HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 04/11/2006 - PROPOSED AMENDMENTS TO THE APPEALS PROCESS CONTAIN DATE: April 11, 2006 WORK SESSION ITEM
STAFF: Steve Roy FORT COLLINS CITY COUNCIL
Greg Byrne
SUBJECT FOR DISCUSSION
Proposed Amendments to the Appeals Process Contained in Chapter 2 of the City Code.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
Should the following proposed amendments to the appeals process contained in Chapter 2 ofthe City
Code be presented for Council's consideration?
BACKGROUND
The City Council is frequently called upon to hear appeals from certain City board and commissions
and other"decision makers"under Chapter 2,Article II,Division 3 of the City Code. Most of these
appeals are from site-specific land use decisions made by the Planning and Zoning Board or a
hearing officer under the City's Land Use Code. However, there are several other boards and
commissions of the City that are called upon to make"quasi-judicial"decisions,and those decisions
are appealable to the Council as well under the provisions of Chapter 2 of the Code. (A "quasi-
judicial" decision is one that is made after notice to parties directly affected by the decision at a
hearing at which those parties are given an opportunity to be heard, and the decision entails the
application of criteria established in the Code to particular fact situations.) In addition, certain
decisions of City service area directors are appealable to the Council,though they are not specifically
referenced in Chapter 2.
The procedure for hearing these appeals has been in the Code since February 1982. Periodically,this
appeal process has been refined through various City Code amendments. City staff believes that it
would be beneficial for the Council to again consider possible changes to the appeal process for the
following reasons.
• Each appeal consumes a significant amount of staff time and Council time in preparing for
and conducting the hearing. Thus, there is some "lost opportunity cost" to be considered
since the time devoted to appeals could be devoted to other City business. Therefore, staff
suggests reviewing the appeal process to ensure that it operates as efficiently as possible.
• There is also a direct monetary cost to be considered. The fee for filing an appeal is fixed
by the Code at $100. As discussed below, staff estimates that the actual costs incurred in
processing appeals far exceeds that amount.
• There are a number of procedural issues that have surfaced during recent appeals that may
warrant amendments to the prescribed rescribed in the Code.
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April 11, 2006 Page 2
These issues are discussed in more detail below.
Deming "evidence."
Because the Code states that Council's decision on an appeal is to be based on the record of the
proceedings before the original decision maker,the Code generally prohibits the introduction of new
evidence at appeal hearings. The term"new evidence"is defined in the Code but "evidence"is not.
Staff recommendation: Add a definition of"evidence" to the Code so that parties addressing the
Council will have a better understanding of the difference between evidence and argument.
Clarifying the definition of"new evidence."
Recently, questions have arisen at appeal hearings as to whether information that was presented to
the original decision maker in one form constitutes "new evidence" when it is offered for Council's
consideration at the appeal hearing in a different form. For example, parties in interest may put
together a power point presentation that contains verbatim excerpts of the transcript for the purpose
of emphasis. Or, something that was described orally in the transcript may be offered in the form
of a map or drawing at the hearing. Considerable time can be consumed at the hearing debating
whether these kinds of exhibits are admissible.
Staff recommendation: Amend the Code to make it clear that the same information in a different
form is not "new evidence."
Eliminating the filing of written statements prior to appeal hearings.
The Code presently states that parties in interest who wish to provide written materials to the Council
regarding the appeal may do so by filing the materials with the City Clerk's Office no later than the
Wednesday prior to the hearing on the appeal.The reason this provision was added to the Code was
to give Councilmembers an opportunity to review any written materials that parties in interest
wanted to submit prior to the hearing. However, this provision has proved to be problematic for a
couple of reasons. First, some parties in interest file written statements and others do not, and this
can result in parties "soliciting" invitations from Councilmembers at the hearing to offer additional
information that missed the Wednesday deadline. Second, the written materials often contain new
evidence. When that occurs, staff needs to decide whether to: (a) send the materials on to Council
with advice to disregard the new evidence, (b) delete the new evidence from the materials before
sending them to Council,or(c) ask the parties submitting the materials to modify them before they
are sent to the Council.
Staff recommendation: Repeal the provision in question.
Clarifying the scope of review on appeal.
The Code presently states that the Council is to consider an appeal based upon the record on appeal,
the relevant provisions of the Code and Charter,the grounds for appeal cited in the notice of appeal
and any additional issues identified by a member of the Council prior to the hearing. Any such
additional issues must be identified in writing and filed with the City Clerk no later than seven
April 11, 2006 Page 3
calendar days prior to the date of the hearing. This second provision was added to the Code to give
parties in interest an opportunity to prepare for all issues that might come up at the appeal hearing,
including those that Councilmembers might raise. As a practical matter,however,Councilmembers
have little opportunity to review the materials related to an appeal more than a week prior to the
appeal hearing. Thus, it isn't until the hearing itself that Councilmembers really have a chance to
identify issues that may not have been included in the notice of appeal. Consequently, questions
have arisen at recent hearings as to whether the Council can go beyond the grounds stated in the
notice of appeal and address other issues that may have come to light at the hearing, even though
they have not filed notice of their intent to do so prior to the hearing.
Because the underlying purpose of the decision-making process is to thoroughly review, in its
entirety,the land use proposal or other matter under consideration,staffbelieves the current wording
of the Code is too limiting and that, on appeal, the Council should be permitted to explore issues
that may not have been raised by the appellant but that are,nonetheless, important to address. Staff
also believes that, by the time the matter comes to Council on appeal, the parties in interest are
familiar enough with the decision at hand to be able to address whatever issues Council believes are
relevant.
Staff recommendation: Amend the Code to clarify that Council has the latitude to address any and
all issues related to the decision that are relevant under the applicable criteria.
Clarifying Council direction on remands.
The Code allows Council to remand a matter to the original decision maker under either of two
circumstances: (a) if the appellant was denied a fair hearing, and (b) in order for the board,
commission or other decision maker to receive and consider additional information with regard to
any issue raised on appeal. When the Council remands a matter in order that a particular issue be
further considered, it generally tries to clarify the scope of the remand,in other words,the extent to
which the initial decision is open for re-consideration. However,clarifying the scope of the remand
is not presently required by the Code.
Staff recommendation: Language should be added to the Code to ensure that a remand for additional
consideration by the original decision maker is accompanied by direction regarding the scope of the
remand.
Addressing ex parte contacts.
Much attention is paid to preserving Council's impartiality in hearing appeals. Frequently, parties
in interest and other members of the public attempt to contact Councilmembers in advance of an
appeal in order to present their positions regarding the appeal. The rules of law pertaining to quasi-
judicial decision making discourage such contacts for two reasons. First,the Council's decision must
be based on the evidence at the appeal hearing, including the record of the proceedings before the
original decision maker and the presentations at the hearing. This limitation is necessary in order
to ensure that all affected parties know the information that Council will use to make its decision and
have an opportunity to speak to that information. Second, the parties in interest are entitled to an
impartial decision maker, and if Councilmembers engage in"ex parte" contacts before the hearing,
they risk losing that impartiality.
April 11, 2006 Page 4
Parties interested in an appeal are often surprised to learn that Council must abide by these kinds of
rules when it make a quasi-judicial decision. The expect to be able to contact their Council
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representatives and present their views ahead of time,just as they are permitted to do when Council
acts in a legislative,policy-making capacity. Staff believes that it might be helpful to add language
to the Code explaining the problems presented by ex parte contacts prior to an appeal hearing and
discouraging such contacts, so that this rule of procedure will be less of a surprise to the public and
easier for Councilmembers to explain to their constituents.
Staff recommendation: Add some general language to the Code discouraging ex parte contacts and
explaining why they should be avoided.
Modifying the role of members of the general public in the filing and hearing of appeals.
The Code defines the parties who are eligible to file an appeal and participate in the appeal hearing
as "parties in interest." Those who qualify as parties in interest are the following:
(1) The applicant;
(2) Any party holding a proprietary or possessory interest in the real or personal property
which was the subject of the decision of the board, commission or other decision
maker whose action is to be appealed;
(3) Any person to whom or organization to which the City mailed notice of the hearing
of the board, commission or other decision maker;
(4) Any person who or organization which sent written comments to the board,
commission or other decision maker prior to the action which is to be appealed;
(5) Any person who appeared before the board, commission or other decision maker at
the hearing on the action which is to be appealed;
(6) The City Council as represented by the request of a single member of the City
Council.
Staff questions whether members of the general public who appeared at the initial hearing or who
sent written comments to the decision maker should be eligible to file an appeal and participate in
the appeal hearing. As noted above, quasi-judicial hearings are designed to afford due process of
to those persons who are directly affected by the decision. In the case of land use decisions,those
parties are the applicant,the owner of the real property that is the subject of the decision, and those
persons or entities that own real property in close proximity to the site of the proposed development.
Clearly, the public has a role in site-specific land use decisions. However, there are two
opportunities for members of the public to provide input on such decisions: (a) when the Council
establishes the Land Use Code standards to be used in making those decisions, it does so by
ordinance, so there are two opportunities during that legislative process for public input (first and
second readings of the ordinance);(b)when the Planning and Zoning Board or other decision maker
applies the criteria to particular facts such as a project development plan application,the public has
April 11, 2006 Page 5
the opportunity to comment on the decision. The question,then,is whether the public should be able
to not only participate in the initial decision but also to appeal that decision.
A recent lawsuit challenging Council's approval of the Cherry Street Station PDP points out the
potential legal implications of allowing members of the general public to file such appeals and to be
included among the parties in interest who may speak at appeal hearings. hi that case, a resident of
the City who owns property eight blocks away from a proposed residential building has challenged
the Council's approval of the building in court. The City has filed a motion to dismiss on the
grounds that the plaintiff lacks standing to file such an action. The plaintiff has responded by
claiming that his standing to file the court action is based, in part, on his status as a party in interest
in the appeal hearing. The court has not yet ruled on the issue.
In 2005,the City received 138 applications for project development plans. Staff believes the ability
to challenge the City's decisions on those applications should be limited to those who are most
directly affected by them,not only because of the expense and time involved in hearing such appeals
but also because the filing of an appeal essentially puts development applications"on hold"pending
the outcome of the appeal which, in turn, can result in considerable expense to the applicant.
Staff recommendation: Limit the filing of an appeal and participation in an appeal hearing to the
applicant, those who have a legal interest in the property that is the subject of the application and
those directly affected members of the general public who received mailed notice of the hearing from
the City.
Considering whether Councilmembers who file an appeal should participate in hearing the
appeal.
This issue arises when one or more Councilmembers file an appeal. The question is whether a
Councilmember who files an appeal can, as a general rule, be unbiased in hearing the appeal. To
date,this question has been addressed on a case-by-case basis. Staff recommends that the Code be
amended to address the question so that Council's position on a subject will be clearly established
prior to the filing of an appeal by a Councilmember.
Staff recommendation: The issues should be addressed in the Code.
Considering whether the appeal fee should be increased.
The Leadership Planning Team has suggested that Council consider increasing the fee charged by
the City for filing an appeal to cover more of the costs incurred by staff in processing appeals. At
present, the fee is set by Code at $100. Staff estimates that the average cost of preparing for an
appeal is approximately$1,650. This includes preparing the record of the proceedings before the
original decision maker,including a verbatim hearing transcript,reviewing the record in light of the
notice of appeal, preparing the management and legal memoranda related to the appeal, preparing
the agenda materials, organizing information,maps and attachments for Council packet, preparing
April 11, 2006 Page 6
Power Point presentation,preparing for questions,copying,folding and mailing of notice to affected
property owners, conducting the appeal hearing, and preparing the resolution finalizing the appeal.
Staff recommendation: The amount of the fee should be increased so as to more closely approximate
actual costs.
ATTACHMENTS
1. Powerpoint presentation slides
2. Current Appeals Procedure from Division 3, City Code
AT7ACHMENT1
PROPOSED AMENDMENTS TO
THE CITY'S APPEAL PROCESS
Presented by:
Steve Roy, City Attorney
Greg Byrne, CPES Director
APPEAL PROCESS
. The Code specifies the decisions that are
• appealable to the Council.
. Grounds for appealing a decision are:
- Failure to properly interpret and apply
relevant provisions of the Code or Charter;
and
- Failure to conduct a fair hearing.
APPEALS PROCESS (.rd)
. Appeals must be filed within 14 days of the
decision being appealed.
. The appeal hearing must be held no less than 30
days and no more than 60 days after the notice
of appeal is filed.
• Only"parties in interest"can appeal a decision
to Council or participate in the appeal hearing.
•
1
APPEALS PROCESS (r«rcd)
• Council's decision on the appeal is based on:
the grounds stated in the notice of appeal;
the relevant provisions of the Code or Charter;
the record of the proceedings before the original
decision maker(exhibits,transcript and videotape);
and
any additional issues that Councilmembers have
identified a week prior to the appeal hearing.
APPEALS PROCESS (r•td>
• Staff presents the appeal, then parties in
interest on both sides of the appeal make
presentations.
• The Mayor sets the time limit for the
presentations.
APPEALS PROCESS (cvird)
• In deciding an appeal, Council can either
uphold the decision that was appealed,
overturn it, modify it, or send the matter
back ("remand"it) for a new hearing if:
- Council finds that the appellant did not have a
fair hearing;or
- Council wants the original decision maker to
consider additional information about any
issue raised at the appeal hearing.
2
"NEW EVIDENCE" RULE
. New evidence is generally not admissible
at the appeal hearing.
. The Code prohibits new evidence at the
appeal hearing except when:
- A party has alleged that evidence was
substantially false or grossly misleading; or
- The new evidence is offered in response to a
Councilmember's question.
PROPOSED CHANGES TO
DEFINITIONS OF EVIDENCE
. Add a definition of"evidence"so parties
can better understand the difference
• between evidence and argument.
. Amend the definition of"new evidence"to
clarify that the same information
presented in a different form is not"new
evidence."
ELIMINATE THE FILING OF WRITTEN
STATEMENTS BY PARTIES IN INTEREST
PRIOR TO THE APPEAL HEARING
. Any written statements parties want Council to
consider must be filed by parties in interest no
later than noon on the preceding Wednesday.
. Concerns:
- Some parties miss the deadline then"solicit"
questions from Councilmembers at the
hearing in order to be able to submit written
materials.
- Written materials often contain new
evidence.
3
ELIMINATE THE FILING OF WRITTEN
STATEMENTS BY PARTIES IN INTEREST
PRIOR TO THE APPEAL HEARING i oorei
. Staff recommendation:
Eliminate the filing of written statements
prior to, or at, the appeal hearing. Limit
input to oral statements.
CLARIFY THE SCOPE OF
REVIEW ON APPEAL
• The Code presently limits Council to the
issues raised in the notice of appeal plus
any issues identified a week in advance by
Councilmembers.
• Councilmembers do not have sufficient
information a week in advance to know
whether other issues should be
considered.
CLARIFY THE SCOPE OF
REVIEW ON APPEAL
• Staff recommendation:
Amend the Code to permit Council to
consider all relevant issues.
4
CLARIFY COUNCIL DIRECTION
ON REMANDS
• When an appeal is remanded for further consideration of
information presented at the appeal hearing,Council
generally advises the decision maker of the scope of the
review at the re-hearing.
. Staff recommendation:
Institutionalize this practice by stating in the Code that
remands will always be accompanied by such direction.
ADDRESS "EX PARTS'
CONTACTS
. To preserve their impartiality,Councilmembers
should avoid off-the-record, ex parte contacts
• with parties affected by Council's decision on the
appeal.
. When Council ads as a legislative body,
Councilmembers are free to talk to their
constituents in advance, so the ex parte rule is
often confusing to the parties.
ADDRESS "EX PARTS"
CONTACTS (cont'd)
. Staff recommendation:
Amend the Code to explain the problems
presented by exparte contacts and to
discourage such contacts.
•
i 5
CONSIDER MODIFYING THE ROLE OF
MEMBERS OF THE PUBLIC IN FILING AN
APPEAL AND PARTICIPATING IN THE
APPEAL HEARING
. Appeals are limited to"parties in interest:"
- The applicant;
The owner or tenant of the property that is
the subject of the decision;
- Any person or organization on the City's list of
affected parties;
CONSIDER MODIFYING THE ROLE OF
MEMBERS OF THE PUBLIC IN FILING AN
APPEAL AND PARTICIPATING IN THE
APPEAL HEARING (cont'd)
Any member of the general public who sent
written comments to the original decision
maker or who appeared at the hearing on the
action that is being appealed;
- The City Council as represented by the
request of a single member of the Council.
CONSIDER MODIFYING THE ROLE OF
MEMBERS OF THE PUBLIC IN FILING AN
APPEAL AND PARTICIPATING IN THE
APPEAL HEARING (coned)
. Question presented:
Should members of the general public be
able to file an appeal and participate in
the appeal hearing, or should their
participation be limited to the hearing
before the board, commission or other
decision maker?
6
CONSIDER MODIFYING THE ROLE OF
MEMBERS OF THE PUBLIC IN FILING AN
APPEAL AND PARTICIPATING IN THE
APPEAL HEARING (�.fd)
. Staff recommendation:
Limit participation to those who have"due process
rights"under the law because:
- they are affected differently than the general
public;
- allowing appeals to be filed by the general
public can result in unnecessary Council
appeals and court appeals.
CONSIDER WHETHER COUNCILMEMBERS
WHO FILE AN APPEAL SHOULD
PARTICIPATE IN THE APPEAL HEARING
a One or more Councilmembers may file an
appeal.
• . No grounds need to be stated in appeals
filed by Councilmembers, but issues must
be identified.
. The Council must be impartial in deciding
an appeal.
CONSIDER WHETHER COUNCILMEMBERS
WHO FILE AN APPEAL SHOULD
PARTICIPATE IN THE APPEAL HEARING
. Staff recommendation:
Council should decide whether, as a general
rule, a Councilmember who files an appeal
should participate in hearing the appeal.
•
i 7
CONSIDER WHETHER TO
INCREASE THE APPEAL FEE
. The fee for filing an appeal is presently set at
$100.
. Counting only"primary staff,"the City's cost for
handling an appeal averages approximately
$1,650.
. Staff recommendation:
Increase the fee to cover more of the cost.
• DIVISION 3. APPEALS PROCEDURE'
Sec. 2-46. Detinitions.
The following words, terms and phrases, when used in this Division, shall have the
meanings ascribed to them in this Section:
Appellant shall mean a party-in-interest who has taken an appeal from a board,
commission or other decision maker to the City Council by the filing of a notice of appeal.
Applicant shall mean the person who or organization which submitted the application to
the board, commission or other decision maker whose decision has been appealed.
Final decision shall mean the action of a board, commission or other decision maker by a
vote of a majority of its members when no further rehearing is available before such board,
commission or other decision maker; provided, however, that a recommendation to the City
Council from a board, commission or other decision maker shall not be considered as a final
decision of that board, commission or other decision maker.
New evidence shall mean any evidence relating to the proposal or application which was
the subject of final decision by a board, commission or other decision maker and which was not
presented at the hearing before such board, commission or other decision maker.
• Parry-in-interest shall mean a person who or organization which has standing to appeal
the final decision of a board, commission or other decision maker. Such standing to appeal shall
be limited to the following:
(1) The applicant;
(2) Any party holding a proprietary or possessory interest in the real or personal
property which was the subject of the decision of the board, commission or other
decision maker whose action is to be appealed;
(3) Any person to whom or organization to which the City mailed notice of the
hearing of the board, commission or other decision maker;
(4) Any person who or organization which sent written comments to the board,
Cross-references—Appeals from the Liquor Licensing Authority, § 3-36;appeals from the Building
Review Board may be heard by the City Council, § 5-312; appeals from the decision of the City regarding
alarm permits to the City Council, § 15-36;appeals from the determinations of the Building Review Board
regarding alarm permits to the City Council, § 15-41(b); disapproval of pawnbroker's license may be appealed
to the City Council, § 15-265(c); applicant for license regarding places of entertainment may appeal the
decision to the City Council, § 15-298;appeals from the denial of the secondhand dealer's license to the City
. Council, § 15-318(d); appeals for denial of a license for a mobile home park may be appealed to the City
Council, § 18-5(d).
• commission or other decision maker prior to the action which is to be appealed;
(5) Any person who appeared before the board, commission or other decision maker
at the hearing on the action which is to be appealed;
(6) The City Council as represented by the request of a single member of the City
Council.
Sec. 2-47. Certain appeals to be taken to City Council.
Appeals taken from decisions made by any of the following boards, commissions or other
decision makers shall be taken to the City Council in the manner set forth in this Division:
(1) Building Review Board;
(2) Fire Board of Appeals;
(3) Landmark Preservation Commission;
(4) Planning and Zoning Board;
(5) A "decision maker" under the provisions of Section 2.2.12 of the Land Use Code;
• (6) Water Board;
(7) Zoning Board of Appeals.
•