Payne corresp. re ZC-downsizing T H I= C I T Y * 0 F
C-OPPEL£
Planning Depar/ment
255 Parkway Blvd
Coppell, Texas 75019
Phone: 972-304-3678
Fax: 972-304-7092
PLANNING DEPARTMENT CONTACT:
DIRECT DIAL:
Marcie Diamond
972-304-3676
FAX COVER SHEET
DATE: April 28, 2003
PAGES: 14 (including cover sheet)
TO: Bob Hager
cc: Gary Sieb
FAX: 214-965-0010
Items Transmitted:
Correspondence from one of the property owners whose property is subject to a
Planning and Zoning Commission authorized public hearing to rezone from LI to HC.
Excerpt from TML Legislative Update, dated April 18, 2003, and a copy of HB 2178
Remarks:
On the first item, the P&Z recommended approval of the rezoning because; there
was no one to speak in opposition (even though all effected property owners replied
in opposition), Mr. Payne only owns 4.2 of the 36 acres being rezoned, and P&Z
was of the opinion that the rezoning was appropriate and that during the next 30 days
the property owners would not change their mind, so they proceeded with this one
case, and pretty much tabled the rest of the cases. I did however, make a
presentation and we had a public hearing, contrary to Mr. Payne's accusations.
On the second item... I assume if we finish the rezoning prior to this becoming law ( if
it does) then there will not be a retroactive clause attached that could effect us.
Please call so we can discuss, Thanks
If you have any questions or would like additional information, please contact me at 972-304-3676 or e-
mail at mdiamond~,ci.coppell.tx.us.
0.4/28/03 M0N 14:59 FAX 214 745 5881 WS~ FLOOR 45 UNIT A ~002
W NSTEAD
April 28, 2003
direct dial: 214.745.5129
rpayne~winstead.oom
Ms. Maxcie Diamond
Planning & Zoning Department
City of Coppell
P. O. Box 9478
Coppell, Texas 75019-9478
via Facsimile
Re: Case No. ZC 614(CH)
Dear Marcie:
As mentioned in my telephone call today~ we think we should have had the right to a
Planning & Zoning hearing instead ora City Council heating on May 13, 2003. Enclosed for
your comments is a draft of our response to the City Council if one has to be made. Before filing
it, I would appreciate your comments. Can't we, by agreement, ret-am it to the Planning &
Zoning Committee?
Very truly yours,
Robert B. Payne
RBP:rlw
Enclosure
5400 RENAISSANCE TOWER PH 214,745.5400 [ WINST/SAD SUC~RF.$T &' MINICK [ A~tin, Dallas, Fort Worth,
04/28/03 MON 15:00 FAX 214 745 5881 WSM FLOOR 45 UNIT A ~003
Case #ZC 614(CH)
Response to the City
by Property Owners Robert B. Payne, et al.
The undersigned property owners (the "Property Owners") file this their response to the
City Council for Coppell, Texas, concerning the above proceeding, for hearing presently set for
May 13, 2003.
Failure to Grant Property Owners the Right of a Hearing
Before the Planning & Zoning Commission--
Request for Hearing Before Planning & Zoning Commission
1. The Property Owners have not had the right to a hearing on this case before the
Planning & Zoning Commission. The Property Owners appropriately requested a continuance
before the Planning & Zoning commission (Attachment "1"). After consultation with the staff,
the extension was seemingly granted (Attachment "2"). Nevertheless, no hearing was ultimately
held before the Planning & Zoning Commission. Instead, the matter was sent direct to the City
Council and is set for appearance before the City Council on May 13, 2003 (Attachment 3).
Objection is therefor made to such a procedure and request is made to return this proceeding to
Planning & Zoning Commission.
The Flawed Staff Report
2. Attached is a copy of the Staff Report. The Staff Report is fundamentally flawed.
For reasons previously explained to the staff, the plat attached to the Staff Report is misleading.
Such attempted rezoning of the subject tract completely ignores the fact that the subject tract is
directly adjacent, along its entire length, to the lands subject to the jurisdiction of the City of
Lewisville, Texas, located to the north thereof. Any zoning of the subject tract, and any
04/28/03 NON 15:00 FAX 214 745 5881 WSM FLOOR 45 UNIT A ~004
development on the subject tract, must be attempted only upon prior consultation with the City of
Lewisville and such adjacent property owners in that city. Accordingly, this action must be
returned to the Planning & Zoning Committee for appropriate action.
Material Misstatements in Staff Report
3. The Staff Report states that the present zoning permits a variety of uses which are
part of the highest and best use for this "high visible comdor". Nevertheless, under the
paragraph headed "Surrounding Land Use & Zoning", the report states that to the "East" is
"Coppell Greens; PD-134R-SF-7". Further, the Staff Report (page 3 of 4) states that "this
property abuts Coppell Greens, a single-family development". Such statements are false. In
actual fact, to the East of the subject property and abutting the same, is a very tall and large
cement plant! In fact, such lands located in Coppell Greens are ~eparated from the subject
property by such a large cement plant. The Planning & Zoning Commission must be afforded
the right to consider this matter.
Conclusion
Petitioners pray that such cause be sent to the Planning & Zoning Commission and
Petitioners granted such other and further relief as they may be entitled.
Respectfully submitted,
By:
Robert B. Payne
Individually and as an Agent and
Attorney for Those Property Owners
listed on the Next Page Hereof
5400 Renaissance Tower
1201 Elm Street
04/28/03 M0N 15:00 FAX 214 745 5881 WSM FLOOR 45 UNIT A ~005
Dallas, Texas 75270-2199
Telephone: (214) 745-5129
Facsimile: (214) 745-5881
DALLAS IX3806249\1
04/28/03 M0N 15:01 FAX 214 745 5881 WSM FLOOR 45 UNIT A ~006
W NSTEAD
April 15, 2003
direct dial: 214.745.5129
tpayne,~wiustead.com
Ms. Marcie Diamond
City of Coppell
P. O. Box 9478
Coppell, Texas 75019
Re: Cases ZC-613(CH) and ZC-614(CH)
Dear Marcie:
Confirming my telephone call of a few minutes ago, I will be out-of-town on Thursday
and request a postponement of the hearing on Thursday night for Items 17 and 18 until the
May 15, 2003 Planning & Zoning meeting. Please respond to fax number 214.745.5881.
Thanks.
Very truly yours,
Robert B. Payne
RBP:rlw
DALLokS_ 1~3800989\1
1821%10 04415/20113
Attachment 1
04/28/03 NON 15:01 FAX 214 745 5881 WSM FLOOR 45 UNIT A ~007
W NSTE
FILE COPY
April 16, 2003
direct dial: 214.745.5129
rpayne~winstead.com
Ms. Marcie Diamond
City of Coppell
P. O. Box 9478
Coppell, Texas 75019
Re: Cases ZC-613(CH) and ZC-614(CH)
Dear Mareie:
Thank you for the 30-day extension. As mentioned, I have no intent to file any permit for
development on this property within the next 60-90 days. Please fax back your okay.
Thanks.
Very truly yours,
Robert B. Payne
RBP:rlw
DALLAS_Ik3801618\1
Attachment 2
5400 R.ENAiSSANCE TOWER PH 214.745.5400 I W[NSTEADSECH[I'E$1'&MJNIC{( I AuStin. Dallax, Fort Worth,
~4/28/03 MON 15:01 FAX 214 745 5881 WSM FLOOR 45 UNIT A ~008
COPPELL
April 21, 2003
Greens West Developmem, L.C.
P.O. Box 129
Lewisville, Texas 75067-0129
Dot V. Turner
148 Cedar Drive
Lewisville, TX 75077-6902
Flournoy, Mary Sue Et Al
516 Main St W
Mo~t Vernon, TX 75457-2210
FRWM~n¢/
PO Box 6173
San Antonio, TX 78209-0173
Texas Industries Inc.
1341 W Mockingbird Ln, Suite 700
Dallas, TX 75247-6913
Robert B.Payne
5400 Renaissance Tower
i201 Elm Street
Dallas, TX 75270-2102
Carol AnnHowsley
AndreaLane Howsley
P.O. Box 700056
Dallas, TX75370-00056
RE: ZC-614(CH}
To Whom It May Concern:
This letter is to inform you that an amendment to the Land Use Plan of the 1996 Comprehensive Master
Plan from Light Industrial/Showroom to Freeway Commercial, and consideration of Case No. ZC-
614(CH), zoning change from LI (Light Industrial) to HC (Highway Commercial) on approximately 36.11
acres of property located north of S.H. 121, between Business S.H. 121 and Coppell Greens, were
recommended for approval by the Coppell Planning and Zoning Commission on Thursday, April 17, 2003.
The date scheduled for consideration by the Coppell City Council is Tuesday, May 13, 2003, at 7 p.m. in
Council Chambers at City Hall.
If you have any questions, please contact the Planning Department at (972) 304-3678.
Sincerely,
Marcie Diamond
Assistant Director of Planning
Cc Building Inspection
File
Attachment 3
B[ffl.nERS ARE ROUTINELY AL[OWED TO MAKE
WIl.n ALLEGATIONS AGAINST CFFIES
Almost every week, Texas builders and developers descend on the Texas Capitol to testify for
bills that are designed to gut municipal regulation of development. This is perfectly
understandable; for obvious reasons, some builders and developers wish to be totally fi'ee from
municipal regulations. What is not so understandable is the willingness of legislators to allow
these b~.ilders/developers to make outlandish accusations against city officials without one shred
of evidence that such accusations are based in fact. Here are some examples:
The purpose (of down-zoning) is either to limit or eliminate affordable housing.
Lots of times it is to get rid of multi-family ....
It is extremely difficult for any builder or developer to litigate against a
municipality just for fear of retribution.., the fear is that if you are hostile to that
municipality - not even to the extent of retribution, just being vocal and outspoken
in front of a city council or critiquing staff- that you will be subjected to
retribution.
Actually, just the opposite is tree. When builders and developers don't get exactly what they
want when they want it from city officials, they seek retribution...through the legislature.
DETRIMENTAL ZONING BII.I.
AUTHOR COMPARES REZONING TO MURDER.
The House Land and Resource Management Committee has approved H.B. 2178, a bill that
would require a city to compensate a property owner for a change in zoning classification that
results in a reduction of more than ten percent in the r '
p operty s value, unless the owner of the
property consents to the change. Last week's TML Legislative Update reported extensively on
this bill.
The bill would also allow, in lieu of compensation, a prevailing property owner to develop th, e
property under the zoning rules that applied to the property before the change in the property s
zoning classification and require a city to waive any fees associated with the development of the
property, including application fees and impact fees.
House Bill 2178 is sponsored by Representative Anna Mowery (R-Fort Worth), who is also the
chair of the House Land and Resource Management Committee. In describing her bill to the
other committee members, she said:
This is a preventative bill. It's just like the bills we have against murder. We don't
want murder to happen; we don't want downzoning to happen. If downzoning
occurs, it occurs only at the request of the owner ... It's a property right.
This bill has been sent to the House Calendars Committee. City officials should flood House and
Senate offices urging the defeat of H.B. 2178. TML believes that the legislature is moving far
too quickly and precipitously on a bill that has far-reaching implications for community
development. The League is urging the legislature to do an in-depth interim study of this issue,
but to defeat H.B. 2178 in its present form.
3
April 9, 2003
HB 2178 (Mowery)
This morning the Land and Resource Management Committee of the Texas House
favorably passed (unchanged) this Bill that relates to the authority of the governing body
of a municipality to change previously adopted zoning regulations. The Bill could require a
City to financially compensate a property owner for the rezoning of their property, when
they object and the loss in property value exceeds 10% of its worth.
On April 2, 2003, the author of the bill, Representative Anna Mowery from District 97 (Fort
Worth-Benbrook Area), described her bill as follows:
"This is a preventative bilL..its just like the bills we have against murder. We don't want
murder to happen. We don't want downzonings to happen. We want...if down zoning
occurs, it occurs only at the request of the owner...it's a property right...."
The proposed Bill reads as follows:
78R8290 AKH-D
By: Mowery
H.B. No. 2178
A BILL TO BE ENTITLED
AN ACT
relating to the authority of the governing body of a municipality to
change previously adopted zoning regulations.
BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
SECTION 1. Section 211.003, Local Government Code, is
amended by adding Subsection (d) to read as follows:
(d~ Notwithstanding any other provision of this subchapter,
the governing body of a municipality may not change the zoning
classification of a property that results in a diminution of more
than 10 percent of the property's value unless:
(1') the owner of the property:
(Al waives any right to ob!ect to the proposed
change; or
(BI fails to file with the governing body before
the 90th day after the date the ~overning body notifies the property
owner of the date the governing body will vote on the proposed
change under Section 211.006:
(ii a written statement objecting to the
proposed change under this section; and
(ii) a copy of an appraisal report by a
state certified or licensed appraiser that states the appraiser's
opinion of the value of the property before and after the proposed
change in the zoning classification; or
(2~ the ~overnin~ body compensates the property owner
for the diminution in value resulting from the change as determined
(A~ an agreement with the property owner; or
(B~ a proceedin~ ~overned bv Chapter 21, Property
Code.
SECTION 2. Subchapter A, Chapter 21, Property Code, is
amended by amending Section 21.003 and adding Section 21.004 to
read as follows:
Sec. 21.003. DISTRICT COURT AUTHORITY. A district court
may determine all issues, including the authority to condemn
property and the assessment of damages, in any suit filed under this
chapter and any suit filed:
(1) in which this state, a political subdivision of
this state, a person, an association of persons, or a corporation is
a party; and
(2) that involves a claim for property or for damages
to property occupied by the party under the party's eminent domain
authority or for an injunction to prevent the party from entering or
using the property under the party's eminent domain authority.
Sec. 21.004. PROCEEDINGS REGARDING CHANGE OF ZONING
CLASSIFICATION. (a~ A oroceeding filed under this chapter for the
puroose of determining the diminution of a property's value under
Section 211.003(d/. Local Government Code, is a condemnation or
eminent domain proceedin~ under this chapter for the sole purpose
of satisfying the procedures required by this chapter.
(b~ In a proceeding described by Subsection fa), the
condemnor or acquiring entity is the municipality, the condemned
property is the orooertv for which the zoning is to be reclassified,
and the condemnation is the change in the property's zoning
classification.
lc') The special commissioners or district court, as
aooropriate, may determine all issues related to a proceeding under
this section.
(d) Not later than the lOth day before the date the
condemnation proceeding begins, each party shall provide to the
other parties a coov of each aopraisal report supporting that
party's opinion of any diminution of value.
(e} The municipality may change the property's zoning
classification after the special commissioners have made an award
as prescribed bv Section 21.021.
SECTION 3. Subchapter B, Chapter 21, Property Code, is
amended by adding Section 21.0121 to read as follows:
Sec. 21.0121. CONDEMNATION PETITION RELATING TO ZONING
CLASSIFICATION. (a~ If the ~overnin~ body of a municipality or a
political subdivision of this state wants to change a property's
zoning classification but is unable to agree with the owner of the
oropertv on the amount of damages, the condemning entity mav begin a
condemnation proceedincz by filin~ a oetition in the proper court.
(bi The petition must:
(1~ describe the property to be reclassified under a
different zoning classification;
(2~ state the purpose for which the property's zoning
is to be changed:
(3~ state the name of the owner of the property if the
owner is known; and
(4) state that the entity and the property owner are
unable to a§ree on the damages.
SECTION 4. The heading of Section 21.021, Property Code, is
amended to read as follows:
Sec. 2:]..02:].. POSSESSION PENDING LITIGATION; ZONING
RECLASSIFICATION.
SECTION 5. Section 21.021(a), Property Code, is amended to
read as follows:
(a) After the special commissioners have made an award in a
condemnation proceeding, except as provided by Subsection (c) of
this section, the condemnor may take possession of the condemned
property or change the zoning classification of the property
pending the results of further litigation if the condemnor:
(1) pays to the property owner the amount of damages
and costs awarded by the special commissioners or deposits that
amount of money with the court subject to the order of the property
owner;
(2) deposits with the court either the amount of money
awarded by the special commissioners as damages or a surety bond in
the same amount issued by a surety company qualified to do business
in this state, conditioned to secure the payment of an award of
damages by the court in excess of the award of the special
commissioners; and
(3) executes a bond that has two or more good and
solvent sureties approved by the judge of the court in which the
proceeding is pending and conditioned to secure the payment of
additional costs that may be awarded to the property owner by the
trial court or on appeal.
SECTION 6. Section 21.047, Property Code, is amended by
amending Subsection (a) and adding Subsection (d) to read as
follows:
(a) Special commissioners shall [may] adjudge the costs of
an eminent domain proceeding as follows: [~.gc. lnst ~ny p~rty.]
(1) if [t~] the commissioners award greater damages
than the condemnor offered to pay before the proceedings began or if
the decision of the commissioners is appealed and a court awards
greater damages than the commissioners awarded, the condemnor shall
pay [aH] costs and reasonable and necessary attorney's fees; or[:]
(2) if [~4] the commissioners' award or the court's
determination of the damages is less than or equal to the amount the
condemnor offered before proceedings began, the court may require
the property owner to [sh~',',] pay the costs.
(d) This section governs a proceeding filed under this
chapter, including a oroceeding filed for the purpose of
determining the diminution of a oropertv's value under Section
211.003(d~. Local Government Code.
SECTION 7. Subchapter C, Chapter 21, Property Code, is
amended by adding Section 21.0485 to read as follows:
Sec. 21.0485. PAYMENT OF DAMAGES BYCONDEMNOR. (a) This
section applies to a property owner who prevails in a suit filed
under this chapter, includin~ a proceeding, filed under this chapter
for the purpose of determining, the diminution of a property's value
under Section 211.003('d), Local Government Code.
(b) The condemnor shall pa,/the full amount of the court or
commissioners' award not later than the second anniversary of th~
date the Judgment is final or all appeals have been exhausted,
whichever is later.
SECTION 8. Subchapter D, Chapter 21, Property Code, is
amended by adding Section 21.066 to read as follows:
Sec. 21.066. PREVAILING PROPERTY OWNER; DEVELOPMENT OF
CERTAIN PROPERTY. Instead of enforcing a judgment under this
chapter, a property owner who prevails in a proceeding' filed under
this chapter for the purpose of determining the diminution of a
prooerty's value under Section 211.003(d), Local Government Code,
may develop the property under the zoning rules that applied to the
property before the change in the property's zonin~ classification.
The municipality shall authorize the development according to
regulations prescribed by that zoning classification and waive any
fee associated with the development of the property, including
a[}plication and impact fees, and any pro rata changes.
SECTION 9. (a) Sections 21.0485 and 21.066, Property Code,
as added by this Act, apply to a suit or proceeding filed under
Chapter 21, Property Code, that is pending in a trial or appellate
court on September 1, 2003.
(b) This Act takes effect September 1, 2003.