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HomeMy WebLinkAboutRebuttal from Attorney Brennan & Winn Development Company Robert L. Brennan, Jr., Esq. O : 978 -965 -5885 | M : 617-233 -4897 rbrennan @smolakvaughan.com {00316591;v2} 120 Water Street, Suite 406, North Andover, MA 01845 WWW.SMOLAKVAUGHAN.COM June 16, 2026 Jacob Dewey, Chairman Barnstable Zoning Board of Appeals 367 Main Street Hyannis, MA 02601 Re: 307 Main Street, Hyannis – Response to Appeal of Building Permit Dear Chairman Dewey and Honorable Members of the Zoning Board of Appeals: Winn Development Company, LP (“Winn” or the “Applicant”), by and through its attorneys, respectfully submits for distribution to the Zoning Board of Appeals, ("Board") this response to the Appeal of the Building Permit ("Appeal") issued for the redevelopment of 307 Main Street in Hyannis (the “Project”) filed by Main Street Times LLC and its managers, Aaron B. Bornstein and Ethan S. Bornstein (the “Appellant”). First, the appeal is not meritorious because the Appellant has not satisfied its burden to "sufficiently allege and plausibly demonstrate" standing as "persons aggrieved" as required by G.L. c. 40A, §17; Section 11 of Ch. 150 of the Acts of 2024. Thus, as provided further below, the Appellant lacks standing to bring its appeal and such appeal should be dismissed in the first instance. Second, and in the event the Board finds that the Appellant has standing to consider the merits of the appeal, the Board should deny the Appellant's claims because Barnstable Building Commissioner Brian Florence properly and reasonably interpreted and applied the Town of Barnstable Zoning Ordinance ("Ordinance") in issuing the Building Permit for the Project. The Appellant’s claims are premised upon an incorrect reading of the Downtown Main Street (“DMS”) zoning provisions, including the applicability requirements of Section 240-24.1.5.E.1 and the Surface Parking Design Standards referenced in the Appeal. Finally, the Appellant’s claim challenging the use of “compact” parking spaces also ignores the reasoned determination issued by Commissioner Florence to the Barnstable Planning Board on January 12, 2024, finding that Winn’s use of compact spaces at the Project was consistent with the Zoning Ordinance – a determination that the Appellant avails itself of and benefits from in connection with its Dockside Condominium project at 110 & 115 School Street, Hyannis. As demonstrated further below, the Project complies with the applicable zoning requirements and Appellant's challenges to Commissioner Florence's proper interpretation of the Ordinance in connection with the Project are without merit and are not a basis to annul the Building Permit. The Building Permit was lawfully issued, and the appeal should be dismissed and/or denied. S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 2 of 11 {00316591;v2} I. STANDARD OF REVIEW A. STANDING “Standing is the gateway through which one must pass en route to an inquiry on the merits [of an appeal]." Central Street, LLC v. Zoning Bd. of Appeals of Hudson, 69 Mass. App. Ct. 487, 493 (2007). Chapter 40A, §§ 8 and 15, allow “any person aggrieved by reason of …. [a] decision of the inspector of buildings" to appeal the matter to the municipality’s “permit granting authority” (here, the Board). The test for a private individual’s standing under §§ 8 and 15 to file such an appeal is identical to that under c. 40A, § 17, which governs when private individuals may seek judicial review of a local zoning board’s decision. See 81 Spooner Rd., LLC v. Zoning Bd. of Appeals of Brookline, 461 Mass. 692, 700 n. 12 (2012). Such individuals must be “person[s] aggrieved” by the disputed decision. G.L. c. 40A, § 17. Aggrievement requires “evidence of an injury particular to the plaintiff, as opposed to the neighborhood in general.” Murchison v. Zoning Bd. of Appeals of Sherborn, 485 Mass. 209, 214 (2020) (discussing standing under § 17). To afford a plaintiff standing under §§ 8 and 15, the injured interest must be one the statute or bylaw “under which [the] plaintiff claims aggrievement intends to protect.” Standerwick v. Zoning Bd. of Appeals of Andover, 447 Mass. 20, 27-28 (2006) (discussing standing under G. L. c. 40B, § 21). A §§ 8 and 15 plaintiff also must provide “credible” evidence of harm to the claimed protected interest. Butler v. City of Waltham, 63 Mass. App. Ct. 435, 441 (2005) (discussing standing under c. 40A, § 17). In addition to the foregoing well-established requirements, the legislature recently amended Section 17 to eliminate a presumption of standing for abutters and certain abutters to abutters, and to require all plaintiffs to "sufficiently allege and ... plausibly demonstrate that measurable injury, which is special and different to such plaintiff, to a private legal interest that will likely flow from the decision through credible evidence." Section 11 of Ch. 150 of the Acts of 2024; JD. Raymond Transport, Inc. v. Farm Avenue Two Lots, LLC, 22 MISC 00681, 2024 WL 4346532, *7 (Land Ct. Sept. 30, 2024). B. MERITS Under Massachusetts General Laws Chapter 40A, §§ 7 and 8, the interpretation and enforcement of the Zoning Ordinance is committed in the first instance to the Building Commissioner. Therefore, in considering the Appellant’s petition, it is entirely appropriate for this Board to recognize: (1) Commissioner Florence's familiarity with both the Zoning Ordinance and the Massachusetts Building Code; (2) his experience applying it consistently; (3) his technical understanding of construction and dimensional standards; and (4) his coordination with planning staff code officials – including through Formal Site Plan Review – particularly where the Ordinance provisions involve technical planning, design, building code and dimensional standards within a specialized zoning district. S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 3 of 11 {00316591;v2} The burden rests with the Appellant to demonstrate that the Building Commissioner erred in issuing the permit. The Appellant has failed to meet that burden. II. THE PROJECT AND EXISTING SITE CONDITIONS The Project consists of the redevelopment of an already -developed infill parcel that was operated most recently as a retail and commercial banking headquarters for TD Bank, located within the Downtown Main Street (“DMS”) Zoning District at 307 Main Street in the Village of Hyannis. The site has historically contained a single multi-story commercial building and paved surface parking infrastructure. The Project redevelops and modernizes the site consistent with the design objectives of the DMS District, including: • the creation of multi-family mixed-income housing; • pedestrian-oriented streetscape improvements; • both surface parking and structured parking; • articulated building massing; and • and activated frontage conditions. Significantly, the Project demolishes the existing building and modifies the existing surface parking lot by decreasing the number of surface parking spaces from 74 surface parking spaces under existing conditions (see Exhibit A attached hereto) to 54 surface parking spaces shown on Exhibit B. The Project does so by incorporating integrated podium construction and 68 structured parking spaces on portions of the site below where the existing building is currently located and below the new residential structure. See Exhibit B. As discussed further below, these existing site conditions and the structured nature of the parking configuration to be located below the new residential building are central to the applicability analysis under Section 240-24.1.5.E.1. S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 4 of 11 {00316591;v2} III. ARGUMENT A. APPELLANT HAS FAILED TO SUFFICIENTLY ALLEGE OR PLAUSIBLY DEMONSTRATE THAT IT WILL SUFFER ANY MEASURABLE UNIQUE HARMS FROM THE PROJECT AND LACKS STANDING TO BRING ITS APPEAL It is well-settled that an appellant must have standing as a "person aggrieved" in order for a zoning board of appeals to review a building inspectors' decision. Massachusetts courts have long held that a person is "aggrieved" if he suffers infringement of his private legal rights or private property interests. See Standerwick v. Zoning Bd. of Appeals of Andover, 447 Mass. 20, 33 (2006). The allegedly injured rights must be of the type that are within the purview of the zoning laws' protections. Standerwick, 447 Mass. at 28-32. In addition, to qualify as an "aggrieved" party, a plaintiff must show "by direct facts and not by speculative personal opinion - that his injury is special and different from the concerns of the rest of the community." Id. at 33. Here, the appeal fails to allege aggrievement at all, much less does the Appellant sufficiently or plausibly support any inchoate claim of aggrievement with credible evidence, nor does it allege - much less demonstrate - any measurable injury to Appellant's interests from the Building Commissioner’s issuance of the building permit for the Project. On page 2 of the appeal, Appellant provides its alleged aggrievement as follows: (1) MST is aggrieved by the issuance of the building permit in that it owns and operates an apartment building on the 319-331 Main Street which has access to its own parking through a 25 foot way shared with 307 MSF; (2) New parking in the proposal requires vehicles to back into this 25 foot way to exit; and (3) Further, the proposal has 158 bedrooms/sleeping quarters, but only 120 parking spaces of which 23 spaces are handicap or electric vehicle spaces and, as such, are unavailable to all tenants of the proposed building. As such, MST expects that individuals will use parking spaces on the 319-331 Main Street property impacting the availability of parking for MST's tenants. The Appellant's first claim of harm is that it is aggrieved simply because it owns and operates an apartment building which abuts the property which has access to its own parking lot. The Appellant no longer enjoys the presumption of aggrievement by merely being an abutter and must allege facts that establish that the Project will result in a definite violation of a private right, property interest, or legal interest that is different from the concerns of the general community. Marashlian v. Zoning Bd. of Appeals of Newburyport, 421 Mass. 719, 721-722 (1996); Nickerson v. Zoning Bd. of Appeals of Raynham, 53 Mass. App. Ct. 680 (2002). The burden of proving standing is on the S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 5 of 11 {00316591;v2} Appellant who must demonstrate that they qualify as aggrieved persons and the Applicant need not present their own evidence and may instead rely on Appellant's lack of evidence to rebut a claimed basis for standing. See Standerwick, 447 Mass. at 33 & 35. Thus, being an abutter to the property no longer provides the Appellant a presumption of standing. The Appellant's second and third claims of harm simply provide that because the Project provides for new parking which will require vehicles to back into [a] 25 foot way to exit and because the project has 122 parking spaces (where only 120 parking spaces are required for the project) it "expects" individuals from the new residential project will use the Appellant's parking area impacting the availability of parking for its tenants. As stated above, The Appellant must “establish – by direct facts and not by speculative personal opinion – that its injury is special and different from the concerns of the rest of the community.” Id. (quoting Standerwick, 447 Mass. 20, 33 (2006), emphasis added. In order to be a basis for standing, the Appellant must offer evidence that parking that fully complies with the number of requisite parking spaces prescribed under the Zoning Ordinance for the Project will materially, uniquely, and adversely impact the Appellant. See, e.g., Kenner v. Zoning Bd. of Appeals of Chatham, 459 Mass. 115, 125 (2011) (plaintiffs’ speculation that traffic changes to a neighborhood would make it impossible for two vehicles to pass on a two-way road did not constitute a basis for standing); Titanium Grp., LLC vs. Zoning Bd. of Appeals of Brockton, No. 348898 (HMG), 2009 WL 117989 at *8 (Mass. Land Ct., Jan, 16, 2009) (holding that “not all traffic-based objections to a special permit or variance will furnish a plaintiff with standing” and finding that the plaintiffs’ traffic-based claim of aggrievement is too speculative because they failed to provide evidence sufficient for a reasonable person to believe that their property will be obstructed by increased traffic). Here, the Appellant has fully failed to assert any plausible claim of a definite violation of any of the Appellant's interests or otherwise provide any evidence to support such a claim and, thus, cannot also maintain standing upon the basis of its second or third concerns. Speculation alone is not standing. The Appellant’s unique brand of speculation as to household composition . . . on top of speculation as to the number of vehicles owned by a household . . . on top of speculation as to the model and size of such vehicles . . . on top of speculation as to fit of those vehicles within the approved parking spaces provided . . . on top of speculation as to if and where tenants might seek alternative parking options, is even further removed from the reality of what is required under Massachusetts law to seek redress before this Board. A further justification for dismissal of this action is the legal insufficiency of Appellant's alleged status as “persons aggrieved” – as the Appellant appears to have been motivated to bring the instant action to prevent business competition. In the Appeal, the Appellant informs that it owns an apartment building abutting the Project. What the Appellant fails to acknowledge in the Appeal is the fact that the income-restricted and market rate rental S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 6 of 11 {00316591;v2} units to be constructed pursuant to the Building Permit that the Appellant is appealing pose direct and significant market competition to the Appellant. Under case law it is clear that a party is not aggrieved for purposes of an G.L. c. 40A, § 17 appeal merely by an increase in business competition. Circle Lounge & Grille v. Bd. of Appeal of Bos., 324 Mass. 427, 429–30 (1949); see also Green v. Bd. of Appeals of Provincetown, 404 Mass. 571, 572 n.4 (1989) (“A business competitor does not have standing as an aggrieved party.”). Simply because the Appellant is a competing residential developer in Hyannis does not grant him standing to bring its appeal. Therefore, without any evidence to support such claims, the Appellant simply alleges that it expects the vehicle parking on Winn's property will cause problems that will purportedly adversely affect it. Such allegations are not sufficient. Thus, Appellant's failure to sufficiently and plausibly allege standing is fatal to their ability to maintain this action. Moreover, even assuming arguendo that the Appellant adequately alleged cognizable harms – which it does not – such allegations are further refuted by the extensive formal site plan review and building permit application process that Winn went through in connection with the Project. Therefore, based on the above, dismissal of this matter is warranted. B. THE APPELLANT MISREADS THE APPLICABILITY OF SECTION 240-24.1.5.E.1 SURFACE POARKING LOT DESIGN STANDARDS The central defect in the Appeal is that the Appellant misreads the clear and express provisions of 24-24.1.5.E – entitled “Surface Parking Lot Design Standards” – automatically apply to the Project without first establishing that the threshold applicability requirements of Section 240-24.1.5.E.1 have been satisfied. They have not. Section 240-24.1.5.E.1 expressly states: This section is applicable to the construction of any new surface parking lot and the expansion or modification of an existing surface parking lot containing 21 or more parking spaces that increases the number of parking spaces by five or more. (Emphasis added). This threshold inquiry determines when the Surface Parking Lot Design Standards of Section 240-24.1.5.E. are triggered. The Project modifies an existing surface parking lot containing 21 or more parking spaces (see Exhibit A) but does not increase the number of parking spaces, rather it decreases the number of parking spaces by 20 parking spaces (see Exhibit B). Therefore, the Building Commissioner correctly determined that because the Project does not increase surface parking by five or more spaces, none of the design standards set forth in Section 240-24.1.5.E.1 cited by the Appellant are applicable to the Project – this includes the requirement that “[a] landscaped buffer at least 10 feet wide S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 7 of 11 {00316591;v2} must be provided between any building and any parking lot with 10 or more parking spaces . . .” A clear reading of Section 240-24.1.5.E.1 demonstrates the limitation of this section of the Zoning Ordinance to “Surface Parking” is significant, logical, and consistent with the Massachusetts Building Code as addressed below. A distinction between surface and structured parking cannot be glossed over as the Appellant attempts, or simply misreads, nor can the threshold inquiry as to increase in surface parking be ignored to apply the substantive design standards to structured spaces and/or surface parking spaces where the requisite increase does not exist. Such an interpretation would be inconsistent with the Zoning Ordinance – which Commissioner Florence correctly interpreted and applied. C. PARKING LOCATED WITHIN THE PROJECT PODIUM STRUCTURE DOES NOT CONSTITUTE “SURFACE PARKING” FOR PURPOSES OF SECTION 240-24.1.5.E.1 Commissioner Florence’s interpretation and application of the Zoning Ordinance is supported by his reasonable determination that the 68 parking spaces located beneath the Project’s podium structure do not constitute “surface parking” – to which the design standards of 240-24.1.E are strictly limited – and therefore are not counted at any property within the DMS District in assessing whether the number of surface parking spaces increases by five or more. Indeed, such an interpretation and distinction is directed by the 2021 International Building Code – which is incorporated in the 10th Edition of the Massachusetts State Building Code (780 CMR) that took effect on July 1, 2025 – and distinguishes structured podium parking from surface parking for distinct treatment under the Building Code. As explained in the correspondence to Commissioner Florence dated April 2, 2026, from Richard P. Crowley, former Chair of the Massachusetts Board of Building Regulations and Standards and former Chair of the Massachusetts Building Code Appeals Board, (a copy of which is attached hereto as Exhibit C) the Project utilizes “podium construction” specifically recognized under Section 510.2 of the 2021 International Building Code. Under this construction methodology: • the parking area functions as part of a structured podium system; • the residential building exists above a horizontal assembly structure; • and the parking is integrated within the building configuration rather than existing as a separate surface parking field adjacent to a building. S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 8 of 11 {00316591;v2} As Mr. Crowley explains: . . . from a zoning perspective, the intent of Section 240-24.1.5.E.3(d) is to provide visual and spatial separation between buildings and adjacent surface parking areas. That condition does not exist here where the parking is not a separate surface parking lot adjacent to the building, rather the building is integrated within and adjacent to a structured podium configuration which is considered a horizontal assembly structure and not a building . . . (Exhibit C, page 1) This distinction is both significant and logical because the purpose of Section 240- 24.1.5.E.3(d) is to provide visual and spatial buffering between buildings and conventional surface parking lots. That condition does not exist here. Accordingly, based on both the Massachusetts State Building Code and the Zoning Ordinance, Commissioner Florence reasonably concluded that parking integrated within the podium structure should not be treated as “surface parking” for purposes of calculating the applicability thresholds of Section 240-24.1.5.E.1. Because those structured podium parking spaces are not counted as surface parking spaces, the Project does not exceed the threshold necessary to trigger the landscaping provisions cited by the Appellant. Therefore: • the ten-foot landscape buffer provisions relied upon by the Appellant does not apply; • the claimed buffer deficiencies fail as a matter of law; and • the Building Permit was properly issued. D. COMMISSIONER FLORENCE PROPERLY DETERMINED THAT COMPACT PARKING SPACES ARE PERMITTED IN THE DMS DISTRICT The Appellant additionally asserts that certain parking spaces do not comply with dimensional requirements applicable elsewhere within the Zoning Ordinance. That claim ignores Commissioner Florence’s prior January 12, 2024, formal written zoning decision regarding this Project and the Downtown Main Street (“DMS”) District parking provisions (attached hereto as Exhibit D) – which was issued after consultation and with the agreement of the Town Attorney’s office – stating: I determined as the duly appointed zoning enforcement officer and Site Plan Review Chairman of the Town of Barnstable that the use of compact spaces in the Downtown Hyannis Zoning District is permitted and is consistent with the zoning ordinance. (Exhibit D, page 2) S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 9 of 11 {00316591;v2} In that determination, Commissioner Florence concluded that: • the parking standards contained within Section 240-24.1.5.C constitute controlling and more specific parking provisions applicable within the DMS District; • the DMS parking provisions do not impose dimensional parking space requirements; and • dimensional standards from more general parking provisions elsewhere in the ordinance may not be imported into the DMS District regulations. Commissioner Florence further concluded: Because the Downtown Hyannis Zoning District regulations beginning in §240-24- 1-1 of the Zoning Ordinance do not contain provisions regarding parking spaces dimensions, I as the chairman of Site Plan Review and the zoning enforcement officer, not a policy maker, am not permitted to add dimensional requirements to the Downtown Hyannis Zoning District provisions of the ordinance. (Exhibit D, page 2) This determination was read into the record of the Planning Board on February 12, 2024, as grounds on which the Planning Board accepted Winn’s withdrawal of a request for the Board’s approval of its parking plan – as the use of compact parking spaces are permitted within the DMS District were found to be fully compliant with the Zoning Ordinance. The Appellant has identified no basis upon which the Board should disturb Commissioner Florence’s January 12, 2024, zoning determination regarding the use of compact parking spaces in the DMS District. Indeed, Appellant Aaron B. Bornstein has availed himself of the allowance for the use of compact parking spaces in connection with the Dockside Condominium project under construction at 110 & 115 School Street in Hyannis. The Dockside project underwent formal Site Plan Review on March 21, 2024, following Commissioner Florence’s January 12, 2024 zoning determination regarding the use of compact parking spaces at 307 Main Street and Winn Development submitted through counsel a letter dated March 21, 2024 (attached hereto as Exhibit E, which included a copy of Commissioner Florence’s January 12, 2024 determination) in support of Mr. Bornstein’s use of compact parking spaces to satisfy the parking requirements for the Dockside project. Having availed himself of compact parking spaces in obtaining Site Plan Review approval and building permits for the Dockside condominiums now under construction, this Board should not entertain Mr. Bornstein’s contrary position now challenging the Build Commissioner’s very same determination regarding Winn Development's use of compact parking spaces at a property to which Bornstein is an abutter. S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 10 of 11 {00316591;v2} E. THE PROJECT COMPLIES WITH THE DMS BUILDING FORM REQUIREMENTS The Appellant further alleges that the Project violates the DMS “Building Width” limitation of 180 feet. That claim is based upon another incorrect interpretation of the DMS design standards by the Appellant. As explained by the Project architect, Icon Architecture, in correspondence to Commissioner Florence dated March 31, 2026, (attached hereto as Exhibit F), the “Building Width” standard contained within Table 3 of Section 240-24.1.6 is a building- form and massing regulation intended to prevent monotonous uninterrupted façade conditions. The Project fully complies with that requirement through substantial façade articulation, roof-plane variation, projections, recesses, and segmented massing elements. The zoning table itself places “Building Width” within the “Building Form” category, confirming that the provision regulates perceived building form and continuous façade massing rather than aggregate linear building length. As further explained in correspondence dated March 31, 2026, from Icon Architecture to Commissioner Florence: The intent [of Section 240-24.1.6] is that the building is not a monotonous form for the entire length of the facade; and the building is required to break up the massing in order to achieve that. (Exhibit F, page 1) Further, ICON’s March 31st correspondence includes Table 3 of Section 240-24.1.6 and points out that the illustration within Table 3 labels building form width with the letter “E” and shows that a change of roof plane constitutes a distinct building form segment for the purpose of measuring width. (Exhibit F, page 1-2) The Project’s architectural elevations show multiple distinct changes in building form and roof plane that interrupt and segment the building massing. See Exhibit G attached hereto. Therefore, properly applying the requirement of Table 3 of Section 240-24.1.6, the maximum continuous building form width is approximately 171'-3", which is compliant with the 180-foot standard. For the foregoing reasons, Commissioner Florence’s interpretation of the DMS Building Form provisions was correct, entirely consistent with Section 240-24.1.6, and his issuance of the Building Permit was reasonable and should not be overturned by this Board. S MOLAK & V AUGHAN LLP Town of Barnstable Zoning Board of Appeals June 16, 2026 Page 11 of 11 {00316591;v2} F. THE REMAINING CLAIMS OF THE APPELLANT LACK MERIT The remaining claims asserted by the Appellant are derivative of the erroneous assumption that the Project is subject to the surface parking design standards cited in the Appeal. These are identified as items B. and C. in Appellant's appeal and each cite 240-24.15C.3(b) [sic] and claim the absence landscape buffers adjacent to Old Colony Way and an “unnamed 25 foot way” between 307 Main Street and 319-331 Main Street. Because the applicability thresholds of Section 240-24.1.5.E.1 were not triggered, the design standards of 240-24.1.5.E do not apply and therefore those claims necessarily fail. Moreover, the Project underwent extensive design review and refinement to ensure consistency with the DMS District’s urban design objectives and dimensional standards. The Appellant has failed to establish any legal basis for reversal of the Building Commissioner’s determination. IV. CONCLUSION For the foregoing reasons, the Building Commissioner properly interpreted and applied the Town of Barnstable Zoning Ordinance in issuing the building permit for 307 Main Street. The Appeal should therefore be dismissed due to the Appellant's lack of standing and/or denied and the building permit affirmed. Respectfully submitted, WINN DEVELOPMENT COMPANY, LP By its attorney, Robert L. Brennan, Jr. SMOLAK & VAUGHAN LLP Enclosures cc: Paul Revere, III, Esq. (counsel for Appellant) EXHIBIT A SCALE: 1" = 40' 344700P020A-005 HARBORVIEW Existing Parking Exhibit 06/09/26 EXHIBIT A EXHIBIT B SCALE: 1" = 40' 344700P020A-004 HARBORVIEW Proposed Parking Exhibit 06/09/26 EXHIBIT B EXHIBIT C RICHARD P. CROWLEY Professional Building, Accessibility, Fire and Safety Code Consultant and Construction Subject Matter Expert 7431 Woolston Road, E. Bloomfield, NY. 14469 Cell: 617-947-8339 - Richardpcrowley@aol.com {00313425;v1} April 2, 2026 VIA EMAIL Brian.Florence@barnstable.gov AND FIRST-CLASS MAIL Brian Florence Barnstable Building Commissioner Town of Barnstable200 Main Street Hyannis, MA 02601 Re: 307 Main St, Barnstable, MA. 02630 Dear Commissioner Florence: I am writing on behalf of Winn Development Company, LP (“Winn”) in connection with the site plan, buildings and parking lot documentation that has been submitted in connection with Winn’s building permit application for 307 Main Street, Hyannis. Specifically, I have been asked to opine as to the applicability of Section 240-24.1.5 Subsection E.3(d) of Article 3 of the Barnstable Zoning Code which states in relevant part:. [a] landscape buffer at least 10 feet wide must be provided between any building and any parking lot with 10 or more parking spaces excluding building entrances. (See Note 1) Based on the plain text of the Barnstable Zoning Code, the 10th Edition of the Massachusetts State Building Code, 2021 International Building Code, and my experience documented in my curriculum vitae, attached hereto as Exhibit A, my informed opinion is that the Section 240-24.1.5 Subsection. E.3(d) does not apply to the proposed orientation between building and parking lot at 307 Main Street for the reasons more fully described below. Specifically, from a zoning perspective, the intent of Section 240-24.1.5.E.3(d) is to provide visual and spatial separation between buildings and adjacent surface parking areas. That condition does not exist here where the parking is not a separate surface parking lot adjacent to the building, rather the building is integrated within and adjacent to a structured podium configuration which is considered a horizontal assembly structure and not a building for the reasons described below. (See Elevations Plan and Site Plan respectively attached hereto as Exhibit B). Requiring a 10-foot landscaped buffer in this condition would not advance the purpose of the ordinance and would result in an impractical and unintended application of the design standard. Moreover, to support this interpretation, and from a State Building Code perspective, the proposed construction of the improvements for 307 Main Street is that of “Podium Construction” specifically addressed in 2021 IBC Section 510.2 – Horizontal Building Separation Allowance. This provision expressly directs that horizontal assembly structures and buildings “shall be considered as separate and distinct . . . for the purpose of EXHIBIT C RICHARD P. CROWLEY Professional Building, Accessibility, Fire and Safety Code Consultant and Construction Subject Matter Expert 7431 Woolston Road, E. Bloomfield, NY. 14469 Cell: 617-947-8339 - Richardpcrowley@aol.com {00313425;v1} determining area limitations, continuity of firewalls, installation of number of stories and type of construction” under seven conditions – all of which are met here. [See Notes 2-4]. Consistent with Section 510.2, and in the absence of any express definitions or interpretative directions within the Barnstable Zoning Code to the contrary, the Podium Construction at 307 Main Street should be treated as a distinct horizontal assembly structure (the columns and parking lot) and building (the residential area located above the columns) that exist on separate horizontal planes “for purposes of determining area limitations” including the planted landscape buffer provisions of Section 240-24.1.5 Subsection E.3(d). While the zoning provision might apply to buildings with parking lots where the building and surface parking lots are horizontal, or at the same elevation, that is not the case presented by the podium construction proposed for this section of the property at 307 Main Street and for these reasons, the buffer requirement set forth in Section 240-24.1.5 Subsection E3(d) of Article 3 of the Barnstable Zoning Code is not applicable to the 307 Main Street project. In this case you have a building (on the second floor) without a parking lot, and a parking lot without a building because it’s a horizontal assembly structure. You have two separate structures. (See Note: 5) Other projects of podium construction include a residential section and a commercial horizontal assembly below, consisting of a series of columns. Some projects involve a combination of residential commercial and parking. What matters is the podium. If the horizontal assembly structure meets all 7 criteria you are a podium and you have a separate building and a separate structure. The columns that pass through the parking lot are there to carry the loads required by section 1604.4 of the building code (See Note: 6). As such, those columns are there to service the podium and are exempt according to the Barnstable Zoning Code. The columns are very similar to the utilities that have to pass through the space below the podium and into the ground. They transfer the loads from the podium into the ground to service the podium. As such, the structural columns supporting the podium do not create the type of horizontal adjacency between a building and a parking lot that the zoning code is intended to regulate. Additionally, and in further support, Section 510.3 of the building code describes "open parking garage shall be classified as separate and distinct building for the purposes of determining the type of construction where the following conditions are met." This sentence states that the "open parking garage" is a building for a limited purpose to meet the seven criteria outline above and in Section 510.2. of the building code. In that sentence the words "open parking garage" are in italics which means that it is defined. 2021 IBC Chapter 2 Definitions defines "open parking garage" as; Open parking garage. A structure or portion of a structure with the openings as described in Section 406.5.2 on two or more sides that is RICHARD P. CROWLEY Professional Building, Accessibility, Fire and Safety Code Consultant and Construction Subject Matter Expert 7431 Woolston Road, E. Bloomfield, NY. 14469 Cell: 617-947-8339 - Richardpcrowley@aol.com {00313425;v1} Note: 3. 2021 IBC Section, Definitions - Structure; "That which is built or constructed." Note: 4: 510.2 Horizontal building separation allowance. A building shall be considered as separate and distinct buildings for the purpose of determining area limitations, continuity of fire walls, limitation of number of stories and type of construction where the following conditions are met: 1. The buildings are separated with a horizontal assembly having a fire-resistance rating of not less than 3 hours. Where vertical offsets are provided as pa11 of a horizontal assembly, the vertical offset and the struc-ture supporting the vertical offset shall have a fire resistance rating of not less than 3 hours. 2. The building below, including the horizontal assem-bly, is of Type IA construction. 3. Shaft, stairway, ramp and escalator enclosures through the horizontal assembly shall have not less than a 2-hour fire-resistance rating with opening protectives in accordance with Section 716. Exception: Where the enclosure walls below the horizontal assembly have not less than a 3-hour fire-resistance rating with opening protectives in accordance with Section 716, the enclosure walls extending above the horizontal assembly shall be permitted to have a 1-hour fire-resistance rating, provided that the following conditions are met: 1. The building above the horizontal assembly is not required to be of Type 1 construction. 2. The enclosure connects fewer than four stories. 3. The enclosure opening protectives above the horizontal assembly have a fire protection rating of not less than 1 hour. 4. Interior exit stairways located within the Type 1A building are permitted to be of combustible materials where the following requirements are met: 4.1. The building above the Type IA building is of Type Ill, IV, or V construction. 4.2. The stairway located in the Type IA building is enclosed by 3-hour fire- resistance-rated construction with opening protec-tives in accordance with Section 716. 5. The building or buildings above the horizontal assembly shall be permitted to have multiple Group A occupancy uses, each with an occupant load of less 300, or Group B, M, R or S occupancies. 6. The building below the horizontal assembly shall be protected throughout by an approved automatic sprinkler system in accordance with Section 903.3.1.1, and shall be permitted to be any occu-pancy allowed by this code except Group H. RICHARD P. CROWLEY Professional Building, Accessibility, Fire and Safety Code Consultant and Construction Subject Matter Expert 7431 Woolston Road, E. Bloomfield, NY. 14469 Cell: 617-947-8339 - Richardpcrowley@aol.com {00313425;v1} 7. The maximum building height in feet (mm) shall not exceed the limits set forth in Section 504.3 for the building having the smaller allowable height as measured from the grade plane. Note: 5 - In the building code a building is a structure, but not all structures are buildings, i.e., a parking lot is a structure. Note: 6 - 2021 IBC Section 1604.4 Analysis - 3rd paragraph any system or method of construction to be used shall be based on rational analysis in accordance with well- established principles of mechanics. Such analysis shall result in a system that provides a complete load path capable of transferring loads from there point of origin to the load resisting elements” which is the earth. EXHIBIT A RICHARD P. CROWLEY Professional Building, Accessibility, Fire and Safety Code Consultant and Construction Subject Matter Expert 7431 Woolston Road, E. Bloomfield, NY. 14469 Cell: 617-947-8339 - Richardpcrowley@aol.com #15580856v1 EDUCATION: Northeastern University, Boston, Ma. Bachelor of Science, Business Administration/Accounting Penn State University, University Park, PA, 2011->15, College of Education – Workforce Education and Development Program REGISTRATION: Comm. of Mass. Constr. Supervisors License #CS-028732 City of Boston ABC License # B30402 City of Cambridge Class 4 License # 6 Massachusetts MCPPO Certification EPA / Mass Certified RRP Renovator – Instructor Best Practices Certified - Instructor USGBC / LEED Green Building Awareness certification AFFILIATIONS: Mass BBRS - Former Member- Massachusetts State Board of Building Regulations and Standards Ad-Hoc Faculty – Wentworth Institute of Technology, Boston, Ma. Town of Littleton – Former Member-Permanent Municipal Building Committee - Past Chairman, Town of Littleton – Former member-School Building Committee – Past Chairman Town of Littleton – Former Member-Planning Board - Past Chairman (Elected Official) Town of Littleton – Former Member-Medical Reserve Corps Carpenters Union Local 40 Carpenters Training Center - Instructor EXPERIENCE Code Consultant  Building, Accessibility, Mechanical, Fire Code, & Safety Consultant 2010- present  Expert Witness, Diagnostic Investigation, Forensic Estimating BBRS- Past Chair, Massachusetts State Board of Building Regulations and Standards Former Board Member  Appointed by the past two Governors of Massachusetts to the BBRS 2010 – 2022 Chair of the body that regulates the Construction Industry. The BBRS manages the State Building Code and Energy Conservation Code. I Also serve as one of the States’ voting representatives to the International Code Counsel (ICC). This is the authority that writes the Building Code for all 50 states and over 50 countries across the globe. Additionally, I served as Chairman of the State Building Code Appeals Board (BCAB) Town of Andover, Ma. Project Manager  BANCROFT ELEMENTARY SCHOOL, Andover, Ma. 2015 50M  Overseeing this K->5 elementary. Report directly to the Town Manager. Worked closely with the Acting Facilities Director, School Building Committee, Architect, OPM, CM, MSBA and Town Counsel. I was instrumental in drafting the RFQ’s, the SOQ template, RFP’s, the CM & OPM Contracts, Subcontracts and their SOQ templates. My duties also included matters concerning litigation, investigation, Freedom of Information requests, protests, Mass & local Historical Commissions, Cons Com, DEP, & NPDES permits, Etc. Additionally, I served on one of the Pre-Qualification sub-committees. Agostini Construction Co, Inc. & Bacon Construction Co, Inc. Executive Project Manager  SLADE ELEMENTARY SCHOOL, Fall River, Ma. 2008 26M  COLLICOT & CUNNINGHAM ELEMENTARY SCHOOLS, Milton, Ma. 2006 29M  LINCOLN MIDDLE SCHOOL, Lincoln, RI 2005 23M.  All public sector schools, Ch. 149 hard bid with filed subcontractors. All projects on time & on budget. RICHARD P. CROWLEY Professional Building, Accessibility, Fire and Safety Code Consultant and Construction Subject Matter Expert 7431 Woolston Road, E. Bloomfield, NY. 14469 Cell: 617-947-8339 - Richardpcrowley@aol.com #15580856v1 R, W, Granger & Sons, Inc. Senior Project Manager  OLD ROCHESTER REGIONAL JR. & SR. HIGH SCHOOLS, Mattapoisett, Ma. 2003 41M  ROOSEVELT MIDDLE SCHOOL, New Bedford, Ma. 2000 27M  All public sector schools, Ch. 149 hard bid environment, filed subcontractors, all projects on time, on budget, with no litigation. During this time period the Construction environment was strife with contractor subcontractor hostilities. I entered this arena with the private sector mentality of team building, working together and it worked. In 2003 there were 21 schools under construction, trying to open. Only three finished on time, only one finished under budget – Roosevelt. I also participated in arbitration, and helped the bonding company with the closure of R.W.Granger when Granger ceased operations in 2005. Paul Maggorie Builders Corp. Senior Project Manager  PARKER CHOMERICS - HI-TECH MFG FACILITIES, Woburn, Ma. & Hudson, NH. 1999 3.5M  BIDS AND BUDGETS FOR OFFICES & WAREHOUSE FACILITIES, Woburn, Ma. 1999 9.5M  Work involved office space, clean rooms, and modern manufacturing build-outs J. Calnan & Associates, Inc. Senior Project Manager  MULBERRY CHILD CARE - GROUND UP, DAY CARE FACILITY, Westwood, Ma. 1998 1.1M  8 UNIT RES. APT. BLDG. RENOV. - MODERN CONTINENTAL,. Cambridge, Ma. 1998 1.3M  LIBERTY MUTUAL INS. CO. - TWO FLOORS HI-RISE, FIT-UP, Danvers, Ma. 1998 .4M  SCHAFER CORP. - HI-TECH R&D, TENANT FIT-UP, Chelmsford, Ma. 1998 .4M  PRI AUTOMATION.- HI-TECH MFG FACILITY w/ CLASS #1 CLEAN ROOM, Lowell, 1997 2.3M  Misc. day care centers, office space, biotech labs, clean rooms, and modern manufacturing build-outs. Suffolk Construction Co. Inc. – Special Projects Division Senior Project Manager  BACK BAY HILTON - 26 STORY ADDITION, Boston, Ma. 1998 3.9M  Everything with Suffolk involved fast tracking of projects, working with challenging owners, and managing difficult subs, suppliers, budgets, and schedules. This project was especially challenging because it was located within a busy part of Boston with essentially no site to operate from. Richard White & Sons, Inc. Project Manager  All private sector negotiated work for schools like: BRIMMER AND MAY SCHOOL, Chestnut Hill, Ma.  WELLESLEY COLLEGE, Wellesley, Ma, BAYBANK, INC. Cambridge, Ma., HARVARD UNIVERSITY, Cambridge, Ma., BOSTON COLLEGE, Chestnut Hill, Ma. and tenant FIT -UPS in hi-rise buildings in Boston & eastern Ma. These were all high demand, high quality, and high-performance owners. REFERENCES UPON REQUEST EXHIBIT B LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" 2 A-301 LEVEL 245'-0" 257 GARAGE34'-0 1/4" 3468 EBBE EBBE EBBE07 0717 1711'-6"10'-8"10'-8"6 1/4"17 17 06 17 06 07 07 33'-6"07 08 17 17 17 1717 ASPHALT SHINGLE ROOFING FIBER CEMENT SHINGLE SIDING FIBER CEMENT LAP SIDING PVC TRIM UPVC WINDOW WITH TRIM DOWNSPOUT AND BOOT 5.85.9 0707 O/D SPOUT A-204 4 SIM FND - AMENITY26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" E FGHJKMNO GARAGE34'-0 1/4" 5 A-301 3 A-405 L FOUNDATION29'-6" 08 07 06 04 07EBBEBEBEBBEB B EBB EBB B B E E B BE E B B B B E E B B E E E E B B B B E E 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 04 03 1717 03 17171717 03 1717 03 1717 03 17 17 03 17 17 03 17 17 03 17 17 B E 07 11'-6"10'-8"10'-8"6 1/4"3'-0"1'-0"3'-0"E E S2-R 17 17 17 ASPHALT SHINGLE ROOFING FIBER CEMENT SHINGLE SIDING JULIET RAILINGS, TYP PVC TRIM FIBER CEMENT LAP SIDING 33'-6" 17 17 17 17 17 UPVC WINDOW WITH TRIM 17 EX3 EX3EX3EX3 1 A-303 3 A-3035 A-303 5 A-302 DOWNSPOUT AND BOOT DOWNSPOUT DOWNSPOUT DOWNSPOUT BOOT FIBER CEMENT LAP SIDING DOWNSPOUT F.1 A-720 2 L2 E E O/D SPOUTO/D SPOUT 5 A-711 FND - AMENITY 26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" 4 A-301 LEVEL 245'-0" 7911 14 15 16 2 A-402 GARAGE34'-0 1/4" 8 FOUNDATION 29'-6" BEEB E B E B E B BEEBB E B E B E B BEEBB E B E B E B B 08 07 07 14 14 14 14 14 14 14 14 14 04 11'-6"10'-8"10'-8"6 1/4"3'-0"1'-0"3'-0"07 34'-0"34'-0"34'-0"T-101 100A ASPHALT SHINGLE ROOFING FIBER CEMENT SHINGLE SIDING PVC TRIM FIBER CEMENT LAP SIDING JULIET RAILINGS, TYP UPVC WINDOW WITH TRIM ASPHALT SHINGLE ROOFING 17 17 B EX1 EX1BLBL BOLLARD WITH LIGHT EX3 CR 4 A-302 DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT 16.5 16.8 17 14 14 CORNERGUARDS GARAGE OPENING 22'-4 3/4" 08 8'-2"COW'S TOUNGUE OVERFLOW DRAIN L1 2'-0 3/4"15'-0"15'-0"15'-0"17'-0"13'-2 1/2" KNOX 08 07 ADO 7 A-301 WALL HYDRANT 1 3 5 4 7 862 LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" 2 A-403 LEVEL 245'-0" B E FG H J K M N 1 A-301 O GARAGE 34'-0 1/4" 5 A-301 3 A-405 1 A-403 AC D L FOUNDATION29'-6" 1404 04 01 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 07 ? 04 04 04 08 08 B B.1 E E.1 B B.1 E E.1 B B.1 E E E B B B B B E E E E B B B B B E E E E E E B B B E E E B B B B B B B B B E E E 35'-0"11'-6"10'-8"10'-8"6 1/4"4'-0"BBBBEE B 08 17 04 0404 10 S2-1 ASPHALT SHINGLE ROOFING THIN BRICK 17 UPVC WINDOW WITH TRIM 10 10 10 10 10 10 V-R01 17 17 04 17171717171717171717 1010 EX3EX3EX3EX3EX3 2 A-303 1 A-303 3 A-303 5 A-303 JULIET RAILINGS, TYP 5 A-302 KNOX3'-6"DS BOOT DS GUTTER DSGUTTER DS DSDS DOWNSPOUT AND BOOTDOWNSPOUT AND BOOT DS F.1 C.1C.2 11'-1"11'-1"CLR7'-4"22'-0" DOWNSPOUT AND BOOTCOW'S TOUNGUE OVERFLOW DRAIN COW'S TOUNGUE OVERFLOW DRAINCORNER GUARD B.7 E E E 08 17171717 08 04 17041'-0"WALL HYDRANT 35'-0"35'-6" A-204 3 FND - AMENITY26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" 2 GARAGE34'-0 1/4" 13 FOUNDATION29'-6" 0411'-6"10'-8"10'-8"6 1/4"3'-0"1'-0"3'-0"04 17 10 01 B B BA A A 33'-6" ASPHALT SHINGLE ROOFING THIN BRICK FIBER CEMENT LAP SIDING PVC TRIM FAUX CAST STONE UPVC WINDOW WITH TRIM FIBER CEMENT PANEL 4 A-303 DOWNSPOUT AND BOOT DOWNSPOUT 08 08 FND - AMENITY26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" E GARAGE34'-0 1/4" EA EA EA FOUNDATION29'-6" B B B 04 08 S1-1C 04 17 17 08 07 07 MT-101A PVC TRIM FIBER CEMENT LAP SIDING ASPHALT SHINGLE ROOFING THIN BRICK FIBER CEMENT SHINGLE SIDING UPVC WINDOW WITH TRIM EX2 EX2 C-101 33'-6" FND - AMENITY26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" GARAGE34'-0 1/4" 8 FOUNDATION29'-6" 07 08 3'-0"1'-0"3'-0"6 1/4"10'-8"10'-8"11'-6"33'-6"04 17 17 17 17 LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" 2 GARAGE 34'-0 1/4" FOUNDATION29'-6" 07 14 14 14 17 17 08 04 1'-0"3'-0 1/4"6"10'-11 3/4"10'-8"10'-8"11'-6"FIBER CEMENT PANEL (WHITE) FAUX CAST STONE - OPENING HEADERS & SILLS FIBER CEMENT 7" SHINGLE SIDING (TAN) PVC SHUTTER EXTERIOR MATERIAL LEGEND ASPHALT SHINGLE ROOF 7" SHINGLE SIDING (DK GREY) FIBER CEMENT 7" LAP SIDING (BLUE) FIBER CEMENT PANEL (GREY) NOT IN USE THIN BRICK (TAN) FIBER CEMENT 7" LAP SIDING (WHITE) 1 2 3 4 12 8 7 5 10 6 COVERBOARD AT GRADE11FIBER CEMENT 7" LAP SIDING (TAN) GLASS13 ALUM. RAILING SYSTEM14 DECORATIVE PVC TRIM16 PVC TRIM/CORNICE (WHITE)17 ALUMINUM CHANNEL LETTERING SIGNAGE15 METAL COPING TRIM18 SIMULATED STANDING SEAM (DK GREY)9 ELEVATION LEGEND GAS METER THROUGH WALL ROOF SCUPPER KNOX BOX 1' X 1' LOUVER DOUBLE EXHAUST VENT, PTD SINGLE EXHAUST VENT, PTD CONCENTRIC EXHAUST VENT, PTD EXTERIOR LIGHT FIRE ALARM STROBE SPEAKER SECURITY CAMERA VIDEO INTERCOM ARCHITECT CONSULTANT STAMP KEY PLAN PROJECT NUMBER: DRAWN BY: CHECKED BY: SHEET TITLE 1/30/2025 4:54:33 PMA-202 BUILDING ELEVATIONS HARBOR VUE 223024 307 MAIN STREET WINN DEVELOPMENT CM GF 3/32" = 1'-0"4SOUTH ELEVATION 01 3/32" = 1'-0"5 EAST ELEVATION 02 3/32" = 1'-0"7SOUTH ELEVATION 02 3/32" = 1'-0"3 WEST ELEVATION 3/32" = 1'-0"1WEST ELEVATION 2-INSET 3/32" = 1'-0"8 SOUTH EAST ELEVATION 1-INSET 3/32" = 1'-0"6 EAST ELEVATION 7-INSET 3/32" = 1'-0"2WEST ELEVATION 1 -INSET NO.DATE DESCRIPTION 2 2024-03-14 DESIGN DEVELOPMENT 3 2024-05-02 70% CDs 4 2024-07-25 90% CDs 5 2025-01-30 CONFORMED SET PREPARED BY:BEALS AND THOMAS, INC.144 Turnpike Road, Suite 210Southborough, Massachusetts 01772-2104T 508.366.0560 | www.bealsandthomas.comARCHITECTCONSULTANTSTAMPKEY PLANPROJECT NUMBER:DRAWN BY:CHECKED BY:SHEET TITLE223024NO.DATEDESCRIPTION12024-01-18SCHEMATIC DESIGN22024-03-14DESIGN DEVELOPMENT32024-07-2590% CD42025-01-30100% CDHARBOR VUE307 MAIN STREETWINN DEVELOPMENTSCALE: 1" = 20'C-3.1LAYOUT ANDMATERIALS PLAN344700P016F-002 EXHIBIT D Office (508) 862-4038 Fax (508) 790-6230 1 www.town.barnstable.ma.us Town of Barnstable Inspectional Services Department Brian Florence, Director/Building Commissioner January 12, 2024 Town of Barnstable Planning Board Chairman Robichaud 367 Main Street Hyannis, MA 02601 Re: Zoning Determination for 307 Main Street Mr. Chairman, As you know I have been asked by the Planning Board through you to provide a zoning determination concerning compact parking spaces proposed for 307 Main Street, Hyannis, a project for which the Board has received a Special Permit application. The proposal for the subject property was heard at Site Plan Review (SPR) on: 8/15/2023 and 10/24/2023 informally. A formal review of the application was conducted on: 11/16/2023. Having heard objections to the dimensions of parking spaces by a member of the public at the formal review (without citations), I decided to take the matter under advisement to allow time for me to review the parking provisions of the Zoning Ordinance further, before determining whether or not the application was approvable under Article IX, the Site Plan Review provisions of the Zoning Ordinance. Shortly thereafter the petitioner’s attorney requested that I as the Building Commissioner and Chairman of SPR, find the proposed project to be approvable in accordance with specific parking provisions of 240-24.1.5(C) again, without citations. Notably, these provisions do not contain dimensional requirements, thus the applicant’s attorney argued that his client should be allowed to use compact-sized parking spaces for the project. I requested that he provide me with a legal opinion to that effect which he did, this time including citations. I have included a copy of that opinion here for your review. In order to complete my review for consistency with zoning under Article IX, I requested an opinion from the Town Attorney’s office as to whether or not I had authority under the ordinance to find compact parking spaces approvable in light of the neighbor’s objections, the opinion of the applicant’s attorney and the ordinance. After consultation with the Town Attorney’s Office, as well as my review of the Zoning Ordinance, I determined that the proposal was consistent with Zoning and therefore the matter was deemed by me to be approvable for Site Plan Review purposes. My affirming determination was made for the following reasons: 1. Section 240-24.1.5. provides Standards for All [Downtown Hyannis Zoning] Districts, and subsection C of that section contains Parking Standards that are specific to each use which are to be applied in the Downtown Hyannis Zoning District. 2. The parking table in Section 240-24.1.5. C. is the parking regulation specific to the Downtown Hyannis Zoning District. Because that section is the more specific regulation to the district the general requirements found in Article IV Off-Street Parking (cited below) are therefore in conflict with this section which means that the provisions of 240-24.1.5. C. prevails. EXHIBIT D www.town.barnstable.ma.us a. Reference: §240-24.3 - General Provisions: Where the provisions of §§ 240-24.1.1 through 240- 24.1.13 conflict with those found elsewhere in the Barnstable Zoning Ordinance, the provisions of this section shall apply. b. Further, the more general parking standards in Section 240-55 & 56 respectively provides: i. Section 240-55 Conflicting Provisions Any specific provision in any other section of this chapter relating to parking shall prevail over the provisions of this section. ii. Section 240-56 - Schedule of Off-Street Parking Requirements – provides for the minimum parking requirements for the uses stated therein. 3. Because the Downtown Hyannis Zoning District regulations beginning in §240-24-1-1 of the Zoning Ordinance do not contain provisions regarding parking spaces dimensions, I as the chairman of Site Plan Review and the zoning enforcement officer, not a policy maker, am not permitted to add dimensional requirements to the Downtown Hyannis Zoning District provisions of the ordinance. (see also below) The applicant’s' attorney made the argument in favor of compact spaces in his opinion and the Town Attorney’s Office agreed with his statement that, “if that if a statute or ordinance is silent on something one cannot interpret language into the ordinance”. Citing Iodice v. Newton: where, if a statute or bylaw or ordinance was intended to contain certain language it would be in there and if it is not, it cannot be interpreted that the drafters meant to include such language. a. However, the Ordinance here does in fact contain language about which set of parking regulations to use for each district, so that is not open to interpretation. What is not contained in the relevant sections of the Ordinance is parking dimensions, so it cannot be read as intending to include parking dimensions. 4. The Building Commissioner acting as the Chairman for SPR has discretionary authority to issue Site Plan Approval authorizing the approval of a plan containing compact parking spaces within the Downtown Hyannis Zoning District. If the Chair were to use his discretionary authority to deny such parking spaces, the denial, in order to be sustainable would need a valid basis that cannot not be due to dimension (other than an improper size, e.g. smaller than standard compact spaces). 5. The applicant's attorney further argues that where there is inconsistency, the Building Commissioner must use his discretionary authority to apply the more specific provisions. a. I agree that the more specific provisions should be applied, but I do not even think there remains any inconsistency given the language in the Ordinance that resolves inconsistencies. As stated above, the Ordinance provides in 2 places (240-55 and 240-24.1.3. A.1.) that the more specific provisions apply where there is any inconsistency. Therefore, I determined as the duly appointed zoning enforcement officer and Site Plan Review Chairman of the Town of Barnstable that the use of compact spaces in the Downtown Hyannis Zoning District is permitted and is consistent with the zoning ordinance. Regards, Brian Florence Building Commissioner/Chairman EXHIBIT E Robert L. Brennan, Jr ., Esq. O : 978.965.5885 | C : 617.233.4897 rbrennan @smolakvaughan.com {00286289;v1}Main Office: 21 High Street, Suite 310 • North Andover, MA 01845 Cape Cod Office: 255 Main Street, Suite A • Hyannis, MA 02601 WWW.SMOLAKVAUGHAN.COM March 21, 2024 VIA E-MAIL Brian Florence Building Commissioner Town of Barnstable 200 Main Street Hyannis, MA 02601 Re: Support and Submission of Prior Zoning Determination - 110 & 115 School Street, Hyannis, SPR-23-92 (the “Project”) Dear Mr. Florence: I am writing on behalf of my client, WinnDevelopment, to express support for the use of “compact” parking spaces (spaces measuring less than 9 feet by 20 feet) in meeting the applicable parking requirements for the proposed Project. In support thereof, I have attached the Zoning Determination issued by your office dated January 12, 2024 regarding a similar issue in connection with 307 Main Street. The January 12th Zoning Determination provides both direct and precedential support for the use of compact parking spaces in Hyannis, and Winn requests that approval of “compact” parking spaces be affirmatively noted in the applicant’s Site Plan Approval letter for the Project Thank you for your attention to this matter. Sincerely, /s/ Robert L. Brennan, Jr. Enc. cc: Maggie Flynn James Kupfer EXHIBIT E Office (508) 862-4038 Fax (508) 790-6230 1 www.town.barnstable.ma.us Town of Barnstable Inspectional Services Department Brian Florence, Director/Building Commissioner January 12, 2024 Town of Barnstable Planning Board Chairman Robichaud 367 Main Street Hyannis, MA 02601 Re: Zoning Determination for 307 Main Street Mr. Chairman, As you know I have been asked by the Planning Board through you to provide a zoning determination concerning compact parking spaces proposed for 307 Main Street, Hyannis, a project for which the Board has received a Special Permit application. The proposal for the subject property was heard at Site Plan Review (SPR) on: 8/15/2023 and 10/24/2023 informally. A formal review of the application was conducted on: 11/16/2023. Having heard objections to the dimensions of parking spaces by a member of the public at the formal review (without citations), I decided to take the matter under advisement to allow time for me to review the parking provisions of the Zoning Ordinance further, before determining whether or not the application was approvable under Article IX, the Site Plan Review provisions of the Zoning Ordinance. Shortly thereafter the petitioner’s attorney requested that I as the Building Commissioner and Chairman of SPR, find the proposed project to be approvable in accordance with specific parking provisions of 240-24.1.5(C) again, without citations. Notably, these provisions do not contain dimensional requirements, thus the applicant’s attorney argued that his client should be allowed to use compact-sized parking spaces for the project. I requested that he provide me with a legal opinion to that effect which he did, this time including citations. I have included a copy of that opinion here for your review. In order to complete my review for consistency with zoning under Article IX, I requested an opinion from the Town Attorney’s office as to whether or not I had authority under the ordinance to find compact parking spaces approvable in light of the neighbor’s objections, the opinion of the applicant’s attorney and the ordinance. After consultation with the Town Attorney’s Office, as well as my review of the Zoning Ordinance, I determined that the proposal was consistent with Zoning and therefore the matter was deemed by me to be approvable for Site Plan Review purposes. My affirming determination was made for the following reasons: 1. Section 240-24.1.5. provides Standards for All [Downtown Hyannis Zoning] Districts, and subsection C of that section contains Parking Standards that are specific to each use which are to be applied in the Downtown Hyannis Zoning District. 2. The parking table in Section 240-24.1.5. C. is the parking regulation specific to the Downtown Hyannis Zoning District. Because that section is the more specific regulation to the district the general requirements found in Article IV Off-Street Parking (cited below) are therefore in conflict with this section which means that the provisions of 240-24.1.5. C. prevails. www.town.barnstable.ma.us a. Reference: §240-24.3 - General Provisions: Where the provisions of §§ 240-24.1.1 through 240- 24.1.13 conflict with those found elsewhere in the Barnstable Zoning Ordinance, the provisions of this section shall apply. b. Further, the more general parking standards in Section 240-55 & 56 respectively provides: i. Section 240-55 Conflicting Provisions Any specific provision in any other section of this chapter relating to parking shall prevail over the provisions of this section. ii. Section 240-56 - Schedule of Off-Street Parking Requirements – provides for the minimum parking requirements for the uses stated therein. 3. Because the Downtown Hyannis Zoning District regulations beginning in §240-24-1-1 of the Zoning Ordinance do not contain provisions regarding parking spaces dimensions, I as the chairman of Site Plan Review and the zoning enforcement officer, not a policy maker, am not permitted to add dimensional requirements to the Downtown Hyannis Zoning District provisions of the ordinance. (see also below) The applicant’s' attorney made the argument in favor of compact spaces in his opinion and the Town Attorney’s Office agreed with his statement that, “if that if a statute or ordinance is silent on something one cannot interpret language into the ordinance”. Citing Iodice v. Newton: where, if a statute or bylaw or ordinance was intended to contain certain language it would be in there and if it is not, it cannot be interpreted that the drafters meant to include such language. a. However, the Ordinance here does in fact contain language about which set of parking regulations to use for each district, so that is not open to interpretation. What is not contained in the relevant sections of the Ordinance is parking dimensions, so it cannot be read as intending to include parking dimensions. 4. The Building Commissioner acting as the Chairman for SPR has discretionary authority to issue Site Plan Approval authorizing the approval of a plan containing compact parking spaces within the Downtown Hyannis Zoning District. If the Chair were to use his discretionary authority to deny such parking spaces, the denial, in order to be sustainable would need a valid basis that cannot not be due to dimension (other than an improper size, e.g. smaller than standard compact spaces). 5. The applicant's attorney further argues that where there is inconsistency, the Building Commissioner must use his discretionary authority to apply the more specific provisions. a. I agree that the more specific provisions should be applied, but I do not even think there remains any inconsistency given the language in the Ordinance that resolves inconsistencies. As stated above, the Ordinance provides in 2 places (240-55 and 240-24.1.3. A.1.) that the more specific provisions apply where there is any inconsistency. Therefore, I determined as the duly appointed zoning enforcement officer and Site Plan Review Chairman of the Town of Barnstable that the use of compact spaces in the Downtown Hyannis Zoning District is permitted and is consistent with the zoning ordinance. Regards, Brian Florence Building Commissioner/Chairman EXHIBIT F DATE: March 31, 2026 RE: Harborview, Hyannis Project Narrative M E M O R A N D U M To Whom it May Concern: The Harborview project is located within the Downtown Main Street Zoning District (DMS). As such, the design is required to meet the standards set forth under Section 240-24.1.6. In November of 2023 the Site Plan Review for Harborview Hyannis was filed. At this time the design was still in the preliminary stages and design development commenced upon approval. The submitted drawings were in conformance with the DMS Zoning section. Throughout design and upon completion of the construction documents, the team has reviewed the design against the Project Narrative and DMS zoning requirements to confirm that all requirements have been satisfied. In regards to the mention of the 180 foot building width provision: the zoning language does not define "Building Width" using the same terms; instead, that is addressed through the Facade Build Out & Primary Frontage. What is labeled as "Building Width" on the zoning table refers to the Building Form. The intent is that the building is not a monotonous form for the entire length of the facade; and the building is required to break up the massing in order to achieve that. See Table 3 below – letter “E” represents the building form width, and shows that the change of roof plane constitutes a change. Based on this definition, referring to the current design, the maximum "Width" that could be considered a continuous form is 171'-3". Please see the elevations, attached to this memo, that provide the dimensions. EXHIBIT F Regards, Matt Marotta COO + Managing Principal FND - AMENITY26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY 30'-6" 4 A-301 4 A-404 2 A-301 LEVEL 245'-0" 25791114151617192123 2 A-402 GARAGE34'-0 1/4" 1 35'-0"F EB FFB.3 E EBE D D C CD D BB E F.2F.2F.2F.2F.2F.2 BB.1B.1 EEB BBBBBB E B E B B E.3FF 35'-0" BB 3 A-404 2 A-404 5 A-403 1 A-404 4 A-403 3 A-403 C D C D C C D C DEB C E.1 E B.1 B A A E E.1 BBBB A-201 4 A-201 6 E.3 E.3B.3 E.3B.3 3468101213182022 FOUNDATION29'-6" 33'-6" 33'-0 1/4"31'-0"30'-0"29'-3 1/8" 34'-1 1/2" 01 07 08 1012 16 07 07 01 08 121212 03 17 04 17 16 06 08 16 16 04 16 01 01 04 04 04 04 0101 E.2 B.2 E.2 12 12 12 12 12 12 10 10 10 10 10 1010 16 17 1703 03 0303 17 3'-0"1'-0"3'-0"6 1/4"10'-8"10'-8"11'-6"04 04 17 14 14 14 17 17 17 101010 04 17 17 17 17 17 07 07 10 10 PVC TRIM FIBER CEMENT LAP SIDING ASPHALT SHINGLE ROOFING THIN BRICK FIBER CEMENT PANEL FIBER CEMENT SHINGLE SIDING FAUX CAST STONE UPVC WINDOW WITH TRIM PVC SHUTTER ASPHALT SHINGLE ROOFING 08 17 EX1EX1 CR EX1EX1 1 A-302 2 A-302 3 A-302 4 A-302 4 A-3036 A-303 SPANDREL GLASS A-714 17'-6"6'-9"7'-4"11'-4"DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT 33'-8 3/4" 5.85.916.516.818.519.5 ASPHALT SHINGLE ROOFING 1'-11 3/4"OVERFLOW DRAIN SPOUT 0404 08 08 0808 0707 04 0404 7 A-301 O/D SPOUTO/D SPOUT O/D SPOUT BEYOND WALL HYDRANT WALL HYDRANT BEYOND A-204 3 A-204 2A-204 3 7 307 MAIN STREET HANGING SIGNAGE ADO 7 FND - AMENITY26'-6" LEVEL 3 55'-8" LEVEL 4 66'-4" ROOF77'-10" AMENITY30'-6" LEVEL 2 45'-0" 4 A-402 GG5 A-402 B.1 F.2 F.2 B.1 B B B B.4 B.4 B A-201 3 A-201 5 DD CCEEFFHHJJKKLL 29'-0" 10 17 04 08 07 08 13 07010112 GG H H 03 17 17 17 170310 10 10 10 11'-6"10'-8"10'-8"14'-6"4'-0"14 07 0817 10 17 01 ASPHALT SHINGLE ROOFING FIBER CEMENT LAP SIDING FIBER CEMENT SHINGLE SIDING THIN BRICK FIBER CEMENT PANEL PVC TRIM ALUMINUM RAILINGS, TYP FAUX CAST STONE UPVC WINDOW WITH TRIM PVC SHUTTER EX1EX1 FLAG POLE A-721 1 DOWNSPOUT AND BOOT A-204 3 SEE ELEC. DRAWINGS FOR CLOCK CONTROL INFORMATION FND - AMENITY26'-6" LEVEL 3 55'-8" LEVEL 4 66'-4" ROOF77'-10" AMENITY30'-6" 3 A-301 LEVEL 2 45'-0" 272526293032333424 2 A-405 BB.1B.1 B.1B.1B.1 B.1 BBBB F.1 F.1HHHH BEEEB EEEB E E B B H.1 B.1E.1 E B H.1H.1H.1H.1 E.1B.1 E B BB 3 A-402 BBB 1 A-402 26'-0"27'-0"29'-0"29'-0" F.1 B.1 B 1 A-405 10 1110 03 0707 1616 07 01 1010 07 04 03 04 04 17 17 10 1010 10 1010 01 01 04 07 1616 07 1017 10 10 1010 10 10 11'-6"10'-8"10'-8"14'-6"4'-0"04 17 00 0707 03 17 17 17 17 1703 17 17 17 17 17 17 1717 17 ASPHALT SHINGLE ROOFING THIN BRICK FIBER CEMENT LAP SIDING UPVC WINDOW WITH TRIM FIBER CEMENT SHINGLE SIDING THIN BRICK FAUX CAST STONE PVC TRIM 171717 FAUX CAST STONEEX1EX118 DOWNSPOUT AND BOOT DOWNSPOUT AND BOOTDOWNSPOUT AND BOOT DOWNSPOUT AND BOOT DOWNSPOUT DOWNSPOUT AND BOOT 3128 CORNER GUARDS O/D SPOUT WALL HYDRANT SIGNAGE - PROVIDE BLOCKING A-721 5 A-204 1 A-204 2 A-204 4 SIM L5 7 7 GAS METER - SEE PLMB 7 FND - AMENITY26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" GARAGE34'-0 1/4" GGAABBDDCCEEFF HH JJ KK LL FOUNDATION29'-6" 01 08 03 0101 06 08 08 07 06 10 10 10 10 B B B B B B B B.1B.1 B.1 B.1 10 10 04 B B B 11'-6"10'-8"10'-8"6 1/4"3'-0"1'-0"3'-0"17 17 10 17 04 PVC TRIMFIBER CEMENT LAP SIDING FIBER CEMENT LAP SIDING ASPHALT SHINGLE ROOFING THIN BRICK FIBER CEMENT SHINGLE SIDING FAUX CAST STONE UPVC WINDOW WITH TRIM 32'-0" 28'-7 7/8"30'-9" 26'-6" 32'-4 7/8" DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT COW'S TONGUE OVERFLOW DRAIN 1717 17 07 WALL HYDRANT EXPOSED INSULATED CONCRETE PANEL A-204 4 L6BEHIND COLUMN FND - AMENITY 26'-6" LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" 3 A-301 LEVEL 245'-0" 2526 24 2 A-405 GARAGE34'-0 1/4"33'-6"33'-0" FOUNDATION 29'-6" 04 06 07 07 EB B B EB B E 08 07 06 11'-6"10'-8"10'-8"6 1/4"3'-0"1'-0"3'-0"B 17 17 ? 17 17 17 17 17 MT-101A PVC TRIM FIBER CEMENT LAP SIDING ASPHALT SHINGLE ROOFING FIBER CEMENT SHINGLE SIDING UPVC WINDOW WITH TRIM, TYP FIBER CEMENT LAP SIDING 04 C-101 EX2EX2 DOWNSPOUT AND BOOT DOWNSPOUT AND BOOT 08 04 1717 17 1 4 2 8 7 5 36 FND - AMENITY26'-6" LEVEL 3 55'-8" LEVEL 4 66'-4" ROOF77'-10" AMENITY30'-6" LEVEL 2 45'-0" 3334 01 04 1003 17 ? B B.1 F.2 11'-6"10'-8"10'-8"14'-6"4'-0"14 10 PVC TRIM FIBER CEMENT LAP SIDING ASPHALT SHINGLE ROOFING THIN BRICK FIBER CEMENT LAP SIDING UPVC WINDOW WITH TRIM 30'-0" DOWNSPOUT AND BOOT H G 17 03 17 14 17 17 ALUMINUM RAILINGS, TYP FIBER CEMENT PANEL PVC TRIM UPVC WINDOW WITH TRIM G H 14 17 03 17 17 17 FIBER CEMENT PANEL FIBER CEMENT PANEL (WHITE) FAUX CAST STONE - OPENING HEADERS & SILLS FIBER CEMENT 7" SHINGLE SIDING (TAN) PVC SHUTTER EXTERIOR MATERIAL LEGEND ASPHALT SHINGLE ROOF 7" SHINGLE SIDING (DK GREY) FIBER CEMENT 7" LAP SIDING (BLUE) FIBER CEMENT PANEL (GREY) NOT IN USE THIN BRICK (TAN) FIBER CEMENT 7" LAP SIDING (WHITE) 1 2 3 4 12 8 7 5 10 6 COVERBOARD AT GRADE11FIBER CEMENT 7" LAP SIDING (TAN) GLASS13 ALUM. RAILING SYSTEM14 DECORATIVE PVC TRIM16 PVC TRIM/CORNICE (WHITE)17 ALUMINUM CHANNEL LETTERING SIGNAGE15 METAL COPING TRIM18 SIMULATED STANDING SEAM (DK GREY)9 ARCHITECT CONSULTANT STAMP KEY PLAN PROJECT NUMBER: DRAWN BY: CHECKED BY: SHEET TITLE 2/6/2026 9:56:25 AMA-201 BUILDING ELEVATIONS HARBORVIEW 223024 307 MAIN STREET WINN DEVELOPMENT CM GF 3/32" = 1'-0"1NORTH ELEVATION 3/32" = 1'-0"4 NORTH EAST ELEVATION FRONT 3/32" = 1'-0"2EAST ELEVATION 01 3/32" = 1'-0"8 SOUTH EAST ELEVATION 3/32" = 1'-0"7SOUTH EAST ELEVATION 02 3/32" = 1'-0"6 NORTH ELEV. INSET 3/32" = 1'-0"3 ANGLED BAY LEFT 3/32" = 1'-0"5 ANGLED BAY RIGHT NO.DATE DESCRIPTION 2 2024-03-14 DESIGN DEVELOPMENT 3 2024-05-02 70% CDs 4 2024-07-25 90% CDs 5 2025-01-30 CONFORMED SET 6 2025-11-24 ADDENDUM 1 7 2026-01-30 ADDENDUM #2 171'-0" 44'-3" 127'-1" 110'-1 1/4" 146'-11 1/2" 35'-7 1/4" EXHIBIT G LEVEL 355'-8" LEVEL 133'-6" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" E = BUILDING FORM 44'-1 3/4" E = BUILDING FORM 126'-10" E = BUILDING FORM 23'-3 3/4" E = BUILDING FORM 109'-9" LEVEL 355'-8" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" E = BUILDING FORM 59'-9 1/8" E = BUILDING FORM 86'-0 1/8" E = BUILDING FORM 35'-4 1/2" FND - AMENITY 26'-6" LEVEL 355'-8" LEVEL 466'-4" ROOF77'-10" AMENITY30'-6" LEVEL 245'-0" E = BUILDING FORM 41'-2 3/4" 1" = 30'-0" HARBORVIEW MAIN ST & OLD COLONY RD ELEVATIONS 6/2/26 1" = 30'-0"1MAIN STREET ELEVATION 1" = 30'-0"2OLD COLONY ROAD ELEVATION 1" = 30'-0"3 MAIN ST/OLD COLONY INTERSECTION EXHIBIT G HARBORVIEW BUILDING FORM BREAKDOWN 6/2/26 HARBORVIEW PARKING LAYOUT - STRUCTURED & SURFACE 6/2/26 HARBORVIEW PARKING LAYOUT - STRUCTURED & SURFACE 6/2/26