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Administrative Appeal
BCC Appeal
LINCOLN COUNTY BOARD OF COUNTY COMMISSIONERS STAFF REPORT
Administrative Appeal HEARING TIME AND DATE: 10:00 a.m., July 8, 2026 LOCATION: Lincoln County Courthouse, Commissioner Boardroom 3rd Floor, 925 Sage Ave., Kemmerer, Wyoming & Via Video Conference Afton Branch Office Building Conference Room, 421 Jefferson St., Afton, Wyoming
File # Administrative Appeal
APPLICANT: Boardwalk Real Estate, LLC PROJECT NAME: Star Valley Trailer Park (Chaparro Trailer Court) COMMUNITY PLAN AREA: Upper Valley ZONING: Rural PLANNER: Ken Kuluski
REPRESENTATIVE: Jim Miller, Manager PARCEL ID: 3318-293-01-001, 3318-293-00-013
_____________________________________________________________________________ PROPOSAL: Permit application to construct two (2) RV pad sites on both lot 16 Star Valley Trailer Park and lot 5 of Grunig Meadows
LOCATION: Located 4 miles north of the Town of Afton, Wyoming in T33N, R118W, Section 29
_____________________________________________________________________________ ATTACHMENTS: 1. Notice of Appeal dated March 5, 2026 2. Notice of Denial of Application dated February 3, 2026
BACKGROUND:
Currently Lot 16 of Star Valley Trailer Park has a quadplex and two accessory dwellings authorized by a conditional use permit 104 CUP 24 (violation remedy). Currently Lot 5 of Grunig Meadows has a
primary and accessory dwelling most recent authorized under permit # 354 RUS 22 on the property. PLANNING OFFICE BACKGROUND Rural Zone allows for the permitting of a primary residence (dwelling) and a guest house (dwelling)
(with size restrictions) on each parcel or lot. Residential Use Permit Application Requirements A. the following are the requirements for Residential Use Permits (applies to Single and Two-family dwellings, Townhomes, Duplexes, Twin Homes and Guest Houses -see land use Chapter 7 (Chapter 2
page 8)
Administrative Appeal
BCC Appeal
Definitions
Dwelling- A building or portions of it, containing one (1) or more living units. This term does not
include any self-contained R.V., motel, hotel, club, or short-term rentals such as Bed and Breakfast
establishments as defined herein. (Chapter 7 page 5) Exempt use not requiring a permit
Non-commercial parking of recreational vehicles unless connected to water and waste facilities.
(Chapter 7 Land Use Table 7.3 page 18)
Boardwalk Real Estate
c/o Jim Miller
PO Box 610
Wilson, WY 83014
March 5, 2026
OƯice of Planning and Development – Lincoln County Wyoming
RE: Appeal of ‘Notice of Denial of Applications’ for Lot 16 of Star Valley Trailer Park and Lot
5 Gruning Meadows, dated February 3, 2026
To Whom it May Concern:
Boardwalk Real Estate acquired the “Star Valley Trailer Park” in March 2022. I described
the park when I bought it as the “worst living conditions in the United States I have ever
seen.” We have replaced over 20 homes and fully remodeled another 7. I have redone all
the electrical infrastructure. I just finished investing $200,000 into the water infrastructure.
On top of the $2,000,000 in improvements I have already made, I just received a permit to
redo the sewer in the park and will invest another $200,000. By the end of 2025 the park
will have all new water, sewer, and electrical – all without any governmental assistance.
Boardwalk Real Estate is appealing the permit denial per the finding “Under Lincoln County
LUR each property in Lincoln County is allowed a primary and accessory dwelling. RV’s
that are not self contained are considered Dwellings and therefore are included in the two
dwelling calculation. Due to this your applications are denied.”
The permit application was to construct two RV pad sites on both Lot 16 and Lot 5.
The relevant definitions per the LUR:
Dwelling - A building or portions of it, containing one (1) or more living units. The term does
not include any self-contained R.V., motel… as defined herein.
Building – Any structure with substantial walls and roof securely aƯixed to the land and
entirely separated on all sides from any other structure by space or by walls in which there
are no communication doors, windows, or opening; which is designed or intended for the
shelter, enclosed for protection of person, animals, or property of any kind.
Recreational Vehicle – an automobile, travel trailer, camp-car, camper, bus, motor home,
tent-trailers or other vehicular or portable unit, with or without motive power, designed and
constructed for travel and intended for human occupancy as temporary living quarters for
recreational or travel purposes.
Boardwalk Real Estate does not dispute that lots 5 & 16 each already contain 2 Dwelling
units each as defined by the LUR. What we are appealing is that an RV Pad Site (which is
what the permit application is for) is a Dwelling.
1. The LUR’s define Dwelling – “as a Building or portions of it”. The LUR’s define
Building as “any structure with substantial walls and roof securely aƯixed to the
land…” No one would define an RV, or more specifically the applied for “Construct 2
RV Pad sites” as a “structure with substantial walls and roof securely aƯixed to the
land.
2. The LUR’s state “The term (Dwelling) does not include any self-contained R.V…”
Thus, interpreting an RV as a Dwelling is specifically excluded from the definition.
It is impossible to define an RV Pad Site as a Dwelling, thus the OƯice of Planning and
Development incorrectly denied my permit for 2 RV Pad Sites on Lots 5 & 16 by defining
them as Dwellings. I ask that the permit be issued immediately.
Sincerely,
Boardwalk Real Estate LLC
James W. Miller, Manager