HomeMy WebLinkAbout2.6.2026 Supplemental Submission Memorandum (195 Phinney's Lane et al, Centerville)1
Law Office of Singer & Singer, LLC
26 Upper County Road
P. O. Box 67
Dennisport, Massachusetts 02639
Andrew L. Singer Tel: (508) 398-2221
Marian S. Rose Fax: (508) 398-1568
_____ www.singer-law.com
Myer R. Singer (1938-2020)
EMAIL MEMORANDUM
To: Barnstable Board of Appeals
From: Andrew Singer, Attorney
Date February 6, 2026
Re: Great Marsh Development LLC
Comprehensive Permit No. 2025-025
This Memorandum is a supplemental submission in response to questions and comments received
at the first session with the Board on the above housing proposal. The Applicant’s goal within is to
clarify and answer as many questions as possible at this time to assist the hearing process as it moves
forward. We anticipate that there will be additional questions and requests for consideration after our
next session with the Board.
Below is a discussion of the following topics (which aggregates questions raised by both Board
members and comments from the public):
1) Environmental (wastewater and stormwater);
2) Transportation (vehicular and pedestrian);
3) Site Design and Screening;
4) Comprehensive Permit Law; and
5) Miscellaneous.
Discussion
Environmental (Wastewater and Stormwater)
The Property is located in the RPOD Zoning Overlay District as well as a Saltwater Estuary
Overlay District. The development will reduce the amount of nitrogen being discharged into the ground,
compared to both existing conditions and that which could be generated with a traditional, non-affordable
subdivision, and will result in a net benefit to the environment in a nitrogen sensitive area. Specifically,
at present there are seven (7) existing bedrooms on four lots. These are each serviced by a respective
Title V septic system. The combined nitrogen load is 3.11 ppm. With the proposal (56 units) being
located on Town sewer, the combined nitrogen load will be reduced to 1.61 ppm, reflecting a 50%
reduction over existing conditions.
When the Town negotiated with the Applicant for an easement to locate piping for the new Town
sewer station adjacent to the Property on the Applicant’s land, the effluent from the Centerville Cove
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development was factored into the calculations. Adding the new subdivision into the sewer will thus not
delay or block any other properties from being attached to the sewer in the ordinary course.
In addition, the Town installed a sewer stub onto the Property as part of the sewer extension. The
Applicant will be responsible for installing the sewer infrastructure, both cost and construction, in the new
subdivision, not the Town. A betterment assessment and sewer connection permit will each be applicable
to the twenty-one proposed lots in the new subdivision. Because of the foregoing, future sewer
connections of surrounding residential neighborhoods to the Property will not be delayed or negatively
impacted as a result of the development.
In response to a question about the Commonwealth Builder Program, which the Applicants hopes
will be the subsidy program for the development, the Town’s installation of the sewer stub will serve as
the Town’s required contribution towards the project.
Stormwater management (SWM) will be provided for the development following both MassDEP
Stormwater Management Policy and the Barnstable SWM requirements. The SWM design will be fully
reviewed by the Barnstable DPW (BDPW), and the Applicant will address any comments they have. The
waiver request from the BDPW SWM Permit is only for a waiver from the “papering” process of the
permit. The process of the permit creates additional costs, and the Applicant is attempting to keep costs
down which ultimately benefits the costs of the units.
Transportation (Vehicular and Pedestrian)
The Traffic Impact and Analysis Study (TIAS) prepared by VHB studied six different
intersections and collected peak hour data during the summer. It investigated crash history, public
transportation availability, as well as present day and future road conditions.
VHB is a well-respected engineering firm that has completed many hundreds of studies on Cape
Cod and elsewhere for applicants and also maintains on-call design contracts with several Cape Cod
Towns. The TIAS determined that no Level of Service (LOS) changes will be created with the project.
The proposed residential development will result in a total of 344 new vehicle trips per day. Of
these, there will be a total of 28 new trips (7 entering/21 exiting) during the weekday morning peak hour,
and 33 trips (20 entering/13 exiting) during the weekday evening peak hour. At peak hours (the busiest
times), this is the equivalent of less than one new car per minute (0.46 and 0.55), exiting or entering at
Great Marsh Road.
The TIAS concludes that “Capacity analyses were conducted for each of the study area
intersections and roadway segments under 2025 Existing conditions, 2032 No-Build conditions (without
the proposed development), and 2032 Build conditions (with the proposed development). The analysis
results show only minor changes at study area intersections because of this Project.”
The proposal will result in the net elimination of three existing or proposed driveways with
residents backing out onto Great Marsh Road. There will be only the new roadway with a curb cut on
Great Marsh Road. The Applicant proposes to install stop signs and stops bars within the new subdivision
and at this curb cut. The Applicant is also willing to install the same on Juniper Road at its intersection
with Great Marsh Road.
The proposed location of the subdivision curb cut on Great Marsh Road lines up with the layout
of the old paper road running through the land. The Applicant reviewed the possibilities of proposing a
four-way stop at the new subdivision or shifting the new roadway to off-set from Juniper Road. From a
transportation engineering perspective, neither of these is warranted nor desirable. The former would lead
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to further traffic delay closer to the Phinney’s Lane intersection. The latter would interject new conflict
points along the road and potentially lead to headlights shining into houses across the street.
In discussion with the Town DPW and COMM during informal site plan review and thereafter, an
emergency access drive out to Phinney’s Lane was requested. This ground-vegetated drive is shown on
the plans with a permanent gate and a knox box providing keyed access as needed to public safety
personnel only.
As requested by the Town, there will also be pedestrian access in this location out to Phinney’s
Lane. The Applicant has agreed to install a sidewalk along Phinney’s Lane to connect to the existing
Route 28 sidewalk and crosswalk. A question was raised as to whether this pedestrian path could be
shifted onto the Town’s adjacent, sewer pump station property. If the Town is willing to grant the
Applicant an easement to do so, this is a potential option.
The proposed subdivision will not result in any thru-traffic to adjacent subdivisions. The exiting
traffic from the proposed development is intended to travel either left or right onto Great Marsh Road.
The internal speed limit will be signed for 20 mph. In such a situation and as generally followed
throughout Barnstable in residential subdivisions, internal sidewalks are not common and one is not
proposed for this subdivision.
School buses will stop on Great Marsh Road as they do at present. The Applicant is willing to
install a bus shelter in the entrance area.
Site Design and Screening
The Centerville Cove housing is intended to serve an unmet need in the community. Owners of
the lots and renters in the apartment building will be teachers, nurses, public safety personnel, and young
people, among others.
The Applicant is proposing a mix of three- and four-bedroom homes. Elevations and floor plans
for the four-bedroom option are included with this supplemental submission. Elevations and floor plans
for the two three-bedroom options have previously been submitted.
Each house lot will have a private, two-car driveway. There will be building envelopes and
landscaping, and individual lot development and utility plans will be provided when seeking building
permits.
Regarding the apartment building lot, the Barnstable Zoning Ordinance requires 9 x 20 parking
spaces, though there is also a graphic included in the Ordinance that allows for 9 x 19 parking spaces.
Ten-foot wide spaces are not part of the Zoning Ordinance. The Applicant is proposing 9 x 19 parking
spaces in accordance with customary design.
The requested waiver for building height is to be only six inches above and for a half-story
beyond what the Zoning Ordinance allows. If the top floor was limited to half the size of the floor below,
then it would be considered a 2.5 story building. This, however, is not feasible as part of the affordable
housing proposal.
The proposed apartment building is suitable for this transition zone between the commercial
shopping plazas and larger development to the west and the residentially used districts. The building, at
its closest point to the traveled ways, respectively, will be located approximately 390 ft. from Great
Marsh Road, approximately 300 ft. from Phinney’s Lane, and approximately 260 ft. from Route 28. The
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building will also be screened by existing and proposed vegetation and buildings. The roof of the
building may be visible from off site in the distance.
There will be bike racks at the apartment building. No exterior storage is proposed at the
apartment building. Solar is not an option with the apartment building because mechanicals will be
located on the roof to hide them from view. The individual homes will be solar-ready for the future.
There will be a ten-foot landscape buffer along Great Marsh Road. The Applicant will maintain
the existing vegetation in this buffer to the extent practical and is also willing to plant additional trees in
this buffer to enhance the buffer. There will be additional trees and vegetation planted as well where
existing driveways are being closed on Great Marsh Road.
There will be no fence around the playground, but there may be as required around the
stormwater management area. The playground will be open to all residents of the subdivision.
The Applicant can provide a rendering from Great Marsh Road later.
Lighting will be dark-sky compliant with no glare off site.
Comprehensive Permit Law
As set forth in the Barnstable Comprehensive Permit Regulations and in accordance with State law, an
Applicant submits preliminary plans – site development, utilities, architectural, and subdivision, for review.
This anticipates that final plans will be prepared after the Comprehensive Permit has issued. Conditions
are appropriate to ensure, e.g., that the ultimate connections to the Town sewer, the final stormwater
management system, and the layout of the improvements to be built on the for-sale lots are prepared and
submitted before obtaining local permits to install and build.
In this case, the Board of Appeals is serving as the Planning Board for purposes of the proposed
subdivision. In accordance with MA law, a Town reviewing a project involving affordable housing looks
at the proposal the same way that it would in reviewing projects not involving affordable housing. For
example, when looking at Site Design and Screening for Centerville Cove, the location of the land in a
transition zone between larger, more intense commercially-zoned land and more traditionally-developed,
residentially-zoned land is part of the analysis. In addition, screening vegetation is meant to soften the
property and make it more attractive, not to block buildings from visibility.
The legal standard and vote required in review of Chapter 40B proposals is different than the legal
standard under traditional zoning in Chapter 40A. For Chapter 40B, the Board votes by majority, not super-
majority vote, and the standard of review is whether the proposed development is “consistent with local
needs.” This is a defined term and is more than simply whether there is neighborhood support or opposition.
There is a rebuttable presumption in MA law that an affordable housing project under Chapter 40B is
consistent with local needs if a local community’s restricted affordable housing is less than ten percent of its
year-round housing stock:
A. “There exists a rebuttable presumption that the regional affordable housing need
outweighs local concerns where the town's stock of low and moderate income housing is
less than ten percent.” (see Zoning Board of Appeals of Holliston v. Housing Appeals
Committee, 80 Mass. App. Ct. 406, 414 (2011) and Zoning Board of Appeals of Hingham
& another v. Housing Appeals Committee & another, 24-P-828, 2025, Appeals Court of
Massachusetts); and
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B. In Zoning Board of Appeals of Canton vs. Housing Appeals Committee & another (451
Mass. 158, 2008), the MA Supreme Judicial Court in a footnote wrote that “Pursuant to
G. L. c. 40B, §§ 20-23, if a municipality has devoted ten per cent of its total housing units
to low or moderate income housing, it may deny a comprehensive permit application, and
that denial is conclusively presumed to be consistent with local needs. A denial in these
circumstances is not appealable to the Housing Appeals Committee (HAC).”
There are certain matters that are within a Board’s jurisdiction to request and review in affordable
housing projects and others which are reserved for the State. The MA Housing Partnership’s Chapter 40B
Handbook for ZBA’s (2017), notes:
A. “The Chapter 40B Regulations specifically prohibit reviewing ‘a pro forma in order to see
whether a Project would still be economic if the number of dwelling units were reduced,
unless such reduction is justified by a valid health, safety, environmental, design, open space,
planning, or other local concern that directly results from the size of a project on a particular
site’ (760 CMR 56.05(6)(a)(4)). Reducing the density of a comprehensive permit
development should be based on valid planning considerations, design deficiencies, or
environmental impacts.”
B. “Recent case law and changes to the Chapter 40B Regulations have helped to distinguish
aspects of comprehensive permits that belong with the ZBA and those reserved for
Subsidizing Agencies. As with any other type of development, local jurisdiction includes the
physical and operational aspects of a project and its impact on public health and safety and
environmental design. In general, conditions of approval that involve these interests are
appropriate for a comprehensive permit, assuming they are based on local requirements,
customarily apply to other types of housing development in the community, and do not make
the proposed project uneconomic.”
The Board is charged with reviewing a proposal under the above standard and may include conditions
that do not render a project uneconomic. The Board balances the need for affordable housing with zoning,
environmental, health, safety, site design, open space, and planning impacts of the proposed development. The
goal is to create quality housing that is affordable for qualified individuals and families and a source of pride to
its residents, the Town, and the project proponent, while at the same time appropriately protecting public
health, safety and welfare.
Miscellaneous
Waivers. The Applicant will subsequently provide more specificity to each requested waiver.
ADU’s. The question of ADU’s on lots within an affordable housing subdivision has not been
answered by the State at this time. If the Applicant learns of an answer during the public hearing process,
we will so inform the Board.
HOA. There will ultimately be an HOA for the subdivision, but this is not a traditional part of
regulatory review. This notwithstanding, if there are specific concerns for which a particular restriction
might be potentially relevant, the Applicant is willing to discuss the same with the Board.
Plans. If there are certain matters that the Board would like to see on the plans which can be
reasonably added at this stage, the Applicant welcomes discussion with the Board on such requests.
Thank you.