HomeMy WebLinkAboutGrounds for Special Permit and Memorandum of LawGROUNDS FOR SPECIAL PERMIT
AND MEMORANDUM OF LAW
APPLICATION OF MARYANN FELLS
57 GENERAL LAWRENCE ROAD, SOUTH YARMOUTH, MA
The Applicant, Maryann Fells (Applicant), hereby submits this application for a Special
Permit, and in the alternative a Variance, to the Yarmouth Zoning Board of Appeals. The relief
is sought pursuant to the following Sections of the Zoning Bylaw to allow for the extension of
the current setback non -conformity by permitting the recently constructed accessory structure to
remain in its present location. In the alternative, the Variance relief is sought to allow the
structure, mistakenly constructed within a front yard setback on a corner lot, to remain in its
present location. The property is located in the R40 Zoning District and has 15,721 square feet
of area, with 69 feet of frontage on General Lawrence Road and 115 feet of frontage on Captain
Bacon Road. The existing house is located 15.4 feet from the side boundary, where 20 feet is
required. There is also a newly construed garage which is located 28.8 feet from Captain Bacon
Road, where 30 feet is required.
The Applicant recently contracted for the construction of a new 30 foot by 35 foot
garage. The intention was to build the garage on a slab, which would meet all the existing
setbacks and other bulk requirements. However, when the as built was created and submitted to
the Yarmouth Building Department, it was learned that the garage had been built, in error, too
close to the front lot line by 1.3 feet.
The Special Permit request is based on the recent Massachusetts Supreme Judicial Court
case of Bellalta v. Brookline Board of Appeals, 481 Mass. 372 (2019), which only requires that
the applicant demonstrate that the extension of the pre-existing nonconformity (setback
violations) is not substantially more detrimental to the neighborhood than the existing building.
There is no detriment to the neighborhood, which permits accessory structures such as this one.
The Bellalta case expands the holding of the case of Gale v. Gloucester Zoning Board, 80 Mass.
App.Ct. 331 (2011).
MEMORANDUM OF LAW
In Bellalta v. Zoning Board of Appeals of Brookline, 481 Mass. 372 (2019), the Supreme
Judicial Court reaffirmed the process by which a preexisting, non -conforming single- or two-
family structure can be altered or expanded, clarifying the framework established by courts
having difficulty with the challenging language of G.L. c. 40A, Section 6. A copy of that statute
is attached to this Memorandum. Bellalta confirmed that changes to such structures can be
made by special permit without the additional need for a variance.
Section 6 regulates the application of local zoning to preexisting, nonconforming
structures and uses. The Bellalta Court recognized and affirmed the notion that "rights once
acquired by existing use or construction of buildings in general ought not to be interfered
with." Opinion of the Justices, 234 Mass. 597, 606 (1920). Thus, under Section 6, a zoning
ordinance or by-law shall not apply to structures or uses lawfully in existence or lawfully
begun ... but shall apply to any change or substantial extension of such use ... to any
reconstruction, extension or structural change of such structure ... except where alteration,
reconstruction, extension or structural change to a single or two-family residential structure does
not increase the nonconforming nature of said structure. Pre-existing nonconforming structures
or uses may he extended or altered, provided, that no such extension or alteration shall be
permitted unless there is a finding by the permit granting authority ... that such change,
extension or alteration shall not be substantially more detrimental than the existing
nonconforming [structure or] use to the neighborhood.
In two sentences, the statute (i) protects previously compliant structures and uses from
the effect of subsequently enacted zoning bylaws, (ii) preserves the need to comply with zoning
if one wants to change or alter a nonconforming structure or use, and (iii) creates a separate
exemption for certain changes or alterations to single- and two-family structures.
In Bellalta, the SJC examined the extent of the protections afforded by the "second
except clause" to owners of single- and two-family preexisting, nonconforming structures.
Defendant homeowners owned a unit in a two -unit Brookline condominium. They proposed to
construct a dormer to add 677 square feet of living space. The building did not comply with the
floor area ratio ("FAR') — the ratio of building gross floor area to lot area --- for the zoning
district in which it was located. The FAR for the zoning district was 1.0 and the FAR for the
defendants' building was 1.14, and the proposal would increase that number to 1.38. After being
denied a building permit, the defendants applied for, and were granted, a "Section 6 finding" by
the Brookline Zoning Board of Appeal. The Board found that the proposed addition and resulting
increase in FAR would not be substantially more detrimental to the neighborhood than the
nonconforming structure was prior to renovation. Interested abutters appealed, arguing that
because Brookline's bylaw expressly prohibited FAR increases of more than 25%, defendants
also needed to apply for a variance — a more difficult type of zoning relief.
Beginning with Fitzsimmonds v. Board of Appeals of Chatham, 21 Mass. App. Ct.
53 (1985), and culminating with Bjorklund v. Zoning Board of Appeals of Norwell, 450 Mass.
357 (2008), the courts have established a three -step framework to analyze a homeowner's
request to alter, reconstruct, extend, or change a preexisting, nonconforming, single- or two-
family home. First, how does the structure violate current zoning? Second, does the proposed
change intensify that non -conformity? If the answer to question two is "no", the proposed
change is allowed by right, without the need for relief. Only if the answer to question two is
"yes" must a homeowner apply for a finding by the local board that the proposed change will
"not be substantially more detrimental than the existing nonconforming use to the
neighborhood." Bellalta, 481 Mass. at 380-81.
In Bellalta, the defendants argued that the new dormer would make the building more
consistent with the architecture and dimensions of other buildings on the street. In addition, the
proposed addition was modest, as it only increased the habitable space by 675 square feet. Thus,
they argued that the new dormer would not be substantially more detrimental to the
neighborhood than the existing, nonconforming building. The Board agreed, issued the Section 6
finding, and allowed the project to proceed without a variance. Bellalta, 481 Mass. at 383; see
also Gale v. Zoning Board of Appeals of Gloucester, 80 Mass, App. Ct. 331 (2011).
In upholding the Board's decision not to require a variance, the Bellalta court explained that
since the "second except" clause was adopted in 1975, the Legislature has amended Section 6 on
multiple occasions, and never clarified the language — thereby ratifying the courts' interpretative
framework. Bellalta, 481 Mass. at 383. To require the defendants to also apply for a variance
would allow the Brookline bylaw to eliminate the special protections otherwise afforded
preexisting, non -conforming single- or two-family structures by Section 6. Id. at 386 -- 87.
Underlying the language of Section 6 and the language in the Bellalta decision is a stated
pronouncement that extra effort should be taken to protect a particular segment of housing stock:
single- and two-family homes. The protections afforded preexisting, nonconforming single- and
two-family homes would be deceptive if owners were obligated to undertake the burden of
applying for a Section 6 finding and a variance. Bellalta, 481 Mass. at 383. Bellalta's re-
affirmation of the "special protections" afforded to single- and two-family homes is particularly
important amid today's housing crisis. Section 6 provides a valuable tool against towns seeking
to stop housing production by increasing minimum lot sizes or other dimensional
requirements. Bellalta, 481 Mass. at 384 — 85. The Section 6 process allows homeowners to
make changes to accommodate evolving housing needs, without adding additional demand to an
undersupplied housing market.
It is my opinion that the petitioner in this case need not establish the Variance criteria, in
addition to demonstrating that the project is not substantially more detrimental to the
neighborhood, which would be contrary to the holding in Bellalta. There are no new non -
conformities being created with this project —just extensions of existing non -conformities.
I have attached a copy of the case of Bellalta and the Gale cases for your review for your
review.