HomeMy WebLinkAboutSP August 26, 1987
DATE: Auqust 26, 1987
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ITEMS GIVEN TO THE CITY COUNCIL
Hay,Lawsui t
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PLEASE ADDRESS THESE ITEMS AT THIS MEETING OR PUT THEM ON THE NEXT
AGENDA.
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LAW OFFICES OF
Burke aud Jlawkius
SUITE '01
299 COON RAPIDS BOULEVARD
COON RAPIDS. MINNESOTA S5433
PHONE (612) 784-2998
JOHN M. BURKE
WILLlAM~. HAWKINS
BARRY M. ROBINSON
;i rCE'VEn
l\G~~~;987lJ
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13 August 19&7
CITY OF ".NDOVF.R
Andover City Hall
1685 Crosstown Blvd.
Andover, MN 55304
Attention:
James E. Schrantz
Administrator
In Re:
Bay Lawsuit
Dear Jim:
Enclosed prease find the Anoka County District Court Order in
regard to the Summary Judgment Motion that was filed on behalf
of the City. The purpose of the Summary Judgment Motion was to
try:and get all of the Hay lawsuit dismissed. We did not expect
that the City would be dismissed since the Summary JUdgment
Motion can only be granted if there are no factual disputes.
Since there are a number of factual disputes, the Court did not
grant Summary Judgment concerning the City as a defendant.
However, the Court did dismiss all of the individual Council
members from the lawsuit. The Order is enclosed. Please
distribute same to all of the City Council members. If they
have any questions, please have them contact me.
kr;~e;)'
~G. Hawkins
WGH:d'A
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AUb .>1::li:l7
STATE OF MINNESOTA
COUNTY OF ANOKA
DISTRICT COURT
TENTH JUDICIAL DISTRICT
rSue Halvorson
Attorney at:.Law
1221 Micollet Mall Suite 700
Minneapolis, MN 55403
L
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CLERK I S NOn CE
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George C. Hoff
Attorney at Law
250 Suburban Nationp.l Bank Building
300 Prairie Center Drive
&len Prairie, MN 55344-5381 ....J
RE: Anoka District CourtFile C7-86-2739
Bruce B. Hay et al VB. City of Andover.et al
You are hereby notified that on July 31, 1987
~ Order (copy enclosed)
was duly filed
in the above-entitled matter.
Dated: 8/4/87
.JANE F. MORROW
Court Administrator
Anoka County, Minnesota
By LS
Deputy
425-REV-7-85
AUG 5 198i
STATE OF MINNESOTA
DISTRICT COURT
TENTH JUDICIAL DISTRICT
COUNTY OF AHOKA
Bruce B. Hay, Bernell Hay,
Steven Johnson, Linda Johnson,
Lesley Barnes, John O. Barnes,
and Round Lake Development Corporation,
Plaintiffs,
ORDER
vs.
City of Andover, Jerry
Windschitl as Mayor of Andover,
the City Council of Andover
and its council members, Jim
Elling, Michael Knight, Ted
Lachinski, and Ken Ortell,
Court File No. C7-86-2739
Defendants.
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'The above-entitled matter came on for hearing on July 16, 1987 before the
undersigned-JUdge of District Court on motion by defendant for summary judgment
pursuant to Rule 56 of the Rules of Civil Procedure for Minnesota District Courts.
Sue Halvorson, Esq., of Hart, Bruner, O'Brien &: 'Thorton, P.A., 1221
Nicollet Mall, Suite 700, Minneapolis, Minnesota 55403, appeared on behalf of
plaintiffs. George C. Hoff, Esq., of Hoff &: Allen, 250 Suburban National Bank
Building, 300 Prairie Center Drive, Eden Prairie, Minnesota 55344-5381,_ appeared on
behalf of defendants.
Based upon the arguments and memoranda of counsel and all the files,
records and proceedings herein, the Court makes the following:
ORDER
IT IS HEREBY ORDERED:
I. That individual defendants' motion for summary judgment on the
claims against the individual defendants is granted.
2. That defendant City of Andover's motion for summary judgment
dismissing the plaintiff's complaint against City of Andover Is denied.
Dated this :3 {S1ay
of July, 1987.
BY THE COURT:
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Lynn ~. Olson
Judge of District Court
Tenth Judicial District
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Let the attached Memorandum be made a part of this Order.
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MEMORANDUM
Plaintiffs herein brought suit against the City of Andover and other named
defendants claiming that the actions of these parties have interfered with and
effectively denied plaintiffs' constitutionally protected property rights in a special use
permit.
1. BACKGROUND AND FACTS
The present case has a rather complicated history which, for our purposes,
begins in April 1970 when Plaintiff Hay first applied to the Township of Grow for a
special use permit to construct and operate a mobile home park. In January 1971, the
application was denied solely on the basis that the Town Board had previously granted
a mobile home park permit to another property owner whose application was submitted
after Hay's.
Haybfought suit in Anoka County District Court to compel the issuance of
the special use permit. The trial court rendered a decision in favor of Hay, concluding
. that "the action of the defendants in refusing the special use permit application of the
plaintiffs. .. was discriminatory, arbitrary and capricious." (See Findings of Fact,
Conclusions of Law and Order for Judgment by the Honorable Leonard Keyes dated
August 11, 1971).
On appeal, the Minnesota Supreme Court affirmed and held that the
Township's denial of Hay's application "was not only arbitrary but also impermissibly
discriminatory, contravening the Equal Protection Clause of the Fourteenth
Amendment of the United States Constitution and Article 1, Section 2 and Article 4,
Sections 33 and 34 of the Minnesota Constitution." Hay v. Township of Grow, 296
Minn. 1, 206 N. W.2d 19, 23 (1973).
In September 1973, Hay appeared before the Grow.Township Board seeking
a variance to allow construction of a.mobile home park with an underground sewer
system under the jurisdiction of the Department of Health. Hay was required to make
a formal application for a variance and to appear personally at the Planning
Commission meeting, and, thereafter, in January 1974, the Planning Commission
considered Hay's request for a variance. Hay presented evidence demonstrating the
feasibility of his proposed system and the health and safety precautions inherent in
Health Department oversight. The Planning Commission recommended denial of the
variance. In February 1974, the Township Board, relying upon the Planning
Commission's recommendation, denied the variance request.
The Minnesota Supreme Court opinion holding unconstitutional the
Township's denial of the special use permit to Hay was rendered on March 26, 1973;
however, the Township only issued the permit on August 19, 1974. The Town Board.
then imposed conditions on the permit, among which are the following:
1. All sanitary sewer and water lines within the
... development site shall be constructed by grantee at
his own expense.
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2. No certificate of occupancy relating to any mobile
home site shall be issued unless said site or unit is
provided with municipal sanitary sewer service. In no
event shall on-site sewage disposal systems be
allowed.
3. If construction is not commenced within two years
following the availability of municipal sanitary sewer
service, this permit shall be null and void. .. The
ori~inal date of availability shall be determined by the
Township En~ineer. (Emphasis added).
There was no municipal sanitary sewer service in that area of Grow Township.
In November 1974, the Township of Grow was incorporated as the City of
Andover. A Comprehensive Plan for Sanitary Sewer and Water Facilities was prepared
by the City's consulting engineer, Toltz, King, Duvall, Anderson & Associates, Inc.
(hereinafter "TKDA"). This report identified an Urban Planning Area (hereinafter
"UPA") and suggested that sanitary sewer service could be provided in the UPA using
the available capacity of the Coon Rapids Interceptor. Hay's property was within the
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UPA. Apparently, the Coon Rapids Interceptor had already been constructed to the
south border of Andover.
In June, 1976, the Comprehensive Sanitary Sewer Plan was revised by
TKDA "to conform to Met Council policy plan for sanitary sewers" under the land use
Planning Act, Minn. Stat. S 473.851 et. seq. TKDA again reported that sanitary sewer
service could be provided to the UP A through the Coon Rapids Interceptor. Again,
Hay's property was within the UPA. The 1976 Plan also considered an alternate
proposed system, the CAB Interceptor, to serve a portion of Andover. However, the
report recommended a master plan, which included Hay's property, within an urban
service area (hereinafter "MUSA").
In spring of 1980, the City Council decided to revise the boundaries of the
MUSA which decision was reviewed at a meeting on March 18, 1980. At the meeting
the mayor also inrtiated a review of the history relative to Hay's proposed trailer park,
and noted that the chances of the western portion of the City getting service from the
CAB Interceptor in the foreseeable future "is very remote." In response to comments
from the public, the mayor stated that "if and when sewer and water is available" the
City would not be able to discriminate in providing utilities to the "trailer park." The
City Attorney also noted that "the City can do nothing to stop the trailer park if and
when sewer is available." After further comment by members of the public, Mayor
Windschitl stated that "he too has serious concerns over a mobile home park within the
City. . . ."
At that same meeting one of the Councilmen pointed out that tithe City has
had the potential to hook up to 32,000 units and has had that potential since 1975, but
has not done it."
After these discussions, the Council members passed a motion excluding
Hay's property from the Coon Rapids Interceptor Area and placing it within the CAB
area, the area where service in the foreseeable future is "very remote."
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Following this MUSA change which excluded Hay's property from the Coon
Rapids Interceptor area, TKDA, in a letter to the mayor and the City Council dated
March 31, 1980, recommended against the MUSA boundary change. On April 24, 1980
at a special City Council rezoning meeting, Hay and his attorney requested sewer
service for the special use property. Nevertheless, a rezoning proposal was drafted
shortly thereafter which had the effect of excluding Hay's property from the MUSA.
On June 23, 1980, the City Council approved the revised MUSA boundaries.
On October 20, 1980 the City submitted its Comprehensive Plan to the
Metropolitan Council. The Met Council, pursuant to its authority under Minn. Stat.
S 473.175, requested that the City reduce the acreage in its pre-1990 MUSA.
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Apparently, the City had great flexibility to amend the MUSA if development should
occur outside the pre-1990 MUSA.
At the April 7, 1981, City Council meeting, Hay and his attorney again
requested sewer service. The matter was tabled by the City Council pending an
engineering report on the feasibility of sewer service to the property. Although the
mayor asserted at that meeting that the decision to place the special use permit
property in the CAB area was made on the basis of gravity flow, the minutes of that
meeting reflect disagreement as to whether studies had been done relative to gravity
flow in that area.
TKDA prepared a feasibility study of extending gravity service to Hay's
property which recommended against the inclusion of Hay's property within the Coon
Rapids Interceptor because of difficulty of gravity service to a portion of the area
(thus necessitating lift stations), minimal lateral benefits and frost protection
concerns and because extension of service was inconsistent with the adopted and
approved Comprehensive Sanitary Sewer Plan and the approved Comprehensive Plan
for the City of Andover. TKDA's report stated that the cost of over $100,000 to
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extend the sewer was not "a reasonable and logical extension to the Coon Rapids
Interceptor. "
Council meeting, Hay offered to extend the sewer service entirely at his own expense.
Subsequent to denying Hay sewer, the City thereafter extended municipal
sewer service to several other parcels of property outside the MUSA. Plaintiff
However, by letter dated March 18, 1981, and again at the April '1, 1981,
enumerates several instances where the City extended sewer service to parcels
without amending the MUSA or trading acreage. Plaintiff contends that Defendants
Elling and Knight were councilmembers when these unauthorized "expansions" of the
MUSA were approved.
Based upon this lengthy history, plaintiffs commenced the instant action.
n. ANALYSIS
,.
Summary Judgment
Summary judgment "shall be rendered forthwith if the pleadings,
depositions, answers to interrogatories, and admissions on file, together with the
affidavits, if any, show that there is no genuine issue as to any material fact and that
either party is entitled to a judgment as a matter of law." Minn. R. Civ. P. 56.03. The
moving party has the burden of proof and the non-moving party has the benefit of that
view of the evidence which is most favorable to him. Seafirst Commercial Corp. v.
Speakman, 384 N. W.2d 895 (Minn. Ct. App.1986). All doubts and factual inferences
must be resolved against the moving party. Id. The court's function is not to decide
issues of fact, but to determine whether there are fact issues to be tried. Id.
Qualified Immunity
Dismissed of Individual Defendants
In the first instance the City asserts that the individual defendants should
be dismissed from the suit under the doctrine of qualified immunity.
Qualified immunity shields certain officials from liability in actions
brought under 42 U.S.C. S 1983 (1982). Under the standard set forth in Harlow v.
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Fitz~erald, 475 U.S. 800, 102 S.Ct. 2727 (1982), "government officials performing
discretionary functions generally are shielded from liability for civil damages insofar
as their conduct does not violate clearly established statutory or constitutional rights
of which a reasonable person would have known.n The rationale of the qualified
immunity defense is that public officials with a broad range of duties and
responsibilities must be able to execute those responsibilities without undue risk of
civil liability. In Harlow, the Court explained:
If the law was clearly established, the immunity defense
ordinarily should fail, since a reasonably competent public
official should know the law governing his conduct.
Nevertheless, if the official pleading the defense claims
extraordinary circumstances and can prove that he
neither knew nor should have known of the relevant legal
standard, the defense should be sustained. But again, the
defense would turn primarily on objective factors.
Id. at 818-19, lO~ S.Ct. at 2739
Thus, if the trial judge determines that the law was not clearly established
at the time the conduct occurred, the inquiry ceases. At that point, the official is
entitled to summary judgment as a matter of law. Id. at 818, 102 S.Ct. at 2738-39.
In Hebson v. Wilson, 737 F.2d 1, 26-27 (D.C. Cir. 1984), the Court
established a step by step process as follows:
[ A ]ssume plaintiff alleges that defendant violated Right
X, and defendant moves for summary judgment on grounds
of qualified immunity, claiming Right X was not well-
established when the alleged acts were committed and,
alternatively, that extraordinary circumstances prevented
him both from knowing and having reason to know the
relevant legal standard. If the district court judge
determines as a matter of law that Right X was well-
established, a question of fact might still remain as to
whether defendant reasonably neither knew nor should
have known of it. The first issue is purely legal and
should be susceptible to initial determination on the
complaint and summary judgment papers. The latter is
potentially an issue for trial, depending upon the unique
circumstances of each case.
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Accordingly, the first question before the Court is whether or not the right
plaintiffs assert was well established or whether, alternatively, extraordinary
circumstances preventing "defendants from knowing the relevant legal standard.
The Court agrees that plaintiffs' constitutional right to a special use
permit was expressly spelled out by the Minnesota Supreme Court in Hay v. Township
of Grow. In this case, however, plaintiffs were granted a special use permit. Hence
the question becomes whether defendant's continuing requirement that municipal
sewer service be connected before plaintiff develop the mobile park, coupled with the
City's denial of municipal sewer connection, in effect violated plaintiffs' constitutional
right to the special use permit. The entire controversy in the instant action rests upon
a determination of whether defendants' actions with respect to the availability of
municipal sewer service to plaintiff Hay had a rational basis, as defendants contend, or
whether such actions were, as plaintiffs contend, a deliberate effort to frustrate the
special use permit.
It is well settled that applicants for permits state substantive due process
claims if they allege the governing authorities capriciously and arbitrarily imposed an
unconstitutional condition on the granting of a permit. See, Littlefield v. City of
Afton, 785 F.2d 596 (8th Cir. 1986). However, to say that a due process claim exists is
not the same as saying that a clear violation of well-established law exists.
Viewing the circumstances of the present case, the Court cannot find here
the clarity required by the Harlow standard. Absent such clarity, the Court believes it
is compelled to grant summary judgment to the individual defendants.
City of Andover
Substantive Due Process Claims
and Equal Protection
Plaintiffs also claim that defendants' arbitrary and capricious actions have
denied plaintiffs' constitutional rights to substantive due process and equal protection.
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Plaintiffs entitlement to a special use permit for development of a mobile
home park was declared by the Minnesota Supreme Court's decision in 1973. As
previously indicated, a claim that governmental authorities arbitrarily imposed an
unconstitutional condition on a permit states a substantive due process claim. See,
Cunnin~ham v. City of Overland, 804 F.2d 1066, 1068 (8th Cir. 1966). Subsequent to
this Court's decision in Hay v. Township of Grow, defendant City did grant a special
use permit, however one which conditioned the development of the park upon the
extension of municipal serves service to the park. Thereafter, plaintiffs were unable
to obtain the required sewer service based upon the City's decisions relative to that
matter. Plaintiffs have presented an ample factual record of events and actions
whereby reasonable persons could differ as to whether or not defendant City's actions
had a rational basis or whether in fact, such actions were, as plaintiffs claim,
arbitrary, capricious and discriminatory. Defendants have denied a variance. They
have rezoned the lines for sewer service, denied sewer connection, and refused to
amend the MUSA line for plaintiffs. Yet defendants have allowed MUSA amendment
and sewer extension to others. Based on this record the Court concludes that genuine
issues of material fact are presented and defendant City of Andover's motion for
summary judgment as to the City of Andover is denied.
Constitutional Taking Claim
Defendants also seek summary judgment dismissing plaintiffs' claims that
the actions of the City constitute a taking of their property without compensation.
The Courts have consistently held that where government activity causes a
definite and measurable decrease in the value of plaintiffs' property and interferes
with the current practical enjoyment of the property, a compensable taking has
occurred. McShane v. City of Faribault, 292 N. W.2d 253 (Minn. 1980). However, the
right to use property as one wishes is subject to and limited by the proper exercise of
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the police power in the regulation of land use, and such regulation does not constitute
8 compensable taking unless it deprives the property of all reasonable use. Euclid v.
Amber Realty Co., 272 U.S. 365, 47 S.Ct. 114,71 L.Ed. 303 (l926).
Defendant City argues that summary judgment is warranted as to the
taking claims because Hay, in fact, has not been deprived of all use of his property.
According to defendant, the property is zoned to allow for development of single
family residences.
However, the Court finds that questions have been raised as to whether the
City of Andover in fact properly exercised its police power. If at trial it is determined
that the City's police power was improperly exercised, such improper exercise may
have resulted in a taking. Thus, genuine issues of material fact are presented in this
case which obviate the granting of summary judgment.
Laches
Defendant City further seeks summary judgment on the ground that
plaintiffs' claims are barred by the doctrine of laches. In order to prove laches, the
person asserting the defense must show inexcusable delay in asserting a right and that
the delay caused undue prejudice to the party asserting laches. City of St. Paul v.
Hardin~, 356 N. W.2d 319 (Minn. App. 1984). The Court agrees with plaintiff that the
doctrine of laches is not applicable in the present case. Plaintiffs base their claim,
not upon a single decision, but rather upon an alleged repeated and continuing series of
decisions made by defendants, up to and including decisions made in 1986. Based upon
these allegations of continuing illegal conduct, the Court concludes that plaintiffs are
not barred by laches.
Standing
Defendants also challenge plaintiffs' standing to raise the issue of low
income housing. In Worth v. Seldin, 422 U.S. 490, 95 S.Ct. 2197 (l975), the Supreme
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Court reviewed the constitutional limitations and considerations that guide a court in
determining a party's standing. The essence of the standing question is "whether the
plaintiff has 'alleged such a personal stake in the outcome of the controversy' [ as] to
warrant his invocation of. . . jurisdiction and to justify exercise of the court's
remedial powers on his behalf." Id., at 498-499, 95 S.Ct. at 2205, quoting Baker v.
Carr, 369 U.S. 186,204,82 S.Ct. 691, 703 (1962). The plaintiff must show that he
himself is injured by the challenged action of the defendant. The injury may be
indirect. See, United States v. SCRAP, 412 U.S. 669, 688, 93 S.Ct. 2405, 2416 (1973).
But, the complaint must indicate that the injury is indeed fairly traceable to the
defendant's acts or omissions. Simon v. Eastern Ky Welfare Rilrhts Orlr., 426 U.S. 26,
41-42,96 S.Ct. 1917, 1925-26 (1976).
The Court believes that Villalre of Arlinlrton Heijrhts v. Metropolitan
Housinlr Development Corporation et. al., 97 S.Ct. 555 (1977), a case similar in some
respects to this one, provides the governing law. In Arlinlrton Heilrhts, the Court held
that a real estate developer, which had contracted to purchase a tract of land in order
to build racially integrated low and moderate income housing, met constitutional
standing requirements in its suit charging local authorities of racial discrimination for
refusing to rezone the tract. Id., at , 97 S.Ct. 561. The Court specifically
found the real estate developer had shown an injury to itself that is likely to be
redressed by a favorable decision. ~ at , 97 S.Ct. 561. This is precisely the
situation presented here. In light of the standard established in Arling-ton HeiJrhts, the
Court concludes that plaintiffs have met the constitutional requirements and therefore
have standing to assert its own rights respecting the issue of low income housing.
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CITY of ANDOVER
SPECIAL CITY COUNCIL MEETING - AUGUST 26, 1987 - AGENDA
7:00 P.M. Planning Commission Interviews
1. Harold Sullivan
2. Rebecca L. Pease
7:30 P.M. 1. Call to Order
2. Fire Station Report
3. Police Department Report
4. City Hall Report
5. Animal Control Contract
6. Purchase/Lease Copy Machine, Postage Meter,
Telephone System
7. Special Assessment Manual
8. Assessment Policy/Cost for Curb & Gutter/County
.Urban Streets
9. Joint Powers Agreement/Crosstown/139th Ave. to Coon
Creek
10. HRA Bylavls
11.
12. Adjournment
Future Items
Dehn's Streets
MSA Designation/university Ave. North of l57th & Crosstown
Anoka Drainage Agreement/Dehn's
Ordinance 8 & 10
Personnel Items: Compensation Plan: Paternity/Maternity
Policy: Eng. Technician Reclassification
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CITY OF ANDOVER
REQUEST FOR COUNCIL ACTION
DATE Auqust 26, 1987
AGENDA SECTION
NQ P&Z Interviews
ORIGINATING DEPARTMENT
Administration
APPR~VE~OR
AGEN"A
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BY: II
V
ITEM
NO.
BY: Vicki Volk
The following interviews for the Planning Commission have
been scheduled:
Harold Sullivan
7:00 P.M.
Rebecca Pease
7:15 P.M.
I spoke to Bill Bernard and he is anxious to serve on the
Commission.
MOTION BY
TO
COUNCIL ACTION
SECOND BY
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H..lgUst 11, 1987
Ci ty of Andover
clo City Clerk
1685 Crosstcw1 Blvd. I\W
A-tdover, t1innesota ::,.'::i.J>4
Dear City Council Members:
I am applying for cne of yeur '...."'D3rlcies en the Pla_Clning and Zoning
Ccmnissicn..
t.;.,' primar.l rea~on for interest in this area is th.~:t in order to
continue to g~ A-tdover in 2. reasone.bl y organized manner proper
planning llLISt occur now. A-1dov-er is a growing camunity--and fast.
We moved into our home 1 1/2 years ago after OWling the lot for a few
years prior to this. I have noticed the t-uge increase in t"Dusing
starts and businesses during this time. Ccmrunities, as well as
tusinesses, need ton plan ahead and be pruactiv-e instead of reactive.
I believe that my e>:perience will help in the planning of OLlr
c:cmJU"1i ty .
My e:.:perience and e;.:pertise include the following:
* CPA certification
* Product develDfIDE"lt accounting consultant
* Department manager of Open Syst9.~, Inc. for 4 y-ears
* PrevioJS t---.....isiness. e>~p-=:ier:ce inclLtded Control Data. and Lhivac
* &tsiness o..--ner and frk?.:!2ger of s'n3.11 retail shop in Cocn Rapids
for 7 years
* r~nse in 9~siness h~miri5tr2tic~/Hcco~~ting from Lhiversity
of Minnesota
*' Degree in !"'.athematics 2nd BiolCX;y fran t12ry'"ount College ~..
Kansas
*' High sctuol math and sc~ence teacher ~n St. LOLlis
If YCH have any questions. plea.52 ccntact me.
Yours truly,
e~a{1~ ~12-<l'./
R:;S;:: L. Pease
~'oo 152nd Lane f\.I.-J ?:ndO\r-er ~ I":h. SS::::.(k4
I-bme phone 427-1845 W::J,k prone 8:::'9-1458
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CITY OF ANDOVER
REQUEST FOR COUNCIL ACTION
DATE
Auqust 26, 1987
Administration
FOR
ORIGINATING DEPARTMENT
ITEM
NO.
BY: Vicki Volk
BY:
Attached is information regarding a new copy machine and postage
meter, both from Pitney-Bowes.
We recently had the copy machine at City Hall for demonstration
purposes and everyone who used it was impressed with it.
The copier I would recommend would be the one listed as System II.
Our present copy machine was intended for a company that makes
up to 3,000 copies per month. Our average per month since the first
of the year is 15,000 copies.
The postage meter that would best serve our needs is shown as System
IV. This meter includes a 5 pound electronic scale, which would be
helpful as our scale is no longer accurate, having been dropped on
the floor many times. *
Mr. Schrantz has the information on the telephone system.
*I was told that 20% of the money used for postage is wasted due
to faulty scales.
COUNCIL ACTION
MOTION BY
TO
SECOND BY
~'.\ :.
o ~I~ ~~~~?~es
August 12, 1987
Victoria Volk
Ci ty of Andover
1605 Crosstown Boulevard
Anoka MN 55303
Dear Victoria:
System I
D640 Copier with automatic feed, sorter, stand, set-up supplies,
training, delivery, and 90 day warranty.
Purchase
Rental (includes service and 15,000
copies per month)
$7,870.00
$711.00/Month overage - $.011
Lease (own equipment at lease end - no buyout)
36 Month Lease
$310.00 Month
$ 2 6 1. 00 Mo nth
$230.00 Month
48 Month Lease
60 Month Lease
"'-J System II
D640 Copier with automatic feed, sorter, duplexing, stand, set-up
supplies, training, delivery, and 90 day warranty.
Purchase
Rental (includes service and 15,000
copies per month)
$8,975.00
$446.00/Month overage - $.011
/fr;
Lease (own equipment at lease end - no buyout)
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36 Month Lease
$356.00 Month
48 Month Lease
$299.00 Month
60 Month Lease
$262.00 Month
8161 Normandale Blvd. Minneapolis, MN 55437-1087 612835-2221
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o ~ Pitney Bowes
Service
15,000 copies x 9 months = 135,000 copies
135,000
(less 90 day warranty)
x .0114/per copy
Point of sale first year discount
$1,539.00
10%
$1,385.10
15,000 copies x 12 months =
divided by
180,000 copies
.0077/per copy
System I
Peripherals
$26.00 x 9 months = $234.00
Point of sale first year discount 10%
$210.60 per year
System II
Peripherals
$36.00 x 9 months =
$324.00
Point of sales first year discount - 10%
$291.60 per year
Supplies
Includes printpowder and developer
$.005171""7
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~ Pitney Bowes
System I
6264 Roll Tape Semi Automatic Mail Machine interfaced to a 5820 5
Pound Electronic Scale, priced with 1831 Folder.
$161.00/Month
System II
Above system with no folder.
$128.00/Month
System III
6262 Strip Tape Semi Automatic Mail Machine interfaced to 5820 5
Pound Electronic Scale, priced with 1831 Folder.
$145.00/Month
""l Sys tern IV
Above system with no folder.
$111.00/Month
Government meter rental is a flat rate of $46.17 per month billed
quarterly or annually.
Meter reset charge of $6.00
Pricing includes trade in 5830 Sealer.
Monthly Maintenance
6264 Mail Machine
6262 Mail Machine
5820 Scale
1831 Folder
System System I I I
16
11
9 9
12 12
Yearly Maintenance
6264
6262
5820
1831
175
122
90
130
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~ Pitney Bowes
1.
2.
3.
4.
5.
6.
7.
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6264 Semi Automatic Mailing Machine
Feeds 40-60 pieces per minute.
Medium volume (lower end) mail machine
Feeds post card size to manila envelopes.
Roll tape.
True sealing machine.
Tape brush unit is removeable for self maintenance.
Auto on/auto off.
Continuous run mode.
Seal/no seal control.
Ink cartridge up to 30,000 impressions.
Positive envelope shipment control.
Water level indicator.
RMRS meter compliments mail machine.
Interface to electronic scales and accounting systems.
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EMS-5 POUND SCALE
1. EMS-5 Pound Electronic Scale weighs envelopes and packages up
to 5 pounds.
2. Interfaces to Pitney Bowes mail machine to control operator
error and prompt mail machine to change meter to proper
postage and or produce a tape for a parcel.
3. Color coded for quick easy operation with association.
4. Rate shop with First Class/Priority Mail, International Third
Fourth Class, Special Delivery, Return Receipt, Certified,
Registered and Insured Mail.
5. Able to add Express Mail rates if needed.
6. Converts Zip-to-Zone automatically.
7. Operator is able to easily and quickly change PROMs to meet
new postal rates.
8. Remains in desired class unless change is prompted by
operator (no need to program class wanted for each piece of
weighed mail)l
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Benefits of Leasing
Pitney Bowes Credit Corporation is designed to offer you unique
benefits. The lease provides maximum flexibility to make
immediate use of the proposed equipment while allowing you to
change equipment as either needs or technology change. An
Equipment Replacement Option is available that releases you from
the last six monthly payments should you elect to replace your
equipment at that time.
Leasing affords the ability to acquire a complete system with only
a minimum initial investment, thereby allowing your company to
take advantage of the total benefits of the proposed system.
The PBCC lease offers you one source responsibility. On a single
invoice you can include any or all of the following: equipment
cost for one or more leases, Equipment Maintenance Agreement cost,
or your internal purchase order numbers or identification codes.
Thus, your administrative cost is reduced and bookkeeping is
convenient.
Leasing allows you to conserve your company's cash.
be used for other investments.
It can then
Leasing provides a hedge against inflation. Our fixed lease
payments protect you against inflationary increases.
Leasing also preserves your company's credit line. With leasing,
equipment can be acquired without tying up your credit line.
Leasing provides effective budget management since equipment and
maintenance costs remain constant throughout the term.
A State and Local Government lease follows all Minnesota
regulations including the following: customer has the right to
cancel the lease if a new budget does not permit funding of the
equipment and the customer has no buyout at the end of the lease.
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