,
totaling less than 25% of the floor area of the home.” …25% of the Goodwin
Manor floor area is roughly 3,500 square feet of the 14,102 total square-foot
structure, and is therefore not supportable as a Home Occupation Accessory
Use.
Note: the above criteria in Sec. 36-253(b)(6)a. must be met in order for City staff to
grant a business license.
In a March 16, 2021 cover letter accompanying this [subject] appeal of the Planning
and Development Department denial of the Home Occupation Accessory Use
business license, the applicant states:
“The Goodwins believe that due to the factors listed above, including but not
limited to the remote location of their property, the enormous size of the
property, the rural nature of the Ferndale neighborhood, the fact that the City
has stated the property is in the ETJ, and other factors support granting the
Goodwins’ Applications for a Business License and Home Occupation
Accessory Use.”
Staff hereby responds as follows:
In accordance with the City Code, “remoteness” is not a factor for
consideration in the context of Sec. 36-253, and while the subject site is
relatively far from other more urbanized neighborhoods, the site is not
remote relative to adjacent and nearby affected neighbors.
May 20, 2021
ITEM NO. 2 Z-9500-A
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The “rural nature” of the neighborhood is not a factor in the context of Sec.
36-253, although it may be argued its rural nature is precisely why a business
permit to operate an event center in this neighborhood is inappropriate.
The “enormous size” of the property is not a factor for consideration within
the context of Sec. 36-253, although staff notes the subject development and
parking area lies within 100 feet of the property boundary, near to adjacent
properties to the east.
As stated in the applicant’s letter, the property lies within the Extraterritorial
Jurisdiction (ETJ,) over which the City of Little exercises land use and zoning
regulation authority, pursuant to Ordinance No. 15,814 (establishing zoning
districts within three miles of the corporate limits of Little Rock) and
Resolution No. 8,170 (whereas the City has authority to zone property, and
have orderly and compatible growth within 3 miles of the City Limits.)
Additional Notes (staff responses in italics) -
Commercial Use
The October 16, 2001 Declaration of Covenants and Restrictions recorded by the
Goodwins with the subdivision of Goodwin Estates states, “No business or
commercial use shall be carried on or permitted in any structure or in any portion of
this addition. This includes but is not limited to, the leasing of any portion of any
structure on the Property. In addition, no noxious or offensive trade or activity shall
be carried on upon any Lot, nor shall anything be done thereon which may be or
become a nuisance to the neighborhood.”
The Goodwins’ September 4, 2020 letter to neighbors states, “We certainly don’t
agree with any designation of our home as commercial. We have tried to seek an
alternate approval for a home occupation permit or a variance which would not
require rezoning, but the City has insisted this rezoning is the only way to obtain their
approval” … “However, it seems there is no other wording the City can come up with
to allow us to share our home and grounds with others.”
The April 2, 2020 PZD application submitted by the owners states, “Desired Use of
Property: Single Family Residence and part time wedding/event rental.” As
evidenced by the content of this report and based upon ample information and
applications submitted by the owners, Goodwin Manor operates, and proposes to
operate, as a commercial use and business.
Frequency of Events
The Goodwins’ February 3, 2020 cover letter states, “…we allow a limited number
of weddings to be hosted at our home, usually no more than 15-20 times a year.”
The Goodwins’ March 2, 2021 Application for Business License states, “Number of
events: Not to exceed twenty-four (24) events per year, so events will occur a
maximum of 24 days out of a 365 day year.”
May 20, 2021
ITEM NO. 2 Z-9500-A
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The “Facts” portion of the applicant’s March 16, 2021 cover letter states, “For the
past several years, the Goodwins have occasionally used a small portion of their
property to host charitable events and weddings, averaging two per month with the
total number of events having never exceeded more than 27 events in a single year.
Based on the above statements, allowing one day for set-up, one day for event run-
throughs and rehearsal dinners, one day for an event itself, and one day to break-
down, event related activities will occur at Goodwin Manor between 60 and 108 days
per year.
ADA Compliance
A March 13, 2020 email from the owner to staff states, “…for the life of me have no
idea how we will get past the commercial event center and make our mountain top
ADA accessible.” The owners’ September 4, 2020 letter to neighbors states, “ADA
standards for parking, access and restrooms will be followed.”
Federal ADA Guidelines would not be necessary if the subject property were not an
event facility or other such business open for consumer or related use (customers
and guests of customers.).
Relative Location
The Goodwins’ February 3, 2020 cover letter states, “The tract which Goodwin
Manor sits on, is in the middle of the 80 total acres, which is owned by our family.”
Per the attached site plan, it is apparent the parking lot is generally adjacent to
(within 100 feet of) off-site properties to the east.
Access
Access to Goodwin manor is via an existing 1,600-foot drive from Garrison Road to
the north, and via a 1,100-foot drive to the south.
These drives are not constructed to public street standards and are suited to low-
volume private residential use, shared by area residents. While the Goodwins have
stated they will widen, pave and illuminate these roadways “if their application is
approved,” doing so would impact area residents by creating a formal thoroughfare
for approaching and departing Goodwin Manor attendees. Prospective off-site street
lighting (for what is essentially a private drive) would be out of character with the
surrounding neighborhood.
The Board of Adjustment is asked to determine if Staff’s denial of a Business License
application for Home Occupation Accessory Use is appropriate pursuant to Section
36-253(b)(6)a of the Little Rock Code of Ordinances.