HomeMy WebLinkAbout20190069 Artisnal Brew Works Appeal Letter 3-22-19 MEYER,
FULLER &-
STOCKWELL
LAKE GEORGE
RLLO ATTORNEYS AT LAW TITLE AGENCY
March 21, 2019
City of Saratoga Springs, Zoning Board of Appeals
City Hall
474 Broadway
Saratoga Springs, NY 12866
Re: Appeal by Quinn Borchardt Brewing, LLC d/b/a Artisanal Brew Works
Property at 41 Geyser Road, Saratoga Springs, NY
Dear City of Saratoga Springs Zoning Board of Appeals:
I am writing in follow up to the appeal for the above. Enclosed herewith please find documents
provided by the City of Saratoga Springs responsive to FOIL requests filed by this office, and
which supplement the prior record I have filed on the matter.
The FOIL response bolsters the applicant's appeal.
- See Supplement, page 12:
Zun Dra )or n.ba rneycsa ratoga-sp rIn g s.org
Re:Artisanal Brew Works
From:John Barney<johrr. me saraa-springs.ertg Wed,Sep 27,2017 C4:39 PM
Subject:Re:Artisanal Brew Works
To;Carrie Spencer<r an-ie.spencer saratoga-springs.org>
Carrie,
The Building Dept has no issues at this time regarding the Eating and Drinking License for
Artisana]Brew Works(41 Geyser Rd),
Sincerely,
John Barney
Zoning and bulidfrig Technician
1557 STATE RT. 9, LAKE G E 0 RG Er NY 12845 Phone: 518-668-219 9 www, & er fu/I rcorri
Page 12
- Supplement, page 22 which is the Building Permit dated 12/12/2016:
Total Value ofWork:1000
Total Square Feet 3383
Application Date:11/1712016 Permit issued By:SS Permit F`ae:1020.75
Scope of Work: F-2 OCCUPANCY WITH A-2 ACCESSORY`USE
Comments/Conditions:
TENANT SPACE INCLUDING BREWERY,TASTI G R I+(BAR),LAB,OFFICE AND COLDROOM.
•
yo./
ZoniV&Building Inspector
The City of Saratoga Springs has been fully aware of, and permitted, the uses that the Building
Department now seeks to curtail, namely: "The tasting room does not have approval under City
Zoning....as an eating and drinking establishment."; "...no food preparation or sale of prepared
food for consumption on the premises is permitted."; "...Retail is not a permitted use in the IND-
G zoning district, nor is an Eating and Drinking Establishment."; and"No outdoor activity such
as food vending, recreational activities, or special events associated with the brewery are
permitted on the property". All of these activities had been permitted, licensed, and allowed by
the City. However, under some "new" review, the City not only changed its stance, but the
Building Department also reduced the allowed occupant capacity within the facility.
We believe that this is part of a direct and coordinated act to bring about the closure of my
clients' business at this facility. My clients are hundreds of thousands of dollars into their
investment in this business, which has become a recognized craft brewery in New York State.
Their styles of beers have won awards at craft beer judging contests, and their value as a brand
has increased every year since they opened. If they cannot sustain the business at this location
through all of the activities that they were previously authorized to do, and again, which were
permitted and licensed, they will suffer hundreds of thousands of dollars in damages.
Lastly, one need not read far between the lines in the documents to understand where the recent
change of stance by the City of Saratoga Springs originated. My clients do not pretend to be
ignorant of the fact that they are bordered by some highly influential people in Saratoga Springs.
Indeed, in this appeal, they fully expect to feel the weight of that opposition to their business.
One need look no further than page 65 of the Supplement. However, the City permitted this
business in close proximity to SPAC and the City, as well as residential neighborhoods not far
away. The presence of a brewery with its accompanying uses such as limited food, light
entertainment and the like does not offend the City's zoning. Indeed, these uses are allowed with
the ambiguous definitions and findings already granted by the City's zoning staff. This is not to
fault the City's staff. They can only work with the legislation crafted and adopted by the City
Council. However the fact remains that this brewery use was permitted, is permitted, and the
uses including light food and entertainment are and have been allowed by the City.
1557 STATE RT. 9, LAKE G EORGE, NY 12845 Phone: 518-6 1 t rn&y rfu/i rcoi
Page 13
The Appeal must be granted. The City's Zoning Ordinance is flawed, and that flaw tilts towards
the benefit of my clients, not objecting influential neighbors.
Please be advised that we respectfully reserve all rights, claims, causes of action and damages
that accrue, and continue accrue, due to the City's recent change in zoning stance on this matter.
Sincerely,
Ado#4411,
iff V./0"41W
Matthew F. Fuller, Esq.
mfuller@meyerfuller.com
1557 STATE RT. 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 www, & er fu/I rcorri