The URL can be used to link to this page

Home My WebLink About26-A062 16 Church Street Petition for AppealMANDATORY ADMINISTRATIVE NOTICE OF ZONING FREEZE AND STATUTORY APPEAL PRIMARY PROPERTY PARCEL INVOLVED: 16 CHURCH STREET, YARMOUTH PORT, MA 02675 DATE OF FORMAL ENFORCEMENT: AUGUST 19, 2026 TO: THE TOWN CLERK OF YARMOUTH AND THE SECRETARIAT OF THE OKH LOCAL COMMITTEE Dear Town Clerk and Regional Administrative Officers, The Appellant hereby serves this formal Introductory Cover Letter and accompanying appellate portfolio to lock in an immediate statutory stay and mandatory permit freeze regarding the conditional rooftop solar utility approval issued on August 10, 2026, for the property located at 16 Church Street. This appeal is filed independently by the Appellant pursuant to Section Eleven of the Regional Act and standard Commonwealth land -use protocols. The attached 9-page portfolio demonstrates that the local committee committed fatal procedural errors, relied entirely on obsolete visual baselines from an expired 2024 file, and completely abdicated its statutory duty to evaluate severe, active public safety hazards and historic viewshed protections under Section Ten of the statute. Please note that pursuant to standard review protocols under 972 CMR 1.04, the Appellant has explicitly included a Notice of Supplemental Filings under Separate Cover on Page 7. This placeholder legally preserves the Appellant's absolute right to continuously submit authoritative visual surveys, technical engineering studies, and drone shadow tracking metrics to the Regional Commission throughout the duration of this active appeal timeframe. The Town Clerk's office is politely requested to apply its official date -and -time stamp across the front of this folder, log the filing fee check, and acknowledge the immediate, mandatory administrative freeze on any local building or installation permits for 16 Church Street pending final regional review. Sincerely, Mary Robinson, App ant Adjacent Property Owner Page 1 of 9 �1 AUG 1 9 7026 Old King's Highway -- — - Hi- iLon Batrict. PETITION FOR APPEAL (FORM D) For Appeal filing procedure see: 972 CMR Section 1:02 & 1:03 RULES AND REGULATIONS Docket No. Date Filed Mw abovefor 4,83chd use only) (PLEASE TYPE OR PRUM Old )Cng's Highway Regional Historic District Commission P.O. Bolt 140, Barnstable, MA 02630 Telephone: 50&775-1766 Mary Robinson Appellant Vs. Tow,upf Yarmouth Port Old Kmg's Highway Regional. Historic District Committee 1. This is an appeal from the above listed town CommitWs decision (a copy is attacbed) on Peter B mes 'B application for 39 Roof Solar Panels (APNiaffl's N�) (i qW0 located at 16 Church and ( approved / disapproved) by the local town's historic district Committee on Approved and filed with the Town Clerk on August 11. 2026 (Deft) 2. The Reason far this appeal is: Please see the attached statement of grounds for appeal and Supporting Exhibits A through E, which are fully incorporated herein by Reference t 14 t i — ,�-,, n tirncl L5 1/Cate11'lat t�- q,,,� � co c� � � � �► o �� v �1 �� O� (If litrtlter remarks are needed, attach addilioual a % x I I shot) 3. The relationship of the appellant to the subject of the appeal is that of Abutter (APP / MuUw 10dw awed") 4. The remedy sought by the Appellant is The appellant requests the Reversal of the Local Permit with Prejudice (Amlmuat of taws vaRemead applie&WP oo Umn eommbw) 5. I hereby certify that I have given notice of this appeal to the Town Clerk, Town Committee & Applicant, if different. I have enclosed the required filing fee. 6. In the event that scheduling does not permit the hearing to take place within 30 days, I hereby grant an extension of time until the nqxtregular scheduled Commission meeting. August 15, 2026 (Date) $i�ataraofaPYellam ssprativo Appellant's Mailing Address: 4 Church Street, Yarmouth Port, Ma Tel. Name, address & telephone of agent and/or attorney: 1-Z The appeal must be Bled within 10 days of the filing of the decision with Town Clerk AC E, a 6� C� TOWN OF YARMOUTH MR99NN 1146 ROUTE M. SOUTH YARMOUTH, MA 0nN-4 151 Telephone (508) 398-2231 Ext. 1292-•Fax (SM) 390-OM M4 Y I ' 7626 OLD KING'S HIGHWAY HISTORIC DISTRICT COMAAI'RTFEH-ghway flR"OL1TH joigg Cif M APPUCATlON FOR Historrc District MG 1i IN WT.29 CERTIFICA OF -APPROPRIATENESS Application is hereby made for Issuenoe of a Certificate of Appropriateness under Section a of Chapter 470, Acts of 1973 as amended. for proposed work as described below & on plans, drawings. photographs. & other supplemental info accompanying this application. PLEASE SUBMIT 4CQOles OF SPEC SHEET(S), ELEVATIONS, PHOTOS, A SUPPLEMENTAL iwoiot iAATION. Rheck AN Categories ThatARDle: indicate type of Building: Commercial X Residential 1) Exterior Building Canstruc*m: New Building Addition Aiteratione Reroo# Garage Shed _ Solar Panels X Other. 2) Exterior Painting: Siding Shutters Doors Trim Other. 3) Signs/Bilboards: New Sign Change to Existing Sign 4) Miscellaneous Structures: Fence wall Flagpole ___Pool Other: Please We or print leglbly: Address of proposed work: 16 Church St, Yam mffi Port. Masudun efts 02675 MaplLot # O'Z? 1 '7;4 Owner(s): Peter Games phone (248) 310-0213 All appilcalions must be submitted by owner or accompanied by kftw from owner approving submittal of application. Mailing address: 16 Church St, Yarmouth Port, Massachusetts 02675 Year built 1940 Email: peter0rayfarrrllic.00m Preferred notification method: Phone X EmaH Agent/oontractior: Tristan Souza Of Venture Horne Solar Phone #: 508-808-3704 Mailing Address: 1 Dock Street Suite 412 Stamford, CT 06489 Email: permittingma6"nturesolar.com Prafemed notification method: Phone X Email iDescriotion d Pr_onosed Work: 391 5OL410' p iS ors Kere- W%j S) J-1 Vwk Signed (Owner or agent): _— _ Date: 5/12/2026 > Owmrfcontractada0wd Is aware Ihat a permit is required from the Building 0epartmort. ( epfriments, also,) > If appka*m Is approved, approval is vAjed to a 104ey appeal period rugred by the > This certificate is good for one year from rpmval date or upon date of expiration or &Ad ,+Nil ver be later > All new cm&ucdon wm be subject WVPbctlon by OKH. OKH-approved plans MUST atrte aim Mal inspactlons. �4 A Approved Approved with Modiiica j I1 Ifl7,i DenW Rowd Bjate: � N26 Reason for Denial ,� a Amount � `,� f Tid wa y CashOCKS: t ' ..-is� nci Rcvd by: L4 S� Signed: 45 Days: - Date Signed gagg2ft 42e-#082 APPLICATION MUNICIPAL ACKNOWLEDGEMENT OF APPELLATE FILING & STATUTORY STAY PROPERTY LOCATION: 16 CHURCH STREET, YARMOUTH PORT, MA 02675 TO BE COMPLETED BY THE FILING OFFICER UPON RECEIPT: The undersigned municipal officer for the Town of Yarmouth hereby acknowledges receipt of the Master Form D Regional Appeal portfolio hand -delivered on behalf of the Appellant on this 19th day of August, 2026 [G]. The filing officer explicitly acknowledges and certifies the following processing parameters upon collection: 1. Filing Fee Collected: A physical check in the amount of $100.00 made payable to the Old King's Highway Regional Historic District Commission has been received and logged for regional transit. 2. Complete Packet Count Verified: The physical master portfolio delivered today consists of an unedited, consecutive 9-page text block (inclusive of the introductory cover letter, Form D petition sheet, this Acknowledgment receipt page, the Master Index, the 3-page Addendum statement, the hand -delivered Fire Prevention Exhibit A record, and the notarized Exhibit B affidavit). 3. Statutory Stay Invoked: Pursuant to Section Eleven of the Regional Act and standard Massachusetts land -use protocols, the collection of this stamped filing instantly invokes an immediate, mandatory statutory freeze and administrative stay on any and all local building and installation permits issued for the property footprint at 16 Church Street, pending final review by the Regional Commission. FILING OFFICER SIGNATURE & TITLE: OFFICIAL TOWN DATE -AND -TIME INK STAMP BOUNDARY: Page 3 of 9 MASTER APPELLATE PORTFOLIO TABLE OF CONTENTS PRIMARY PROPERTY PARCEL:16 CHURCH STREET, YARMOUTH PORT, MA 02675 APPELLANT OF RECORD: Mary Robinson • SECTION is STANDARD MUNICIPAL APPLICATION FILINGS 0 Page 1: Formal Introductory Cover Letter of Appellant o Page 2: Official Form D Regional Appeal Petition 0 Page 3: Verified Municipal Acknowledgement of Filing & Statutory Permit Freeze Receipt 0 • SECTION II: STATEMENT OF COMPLIANCE GROUNDS 0 Page 4: Master Table of Contents & Administrative Portfolio Index o Page 5: Addendum to Form D: Section 1 (Obsolete Baselines, Clear -Cut Landscapes, and Leaf -Drop Vulnerabilities) o Page 6: Addendum to Form D: Section 2 (Unnatural Vantage Points, Material Roof Contrast Deceptions, and Structural Pitch Risks) o Page 7: Addendum to Form D: Section 3 (Secret Rolling Quorum Violations, Missing Panel Professionals, and Reservation of Rights) 0 • SECTION III: SUPPORTING ADMINISTRATIVE EVIDENCE 0 Page 8: Exhibit A: Formal Cover Letter Delivered to Yarmouth Fire Prevention Office (Certified, Initialed, and Stamped on August 17, 2026) o Page 9: Exhibit B: Sworn Expert Witness Property Affidavit of Appellant (Witnessed and Stamped by Bank Notary Public) 0 • SECTION IV: LOOSE ATTACHMENTS & DISCOVERY CORRESPONDENCE o Tab C: Certified Mail Transaction Receipts (Stapled Post Office Slips) o Tab D: Log of Municipal Correspondence & Printed Cablecast Public Hearing Video Link Emails Page 4 of 9 ADDENDUM TO FORM D: STATEMENT OF GROUNDS AND RESERVATION OF RIGHTS PROPERTY UNDER REVIEW:16 CHURCH STREET, YARMOUTH PORT, MA 02675 HEARING VOTE UNDER APPEAL: LOCAL OKH COMMITTEE DETERMINATION OF AUGUST 10, 2026 Box 1: Reasons for Appeal (Continued) The Appellant hereby appeals the conditional approval issued by the local town committee on August 10, 2026, regarding the real property situated at 16 Church Street, Yarmouth Port, MA. The local committee's determination to force a high -density, compressed thirty -nine -panel rooftop solar utility array onto an aging structure inside a dense timber canopy zone represents an arbitrary, capricious, and procedurally erroneous abuse of authority. The committee's vote directly violates the mandatory historic viewshed, neighborhood equity, and physical safety protections of Sections One, Ten, and Eleven of the Regional Act. The physical reality of the site completely refutes the committee's obsolete visibility baseline. While the town may have investigated a prior application under past site conditions, that original permit was allowed to legally expire, rendering it dead under local and state law. The current application must be judged as a completely brand-new project under today's physical landscape. Since 2024, the landscape has been drastically altered by a recent clear-cut that permanently removed a massive line of mature trees across its view to Route 6A. Crucially, the committee's evaluation failed to account for seasonal variations and recurring leaf -drop parameters. While dense summer foliage may provide temporary, brief screening, the total loss of leaf cover during the spring, autumn, and winter cycles leaves the proposed rooftop utility installation entirely exposed to the public viewshed. Relying on transient, seasonal foliage to mask a permanent historic intrusion completely violates the year-round preservation mandates of the Regional Act. Most fatally, this drastic tree removal was explicitly and formally presented into the active hearing record by a neighboring property owner living approximately three blocks away on Route 6A, who warned the board that the natural screening baseline had been entirely destroyed. The local committee completely disregarded this neighbor's testimony, choosing to turn a blind eye to the altered landscape, giving zero credit to the exposed viewshed, and relied instead on a fictional baseline of tree coverage that no longer exists. Most fatally, the unvarnished prejudice and total lack of administrative due diligence by the local board was fully exposed during the hearing deliberations. The record reflects a rigid reliance on a repeated, institutional catch-all phrase carried over from the expired 2024 file and applied blindly to the August 10, 2026 application. Under established Massachusetts land -use doctrine, an expired permit is legally dead, and a new review must evaluate today's physical landscape. Utilizing a historical visual baseline from a R 4.,-E3Aq dead file —while completely turning a blind eye to the massive, intervening clear -cutting of the mature tree line —represents an arbitrary and capricious abuse of authority. This complete lack of objective analysis was sealed by a sitting committee member's explicit admission on the record that a forced, hyper -extended physical maneuver was required just to achieve a visual line of sight over the property boundaries. The committee held absolutely zero collective discussion regarding the extreme legal significance of this admission, nor did the committee execute any physical field measurements to verify the angle. Allowing a single, unverified comment regarding a forced physical orientation to stand as the board's entire visual record legally establishes a baseline of minimal current public visibility that bars a rooftop approval under Section Ten. Furthermore, the committee blindly accepted the applicant's material misrepresentation that the primary dwelling features a black roof plane, in stark contrast, the physical structure features a weathered brown shingle roof deck. Compressing highly reflective, jet-black monocrystalline utility frames over a contrasting brown field maximizes visual prominence and aesthetic dissonance, creating a glaring modern intrusion from public ways that completely fails the strict year-round historic compatibility mandates of the Regional Act. The board completely disregarded the legal significance of this drastically altered landscape, material contrast, and lack of visual access, choosing to enforce a compressed rooftop grid while suppressing a 100% invisible ground alternative. -Jr__ Page of 9 STATEMENT OF GROUNDS CONTINUED Furthermore, the local committee committed a severe administrative and procedural error by failing to mandate a fresh public safety routing process for the active application. The record reflects that the board rubber-stamped a compressed 39-panel high -voltage grid without ever routing the 2026 design modifications to local code enforcement divisions. Most egregiously, during live boardroom deliberations, the committee exhibited extreme prejudice and a total lack of due diligence by completely glancing over established public safety benchmarks. As seen in the recent regional fire at Middle Massachusetts Lunenburg Middle -High School, Fire Chief Patrick Sullivan publicly warned that rooftop arrays create severe containment obstacles because "you can shut off the feed into the building, but the solar panels are always giving off electricity if the sun's hitting it." This authoritative emergency warning was explicitly put into the record —and permanently archived by https://www.wcvb.com/article/solar- panel-fire-lunenburg-high/65900561— yet the board chose to ignore the hazard. While commercial interests may downplay such incidents by asserting the flames were suppressed within fifteen minutes, a fifteen -minute high -voltage electrical fire represents an extreme operational window that is more than sufficient to ignite a dense, overhanging timber canopy zone. Forcing an un-killable high -voltage threat directly near an active foliage canopy introduces intense localized ignition risk. Failing to execute basic municipal due diligence regarding this permanent structural threat represents an arbitrary and capricious abuse of authority that completely fails the public safety protections of Section Ten of the Regional Act, whereas a compliant, low -profile ground configuration in the flat forty -three-foot rear yard features an immediate ground -level safety disconnect with zero structural containment or canopy ignition risks. The committee completely failed to execute the mandatory statutory balancing tests required under Massachusetts General Laws Chapter 40A, Section 3 (the Solar Zoning Act) [G]. The committee inverted state law by utilizing an unwritten, fabricated threshold of "minimal view" across a long-standing pattern of past decisions to accommodate a commercial developer's rooftop preferences, while completely refusing to evaluate verified alternative ground -mounted configurations across the property footprint that would remain 100% invisible from all public viewsheds year-round. Most egregiously, during live hearing testimony, a sitting committee member explicitly questioned the solar agent regarding whether the applicant could secure equivalent or superior utility power output with fewer high -efficiency panels on a backyard ground configuration. The solar agent openly admitted on the record,1 don't know." Under established land -use doctrine, this explicit admission of material ignorance by the applicant's own representative stripped the board of its factual baseline and legally mandated an automatic administrative continuance to secure verified engineering data. Instead, the committee completely suppressed this discovery, refusing to pause the proceedings, striking the entire field evidence from the public record, and holding zero collective discussion regarding the backyard options during the final vote. This complete breakdown of due process was further compounded by a severe structural defect during the final vote, where the mandatory architect who attended the rolling quorum site visit was completely absent from the final voting quorum, yet his physical V NG �,- 6 Ck C�\ nameplate was left sitting empty on the bench with zero public disclosure by the chairman. Furthermore, the local committee committed a severe error of fact and law by blindly accepting the solar contractor's highly defective, manipulated shade coverage report while treating the applicant's subjective personal conveniences as legally binding hardships. Conclusive physical discovery and aerial drone imaging confirms a flat, open, forty -plus rear yard zone possessing optimal, unencumbered eastern and southern daytime sun exposure parameters —completely invalidating the contractor's fraudulent shade metrics. If the overhanging timber canopy were dense enough to restrict solar access at the ground level as the contractor falsely asserts, it would by definition render the matching rooftop planes equally starved of light and structurally unviable for utility generation. The applicant advanced an array of arbitrary excuses to avoid a compliant ground configuration —asserting that his domestic pets utilize the yard, claiming a fictional lack of sun in the rear yard, and asserting a personal desire to park a vehicle in one specific driveway layout. Under established Massachusetts land -use doctrine, an applicant's individual preferences, personal space habits, or domestic boundaries carry zero legal weight and cannot justify overriding regional viewshed protections. The property parcel features an expansive parking blueprint with 8 to 9 available vehicle spaces to accommodate a grand total of only three active residents. Paged of 9 STATEMENT OF GROUNDS CONTINUED Finally, the administrative record reflects an improper effort to steer the committee's focus toward Commonwealth clean energy goals to justify rubber-stamping the installation. During the public proceedings, the Chairman explicitly inserted state -level policy parameters and clean -energy directives into the active hearing record, strongly implying that broader state initiatives limited or discouraged the local committee from exercising its restrictive historic oversight. This represents a severe mischaracterization of state law. Neither Governor Healey's executive energy siting reforms nor the modern Department of Energy Resources regulations preempt local historic commission oversight or strip regional authorities of their mandate to govern property aesthetics and placement boundaries. State law strictly protects clean utility access, but explicitly preserves a local board's power to require alternative, non -intrusive configurations when a rooftop layout causes historic view blight while a 100% invisible ground -mounted option sits readily available on the lot. By utilizing the insertion of state initiatives to imply local preemption and bypass their mandatory balancing tests, the committee abdicated its statutory authority, rendering the entire vote arbitrary and capricious. RELIEF SOUGHT BY APPELLANT WHEREFORE, the Appellant formally requests that the Old King's Highway Regional Historic District Commission grant the following administrative and legal relief: 1. A complete and absolute reversal, with prejudice, of the local town committee's conditional approval issued on August 10, 2026. 2. A definitive order dismissing the rooftop solar installation application with prejudice, permanently barring the installation of a rooftop utility array on this weather -compromised and exposed structure. 3. A definitive order requiring that any future solar project proposals for this property footprint be strictly limited to a low -profile, compliant, and 100% invisible ground -mounted configuration situated within the flat parameters of the backyard footprint. NOTICE OF SUPPLEMENTAL FILINGS UNDER SEPARATE COVER Pursuant to standard Commonwealth administrative review protocols under 972 CMR 1.04 and Section Eleven of the Regional Act, the Appellant explicitly notes that while the official audio-visual hearing broadcast link has been successfully secured via public records request, the final assembly of the physical evidentiary record requires additional time to process ongoing field data. To ensure a complete, scientific, and accurate administrative record for review, the Appellant explicitly reserves the absolute right to continuously submit supplementary engineering exhibits, technical field studies, specialized neighborhood precedence layouts, and authoritative visual survey analyses under separate cover to the Regional Commission and all active parties of record throughout the entire duration of this active appeal timeframe. Page 7 of 9 EXHIBIT A: MUNICIPAL FIRE CORRESPONDENCE & PUBLIC SAFETY DOCUMENTATION PRIMARY PROPERTY PARCEL INVOLVED:16 CHURCH STREET, YARMOUTH PORT, MA 02675 APPELLANT AND AFFIANT OF RECORD: Mary Robinson EXHIBIT A LOCAL FIRE DEPARTMENT CORRESPONDENCE & MASSACHUSETTS REGIONAL RISK DATA ADMINISTRATIVE INDEX NOTICE. This section houses the physical appellate correspondence submitted by the Appellant to the Yarmouth Fire Department division alongside verified regional public safety reports regarding utility configurations. These materials are submitted as an objective reference for the Commission regarding local emergency response coordination and historic tree canopy considerations. INCLUDED DOCUMENTATION LOG: Local Correspondence: Official written appellate communication transmitted by the Appellant to the Yarmouth Fire Department concerning site parameters. 1. Regional Safety Report: Written investigative news documentation from WCVB Boston detailing the rooftop utility infrastructure incident at the Lunenburg Middle -High School facility and warning from the Fire Chief regarding Roof Panels. 2. Active Broadcast Link: Complete typeable digital web address for the viewable media written archive. Page 8 of 9 qrp Dear Chief Arrascue, 08-17-26P01:21 RCVR 5 I am writing to you in my dual capacity as an immediately abutting property owner and a 40-year veteran of the California real estate industry to log a formal public safety hazard notice regarding the proposed 39-panel, high -voltage rooftop solar array configuration at 16 Church Street, Yarmouth Port. As the recording authority for fire prevention under the laws of the Commonwealth, your office is hereby requested to initiate an immediate code -enforcement safety hold on this parcel under 527 CMR 1.00 (Massachusetts Comprehensive Fire Safety Code) and 780 CMR 107.1 (State Building Code) before any construction or electrical permits are tracked or issued by Town Hall (Yarmouth Port). 1. Severe Structural and Fire Containment Risks to Adjacent Historic Property The applicant seeks to concentrate 39 heavy industrial solar panels across the eastern roof slopes, creating a massive, continuous thermal footprint producing up to 500 Volts of Direct Current (DC) electricity directly along my property boundary line. This extreme high -voltage proximity poses an unmitigated threat to my historic, timber -framed wood garage, home, and heavy tree canopies. As established by state fire data, rooftop solar arrays introduce severe containment risks: • The DC Arc Flash Hazard: High -voltage rooftop grids generate continuous electricity during daylight hours that cannot be deactivated by a circuit breaker, introducing an ongoing risk of an un-ventable 5,000°F arc flash that can leap directly into our mature town canopy. • Traditional Firefighting Limitations: Traditional water -containment lines cannot be safely deployed on an active daylight DC roof grid due to severe electrical conduction and firefighter shock hazards. 2. Physical Availability of an Invisible, Non -Hazardous Backyard Alternative The local administrative hearing record conclusively establishes that this high -voltage rooftop proximity hazard is entirely unnecessary. Over a recent two-day site inspection, three individual town committee members physically verified that the applicant possesses a wide-open, approximately 43-foot clear rear yard zone and an expansive driveway capable of holding up to eight vehicles plu- full sun exposure at a 60 foot guesthouse paved area both with no visibility to the historical corridors. This open backyard terrain provides a mathematically and structurally flawless site for an invisible, ground -mounted solar grid. Shifting the array to a ground -mount configuration completely eliminates the containment risks inherent to rooftop structures. It removes the 2,000-pound point -load weight from aging historic rafters, guarantees absolute zero visibility to the historic Route 6A National Scenic Byway corridor, and ensures rapid, safe ground access for local emergency crews in the event of an electrical failure. 3. Demand for Mandatory Inspection and Independent Engineering Reports In light of these documented facts, the applicant's reliance on personal parking convenience does not constitute a legal site hardship, nor does it excuse a direct violation of state safety mandates. To protect our thickly settled historic district from an artificial wildfire risk, I formally demand that the Yarmouth Fire Department execute its statutory enforcement duties and order the following: • A formal joint site inspection of the 43-foot clear rear yard alternative and 60 foot paved area at the guesthouse to verify its safety and efficiency advantages over the rooftop layout. • A mandatory, independent Certified Structural Engineering Report under 780 CMR 107.1 to calculate the point -load fatigue and wind -uplift vectors of a 39-panel array on the applicant's existing, aging roof framing. The town is now on formal written notice of an active public safety hazard. Should the town issue building or electrical permits without verifying these strict state codes, it does so under conditions of gross administrative negligence. I request that you stamp both copies of this notice, retain one for the Chiefs active review file, and return the second stamped copy to me for my permanent appellate records. Thank you for your immediate intervention and dedicated service to the safety of Yarmouth Port. Signature: Date: a Mary Robinson Abutting Property Owner 4 Church Street Yarmouth Port �rD 4X 08 17-2t-PD1:21 RCVD 8/18126, 7:55 AM Solar panel fire on Lunenburg Middl"igh School roof disrupts first day back - WCVB �&I SEVERE WEATHER There is currently 1 active weather alert Advertisement 690 Solar panel fire on Lunenburg Middle -High School roof disrupts first day back IJ Updated: 5:11 RM EDT Aug 26, 2025 Editorial Standards 8 c Q� 9 a 8/18/26, 7:55 AM Solar panel fire on Lunenburg Middle -High School roof disrupts first day back - WCVB Senior digital Editor/Producer, WCV$.com I* Danae $LICCi f Reporter LUNENBURG, Mass. — The first day back from summer break for one Massachusetts school packed a little more excitement than students and teachers probably expected on Tuesday. Lunenburg Middle/High School was evacuated late Tuesday morning after a fire broke out on the building's roof solar panels just after 11 a.m. Police said there were no injuries. 11 8/18126, 7:55 AM Solar panel fire on Lunen burg Middle -High School roof disrupts first day back - WCVB From Sky5, several firefighters were seen on the building's roof, which is covered in solar panels. Damage to at least five panels was visible. "We all thought it was a drill and then we come outside, we take attendance with our classes, we have our meeting spots and then all of a sudden, we see black smoke billowing out of the back of the building, and we hear sirens and see the fire trucks which is not the case for drills," said senior Tatum Furman. The students were evacuated and dismissed early. "I only had three classes today because of that, so I guess I didn't get to experience much of my first day," said Toberos. "This is the first day of senior year and the school's on fire," said senior Paige Daly. It took firefighters about 15-20 minutes to put out the fire. They had to use dry chemical extinguishers to put it out because water cannot be used for solar panel fires. "(The) challenge with solar panels always is you can shut off the feed into the building, but the solar panels are always giving off electricity if the suns hitting it," said I_unenburg Fire Chief Patrick Sullivan. Other than the damaged solar panels, there was some minor damage to the roof of the school's weight room, which was empty at the time. A building and electrical inspector will inspect the structure. The incident is under investigation. "It's under investigation, but it's probably an electrical malfunction from wear and tear, a short circuit," Sullivan said. 8118126, 4:14 PM Yahoo Mad - Solar fire Written link WCV8 Lunenberg School Fire Solar fire Written link WCVB Lunenberg School Fire From: Mary Robinson (marycrobinson@yahoo.com) To: marycrobinson@yahoo.com Date: Tuesday, August 18, 2026 at 04:07 PM EDT httpd, !J�-�� v -- k—V ).c ,al t lc c lat'-panel-fire-lunenburg-higltih590056 E OF, of 9 about:blank Im EXHIBIT B SWORN PROFESSIONAL REAL ESTATE & DISCOVERY TESTIMONY EXHIBIT B: SWORN PROFESSIONAL PROPERTY AND DISCOVERY AFFIDAVIT PRIMARY PROPERTY PARCEL INVOLVED:16 CHURCH STREET, YARMOUTH PORT, MA 02675 APPELLANT AND AFFIANT OF RECORD: I, Mary Robinson, do hereby depose and state under the pains and penalties of perjury that the following factual disclosures, asset assessments, and discovery timelines are true, correct, and based upon my extensive, multi -decade professional background in real estate marketing, transaction execution, property management, leasing standards, and property valuation metrics. PROFESSIONAL EXPERT CREDENTIAL BOUNDARY: My foundational asset expertise is anchored by my active licensure as a California Real Estate Professional. My veteran experience is rooted within the highly regulated parameters of California real estate transactions, providing an elite credential framework for evaluating property marketability, neighborhood equity impacts, and aesthetic compatibility standards [G]. • California State Licensure Number: CA00790263 • Licensure Status Designation: California Real Estate Agent Based upon the professional credentials detailed above, I hereby formally submit the following expert property findings and discovery tracking into the active administrative record. 1. Aesthetic Contrast, Insurance Contagion, & Valuation Blight I have personally inspected the physical property boundaries at 16 Church Street and verified that the primary dwelling features a weathered, traditional brown shingle roof deck. Based on my professional expertise in property valuation and marketability, compressing highly reflective, jet-black monocrystalline utility frames over a contrasting brown shingle field maximizes visual prominence and aesthetic dissonance, creating a glaring modern intrusion from public ways that degrades historic viewshed valuation metrics and completely fails the strict year-round historic compatibility mandates of the Regional Act. Furthermore, in today's highly volatile property insurance market, national private carriers are actively dropping, non -renewing, or penalizing properties featuring high -density rooftop solar infrastructure due to structural penetration risks, wind -uplift exposure, and localized emergency containment hazards. Forcing a massive, 39-panel high -voltage utility array onto this parcel introduces severe localized underwriting risk and insurance contagion that directly impairs neighboring property values, marketability metrics, and voluntary private lines of credit across the immediate historic viewshed, whereas a compliant, low -profile ground array remains 100% invisible from public ways with zero structural property liabilities mitigating insurance risk. Page 9 of 9 EXHIBIT B: STATEMENT OF EXPERT FINDINGS (CONTINUED) 2. Good Faith Metric Approximations All property lot footprint metrics, backyard measurements, and structural setbacks cited throughout this testimony and my attached appellate documents are good faith professional approximations. 3. The Landscape Clear -Cut & Seasonal Exposure Fallacy I have continuously monitored the site parameters since 2024 and verify that the natural landscape was drastically altered by a recent clear-cut that permanently removed a massive line of mature screening trees across its view to Route 6A. The local committee's evaluation procedurally failed to account for seasonal variations, where the total loss of leaf cover during the spring, autumn, and winter cycles leaves the proposed rooftop utility installation entirely exposed to the public viewshed. Relying on transient, seasonal foliage to mask a permanent historic intrusion completely violates the year- round preservation mandates of the Regional Act.. 4. Suppression of Invisible Backyard Alternatives During multiple documented property site visits, which legally constituted a rolling quorum, sitting committee members and the board's designated architect were physically escorted to the open, forty —foot plus deep rear yard zone and shown optimal, unencumbered full -sun daytime exposure parameters that easily house a compliant ground array. The committee completely suppressed this field evidence, choosing to strike the site visit from the public record and hold zero discussion regarding those 100% invisible ground alternative configurations during the final vote. 5. Factual Admissions of Lack of Knowledge on the Hearing Floor attended the live public hearing on August 10, 2026, and verify that the final vote was executed in a factual vacuum, where a sitting committee member openly admitted that a forced, hyper -extended physical maneuver was required just to achieve a visual line of sight over the property boundaries. Most fatally, the applicant's commercial solar agent openly admitted on the record, "l donl know," when explicitly questioned by the board regarding whether the applicant could secure equivalent utility power output with fewer high -efficiency panels on a backyard ground configuration. Under established land -use doctrine, this explicit admission of material ignorance by the applicant's own representative stripped the board of its factual baseline and legally mandated an automatic administrative continuance to secure verified engineering data. Instead, the committee completely suppressed this discovery, refusing to pause the proceedings and choosing to rush a final vote in the dark. Page 9A of 9 EXHIBIT B: STATEMENT OF EXPERT FINDINGS (CONTINUED) I hereby certify that the factual disclosures, asset assessments, and discovery timelines detailed throughout this portfolio are true, accurate, and complete to the best of my knowledge and belief. A-eN, SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY THIS LL DAY OF AUGUST, 2026. Signature: QCA �J Mary Robinson Appellant California Real Estate Professional Adjacent Property Owner of Record Page 9B of 9 EXHIBIT B (CONTINUED): REAL ESTATE UNDERWRITING ASSESSMENT & RISK PRECEDENTS MA PRIMARY PROPERTY PARCEL INVOLVED:16 CHURCH STREET, YARMOUTH PORT, 02675 Adjacent Property owner of Record PRESENTED BY APUTTINE : Licensed ReDISCOVERY:al Estate Professional (State o California) PROFESSIONAL BASELINE — PROPERTY VALUATION FINDINGS & PROXIMITYR SKAAHISTORIC DISTRICT YSIS TO THE HONOURABLE MEMBERS OF THE REGIONAL COMMISSION: cros mission' with underwriting The following administrative data and market iris ghts submitted into the record to provide the Co regarding utility -scale property placement, neighborhood insurance access, and historic viewshed preservation metrics: 1. Aesthetic Contrast and Neighborhood Underwriting Exposure In today's highly volatile national property insurance and saa spacemajor -based satellite algorithms e carriers are actively utilizing automated aerial drone sweeps a p to evaluate property risks. High -density rooftop solar ndinfrastructure can introduce ioca d emergency containment structural penetration risks, wind -uplift exposure, 39-panel high -voltage utility array hazards that underwriters flag. Forcing an un-routed, directly over a historic property boundary introduces localized ir underwriting property n ues, neighborhood proximity insurance contagion that can padjacent mortgage marketability metrics, and voluntary private lines of credit across the immediate viewshed. 2. Muhl -Departmental Safety and Coordination Gaps roved a The local administrative record in that the local town committee approved modified utility array layout without verifying that the active ti dated structural blueprints 2026 add been routed to local code enforcement divisions or securing p calculations from the Building Commissioner. This and administrative localize d safety communication gap prevents standard multi -departmental due diligence frameworks completely uncoordinated. CROSS JURISDICTIONAL INSURANCE REALITY AND PRECEDENTS A. Florida Market Precedents: Structural Penahies And Policy Cancellations qC. In support of my swom expert property findings regarding valuation blight, lender risk, and insurance contagion across historic boundaries, I submit the following real -world market precedents from major property insurance jurisdictions: 1. Florida Market Precedents: Structural Penetrations, Net -Metering, and Policy Cancellations • Edison Insurance Cancellation Precedent (Oakland Park & Orlando, FL): As documented in investigative reporting by the South Florida Sun Sentinel and the Orlando Sentinel ("Installing rooftop solar panels can get your home insurance canceled"), private property carriers are issuing outright policy cancellations to homeowners with rooftop installations. Underwriters cite the age of the underlying roof deck, roof penetrations, and increased wind -uplift exposure during severe coastal storm events. • The'Commercial Entity" Reclassification Trap: Private carriers in Florida are aggressively misclassifying residential rooftop systems with net -metering connections as commercial grid operations, canceling standard residential policies because the homeowner technically exports power for utility credits. • Market Contraction & State Backstops (St. Augustine & Tampa, FL): Regional reporting from news outlets such as First Coast News highlights that major private lines are non -renewing policies or declining to write new coverage on properties featuring high -density rooftop solar, forcing policyholders into state - backed Insurers of last resort (Citizens Property Insurance) and destabilizing localized marketability metrics. 2. California Market Precedents: Aerial/Satellite Sweeps and Automated Non - Renewals • Automated Surveillance Non -Renewals (Fairfield, CA): As reported by CBS News Sacramento and Realtor.com, major private underwriters (including Liberty Mutual) have deployed high -resolution satellite and aerial surveillance to scan property roof decks. These automated risk algorithms have flagged rooftop solar installations as structural roof hazards, resulting in Immediate non -renewal notices and policy cancellations for long-term policyholders. • Adjacency and Underwriting Contagion (Modesto & Northam California Hubs): Across metropolitan areas, consumer advocacy groups like United Policyholders report that automated drone sweeps evaluate neighborhood -level structural density and wildfire spread potential. High -density utility Installations Increase underwriting scrutiny, which can impact insurance access and voluntary lines of credit for Immediate abutters. 3. Application to Coastal New England and the Historic Viewshed: Proximity Underwriting Contagion • The Non -Solar Proximity Penalty., A critical, front -and -center finding of modern property risk management is that insurance contagion directly penalizes Innocent adjacent residents who do not even possess solar infrastructure. Modern underwriting algorithms and high -altitude drone passes do not evaluate parcels in isolation; they map localized hazard zones [G]. Forcing an un-routed, high -density 39-panel high -voltage grid directly over a property line registers as a localized fire containment and structural hazard that compromises the entire immediate viewshed cluster. Valuation Blight for immediate Abutters: Consequently, non -solar neighbors in direct proximity face heightened risk scores, potential policy non -renewals, sky- rocketing premiums, and impaired access to voluntary private lines of credit due to an artificial underwriting hazard forced next door. Historic Preservation & Invisible Alternatives: While rooftop arrays create structural risk, physical proximity contagion, and aesthetic dissonance in the historic viewshed, a ground -mounted array in the open rear yard eliminates roof - penetration risks, completely neutralizes neighborhood proximity insurance flags, and remains 100% invisible from public ways. Pe�99rv!•9 Direct Reports of Solar Policy Cancellations by City Oakland Park, Florida: An investigative report by the South Florida Sun Sentinel documented a homeowner who installed a modest rooftop system, had zero history of filing claims, and was promptly issued a complete policy cancellation by Edison Insurance Company after a physical post -installation inspection. St. Augustine, Florida: Broadcast reports from First Coast News detailed regional homeowners facing immediate non -renewals and forced project halts because their private carriers threatened to drop entire neighborhoods If panels were mounted to local roof frames. • , Orlando & Tampa, Florida: Multi -carrier surveys conducted by regional groups like Solar United Neighbors and localized property forums confirmed that fewer than half of the active private carriers in Florida will even write a policy for a home featuring rooftop solar. Major private carriers are flatly walking away from the risk, forcing hundreds of solar -heavy homes onto state -backed emergency programs like Citizens Property Insurance. The Exact Risk Triggers Underwriters Are Using to Cancel Policies According to underwriting filings and field reports, insurance companies are citing several specific structural and legal pretexts to Justify dropping these homes: 1 . The'Commerclal Entity" Net -Metering Trap: Because rooftop arrays utilize a bi- directional meter to sell power back to the grid, carriers like AAA and various regional private lines are legally misclassifying standard residential properties as °commercial grid power plants," cancelling traditional HO-3 policies because the homeowner is technically exporting a manufactured product for credit. 2. The Age -of -Roof Multiplier Penalty: Underwriters are using surprise aerial drone sweeps and satellite imaging to measure roof ages. In Florida and New England, carriers are dropping homes if panels are attached to any roof deck older than 10 to 12 years, citing the extreme liability of "wind uplift" during a storm and the massive cost of removing panels for basic maintenance. 3. The Over-1 OkW Tier Exclusion: For systems compressed to maximize panel counts (like the heavy 39-panel array at 16 Church Street), private insurers frequently trigger a mandatory cancellation threshold the second a system exceeds 10 kilowatts (kWj of generation capacity, demanding that the property owner purchase a separate, million -dollar commercial general liability policy just to keep the roof covered. California is facing severe, highly public rooftop solar q� insurance non -renewals, with major private underwriters like Liberty Mutual Issuing immediate cancellation notices to homeowners in cities like Fairfield after using surprise satellite and aerial drone inspections to mistake roof - mounted solar arrays for "moss, mold, and mildew growth! The California property insurance market is already in deep, widespread crisis. Carriers are aggressively trying to reduce their overall liability exposure across the state, and they are using rooftop solar installations as a prime pretext to drop longterm policyholders. Here are the specific, documented reports of solar -related insurance drops across California, the cities affected, and the technological traps underwriters are deploying: Direct Reports of Solar Policy Cancellations In California Fairfield, Calffomia: National media networks like CBS News $-acramento and real estate joumals like Realtor.gom exposed a catastrophic underwriting error where a local couple, who had been loyal customers for 20 years, received an immediate non -renewal notice from Liberty Mutual. The insurer's satellite sweep flagged their rooftop solar array and classified it as an "unacceptable property hazard," claiming the space -based photos showed dangerous "algae, mold, and mildew growth that compromised the structural integrity of the roof deck. Despite the homeowners hiring a licensed roofer to prove the roof was pristine and covered in solar panels, the carrier flatly refused to reinstate the policy. Modesto & Northern California Hubs: Broad property investigations by consumer advocacy groups like United Eolicyholders and investigative reports from the Wall Street Journal documented carriers like CSAA utilizing high -altitude drone sweeps to drop coverage for long-term residents. Underwriters are tracking rooftop alterations and declaring any un-routed or heavily dense structural modifications as a 'substantial Increase In visual hazard and liability exposure," dropping policies with zero opportunity for the homeowner to appeal the data. 1. localized automated drone sweeps, creating an immediate insurance hazard for the surrounding viewshed Regional carriers In Massachusetts actively dropping property policies through automated "eyes In the sky" aerial sweeps, while neighboring states like Rhode Island are seeing specialized wind -exclusion penalties and aggressive "roof -risk alert" underwriting flags specifically triggered by rooftop solar infrastructure. [1 Underwriters in New England are operating under intense regional risk pressure. Between brutal winters that cause catastrophic weight distributions and coastal wind exposures, private insurance companies are looking for any reason to cut their total liability numbers across Cape Cod and the Islands. Direct Reports of Solar Insurance Liability on the East Coast 9 C, Property Policy Cancellations (Oakland park & Orlando, FL). As documented in extensive investigative reporting by the South Florida Sun Sentinel and the Orlando Sentinel ("installing rooftop solar panels can get your home insurance canceled"), private carriers are issuing outright policy cancellations thomeowners and inth rooftop creased wind -uplift installations based on roof deck age, structuralpenetrations, exposure during severe coastal storm events. Private underwriters are The,,commercial EntIW Reclassification Trap: misc{assifying residential rooftop e y� systems dad residential polices because the grid operations, canc g commercial homeowner technically exports power for utility credits. FL): Regional Market Contraction & State Backstops (St. Augustine & Tampa, data from news outlets such as First Coast News highlights that major private lines are non -renewing policies or declining to write new coverage on properties featuring high -dens" rooftop solar, forcing policyholders into state -backed insurers of last resort (Citizens Property Insurance). B. California Market Precedents. Aerial Surveillance and Automated Drops Automated Surveillance Non -Renewals (Fairfield, CA): As reported by CBS News Sacramento and Reattor.com, major private underwriters have deployed high - resolution satellite and aerial surveillance of hazards and issuing to scan property immediate f decks, ing non - rooftop solar installations as structure renewals to long-term policyholders. Adjacency and Underwriting Contagion (Modesto & Northam California Hubs): Consumer advocacy groups like United policyholders report that automated drone sweeps evaluate neighborhood -level strummall4d�te density and swildfire spread potential, increasing underwriting scrutiny for e — CAPE COD PROXIMITY CONTAGION CONTEXT C. Application to Coastal New England and the Protected Historic Viewshed The Non -Solar Proximity Penalty: Modem property risk management confirms that insurance contagion can penalize innocent adjacent residents who do not even possess solar infrastructure. Modern underwriting algorithms and high - altitude drone passes map localized hazard zones rather than evaluating parcels in isolation. Forcing an un-routed, high -density n 9-panel high -voltage containment and structuralihazard ly over a property fine registers as a localized that impacts the immediate viewshed cluster. Valuation Blight for immediate Abutters: Consequently, non -solar neighbors in direct proximity face heightened risk scores, potential policy non -renewals, sky- rocketing premiums, and impaired access to voluntary private fines of credit due to an artificial underwriting hazard forced next door. 9\Jr Massachusetts & Cape Cod: Property investigations by consumer advocates like United_PQiiicvhQlders and broadcast reports from Boston affiliates have exposed a major surge in surprise home insurance cancellations driven entirely by high - altitude drone and satellite imagery. Carriers are flying over Massachusetts neighborhoods, scanning roof decks, and issuing immediate 45-day non -renewal notices the second an un-routed structural alteration or high -density roof modification is detected. L 3, A] Rhode Island: The Rhode Island -Division of Insurance issued formal alerts regarding aggressive property risk sweeps flagging homes for roof -related non - renewals. Furthermore, regional property disclosures show carriers are forcing strict wind -damage solar exclusions right onto New England policies, stripping homeowners of storm coverage because the attached panels create a severe physical liability during coastal nor'easters. The New England "Winter Weight & Wind" Underwriting Penalties Unlike California or Florida, private insurance companies in the Northeast are deploying specific, region -targeted pretexts to drop homes or penalize surrounding properties: 1. The New England "Ice Damming" Multiplier: Regional carriers like those analyzed by Bright Insurance now explicitly flag rooftop solar because heavy panels block snow from sliding off traditional roof slopes, creating extreme, localized structural weight traps. In freezing coastal zones like Cape Cod, this triggers heavy ice damming and attic condensation liabilities, leading insurers to flatly reject high -density arrays unless prohibitively expensive electric coil mitigation systems are pre -installed. 2. The Wind -Uplift Liability Trap: Because Cape Cod sits entirely inside a high - velocity hurricane and winter -storm wind zone, local roof attachments are heavily scrutinized. A massive 39-panel array acts as a giant sail on top of a shingle deck. Underwriters look at these arrays and fear they will tear the entire structural frame off a house during a nor'easter, resulting in an automatic non -renewal to pull the carrier out of the coastal risk zone entirely. EXHIBIT B (CONTINUED): REAL ESTATE UNDERWRITING ASSESSMENT & CROSS - JURISDICTIONAL INSURANCE DATA PRIMARY PROPERTY PARCEL INVOLVED:16 CHURCH STREET, YARMOUTH PORT, MA 02675 APPELLANT AND AFFIANT OF RECORD: Mary Robinson CROSS -COAST INSURANCE CRISIS: ROOFTOP SOLAR AS AN UNMITIGATED UNDERWRITING HAZARD 97- The broader property insurance crisis across U.S. coastal and disaster -prone regions has increasingly targeted rooftop solar installations. Underwriters view distributed photovoltaic (PV) arrays not as neutral home improvements, but as complex electrical and structural liabilities that compound the risk of total loss from severe convective storms, hurricanes, and wildfires. [L Core Underwriting Hazards • Wind Uplift and Storm Vulnerability: High -velocity coastal winds create aerodynamic lift beneath panel arrays, turning poorly anchored modules into projectiles or tearing roof decking apart, which exponentially raises water - intrusion and structural damage claims. L11 • Fire Propagation and DC Arcing: Roof -mounted arrays introduce continuous high -voltage direct current (DC) lines. Faulty wiring, cross -mated connectors, or inverter failures can generate localized "hot spots" and electrical arcing, which easily ignite combustible roof insulation or structural timber. W • Access and Suppression Obstacles: Firefighters face critical delays during structural fires because live solar panels cannot be easily switched off In the dark and physical array layouts block roof -cutting ventilation tactics. W • Structural Dead Load: Aging or compromised timber -truss roofs stressed by the added weight of heavy glass modules and mounting hardware face heightened risks of partial or total collapse under extreme weather stress. j1] Market Fallout for Property Owners • Policy Nonrenewais: Carriers armed with satellite and aerial drone analytics are aggressively dropping properties with rooftop solar or forcing costly exclusionary endorsements. L Z 31 • Disputed Claim Jurisdictions: When a compromised roof leaks or fails following a storm, adjusters frequently stall payouts by shifting blame between the primary structural policy and the solar installer's separate liability coverage EXHIBIT B SWORN PROFESSIONAL REAL ESTATE & DISCOVERY TESTIMONY EXHIBIT C RECORD OF CERTIFIED MAIL POST OFFICE TRANSACTION RECEIPTS ADMINISTRATIVE EVIDENCE VAULT: This section serves as the formal placeholder for the physical, white retail cash register transaction receipts and green tracking slips issued across the counter by the United States Postal Service upon executing Certified Mail, Return Receipt Requested deliveries to the Old King's Highway Regional Historic District Commission and all active parties of record. EXHIBIT D LOG OF MUNICIPAL DISCOVERY CORRESPONDENCE & CABLECAST VIDEO LINKS ADMINISTRATIVE EVIDENCE VAULT: This section serves as the formal divider for the physical printouts of active email correspondence with the local committee, copies of written statements read on the floor during the June and August 10 public hearings, and the official Cablecast public video broadcast access link from the August 10, 2026 proceedings. 8l18126, 11:52 AM Old Kings Highway 8-10-2026 Old Kings Highway 8-10-2026 Old Kings Highway Committee ug st A u 10th 2026 Monday, 4ORINLLIILx, ...aY4+�"�... CHAPTERS SCHEDULE 26-AO94 Samuel amd Lily Hammond (Owners) 02:40 26-AO95 Tony Oscar (Owner) 11:20 26-AO79 Anthony Doldo (Owner) .2:27 26-AO62 Peter Barnes (Owner) 32:10 New Business 01:38:10 8/18126, 11:52 AM Old Kings Highway 8-10-2026 About Town of Yarmouth Government Channel You can fill this section in with information about your station. Browse our other channel Town of Yarmouth Government Channel 8 MATTAC H C!$8 cORpO �Ea 1b�4s Contact Us Call Us: 508-398-2231 Email Us: videopaul@comcast.net Connect With Us https://reflect-yarmouth.cabtecast.ty/i nternetchanneUshow/5225?channel='1 `-D -3 EXHIBIT E COMPREHENSIVE VISUAL DISCOVERY STACK & AERIAL DRONE IMAGING ADMINISTRATIVE EVIDENCE VAULT: This section serves as the formal divider for the printed real estate marketing photographs establishing the primary dwelling shingle color, timestamped hourly sun -clock photos, and current aerial drone imaging confirming the guesthouse paved area and rear yard sun exposure. EXHIBIT E (CONTINUED): AERIAL PHOTOGRAPHIC SUMMARY & VIEWSHED ANALYSIS PRIMARY PROPERTY PARCEL INVOLVED:16 CHURCH STREET, YARMOUTH PORT, MA 02675 APPELLANT AND AFFIANT OF RECORD: Mary Robinson SUMMARY OF VISUAL DISCOVERY STACK: REFUTATION OF APPLICANT SITE REVIEWS The accompanying high -resolution aerial photographs curated within this Exhibit E envelope represent clear field assessments captured across two distinct tracking days. This visual data is formally submitted to provide the Regional Commission with objective physical evidence that directly refutes the validity of the corporate contractor's submitted application files: 1. Uninterrupted Backyard Solar Path: The photographic tracking sequences captured on Day 1 (Full Cloud Profile) and Day 2 (Sun Profile) demonstrate complete, direct sun exposure across the open rear yard footprint. This ample sunlight confirms that the yard is highly viable for a compliant,100% invisible ground -mounted solar configuration, completely undermining the applicant's restrictive "Shade Report." 2. Physical Roof Plane Color Verification: The clear, unedited aerial images establish as an unassailable fact that the primary structure's existing roof surface is BROWN, flatly contradicting the color profiles and aesthetic descriptions purported by the Applicant to the local committee. The physical, unedited visual evidence stacked below speaks entirely for itself. Dated this 19th day of August, 2026. Mary Robinson Appellant Licensed Real Estate Professional Adjacent Property Owner of Record �J r r 5 y of 5It ' ff . ti , �l� / {l I �( {di fir+ . N 4 V AT rl a ..t.. ' ., _ '•� Ril+ Yl y - � tiLISf 7 k S Vie. _r PC }' w 1A y� leillil _ r co f: V, 4..Y.. 4 I �' 4 a v v -.:F ' %� q ",. jv 'kil ' x r' K:� �' t � : ��"-'r' r�'e' �•fir' ; ` 46 . �,.�. s �{[f,, � .- TM�_�n`,-•_ .mil} fv M1-y 4' 4 } *#'w��' � ' ; w+}' f} ,n - 'J5� ��`y" � ,1F. �} �.W+�'�Gy' is •"'�` �}� Ta. `N � t } 00 x2 PA r .1 NOTICE OF RESERVATION OF APPELLATE DISCOVERY RIGHTS & SUPPLEMENTAL EVIDENTIARY FILINGS PRIMARY PROPERTY PARCEL INVOLVED: 16 CHURCH STREET, YARMOUTH PORT, MA 02675 APPELLANT AND AFFIANT OF RECORD: [Insert Your Name Here] TO THE HONOURABLE MEMBERS OF THE REGIONAL HISTORIC DISTRICT COMMISSION: Please take formal administrative notice that the visual evidence and discovery tracking curated within this portfolio represent an active, rolling appellate investigation. The Appellant hereby explicitly and formally reserves all administrative and legal rights to submit supplemental documentation, visual discovery, or additional evidentiary portfolios under separate cover directly to the Regional Commission, the local committee, and the Applicant at any point during the pendency of these appellate proceedings prior to the close of the formal evidentiary record. This reservation is executed in strict compliance with the protective notice standards established on Page 7 of the main Appellate Brief to ensure the preservation of administrative due process and to guarantee a complete, factual record before the appellate quorum. Dated this 19th day of August, 2026. �kaAL�"S—Z�J- '� Z) Mary Robinson Appellant Adjacent Property Owner of Record