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<br />con ~CLct th <br /> <br />q~ <br /> <br />fl \ colt . <br />J}1.4.~ <br /> <br /> <br />Attachment 5 <br /> <br />William R. Warhurst 8B#95551 <br />HANNIG LAW FIRM LLP <br />2991 EL CAMINO REAL <br />REDWOOD CITY, CA 94061-4003 <br />(650) 482-3040 Facsimile (650) 482-2820 <br /> <br />Attorneys for Nicoll Enterprises <br /> <br />APPEAL TO THE CITY CO UN CIL <br /> <br />REDWOOD CITY <br /> <br /> <br />From a Notice of Official Action (September 22, 2005) <br />- denial of use permit application for seasonal sales ofpumpkins and Christmas trees <br /> <br />Project No. UP2005-31 <br /> <br />Property Address: 150 El Camino Real and 20 Avondale Avenue <br /> <br />Assessor's Parcel Numbers: 052-064-100 & 052-064-110 <br /> <br />INTRODUCTION <br /> <br />For the last nine years, Nicoll Enterprises has sold Christmas trees at the comer of <br />A vondale and EI Camino Real from the week before Thanksgiving to Christmas Eve. <br />During the last seven years, Nicoll has also sold pumpkins during the month of October. <br />These seasonal businesses are very popular and strongly supported by the community. <br />Nicoll submitted pages of signatures last year from satisfied customers who appreciated <br />this very fun holiday experience. (See Exhibit A.) <br /> <br />The Zoning Administrator has now opined that there is no significant community <br />benefit from this long-standing activity, because of unspecified complaints that she <br />merely states have been "substantiated." She does not say what complaints. She does not <br />say if any of the complaints arise from activities after Nicoll adopted new procedures <br />starting with the Christmas tree sales last year (that is, after December I, 2004): She does <br />not say what "evidence" qualified as substantiation for the complaints. Her denial of the <br />use permit appears to be based on just her opinion that such vague complaints are more <br /> <br />(N IC: 14 7 8:WRW:HOO2167 5. DOC.1) <br /> <br />PAGE 1 OF 4 <br />