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MoeM (<Click to Select State>)
Posts: 12
Posted:
Some months ago the architectural committee denied an application for rooftop photovoltaic solar installation on grounds that were interpretted by the owner as being aesthetic, altho the specific grounds for denial were not enunciated. The denial was as mandated by bylaws (in writing and within 30 days). The denial included several comments, that a) a differently configured plan would be approved, and b) the committe needed more technical information regarding the proposed installation.

Bylawas state that if the HOA has neither approved nor disapproved in writing of an architectural submission within 30 days, approval is not required and the owner is free to commence the work as if all provisions of the submission process had been met.

Five months later, the owner submitted a second application. The application was sent certified/return receipt. The return receipt was signed, but not dated, by a management company owner/employee. The US Postal Service web site shows a delivery day and time—within business hours at a POBox. An email was sent to the owner confirming delivery by the management company principal a day or two later.

1. which delivery date is the legally effective one:
- USPS timestamp of delivery to HOA agent postal box
- signed but undated return receipt
- date of email sent by HOA agent?

The HOA failed to deliver to the owner either an approval or formal denial within a 30 day period as measured from USPS timestamp. A board meeting occurred on the 30th day from the date of the email during which the application was discussed with the owner present. During the meeting it was evidenced that:
- the architects denied the application (no grounds were given, only implied as aesthetic)
- the architectural committee chair indicated but did not explicate disapproval of the project
- another architectural committee member's objections were neither responded to nor taken up; this member stated that s/he was not included in any prior committee deliberations
- although subsequent owner/HOA conversation regarding project details has ensured, the HOA has not in writing, or explicityly, approved or
denied the second application, even within the "second" 30 day timeframe as measured by the date of email acknowledgement of the original submission.

2. given the HOA failure to respond in writing within either date timeframe, is defacto approval given to proceed despite architectural committee objections as either previously written on the first application or for any other reason?
HaroldS (Arizona)
Posts: 906
Posted:
Sounds like you are home free! Go ahead and install it, but save all your documentation. You can request a copy of the board meeting minutes too for your records, where it was discussed but neither approved nor denied. Good luck. Harold
RogerB (Colorado)
Posts: 5,067
Posted:
Moe, you have defacto approval but I would CYA by sending a letter outlining these facts and that you believe this provides defacto approval. Ask them to advise if they disagree and state their basis.

BTW, I know Colorado passed a statute in 1982 allowing solar installation. It overrides many aspects of HOA Declarations which would otherwise prevent their installation.
MoeM (<Click to Select State>)
Posts: 12
Posted:
The statute is an interesting one in that the main clause establishes the illegality of denying solar on aethetic grounds. The 2nd clause, however, says that an HOA can enforce "reasonable" aesthetic requirements so longs as implementing them doesn't cost appreciably. To wit:

"(2) Subsection (1) of theis section shall not apply to aesthetic provisions which impose reaonable restrictions on solar energy devices and which do not significantly increase the cost of the device."

So, potential areas of contention for anyone taking this up are what constitutes "reasonable" and "significant" cost increases (and how that's interpreted over the 30 year system horizon...for instance, does reduced energy generation due to an enforced HOA small footprint requirement based in fact or presumably on aesthetics, constitute an increased cost due to lost savings of said power generation—even though it would cost an owner more $ upfront to install a larger array?

Seems like the statue leaves a yawning loophole that hasn't been litigated...yet (suspect Amendment 37 and all the new solar activity based on it, with it's ma$$ive rebates, will stimulate a case).
MoeM (<Click to Select State>)
Posts: 12
Posted:
btw the statute is C.R.S. §38-30-168 Unreasonable restrictions on solar energy devices void.
LuciusD
Posts: 139
Posted:
It has been litigated. I believe the reference is:

705 P.2d 1011, Colorado Court of Appeals, Div. III. GOVERNOR'S RANCH HOMEOWNER'S ASSOCIATION, INC., a Colorado corporation not for profit, Plaintiff-Appellant, v. Walter F. GUNTHER, Defendant-Appellee. No. 84CA0486. April 11, 1985

I understand the HOA lost "big-time".
LuciusD
Posts: 139
Posted:
MoeM,
I went through a similar process earlier this year in Colorado with and ignorant comittee and an uninformed board both of whom were disinclined to see new solar energy get started in their "front-yard".
The request is now fully approved and similar ones will be.
I will be happy to share my research and experience.
[email protected]

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