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1992-01-28 Objections to Special Assessments '" " OBJECTIONS TO SPECIAL ASSESSMENTS To: City of Albertville and its City Council From: JOHN GEORGE INC. Re: Proposed Special Assessments in the sum of $31~086.87 referred to in Notice of Hearing hereto attached as Exhibit A and incorporated herein by reference. The undersigned JOHN GEORGE INC. 15 the fee owner of the land described in the attached Notice of Hearing. The undersigned hereby objects to the proposed assessments. The objections include, but are not limited to, the following: 1) The property has already been assessed for trunk water main and is subject to a deferred assessment therefor. 2) The pt~opDsed assessment is cDntt~at'y to action taken by City Council when improvements were installed in 1988 whereby they determined to assess a portion of the costs of the water main and the Highway 37 Interceptor, lift station and forcemain to certain benefitted properties and to recover the remaining costs by Sewer and Water availability and connection charges and user fees. 3) The proposed assessment is contrary to the agreement between the undersigned and the City and the Developer's Agreement between them. 4) The property receives no benefit from the proposed assessment. 5) The proposed assessments have not been made in the manner reguired by Minnesota Statutes Chapter 429 and are contrary to law. Dated at Otsego, Minnesota this 30th day of October, 1991. JOHN GEORGE INC. by by Its Pt'es ident I ts Sect--etat~y ~ Page 2 The city addressed the guest ion of financing for the Highway 37 trunk interceptor, lift station and forcemain and chose not to finance that project by special assessments since it would have reguired assessments on all of the remaining land in the city. This was an action the city was not prepared to make. They therefore developed a fee schedule which provided connection charges which would be payable at the time building permits were issued. The bonds that were sold to finance that project were issued pursuant to Chapter 444. The other improvement projects were made pursuant to Chapter 429 and those bonds were to be repaid out of special assessment proceeds. ~ The decision to purchase the Becker property was not made until late March 1988 after the city had approved the preliminary plat of Westwind and ordered construction of the various improvements under Chapter 429. It was during this period that we were finishing up the details on our developers agreement. Our development concept covered the entire Becker farm and provided for a phased development consisting primarily of single family residential, multiple residential. and commercial. It was expected that the commercial land would be developed last since commercial development is dependent on a population base sufficient to make development economically feasible. The developers agreement provided for park fees on all of the single family lots (175) and the first phase of apartments. Park fees on the remaining lands were to be deferred until later development occurred. In late April we completed our land purchase after the final plat was approved, the plans for the improvements were approved and bidding process implemented. We completed our negotiations on the Developers Agreement which was executed on April 27th. Once the varous 1988 improvements were under way the city initiated action to secure PCA approval for an expansion of sewer plant capacity (cf. July 18 minutes). This was a vital step since it was obvious that expansion would eventually be reguired to acccmodate the projected population growth. Page 3 Thet~e was a "meeting of the minds" with the city representatives that development costs would be deferred with respect to the commercial land until development actually occurred. The land was (and is) subject to a deferred Joint Powers water assessment of $10,175 which will activate when development occurs. It was then uncertain (and still is) whether or not the water line along County Road No. 37 would be utilized in development of the commercial lands. It is also uncertain as to what extent those lands would be served by the new watermain along No. 37. These factors all had a bearing on the decision to defer costs - wherever possible - until actual development occurs. An additional factor also applied with reference to the watermain. We have attached hereto copies of the applicable Minnesota law as set out in two relatively recent cases and the authoritative work on the laws relating to municipal corporations which discusses one of those cases. The law is clear that the city could make no valid a~sessment for the watermain alonRNo. 37 unless the commercial land actually uti 1 i ;;.~es the w.~....tet~ma in. Recent developments in Albertville have also contributed to the uncet~tainty of when we might proceed with development of our remaining lands. The city failed to follow through with its agreement to seek timely approval by PCA of the needed sewer plant expansion and now we are faced with a situation where other developers and the High School are being given prioity by the City Council for the limited remaining plant capacity. This places us in a high risk situation since we are being asked to assume substantial costs even though it is questionable that there is capacity available for our pt~ojects. ~. Page 4 However, it has always been our intention to pay our improvement costs on the commercial land when it is ultimately developed. The timin8 of our payment is of primary importance and the manner of payment is also significant. In order to facilitate disposition of these matters we are therefore proposing terms of settlement which we have attached to this memorandum and we respectfully reguest your consideration of our offer. Dated at Otsego, MN this 28th day of January, 1992 ~