HomeMy WebLinkAboutMemo - Read Before Packet - 10/19/2021 - Memorandum From Heather Walls Re: Item 18 - Sam’S Club Appeal - New Evidence (8)
City Clerk
300 LaPorte Avenue
PO Box 580
Fort Collins, CO 80522
970.221.6515
970.221-6295 - fax
fcgov.com/cityclerk
MEMORANDUM
DATE:October 19, 2021
TO:Mayor and Councilmembers
THROUGH:Kelly DiMartino, Interim City Manager
Kyle Stannert, Deputy City Manager
Tammi Pusheck, Interim City Clerk
FROM:Heather Walls, Deputy City Clerk
RE: #18 Club Appeal New Evidence
Attachedplease find additional materialsinadvertently sentto a previous clerk, however filed on
time. These letters were not included in original packet. As this is new evidence,
Councilwill have the ability todetermine whethertoaccept thisinformationinto evidenceat the
hearing tonight.
bhfs.com
410 Seventeenth Street, Suite 2200
Denver, CO 80202
main 303.223.1100
Brownstein Hyatt Farber Schreck, LLP
Carolynne C. White
Attorney at Law
303.223.1197 tel
cwhite@bhfs.com
June 10, 2021
NEW EVIDENCE
City Clerk, Wanda Winkelman
City of Fort Collins
300 La Porte Avenue
PO Box 580
Fort Collins, CO 80522
Email: wwinkelman@fcgov.com
Dear: Ms. Winkelman
Please accept this correspondence and the attached letter from the Harmony Market Owners Association
MJA#200002.
This constitutes the New Evidence referenced in our appeal.
ith the
applicable criteria.
982 fuel facilities throughout the United States (in 46 states). Those facilities include roughly 3,500
underground storage tanks (UST) in total.
disasters throughout the years, including: no tank buoyancy issues, no spills and no environmental
exposure of gasoline. The record-shattering 2020 Atlantic Hurricane Season (with 28 named tropical
storms so far, 11 of which have made landfall), is no exception.
By way of recent example: Hurricane Zeta, which made landfall on October 28, 2020 at 4:00 p.m., caused
devastating damage to private property and public infrastructure on the East Coast of the United States. In
one city alone (Atlanta, Georgia), over one million people lost electric power to their homes and
business
Petitioner is pleased to report that each and every one of its fuel facilities was operational within less than
, proudly providing fuel to the impacted communities.
-of-the-art fuel facilities have worked as designed to endure extreme weather without
sustaining any water intrusion, fuel release or other contamination to the environment. Petitioner has a
100% proven track record of successfully withstanding severe environmental conditions at each of its fuel
stations.
City Clerk, Wanda Winkelman
June 10, 2021
Page 2
Petitioner respectfully requests the Town Board to consider the significance that the foregoing bears on the
merits of approving the Project.
Should you have any questions please let me know.
Sincerely,
Carolynne C. White
22769015.1