Agreement for Legal Services_Ted A. Cox

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prohibits the installation and use of such diesel pumps on the Project. The Project does not constitute a truck stop as defined in of Special Conditional Use Permit #15-91000004. The actions and decisions of Mr. Alexander are not based on the facts and law or City ordinance and me unreasonable, arbitrary and capricious and are an interference with Owner's property rights. The installation of the diesel dispensers in question was approved and authorized by the City and its representatives. No objection was made by Mr, Alexander until after completion of construction. Owner relied upon the actions and approvals by the City in the construction and installation of the diesel pumps by spending hundreds of thousands of dollars for the installation of such diesel pumps at the Project, The City is estopped to complain or use as a justification for denial of the Certificate of Occupancy the installation of such diesel pumps and such estoppel will not interfere with the City's governmental functions. Certificate of Occupancy The City of La Porte Ordinances contain no provisions regarding the requirements for the issuance of the Certificate of Occupancy. However, the City has adopted the International Building Code 2002 edition and the relevant provisions of the IBC regarding the Certificate of Occupancy and the issues in this appeal are the following: SECTION 101 GENERAL The purpose of this Code is to establish the minimum requirements to safeguard the public health, safety and general welfare through structural strength, means of egress facilities, stability, sanitation, adequate light and ventilation, energy conservation, and safety to life and property from fire and other hazards attributed to the built environment and to provide safety to fire fighters and emergency responders during emergency operation. The IBC provides in Section 111 for the issuance of a Certificate of Occupancy as follows: