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CARMEL BOARD OF ZONING APPEALS | REGULAR MEETING
DEPARTMENT REPORT
MONDAY, FEBRUARY 28, 2022
1. (A) Docket No. PZ-2022-00002 A: VOWC Gas Station Appeal. The applicant seeks to appeal the
12/9/21 Determination Letter written by the Carmel Dept. of Community Services Director. The site is
located at 2425 Harleston St. (part of Block B in Village of WestClay subdivision Section 6003-B). It is
zoned Village of WestClay PUD/Planned Unit Development. Filed by Brenwick TND Communities LLC
and Indy Holdings LLC, applicants.
General Info:
The Department of Community Services Director issued a zoning determination letter on December 9, 2021
pertaining to the proposed Village of WestClay gas station and convenience store on 1.1 acres (Docket no. PZ-
2021-00201 TAC.) Per UDO Section 9.01 - Administrative Appeal Process, the Petitioner had 30 days to file an
Appeal and that was accomplished. The appeal petition is before you this evening.
The Determination specifically refers to two sections of the current version of the Unified Development
Ordinance: UDO sections 5.65 and 9.05.A.4.C. The detailed language of those two sections is below:
UDO Section 5.65 US-19: Automobile Service Station; Automobile Filling Station Use-Specific Standards.
These Use-Specific Standards (US) apply to the following districts:
A. Setback:
1. Principal Building: Per primary zoning district.
2. Pumps and Pump Islands: Minimum of five hundred (500) feet from residentially zoned or used property.
May not be located within required yards.
3. Vent pipes for underground storage tanks: Minimum of five (500) hundred feet from residentially zoned
or used property. May not be located within required yards.
UDO Section 9.05.A.4.C: Planned Unit Development. Any portion of the Carmel Unified Development
Ordinance may be referenced in the District Ordinance. However, the Unified Development Ordinance shall
govern in instances where the PUD District Ordinance is silent.
The letter was mainly written to answer a question not answered by the Village of WestClay PUD ordinance –
what are the specific setbacks for gas station pumps? As proposed, the gas pumps will be located close to 67-ft
from the south property line of the subject site, which abuts the senior living cottages.
Please view the Petitioner’s Info Packet, as well as Dept. of Community Services’ Info Packet, for more
detail and analysis.
Zoning Research/History Timeline
(Note: Underlined text below is hyperlinked to relevant documents in Laserfiche.)
Introduction: The gas station is proposed to be located in Uptown Carmel, in the Peripheral Retail Area (PRA)
of the Village of WestClay PUD (Planned Unit Development). The gas station pumps are proposed to be
located around 67-ft north of the southern property line (where the senior living cottages are located.) Below is
some history of relevant changes to the VOWC PUD and Zoning Ordinance, as well as a timeline of events.
VOWC PUD: The original version of the Village of WestClay PUD Ordinance Z-330-99 was adopted on
1/4/1999. The primary plat was also approved in 1998 under PC docket no. 18-98 PP and 17-98 Z.
The Village of WestClay PUD Ordinance (as amended) was adopted in 2005 by City Council (Ordinance Z-
465-04). The related Plan Commission docket nos. are 04060035 OA and 04060036 Z. The proposed layout of
the PRA changed; also see the proposed site plan layout showing the initial proposed location of a gas
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station/filling station (in the DOCS info packet), as well as the representative gas station/ filling station
renderings. (See PUD Sections 2, 5.3, and 15.5, specifically, shown below, as well as other sections referenced
below.)
VOWC PUD Section 2: Applicability of Ordinance – states: Development in the District shall be governed
entirely by the provisions of this Ordinance with the exception that provisions of the Subdivision Control
Ordinance the Zoning Ordinance and the Sign Ordinance specifically referenced within this Ordinance and
as in effect on the date hereof shall also apply.
VOWC PUD Section 5.3.A (Permitted uses in the PRA):
The following uses are permitted in the Peripheral Retail Area:
A. The following commercial uses
1. financial institutions including drive thru teller service and exterior ATMs
2. restaurants or fast food operations including drive thru window service
3. grocery store including customary ancillary uses such as flower shop and bakery including drive thru
window service
4. drug store including drive thru window service
5. the sale of gasoline and other petroleum products exclusive of liquefied petroleum gas and as an
accessory use only, the polishing greasing washing or other cleaning servicing or repairing of motor
vehicles provided such services are rendered within a fully enclosed service bay or shielded from view
from adjacent properties. Automobile body repairs are not permitted
6. convenience store with or without gas sales
VOWC PUD Section 15.8.1 - Commercial uses in the Peripheral Retail Area (Area and Bulk
Regulations (for structures)):
A. Lot area minimum of 5000 square feet
B. Lot width at the build to line 50 feet
C. Minimum lot depth 100 feet
D. Yard dimensions
Build to line:10 feet unless otherwise indicated on an approved final plat or in another recorded instrument
Front: 10 feet
Side: 10 feet
Rear: 10 feet
E. Maximum building height 40 feet
F. On-site parking must comply with the requirements of Section 11
VOWC PUD Section 15.15 states: Where gasoline sales are permitted pumps and light standards may be
located in any yard.
VOWC PUD Sections 6 and 6.3 = Permitted accessory buildings and uses in the Peripheral Retail Area
(Refer back to PUD Section 5.3 (shown in a few paragraphs above).
VOWC PUD Section 8.5: Commercial uses may be mixed and integrated with dwellings and civic uses
within the Village Center, Peripheral Retail Area and Primary Area (SH).
2006 PUD Amendments: VOWC Development Plan Amendment and a text amendment for the Peripheral
Retail Area in the Village of WestClay PUD was approved in 2006. See PC docket no. 06060018 DP Amend
and also City Council Resolution CC-09-18-0-03.
2013 Zoning Ordinance Amendment: A zoning ordinance amendment to Carmel/Clay Zoning Ordinance
Chapter 31 was adopted in 2013. The Planned Unit Development wording/regulations changed, and it included
adding this statement: “Any portion of the Carmel Subdivision Control or Zoning Ordinance may be referenced
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in the District Ordinance. However, the Subdivision Control and/or Zoning Ordinance shall govern in instances
where the PUD District Ordinance is silent.” (See City Council Ordinance Z-578-13 and Plan Commission
docket no. 13010013 OA.)
2016 Rezone: A Rezone from the VOWC Primary Area (SH) (primarily senior housing) to the Peripheral
Retail Area was adopted on 2/15/2016. Please see City council ordinance Z-608-16 and Plan Commission
docket no. 15090010 OA. (The area rezoned is the subject site of the proposed gas station, along the south side
of Harleston St., west of Towne Rd., and adjacent to and north of the senior living cottages. See DOCS Info
Packet for graphic.)
2018 UDO Adoption: The Unified Development Ordinance (UDO) was adopted in January 2018, taking the
place of the Carmel/Clay Zoning Ordinance and the Subdivision Control Ordinance.
2020 BZA Variances: In 2020, BZA variances related to the proposed VOWC gas station were filed by
Brenwick, but then were withdrawn and never heard by the BZA. (This was around the same time that the
August 25, 2020 email was written by Planning Administrator, Ms. Conn. The Petitioner planned to modify
their concept site plan to comply with all development standards.)
• Docket No. PZ-2020-00093 V VOWC PUD Section 8.11 Buildings in PRA shall be designed in
conformance with the Peripheral Retail Area Design Guidelines, Deviation from guidelines requested.
• Docket No. PZ-2020-00094 V VOWC PUD Section 15.8.1.D Required 10’ build-to line unless
otherwise indicated on an approved final plat or in another recorded instrument, 118’ requested.
• Docket No. PZ-2020-00095 V VOWC PUD Section 15.11 Accessory buildings may be located in the
rear and side yards behind the rear facade of the principal structure, Accessory structure located in front of
primary structure requested.
• Docket No. PZ-2020-00096 V VOWC PUD Sections 16.17.A & 16.17.D.5 Stacking shall be confined
to the sides and rear of the parcel, Stacking in front requested. Also, the minimum number of vehicle stacking
spaces required for drive-thru lanes shall be 3 measured from the gas pump island, Request to include car
parked at pump.
2021 UDO Ordinance Amendment regarding gas stations & 500-ft setback: See Plan Commission docket no.
PZ-2021-00062 OA (Plan Commission favorable recommendation vote on 7/20/2021 & and City Council
ordinance Z-669-21 adoption on 09/21/2021). The prior-required setback for certain zoning districts was 80-ft.
2021 Pending VOWC PUD Ordinance Amendment: City Council Ordinance Z-670-21 is still pending at
City Council, and this Ordinance proposes to amend the WestClay Village Planned Unit Development District,
as amended, to apply the 500-ft setback from residentially used property for gas station pumps, pump islands
and vent pipes set forth in Ordinance Z-669-21 to the WestClay PUD district. The item was heard at 12/6/21
City Council meeting and then sent to their Land Use and Special Studies Committee, where it remains
pending. (Also see PC Docket No. PZ- 2021-00191, initiated on 10/11/21 and City Council Resolution CC 11-
01-21-01 which instructed the Plan Commission to do initiate this PUD ordinance amendment petition.)
2021 TAC Application: The VOWC Gas Station TAC Application was filed/initiated on 10/16/21 for review
of the project by the Technical Advisory Committee for compliance with technical aspects and compliance with
development standards. (Docket no. PZ-2021-00201 TAC). The 1.1-acre site is located at the southwest corner
of Harleston St. and Towne Rd. It is located within the Peripheral Retail Area of the Village of WestClay PUD.
2021 Determination Letter: The Director’s Determination Letter was issued on 12/09/2021, which halted the
TAC review process. A part of this action was the fact that new information was brought to the Director’s
attention regarding the environmental and health impacts of benzene and gas stations located close to residential
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uses. (The letter can be viewed here: PZ-2022-00002 A). Also, UDO Sections 5.65 and 9.05.A.4.C are
referenced in the Letter:
UDO Section 5.65 US-19: Automobile Service Station; Automobile Filling Station Use-Specific Standards
These Use-Specific Standards (US) apply to the following districts:
A. Setback:
1. Principal Building: Per primary zoning district.
2. Pumps and Pump Islands: Minimum of five hundred (500) feet from residentially zoned or used property.
May not be located within required yards. (Note: Before the 2021 Amendment for 500-ft setbacks, the
Unified Development Ordinance (UDO) read: “b. Pumps and Pump Islands: Minimum eighty (80) feet from
residentially zoned or used property. May not be located within required yards.” And, that was changed
from 30-ft to 80-ft in 2018. Before that, the 2003 version of the Zoning Ordinance ZO section 25.19 read:
“Pumps and Pump Islands. Minimum thirty (30) feet from residentially zoned or used property. May not be
located within required yards.”)
3. Vent pipes for underground storage tanks: Minimum of five (500) hundred feet from residentially zoned
or used property. May not be located within required yards.
UDO Section 9.05.A.4.C: Planned Unit Development. Any portion of the Carmel Unified Development
Ordinance may be referenced in the District Ordinance. However, the Unified Development Ordinance shall
govern in instances where the PUD District Ordinance is silent. (This statement was adopted in 2013; see
above for the 2013 Zoning Ordinance Amendment.)
2022 Appeal: The Petitioner filed the BZA Appeal Application on 01/05/2022, meeting the 30-day period to
file an appeal to the Director’s Determination. (It is Docket No. PZ-2022-00002 A)
Examples of Prior Director Determination Letters that were not appealed:
• 2014-15 letter re: VOWC Chapel Square – special events use in Village of WestClay PUD (included in
DOCS Info Packet).
• 2014 letter re: VOWC maintenance barn, rebuild after fire, in Village of WestClay PUD (included in DOCS
Info Packet).
Examples of Prior Appeals to the BZA of Director Determination Letters:
• Traditions on the Monon PUD – HOA Appeal: docket no. 11110010 A (Determination letter is included in
DOCS Info Packet)
• Traditions on the Monon PUD – Pulte Appeal: docket no. 11110011 A
• Westmont PUD Appeal – docket no. 15110008 A
• Lucas Estate Appeal – docket no. 17120006 A
• Thornhurst appeal – docket no 11060001 A
• 646 Johnson Drive appeal – docket no. 09020014 A
Final DOCS Comment:
A lot has changed since the original PUD for the Village of WestClay was adopted in 1999. Ordinances were
amended, development plans were amended, and the risks associated with benzene and gas stations were
studied. Circumstances change, and issues evolve.
Determination letters written by the Director are not out of the ordinary and often are a necessity. In this
instance, the Village of West Clay PUD was (and is) silent on the appropriate setbacks from residentially zoned
or used property. As a result, the Director consulted the UDO for guidance or authority and determined that the
proposed gas station and convenience store failed to comply with the required setbacks from residentially zoned
or used property.
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Findings of Fact: If the appeal is denied, the BZA attorney will write up the negative Findings of Facts.
Recommendation:
The Dept. of Community Services recommends the BZA votes to deny the appeal and to uphold the Director’s
Determination, and with adoption of the findings of fact to be written up by the BZA attorney.