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4. The Borough Council is the governing body of the borough and the Shippensburg
Borough Planning Commission ("Commission") is an appointed body to which the Borough
Council has delegated the review and approval of preliminary subdivision and land development
plans.
5. Appellant, Senior Cottages, is the legal title holder to certain real estate
comprised of approximately 17 acres located along Baltimore Road, Shippensburg, Cumberland
County, Pennsylvania by deed dated March 29,1996 and recorded in the Office of the Recorder
of Deeds in and for Cumberland County, Pennsylvania on December 23, 1996 (the "Property").
6. On or about late September, 1996, Senior Cottages' engineer, Frederick Seibert
and Associates, Inc. met with Borough stalT to discuss a sketch plan for the Property pursuant to
Section 501.01 of the Subdivision and Land Development Ordinance of the Borough of
Shippensburg (herein the "Subdivision Ordinance"), which showed the site layout for 120 one-
story residential units for senior citizens,
7. On or about October 9, 1997, Senior Cottages' engineer attended a meeting of
Borough Council and stalTto discuss the sketch plan.
8. On or about November IS, 1996 the Shippensburg Borough Authority
("Authority") provided notice to Senior Cottages that pursuant to its meeting of November 12,
1996 the sewage module was approved for the Property. A copy of the correspondence
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22. At its regularly scheduled mecting on March 12, 1997, the Commission
acknowledged that the conditions set forth in the February 12, 1997 decision had been fully and
finally satisfied by Senior Cottages.
23. As the Preliminary Plan approval was granted by the Commission and the
conditions set forth by the Commission were satisfied by Senior Cottages, the Preliminary Plan
as filed is approved pursuant to the requirements of the Subdivision Ordinance.
WHEREFORE, Appellant requests this Honorable Court to issue an Order
affinning approval of the Preliminary Plan of Appellant.
COUNT II-IMPROPER DENIAL
24. Paragraphs I through 23 are hereby incorporated by reference as though fully set
forth at length herein.
25. The decision of the Borough Council was arbitrary, capricious and an abuse of
discretion, in that it has no authority under the Pennsylvania Municipalities Planning Code or its
own Ordinance to deny a Preliminary Plan.
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26. Article V of the Ordinance clearly and unambiguously delegates all powers as to
the review and approval of preliminary subdivision and land development plans to the
Commission.
27. Moreover, the notice of denial provided by Borough Council is deficient as noted
in Count III below for failure to meet the requirements of 53 P .S. ~ I 0508 as nowhere in the
notice of decision does the Borough Council specify the deficiencies in the Preliminary Plan or
cite to provisions of the Subdivision Ordinance as the basis for the denial.
WHEREFORE, Appellant requests this Honorable Court to issue an Order affinning
approval of the Preliminary Plan as filed.
COUNT 1/1- DEEMED APPROVAL PURSUANT TO 53 P.S. f10508
28. Paragraphs 1 through 27 are hereby incorporated by reference as though fully set
forth at length herein.
29. The Planning Code provides that "[w]hen the application is not approved in tenns
as filed the decision shall specifY the defects found in the application and describe the
requirements which have not been met and shall, in each case, cite to the provisions of the statute
or ordinance relied upon." 53 P.S. ~ 10508(2).
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WHEREFORE, Appellant requests this Honorable Court to issue an Order affinning
approval of the Preliminary Plan of Appellant.
Respectfully submitted,
MElTE, EVANS & WOODSIDE
By:
y~~~.e
Paula J. LeiC' t, E quire
Sup. Ct. I.D. No. 42585
Daniel M. Cwnpbcll, Esquire
Sup. ClI.D. No. 72689
340 I North Front Street
P.O. Box 5950
Harrisburg, PA 17110-0950
(717) 232-5000
DATED: March 20, 1997
Attorneys for Appellant
Senior Cottages of America, LLC
96023 I
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SHIPPENSBURG
WIllIAM W, WOlII
Io<ougn 101_'
W, DWAYNI DflGAANDI,"',
DlrlCtor 01 h1b1O"_
ROIEAI C, WEAVER
C_ EnlooellMllt OIIIC.'
OA/oCI.... Kt~IA
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ICROUGH OF 'III'PENSlURG
~W,I~dSIr",
P.O. lox 129
IIl/ppenIllwg. PA 17257.0129
(717) M2-21.7
FAX . (717) 632-6'1'.
November 15, 1996
Frederic M. Frederick, R.L.S., P.!.
Frederiok, Seibert and Associates, Inc.
128 South Potomac street
Hagerstown, Maryland 21740
Re: Senior cottages of America
Dear Mr. Frederick:
I am writing to inform you that the Sllippensburg Borough
Authority, at its NOVOlllber 12, 1996, meeting, took action to allow
the signinq of the sewago Module for the abovo-referenced project.
Please, at your convenience, llIa)(e arrangeDients with me to sign
the module.
Should you have any questions, please don't hesitate to
contact me.
sincerely,
1At- :#' ~
william W. Wolfe
seoretary
liWW:))lv
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ARTICLE V
PJ,AN PROCESSING PROCEDURES
Section 501 Pre-Appllcntlon Review. The purpose of the pre-application meeting or
sketch plan review is to affordlhe applicant the opportunity to receive the
advice and assistance of lhe Municipality's staff. Such meeting and/or
review shall be considered as confidential between the applicant and slaff.
501.01 Required Pre.Applicntlon Review. Proposals for possible development
of sites into subdivisions of more lhan twenty (20) lots or which involve
the crealion of new slreelS and plans for the development of retail,
industrial or office slnlclures shall be discussed with the staff of the
Municipality and sketch plans shall be submilled for review prior to
submission of Preliminary Plans, Submission of a Sketch Plan shall not
constilUle a formal filing of a plan with the Municipality. However, the
applicant may request, in writing, a formal review by the Commission, in
which case the Commission will take action, discuss the plan at a public
meeting, and comment by leller. Generally, staff reviews will be
scheduled within fifleen (15) consecutive days from the date of the
Municipality's receipt of the request, but shall not exceed 30 days. If the
applicant requesls a formal review of a Sketch Plan by the Commission,
the plan shall be reviewed at a public meeting within ninety (90) days of
the receipt hy the Commission of the malerials for review. Generally,
such plans will be schcduled for review within thirly (30) days of lhe
Commission'.s receipt of such malerials.
501.02 Optional Pre-Application Review. Applicanls are urged, but not
required, to discuss olher lypes of proposals and submit Skelch Plans for
review.
Section 502 Preliminary Plan Applications. With the exceptions specifically noted in
this Ordinance, a Preliminary Plan is required for applicalions which
propose new streets, all land development plans, as defined in Section
602, and subdivision plans of len (10) or more lots. All other plans may
be suhmilled as Final Plans in accordance with Seclion 603.
502.01 Application Reqnil'ements. All Preliminary Plans shall include the
following:
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A. Ten (10) copies of the Preliniinary Plan, plus one (1) additional copy
if Ihe sile is within 1000 yards of a municipal boundary, plus one (I)
additional copy if lhe site abuls a Slale Road. All plans shall be eilher
black on white or blue on white paper prints.
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502.02
B. Two. (2) copies of all reports, notificalions and'certlficatlons which arc
not provided on the Preliminary Plan, including storm water management
plans and calculations.
C. One' Application Form (see Appendix 24.) completely and correctly
executed with all information legible, and bearing the required signatures.
D. Filing fee (see schedule of fees available at the office of the
Municipality). Note: A separate filing fee must be submitted with each
application. If one check Is Issued for multiple plans, a detailed
breakdown of the individual fee assessment must accompany Ihe payment.
In addition to the filing fees required hereunder, Ihe Commission and/or
Borough shall require a deposit from the applicant in an amount It shall
determine necessary for the cosls Incured by the Commission and/or
Borough on account of engineering fees, administrative cosls and legal
review.
E. Notification signed by Ihe zoning officer thatlhe proposal Is generally
in conformance with applicable zoning regulations, and Ihat If any zoning
variance, special exceplion, or conditional use Is required that such
approval has been granted or the slatus of any such application which has
not been granted. A copy of the decision of Ihe Zoning Hearing Doard
of Shlppcnsburg, including all conditions imposed. shall be submitledlo
Ihe Commission as pari of thc Preliminary Plan Application.
F. Incomplete Applications. A preliminary plan application shall be
accompanied by all required plans and documents and the required filing
fee. The Manager or Ihe Manager's designee shall have seven (7) days
from tbe dale of submission of an application to check the plans and
documents to determine if on their face they arc In proper form and
contain all the information required by this Ordinance. If defeclive, the
application may be returned to the applicant with a stalement' Ihat the
application is incomplete within the seven (7) day period: otherwise Ihe
applicalion shall be deemed accepted for filing as of Ihe date of
submission. Acceptance shall not.. however. constitute a waiver of any
deficicncies or irregularilles. The applicant may appeal a decision by Ihe
Manager under this Section to the Planning Commission in accordance
wilh Section 1105 of Ihis O.rdlnance.
Plan Requiremcnts. All Preliminary Plans shall be prepared in
conformance with Ihc provisions of Seclion 602 of Ihis Ordinance and any
other applicable requiremcnt or law.
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502.03
Distribution, The Commission shall distribute one (I) copy of the
Preliminary Plan to each of the following individuals:
A. Municipal secretary or manager.
n. Municipal planning commission secretary.
C. Fire company.
D. Electric company.
E. Telephone company.
F. Gas Company.
G. Pennsylvania Department of Transportation (if the subject
site abuts a State road).
H. Pennsylvania Department of Environmental Resources.
I. Cumberland or Franklin County Planning Commission
(two [2] copies).
J. Adjoining municipality (if site is located within one thousand
[1000] yards of a municipal boundary).
The Commission will also notify the landowner, applicant, finn
that prepared the Plan, municipal solicitor, municipal engineer,
and school district of the filing of the Plan.
502.04
Commission Action. The Commission will schedule the
Preliminary Plan applicalion for action at a regularly scheduled
public meeting within ninety (90) days of the first public meeting
of the' Commission after the date of filing.
In general. the Commission will schedule the Preliminary Plan
application for action at the first Commission meeting which is at
least sixteen (16) business days following filing.
502.05
Notification of Commission Action. Within fifteen (15)
consecutive days after lhe meeting al which the Preliminary Plan
is reviewed, the staff shall send wrillen notice of the Commission's
IIction to the following individuals:
A. Landowner or his ngen!.
n. Applicant.
C. Finn that prepared lhe plan.
D. Municipal secretary (jr manager.
E. Municipal planning commission secretary.
F. Municipal engincer (only at the request of the
municipality),
G. Municipal solicitor (only at the request of the
municipality).
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If the application is disapproved, the Commission will notify the
above individuals, in writing, of the defects in the application and
will identify the requirements which have not been met, citing the
provisions of the statute or ordinance relied upon.
502.06
Compliance with Commission Action. If the Commission
conditions its Preliminary Plan approval upon receipt of additional
information, changes, and/or notifications, such data shall be
submitted and/or allerations noted on two (2) copies of the Plan to
be submitted to the Commission for approval by the staff. All
correspondence and copies of the plan shall reference the PlaMlng
Commissions file number.
502.07
Commission Apllroval and Certification. The Commission will
acknowledge the satisfactory compliance wilh all conditions, If
any, of the Preliminary Plan approval at a regularly scheduled
public meeting. All materials to be considered by the Commission
at such meeting shall be submitted by the applicant to the
Commission's staff atlesl fourteen (14) days prior to the meeting.
Addilionally, at the option of the applicanl, after receipt of
Preliminary Plan approval and compliance with all conditions of
approval, a Preliminary Plan may he presented to the Commission
for acknowledgementlhrollgh a formal slatement on the Plan. (See
Appendix 17.)
Approval of a preliminary application shall constitute approval of
the proposed suhdivision and/or land development as to the
character and intensity of development and the general
arrangement of streels, lOIS, SlmclUres, and other planned
facilities, but shall not constitute Final Plan approval. The
Preliminary Plan may not be recorded In the office of the
Cumberlaml or Franklin County Recorder of Deeds. . '
Preliminary Plnn approval will be effective for a five-year period
from the dale of lhe Commission's approval of the Preliminary
Plan application; lherefore, Final Plan applications for the entire
project must be made wilhin five (5) years of Preliminary Plnn
approval unless the Commission grants a waiver by extending the
effective time period bf the approval.
The Applicanl may, arler receipt of ncknowledgment from the
Commission of Ihe satisfaclory completion of any conditions of
Preliminary Plan approval, proceed to conslmctthe Improvemenll
required by the Ordinance and shown on the approved Preliminary
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Preliminary Plan shall be submitled.
503.01
Application Requirements.. All Final Plan applications shall
include the following:
A. Nine (9) copies of Ihe Final plan, plus one (1) addlllonal
copy If lhe slle is wilhln one Ihousand (1000) yards of a
municipal boundary and one (1) addllional copy If Ihe sile
abulS a Slale road. All plans shall be ellher black on while
or blue on while paper prinls.
B. Two (2) copies of all reports. nOlificalions and certificales
which are nol provided on Ihe Final Plan, including slonn
waler managemenl plans and calculalions.
C. One (1) correcl and complele application fonn. (See
Appendix 24.)
D. A filing fce shall accompany Ihe Final Plan, consisling of
a check or money order drawn 10 Ihe Borough of
Shippensburg Treasurer (See fee schedule available al the
Commission). Nole: A separale filing fee musl be
sub milled for each applicalion. If one check is issued for
mulliple plans. a delailed breakdown of Ihe individual fee
. assessments musl accompany the paymen!.
E. Nolificalion signed by Ihe municipal zoning officer Ihat Ihe
proposal is generally In conformance wilh applicable zoning
regulations, and Ihal if any zoning variance, special
exception, or conditional use is required Ihat such approval
has been granled or Ihe slatus of any such applicallon
which has nol been granled. A ,copy of the zoning
variance, including all conditions imposed. shall be
submllled 10 Ihe Planning Commission as part of any
Preliminary Plan application.
P. One (1) copy 'Cfall applicable supplemenlary dala, nolices
and cerlificales required in Seclions 603.04 and 603.05 of
lhis Ordinance.
G. One (1) verificalion form (see Appendix 33).
n, A Final Plan application shall be accompanied by.. all
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public meellng wilhin ninety (90) 'days of lhe first public
meeling of Ihc Commission after the dale of filing.
In genernl, lhe Commission will schedule the Flnal Plan
applicntion for nClion at lhe first Commission meeting
which is alleast sixteen (16) business days following filing.
However, a municipality may request the Commission to
delay action on the application up to ninety (90) days from
the dale of filing to allow for the submission of lIS
comments 10 the Commission. Final Plan approval will be
effeclive for ninety (90) days from the date of the
Commission's nClion on the Final Plan, unless the
Commission granls a waiver by extending the effeclive time
period of lhe approval. Wilhin this time period the
applicaat; must meet all conditions of approval, if any;
certify plans as specified in this Ordinance; and record
plans as speci fied in this Ordinance.
503.05
Notification of Commission Action. Within fifteen (IS)
consecutive days after the meeting at which the Final Plan
is reviewed, the slaff shall send wrillen nOlice of the
Commissioa's aClion to the following:
A, L1ndowner or his agent.
n, Applicant.
C. Firm Ihat prepared the plan.
0, Municipal secretary or manager.
E. Municipal planning commission secretary.
F. Municipal engineer (only atlhe request of the
municipality).
G, Municipal solicitor (only at the request of the
municipality).
II. Cumberland or Franklin County Recorder of Deeds.
503.06
Compliance wilh Commission Action. If the Commission
conditions its Final Plan approval upon receipt ofaddltional
informal ion, changes, andlor notifications, such data shall
be submilled andlor alteralions noted on two (2) copies of
the plan to be'submiued to the Commission for approval by
the slaff.
503.07
Final I'lall Certification. After the Commission's
approval of lhe Final Plan and the required changes, if any,
are made. lhe applicant shall proceed to prepare two (2)
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reVISion, the slaff will, in wriling, advise the
applicant whelher or not the revision complies with
Ihe slandards of Seclion 603.04 of this Ordinance.
B. If the revision complies, the applicant shall prepare
IWO (2) Plans, which shall be transparent black line
reproductions of the original plan and one (1) set of
paper copies of the Plan for the Commission's files,
and which shall specifically identify the alteration(s)
to lhe previously recorded plan.
C. The applicant shall lhen submit lhe Plan to the
municipal secrelary or authorized municipal official
for certification as specified in Section 503.08 of
this Ordinance and the Commission for signature as
specified in Section 503.09 of this Ordinance. (See
Appendices 22 and 19).
D. The Plans shall lhen be recorded as specified in
Seclion 503.10 of Ihis Ordinance.
E. Prior to any rerecording, a note shall be placed on
the replat specifying the Record Plan Book number '
of the original final plan,
SECTION 505
, Minor Land Dcvclopment Plans. Land developments
which involve a single, nonresidential structure on a
previously approved and recorded lot or, Ihe provision of
a second principal building on a lract or parcel which
currently conlains a single principal building, or
development of a single tract or parcel of land which
involves a single building containing nol more than four (4)
units of occupancy may be submitted as final plans in
accordance with the provisions of this Ordinance.
All land development plans which do not meel the above
criteria shall be submitted in accordance with Section S02
of this ordinance.
SECTION 506
Lot Add-On Plans.A plan which proposes 10 alter Ihe
local ion uf lot lines belween existing lots of separale
ownership for the sole purposc of increasing 101 size.
506.01
Lot Add-On Requlrcments. Lot Add-on Plans shall only
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Commission shall review the request ~o detennine if the
Iiteml compliance with any mandatory provision of the
Ordinance is demonstrated by Ihe applicant to exact undue
hardship or to be unreasonable, or that an alternative
standard has been demonstrated to provide equal or beller
resulls, provided that such modification will not be contrary
to lhe public inlerest and that the purpose and intent of this
Ordinance is observed. The applicant shall demonstrate
that the alternative proposal represents the minimum
modification necessary. If the Commission detennlnes that
the applicant has met his burden, it may grant a waiver
from lhe literal compliance with the tenns of this
Ordinance.
507.03
Notification of Commission Action. After the meeling at
which the waiver was reviewed, lhe Commission shall send
notice of the Commission's action to the following
individuals:
A. Landowner or his agent.
n. Applicant.
C. Finn lhat prepared the plan.
D. Municipal secrelary.
E. Municipal planning commission secrelary.
F. Municipal solicitor (only atlhe request of
lhe municipality).
G. Municipal engineer (only at the request of
the municipality.)
If lhe Commission denies lhe request, The Commission will
notify the above individuals, in writing, of the justification
for denial. If the Commission grants the request, the Final
Plan shall include a note which identifies the specific
waiver as granled.
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CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing document upon
the person(s) and in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of
same in the United States Mail at Harrisburg, Pennsylvania, with first-class
postage, prepaid, as follows:
Forest Myers, Solicitor
Borough of Shippensburg
P.O. Box 129
Shippensburg, PA 17257-0129
METrE, EVANS & WOODSIDE
By:
~~9'~
Paula J. Icht, squire
Sup. Ct. I.D. No. 42585
3401 N. Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
(717) 232-5000
Attorneys for Appellant
Senior Cottages of America, LLC
DATED: March 20, 1997
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