HomeMy WebLinkAbout2016-07 Ordinance 2016-07
Ordinance Amending the Zoning Regulations
For the Board of Zoning Appeals
WHEREAS, the provisions of the Code of Virginia governing boards of zoning appeals
were amended by the 2015 General Assembly; and,
WHEREAS, that portion of the Zoning Regulations of the Town of Pulaski dealing with
the Board of Zoning Appeals required amending and updating to bring the Town's
regulations into compliance with the changes in state law; and,
WHEREAS, the Planning Commission and Town Council conducted duly noticed public
hearings on February 8, 2016 and March 1, 2016 respectively, wherein public
comments were received and considered concerning amending provisions of the Board
of Zoning Appeals regulations;
NOW, THEREFORE be it ORDAINED by the Town Council of the Town of Pulaski,
Virginia, sitting in regular session this 15th day of March 2016, that Section 1102
"Definitions" of the Zoning Regulations of the Town of Pulaski Virginia is hereby
amended to include the definitions listed in Attachment A, affixed hereto and expressly
made part of this ordinance;
FURTHER ORDAINED that Sections 705 through 708 of the Zoning Regulations are
hereby amended as set forth in Attachment B, affixed hereto and expressly made part
of this ordinance.
This ordinance is effective upon adoption and is hereby adopted this 15th day of March
2016 by the duly recorded vote of the Town Council of the Town of Pulaski, Virginia as
follows:
Heather L. Steele -Aye H.M. Kidd -Aye
Gregory C. East -Aye James A. Radcliffe -Aye
David L. Clark -Absent Lane R. Penn -Aye
THE TOWN OF PULASKI, VIRGINIA
BY:
= =. Worrell,' ayor
ATTEST:
Patricia Cruise, Clerk of Council
I.
Attachment A
Ordinance 2016-07
List of Definition Amendments
Section 1102
1. Section 1102-Change in definition of a variance as follows:
"Variance" means in the application of a zoning ordinance, a reasonable
deviation from those provisions regulating the shape, size or area of a lot or
parcel of land; or the size, height, area, bulk or location of a building or structure
when the strict application of the ordinance would unreasonably restrict the
utilization of the property and such need for a variance would not be generally
shared by other properties and provided such variance is not contrary to the
purpose of the ordinance. It shall not include a change in use, which change shall
be accomplished by a rezoning or by a conditional zoning. 015.2-2201 as amended)
2. Section 1102-Addition of a definition for the term "determination":
"Determination" means any order, requirement, decision or determination made
by an administrative officer. (15.2-2309 (1), as amended)
3. Section 1102-Addition of a definition of"non-legal staff of the governing body".
"Non-legal staff of the governing body" means any staff who is not in the office of
attorney for the locality or for the board who is appointed by special law or
pursuant to §15.2-2214. 015.2-2308.1) added.
Attachment B
Ordinance 2016-07
Section 705
Organization of the Board of Zoning Appeals
The Board of Zoning Appeals shall be organized as set forth in the Code of Virginia
1950, as amended, §§15.2-2308-15.2-2315.
705.1 Board of Zoning Appeals: Composition; Nomination of Members;
Appointment of Members; Vacancies; Terms of Office; Qualifications;
Compensation; Alternate Members; Contracting for Services; Removal
from Office.
705.1-1. Membership & Term of Office.
The Board of Zoning Appeals for the Town of Pulaski, Virginia shall
consist of five (5) regular members and two (2) alternates. Both regular
members and alternates shall be appointed by the Circuit Court of Pulaski
County for terms of five (5) years except that original appointments shall
be made for such terms that the term of one member shall expire each
year. Appointments shall be made only for the unexpired portion of the
term. 1
705.1-2. Notification of Vacancies.
The secretary of the board shall notify the court promptly if any vacancy
occurs and shall notify the court a minimum of thirty (30) days in advance
of the expiration of a term of office. A member whose term expires shall
continue to serve until their successor is appointed and qualifies.
Members may be appointed to succeed themselves. 2
705.1-3. Qualifications for Office.
Both members and alternates of the board: (1) shall be residents of the
locality; and, (2) shall hold no other public office in the locality, except that
one member may be a member of the planning commission.3
705.1-4. Nomination of Prospective Members by Council.
The Council may approve a written resolution, duly voted upon and
recorded in the public records of the Town, nominating a candidate who
qualifies for membership on the BZA either as a regular member of or as
an alternate. Said resolution shall be transmitted to the Circuit Court of
Pulaski County for the Court's consideration regarding appointment of the
nominee to the board as a regular member or alternate.
1 Code of Virginia 1950, as amended, §15.2-2308(A).
2 Code of Virginia 1950, as amended, §15.2-2308(A).
3 Code of Virginia 1950, as amended, §15.2-2308(A).
705.1-5. Qualifications and Seating of Alternate Members for Hearings.
The qualifications, terms and compensation of alternate members shall be
the same as regular members. If a regular member knows they will be
absent from a meeting or have to abstain from any application at a
meeting, they must notify the chairman twenty-four hours (24) prior to the
meeting. The chairman shall then select an alternate to serve in the
absent or abstaining members place note of which shall be recorded in the
records of the board. An alternate member may vote on any application in
which a regular member abstains.4
705.1-6. Compensation Authorized.
Members of the board may receive such compensation as may be
authorized by the Town Council. 5
705.1-7. Conflicts of Interest.
All Board members and alternates shall be subject to the Virginia Conflict
of Interest Act and shall not act upon a matter in which they have a
financial interest or where action would financially benefit them as
specified in the laws of the Commonwealth.
705.1-8. Removal from Office.
Any board member or alternate may be removed for malfeasance,
misfeasance or nonfeasance in office, or for other just cause, by the court
that appointed him, following a hearing held after at least fifteen (15) days'
notice.6
705.2 Operation of the BZA: Rules of Procedure; Contracting for Services;
Records of the Board; Election of Officers; Actions by Presiding Officer;
Quorum for Hearings; Notice and Hearing.
705.2-1. Rules of Procedure and Records.
The board may make, alter and rescind rules and forms for its procedures
consistent with ordinances of the locality and general laws of the
Commonwealth. The board shall keep a full public record of its
proceedings and shall submit a report of its activities to the governing
body or bodies at least once a year.'
705.2-2. Employment or Contracting for Services.
Within the limits of funds appropriated by the Council, the board may
employ or contract for secretaries, clerks, legal counsel, consultants and
other technical and clerical services.8
4 Code of Virginia 1950, as amended, §15.2-2308(A).
5 Code of Virginia 1950, as amended§15.2-2308 (C).
6 Code of Virginia 1950, as amended, §15.2-2308(D).
7 Code of Virginia 1950, as amended, §15.2-2308(C) and§15.2-2312.
8 Code of Virginia 1950, as amended§15.2-2308 (D).
705.2-3. Election of Officers.
With the exception of the secretary and the alternates, the board shall
elect from its own membership a Chairman and Vice-Chairman who will
serve annual terms and may succeed themselves. A Secretary shall also
be elected who may or may not be a member of the board.A secretary
who is not a member of the board may not vote on any matter before the
board.9
705.2-4. Discretionary Powers of the Presiding Officer.
The Chairman, or in his absence the Vice-Chairman or acting Chairman,
may administer oaths and compel the attendance of witnesses.10
705.2-5. Quorum for Hearings.
Notwithstanding any other provisions of law, general or special for the
conduct of any hearing, a quorum shall not be less than a majority of all
the members of the board and the board shall offer an equal amount of
time in a hearing on a case to the applicant, appellant, or other person
aggrieved under§15.2-2314 and the staff of the local governing body.
Except for matters governed by §15.2-2312, no action of the board shall
be valid unless authorized by a majority vote of those present and
voting.11
705.2-6. Notice and Hearing Required.
The board may not take action on a matter or consider a variance until
notice and hearing have been given as mandated by §15.2-2204 of the
Code of Virginia.
705.3 Ex Parte Communications: Notification of Communications; Availability of
Case Materials; Non-legal Staff Defined; Exemptions.
705.3-1. Ex Parte Communications.
The non-legal staff of the governing body may have ex parte
communications with a member of the board prior to the hearing but may
not discuss the facts or law relative to a particular case. The applicant,
landowner or his agent or attorney may have ex parte communications
with a member of the board prior to the hearing but may not discuss the
facts or law relative to a particular case. If any ex parte discussion of facts
or law in fact occurs, the party engaging in such communication shall
inform the other party as soon as practicable and advise the other party of
the substance of such communication. For purposes of this section,
regardless of whether all parties participate, ex parte communications
shall not include (i) discussions as part of a public meeting or (ii)
9 Code of Virginia 1950, as amended, §15.2-2308(C).
10 Code of Virginia 1950, as amended, §15.2-2309(8).
11 Code of Virginia 1950, as amended, §15.2-2308(C).
discussions prior to a public meeting to which staff of the governing body,
the applicant, landowner or his agent or attorney are all invited. 12
705.3-2. Availability of Case Materials.
Any materials relating to a particular case, including a staff
recommendation or report furnished to a member of the board, shall be
made available without cost to such applicant, appellant or other person
aggrieved under§ 15.2-2314, as soon as practicable thereafter, but in no
event more than three business days of providing such materials to a
member of the board. If the applicant, appellant or other person aggrieved
under § 15.2-2314 requests additional documents or materials be
provided by the locality other than those materials provided to the board,
such request shall be made pursuant to § 2.2-3704. Any such materials
furnished to a member of the board shall also be made available for public
inspection pursuant to subsection F of§ 2.2-3707. 13
705.3-3. Non-legal Staff Defined.
For the purposes of this section, "non-legal staff of the governing body"
means any staff who is not in the office of the attorney for the locality, or
for the board, or who is appointed by special law or pursuant to § 15.2-
1542. Nothing in this section shall preclude the board from having ex parte
communications with any attorney or staff of any attorney where such
communication is protected by the attorney-client privilege or other similar
privilege or protection of confidentiality.14
705.3-4. Exemption.
This section shall not apply to cases where an application for a special
exception has been filed pursuant to subdivision 6 of§ 15.2-2309.15
Section 706
Powers and Duties of the Board of Zoning Appeals
706.1 Appeal from Administrative Ruling.
The board has the authority to hear and decide appeals from any order, requirement,
decision, or determination made by an administrative officer in the administration or
enforcement of this article or of any ordinance adopted pursuant thereto. The decision
on such appeal shall be based on the board's judgment of whether the administrative
officer was correct. The determination of the administrative officer shall be presumed to
be correct. At a hearing on an appeal, the administrative officer shall explain the basis
for his determination after which the appellant has the burden of proof to rebut such
presumption of correctness by a preponderance of the evidence. The board shall
consider any applicable ordinances, laws, and regulations in making its decision. For
12 Code of Virginia 1950, as amended, §15.2-2308.1 (A).
13 Code of Virginia 1950, as amended, §15.2-2308.1 (B).
14 Code of Virginia 1950, as amended, §15.2-2308.1 (C).
15 Code of Virginia 1950, as amended, §15.2-2308.1 (D).
purposes of this section, determination means any order, requirement, decision or
determination made by an administrative officer. Any appeal of a determination to the
board shall be in compliance with this section, notwithstanding any other provision of
law, general or special.16
706.2 Granting.of Variances: Authorization to Grant Variances; Standards for
Consideration; Notice and Hearing; Imposition of Conditions/Bonding
706.2-1. Authorization to Consider Variance.
The board is authorized, notwithstanding any other provision of law,
general or special, togrant upon appeal or original application in specific
cases a variance as defined in § 15.2-2201, provided that the burden of
proof shall be on the applicant for a variance to prove by a preponderance
of the evidence that his application meets thestandardfor a variance as
defined in § 15.2-2201 and the criteria set out in this section.17
706.2-2. Standards for Considering a Variance.
Notwithstanding any other provision of law, general or special, a variance
shall be granted if the evidence shows that the strict application of the
terms of the ordinance would unreasonably restrict the utilization of the
property or that the granting of the variance would alleviate a hardship due
to a physical condition relating to the property or improvements thereon at
the time of the effective date of the ordinance, and (i) the property interest
for which the variance is being requested was acquired in good faith and
any hardship was not created by the applicant for the variance; (ii) the
granting of the variance will not be of substantial detriment to adjacent
property and nearby properties in the proximity of that geographical area;
(iii) the condition or situation of the property concerned isnot of so general
or recurring a nature as to make reasonably practicable the formulation of
a general regulation to be adopted as an amendment to the ordinance;.(iv)
the granting of the variance does not result in a use that is not otherwise
permitted on such property or a change in the zoning classification of the
property; and (v) the relief or remedy sought by the variance application is
not available through a special exception process that is authorized in the
ordinance pursuant to subdivision 6 of§15.2-2309 or the process for
modification of a zoning ordinance pursuant to subdivision A 4 of§ 15.2-
2286 at the time of the filing of the variance application.'$
706.2-3. Notice and Hearing Required.
No variance shall be considered except after notice and hearing as
required by § 15.2-2204. However, when giving any required notice to the
owners, their agents or the occupants of abutting property and property
immediately across the street or road from the property affected, the board
16 Code of Virginia 1950, as amended, §15.2-2309 (1).
17 Code of Virginia 1950, as amended, §15.2-2309 (2).
18 Code of Virginia 1950, as amended, §15.2-2309 (2).
may give such notice by first-class mail rather than by registered or
certified mail.19
706.2-4. Imposition of Conditions/Bonding.
In granting_a variance, the board may impose such conditions regarding
the location, character, andother features of the proposed structure or use
as it may deem necessary in the public interest and may require-a
guarantee or bond to ensure that the conditions imposed.are being and
will continue to be complied with. Notwithstanding any other provisionof
law, general or special,, the property upon which a property owner has
beengranted a variance shall be treated as conforming for all purposes
under state law and local ordinance; however, the structure permitted by
the variance may not be expanded unless the expansion is within an area
of the site or part of the structure for which no variance is required under
the ordinance. Where the expansion is proposed within an area of the site
or part of the structure for which a variance is required, the approval of an
additional variance shall be required.20
706.3 Interpretation of District.Map: Authorization; Guidelines for Interpretation;
Notice and Hearing.
706.3-1. Authorization to Interpret Maps
The board is authorized to hear and decide applications for interpretation
of the district map where there is any uncertainty as to the location of a
district boundary.
706.3-2. Guidelines for Interpretation; Notice and Hearing.
After notice to the owners of the property affected by the question, and-
after public hearing with notice as required by § 15.2-2204, the board may
interpret the map in such way as to carry out the intent and purpose of the
ordinance for the particular section or district in question. However, when
giving any required notice to the owners, their agents or the occupants of
abutting property and property immediately across the street or road from
the property affected, the board may give such notice by first-class mail
rather than by registered or certified mail. The board shall not have the
power to change substantially the locations of district boundaries as
established by ordinance.21
19 Code of Virginia 1950, as amended, §15.2-2309 (2).
20 Code of Virginia 1950, as amended, §15.2-2309(2).
21 Code of Virginia 1950, as amended, §15.2-2309(3).
706.4 Authorization to Consider Special Exception Use Permits for Structure
Placement: Authorization; Application of Conditions; Required Findings;
Standards for Determining Health and Safety.
706.4-1. Authority to Consider Special Exception Use Permits.
The Board of Zoning Appeals is authorized to hear and decide .on requests
for special exception use permits (also referred to as "use permits") that
allow modification of placement requirements for structures in all zoning
districts of the Town.
706.4-2. Application of Conditions.
The Board of Zoning Appeals may impose conditions on the use permit that
it deems necessary in the public interest, including limiting the duration of the
use permit.
706.4-3. Required Findings.
The Board of Zoning Appeal shall not approve a use permit unless it finds:
a. That the proposal will not affect adversely the health or safety of
persons residing in the neighborhood; and,
b. That the proposal will not be detrimental to the public welfare or
injurious to property or improvements in the neighborhood; and,
c. That the proposal will not be in conflict with the purposes of the
master plans and land use and zoning related policies of the Town.
706.4-4. Standards for Determining Effects on Neighborhood Health and Safety.
In determining whether the proposal will adversely affect the health and
safety of persons residing in the neighborhood or will be detrimental to the
public welfare, injurious to property or improvements in the neighborhood,
the BZA shall consider:
(1) Whether the modification will promote compatibility of development
with the surrounding neighborhood, because the structure's overall
footprint size and placement are similar to structures or property
surrounding the lot in question; and,
(2) Whether the modification will help preserve natural land form,
historical features, and/or significant trees and foliage.22
706.5 Appeals from Decisions of the Zoning Administrator.
The board is authorized to hear and decide appeals from the decision of the zoning
administrator after notice and hearing, as provided by §15.2-2204. However, when
giving any required notice to the owners, their agents or the occupants of abutting
property and property immediately across the street or road from the property affected,
22 Ordinance 2011-11.
the board may give such notice by first-class mail rather than by registered or certified
mail.23
706.6 Restrictions Regarding Rezoning and Legislative Intent.
No provision of this ordinance shall be construed as granting any board of zoning
appeals thepower to rezone property or to base board decisions on the merits of the
purpose and intent of local ordinances duly adopted by the governing body:24
706.7 Hearing and Decisions Regarding Special Exceptions: Authorization;
Notice and Hearing.
706.7-1. Authorization.
The board is approved to hear and decide applications for special
exceptions as may be authorized in the ordinance. The board may impose
such conditions relating to the use for which a permit is granted as it may
deem necessary in the public interest, including limiting the duration of a
permit, and may require a guarantee or bond to ensure that the conditions
imposed are being and will continue to be complied with.
706.7-2. Notice and Hearing.
No special exception may be granted except after notice and hearing as
provided by § 15.2=2204. However, when giving any required notice to the
owners, their agents or the occupants of abutting property and property
immediately across the street or road from theproperty affected, the board
may give such notice by first-class mail rather than by registered or
certified mail.25
706.8 Revocation of Special Exceptions: Revocation Authority of BZA ; Notice
and Hearing; Revocation Authority of Town Council.
706.8-1. Authority to Revoke Special Exception by the BZA.
The board has the authority to revoke a special exception previously
granted by the board of zoning appeals if the board determines that there
has not been compliance with the terms or conditions of the permit.
706.8-2. Notice and Hearing.
No special exception may be revoked except after notice and hearing as
provided by § 15.2-2204. However, when giving any required notice to the
owners, their agents or the occupants of abutting property and property
immediately across the street or road from the property affected, the board
may give such notice by first-class mail rather than by registered or
certified mail.
23 Code of Virginia. 1950, as amended, §15.2-2309 (3).
24 Code of Virginia 1950, as amended, §15.2-2309 (5).
25 Code of Virginia 1950, as amended, §15.2-2309 (6).
a
706.8-3. Revocation by Town Council.
If Town Council reserves unto itself the right to issue special exceptions
pursuant to § 15.2-2286, and, if the Council determines that there has not
been compliance with the terms and conditions of the permit, then it may
also revoke special exceptions in the manner provided by this
subdivision.26
706.9 Scheduling of Meetings.
The board by resolution may fix a schedule of regular meetings, and may also fix the
day or days to which any meeting shall be continued if the chairman, or vice-chairman if
the chairman is unable to act, finds and declares that weather or other conditions are
such that it is hazardous for members to attend the meeting. Such finding shall be
communicated to the members and the press as promptly as possible. All hearings and
other matters previously advertised for such meeting in accordance with § 15.2-2312
shall be conducted at the continued meeting and no further advertisement is required.27
Section 707
Application and Procedures for Board Hearings
707.1 Hearings Regarding Special Exceptions and Variances: Eligible Applicants;
Transmission of Application Documents; Notice; Time Limit on
Request/Resubmission; Withdrawal of Application; Allotment of Fees
707.1-1. Eligible Applicants.
Applications for special exceptions and variances may be made by any
property owner, tenant, government official, department, board or
bureau.28
707.1-2. Application and Transmission of Documents.
Applications shall be made to the zoning administrator in accordance with
rules adopted by the board. The application shall be accompanied by one
(1) copy of documentation containing reasonable information as shall be
required by the Zoning Administrator. The application and accompanying
maps, plans or other information shall be transmitted promptly to the
secretary of the board who shall place the matter on the docket to be
acted upon by the board.29
707.1-3. Notice and Hearing.
No special exceptions may be granted or variances shall be considered
except after notice and hearing as required by § 15.2-2204. The zoning
administrator shall also transmit a copy of the application to the local
26 Code of Virginia 1950, as amended, §15.2-2309 (7).
27 Code of Virginia 1950, as amended, §15.2-2309(8).
28 Code of Virginia 1950, as amended, §15.2-2310.
29 Code of Virginia 1950, as amended, §15.2-2310.
planning commission which may send a recommendation to the board or
appear as a party at the hearing.3o
707.1-4. Time Limit on Resubmission of Request.
Any locality may provide by ordinance that substantially the same
application will not be considered by the board within a specified period,
not exceeding one year.31
707.1-5. Withdrawal of Application.
Any petitions for a hearing before the Board may be withdrawn prior to
action thereon, by said Board at the discretion of the person, firm or
corporation initiating such request upon written notice to the Secretary of
said Board.
707.1-6. Payment and Fees.
Applications to the Board shall be accompanied by payment of a fee set
forth in Section 801 to help defray the cost of publicizing and conducting
the public hearing. Upon withdrawal of an application, the fee required will
be refunded provided no expenditures have been made for publicizing or
conducting the public hearing at the time the notice is received. If the
withdrawal is done after publicizing costs have been incurred, the
applicant is responsible for payment of these costs.
707.2 Hearings Regarding Administrative Decisions: Eligible Appellants; Notice
of Appeal Process and Deadline for Filing; Length of Time to Appeal
Ruling; Filing and Transmission of Appeal to Board; Notice and Hearing;
Stay of Action During Appeal; General Appeal Procedure; Withdrawal of
Appeal; Payment of Fees.
707.2-1. Eligible Appellants.
An appeal to the board may be taken by any person aggrieved or by any
officer, department, board or bureau of the locality affected by any
decision of the zoning administrator or from any order, requirement,
decision or determination made by any other administrative officer in the
administration or enforcement of this article, any ordinance adopted
pursuant to this article, or any modification of zoning requirements
pursuant to Code of Virginia § 15.2-2286.32
707.2-2. Violation/Order to Include Notification of Right to Appeal.
Any written notice of a zoning violation or a written order of the zoning
administrator shall include a statement informing the recipient that he may
have a right to appeal the notice of a zoning violation or a written order
within 30 days in accordance with this section, and that the decision shall
3° Code of Virginia 1950, as amended, §15.2-2309 (6) and(2)and §15.2-2310.
31 Code of Virginia 1950, as amended, §15.2-2310.
32 Code of Virginia 1950, as amended, §15.2-2311 (A).
M
be final and unappealable if not appealed within 30 days. The zoning
violation or written order shall include the applicable appeal fee and a
reference to where additional information may be obtained regarding the
filing of an appeal. The appeal period shall not commence until the
statement is given. A written notice of a zoning violation or a written order
of the zoning administrator that includes such statement sent by registered
or certified mail to, or posted at, the last known address of the property
owner as shown on the current real estate tax assessment books or
current real estate tax assessment records shall be deemed sufficient
notice to the property owner and shall satisfy the notice requirements of
this section.33
707.2-3. Filing and Transmission of Appeal Documents to the Board.
The appeal shall be taken within 30 days after the decision appealed from
by filing with the zoning administrator, and with the board, a notice of
appeal specifying the grounds thereof. The zoning administrator shall
forthwith transmit to the board all the papers constituting the record upon
which the action appealed from was taken.34
707.2-4. Application of Decision to Appellant as Regards Notice and Hearing.
A decision by the board on an appeal taken pursuant to this section shall
be binding upon the owner of the property which is the subject of such
appeal only if the owner of such property has been provided notice of the
zoning violation or written order of the zoning administrator in accordance
with this section. The owner's actual notice of such notice of zoning
violation or written order or active participation in the appeal hearing shall
waive the owner's right to challenge the validity of the board's decision
due to failure of the owner to receive the notice of zoning violation or
written order.35
707.2-5. Stay of Action/Order During Appeals Process; Exceptions.
An appeal shall stay all proceedings in furtherance of the action appealed
from unless the zoning administrator certifies to the board that by reason
of facts stated in the certificate a stay would in his opinion cause imminent
peril to life or property, in which case proceedings shall not be stayed
otherwise than by a restraining order granted by the board or by a court of
record, on application and on notice to the zoning administrator and for
good cause shown.36
707.2-6. General Procedure of the Appeal.
The board shall fix a reasonable time for the hearing of an application or
appeal, give public notice thereof as well as due notice to the parties in
33 Code of Virginia 1950, as amended, §15.2-2311 (A)
34 Code of Virginia, 1950, as amended, §15.2-2311 (A).
36 Code of Virginia, 1950, as amended, §15.2-2311 (A).
36 Code of Virginia, 1950, as amended, §15.2-2311 (A).
interest and make its decision within ninety days of the filing of the
application or appeal. In exercising its powers the board may reverse or
affirm, wholly or partly, or may modify, an order, requirement, decision or
determination appealed from. The concurring vote of a majority of the
membership of the board shall be necessary to reverse any order,
requirement, decision or determination of an administrative officer or to
decide in favor of the applicant on any matter upon which it is required to
pass under the ordinance or to effect any variance from the ordinance.
The board shall keep minutes of its proceedings and other official actions
which shall be filed in the office of the board and shall be public records.
The chairman of the board, or in his absence the acting chairman, may
administer oaths and compel the attendance of witnesses.
707.2-7. Sixty Day Limit on Administrative Changes to Order; Exemptions.
In no event shall a written order, requirement, decision or determination
made by the zoning administrator or other administrative officer be subject
to change, modification or reversal by any zoning administrator or other
administrative officer after 60 days have elapsed from the date of the
written order, requirement, decision or determination where the person
aggrieved has materially changed his position in good faith reliance on the
action of the zoning administrator or other administrative officer unless it is
proven that such written order, requirement, decision or determination was
obtained through malfeasance of the zoning administrator or other
administrative officer or through fraud. The 60-day limitation period shall
not apply in any case where, with the concurrence of the attorney for the
governing body, modification is required to correct clerical errors.
707.2-8. Tie Votes.
In any appeal taken pursuant to this section, if the board's attempt to
reach a decision results in a tie vote, the matter may be carried over until
the next scheduled meeting at the request of the person filing the appeal.
707.2-9 Withdrawal of Appeal.
Any application for appeal before the Board may be withdrawn without
prejudice, prior to action thereon by said Board, at the discretion of the
person, firm, or corporation initiating such a request upon written notice to
the Secretary of said Board.
707.2-10. Fees.
Each application for an appeal shall be accompanied by payment of a fee
as set forth in Article 800 to help defray the cost of publicizing and
conducting the public hearing. Upon withdrawal of an application, the fee
required will be refunded minus any expenditures which have been made
for publicizing or conducting the public hearing at the time the notice is
received. The fee for filing an appeal shall not exceed the cost of
advertising the appeal for public hearing and reasonable costs.37
Section 708
Certiorari to Review Decisions of the Board
708.1 Aggrieved Parties; Form of Writ.
Any person or persons jointly or severally aggrieved by any decision of the board of
zoning appeals, or any aggrieved taxpayer or any officer, department, board or bureau
of the locality, may file with the clerk of the circuit court for the county or city a petition
that shall be styled "In Re: date Decision of the Board of Zoning Appeals of[locality
name]" specifying the grounds on which aggrieved within 30 days after the final decision
of the board.38
708.2 Issuance of writ; Notification of the Board of Filing of an Appeal.
Upon the presentation of such petition, the court shall allow a writ of certiorari to review
the decision of the board of zoning appeals and shall prescribe therein the time within
which a return thereto must be made and served upon the secretary of the board of
zoning appeals or, if no secretary exists, the chair of the board of zoning appeals, which
shall not be less than 10 days and may be extended by the court. The allowance of the
writ shall not stay proceedings upon the decision appealed from, but the court may, on
application, on notice to the board and on due cause shown, grant a restraining order.39
708.3 Status of the Board in Appeal Proceedings.
Any review of a decision of the board shall not be considered an action against the
board and the board shall not be a party to the proceedings; however, the board shall
participate in the proceedings to the extent required by this section. The governing
body, the landowner, and the applicant before the board of zoning appeals shall be
necessary parties to the proceedings in the circuit court. The court may permit
intervention by any other person or persons jointly or severally aggrieved by any
decision of the board of zoning appeals.43
708.4 Possession of Original Papers; Certification of Documents.
The board of zoning appeals shall not be required to return the original papers acted
upon by it but it shall be sufficient to return certified or sworn copies thereof or of the
portions thereof as may be called for by the writ. The return shall concisely set forth
such other facts as may be pertinent and material to show the grounds of the decision
appealed from and shall be verified.41
37 Code of Virginia 1950, as amended, §15.2-2311 (A).
38 Code of Virginia 1950, as amended, §15.2-2314.
38 Code of Virginia 1950, as amended, §15.2-2314.
48 Code of Virginia 1950, as amended, §15.2-2314.
41 Code of Virginia 1950, as amended, §15.2-2314.
V O
708.5 Authorized Court Actions on the Appeal.
The court may reverse or affirm, wholly or partly, or may modify the decision brought up
for review.
708.6 Presumptions of Correctness, Burden of Proof for Appeals of Decisions of
Administrative Officials.
In the case of an appeal from the board of zoning appeals to the circuit court of an
order, requirement, decision or determination of a zoning administrator or other
administrative officer in the administration or enforcement of any ordinance or provision
of state law, or any modification of zoning requirements pursuant to § 15.2-2286, the
findings and conclusions of the board of zoning appeals on questions of fact shall be
presumed to be correct. The appealing party may rebut that presumption by proving by
a preponderance of the evidence, including the record before the board of zoning
appeals that the board of zoning appeals erred in its decision. Any party may introduce
evidence in the proceedings in the court. The court shall hear any arguments on
questions of law de novo.42
708.7 Presumptions of Correctness, Burden of Proof for Appeals Involving
Variances.
In the case of an appeal by a person of any decision of the board of zoning appeals that
denied or granted an application for a variance, the decision of the board of zoning
appeals shall be presumed to be correct. The petitioner may rebut that presumption by
proving by a preponderance of the evidence, including the record before the board of
zoning appeals that the board of zoning appeals erred in its decision.43
708.8 Presumptions of Correctness, Burden of Proof for Appeals Involving
Special Exceptions.
In the case of an appeal by a person of any decision of the board of zoning appeals that
denied or granted application for a special exception, the decision of the board of zoning -
appeals shall be presumed to be correct. The petitioner may rebut that presumption by
showing to the satisfaction of the court that the board of zoning appeals applied
erroneous principles of law, or where the discretion of the board of zoning appeals is
involved, the decision of the board of zoning appeals was plainly wrong, was in violation
of the purpose and intent of the zoning ordinance, and is not fairly debatable.44
708.9 Introduction of Evidence in Appeal from the Board.
In the case of an appeal from the board of zoning appeals to the circuit court of a
decision of the board, any party may introduce evidence in the proceedings in the court
in accordance with the Rules of Evidence of the Supreme Court of Virginia.45
42 Code of Virginia 1950, as amended, §15.2-2314.
43 Code of Virginia 1950, as amended, §15.2-2314.
as Code of Virginia 1950, as amended, §15.2-2314.
45 Code of Virginia 1950, as amended, §15.2-2314.
r
708.10 Allotment of Appeal Costs.
Costs shall not be allowed against the locality, unless it shall appear to the court that it
acted in bad faith or with malice. In the event the decision of the board is affirmed and
the court finds that the appeal was frivolous, the court may order the person or persons
who requested the issuance of the writ of certiorari to pay the costs incurred in making
the return of the record pursuant to the writ of certiorari. If the petition is withdrawn
subsequent to the filing of the return, the locality may request that the court hear the
matter on the question of whether the appeal was frivolous.46
46 Code of Virginia 1950, as amended, §15.2-2314.