HomeMy WebLinkAboutLetter #05 Michael Andreoli - representing Woodhaven HOABEFORE THE CARMEL PLAN COMMISSION
DOCKET NO. PZ-2021-00205 DP/ADLS
And
BEFORE THE CARMEL BOARD OF ZONING APPEALS
DOCKETS NO. PZ-2021-00224 V, 00228V9 00234 V,
00240 V, 00241 V, and 00244 V
IN RE: THE MATTER OF
11335 N. Michigan Road Apartments
SUPPLEMENTAL RESPONSE IN OPPOSITION
This written remonstrance has been prepared for and on behalf of the Woodhaven single
family home residents and, generally, all others who may be in opposition to the Application and
requests for Variances. As the remonstrators Response in Opposition was heretofore filed under the
Plan Commission Docket, the remonstrators respectfully request that the original Response in
Opposition also be adopted verbatim in response to the Variances requested in the above docketed
items before the Carmel Board of Zoning Appeals.
MULTIFAMILY USE
The Woodhaven single family home residents are categorically opposed to the multifamily
use being proposed for this site. Historically, and without general opposition, the Michigan Road
Corridor has generally been laid out to include more intensive uses in and along Michigan Road with
larger big box and/or offices as the developments have progressed farther to the east. Plan
Commission and Board of Zoning Appeals members are actively encouraged to either Google Map
the area or take a short drive from 98 h Street on the north along Commerce Drive in particular to
1061h Street. What the members will find is that in this particular area along Commerce Drive,
development has occured with a mix of large open space along with a combination of professional
office buildings as a buffer between the big box developments and the residential immediately to the
east. The members will note that tremendous areas of open space buffering, fencing and low
intensity office and professional use allow both the single family residential and commercial
component in and along Michigan Road to not only co -exist but to thrive. North of 106th Street,
along the backs of all of the commercial buildings, fencing with substantial mounding and
landscaping has occurred to once again allow these uses to co -exist with the residential development
immediately to the east. What members will NOT find located in these areas, specifically adjacent
to residential development, and specifically adjacent to high end low density residential
development, is an intense multifamily project.
While obviously the Woodhaven residents would like to see the reforested area of trees
planted by Altums to remain in place with no intensive use, they recognize this request may be
unrealistic. While everyone would love to see a park or nature preserve behind their residential
homes, they have suggested to REI that an apartment complex is not the highest and best use for that
particular ground, especially as it relates to their properties. They have legitimate concerns that a
multifamily development with this number of homes and parking will have doors slamming at all
hours of the night, lights, noise from the residents' music and all those particular difficulties that
generally do not occur by having professional offices that have more defined hours and use. In
meetings with Mr. Fehsenfeld and Mr. Wells regarding the proposed use of this ground, we were
told that commercial office buildings, et cetera, were unrealistic as it was too far back. This is a
preposterous and disingenuous response to a very real concerns raised by Woodhaven. All up and
down Michigan Road along Commerce Drive and otherwise, until Altum Gardens, one can see how
commercial and residential transitioned and how low-level office use was included far off Michigan
Road along Commerce Drive with successful results and extremely high occupancy. The developer
doesn't want to accommodate this request from Woodhaven, not because it wouldn't be successful
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or wouldn't be in line with all other development in and along Michigan Road, but rather this is not
what REI does as they intend to make this a legacy multifamily project managed by the Fehsenfeld
and Wells heirs. Moreover, they seek to do this with six (6) requested Variances which, as
previously suggested to the Boards, requires the Plan Commission and Board of Zoning Appeals, in
particular, to fit a square peg into a round hole. While the developers' goal is clearly to maximize
every inch of the site to its full development and money -making potential, this should not be allowed
on the backs of the enjoyment and property values of the Woodhaven Subdivision.
ATTEMPTS TO ACCOMMODATE
As to the proposed development, the Woodhaven residents, through this attorney, conducted
two (2) meetings: one with Fred Fehsenfeld, Mike Wells and Ryan Wells; and the other with
essentially Ryan Wells. Concerns regarding this project and requests for the developer to conform
the use to a more traditional commercial use as shown up and down Michigan Road were
unreceptive. Hence, Woodhaven residents, having a stake in the game, made constructive attempts
to create a better product that would allow the multifamily to move forward at a slightly less dense
development, with better, more efficient setbacks, restructured and relocated buildings, and a
common fence line with Woodhaven that would provide the appropriate buffering, sound control and
aesthetic component that most assuredly should be part of Carmel's approval process. Instead, the
current proposal puts forth very little change and a proposal for a white vinyl fence along the
common property line. Members of the Carmel Plan Commission and Board of Zoning Appeals,
Really???? A white vinyl fence is the best the developer could come up with? Simply looking
across the street at the project that Buckingham did, approved in Zionsville, adjacent to a high -end
low density residential subdivision shows a brick and stone fence. With the proposed buffering and
mounding of the fence proposed by Woodhaven, the developer would meet the requirements of
separation, noise control and aesthetics that one would expect from a "Legacy Project". In the end,
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Woodhaven is left to remonstrate and remain in opposition to this project as whatever truly
constructive attempts they made to make the project more compatible for area residents fell on deaf
ears. (See Andreoli Law letter to Wells dated March 28, 2022).
CONCLUSION
In the end, no multifamily product has been developed in and along the east side of Michigan
Road. The developer would be hard pressed to point to the Plan Commission and Board of Zoning
Appeals similar high density multifamily next to low density single family residential in Carmel.
Professional offices and other successful office structures have been located and, with proper
buffering, have blended in to the adjacent neighborhoods. This is not a use that is compatible with
the existing surrounding neighborhoods based upon all the substantive reasons provided to the
Boards and the many letters sent in opposition to this project. Moreover, the neighbors' concerns
and suggestions have largely gone unanswered. This project does not appropriately comply with the
Michigan Road Overlay District and the number of Variances and requests being made from the Plan
Commission and Board of Zoning Appeals to fit this project into this site should ring loud alarm
bells for the Boards that would strongly suggest that perhaps this site is not an appropriate size or
location for the use being requested by REI and the Fehsenfeld
Michael J. Andreoli, #2412-06
Attorney at Law
1393 W. Oak St.
Zionsville, IN 46077
317-873-6266
andreoli(& atlaw.co
S
Attorney for Remonstrators
Page 4
MICHAEL J ANDREOLI
ATTORNEY AT LAW
1393 West Oak Street
Zionsville, Indiana 46077-1839
(317) 873-6266
Fax (317) 873-6384
mandreoli(ab-datlaw.com
March 28, 2022
Via E-Mail
Ryan Wells, Director of Development
RE[ Real Estate Services, Inc.
11711 North Pennsylvania Street, Suite 200
Carmel, Indiana 46032
RE: Altums Development
PZ-2021-00205-DP/ADLS-11335 N. Michigan Road/
Apartments
Dear Ryan:
I am following up on our two meetings, the last of which presented suggestions and
proposals to see if your proposed development could be made more user friendly for my
clients immediately to the north. As you are aware, the Woodhaven Development is an
older, well established, low -density single-family home development. While Woodhaven
does not believe that the proposed development by REI is compatible with Woodhaven,
the following suggestions are being made to try and reach an accommodation that
would allow you to move forward, to -wit:
We propose that you install a 3' berm with an 8'-10' stone and/or masonry
fence along the top along our common property line. This would sufficiently
screen our development from yours. Your suggestion of a white vinyl fence is
a non -starter for the neighborhood as we believe this looks cheap and tacky
in light of the fact that you are proposing this apartment complex as a legacy
project. We pointed you to fencing installed several years ago by
Buckingham Co. to screen from a similar low -density single-family
development.
2. That you would move Building 1 to the south where the pool is located.
3. That Building 4 and the units therein would be eliminated so that it's not so
close to the Woodland's properties. In doing so, we propose relocating
Building 3 a little farther to the north with the pool to be located just south and
east of Building 3. This would make the pool closer to the overall interior of
the development to serve the needs of its residents and allow Building 1 to be
moved to the south.
4. That all air conditioning and heating to be relocated non -adjacent to the
Woodhaven development.
5. As you have proposed, the elimination of any sidewalk people trail on the
northern edge of the proposed pond. This is acceptable.
6. The rotation of Building 7 will provide setback relief for the Weston Point
community together with a fence the same material but of a reduced height
and berm.
7. That we request that the following uses be removed from consideration of
development in your out lots:
a. Gas station;
b. Automotive or truck repair;
c. Automotive or truck sales;
d. Bars;
e. Hookah bars;
f. Car wash; and
g. Restaurants would be per]I%ichaEeUAndreoli
patio seating.
MJA/ba
Enclosure
cc: Joe Shestak
Clients
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