Loading...
HomeMy WebLinkAboutsigned - WinnDevelopment to Commissioner Florence (2023.11.20) Robert L. Brennan, Jr., Esq. O : 978.965.5885 | C : 617.233.4897 rbrennan@smolakvaughan.com 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 November 20, 2023 VIA E-MAIL Brian Florence Building Commissioner Town of Barnstable 200 Main Street Hyannis, MA 02601 Re: Formal Site Plan Review - 307 Main Street, Hyannis, Massachusetts (the “Project”) Dear Mr. Florence: I am writing on behalf of my client, WinnDevelopment, as a follow-up to our recent Formal Site Plan Review meeting on November 16, 2023 in order to recount the procedural history of the Project’s development, design and review (including by your Department), call your attention to the lack of dimensional requirements specified for the Project’s newly-created zoning district, and discuss the authority and alternative paths under which WinnDevelopment is entitled to approval pursuant to formal Site Plan Review. Procedural History: As you will recall, WinnDevelopment first met informally with you and other Town Department heads in the Town Council Conference Room in Town Hall on May 31, 2023 (the “May 31st Meeting”). At the May 31st Meeting, we discussed the preservation and use of “compact” spaces as a part of the redevelopment of 307 Main Street. WinnDevelopment was aware that such spaces were approved for use in connection with other projects throughout Barnstable, raised this issue with you directly, and was advised at the May 31st meeting that the use of “compact” spaces would be appropriate and permissible in connection with satisfying the parking requirements for the redevelopment of 307 Main Street. WinnDevelopment’s architectural and engineering team made an initial submittal for Informal Site Plan Review on July 31, 2023. The designs were reviewed during Informal Site Plan Review meetings on August 15, 2023 and October 24, 2023, and the proposed project - including parking - received Informal Site Plan Review approval on October 24, 2023. The design submission approved at Informal Site Plan Review incorporated compact parking spaces consistent with both preexisting parking spaces at 307 Main Street and the direction provided by you and others at the May 31st Meeting. Based upon the Informal Site Plan Review approval, WinnDevelopment’s architectural and engineering team submitted an updated design packet for Formal Site Plan Review on November 1, 2023, which was reviewed on November 17, 2023, and the approval of which is now respectfully requested. S MOLAK & VAUGHAN LLP Brian Florence November 20, 2023 Page 2 of 4 {00276786;v2} The Lack of Dimensional Standards for the Downtown Main Street District 307 Main Street is located within the Downtown Main Street (“DMS”) District of the Downtown Hyannis Zoning Districts. Section 240-24.1.3.A.1 of the Zoning Bylaw includes very specific direction with regard to applying prescribed standards of the Downtown Hyannis Zoning Districts in stating, “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.” More specifically, the Downtown Hyannis Zoning Districts include detailed standards for parking as set forth in Section 240- 24.1.5(C) entitled “Parking Standards.” Accordingly, because the Downtown Hyannis Zoning Districts provisions of §§ 240-24.1.5(C) clearly establish specific parking standards for this District as a whole, application of Section 240-24.1.3.A.1 mandates these parking standards to be used, which is entirely consistent with the conflicts provision of the more general parking requirements under Section 240-55 of the Zoning Bylaw which directs that “[a]ny specific provision in any other section of this [Zoning] chapter relating to parking shall prevail over the provisions of this section.” (Emphasis added) Because Section 240-24.1.5(C) clearly and unambiguously establishes specific parking standards in the DMS District and other Downtown Main Street Zoning Districts which are different from other zoning districts under the Zoning Bylaw, it would be inappropriate to import from elsewhere in the Zoning Bylaw other standards not stated or expressly referenced in Section 240-24.1.5(C). See Murray v. Bd. of Appeals of Barnstable, 22 Mass. App. Ct. 473, 479 (1980) (where other sections of bylaw cross-reference restrictive section “if an omission from a [bylaw] was intended (e.g., a specific cross reference), no court can supply it; if the omission was due to inadvertence, an attempt to supply it would be tantamount to adding to a [bylaw] a meaning not intended by the [legislative body]”). See also, Iodice v. City of Newton, 397 Mass. 329, 332–33 (1986) (where the bylaw is clear on its face, no further interpretation is required; but where a provision, word, or phrase is ambiguous, its meaning will be determined by the court in accordance with ordinary principles of statutory construction). Section 20-240.1.5(C) purposely does not prescribe any dimensional parking space or aisle width standards. Instead, leaving it to the Building Commissioner and others involved in the Site Plan Review process to review the Project for consistency with the express design standards of the DMS District and with the purpose and intent of the bylaw in accordance with the Site Plan Review process pursuant to Article IX. Moreover, the application of the parking and other provisions of the Downtown Hyannis Zoning Districts in this manner is entirely consistent with the Council’s expressed intent in adopting the Downtown Hyannis Zoning Districts: “The Downtown Main Street District is intended to promote the continuation of a walkable, pedestrian-oriented downtown environment with continuous active streetscape.” Section 240-24.1.10.A.1, Barnstable Town Council Item #2022-144 (March 3, 2022; emphasis added; attached as Exhibit A). S MOLAK & VAUGHAN LLP Brian Florence November 20, 2023 Page 3 of 4 {00276786;v2} For the reasons above, the Applicant has satisfied the applicable parking requirements and other requirements for the DMS District of the Downtown Hyannis Zoning Districts as well as other applicable provisions of the Zoning Bylaw. The Project rightfully received approval through Informal Review, and the Project is now entitled to Formal Site Plan Review approval. Discretion of the Zoning Enforcement Officer Notwithstanding the foregoing, and even assuming any ambiguity is perceived with respect to parking requirements for the Project, it is within the discretion of the Building Commissioner, as the Barnstable Zoning Enforcement Officer to grant unconditional formal Site Plan Review approval of WinnDevelopment’s submission for 307 Main Street. The local official’s interpretation, if reasonable, is to be afforded deference. See, e.g., Wendy’s Old-Fashioned Hamburgers of N.Y., Inc. v. Bd. of Appeal of Billerica, 454 Mass. 374, 381 (2009) (noting municipality’s “special knowledge” of “history and purpose of [its] zoning by-law”). As noted in a leading treatise on the matter, “When a conflict or ambiguity arises . . . the administrative process begins with the ‘zoning enforcement officer.’” MCLE Massachusetts Zoning Manual, Section 13.1. Indeed, under Massachusetts Zoning Statute, it is “[t]he zoning enforcement officer, who is the building inspector or other local official designated by local regulations, is vested with initial responsibility for interpreting . . . local regulations.” Massachusetts Zoning Manual, Section 13.2; citing M.G.L. c. 40A, section 7. While zoning interpretations may not be unreasonable, arbitrary, whimsical or capricious, in assessing applications, the zoning enforcement officer is “under a duty to act in a fair, judicial and reasonable manner upon the evidence . . . presented . . . keeping in mind the objects of the by-law.” Castelli v. Bd. of Selectmen of Seekonk, 15 Mass App. Ct. 711, 714 (1983) (citing Butler v. Town of East Bridgewater, 330 Mass, 33, 38 (1953). Here, the clear intention of the Downtown Main Street District bylaw is the creation of a “walkable pedestrian-oriented downtown,” (see Exhibit A, Section 240-24.1.10.A.1) and that object of the bylaw is the lens through which ambiguities should be resolved. See Castelli, 15 Mass. App. Ct. at 714. Consistent with the authority above, and in the absence of any parking space dimensional mandates within the controlling district-specific “Parking Standards,” it would therefore be reasonable for the Zoning Enforcement Officer to determine compliance with parking space requirements under the Zoning Bylaw, and it would be inappropriate to import or apply standards not expressly included in the DMS. See Murray, 22 Mass. App. Ct. at 479 (to do otherwise “would be tantamount to adding to a [bylaw] a meaning not intended by the [legislative body]”). Moreover, the Building Commissioner may look to existing spaces for both district precedent and compliance with count requirements for 307 Main Street. Indeed, Section 240-50 of the Zoning Bylaw expressly provides, “Existing parking spaces may be counted S MOLAK & VAUGHAN LLP Brian Florence November 20, 2023 Page 4 of 4 {00276786;v2} to meet the minimum off-street parking requirements for an intensified use” if they are not otherwise committed to use by other continuing uses at the property. As reflected in the memorandum from Beals & Thomas, Inc. dated November 17, 2023, and attached as Exhibit B, a total of 71 compact parking spaces currently exists at 307 Main Street. These spaces are not committed to any other use than for the Project. Therefore, these existing spaces can be counted to meet parking needs for the Project and serve as precedent1 for the Building Commissioner’s review and approval of Formal Site Plan Review. Based upon the clear and unambiguous direction of the District requirements, a decision to approve the Project for Formal Site Plan Review which includes the existing spaces at 307 Main Street – where no dimensional requirements are prescribed, and which approves the creation of other parking spaces consistent with the existing parking space dimensions documented by Beals & Thomas (see Exhibit B) – would be a reasonable exercise of discretion by the Building Commissioner. This authority vests in the Building Commissioner both as the official charged with issuing Site Plan Review approval, and as the Zoning Enforcement Officer with discretionary authority to resolve the specific inconsistencies and ambiguities in the Zoning Bylaw in a manner that not unreasonable, arbitrary or capricious, but indeed is mindful of the “object of the bylaw.” See Castelli, 15 Mass. App. Ct. at 714. Conclusion Section 240-24.1.3.A.1 of the Zoning Bylaw compels that the Building Commissioner must apply the unambiguous provisions of the parking provisions of the Downtown Hyannis Zoning Districts to approve the Project under Site Plan Review. Even assuming, arguendo, there is some ambiguity regarding parking requirements under the Downtown Hyannis Zoning Districts provisions of the Zoning Bylaw, it is within the Building Commissioner’s discretion to find that the parking requirements under the Zoning Bylaw have been satisfied such that Site Plan Review approval can be issued. Thank you for your time and attention, and please do not hesitate to contact me directly if you have any further questions regarding this matter. Sincerely, Robert L. Brennan, Jr. 1 It should be noted that Mr. Bornstein also maintains compact spaces at 319 Main Street, including 10 compact spaces located perpendicular to the driveway easement between his building and the Project site at 307 Main Street. Compact spaces at 319 Main Street serve as additional precedent supporting approval of Formal Site Plan Review for the Project. EXHIBIT A EXHIBIT B