HomeMy WebLinkAbout07-21-17 Public Comment - Gallik, Bremer & Molloy, P.C. - UDC Update Noticing •
�1
GALLIK, BREMER & MOLLOY, P.C.
Attorneys at Law
777 East Main Street, Suite 203
Post Office Box 70
Bozeman, Montana 59771-0070
(406)404-1728
July 21, 2017 COPY
Greg Sullivan
City Attorney
City of Bozeman
121 N.Rouse Ave.
Bozeman,MT 59715 HAND DELIVERY
Re: Uniform Development Code— Ongoing Revisions —Deficient Notice
Dear Mr. Sullivan:
This letter follows Mayor Carson Taylor's July 18'h response to our letter of July 12,2017. We
understand from that response that the City Commission has scheduled discussion of a final draft
of the Uniform Development Code ("UDC") on August 17, 2017, and that"[a]s always all of the
public is invited to attend."
The purpose of this follow up letter is to provide notice to the City that our clients also object to
the process by which the City is adopting the revisions to the UDC. That process is unlawful for
many of the same reasons as was the adoption of Resolution 4598. The UDC revisions should be
placed on hold until the City provides a lawful process that provides notice to property owners
within 150 feet of the revisions to allow them the opportunity to meaningfully protest such
revisions as allowed by statute.
The revisions to the UDC will effect substantive changes in applicable zoning regulations, and,
as noted in our July 121h letter, the City is obligated to comply with applicable statutes and
ordinances. Cf.. Southern Mont. Tel. Co. v. Mont. PSC, 2017 MT 123, 2017 Mont. LEXIS 324
(May 30, 2017)(declaring invalid a policy adopted as a"rubric"by the PSC,because the policy
was a rule as defined by Montana's Administrative Procedure Act, and was not properly
adopted). Specifically, MCA § 76-2-303(2),requires that a zoning regulation or boundary"may
not become effective until after a public hearing...at which parties in interest and citizens have
an opportunity to be heard....At least 15 days' notice of the time and place of the hearing must
be published in an official paper...of general circulation in the municipality."While that portion
of the statute may have been met with respect to the UDC revisions, in addition, MCA § 76-2-
305(1) specifies that the requirements of section 76-2-303(2) apply equally to changes or
amendments to zoning requirements. It further provides that an "amendment may not become
effective except upon a favorable vote of two-thirds of the present and voting members of the
[city commission] if a protest against [an amendment] is signed by the owners of 25% or more
of...(b) those lots...150 feet from a lot included in a proposed change." MCA § 76-2-305(2).
Mayor Carson Taylor
July 21, 2017.
Page 2
Consistent with this statutory provision, Section 38.36.040 of the UDC provides that in the "case
of protest against [such amendments] signed by the owners of 25 percent or more of either the
area of the lots included in any proposed change, or those lots 150 feet from a lot included in a
proposed change, such amendment may not become effective except upon a favorable vote of
two-thirds of the present and voting members of the city commission."
The intent of the City's noticing provisions is to "provide for adequate notice of governmental
actions to those affected by such actions," and further acknowledge "[njotice is required in
order for-citizens to participate in decision making which affects their interests and provides
opportunity to receive information pertinent to an application that would not otherwise be
available to the decision maker." See UDC, Section 38.40.010. (Emphasis added.) However,
the City's notice requirements for text amendments do not comply with state law, as notice is not
required for property owners within 150 feet from a lot included in a proposed change. Absent
such notice, such property owners are deprived of their right to protest and Right to Participate
and Right to Know requirements under Montana Constitution Article II, sections 8 and 9
Our clients who are within 150 feet of the proposed revisions to the UDC have not received
actual notice of the proposed UDC revisions, although some are aware of the UDC revisions due
to ongoing communications with Marty Matsen, Community Development Director. With
adequate notice,property owners within 150 feet the proposed UDC revisions would have the
opportunity to exercise their protest rights and, in doing so, and may have the opportunity to
defeat the proposed revisions.
We do not believe that newspaper notices of the proposed UDC revisions published by the City
are sufficient with respect to the Right to Participate and Right to Know requirements under
Montana Constitution Article II, sections 8 and 9. The proposed revisions to the UDC will
substantially impact landowners within 150 feet of the areas included in the revision, as well as
many other citizens of Bozeman. To have a meaningful opportunity to participate and exercise
their rights to protest the proposed revisions or amendments, the property owners must receive
adequate and timely notice. Absent actual notice, property owners within 150 feet of the
proposed amendments will be deprived of notice and correspondingly their constitutional rights
to know and participate.
As we advised previously, our clients support continued, orderly development and growth in
Bozeman, and revisions to the UDC—so long as stakeholders, including residents and owners in
residential districts and neighborhoods who may be impacted by the UDC amendments, are
actively and constructively engaged and included in a dialogue addressing potential adverse
impacts to those residential districts, neighborhoods, and individual properties resulting from the
UDC revisions. We and our clients are prepared to engage constructively with the City and all
stakeholders, including developers. However, the City must provide property owners within
150 feet actual notice and we request that the City provide such notice prior to the City
Commission proceeding with a hearing consider the adoption of such revisions.
If the City continues to pursue the UDC revisions absent such notice, this leaves our clients with
no option other than to seek relief from the Court. While we appreciate Mayor Taylor's response
Mayor Carson Taylor
July 21, 2017
Page 3
on July 18, 2017, we respectfully request a more substantive written response to this letter by no
later than Friday,July 28, 2017. Specifically,please advise whether or not the City will be
providing actual notice to property owners within 150 feet of the proposed revisions to the
UDC. Thank you.
S'
GALLIK,7ENIER& OLLOY,P.
JameMolloy'
J cyn remer
c: Mayor Carson Taylor
Deputy Mayor Cindy Andrus
City Commissioner Jeff Krauss
City Commissioner Chris Mehl
City Commissioner I-Ho Pomeroy
Dennis Taylor, Interim City Manager
Marty Matsen, Director of Community Development