Cottages Development Appeal
Cottages Development Appeal
Cottages Development Appeal
filed herein, a copy of which is herewith served upon you, and to serve a copy of your
answer to this Petition/Complaint upon the subscriber, at the address shown below,
within thirty (30) days after service hereof, exclusive of the day of such service, and if
you fail to answer the Petition/Complaint, judgment by default will be rendered against
The above-named Petitioners file this Petition pursuant to S.C. Code Ann. § 6-
29-900 and the Zoning Ordinance of the City of Myrtle Beach § 606 asserting that the
decision entered by the City of Myrtle Beach Community Appearance Board on January
27, 2022, and determinations, acts and/or omissions of the City of Myrtle Beach and the
City of Myrtle Beach Zoning Administrator leading to same, are contrary to law, and
states as follows:
INTRODUCTION
1. This matter is before the Court on appeal from a decision of the City of
landscaping, parking and fence for a 305-unit horizontal apartment complex containing
two-unit and multifamily dwellings (hereafter referred to as the “Cottages”) within the
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Cane Patch Tract of the Grande Dunes Planned Unit Development (“PUD”). The
Cottages development would provide traffic access directly onto 76th Avenue North (“76th
Ave. N.”) not only from the Cottages, but also from an adjoining 325 residential rental unit
development known as the Willows. The Cottages is located within a portion of the of the
Cane Patch Tract set aside for development consistent with the City’s R-7 zoning
classification. The Cottages is not an authorized use in the R-7 zoning classification, the
CAB’s decision approving its layout and design and the manner in which the CAB and the
City’s Zoning Administrator administered this matter was and is in clear and direct
violation of the City’s zoning code and contrary to law. The Petitioners also seek relief for
Briarwood Drive, in an area adjacent to the development at issue and he and his property
are adversely affected by the development of the property subject to this Petition.
to the development at issue and he and his property are adversely affected by the
an area adjacent to the development at issue and he and his property are adversely
in an area adjacent to the development at issue and he and his property are adversely
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6. Petitioner, Cynthia Setzer, is an adult individual residing on Catena Lane, in
an area adjacent to the development at issue and she and her property are adversely
area adjacent to the development at issue and he and his property is adversely affected
the development at issue and he and his property is adversely affected by the
Drive, in an area adjacent to the development at issue and he and his property is
Board (“CAB”), is an architectural review board established by the City of Myrtle Beach in
Article 6 under of the Zoning Ordinance of the City of Myrtle Beach (“Ordinance”) and the
11. Respondent, City of Myrtle Beach, South Carolina (the “City”) is a municipal
corporation and body politic created by and subject to the laws of the State of South
Carolina.
limited liability company having an address at 1400 Sunday Drive, #101, Raleigh, NC
27607 and, based on Horry County Tax Assessment Records, is the owner of a certain
26.69 acre parcel of land located along US Highway 17 Bypass between 71st Ave. N. and
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76th Ave. N., designated as Horry County PIN No.: 39500000030 Parcel No. 2, hereafter
13. The Property is located in the northwest corner of the Cane Patch Tract of
14. Upon information and belief, the Zoning Administrator for the City was
charged with the duty to properly administer the City Zoning Code, subject to those
15. Petitioners are aggrieved by the decision of the CAB made on January 27,
2022 granting final approval of the layout and design of 305 multifamily residential rental
units in the northwest corner of the Cane Patch Tract of the Grande Dunes PUD (i.e., the
“Cottages”) and the location of a road providing ingress and egress to 76th Ave. N. and
request:
(i) Declaratory relief finding and declaring that any decision of the CAB
approving the Cottages development is contrary to law, ultra vires, void
and invalid as a matter of law as the CAB does not have the statutory
authority to review or approve plans which change the density of
development without compliance with the terms of the City’s Zoning
Code; and
(ii)
(iii) Declaratory relief finding and declaring that the CAB’s approval of the
Cottages plan is contrary to law and must be reversed as it fails to
protect the public health, safety and welfare and will cause substantial
injury to the value of other property in the immediate area
b. Declaratory relief finding and declaring that any decision by the Zoning
Administrator to place the Cottages development before the CAB, or
determine the Cottages development to be a “minor amendment” to the 76th
Ave. Carve-Out of the Cane Patch PUD, is contrary to law, outside the
scope of his authority, ultra vires, void ab initio, voidable and subject to
reversal by the Circuit Court.
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c. Declaratory relief finding and declaring that improper unilateral
interpretations by the Zoning Administrator which authorizes the
development of uses not specifically identified by Ordinance as permissible
in the Grande Dunes PUD in general, and in the Cane Patch Tract in
particular, and the submission of development plans for same to the CAB
for approval, violates Petitioners’ procedural and substantive due process
rights.
d. A request for declaratory relief finding and declaring that the City, through its
Zoning Administrator, failed to supply documents relative to the construction
of the Cottages prior to final approval by the CAB in violation of S.C. Code
Ann. § 30-4-10 and the grant of legal and/or equitable relief resulting from
same.
e. Supersedeas or other injunctive relief enjoining the City from issuing permits
or taking action on any requests for the approval of vested development
rights in the Cottages pending resolution of those issues raised in this action
and setting aside any actions taken by the City to approve same.
16. This Honorable Court has both subject matter and personal jurisdiction over
17. Venue is proper in Horry County pursuant to the provisions of S.C. Code
violate a specific statute/ordinance and exceed such agencies’ specific authority to act as
BACKGROUND
different types and densities and of compatible commercial uses, or commercial centers,
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development and is characterized by a unified site design for a mixed-use
Ordinance and approved final plans. It is a contractual undertaking that is binding upon
the applicant and the owners of the land covered by the PUD, their successors and
assigns, and limits and controls the construction, location, use and operation of all land
and all improvements to be located within PUD. City of Myrtle Beach Zoning Code §
1903.H.
22. Changes that alter the concept of the PUD, including but not limited to,
changes in density, type and location, height of buildings, proposed open space,
24. On October 27, 1998, the City amended its Zoning Code through the
enactment of Myrtle Beach Ordinance 981027-52, adopted October 27, 1998 to create
an area known as the “Grande Dunes PUD”. The Grande Dunes PUD is a mixed-use
PUD having multiple tracts, one of which is the “Cane Patch Tract”.
25. The Cane Patch Tract is located between Kings Highway and US 17
Bypass and runs along 76th Ave. N. adjacent to the Northwood Plan of Lots, one of the
City’s founding communities. All Petitioners herein reside either within single family
residential housing developments in the Cane Patch Tract or the Northwood Plan.
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26. The Property at issue is located in the northwest corner of the “Cane
Patch Tract” at the intersection of 76th Ave. N. and US 17 Bypass. It is a separate and
distinct 26.69 acre parcel of land fronting along US 17 Bypass between 71st Ave. North
27. In or about May 2002, City Council enacted Ordinance No. 2002-28
Any portion of said lots which abut on 76th Ave. N. shall be designated
as a rear yard for setback purposes.
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28. Exhibit 1A carves out an area of the Cane Patch Tract extending west
along 76th Ave. N. from a commercial hotel to US Bypass 17 and restricts development
to uses consistent with the City’s “R-7 zoning” classification (hereafter the “76th Ave.
Carve-Out”).
29. There are three authorized uses in the City’s R-7 Zoning district, namely:
“road, street, thoroughfare, alley or travel lanes northwest from Driftwood Drive up to US
17 Bypass” refers to “Driftwood Drive” in the Northwood Plan of Lots, located across
76th Ave. N. from the entrance to “Seville”.1 A copy of the foregoing Exhibit 1A is
attached hereto, made a part hereof and marked Exhibit “A” to this Petition.
1903.I.2 of the Zoning Code that would change the R-7 zoning classification of this
property and, accordingly, development of the 76th Ave. Carve-Out is and continues to
be limited and restricted to only those uses authorized in the City’s R-7 zoning
classification.
1
Seville is a component of the Cane Patch Tract comprised of only single-family
residential homes and constructed in compliance with the Grande Dunes PUD.
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32. Although minor changes to a PUD may be made by the Zoning
request for the construction of “Conceptual buildings, landscaping, parking and fence for
a 305 unit horizontal apartment complex” within the 76th Ave. Carve-Out (hereafter
Two-Family and Multifamily dwelling units with access to 76th Ave. North directly across
from Briarwood Drive, a roadway sitting between Driftwood Drive and US 17 Bypass.2
34. None of the uses contemplated by the Cottages are permitted in the R-7
zoning district and the construction of the accessway onto 76th Ave. North is precluded
as it would not connect 76th Ave. North to uses that were permitted in the R-7 zoning
classification.
2
Upon information and belief, DRG is an engineering and architectural company
that assists individuals and entities with the development of property. Although
information submitted by DRG along with the application makes reference to
“360” and “Freehold”, the interests of 360 and Freehold in the Property are not
specifically identified.
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35. After reviews of “conceptual plans”, DRG made application to the CAB for
a final review of the Cottages on or about January 10, 2022. On January 27, 2022,
of the Petitioners herein raising the CAB’s inability to approve the Cottages due to
zoning issues, the CAB voted to approve those documents submitted by DRG for the
Cottages. A copy of the aforesaid Memorandum is attached hereto, made a part hereof
facility for persons with mental or physical handicaps” as two-family and multifamily
residential dwellings are defined in the City’s zoning code and excluded from being
37. The Cottages development alters the concept of the 76th Ave. Carve-Out,
changes the density and type of buildings, proposed open space and access ways, and
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38. Petitioners incorporate herein by reference those allegations set forth in
39. The submissions made to the CAB for the Cottages Development included
“As the development of the Grande Dunes Resort will evolve over a
number of years, it is necessary for a method to be a part of this ordinance
which allows for land use transfers to occur in a manner that maintains
adequate levels of public facilities and provides for transfer relationships
to surrounding properties. The accompanying table reflects this transfer
determination based on the impact to the transportation system as it
represents a measurable relationship of intensity of use. The only area not
subject to this provision (relating to “density transfer provisions”) will
be the Single-Family lots (see Exhibits 1 and 2) in the Cane Patch
Tract. This tract is to be developed as defined by Exhibit 2. They shall
be developed in accordance with the R-7 zoning regulations of the
City of Myrtle Beach with the exception of required front yard and
side yard requirements for Residential Uses…”. (Emphasis added).
40. Exhibits 1 and 2 referenced above show the Siena Park and Seville
developments as constructed and continue to identify the remaining area of the 76th
Ave. Carve-Out separately from the other portions of the Cane Patch Tract. Copies of
Exhibits 1 and 2 are attached hereto, made a part hereof and marked collectively as
Exhibit “C”. Nothing in the aforesaid Exhibits change the R-7 zoning classification of this
area.
41. The Cottages proposed development plan changes the R-7 zoning
classification of this area, alters the concept of the Cane Patch Tract applicable to the
76th Ave. Carve-Out relating to density of development, the types of buildings permitted
for construction and modifies the agreements, provisions and covenants previously
approved by Ordinance enacted by the Council of the City for this area.
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42. Changes that alter the concept of the PUD, including but not limited to,
changes in density, type and location, height of buildings, proposed open space,
Beach Zoning Code § 1903.I.2. No variances may be granted within, or for, a Planned
43. The CAB does not have the authority to waive or modify the site
development requirements of the City’s zoning code, or the requirements of any other
44. The CAB’s decision modifies the permitted uses authorized for the 76th
Ave. Carve-Out and the site development requirements for this area contrary to the
City’s zoning code.
45. The CAB lacks statutory authority to hear, or make determinations on
development applications which change or alter the concept of a PUD, including but not
limited to, changes in density, type and location, height of buildings, proposed open
space, development schedule, road standards or any changes in final governing
agreements, or provisions or covenants, such authority being vested solely within the
City through the PUD amendment process, and any such determination is contrary to
law.
46. The CAB’s decision approving the Cottages application is contrary to law,
outside the scope of its authority, contrary to the procedures established by the City for
the type of changes required for the Cottages, ultra vires, void ab initio or voidable,
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COUNT II – NOTICE OF APPEAL FROM CAB DECISION AND REQUEST FOR
DECLARATORY RELIEF
48. The Ordinance requires PUDs to be designed so that the public health,
welfare and safety is protected and does not cause substantial injury to the value of
other property in the immediate area. City of Myrtle Beach Zoning Code § 1903.B.6
and B.7.
whether the proposed development would “sustain the comfort, health, tranquility, and
contentment of residents and attract new residents by reason of the City's favorable
environment; and thus, to promote and protect the peace, health and welfare of the
50. The Cottages is intended to have direct access to 76th Ave. N. In addition,
it’s internal road system will provide direct site interconnected cross-access to 76th Ave.
N. from a neighboring 325 multifamily residential rental unit development known as the
“Willows”.
permit traffic from 630 multifamily dwelling units to enter from and exit to 76th Ave. N.
across from Briarwood Drive in the Northwood Plan. It will also permit this traffic to use
the streets in the Northwood Plan for through traffic to 79th Ave. N.
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52. Both 76th Ave. N. and 79 th Ave. N. are 2-lane roadways extending between
US 17 Bypass and Kings Highway. They abut the Northwood Plan to its north and
walk, jog, walk dogs, ride bicycles, and operate golf carts within the roads in the
53. Grocery stores, restaurants, drug stores, hairdressers, nail salons and
other forms of retail shops for goods and services are located along Kings Highway,
between 0.6 and 0.8 miles away from the entrance of the Cottages onto 76th Ave. N.,
known to be prone to severe accidents and was referred to during CAB meetings on the
55. In the summer of 2021, before the current Cottages plan was proposed,
76th Ave. N. and 79th Ave. N. were determined by the City to have problems with
speeding under pre-development conditions and, as a result, the City agreed to install
additional traffic calming measures on both roads to address existing adverse traffic
conditions.
56. The area of the Northwood plan between Driftwood Drive and US 17
homes and one church (a density of one single family dwelling for every 0.57 acres of
land). The area of the Cottages contains approximately 26.6 acres of land and is
proposed to contain 305 multifamily dwelling units (a density of one dwelling unit for
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57. There are approximately 210 single-family homes combined in the
58. The combined number of dwelling units contained in the Willows and
Cottages plans (i.e., 630) will increase the density of residential dwelling units in the
area by 200%.
59. Upon information and belief, Petitioners aver that the dwelling units
contemplated in both the Willows and Cottages plans are intended to be rental units
with both sites being under and subject to the control of a single owner.
residential rental dwelling units will decrease the value of the surrounding properties that
61. The CAB’s approval of the Cottages plan fails to take into consideration
the substantial impact the Cottages development would have on the public health,
safety and welfare of surrounding property owners, and the devaluation of their
properties caused by the substantial increases in the density of development and traffic
flow from the Cottages plan, impermissibly alters the protections provided to residents
within the 76th Ave. Carve-Out and the adjoining Northwood Plan by the creation of the
R-7 zoning classification for that area, fails to follow those directives for CAB review
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authority, ultra vires, void ab initio, voidable and subject to
reversal by the Circuit Court.
materials submitted to the CAB to ensure they satisfy submission requirements and
arrange for their presentation before the Board. This review is required to ensure that
projects that come before the Board are compliant with zoning standards. Ordinance §
605.A.
65. The 76th Ave. Carve-Out is limited to development consistent with the R-7
zoning classification which does not include multifamily dwellings. There are three
66. Although the Zoning Administrator has some authority to make minor
changes to an approved PUD as a “minor amendment”, the Zoning Administrator’s
authority to act does not permit “minor amendments” which:
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a. Alter the concept of the PUD;
b. Change the permitted land uses; or
c. Otherwise violate the restrictions applicable within the PUD.
City of Myrtle Beach Zoning Code § 1903.I.1.
67. Any attempt by the Zoning Administrator to “interpret” the zoning code to
include the Cottages within one of the three uses authorized in the R-7 zoning
changes the permitted land uses in the R-7 zoning classification from Single-Family
homes to Two-Family and Multifamily dwellings, alters the concept of the 76th Ave.
Carve-Out portion of the Cane Patch Tract and violates the restrictions, limitations and
covenants agreed to by City Council and approved by Ordinance some 20 years ago.
68. The Cottages development clearly, and as a matter of law, alters the
concept of the PUD, changes the permitted land uses in same or otherwise violates the
R-7 development restrictions applicable to the 76th Ave. Carve-Out and any action by
law, outside the scope of the Zoning Administrator’s authority, ultra vires, void ab initio,
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69. Petitioners incorporate herein by reference those allegations set forth in
70. The City provides a process through which changes in PUDs may be
pursued.
71. Changes that alter the concept of the PUD, including but not limited to,
changes in density, type and location, height of buildings, proposed open space,
Beach Zoning Code § 1903.I.2. No variances may be granted within, or for, a Planned
72. The PUD amendment process requires review of such amendment by the
the form of advertisement in a local newspaper, public hearing sign(s) posted on the
property, and letters mailed to owners of property within 300 feet of the PUD.
73. Upon information and belief, Petitioners aver that the Zoning Administrator
has made improper unilateral legislative determinations in this and other cases involving
the Grande Dunes PUD, which authorize uses not specifically identified by Ordinance
as approved for the PUD, and, without making same a matter of public record,
submitted applications for the construction of same to the CAB for approval without
submitting them for prior review through the PUD amendment process.
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74. Such improper unilateral determinations eliminate requirements for
planning commission review and approval of amendments to the PUD, eliminates the
necessity for public hearings, and circumvents City Council review and approval of PUD
75. As the CAB is not required to conduct a “public hearing” on any matter
before it, the aforesaid practice effectively avoids or limits public comment to only those
“architectural matters” that are within the “purview of the CAB”, precludes public
matters”, reduces the time allowed for public comment and is violative of the public’s
rights to substantive and procedural due process otherwise afforded through public
which authorized or permitted the Cottages development to proceed before the CAB is
void as a matter of law, outside the scope of the Zoning Administrator’s authority to act
77. The Petitioners pray the Circuit Court declare the actions of the Zoning
substantive and procedural due process, reverse any action, inaction or failure of the
Zoning Administrator which caused the Cottages to appear before the CAB for review
and approval, declare any such act or omissions to be ultra vires under the
circumstances and direct the Zoning Administrator to return the Cottages application to
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COUNT V – CITY OF MYRTLE BEACH
FREEDOM OF INFORMATION ACT VIOLATION
79. The City is a public body subject to the provisions of the South Carolina
Freedom of Information Act (FOIA) at S.C. Code Ann. § 30-4-10, et. seq.
80. The City maintains documents subject to public disclosure under the FOIA
in various departments throughout the City, including the office of the Zoning
Administrator.
81. The City, and its Zoning Administrator, have a duty to make a response to
FOIA records requests within ten (10) business days of the date of a FOIA request
82. On December 20, 2021, one of your Petitioners filed a request with the
City under the Freedom of Information Act requesting, “All plans, records, drawings,
traffic studies, traffic impact assessments, and all other documents submitted for the
83. The Willows and the Cottages are the only two development plans in the
84. In response, the City provided some, but not all, documents associated
with the Willows Plan for in person review on the morning of January 6, 2022. However,
it did not provide any documents associated with the current Cottages plan nor did it
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state any objections to the production of such documents or provide a reason why same
85. At 1:30 p.m. on January 6, 2022, at a CAB meeting scheduled at the time,
the CAB discussed a revised conceptual plan submission for the Cottages, but did not
take any public comment on same. Petitioners believe that the CAB had a variety of
documents in its possession associated with the Cottages at its January 6, 2022
meeting, and a prior meeting held November 4, 2022, which it was required, but failed,
86. The City did not provide any documents associated with the Cottages
under the December 20, 2021 FOIA until after the CAB meeting on January 27, 2022 at
87. After the January 27, 2022 CAB meeting the City, through its Zoning
88. From December 20, 2022 FOIA to date, the Petitioner has sought
documents and information from the City regarding how the use of the property for the
89. To date, the City has failed to provide any document which would reflect a
statement of policy, or interpretation of the City’s zoning code, adopted by the City,
specifically relating to the R-7 zoning classification of the 76th Ave. Carve-Out, that
would permit two-family or multifamily dwellings within same, nor has it provided a
reason why such document has not been produced or admitted that no such document
exists.
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90. Petitioners believe, and therefore aver, that the City, through its Zoning
Administrator, has arbitrarily and capriciously violated the provisions of FOIA by (a)
voluntarily withholding records associated with the Cottages development until after the
CAB granted final approval for same; (b) attempting to impose unreasonable charges of
$1,000.00 for the search and production of documents that it has in its possession in
digital format; (c) advising Petitioner(s) that certain documents associated with the
Siena Park and Seville developments were no longer available; and (d) piece-mealed
91. The failure of the City, by and through the office of its Zoning
adversely affected, and continues to adversely impact, (a) the ability of Petitioners to
obtain information and documents required to fully assess the appropriateness of the
Cottages plan and (b) actions that could have been taken by the Petitioners if the
92. Petitioners pray that this Court issue an order directing the City to produce
forthwith any written document, adopted by the City, which would reflect a statement of
policy or interpretation of the City’s zoning code stating that two-family or multifamily
dwellings were appropriate for construction within the R-7 zoning classification
attributable to the 76th Ave. Carve-Out or provide a response that no such document
can be produced. In addition, Petitioners request an award of attorney’s fees, costs and
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COUNT VI – CITY OF MYRTLE BEACH – FREEDOM OF INFORMATION ACT
VIOLATION - REQUEST FOR SUPERSEDEAS OR INJUNCTIVE RELIEF
94. For reasons set forth above, Petitioners believe the City, through the office
95. The failure of the City, by and through the office of its Zoning
adversely affected, and continues to adversely impact, the ability of Petitioners to obtain
complies with the City’s Zoning Code are at issue in this case.
97. There are two types of development plans which may be submitted to the
City for approval, namely a “Phased development plan” and a “Site specific
development plan”.
local governing body, or body authorized by the local governing body, to make land
use decisions that shows the types and density or intensity of uses for a specific
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requirements for a site-specific development plan. The Code of Ordinances, City of
local governing body, or a body authorized by the local governing body to make land
use decisions, by a landowner describing with reasonable certainty the types and
density or intensity of uses for a specific property or properties. The plan may be in the
form of, but is not limited to, the following plans or approvals: planned development;
special use permit plan; conditional or special use district zoning plan; or other land
use approval designations as are used by the City; provided that all such plans must
conform to, comply with and satisfy all applicable planning, zoning, subdivision, storm
water management and control, building, fire, water and sewer, road and other City
100. Based on the information provided by the City to date under the
December 20, 2021 FOIA, the Petitioners are unable to determine whether the
development plan” or what stage of review the Cottages plan is currently in.
101. Petitioners believe and therefore aver that the current status of the
Cottages development may tempt plan proponents to request the City to afford the
102. The City may not approve the establishment of a vested right in an
approved phased development plan, and may only approve and establish a vested
right in any phase of a phased development plan, if it conforms to, complies with and
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satisfies all state statutes and county codes and ordinances including, but not limited
to, planning, zoning, subdivisions, storm water management and control, building, fire,
water and sewer, road and other state and county codes applicable to such
development. The Code of Ordinances, City of Myrtle Beach, South Carolina § 20-
73(d).
103. If the City approves a vested right for one or more phases of a phased
development plan, a site specific development plan is required for approval with respect
to each phase in accordance with regulations in effect at the time of vesting. The Code
104. The form and content of a site specific development plan submitted by a
landowner must conform and comply with the city planning, zoning, subdivision, storm
water management and sediment control, building, electrical, mechanical, life safety,
fire, water and sewer, road and other codes, ordinances and regulations applicable to
except in conformity with the city planning, zoning, subdivision, storm water
management and sediment control, building, electrical, mechanical, life safety, fire,
water and sewer, road and other land use codes, ordinances and regulations. The
classification, no phased or site specific development plan can be submitted for the
Cottages that complies with the R-7 zoning classification for the 76th Ave. Carve-Out,
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the Petitioners’ rights to relief are clear and, accordingly, such development cannot be
107. Based on information and belief, Petitioners believe and therefore aver
that following the CAB’s January 27, 2022 approval, additional plan reviews are still
required for the Cottages project, that the project is not approved until all departments
assigned to the project have signed off and that the project will not be ready to permit
until such reviews have occurred and the plans have been determined to be
appropriate.
108. To the extent a vested rights request has been made to the City but not
yet approved, the Petitioners pray that this Court enter a supersedeas as the Court
deems equitable under S.C. Code Ann. § 6-29-920 or otherwise to enjoin the City from
approving same or issuing permits for construction pending the disposition of this
Petition.
109. To the extent a vested rights request has been made to the City and has
been approved, the Petitioners pray that this Court grant equitable relief, declare such
approval to be void or invalid, suspend, set aside and/or vacate such approval as ultra
vires, and enjoin the City from approving any further request for a vested rights pending
110. The Petitioners pray that this Court enter a supersedeas as the Court
deems equitable, together with such other equitable or injunctive relief set forth above,
and enter an award of attorney’s fees costs and expenses in addition to any
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ELECTRONICALLY FILED - 2022 Feb 25 5:40 PM - HORRY - COMMON PLEAS - CASE#2022CP2601234
PRAYER FOR RELIEF
1. Enjoining the City from considering the Cottages plan for vested
rights treatment while this action is pending;
5. Enjoining the City of Myrtle Beach from taking any action with
respect to the Cottages application unless and until the City
complies with the requirements of the Grande Dunes PUD;
7. Such other and further relief as this Honorable Court may deem
just and equitable.
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