HomeMy WebLinkAboutPublic Comment from Fitzgerald 1
Public Comment
Zoning Board of Appeals
June 2026
460 West Main Street, Hyannis - Dover Amendment Religious Use Appeal
My name is Sandra Jones Fitzgerald. I am a Barnstable resident.
I started looking closely at a $3 million federal ARPA grant for homeless services that Barnstable
County awarded to Housing Assistance Corporation (HAC). What caught my attention was not the
amount, though it was significant. It was how the vote happened. The Commissioners approved $3
million in public funds without asking a single question at the meeting, and without one page of
independent analysis in its meeting package. That government body asked not one question – not even
about why there was only one bidder in what was supposed to be a competitive bid process despite all
the homeless service providers on the Cape, or whether using $3 million, or any part of it, to fund more
urgently needed homeless beds was even explored. That government body sat down, voted to approve a
public grant that was effectively sole sourced, and then asked to hear from the grant applicant.
That is what sent me into the documents.
Since then, I have read thousands of pages. This included grant applications, grant agreements, registry
records, financial audits, IRS filings, building permits, and correspondence between HAC and the
government bodies that fund it and regulate it. I want to share with you something I found consistently
across all of it, because it is directly relevant to what you as ZBA members are being asked to decide.
Records show that HAC says different things to different government bodies on the same topic,
depending on the forum and the outcome it is seeking.
I am not asking you to take my word for that. I have attached an Exhibit that documents it. Each entry is
sourced to a specific public document. There are twelve representative illustrations in that exhibit. I
want to walk you through the one most relevant to this appeal. I ask you to review the rest later on.
HAC has described its shelter operations consistently, across years of public filings, as secular social
services work. Its IRS Form 990 filings, its website, its state filings all describe shelter work in secular
terms. That is the baseline.
Here is what happened as HAC sought public money and zoning protection for 460 West Main.
HAC knew from the outset that Catholic Charities was the planned shelter operator. That was not a late
development. It was part of the plan when HAC first applied for public funds.
To Barnstable County - when seeking $3 million in federal ARPA funds to acquire 460 West Main -
HAC identified the Dover Amendment basis for the property as educational use. Not religious.
Educational. That is in the HAC application, on HAC letterhead, in writing. HAC attested to its
accuracy. The County awarded the grant.
To MassDevelopment - when seeking a $354,000 state grant for the same property - HAC referenced
Dover protection. The word religious does not appear once in that application. Not once. HAC attested
to its accuracy. MassDevelopment awarded the grant.
2
To the Town of Barnstable's Affordable Housing Trust - in June 2023, HAC applied for $500,000 in
CPC housing funds for this same shelter project at another location, 55 Falmouth Road (formerly WB
Mason Warehouse). Catholic Charities was already named as the planned operator. That application ran
132 pages. The word religious appears once in all of it - in a footnote to a financial statement noting that
HAC receives clothing donations from, among others, religious organizations. Not one mention of
religious use. Not one mention of a Corporal Work of Mercy. This was HAC, to this town, with Catholic
Charities already in the picture.
To the Town of Barnstable - in April 2025, after the County and MassDevelopment money had been
received - HAC filed a Dover application jointly with Catholic Charities arguing for the first time that
the shelter constitutes a religious use: specifically, a Corporal Work of Mercy under Catholic doctrine.
Barnstable’s Town Attorney did not agree, yet the Building Commissioner issued an affirmative finding.
That finding is what brings us here today.
To Cape Cod towns - in HAC’s CPC applications to Brewster and Sandwich, submitted after the April
2025 religious use filing was already on record with the Town of Barnstable, HAC described the project
as community housing. Religious use was not mentioned.
So the timeline is this:
• To the IRS and state regulators, consistently over years: secular.
• To the County, seeking $3 million: Dover protection based on educational use.
• To the Town of Barnstable Affordable Housing Trust, in a 2023 application for CPC housing
funds for the same shelter project with Catholic Charities already named as operator - 132 pages,
the word religious appears once, in a footnote referencing clothing donations from religious
organizations. Not one mention of religious use. Not one mention of a Corporal Work of
Mercy. This was HAC, to this town, with Catholic Charities already in the picture.
• To MassDevelopment, seeking $354,000: Dover referenced, religious use not mentioned.
• To the Town of Barnstable, seeking a zoning exemption: religious use - for the first time.
• To the Town of Brewster and Sandwich, seeking CPC funds, religious use not mentioned.
The religious characterization appeared when HAC needed it for zoning. It did not appear when
HAC sought public money from government bodies that had no zoning interest in the outcome.
Your job is to gather and assess facts and law independently. I am asking you to do that -
genuinely and rigorously - and not to simply accept what HAC presents to you today at face value.
The reason I started pulling documents was that a government body sitting at a bench like you are
approved $3 million without asking a single question, without a single page of independent analysis in
its meeting package. To emphasize the point – public documents show HAC told the County different
things about its use of $400,000 of a homeless services grant that could not conceivably both be true,
and yet, the County government accepted it and filed with the federal government. This is documented.
I am asking ZBA members to do better than that.
The question of whether a use is genuinely religious in character - dominant and primary, as
Massachusetts law requires - is a serious factual and legal question. It deserves serious scrutiny and
independent fact-finding, especially given the documented pattern of how this characterization has
evolved depending on the audience HAC appears before.
3
Please review Exhibit A. Every entry is sourced. Every source is a public document. None of it is
opinion or views or inferences. Draw your own conclusions.
Reading public documents is not anti-HAC. It is not anti-shelter. It is not anti-homeless. Government
bodies that award public funds and make zoning decisions depend on accurate and consistent
representations from applicants. When the record shows those representations shift depending on who is
asking and what outcome is needed, every government body asked to rely on them - including the ZBA -
has to examine the facts independently. That is all I am asking you to do.
Thank you.
4
EXHIBIT A
Documented Inconsistencies in HAC's Representations Across Government Bodies
Submitted by: Sandra Jones Fitzgerald | June 2026 | Re: 460 West Main Street, Hyannis -
Part A shows representations HAC made to different government bodies on the same subject
that are inconsistent with each other.
Part B shows public claims HAC made that are unsupported by, or contradicted by, records in
the relevant agency's files, HAC's audited financials, or the Barnstable Registry of Deeds.
Every entry is sourced to a specific public document.
These are not interpretations. They are what the documents say.
Subject What HAC said
and to whom
What HAC said to
a different body
on the same
subject - or what
the public record
shows
Source
Documents
PART A. HAC made inconsistent representations to different government bodies on
the same subject. Each entry is from documents HAC submitted or was bound by.
Dover
Amendment
basis for 460
West Main
Street
To Barnstable
County - in its
application for
$3M in federal
ARPA funds to
acquire 460
West Main -
HAC identified
the Dover
Amendment
basis as
educational use.
Not religious.
To the Town of
Barnstable - in its
April 2025 Dover
filing, submitted
after receiving both
County and
MassDevelopment
funds - HAC argued
for the first time that
the use is religious:
a Corporal Work of
Mercy under
Catholic doctrine.
County ARPA
application;
HAC/Catholic
Charities Dover
filing to Town of
Barnstable
Religious use in
the
MaDevelopment
application?
HAC's certified
application to
MaDevelopment
for a $354,000
state grant for
460 West Main
referenced
Dover
Amendment
By the time HAC
submitted this
application (certified
June 4, 2025), it
had already been
working with
Catholic Charities
on the shelter plan.
Catholic Charities'
HAC UPP
Application
(certified June 4,
2025 by CEO
Alisa Magnotta)
5
Subject What HAC said
and to whom
What HAC said to
a different body
on the same
subject - or what
the public record
shows
Source
Documents
protection. The
word religious
does not appear
in that
application - not
once.
role as operator
was the stated
basis of the later
religious use claim
to the Town of
Barnstable.
Religious use -
in HAC’s 2023
application to
the Town of
Barnstable’s
Affordable
Housing Trust?
In 2023, HAC
applied to the
Town of
Barnstable’s
Affordable
Housing Trust
for CPC housing
funds for the
same shelter
project. Catholic
Charities was
already named
as the planned
operator. The
application ran
132 pages. The
word religious
appears once -
in a footnote to a
financial
statement noting
that HAC
receives clothing
donations from,
among others,
religious
organizations.
Not one mention
of religious use.
Not one mention
of a Corporal
Work of Mercy.
Two years later,
HAC filed a Dover
application to the
same Town of
Barnstable - with
the same Catholic
Charities as
operator - arguing
for the first time that
the shelter is a
religious use. Same
town. Same
applicant. Same
operator. A 132-
page application to
the town’s Trust
Fund contained no
religious use
argument. The
religious
characterization
appeared only
when zoning relief
was needed.
HAC application to
Town of
Barnstable
Affordable
Housing Trust
(2023);
HAC/Catholic
Charities Dover
filing to Town of
Barnstable (April
2025)
Religious use -
in the CPC
HAC submitted
CPC
These CPC
applications were
HAC CPC
applications to
6
Subject What HAC said
and to whom
What HAC said to
a different body
on the same
subject - or what
the public record
shows
Source
Documents
applications to
Cape towns?
applications to
Brewster,
Sandwich (and
other Cape Cod
towns) seeking
$100,000 each
for the 460 West
Main renovation.
Those
applications
described the
project as
community
housing.
Religious use
was not
mentioned.
submitted after
HAC had already
filed its religious
use claim with the
Town of Barnstable
in April 2025. HAC
knew the religious
use argument was
on record when it
described the same
project as
community housing
to CPC committees.
Brewster,
Sandwich, and
other Cape towns
(2025-2026)
Whether
operating a
shelter is
secular or
religious work
HAC's IRS Form
990 filings,
website, and
state filings
consistently
describe shelter
operations in
secular terms
across multiple
years. No filing
characterizes
shelter work as
religious activity.
HAC's April 2025
Dover filing to the
Town of Barnstable
characterizes the
same shelter
operations as a
religious use - a
Corporal Work of
Mercy - for the first
time, in the context
of seeking a zoning
exemption.
HAC IRS Form
990 (multiple
years); HAC
website and state
filings;
HAC/Catholic
Charities Dover
filing (April 2025)
When the ARC
shelter project
originated
HAC's CEO
stated publicly
that the project
"has been five
years in the
making" and that
the Asclepius
reorganization
negotiations
began in 2018 -
HAC's CPC
application to Cape
Cod towns stated
the project's
"beginnings were
rooted in the spring
of 2021 with
COVID-19 still a
pandemic" - placing
the origin in 2021,
HAC CEO public
statements;
County ARPA
application and
closing documents
(2024); HAC CPC
application to
Cape towns
(2025-2026)
7
Subject What HAC said
and to whom
What HAC said to
a different body
on the same
subject - or what
the public record
shows
Source
Documents
before COVID-
19 existed. The
County ARPA
program
required a
specific COVID-
19 harm as an
eligibility
condition.
which connected
the project to
COVID. This is a
different date from
what appears in the
County ARPA
record.
Whether
$400,000 in
ARPA funds
had been spent
On June 10 and
June 16-19,
2025, HAC
represented to
Barnstable
County that the
$400,000
renovation
budget had not
yet been spent
and provided a
forward-looking
expenditure
plan.
On June 27, 2025 -
8 days later - HAC
represented to the
same County body
that the identical
$400,000 had
already been fully
spent during Q4
2024 on completed
renovations at 255
Independence
Drive. Both cannot
be true.
Barnstable County
ARPA monitoring
correspondence
(June 10, 16-19,
and 27, 2025)
What the $3M
ARPA grant
was for
HAC's CEO
signed a sworn
statement (April
24, 2024): "The
$3,000,000 in
ARPA funding
will be used to
gain site control
of the property
located at 460
West Main
Street."
$400,000 of that
same grant was
subsequently
attributed to
renovations at 255
Independence Drive
- a different
property entirely,
and HAC's own
administrative
headquarters.
HAC CEO sworn
statement (April
24, 2024);
Subrecipient
Monitoring Report
(August 29, 2025)
Municipal
support letter -
MaDevelopment
UPP application
In its application
to
MaDevelopment,
HAC labeled an
The letter was
written by a single
Town Councilor,
Matthew Levesque
HAC UPP
Application
attachment index
8
Subject What HAC said
and to whom
What HAC said to
a different body
on the same
subject - or what
the public record
shows
Source
Documents
attachment as
"Letter of
Support — Town
of Barnstable,"
presenting it as
a letter of
municipal
support from the
Town.
(Precinct 10), in his
individual capacity.
The Barnstable
Town Council took
no vote, passed no
resolution, and
gave no institutional
authorization.
Levesque also said
the property was
vacant when it was
not - HAC filed it.
(2025); Councilor
Levesque letter
How that same
letter was
described to
Brewster's CPC
In its CPC
application to the
Town of
Brewster, HAC
wrote: "There is
also a letter of
support attached
from the
Barnstable Town
Council, as the
building is
located in
Barnstable."
It was the same
individual
councilor's letter —
no council vote, no
resolution, no
authorization. In the
Brewster
application, HAC
described it in
narrative text as a
letter from the full
Town Council.
HAC CPC
application to
Town of Brewster
(2025-2026)
How long
tenants had the
right to remain
at 460 West
Main
HAC's UPP
application
narrative stated
the tenants at
460 West Main
held leases
through the end
of 2025.
The Barnstable
County ARPA grant
agreement -
executed November
2024 and attached
as an exhibit - gave
the Asclepius co-
owners occupancy
rights extending to
late 2026. The
document
contradicted the
lease
representation.
HAC UPP
Application
(certified June 4,
2025); Barnstable
County ARPA
Grant Agreement
(November 2024)
9
Subject What HAC said
and to whom
What HAC said to
a different body
on the same
subject - or what
the public record
shows
Source
Documents
PART B — HAC made public claims that are unsupported by - or contradicted by -
records in the relevant agency's files, HAC's own audited financials, or the
Barnstable Registry of Deeds.
MaDevelopment
grant claimed
for 255
Independence
Drive
renovations
HAC's
November 2024
press release
stated that a
MaDevelopment
grant supported
renovations at its
new
headquarters at
255
Independence
Drive.
No such grant
appears in
MassDevelopment's
public award
records, or in HAC's
FY2025 audited
financial
statements.
HAC press
release
(November 2024);
MassDevelopment
One Stop award
records (FY23-
FY26); HAC
FY2025 audit);
When the
$400,000
renovation at
255
Independence
Drive took
place
HAC
represented to
Barnstable
County that the
$400,000 was
spent renovating
255
Independence
Drive during Q4
2024 (October
through
December 2024)
- after the ARPA
grant was
awarded.
Barnstable building
permit records
show the relevant
permits - office
alteration, sprinkler
installation, kitchen
installation - were
pulled in September
2024, before the
ARPA grant was
even awarded on
November 26,
2024. No permits
were pulled at that
address during Q4
2024.
County ARPA
monitoring
correspondence
(June 27, 2025);
Town of
Barnstable online
building permit
portal
All source documents are public records available from Barnstable County, the Barnstable
Registry of Deeds, MassDevelopment, the Town of Barnstable, and HAC's IRS filings. Copies
available upon request.