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HomeMy WebLinkAboutMiscellaneous - 12 CARRIAGE CHASE (2) /Y1 3'74 310 CMR 10.99 / � Form 8 DEP Fite Na. 242— 627 (To ne oroviaed by DEP) Commonwealth Citylown ' North Andover --�—{t of Massachusetts Aooucant Hayes Engineering, Inc. Lot #)'15 Carriage Chase Certificate of Compliance Massachusetts Wetlands Protection Act, C.L. c. 131 , §40 From North Andover Conservation CommissioA issuing Authority 603 Salem Street To Hayes Engineering, Inc. Wakefield, MA 01880 (Name) (Address) Dace of Issuance August 20, 1997 his Certificate is issued for work regulated by an Order of Conditions issued to Kenneth P. Wil ner dated 12/10/92 .and issued by the NACC C-7 It is hereby certified that the work regulated by the above-referenced Order of Conditions has been satisfactorily completed. 2. It is hereby certified that only the following portions of the work regulated by the above- refer-enced Order of Conditions have been satisfactorily completed: (it the Certificate of Compliance does not include the entire project, specify what portions are included.) Lot #15 Carriage Chase 3. Q It is hereby certified that the work regulated by the above-referenced Order of Conditions was never commenced.The Order of Conditions has lapsed and is therefore no longer valid. No future work subiect to regulation unser the Act may be commenced without filing a new Nonce of Intent and receiving a new Order of Conditions. ........................................................................................................................... (Leave Soace Blank) 8•t a, p This certificate shalt be recorded in the Registry of Deeds or the Land Court for the district in which the land is located. The Order was originally recorded on 8/15/95 (date) at the Registry of Deeds, North Essex . Book . Page Instrument #17690 5. [J The following conditions of the Order shall continue: (Set forth any conditions contained to the Final Order, such as maintenance or monitoring, which are to continue for a longer period.) Issued by t r Conservation Commission Signatures) -Zzl(Y"IVG i When issued by the Conservation Commision this Certificate must be signed by a majority of is members. On this 20th day of August , 1 9 97 before me personally appeared Joseph W. Lynch. Jr. to me known to be the person described in and who executed the foregoing'instrument and acknowledged that he/she executed the same as his/her free act and deed. Notary Public My commission expires Detach an dotted line and submit to the ......................................................................................................................................................._......................................................... To NACC Issuing Authority Please be advised mat the Certificate of CompiLance for the protect at. FileNumcer 242— has been recorcedatthe Registry of Deeds, Northern Essex and has been noted in the cnain of tide of:tie affected aroeerty on 19 It recorded tand.:ne instrument numoer wnicn identities trns transaction is !_registered fano.the cocument numoer wnicn identifies tnis transaction is w A � 370 CMR 10.99 JN Form 56t' 242-627 (Tom oewmo ar oEPI +r. T North Anodver - Commonwealth d'ry' °M"' - of Massachusetts aoeacant Kenneth Wi11 npr Lot 15 Carriage Chase Order of Conditions Massachusetts Wetlands Protection Act O.L. C. 131, §40 and under the Town of North Andover's Wetlands Bylaw, Chapter 178 From NORTH To Kenneth P Willnar Scott Follansbpp (Name of Applicant) (Name of property ownerl Address 2 Bellehaven nr , e--- =^-= =r--�- Address - This Orcer is issued and delivered as follows: ❑ by hand delivery to applicant or representative on (date) (date) by certified mail.return receipt requested on a This project is iocated at 1 ni- 11; (#21) Carriage C -,,p The property is recorded at the Registry of gook 337 -Page 261 Certificate(it registered) t The Notice of Intent for this project was filed on September 25. 1992 (date) The oublic nearing was closed on Nlyembei 18, 392 (date) Findings The NACC _ has reviewed the above-referenced Notice of Intent anc mans anc has netd a punlic hearing on the project.3esed on tt]e"�nfomtation available to the NArr at this time.the rTArr has deterntmed that the area on which the proposed work is to be done Is significant to the toilowmg interests in accordance with the Presurtlptldns of Significance set forth in me regulations for each Area Subject to Protection Under the Act tC:ecfc zs appropriate): Ch.178 prevention of erosion and sedimentation. Pubifc water supply Flood control 11 Land containing shellfish Private water supply Storm camage prevention Fisheries tife habitat Prevention of pollution Protection of wild Ground watersuppfy Ch.17 Recreation Ch. 178 Wildlife State Share Total Fiing Fee Su�mrte�O (1F fes in excess cf 52:.) Cityi7own Share State Portion S Total Refund Due S CitylTown Portion S - (3/2 total) (1/2 total) E!te ,ve 'V1 #242-627 Lot 15 Carriage Chase Therefore, the North Andover Conservation Commission (hereafter the "NACC") hereby finds that the following conditions are necessary, in accordance with the Performance Standards set forth in the State Regulations, the local ByLaw and Regulations, to protect those interests- noted above. The NACC orders that all work shall be performed in accordance with said conditions and with the Notice of Intentreferencedabove. To the extent that the following conditiogs-modify-or differ from the plans, specifications or other proposals submitted with the Notice of Intent, the conditions shall control. GENERAL CONDITIONS 1. Failure to comply with all conditions stated herein, and with all related statutes and other regulatory measures, shall be deemed cause to revoke or modify this Order. 2 . This Order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private property or invasion of private rights. 3 . This Order does not relieve the permittee or any other person of the necessity of complying with all other applicable federal, state or local statutes, ordinances, by-laws or regulations. 4. The work authorized hereunder shall be completed within three years from the date of this Order. 5. This order may be extended by the issuing authority for one or more periods of up to one year each upon application to the issuing authority at least 30 days prior to the expiration date of the Order. 6. Where the Department of Environmental Protection is requested to make a determination and to issue a Superseding Order, the Conservation Commission shall be a party to all agency proceedings and hearings before the Department. 7. The proposed work includes construction of residence and appurtenances. 8. The work shall conform to the following (except as noted in the remainder of this document where revisions may be required) : (a) Notice of Intent filed by Thomas E. Neve Assoc. , Inc. I (b) Plans prepared by Thomas E. Neve, September 17, 1992. 9. The following wetland resource areas are affected by the proposed work: bordering vegetated wetland. The site is within the watershed of Lake Cochichewick and therefore deemed a vital resource under the Town Bylaws. These resource areas are c #242-627 Lot 21 Carriage Chase 3 significant to the interests of the Act and Town Bylaw as noted above. These resource areas are also significant to the recreational and wildlife e interests of the .B lawe PP Th applicant Y has not attempted to overcome the presumption of significance of these resource areas to the identified interests. 10. The NACC agrees with the applicant's delineation of the wetland resource areas on the site as shown on the plans dated revised September 17, 1992 and November 16, 1992. 11. Issuance of these Conditions does not in any way imply or certify that the site or downstream areas will not be subject to flooding or storm damage. 12 . The conditions of this decision shall apply to, and be binding upon, the applicant, owner, its employees and all successors and assigns in interest or control. 13. The NACC finds that the intensive use of the upland areas and buffer zone proposed on this site to construct a residence and appurtenances will cause further alteration of the wetland resource areas. In order to prevent any alteration of wetland resource areas beyond those proposed in the Notice of Intent and approved herein, a twenty-five (25) foot no-disturbance zone and a thirty-two (32) foot no-construction zone shall be established from the edge of the adjacent wetlands. No disturbance of existing grade, soils or vegetation is permitted in the no- disturbance zone. (See Appendix 5 of the local Regulations) . PRIOR TO CONSTRUCTION 14. No work shall be undertaken until all administrative appeal periods from this Order have elapsed or, if such an appeal has been filed, until all proceedings before the Department or Court have been completed. 15. This Order shall be recorded by the applicant at the Registry of Deeds immediately after the expiration of all appeal periods. No work shall be undertaken until the Final Order has been recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land upon which the proposed work is to be done. In the case of registered land, the Final Order shall also be noted on the Land Court Certificate of Title of the owner of the land upon which the proposed work is to be done. The recording information shall be submitted to the North Andover Conservation Commission on the form at the end of this Order prior to commencement of the work. I #242-627 Lot 21 Carriage Chase 4 16. A sign shall be displayed at the site not less than two square feet or more than three square feet in size bearing the words, "Massachusetts Department of Environmental Protection, File Number 242-627". 17. Any changes in the submitted plans caused by the applicant, another Board's decision or resulting from this Order of Conditions must be submitted to the NACC for approval prior to implementation. If the NACC finds said changes to be significant, the NACC will call for another public hearing (at the expense of the applicant) . Within 21 days of the close of said public hearing the NACC will issue an amended or new Order of Conditions. Any errors found in the plans or information submitted by the applicant shall be considered as changes. The proposed project may be still under review by other local or state boards or agencies. This may result in changes to the project plans or wetland impacts. If any such changes occur a revised plan and an explanation of the revisions shall be submitted to the NACC for review and approval prior to the start of construction. No work shall begin on a project until written approval has been granted by the NACC. 18. The applicant shall contact the Conservation Office prior to site preparation or construction and shall arrange an on-site conference with an NACC representative, the contractor and the applicant to ensure that all of the Conditions of this Order are understood. This Order also shall be made a part of the contractor's written contract. The applicant or contractor shall notify the NACC in writing of the identity of the on-site construction supervisor hired to coordinate construction and to ensure compliance with this Order. 19. The applicant shall submit a construction schedule/sequence to the NACC detailing the proposed sequence of work on site to complete this project. 20. Wetland flagging shall be checked prior to start of construction and shall be re-established where missing so that erosion control measures can be properly placed and wetland impacts can be monitored. 21. A row of staked hay bales backed by a siltation fence shall be placed between all construction areas and wetlands. The erosion control barrier will be properly installed and placed on the plan to be filed and shall be inspected and approved by the NACC prior to the start of construction and shall remain intact until all disturbed areas have been permanently stabilized to prevent erosion. All erosion prevention and sedimentation protection measures found necessary during construction shall be implemented at the direction of the NACC. 22 . The applicant shall have on hand at the start of any soil #242-627 Lot 21 Carriage Chase 5 disturbance, removal or stockpiling, a minimum of thirty (30) hay bales and sufficient stakes for staking these bales (or an equivalent amount of silt fence) . Said bales shall be used only for the control of emergency erosion problems, and shall not be used for the normal control of erosion. 23 . A proper bond or a deposit of money running to the Town of North Andover shall be provided in the amount of $3,000.00 which shall be in all respects satisfactory to Town Counsel, Town Treasurer, and the NACC, and shall be posted with the North Andover Town Treasurer before commencement of work. Said bond or deposit of money shall be conditioned on the completion of all conditions hereof, shall be signed by a party or parties satisfactory to the NACC, and Town Counsel, and shall be released after completion of the project, provided that provision, satisfactory to the NACC, has been made for performance of any conditions which are of continuing nature. The applicant may propose a bond release schedule keyed to completion of specific portions of the project for the NACC's review and approval. This condition is issued under the authority of the local Bylaw. DURING CONSTRUCTION 24. Upon beginning work, the applicant shall submit written progress reports every one (1) month detailing what work has been done in or near resource areas, and what work is anticipated to be done over the next period. This will update the construction sequence. 25. Any fill used in connection with this project shall be clean fill, containing no trash, ' refuse rubbish or debris, including but not limited to lumber, bricks, plaster, wire, lath, paper, cardboard, pipe, tires, ashes, refrigerators, motor vehicles or parts of any of the foregoing. 26. No exposed area shall remain unfinished for more than thirty (30) days, unless approved by the NACC. 27. No regrading in the buffer zone shall have a slope steeper than 2:1 (horizontal:vertical) . Slopes of steeper grade shall be rip-rapped to provide permanent stabilization. 28. There shall be no stockpiling of soil or other materials within twenty-five (25) feet of any resource area. 29. Washings from concrete trucks, or surplus concrete, shall not be directed to, any drainage system or wetland resource area. 30. All waste generated by, or associated with, the construction activity shall be contained within the construction area, and away from any wetland resource area. There shall be no burying #242-627 Lot 15 Carriage Chase 6 of spent construction materials or disposal of waste on p the site by any other means. The applicant shall maintain dumpsters (or other suitable means) at the site for the storage and removal of such spent construction materials off-site. 31. Accepted engineering and construction standards and procedures shall be followed in the completion of the project. 32 . Members of the NACC or its agent shall have the right to enter upon and inspect the premises to evaluate and/or effect compliance with this Order of Conditions. The NACC reserves the right to require, following field inspection, additional information or resource protection measures. 33 . During and after work on this project, there shall be no discharge or spillage of fuel, or other pollutants into any wetland resource area. If there is a spill or discharge of any pollutant during any phase of construction the NACC shall be notified by the applicant within one (1) business day. No construction vehicles are to be stored within 100 feet of wetland resource areas, and no vehicle refueling, equipment lubrication, or maintenance is to be done within 100 feet of a resource area. 34. In an effort to protect the public water supply, the landowner will record a permanent deed restriction on the wetland portion of this lot, which will prohibit any cuttings or disturbance of vegetation, soils or topography. AFTER CONSTRUCTION 35. No underground storage of fuel oils shall be allowed on any lot within one-hundred (100) feet of any wetland resource area. This Condition shall survive this Order of Conditions, and shall run with the title of the property. This condition is issued under the authority of the Town's Wetland Protection ByLaw. 36. Fertilizers utilized for landscaping and lawn care shall be organic and not greater than 5% nitrogen content, and shall be used in moderation. Pesticides and herbicides shall not be used within 100 feet of a wetland resource area. This condition is issued under the authority of the Town's Wetland Protection Bylaw. The landowner will record a permanent deed restriction to ensure compliance with this condition. 37 . Upon completion of construction and grading, all disturbed areas located outside resource areas shall be stabilized permanently against erosion. This shall be done either by loaming and seeding according to SCS standards. If the latter course is chosen, stabilization will be considered complete once vegetative cover has been achieved. #242-627 Lot 15 Carriage Chase 7 38. Upon completion of the project, the applicant shall submit a letter to the NACC from a Registered Professional Civil Engineer certifying compliance with this Order of Conditions and the approved plans referenced herein (or approved revisions) . A letter from a qualified wetland scientist certifying compliance with local/state regulations is also required for the wetland replication/restoration area. A stamped "As-Built" topographic plan of all areas within the jurisdiction of the Wetlands Protection Act and Bylaw shall be submitted when a Certificate of Compliance is requested. This plan will include: a. "As-Built" elevations and grades of all filled or altered wetland resource areas. b. Distances from structures to wetlands. c. A line showing the limit of work. "Work" includes any disturbance of soils or vegetation. 39. The following special conditions shall survive the issuance of a Certificate ,of Compliance for this project: 33 . Discharge or spillage of pollutants. 34. Conservation restriction. 35. Prohibition of storage of fuels underground. 36. Limitations on the use of fertilizers, herbicides and pesticides. Issued By North Andover Conservation Commission Signature(s) This Order must be signed by a majority of the Conservation Commission. On this ,Ld day of_ V61PE 19 before me personally appeared to me known to be the person described in and who executed the foregoing instrument and acknowledged that he:she executed the same as his/iter free act and deed. otary Public My commission ex fres The apblicant,the Owner.any person aggrieved by this Order,any owner of land abutting the land upon which the proposed work is to be done.or any ten residents of the city or town in which such land is located,are hereby notified of their right to recuest the Deoartment of Environmental Protection to issue a Superseding Order,providing the reouest is made by certified mail or hand delivery to the Deoartment. with the appropriate filing fee and Fee Transmittal Form as provided in 310 CMR 10.03(7).within ten days from the date of issuance of this Determination.A copy of the request shall at the same time be sent by certified mail or hand delivery to the Conservation Commission and the applicant. If you wish to appeal this decision under the Town Bylaw, a complaint must be filed in Superior Court. Detach on dotted line and submit to the North Andover Conservation Comm. prior to commencement of work. .......................... . ................................................................................... North Andover ConservationCommission ' To Issuing Authority Please be advised that the Order of Conditions for the protect at Lot 15 021) Carriage Chase File Number 242— 62 has been recorded at the Registry of Deeds, North Essex aria has been noted in the chain of tate of the affected property in accordance with General Condition 8 on . t 9 It recorded land. the instrument number which identifies this transaction is If registered land. the document number which identifies this transac0on is Sicnature Acolic3n! 5-4A f (TO PLAINTIFF'S ATTORNEY: Please C*%*Type of Action Involved., — - MOTOR VEHICLE TORT— rCONTRACT-EQUITABLE RELIEF OTHER. A `TRUE COPY ATTEST 114COMMONWEALTH OF MASSACHUS AS* o l ESSEX, ss. SUPERIOR COURT a CIVIL ACTION 0 No. 93-0126 v s C— Z C Kenneth P Willner , Plaintiff(s) r",) ... ............ ...................... ...... ................ .. v rl x George Reich, Allison Brewster, Richard Milliard, fN3 Paul Tariot, Robert Mansour, Kevin Foley and ry ;carr ° Albert Manzi Jr as the are members of the '-� �....... ................ ....... Defendant(s) North Andover Conservationomucissioii'arid'fh'e' Town of North Andover .o SUMMONS To the above named Defendant: Town of North Andover, Main St., North Andover, MA � L= , Mark .. Johnson o You are hereby summoned and required to serve upon...----rk.....r............................................................................. plaintiff's attorney,whose address is ..... 1810.................... . an answer to the T complaint which is herewith served upon you,within 20 days after service of this summons upon you,exclusive of the o a 0 a day of service. If you fail to do so,judgment by default will be taken against you for the relief demanded in the Tcomplaint. You are also required to file your answer to the complaint in the office of the Clerk of this court at Salem............................................ either before service upon plaintiff's attorney or within a reasonable time thereafter. v = n 3 Unless otherwise provided by Rule 13(a),your answer must state as a counterclaim any claim which you may a v have against the plaintiff which arises out of the transaction or occurrence that is the subject matter of the plaintiff's 3 claim or you will thereafter be barred from making such claim in any other action. O C C 'S v DATE OF SERVICE: a 3 >- ; WITNESS,Robert L. Steadman,Esquire, at Salem,the 19th ! ° day of January in the year of our Lord one thousand Z 0 nine hundred and ninety-three ¢ a og Z W v 0 �J N Clerk o ° 4- a NOTES: 1. This summons is issued pursuant to Rule 4 of the Massachusetts Rules of Civil Procedure. 2. When more than one defendant is involved,the names of all defendants should appear in the caption. If a separate summons is used for each defendant,each should be addressed to the particular defendant. Office#30 A INI:i::;NEW9 ESSEX COURT FOR CIVIL 12J;i:L'NESS P R E:: 6 1.1 I"1 E•' T I V E D A f E:: U- P D A 'T E:: DOCKET 9300126 P A.IN'T [FF WII._L_NER KENNETH F' DEFENDANT f RFWS(E R FAIME MIC ONSV CIriu3M N A DOCKET NO ENTRY DATE CASE TYPE TRACK SESS 9300126 011593 C.:99 F: t 02 SERVICE t...t.lMPI._.ETED . . . 041593 05 ANSWER FILED , • • , • • • • • • . . .1.0 RULES 12, 15, 19, :'Q • •Pl(Irl:(]itiltallFt�lil:). �S:L�t�;3 '0 DISCOVERY COMPLETED . . . . . . . . . . . . . . . . 1.1.1.19:.3 i•�• 40 PRETRIAL CONFERENCE . . . . . 01.109r ;t..: APPROXIMATE DATE r• S TO EE '6 "r -tWIil-1 NOTICE= WILL BE ,SENT 60 TRIAL 60 TRIAL t�'i]N f:f.Nt1E:i7 'T'Ti , , , . , . . � . . . . . . . . 000009 LAST CONTINUANCE . . . . . . . . . . . Dx'r NO SUF F INQUIRY P.RE AK WiPM T. .11 PL( F fS CGS _ 1 GF 1, , i. .._ -. I Gia- I 7 pa 1' :EN y c 4• vp J1A �� �,fa led to Trial Court of Massachusetts \ DOCKET NUMBER i SUPERIOR COURT DEPARTMENT CIVIL ACTION COVER SHEET Essex Division 410V PLAINTIFF(S) DEFENDANT(S)George Reich, Allison Brewster, Kenneth P. Willner Richard Milliard, Paul Tariot, Robert Mansou Ir a--- members-of- ATTORNEYS)FIRM NAME,ADDRESS AND TEL.) ` Mark B. Johnson ATTORNEY(S)(if known) NO. And Cons Comm & Town of Nc Law Office of Mark B. Johnson Andovez 12 Chestnut Street (508) 475-4488 BAMOOY'ffat &ersRA19 (Required) 252760 ORIGIN CODE AND TRACK DESIGNATION Place an ® in one box only: 1. F01 Original Complaint ❑,4. F04 District Ct. Appeal c231, s. 97 (X) ❑ 2. F02 Removal to Sup. Ct. c 231, s. 104 (F) ❑ 5. F05 Reactivated after Rescript; Relief from ❑ 3. F03 Retransfer to Sup. Ct. c 231, s, 102C (X) judgmentlorder (Mass. R Civ. P. 60 (X) ❑ 6. E10 Summary process appeal (X) TYPE OF ACTION AND TRACK DESIGNATION (See Reverse Side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE? C99 MGL c 249 sec 4 & Declaratory_,I1idg-went ' (F ) ❑ Yes ® No 1. PLEASE GIVE A CONCISE STATEMENT OF THE FACTS: (Required in ALL Types of Actions) This is an action in the nature of Certiorari pursuant to MGL c. 249, section 4 and Declaratory Judgment, appaaiiag seeking a declaration that the Conservation Commission exceeded its authority, that the Conservation By Law is unenforceable, and that the Conservatin By Law is illegal and invalid. i 2. IN A CONTRACT ACTION (CODE A) OR A TORT ACTION (CODE B) STATE, WITH PARTICULARITY, MONEY DAMAGES WHICH WOULD WARRANT A REASONABLE LIKELIHOOD THAT RECOVERY WOULD EXCEED $25,000: N/A 3. PLEASE IDENTIFY,BY CASE NUMBER, NAME AND DIVISION, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. None SIGNATURE OF ATTORNEY OF RECORD OR PLAINTIFF./)/V DATE Attorney Mark B. Johnson 4 1/14/93 • •11 n 4 11111[ellln d-.1171 It DISPOSITION RECEIVED A. Judgment Entered + B. No Judgment Entered BY. ❑ 1. Before jury trial or non-jury hearing ❑ 6.Transferred to District DATE ❑ 2. During jury trial or non-jury hearing Court under G.L.c.231, DISPOSITION ENTERED ❑ 3. After jury verdict s.102C. ❑ 4. After court finding Disposition Date BY: ❑ 5. After post trial motion DATE. COMMONWEALTH OF MASSACHUSETTS f Essex, ss SUPERIOR COURT DEPARTMENT CIVIL ACTION" NO: KENNETH P. WILLNER Plaintiff VS. GEORGE REICH, ALLISON BREWSTER, RICHARD MILLIARD, PAUL TARIOT, ROBERT MANSOUR, KEVIN FOLEY and ALBERT MANZI, JR. as they are members of the Conservation Commission of the Town of North Andover, and the TOWN OF NORTH ANDOVER, Defendants COMPLAINT IN THE NATURE OF CERTIORARI PURSUANT TO MASSACHUSETTS GENERAL LAWS CHAPTER 249 SECTION 4 AND DECLARATORY JUDGMENT STATEMENT OF CASE This is an action in which the Plaintiff seeks Declaratory Judgment: (1) that the Conservation Exceeded its authority in imposing certain conditions in the Order of Conditions issued to the Plaintiff; (2) that the Conservation By law of the Town on North Andover and the Regulations thereto are illegal and unenforceable; and (3) that the Conservation By Law of the Town of North Andover is less stringent than the DEP Regulations and therefore are unenforceable and invalid. PARTIES 1. The Kenneth P. Willner is an adult individual residing in Andover, Essex County, Massachusetts. 2 . The Defendant George Reich is an adult individual who resides at 284 Salem Street, North Andover, Massachusetts and is a member of the North Andover Conservation Commission (hereinafter referred to as "NACC") . 3 . Allison Brewster is an adult individual who resides at 1005 Forest Street, North Andover, Massachusetts and is a member of the NACC. 4 . Richard Milliard is an adult individual who resides at 195 Barker Street, North Andover, Massachusetts and is a member of the NACC. 1 r ' 5. Paul Tariot is an adult individual who resides at 46 Osgood Street, North Andover, Massachusetts and is a member of the NACC. 6. Kevin Foley is an adult individual who resides at 52 Hewitt Avenue, North Andover, Massachusetts and is a member of the NACC. 7 . Robert Mansour is an adult individual who resides at 1001 Johnson Street, North Andover, Massachusetts and is a member of the NACC. 8 . Albert Manzi, Jr. is an adult individual who resides at 72 Foster Street, North Andover, Ma. 9. The Town of North Andover is a municipal corporation in the Commonwealth of Massachusetts established in April 1855 and having a place of business on Main Street, North Andover, Massachusetts JURISDICTION 10. This Court has jurisdiction to review by Certiorari the decision of the NACC Order of Conditions issued pursuant to Town By Law and pursuant to Massachusetts General Laws, Chapter 249, Section 4 . 11. Plaintiff has sought a superseding Order of Conditions with the Department of Environmental Protection based upon the Order of Conditions issued by the NACC. FACTS 12 . Plaintiff submitted a Notice of Intent to the NACC for the property known as 21 Carriage Chase, North Andover, Massachusetts pursuant to 310 CMR 10. 53 (3) (e) and Town Bylaw, Chapter 178. 13 . Following hearing, the NACC issued on December 12, 1992 , the "Lot 15 Carriage Chase Order of Conditions Pursuant to Massachusetts Wetlands Protection Act G. L. c. 131, sec 40 and under the Town of North Andover's Bylaw Chapter 178". (A copy of the Order of Conditions is annexed hereto and marked EXHIBIT "1") . 14 . The Order of Conditions contains 39 numbered paragraphs describing conditions imposed by the NACC. 15. This Complaint in the Nature of Certiorari, seeks review of the decision of the `followings conditions set forth in the Order of Conditions: conditions numbered 13 , 23 , 27, 32, 34, 36, and 38. ACTION BEYOND JURISDICTION ERRORS OF LAW AND DECLARATORY JUDGMENT 2 16. The Plaintiff hereby restates, realleges and incorporates by reference paragraphs Complaint as fully and completelyas thou res within their entirety herein. g tated in 17. The decision of the NACC exceeded its jurisdiction Pursuant to Massachusetts General Laws, Chapter 40 and the Town of North Andover By-lawas to the following g Condition. 13 The NACC finds that the intensive use of the upland areas and buffer zone proposed on this site to construct-a residence and appurtenances will cause further alteration of the wetland resource areas, In any alteration of wetland resource aareas beyonder totthose proposed in the Notice of Intent and approved herein, a twenty-five (25) foot no-disturbance zone and a thirty-two (32) foot no-construction zone shall be established from the edge of the adjacent wetlands. No disturbance of existing grade, soils or vegetation is permitted in the no- disturbance zone. (See Appendix 5 of the local Regulations) . Condition 23. A proper bond or a deposit of money running to the Town of North Andover shall be provided in the amount of $3, 000. 00 which shall be in all 'respects satisfactory to Town Counsel, Town Treasurer, and the NACC,and shall be posted with the North Andover Town Treasurer before commencement of work. Said bond or deposit of money shall be conditioned on the completion of all conditions hereof, shall be signed by a party or parties satisfactory to the NACC, and Town Counsel, and shall be releases after completion of the project, provided that provision, sati to the NACC, has been made for performances ofCanyy conditions which are of continuing nature. The applicant may propose of bond release schedule keyed to completion of specific portions project of the NACC's review and a pra of the l. condition is issued under the authorityaof theis local Bylaw. Condition 27. No regrading in the buffer zone shall have a slope greater than 2 :1 (horizontal:vertical) Slopes of steeper shall be rip-rapped to provide P grade stabilization. permanent Condition 32. Members of the NACC or its agent shall have the right to enter upon an inspect the premises to evaluate and/or effect compliance with this Order of Conditions. The NACC reserves the right to require, following field inspection, 3 additional information or resource protection measures. Condition 34. In an effort to protect the public water supply, the landowner will record a permanent deed restriction on the wetland portion of this lot, which will prohibit any cuttings or disturbance of vegetation, soils or topography. Condition 36. Fertilizers utilized for landscaping and lawn care shall be organic and not greater than 5% nitrogen content, and shall be used in moderation. Pesticides and herbicides shall not be used within loo feet of a wetland resource area. This condition is issued under the authority of the Town's Wetland Protection ByLaw. The landowner will record a permanent deed restriction to ensure compliance with this condition. Condition 38. Upon completion applicant shall submit a letter tothe thepNACCcfromha Registered Professional Civil Engineer certifying compliance with this Order of Conditions and the approved plans referenced herein (or approved revisions) . A letter from a qualified wetland scientist certifying compliance with local/state regulations is also required for the wetland replication/restoration area. A stamped "As Built" topographic plan of all areas within the jurisdiction of the Wetlands Protection Act and Bylaw shall be submitted when a Certificate of Compliance is requested. This plan will include: a. "As-Built" elevations and grades of all filled or altered wetland resource areas b• Distances from structures to wetlands. C. A line showing the limit of work. "Work" includes any disturbance of soils or vegetations. 18 . Plaintiff submitted ample credible evidence that activity proposed in the notice of intent will not cause significant harm to any wetland resource areas or any area which the Defendants may lawfully protect. 19. The Conditions imposed by the Conservation Commission are exceed the authority of the Conservation Commission and the Commission has committed an error of law in that the Conditions: A. are based upon a by-law which has not been lawfully adopted by the Town; 4 B. are based upon regulations which exceed the authority of the Conservation Commission to adopt; C. impose conditions which are not within the jurisdiction of the Conservation; D. seek to regulate activities which are not within the jurisdiction of the Conservation Commission; E. are arbitrary, not based upon credible evidence and are illegal; WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter the followings 1. That the appropriate process issue by the Court requiring the Defendants to Certify fully, within a time specified by the Court, the record and/or proceedings of the Conservation Commission relative to the Plaintiffs applications. 2 . The Court enterud j gment that the. NACC and the Town of North Andover have exceeded their Jurisdiction by including the conditions set forth in paragraphs 13, 23, 27, 32, 34, 36, and 38 in the Order of Conditions which are the subjects of this action. 3 . The Court enter judgment that the NACC and the Town of North Andover have committed errors of law by including the conditions set forth in paragraphs 13, 23, 27, 32, 34, 36, and 38 in the Order of Conditions which are the subjects of this action. 4 . The Court enter aud j gment annulling the conditions which are the subject of this Complaint. 5. The Court enter a judgment that.. the decision of the NACC which places conditions upon the applicant where there was no substantial evidence that wetland areas would be adversely affected is beyond the jurisdiction of the NACC. 6. The Court enter a judgment that the decision of the NACC which places conditions upon the applicant where there was no evidence that wetlands areas would suffer significant adverse effects constitutes an error of law. 7. Enter judgment that Plaintiff submitted ample credible evidence that activity proposed in the notice of intent will not cause significant harm to any wetland resource areas. 5 8 • Enter judgment directing the NACC to issue Order of Conditions, deleting the subject the conditions. 9• The Court enter such other and further reli the Court deems, just, of as COUNT AQARATO Y JUDGMEiurm 20. Plaintiff restates and realleges and hereby incorporates by reference paragraphs i through 51 of the within Complaint as fully and completely as 'tho restated in their entirety herein. ugh 21. The NACC establishedtheOrder of Conditions applicants property based upon its ConservationrB l and Regulations allegedly promulgated thereunder. y law 22. A dispute has arisen as to whether the Conservation Commission has the authority to issue the conditions set forth above. 23 . A dispute has arisen as to whether the Conservation Commission has the authority to issue the regulations which the conditions are based upon. 24 . A dispute has arisen as to whether the Conservation Law is more stringent than Wetlands Protection Act. By 25. There is a dispute between the pes as the NACC has the legal authorityarttolenact theWhether Conditions set forth in the Order of Conditions and forth above. set WHEREFORE, Plaintiff respectfully requests that thi Honorable Court enter the following: s 1. The Court enter Declaratory Jud ent s that the NACC does not have authorityeorablishing jurisdiction to issue the conditions at issue in his action. 2 . The Court enter Declaratory Judgment establishin that the NACC does not have authority or g Jurisdiction to impose the Conditions based upon the Conservation By Law as said by law was not lawfully enacted. 3 • The Court enter Declaratory Judgment establishi that the NACC does not have authority or ng Jurisdiction to impose the Conditions based upon the Conservation Regulations as said regulations go beyond the scope of the bylaws or the authority Of the Conservation Commission and are therefore illegal and void. 6 4 . Enter judgment that the Conservation By-Law is of no effect as it isnot more stringent than the Wetlands Protection Act. 5. Such other and further relief as the Court deems just. Count III (Damages) 26. The Plaintiff realleges the allegations set forth above. 27. The Conservation Commission has imposed the following condition upon the Plaintiffs land: "Condition 34. In an effort to protect the public water supply, the landowner will record a permanent deed restriction on the wetland portion of this lot, which will prohibit any cuttings or disturbance of vegetation, soils or topography. " 28. The above condition amount to a taking for which the Plaintiff is entitled to compensation. 29. The Defendants have not followed the statutory procedure for an eminent domain taking 30. As a result of the imposition of this condition the Plaintiff has suffer a loss of his property and has suffered monetary damages Wherefore, the Plaintiff request that this Court, if it upholds the above condition, award the Plaintiff damages for the partial loss of his property, `plus costs and attorney fees. Kenneth P. Willner by his attorney, M Joh son d1 Chestnut Street Andover, Ma. 01810 508 475-4488 litig/willner B.B.O. #252760 7' 310 CMR 10.99 Form 5 , 9=1 ]6 I 242=627 DEPI ' Gty.Towt+ North Anod _gz - Commonwealtri ' =•of Massaeriusett5 Aooucant Kenneth Wily Lot 15 Carriage Chase Order of Conditions Massachusetts Wetlands Protection Act C.L. 0. 1311 §40 and under the Town of North Andover's Wetlands, Bylaw, Chapter 178 From NORTH To. Kenneth P. Will— Scott Fo langhpP - (Name of Applicant) - (Name of property owner) AOCress 2 Bellehnyan nr AAJ—X-- Me Address This Orcer is issued and delivered as follows: • (Date) p by nano delivery to applicant or representative oft_ (::ate) by certified mail.return receipt requested on P � 1 This project is located at (#21) Carriage The property is recorced at the Registry of Boo33'7 -Page 261 n - Cenriicate(it registered) , The Nonce of Intent for tuts project was files on September 95• 1999 (p2te) The ouofic nearing was closed on November 18, 1992 (date! Findings NACC has reviewed the above-referenceC NotiC_of The rias nets a puotic nearing on the~role-t. 8asec on the�intormauon avaiiao:e tc the Intent anc:.cans anc S N^ter' at this time.the Nary has cetermtned that the area on wnt cit tate OrOcosea worts is to oe cone rs slgndtcartt t0 tfle f0110wtng interests M accordance with the Presurnutions of Significance set form in the reguiaaons for earn Area Suoject to Proteson Under the Act tC:ecK 2S�roartatet: Ch.-1784 prevention o£ erosion and sedimentation ' Pubiic.water suoatY Flood control C3 Land rung stielltisri Storm carnage prevention Fisherriesies Private water sutipty Protection of wildlife habitat Ground water supply Prevention of poltuuon Ch. 178 Wildlife Cts 1 re Recreation Total rising t=ee SU mored State,..hare . City(?own Share 1 137.50 ('h tee in exce�cf 52.1 Total Retuno Due S City/Town Portion S State Por5 (,,h total) (�/z tatal) il #242-627 Lot 15 Carriage Chase Therefore, the. North Andover Conservation Commission (hereafter the "NACC") hereby finds that the following conditions are necessary, in accordancewiththe Performance Standards set forth in the State Regulations, the local Bylaw' and Regulations, to protect those interests noted above. The NACC orders that all work shall be performed in accordance with said conditions and with the Notice of Intent referenced above. To the extent that the following conditions-modify-or differ from the plans, specifications or other proposalssubmittedwith the Notice of Intent, the conditions shall control GENERAL CONDITIONS 1. Failure to comply with all conditions stated herein, and with all related statutes and other regulatory measures, shall be deemed cause to revoke or modify this Order. 2. This Order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private property or invasion of private rights. 3 . This Order does not relieve the permittee or any other person of the necessity of complying with all other applicable federal, state or local statutes, ordinances, by-laws or regulations. 4 . The work authorized hereunder shall be completed within three years from the date of this Order. 5. This order may be extended by the issuing authority for one or more periods of up to one year each upon application to the issuing authority at least 30 days prior to the expiration date of the Order. 6. Where the Department of Environmental Protection is requested to make a determination and to issue a Superseding Order, the Conservation Commission shall be a party to all agency proceedings and hearings before the Department. 7 . The proposed work includes construction of residence and appurtenances. 8. The work shall conform to the, following (except as noted in the remainder of this document where revisions may be required) : (a) Notice of Intent filed by Thomas E. Neve Assoc. , Inc. (b) Plans prepared• by Thomas E. Neve, September 17, 1992 . 9. The following wetland resource areas are affected by the proposed works bordering vegetated wetland. The site is within the watershed of Lake Cochichewick and therefore deemed a vital resource under the Town Bylaws. These resource areas are i 1242-627 Lot 21 Carriage Chase 3 significant to the interests of the Act and Town Bylaw as noted above. These resource areas are also significant to the recreational and wildlife interests, of the Bylaw. The applicant has not attempted to overcome theresum t' ' p p ion of significance of these resource areas to the identified interests. 10. The NACC agrees with the applicant's delineation of the wetland resource areas on the site as shown on the plans dated , revised September 17, 1992 and November 16, 1992. 11. Issuance of these Conditions does not in any way imply or certify that the site or downstream areas will not be subject to flooding or storm damage. 12 . The conditions of this decision shall apply to, and be binding upon, the applicant, owner, its employees and all successors and assigns in interest or control. i 13 . The NACC finds that the intensive use of the upland areas and buffer zone proposed on this site to construct a residence and appurtenances will cause further alteration of the wetland resource areas. In order to prevent any alteration of wetland resource areas beyond those proposed in the Notice of Intent and approved herein, a twenty-five (25) foot no-disturbance zone and a thirty-two (32) foot no-construction zone shall be established from the edge of the adjacent wetlands. No disturbance of existing grade, soils or vegetation is permitted in the no- disturbance zone. (See Appendix 5 of the local Regulations) . PRIOR TO CONSTRUCTION 14 . No work shall be undertaken until all administrative appeal periods from this Order have elapsed or, if such an appeal has been filed, until all proceedings before the Department or Court have been completed. 15. This Order shall be recorded by the applicant at the Registry of Deeds immediately. after the expiration of all appeal periods. No work shall, be undertaken until the Final order has been recorded in the Registry of Deeds or the Land Court for the district in .which the land is located, within the chain of title of the affected property.- In the case of recorded land, the Final Order ,shall also be noted in the Registry's Grantor Index under the name of the owner of the land upon which the proposed work is to be done. In the case of registered land, the Final Order shall also be noted on the Land Court Certificate of Title of the owner of the land upon which the proposed work is to be done. The recording information`shall be submitted to the North Andover Conservation Commission on the form at theend of this Order prior to commencement of the work.' 1242-627 Lot 21 Carriage Chase 4 16. A sign shall be displayed at the site not less than two square feet or more than three square feet in size bearing the words, "Massachusetts Department of Environmental Protection, File Number 242-62711. 17. Any changes in the submitted plans caused by the applicant, another Board's decision or resulting from this Order of Conditions must be submitted•_to the NACC for approval prior to implementation. If the NACC finds said changes to be significant, the NACC will call for another public hearing (at the expense of the applicant) . Within 21 days of the close of said public hearing the NACC will issue an amended or new Order of Conditions. Any errors found in the plans or information submitted by the applicant shall be considered as changes. The proposed project may be still under review by other local or state boards or agencies. This may result in changes to the project plans or wetland impacts. _If any such changes occur a revised plan and an explanation of the revisions shall be submitted to the NACC for review and approval prior to the start of construction. No work shall begin on aproject' until written approval has been granted by the NACC. 18 . The applicant shall contact the Conservation Office prior to site preparation or construction and shall arrange an on-site conference with an NACC representative, the contractor and the applicant to ensure that all of the Conditions of this Order are understood. This Order also shall be made a part of the contractor's written contract. The applicant or contractor shall notify the NACC in writing of the identity of the on-site construction supervisor hired to coordinate construction and to ensure compliance with this Order. 19 . The applicant shall submit a construction schedule/sequence to the NACC detailing the proposed sequence of work on site to complete this project. 20. Wetland flagging shall be checked prior to start of construction and shall be re-established where missing so that erosion control measures can be properly placed and wetland impacts can be monitored. 21. A row of staked hay bales backed by a siltation fence shall be placed between all construction areas and wetlands. The erosion control barrier will be properly installed and placed on the plan to be filed and shall be inspected and approved by the NACC prior to the start of construction and shall remain intact until all disturbed areas have been permanently stabilized to prevent erosion. All erosion' prevention and sedimentation protection measures found necessary during construction shall be implemented at the direction of the NACC. 22. The applicant shall have on hand at the start of any soil r 1242-627 hot 21 Carriage Chase 5 disturbance, removal or stockpiling, a minimum of thirty (30) hay bales and sufficient stakes for staking these bales (or an equivalent amount of silt fence) . Said bales shall be used only for the control of emergency erosion problems, and shall not be used for the normal control of erosion. 23 . A proper bond or a deposit of money running to the Town of North Andover shall be provided in the amount of $3, 000. 00 which shall be in all respects satisfactory to Town Counsel, Town Treasurer, and the NACC, and shall be posted with the North Andover Town Treasurer before commencement of work. Said bond or deposit of money shall be conditioned on the completion of all conditions hereof, shall be signed by a party or parties satisfactory; to the NACC, andTownCounsel, and shall be released after completion of the project, provided"that -provision, satisfactory to the NACC, has been made for performance of any conditions which are of continuing nature. The applicant may propose a bond release schedule keyed to completion of specific portions of the project for the NACC's review and approval. This condition is issued under the authority of the local Bylaw. DURING CONSTRUCTION 24 . Upon beginning work, the applicant shall submit written progress reports every one (1) month detailing what work has been done in or near resource areas, and what work is anticipated to be done over the next period. This will update the construction sequence. 25. Any fill used in connection with this project shall be clean fill, containing no trash, ' refuse rubbish or debris, including but not limited to lumber, bricks, plaster, wire, lath, paper, cardboard, pipe, tires, ashes, refrigerators, motor vehicles or parts of any of the foregoing. 26. No exposed area shall remain unfinished for more than thirty (30) days, unless approved by the NACC. 27 . No regrading in the buffer zone shall have a slope steeper than 2 : 1 (horizontal:vertical) . Slopes of steeper grade shall be rip-rapped to provide permanent stabilization. 28 . There .shall be no stockpiling of soil or other materials within twenty-five (25) feet of any resource area. 29. Washings from 'concrete trucks, or surplus concrete, shall not be directed to, any drainage system or wetland resource area. 30. All waste generated by, or associated with, the construction activity shall be contained within the construction area, and away from any wetland resource area. There shall be no burying #242-627 Lot 15 Carriage Chase 6 of spent construction materials or disposal of waste on the site by any other means. The applicant shall maintain dumpsters (or other suitable means) at the site for the storage and removal of such spent construction materials off-site. 31. Accepted engineering and construction standards and procedures shall be followed in the completion of the project. 32 . Members of the NACC or its agent shall have the right to enter upon and inspect the premises to evaluate and/or effect compliance with this Order of Conditions. The NACC reserves the right to require, following field inspection, additional information or resource protection measures. 33 . During and after work on this project, there shall be no discharge or spillage of fuel, orotherpollutants into any wetland resource area. If there is a spill or discharge of any pollutant during any phase of construction the NACC shall be notified by the applicant within one (1) business day. No construction vehicles are to be stored within 100 feet of wetland resource areas, and no vehicle refueling, equipment lubrication, or maintenance is to be done within 100 feet of a resource area. 34 . In an effort to protect the public water supply, the landowner will record a permanent deed restriction on the wetland portion of this lot, which will prohibit any cuttings or disturbance of vegetation, soils or topography. AFTER CONSTRUCTION 35. No underground storage of fuel oils shall be allowed on any lot within one-hundred (100) feet of any wetland resource area. This Condition shall survive this Order of Conditions, and shall run with the title of the property. This condition is issued under the authority of the Town's Wetland Protection ByLaw. 36. Fertilizers utilized for landscaping and lawn care shall be organic and not greater than 5% nitrogen content, and shall be used in moderation. Pesticides and herbicides shall not be used within 100 feet of a wetland resource area. This condition is issued under the authority of the Town's Wetland Protection ByLaw. The landowner' will ;record a -permanent deed restriction to ensure compliance with this condition. 37. Upon completion of construction and grading, all disturbed areas located outside resource areas,shall be stabilized permanently against erosion. This shall be done either by loaming and seeding according to SCS standards. If the latter course is chosen, stabilization will be considered complete once vegetative cover has been achieved. #242-627 Lot 15 Carriage Chase 7 38. Upon completion of the project, the applicant shall submit a letter to the NACC from a Registered Professional Civil Engineer certifying compliance with this order of Conditions and the approved plans referenced herein (or approved revisions) . A letter from a qualified wetland scientist certifying compliance with local/state ,regulations is also required for the wetland replication/restoration area. A stamped "As-Built" topographic plan of all areas within the jurisdiction of the Wetlands Protection Act and Bylaw_shall 'be submitted when a Certificate of Compliance is requested. This plan will include: a. "As-Built" elevations and grades of all filled or altered wetlandresourceareas. b. Distances from structures to wetlands. c. A line showing the limit of work. "Work" includes; any disturbance of soils: or vegetation. 39 . The following special conditions shall survive the issuance of a Certificate of Compliance for this project: 33. Discharge or spillage of pollutants. 34. Conservation restriction. 35. Prohibition of storage of fuels underground. 36. Limitations on the use of fertilizers, herbicides and pesticides. t . J Issued By North Andover Conservation Commission Signature(s) �JdVA-AA This Order must be signed by a majority of the Conservation Commission. On this ZILd _..sday o} f 19 . before me personally appeared ��� Aid Z' , to me known to be the person described in and who executed the foregoing instrument and acknowledged that hershe executed the same as his/her free act and deed. otary Public Mycommission ex Cres The apoucant.the owner,any person aggrieved by this Order,any owner of land abutting the land upon which the proposed work is to be cone,or any ten residents of the City or town in Which Sucn land is located.are hereby notified of their right to recuest the Decanmenl of Environmental Protection to issue a Superseding Order,providing the reouest is made by certified mail or hand delivery 10 the Deoanment, with the appropriate filing fee and Fee Transmural Form as provided in 310 CMR 10.03(7),within ten days from the date of issuance of this Determination.A copy of the request shall at the same time be sent by certified mail or hand owivery to the Conservation Commission and the applicant If you wish to appeal this decision under the Town Bylaw, a complaint must be filed in Superior Court. Detach on dotted line and submit to the North-Andover Conservation o m prior to commencement of work. To North Andover Conservation 'Commission Issuing Autnorrty Please be advised that the Order ofConditiorts for the project at Lot l (}f21) Carriiagp,Chase 242— Deeds North F�gx and ��te Number 627 has been.recorded at the Registry of has been noted in the chain of title of the atiecteo property in accordance wan General Condition a on 19 It recorded land. ins instrument number which identifies tius saasacaon ra 11 regisiereo land. the document number which identifies this transaction 05 Acoucan, Sagna,ure 5•4A 310 CMR 10-99 DFP File Na 242-6,,? Form 9 (ro be provided by DEP) afro„o NORTH ANDOVER mak= Kenneth Willner commonwealth of Massachusetts Lot 15 Carriage Chase Enforcement Order Massachusetts Wetlands Protection Act, G.L. c. 131, 540 AND UNDER THE TOWN OF NORTH ANDOVER BYLAW, CHAPTER 3, SECTION 3.5 Prom NORTH ANDOVER CONSERVATION COMMISSION (NACC) issuing Authority To Kenneth P. Willner, PO Box 423, Hathorne MA 01937 To oward P. Speicher, Esi. , One Boston Place, Boston, MA 02108-4470 Date of. Issuance Apk Z. 1"6 Property lot/parcel number, address Lot 14 Carriage Chase Extent and type of activity: THIS ENFORCEMENT ORDER ALLOWS WORK TO BE CARRIED OUT UNDER AND EXPIRED ORDER OF CONDITIONS. THE APPLICANT:MUST ABID.E:BY ALL -THE CONDITIONS STATED_ IN ,THE_ORDER,OF CONDITIONSISSUED 12/10/92. ALL WORK MUST BE COMPLETELY BY SEPTEMBER 30, 1996. SEE "VIOLATIONS" ATTACHED HERETO_AND MADE A PART The NACC has determined that the activity describe HEREOF. above is in violation of the wetlands Protection Act, G.L. C. 131, $40, and the Regulations promulgated pursuant thereto, 310 CHR 10.00, because: ❑ said activity has been/is being conducted without a valid Order of Conditions. C] said activity has been/is being conducted in violation of an order of Conditions issued to dated , Pile number 242- condition number(s) other (specify) The NORTH ANDOVER CONSERVATION COMM. hereby orders the following: [� The property owner, his agents, permittees and all others shall immediately cease and desist from further activity affecting the wetland portion of this property. 0 wetland alterations resulting from said activity shall be corrected and the site returned to its original condition. 9'1 Effective 11/10/89 NORTH ANDOVER CONSERVATION Comission Issued by ` y the t and ❑ completed application forms and plans as required C N ERVATI N COMMISSION shall be filed with the (date), on or before and no further work shall be performed until a public hearing has been held and an order of Conditions has been issued to regulate said work. Application forme are available at: NACC Office, Town Hall Annex ❑ The property owner shall take every reasonable step to prevent further violations of the act. ❑ other (specify) Failure to comply with this order may constitute grounds for legal action, Massachusetts General Laws chapter 131, Section 40 provides: Whoever violates any provision of this section shall be punished by a fine of not more than twenty-five thousand dollars or by imprisonment for not more than two years or both. Each day or portion thereof of continuing violation shall constitute a separate offense. Questions regarding this Enforcement order should be directed to Michael D. Howard, Conservation Administrator Issued by NORTH ANDOVER CONSERVATION COMMISSION Signature(s)_ ' Chap rman.) (Ad n strator) i (Signature of delivery person or certified mail number) 9-2b 242-627 April 17, 1996 VIOLATIONS The applicant must immediately address the violations observed on Wednesday, April 17, 1996: - The DEP sign must be posted - Haybales must be replaced - Silt fence must be re-installed properly - 15 haybales must be stockpiled on the property. The applicant must submit a $100 check to the Town of North Andover for the Enforcement Order issued to allow work to be completed under an expired Order of Conditions pursuant to Section I, D2 (g) of the North Andover Wetlands Regulations. 3' (b) Notices of Intent submitted under both the Act and Bylaw shall be subject to the filing fees mandated by State Regulation. In addition, a fee of $25 . 00 will be charged under the Bylaw for the verification of a wetland resource area delineation. If at the time of filing, or after the Commission' s review, the wetland resource area delineation is found to be greater than 100 feet in length, an additional fee of $25. 00 shall be charged for each 100 linear feet of wetland line (or any portion therof. ) Adopted by the North Andover Conservation Commission March 15, -1995) (c) $50 . 00 shall be charged for each requested or required Modification or Amendment of an Order of Conditions. This shall not apply to Modifications or Amendments required by the Commission' s order of Conditions or required by another Town Board. (d) $50. 00 shall be charged for each request for a Certificate of Compliance request after the first such request has been denied, (e) $50 . 00 shall be charged for each request to extend an Order of Conditions. (f) $50 . 00 shall be charged for an Emergency Certification. This fee shall be applied to a Notice of Intent filing fee if required. (g) $100. 00 shall be 'charged for each Enforcement Order issued to allow work to be completed under an expired Order when the work is substantially complete and the applicant is seeking a Certificate of Compliance. 3. Waivers from Regulations Strict compliance with these Regulations may be waived when, in :he judgment of the Commission, such action is consistent with .he intent and purpose of the Bylaws and these Regulations. The applicant shall have the burden of proof that the granting of the waiver is consistent with the intent and purpose of the Bylaws ind these Regulations. The Commission shall act on the request and shall provide to the applicant, either by certified mail or land delivery, its written decision. See Appendix 2 for a waiver 2equest Form. aOfficers and Members i. Officers There shall be a Chair and Vice-Chair, who shall be elected by a majority vote of the eligible Commission members. The MALm& D'AGosTi r - DAviS, YCJEG' ' A PROFESSIONAL CORPORATION TOWN {1.L.E.R.K One Bos7'oN PLACE NORTH ANDOVER 0 G 8 p9 Julian J.D•Agostine Richard A.Nyden,Jr. BosTON,MAssACNusLnTs 02108-447AU C.Michael Maim Carol R.Cohen Harold R.Davis Howard P.Speicher (61 TELEPHONE; Frank P.Conrad Paul L.Feldman 7)367-2500 William F.Griffin,Jr. Kevin F.Long TE XCOP1[+&(617)523-6215 Paul E.Levenson Peter L.Koff Robert C.Gerrard Gary M.Feldman John G.Serino George A.Hewett John R.Berman Harold G.Clarke.Jr. Sidney J.Wartel Robert J.Diettrich Gary S.Matsko J.Gavin Cockfield Judith Ashton Ellen Donovan McCann John T.Lynch Thomas S.Fitzpatrick Grover S.Parnell,Jr. Robert E.Richards,Jr. Robert J.Galvin Jennifer L.WOinsky John D.Chambliss Lori H.Freedman August 8, 1995 Charles Trombly, Recorder Land Court Department 408 Old Courthouse Boston, MA 02108 Re: Kenneth P. Willner. et al v Town of North Andover Planning Board et al Misc. No. 219232 Dear Mr. Trombly: Enclosed please find for filing a Notice of Voluntary Dismissal in the above entitled matter. Thank you for your attention to this matter. Very truly yours, Howard P. Speicher i Enclosure CC: Kenneth P. Willner Joel B. Bard, Esq. J:%PEfCHERXWILLNERICLERKLTa DAvis, MALM& D'AGonm A PROFESSIONAL CORPORATION ONE BOSTON PLACE BosToN,MAssAcHusErrs 02108-4470 Julian J.D•Agostine Richard A.Nylen,Jr. C.Michael Maim Carol R.Cohen Harold R.Davis Howard P.Speicher TELEPHON& 61 361-2500 Frank P.Conrad Paul L.Feldman William F.Griffin,Jr. Kevin F.Long TWY=PWu(617)523-6215 Paul E.Levenson Peter L.Koff Robert C.Gerrard Gary M.Feldman John G.Serino George A.Hewett John R.Berman Harold G.Clarke,Jr. Sidney J.Wartei Robert J.Diettrich Gary S.Matsko J.Gavin Cockfield Judith Ashton Ellen Donovan McCann John T.Lynch Thomas S.Fitzpatrick Grover S.Parnell,Jr. Robert E.Richards,Jr. Robert J.Galvin Jennifer L.Wilinsky John D.Chambliss Lori H.Freedman August 8, 1995 Charles Trombly, Recorder Land Court Department 408 Old Courthouse Boston, MA 02108 Re : Kenneth P. Willner, et al. v. Town of North Andover Planning Board, et al - Misc. No. 219232 Dear Mr. Trombly: Enclosed please find for filing a Notice of Voluntary Dismissal in the above entitled matter. Thank you for your attention to this matter. Very truly yours, 01 Howard P. Speicher 1 Enclosure CC : Kenneth P. Willner Joel B. Bard, Esq. J:iSPEICHEMW ILLNERICLEPK LT8 t+ Y t t COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. G IJ G COURT MISC. NO. 219232 KENNETH P. WILLNER and JACQUELINE D. BEST-WILLNER, Plaintiffs V. RICHARD A. NARDELLA, JOHN NOTICE OF VOLUNTARY DISMISSAL SIMONS, JOSEPH MAHONEY, ALISON LESCARBEAU and RICHARD ROWEN, as they are the members of the PLANNING BOARD OF THE TOWN OF NORTH ANDOVER, Defendants The plaintiffs hereby voluntarily dismiss this action pursuant to Rule 41 (a) (1) (i) , Mass. R. Civ. P. , no answer having been served. KENNETH P. WILLNER and JACQUELINE D. BEST-WILLNER, By their attorney, r Howard P. Sp cher/BBO#47438 DAVIS, MALM & D'AGOSTINE, P.C. One Boston Place j Boston, MA 02108 (617) 367-2500 Dated: August 8, 1995 I NEREW,CERTIFY THAT ACOPV OF TMEABOVE DOCUIi M JASPEICHER\WILLNEROISMISS.Nar unm TM9 ATMRNFLnF RECORD FOR t COMMONWEALTH OF MASSACHUSETTS ESSEX, ss . LAND COURT MISC. NO. 219232 KENNETH P. WILLNER and JACQUELINE D. BEST-WILLNER, Plaintiffs V. RICHARD A. NARDELLA, JOHN NOTICE OF VOLUNTARY DISMISSAL SIMONS, JOSEPH MAHONEY, ALISON LESCARBEAU and RICHARD ROWEN, as they are the members of the PLANNING BOARD OF THE TOWN OF NORTH ANDOVER, Defendants The plaintiffs hereby voluntarily dismiss this action pursuant to Rule 41 (a) (1) (i) , Mass. R. Civ. P. , no answer having been served. KENNETH P. WILLNER and JACQUELINE D. BEST-WILLNER, By their attorney, r Howard P. Sp cher/BBO#47438 DAVIS, MALM & D'AGOSTINE, P.C. One Boston Place j Boston, MA 02108 (617) 367-2500 Dated: August 8, 1995 1i 0gWCERTIFYTHATACOPYOFTHEABODE000 MWT J:WEICHER\WILLNEROISMISS.NOT S HE ATTORNE FR RCF a. s , 3• • E C E '# 0 f•. ( .: JOYCE RAZ;_.HAW Any appeal shall be filed ';mss••„•. TOW? CLERK within (20) days after the '*+ �l;;?•' NORTH ANDOVER date of filing of this NOF NORTH ANDOVERotice in the OfficeTOWN JULr3AS9ACHLTSETTJULZ411 24 � of the Town Ciera. BOARD OF APPEALS NOTICE OF DECISION Date 7.24 . 95 Petition No. 027-95 Date of Hearing June 13 July 11, 1995 Pe'-ition of: Kenneth & Jacqueline Wilner Premises :f ected Lot 15 Carriage Chase Referring to the above petition for a variation from the requirements o Section 4. 133, para, (3) (c) of the 1984 Zoning Bylaw so as L to permit relief of 5 feet for purposes of the construction of -a- new house in the 25 foot no cut zone to a wetland resource area in the Watershed District, The applicants also requested a variation from Section 7, para. 7 .3 and Table 2 of the Zoning Bylaw so as to permit relief of 11 feet from the left side _setback requirement of 30 feet and relief of 4 feet from the front setback requirement of 30 feet . After a cublic hearing given on the above date , the Board of Appea=s voted to GRANT the Variances and hereby author-ze the Building Inspector to issue a permit to: Kenneth & Jacqueline Wilner for t':-.e construction of the above work, ,99ffXXjXX iXXXXXXN1XXX'XXiq cXXkkKkxx-AXX The Board finds that the petitioner has satisfied the provisions of Section 10, para. 10. 4 of the Zoning Bylaw and that the granting of these variances will not adversely affect the neighborhood or derogate from the the intent and purpose of the Zoning Bylaw. Board of Appeals , Joseph Faris John Pallone Robert Ford Ellen McIntyre -W J4 r £ TOWS OL }� kNDOyER Town of North C'Sover= , 40RTH ff tt,' ys O "'20 ,6 ti MCECOMMUNITY DEVELOP NT AND SERVICES A n 146 Main Street KENNETH R.MAHONY North Andover,Massachusetts 01845C 9SSAHUS�t Director (508)688-9533 Kenneth & Jacqueline Wilner Decision 55 Union Street Petition # 027-95 Boston, MA 02108 The Board of Appeals held a regular meeting on June 13, 1995 and continued until July 11, 1995 upon the appeal of Kenneth & Jacqueline Wilner requesting a variation of Section 4.133, para. (3) (c) of the 1984 Zoning Bylaw so as to permit relief of 5 feet for purposes of the construction of a new house in the 25 foot no cut zone to a wetland resource area in the Watershed District. The applicants also requested a variation from Section 7, para 7.3 and table 2 of the Zoning Bylaw so as to permit relief of 11 feet from the left side setback requirement of 30 feet and relief of 4 feet from the front setback requirement of 30 feet for a proposed house to be located at Lot 15 Carriage Chase Road. The following members were present and voting: Robert Ford, Joseph Faris, Ellen McIntyre and John Pallone. The public hearing was advertised in the North Andover Citizen on May 24 and May 31, 1995 and all abutters were notified by regular mail. Motion by Joseph Faris to Grant the Variances as requested, seconded by Ellen McIntyre. Vote: unanimous. Voting in favor: Robert Ford, Joseph Faris, Ellen McIntyre, and John Pallone. The Board finds that the petitioner has satisfied the provisions of Section 10, para. 10.4 of the Zoning Bylaw and that the granting of these variances will not adversely affect the neighborhood or derogate from the intent and purpose of the Zoning Bylaw. Board of Appeals, Joseph Faris Dated: July 24, 1995 John Pallone Robert Ford Ellen McIntyre BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 6$8-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D.Robert Nicetta Michael Howard Sandra Starr KAWeen Bradley Colwell IOYCI 11A AW TOWN OF NORTH AND OVE TOWN CLERK H A S S A C H U S E T T SORTH ANDOVER Any appeal shall be, filedjUN ;-7 P ` MORTN t 1,y within (20) days after the oro•4•`�0 l''° ��� F 9 date of filing of this [notice • 10 in the Office of the Town �, �,.....•��ty Clerk. ss4CH NOTICE OF DECISION Date. June 9,, .1995 . . . . . . . . . . . . . . Date of Hearing • June. 6,. 1995. Kenneth P. Willner and Jacqueline Best-Willner Petitionof . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Lot 15 Premises affected . . . . .. .. . . .5) •Carriage•Chase Referring to the above petition for a special permit from the requirements North Andover Zoning Bylaw Section 133 Paragraph (3) (d) as in effect of the . , . . . . . , in 1984. so as to .411QW.the.GQUStxuCtiQn.of .a.single .familg .dwell ing and -r-elated improvements within the Watershed Protection District. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . After a public hearing given on the above date, the Planning Board voted conditionally SPECIAL PERMIT toaQPrTvq . . . . . . . .the . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . CC: Director of Public works based upon the following conditions: Building Inspector Natural Resource/Land Use Planner Health Sanitarian qr Assessors Signed�444& Police Chief rman Fire Chief Joseph. . . . . . . .. . . . .. .. . . . . • . . . . Applicant Richard Rowen. ViceChairman Engineer • • • . . . • File Interested Parties Alison Lescarbeau, Clerk Richard A. Nardella John Simons •• . • • • . •• •••• . • • . . .• Town of North Andover t AoRrh OFFICE OF 3?C`,,to le,b��0. COMMUNITY DEVELOPMENT AND SERVICES p 146 Main Street KENNETH R MAHONY North Andover,Massachusetts 01845SACN CH 4SUS�� Director (508)688-9533 June 9, 1995 Ms. Joyce Bradshaw Town Clerk 120 Main Street North Andover, MA 01845 Re: Special Permit - Watershed Protection District Lot 15 (#15) Carriage Chase Dear Ms. Bradshaw: The North Andover Planning Board held a public hearing on Tuesday evening, June 6, 1995 in the Senior Center behind the Town Building, upon the application of Kenneth P. Willner and Jacqueline Best-Willner, 55 Union Street, Boston, MA 02108 requesting a Special Permit under Section 133, Paragraph (3) (d) of the Zoning By-law as in effect in 1984. The legal notice was properly advertised in the North Andover Citizen on May 17 and May 24, 1995 and all parties of interest were duly notified. The following members were present: Joseph Mahoney, Chairman, Richard Rowen, Vice Chairman, Alison Lescarbeau, Clerk, Richard Nardella and Alberto Angles, Associate Member. The petitioner was requesting a special permit to allow the construction of a single family dwelling and related improvements in the Watershed Protection District. Ms. Lescarbeau read the legal notice to open the public hearing. Atty. Howard Speicher was present representing the Willner's. Ms. Colwell stated that there was concern over the drainage system and where the water will flow. The applicant added a drainage system to handle stormwater. Awaiting certification that the plan addresses all issues regarding quality of water entering the lake. On a motion by Ms. Lescarbeau, seconded by Mr. Rowen, the Board voted unanimously to close the public hearing. BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Puffin D.Robert Niceda Michael Howard Sandra Starr Kathleen Bradley Colwell At the same meeting, on a motion by Mr. Rowen, seconded by Ms. Lescarbeau, the Board voted unanimously to approve the special permit as written and amended. Attached are those conditions. Sincerely, North Andover Planning Board 44zt4�YL R) oseph- Mahoney, airman Lot 15 Carriage Chase special Permit rmit - Watershed Protection District The Planning Board grants this special permit under Section 133, Paragraph (3) (d) of the Zoning Bylaw in effect in 1984, for the purpose of allowing construction of a dwelling and related improvements in the Watershed Protection District, on land known as Lot 15 Carriage Chase, owned by Kenneth P. Wilner and Jacqueline D. Best, 55 Union Street, Boston, MA 02108. The granting of . this special permit is in accordance with the settlement of Massachusetts Land Court Misc. No. 205479. FINDINGS OF FACT: 1. The lot was created as part of the Marbleridge Subdivision. The preliminary subdivision plan was filed in the Spring of 1984. The preliminary plan was followed by a definitive plan which was approved by the Planning Board on January 8, 1985. The plans were endorsed on March 13, 1985. As such, the property herein is considered subject to the North Andover Zoning Bylaw as it was in effect at the time of submission of the preliminary, subdivision plan in May of 1984 for eight years from endorsement of the plan on March 13, 1985 as extended by the period of any litigation involving the right to develop the property. 2. The property was the subject of litigation with the North Andover Conservation Commission which commenced prior to March 13, 1993 and was resolved favorably to the plaintiffs by a settlement. Therefore the property herein is considered subject to the North Andover Zoning Bylaw in effect in May of 1984. 3. Under the 1984 North Andover Zoning Bylaw, no construction may occur one hundred (100) feet horizontally from the edge of all tributaries, except by Special Permit issued by the Planning Board. Upon reaching the above findings, the Planning Board approves this Special Permit for the construction of a single family home within one hundred (100) feet horizontally from the edge of a tributary based upon the following conditions: SPECIAL CONDITIONS: 1. This decision must be filed with the North Essex Registry of Deeds. The following information is included as part of this decision: Plan of Land in No. Andover, MA Scale: 1" = 20' 1 . k Hayes Engineering, Inc. 603 Salem Street Wakefield, Mass 01880 August 18, 1993; last revision date 5/1/95 An changes made to these plans shall be Approved b the Town Y g P PP Y Planner. Any changes deemed substantial by the Town Planner will require a public hearing and modification by the Planning Board. 2. Prior to any work on site: a. The applicant must submit to the Planning Department written certification by a Registered Professional Engineer, or, other scientist educated in and possessing extensive experience in the science of hydrology and hydrogeology, stating that no significant degradation of the quality or quantity of water in or entering Lake Cochichewick will occur as a result of the development of this lot. b. The applicant must submit a statement that there is no reasonable alternative location outside the one hundred (100) foot no-construction zone for the structure. C. A performance guarantee of two thousand ($2,000) dollars in the form of a check made out to the Town of North Andover must be posted to insure that construction will take place in accordance with the plans and the conditions of this decision. This will also insure that an as-built plan will be submitted. d. All erosion control measures as shown on the plan including hay bales and silt fence must be in place and reviewed by the Town Planner. All work on the site will be monitored by the Planning Office and/or the Division of Public Works on a regular basis. e. The site shall have received all necessary permits and approvals from the North Andover Conservation Commission, Board of Health, the Zoning Board of Appeals, and the Department of Public Works 3. Prior to FORM U verification (building permit issuance) : a. All plans for the tie-in to the municipal sewer must be reviewed and approved by the Division of Public Works. 4. Prior to Planning Board verification of the Certificate of Occupancy: a. The roof drains and stone trench must be constructed as 2 . k shown on the plan. b. The stone masonry retaining wall must be constructed 'as shown on the plan and reviewed by the Town Planner. 5. Prior to release of the Performance Bond: a. The applicant shall submit a certification by either a Registered Professional Land Surveyor or Practicing Engineer that the site has been constructed in accordance with the approved plan. b. The Planning Board must by a majority vote make a finding that the site is in conformance with the approved plan and that any unforeseen circumstances have been adequately addressed by the applicant. 6. Upon conveyance of the property by the current owner, the deed must contain language restricting the area of maintained lawn to those areas outside of the proposed stone masonry wall as shown on the plan. Areas between the stone masonry wall and the wetland resource area are to remain in their natural state. 7. Fertilizers utilized for landscaping and lawn care shall be organic and not greater than 5% nitrogen content, and shall be used in moderation. Pesticides and herbicides shall not be used within 100 feet of a wetland resource area. 8. In no instance shall the applicant's proposed construction be allowed to further impact the site than as proposed on the plan referenced in Condition # 1. 9. No open burning shall be done except as is permitted during burning season under the Fire Department regulations. 10. The Contractor shall contact Dig Safe at least 72 hours prior to commencing excavation. 11. The provisions of this conditional approval shall apply to and be binding upon the applicant, it's employees and all successors and assigns in interest or control. 12. This permit shall be deemed to have lapsed after a two (2) year period from the date on which the Special Permit was granted unless substantial use or construction has commenced. Therefore the permit will expire on :7'Unc. /,�, /997 cc. Director of Public Works Building Inspector Health Agent Assessor 3 . Conservation Administrator Police Officer Fire Chief Applicant Engineer File Carriage.settle 4 of"O"TH; ~" OFFICES OF: a� m Town of 120 Main Street North Andover, APPEALS .off::-. NORTH ANDOVER Massachusetts o 1845 BUILDING CONSERVATION48a"O"Sys DIVISION OF (617)685-4775 HEALTH PLANNING PLANNING & COMMUNITY DEVELOPMENT KAREN H.P. NELSON, DIRECTOR MODIFICATION TO ORDER OF CONDITIONS File No. 242-627 Project: Lot 15 Carriage Chase T6 NORTH ANDOVER CONSERVATION COMMISSION at its meeting on „ t December 15, 1993 , agreed to accept a change to Condition #13 requiring X. a 71-1� no-disturbance zone in lieu e of the original nal Irl' no-disturbance zone, as a Modification to the Order of Condition issued in file #242- 627 dated December 10, 1992 and recorded in Book # and Page # Issue by the NORTH ANDOVER CONSERVATION COW ISSION F On this day of 19 Q q , before me personally appeared , to me known to be the person described in and ho executed the foregoing instrument and acknowledged that he/she executed the same as his/her free act and deed. ,.My Commission Expires Jun®20,1997, Notary Pub is My commission expiies A receipt from the Registry of Deeds must be submitted t--a Lhis office showing that this Modification has been recorded and referenced to the Book and Page numbers where the original Order #242- 627 was recorded. Town of North Andover , NORTN , OFFICE OF 3?0t,,,.o ,,16 0Z. COMMUNITY DEVELOPMENT AND SERVICES ° 4L ♦ 9 i 146 Main Street 4Q.,;,o .•`�y KENNETH R.MAHONY North Andover,Massachusetts 01845 "SSAW' Director (508)688-9533 MODIFICATION TO ` ' ORDER OF CONDITIONS 242-627 s File No. co~x Projects Lot 15 Carriage Chase The NORTH ANDOVER CONSERVATION COMMISSION at its meeting on June 21, 1995 , agreed to accept the following: The site is to be approved by the Natural Resource/Land Use Planner; Perimeter Drain Only; no connection to house or pool as a Modification to the Order of Conditions issued in file # 242- 627 dated 12-10-92 Amended 10-20-94 and recorded in Book # and Page # is ed by ,th H ANDOVER CONSERVATION COMMISSION: W i G Aim On this 21st day of June 19 95 before me personally appeared - Joseph Lynch , to me known to be the person described in and who executed the foregoing instrument and acknowledged that he/she executed the same as his/her free act and deed. March 22, 2002 Notary Public onna ae DIZ54ta My Commission Expires A receipt from the Registry of Deeds must be submitted to this office showing that this Modification has been recorded and referenced to the Book and Page numbers where the original Order 242- 677 was recorded. BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D.Robert Nicetta Michael Howard Sandra Starr Kathleen Bradley Colwell fit: Joh c r rt k AW 310 CMA 10.94 TOW'( NORTH b, c {.`E`ER Form 5 t ? tw 242-627 :r. DICT ZO 18 (Facem— -aoEm Commonweaffh ,-7owr,, North Andover of Massacnusetts Kenneth Wllner **AMENDED** Lot 15 Carriage Chase Order of Conditions Massachusetts Wetlands Protection Act C.L. c. 131, §40 and under the Town of North Andover's Wetlands Bylaw, Chapter 178 From North Andover Conservation Commission Te Kenneth P. Willner Scott Follansbee (Name of Applicant) (Name of property owners 3 Bellehaven Dr. Acoreas Andover, MA 01810 Address This Orcer is issued and delivered as follows: C2 by hand delivery to apoiicant or representative an (date) by certifies mail. return receipt requested on OCTOBER 20, 1994 Z115 797 997 (pates This project is located at Lot 15 (#21) Carriage Chase The procerty is recorded at the Registryof Deeds, North Essex Boo4 3377 Page 261 Cenricate (if re_sstered)- -- - - The Notice of Intent for trtts protect was files on September 25, 1992 (sate) The eublic nearing was closed on November 18, 1992 (pate) Findinas The NACC has reviewec the above•referertced Nonce of Intent anc;.cans ana nas nets a-uoiicneanng on;ne c:o;e.z. Sasso on the tn:orrrauon avanao!e to the NACC at this time. the NACC has ce;ertmneo that the area on wntcn the orcoosec worts is to be cone is significant to the toifowing interests in amcroance wan the Pfesutr.=uwls of Significance set form ►n the re-uta:nons for each Area Suoiect to Pmtecton Uncer the Act tC:ecx as acoroortate): Ch.178( Prevention of erosion and sedimentation Pubiic water suaaiy Q Flood comroi C2 Land containing shellfish Private water supply Q Storm damage orevention Fisheries Ground water supply 110 Prevention of pofiuuon Protection of wildlife habi= Ch.17 t n C 7 io c s�_� W1 ldlif a State Share $ Total Fling s=ee ..ubmnied Citvs?own Share $137.50 ('l4 fee in excess c:==i Tota! Retunc Due S Cityfrown Portion 5 State Portion 5 ('/z total) (1/2 total) S #242-627 Lot 15 Carriage Chase 2 ** This amended Order of Conditions incorporates the December 15, 1993 vote of the Conservation Commission regarding amendments to Conditions 8 and 13. ** Therefore, the North Andover Conservation Commission (hereafter the "NACC") hereby finds that the following conditions are necessary, in accordance with the Performance Standards set forth in the State Regulations, the local ByLaw and Regulations, to protect those interests noted above. The NACC orders that all work shall be performed in accordance with said conditions and with the Notice of Intent referenced above. To the extent that the following conditions modify or differ from the plans, specifications or other proposals submitted with the Notice of Intent, the conditions shall control. GENERAL CONDITIONS 1. Failure to comply with all conditions stated herein, and with all related statutes and other regulatory measures, shall be deemed cause to revoke or modify this Order. 2 . This Order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private property or invasion of private rights. 3 . This Order does not relieve the permittee or any other person of the necessity of complying with all other applicable federal, state or local statutes, ordinances, by-laws or regulations. 4 . The work authorized hereunder shall be completed within three years from the date of this Order. 5. This Order may be extended by the issuing authority for one or more periods of up to one year each upon application to the issuing authority at least 30 days prior to the expiration date of the Order. 6. Where the Department of Environmental Protection is requested to make a determination and to issue a Superseding Order, the Conservation Commission shall be a party to all agency proceedings and hearings before the Department. 7 . The proposed work includes construction of residence and appurtenances. 8 . The work shall conform to the following (except as noted in the remainder of this document where revisions may be required) : (a) Notice of Intent filed by Thomas E. Neve Assoc. , Inc. (b) Plans prepared by Thomas E. Neve, September 17, 1992, amended by Hayes Engineering, Inc. , plan dated August 18, 1993, revised December. 13, 1993, December 15, 1993 , December 17 , 1993 and December 28, 1993 . #242-627 Lot 15 Carriage Chase 3 9. The following wetland resource areas are affected by the proposed work: bordering vegetated wetland. The site is within the watershed of Lake Cochichewick and therefore deemed a vital resource under the Town Bylaws. These resource areas are significant to the interests of the Act and Town Bylaw as noted above. These resource areas are also significant to the recreational and wildlife interests of the Bylaw. The applicant has not attempted to overcome the presumption of significance of these resource areas to the identified interests. 10. The NACC agrees with the applicant's delineation of the wetland resource areas on the site as shown on the plans dated revised September 17, 1992 and November 16, 1992. 11. Issuance of these Conditions does not in any way imply or certify that the site or downstream areas will not be subject to flooding or storm damage. 12 . The conditions of this decision shall apply to, and be binding upon, the applicant, owner, its employees and all successors and assigns in interest or control. 13 . The NACC finds that the intensive use of the upland areas and buffer zone proposed on this site to construct a residence and appurtenances will cause further alteration of the wetland resource areas. In order to prevent any alteration of wetland resource areas beyond those proposed in the Notice of Intent and approved herein, a twenty (20) foot no-disturbance zone and a thirty-two (32) foot no-construction zone shall be established from the edge of the adjacent wetlands. No disturbance of existing grade, soils or vegetation is permitted in the no- disturbance zone. (See Appendix 5 of the local Regulations) . PRIOR TO CONSTRUCTION 14. No work shall be undertaken until all administrative appeal periods from this Order have elapsed or, if such an appeal has been filed, until all proceedings before the Department or Court have been completed, 15. This Order shall be recorded by the applicant at the Registry of Deeds immediately after the expiration of all appeal periods. No work shall be undertaken until the Final Order has been recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land upon which the proposed work is to be done.,* In the case of registered land, the Final Order shall also be noted on the Land Court Certificate of Title #242-627 Lot 15 Carriage Chase 4 of the owner of the land upon which the proposed work is to be done. The recording information shall be submitted to the North Andover Conservation Commission on the form at the end of this Order prior to commencement of the work. 16. A sign shall be displayed at the site not less than two square feet or more than three square feet in size bearing the words, "Massachusetts Department of Environmental Protection, File Number 242-62711 . 17 . Any changes in the submitted plans caused by the applicant, another Board's decision or resulting from this Order of Conditions must be submitted to the NACC for approval prior to implementation. If the NACC finds said changes to be significant, the NACC will call for another public hearing (at the expense of the , applicant) . Within 21 days of the close of said public hearing the NACC will issue an amended or new Order of Conditions. Any errors found in the plans or information submitted by the applicant shall be considered as changes. The proposed project may be still under review by other local or state boards or agencies. This may result in changes to the project plans or wetland impacts. If any such changes occur a revised plan and an explanation of the revisions shall be submitted to the NACC for review and approval prior to the start of construction. No work shall begin on a project until written approval has been granted by the NACC. 18. The applicant shall contact the Conservation Office prior to site preparation or construction and shall arrange an on-site conference with an NACC representative, the contractor and the applicant to ensure that all of the Conditions of this Order are understood. This Order also shall be made a part of the contractor's written contract. The applicant or contractor shall notify the NACC in writing of the identity of the on-site construction supervisor hired to coordinate construction and to ensure compliance with this Order. 19. The applicant shall submit a construction schedule/sequence to the NACC detailing the prdposed sequence of work on site to complete this project. 20. Wetland flagging shall be checked prior to start of construction and shall be re-established where missing so that erosion control measures can be properly placed and wetland impacts can be monitored. 21. A row of staked hay bales backed by a siltation fence shall be placed between all construction areas and wetlands. The erosion control barrier will be properly installed and placed on the plan to be filed and shall be inspected and approved by the NACC prior to the start of construction and shall remain intact until all disturbed areas have been permanently stabilized to #242-627 Lot 15 Carriage Chase 5 prevent erosion. All erosion prevention and sedimentation protection measures found necessary during construction shall be implemented p nted at the direction of the NACC. 22 . The applicant shall have on hand at the start of any soil disturbance, removal or stockpiling, a minimum of. thirty (30) hay bales and sufficient stakes for staking these bales (or an equivalent amount of silt fence) . Said bales shall be used only for the control of emergency erosion problems, and shall not be used for the normal control of erosion. 23 . A -proper bond or a deposit of money running to the Town of North Andover shall be provided in the amount of $3, 000.00 which shall be in all respects satisfactory to Town Counsel, Town Treasurer, and the NACC, and shall be posted with the North Andover Town Treasurer before commencement of work. Said bond or deposit of money shall be conditioned on the completion of all conditions hereof, shall be signed by a party or parties satisfactory to the NACC, and Town Counsel, and shall be released after completion of the project, provided that provision, satisfactory to the NACC, has been made for performance of any conditions which are of continuing nature. The applicant may propose a bond release schedule keyed to completion of specific portions of the project for the NACC's review and approval. This condition is issued under the authority of the local Bylaw. DURING CONSTRUCTION 24 . Upon beginning work, the applicant shall submit written progress reports every one (1) month detailing what work has been done in or near resource areas, and what work is anticipated to be done over the next period. This will update the construction sequence. 25. Any fill used in connection with this project shall be clean fill, containing no trash, refuse rubbish or debris, including but not limited to lumber, bricks, plaster, wire, lath, paper, cardboard, pipe, tires, ashes, refrigerators, motor vehicles or parts of any of the foregoing. 26. No exposed area shall remain unfinished for more than thirty (30) days, unless approved by the NACC. 27 . No regrading in the buffer zone shall have a slope steeper than 2 : 1 (horizontal:vertical) . Slopes of steeper grade shall be rip-rapped to provide permanent stabilization. 28. There shall be no stockpiling of soil or other materials A g within twenty-five (25) feet of any resource area. 29 . Washings from concrete trucks, or surplus concrete, shall not #242-627 Lot 15 Carriage Chase 6 be directed to, any drainage system or wetland resource area. 30. All waste generated by, or associated with, the construction activity shall be contained within the construction area, and away from any wetland resource area. There shall be no burying of spent construction materials or disposal of waste on the site by any other means. The applicant shall maintain dumpsters (or other suitable means) at the site for the storage and removal of such spent construction materials off-site. 31. Accepted engineering and construction standards and procedures shall be followed in the _completion of the project. 32 . Members of the NACC or its agent shall have the right to enter upon and inspect the premises to evaluate and/or effect compliance with this Order of Conditions. The NACC reserves the right to require, following field inspection, additional information or resource protection measures. 33 . During and after work on this project, there shall be no discharge or spillage of fuel, or other pollutants into any wetland resource area. If there is a spill or discharge of any pollutant during any phase of construction the NACC shall be notified by the applicant within one (1) business day. No construction vehicles are to be stored within 100 feet of wetland resource areas, and no vehicle refueling, equipment lubrication, or maintenance is to be done within 100 feet of a resource area. 34. In an effort to protect the public water supply, the landowner will record a permanent deed restriction on the wetland portion of this lot, which will prohibit any cuttings or disturbance of vegetation, soils or topography. AFTER CONSTRUCTION 35. No underground storage of fuel oils shall be allowed on any lot within one-hundred (100) feet of any wetland resource area. This Condition shall survive this Order of Conditions, and shall run with the title of the property. This condition is issued under the authority of the Town's Wetland Protection ByLaw. 36. Fertilizers utilized for landscaping and lawn care shall be organic and not greater than 5% nitrogen content, and shall be used in moderation. Pesticides and herbicides shall not be used within 100 feet of a wetland resource area. This condition is issued under the authority of the Town's Wetland Protection Bylaw. The landowner will record a permanent deed restriction to ensure compliance with this condition. 37. Upon completion of construction and grading, all disturbed areas located outside resource areas shall be stabilized #242-627 Lot 15 Carriage Chase 7 permanently against erosion. This shall be done either by loaming and seeding according to SCS standards. If the latter course is chosen, stabilization will beconsideredcomplete once vegetative cover has been achieved. 38. Upon completion of the project, the applicant shall submit a letter to the NACC from a Registered Professional Civil Engineer certifying compliance with this Order of Conditions and the approved plans referenced herein (or approved revisions) . A letter from a qualified wetland scientist certifying compliance with local/state regulations is also required for the wetland replication/restoration area. A stamped "As-Built"topographic plan of all areas within the jurisdiction of the Wetlands Protection Act and Bylaw shall be submitted when a Certificate of Compliance is requested. This plan will include: a. "As-Built" elevations and grades of all filled or altered wetland resource areas. b. Distances from structures to wetlands. c. A line showing the limit of work. "Work" includes any disturbance of soils or vegetation. 39. The following special conditions shall survive the issuance of a Certificate of Compliance for this project: 33. Discharge or spillage of pollutants. 34. Conservation restriction. 35. Prohibition of storage of fuels underground. 36. Limitations on the use of fertilizers, herbicides and pesticides. ** This amended Order of Conditions incorporates the December 15, 1993 vote of the Conservation Commission regarding amendments to Conditions 8 and 13 ** 242-627 Lot 15 (421) CarriageChase i Issued By North 4doveg Conservation Commission Signature(s)— This Order must be signed by a majority of the Conservation Commission. On this 19TH day of OCTOBER 19 94 before me personally appeared George Reich . to me known to be the person described in and who executed the foregoing instrument and acknowledged thathershe executed the same as his/iter free act and deed. Notary Public My commission expires The apolican-,.irie owner,any person aggrieved by this Order,any owner of land abutting the land upon which the oromseo work is to be cone,or any ten residents of the city or town in which such land is located,are hereby notified of their right to request the Department of Environmental Protection to issue a Superseding Order, providing the request is made by certified mail or hand delivery to the Department. with the appropriate filing tee and Fee Transmittal Form as provided in 310 CMR 10.03(7),within ten days from the date of issuance of this Determination.A copy of the request shall at the same time be sent by Certified mail or hand delivery to the Conservation Commission and the applicant. If you wish to appeal this decision under the Town Bylaw, a complaint must be filed in Superior Court. Detach on dotted line and submit to the North Andover Conservation Comm. prior to commencement of work. .................................................................................................................................................................................................................. MA 01845 To North Andover Conservation Commission, 120 Main St. , No. Andover IssungAulnority Please be advised that the Order of Conditions for the project at Lot 15 (4421) Carriage Chase ;r,le Numoer 242–627 has been recorded at the Registy of Deeds, North Essex and has been noted in the chain of title of the atfectec prooerty in accordance with General Condition 6 on 1 9 if recorded land. the iRstTument number Which acenciies this transacttorl is if registered land, the document number which identities this trwsaction is Sicnawre %+coucant 5-4A r; DAvis, MALM& WAGosTnvE Gi R A PROFESSIONAL CORPORATION 401-0,A. ONE BOSTON PLACE ry{{( _ ; BOSTON,MASSACHUSETTS 02108-4470 a7 UK �j` 55 Julian J.D,Agostine Carol R.Cohen Uts C.Michael Malm Howard P.Speicher Harold R.Davis Paul L.Feldman TELEPHONE: 617 367-2500 Frank P.Conrad Kevin F.Long ( ) William F.Griffin,Jr. Peter L.Koff TELECOPItitt:(617)523-6215 Paul E.Levenson Gary M.Feldman Robert C.Gerrard George A.Hewett John G.Serino Harold G.Clarke,Jr. John R.Berman Robert J.Diettrich Sidney J.Wartel J.Gavin Cockfield Gary S.Matsko Ellen Donovan McCann Judith Ashton Thomas S.Fitzpatrick John T.Lynch Robert E.Richards,Jr, Grover S.Parnell,Jr. Jennifer L.Wilinsky Robert J.Galvin Lori H.Freedman John D.Chambliss June 30, 1995 HAND DELIVERED Ms. Joyce Bradshaw, Town Clerk Town Hall 120 Main Street North Andover, MA 01845 Re: Kenneth P. Willner, et al. v. Town of North Andover Planning Board Dear Ms. Bradshaw: You are hereby notified pursuant to G.L.c. 40A, Section 17 that the plaintiffs in the above-referenced action yesterday filed an action in the Land Court appealing the decision of the North Andover Planning Board, filed with you on June 12, 1995, granting with conditions a special permit with respect to the plaintiffs' property at Lot 15, Carriage Chase, North Andover. A copy of the complaint is attached hereto. Please acknowledge the date of the receipt of this letter on the copy provided as well as on the original and give the copy to the person delivering this letter. Very truly yours, Howard P. Speicher Enclosures cc: Kenneth P. Willner Received: By: '• M: ,,,.ter. RECEIVED s.. taas ,JOYCE BRADSHAW Any appeal shall be filed •�s....,.`� TOWN CLERK within (20) days after the ''.9 V NORTH ANDOVER date of riling of this TOWN OF NORTH ANDOVER Notice in the Office MASSACHUSETTS JCIL 14 II 24A M, of the -Lown, Clerk. BOARD OF APPEALS NOTICE OF DECISION Date 7.24. 95 Petition No. 027-95 Date of Hearing June 13 July 11, 1995 Pet tion of Kenneth & Jacqueline Wilner Premises ?fffected Lot 15 Carriage Chase Referri^g to the above petition for a variation from the require -eats oZ Section 4. 133, para, (3) (c) of the 1984 Zoning Bylaw so as to permit relief of 5 feet for purposes of the construction of -a- new house in the 25 foot no cut zone to a wetland resource area in the Watershed District. The applicants also requested a variatio from Section 7, para. 7. 3 and Table 2 of the Zoning Bylaw so as to permit relief of 11 feet from the left side setback requirement of 30 feet and relief of 4 feet from the front setback requirement of 30 feet . Alfter a public hearing given on the above date, the Board of Aw=e=- =s votes _o GRANT the VariancAs and hereby aut cr_ze the Building Inspector to issue a permit to: Kenneth & Jacaueling Wilner for t^:e construction of the above work, ffXXX_ X €XXXXXXXXXXX'XXX cXX��XXXX=XXX The Board finds that the petitioner has satisfied the provisions of Section 10, para. 10. 4 of the Zoning Bylaw and that the granting of the: variances will not adversely affect the neighborhood or derogate from the the intent and purpose of the Zoning Bylaw. Board of Appeals , Joseph Faris John Pallone Robert Ford Ellen McIntyre L\t;,�LitLi JOYCE BSA^ W - TOWS CLERK tt RTsovery ANDOVER Town of North rnNORTN OFFI('.E t 24 �r^ ?Oystap Ie`'�OO `� 3 c COMMUNITY DEVELI NT AND SERVICES41A f 1 ^ X 146 Main Street KENNETH R.MAHONY North Andover,Massachusetts 01845 "Ssgc►+us�t Director (508)688-9533 Kenneth & Jacqueline Wilner Decision 55 Union Street Petition # 027-95 Boston, MA 02108 The Board of Appeals held a regular meeting on June 13, 1995 and continued until July 11, 1995 upon the appeal of Kenneth & Jacqueline Wilner requesting a variation of Section 4.133, para. (3) (c) of the 1984 Zoning Bylaw so as to permit relief of 5 feet for purposes of the construction of a new house in the 25 foot no cut zone to a wetland resource area in the Watershed District. The applicants also requested a variation from Section 7, para 7.3 and table 2 of the Zoning Bylaw so as to permit relief of 11 feet from the left side setback requirement of 30 feet and relief of 4 feet from the front setback requirement of 30 feet for a proposed house to be located at Lot 15 Carriage Chase Road. The following members were present and voting: Robert Ford, Joseph Faris, Ellen McIntyre and John Pallone. The public hearing was advertised in the North Andover Citizen on May 24 and May 31, 1995 and all abutters were notified by regular mail Motion by Joseph Faris to Grant the Variances as requested, seconded by Ellen McIntyre. Vote: unanimous. Voting in favor: Robert Ford, Joseph Faris, Ellen McIntyre, and John Pallone. The Board finds that the petitioner has satisfied the provisions of Section 10, para. 10.4 of the Zoning Bylaw and that the granting of these variances will not adversely affect the neighborhood or derogate from the intent and purpose of the Zoning Bylaw. Board of Appeals, Joseph Faris Dated: July 24, 1995 John Pallone Robert Ford Ellen McIntyre BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D.Robert Nicetta Michael Howard Sandra Start Kathleen Bradley Colwell AW DAVIS, MALM& D'AGOSTINE TOWN C L : ;K A PROFESSIONAL CORPORATION NORTH ANDOVR ONE BOSTON PLACE !{�f 'l}0(}[ iy- BOSTON.MASSACHUSETTS 02108-"70 jUN 39 "'6 AM 'b5 Julian J.D•Agostine Carol R.Cohen C.Michael Malm Howard P.Speicher Harold R.Davis Paul L.Feldman Frank P.Conrad Kevin F.Long TELEPHONE:(617)367-2500 William F.Griffin,Jr. Peter L.Koff TELECOPtER:(617)523-6215 Paul E.Levenson Gary M.Feldman Robert C.Gerrard George A.Hewett John G.Serino Harold G.Clarke,Jr. John R.Berman Robert J.Diettrich Sidney J.Wartel J.Gavin Cockfield Gary S.Matsko Ellen Donovan McCann Judith Ashton Thomas S.Fitzpatrick John T.Lynch Robert E.Richards,Jr. Grover S.Parnell, Jr. Jennifer L.Wifinsky Robert J.Galvin Lori H.Freedman John D.Chambliss June 29, 1995 HAND DELIVERY Charles Trombly, Recorder Land Court Department 408 Old Courthouse Boston, MA 02108 Re : Kenneth P. Willner, et al v. Town of North Andover Planning Board, et al , Misc. No. Dear Mr. Trombly Enclosed please find an original Complaint for filing in the above-referenced action. Also enclosed is a check in the amount of $110 . 00 made payable to Massachusetts Land Court for a filing fee. Thank you for your attention to this matter. Very truly yours, Howard P. Speicher Enclosure CC : Kenneth P. Willner >J:\SPEICHER\WILLNER\CLERK.LETa t COMMONWEALTH OF MASSACHUSETTS ESSEX, ss . LAND COURT MISC. NO. KENNETH P. WILLNER and JACQUELINE D. BEST-WILLNER, Plaintiffs V. RICHARD A. NARDELLA, JOHN COMPLAINT SIMONS, JOSEPH MAHONEY, ALISON LESCARBEAU and RICHARD ROWEN, as they are the members of the PLANNING BOARD OF THE TOWN OF NORTH ANDOVER, Defendants INTRODUCTION 1 . This is an action pursuant to G.L. c . 40A, §17 appealing a decision of the Town of North Andover Planning Board granting a special permit with conditions. PARTIES 2 . Plaintiffs Kenneth P. Willner and Jacqueline D. Best-Willner are residents of Danvers and are the owners of the property which is the subject of this action, located at and known as Lot 15, Carriage Chase, North Andover (the "Property" ) . 3 . The individual defendants are the members of the North Andover Planning Board. Their names and addresses are as follows : Richard A. Nardella 63 Haymeadow Road North Andover, MA 01845 John Simons 25 Ironwood Road North Andover, MA 01845 Joseph Mahoney 24 Mill Pond North Andover, MA 01845 Alison Lescarbeau 68 Laconia Circle North Andover, MA 01845 Richard Rowen 102 Bearhill Road North Andover, MA 01845 FACTS 4 . The Property, purchased by the plaintiffs in December, 1991, is an approved subdivision lot located in an R-1 zoning district and the Watershed Protection overlay district under the Town of North Andover Zoning By-law (the "By-law") . 5 . The Property is one of several lots approved as the Marbleridge Estates Subdivision, all of which, except the Property, have been developed by the construction of single -2 family dwellings without the Town of North Andover requiring the issuance of a special permit . 6 . The preliminary subdivision plan for the Marbleridg e Estates Subdivision was submitted in May, 1984 and was followed within seven months by the submission of a definitive subdivision plan. The definitive subdivision plan was approved by the Planning Board in January, 1985 and the plan was endorsed on March 13 , 1985 . 7 . Accordingly, pursuant to G.L. c. 40A, §6, the Property is subject to the Town of North Andover Zoning By-law as it was in effect at the time of submission of the preliminary subdivision plan in May, 1984, for eight years from the date of endorsement of the plan on March 13, 1985 as extended by the period of any litigation involving the right to develop the Property, including this action. 8 . The Property was the subject of litigation with the North Andover Conservation Commission which was commenced prior to March 13, 1993 and was resolved favorably to the plaintiffs by a settlement which resulted in the modification of an order of conditions allowing the plaintiffs to go forward with their building plans for the Property. -3- r 9 . The property is presently the subject other litigation with the Board and, the Town. Such other litigation is pending in this Court 10 . Consequently, pursuant to the zoning freeze provisions of G.L. c . 40A, §6, the Property is subject to the provisions of the By-law as it was in effect in May, 1984 . 11 . On or about February 11, 1994, at the insistence of Town officials, the plaintiffs applied to the Planning Board for a special permit pursuant to the watershed protection district provisions of the By-law as it was in effect in 1984 in order to construct a single family dwelling on the Property, while reserving their right to claim that the special permit is not required. 12 . Under the By-law, a special permit is required for construction within 100 feet of a tributary of Lake Cochichewick. Mr. Willner' s planned construction is within 100 feet of a wetland which is not a tributary of Lake Cochichewick. 13 . On March 1, 1994, the Planning Board held a duly advertised public hearing on the plaintiffs , application for a special permit, The hearing was continued to March 15, 1994, at which time the hearing was closed and four members of the Planning -4- Board, only three of whom had been present at the public hearing on March 1, voted to deny the special permit . 14 . The Planning Board' s decision was filed with the town clerk on March 29, 1994. That decision is the subject of other litigation now pending in this Court . 15 . In the course of the other litigation now pending in this Court, the parties contemplated and negotiated a compromise and settlement which would allow the plaintiffs to go forward with the construction of the dwelling they had proposed for the Property. The settlement contemplated and required, among other things, the granting of three variances by the North Andover Board of Appeals 16 . On June 6, 1995 the Board held a public hearing on the plaintiff' s request for a special permit which would implement the terms of the settlement between the parties int he earlier litigation. 17 . At the hearing, the Board approved a special permit, subject to conditions. The Board' s written decision was dated June 9, 1995 and was filed with the Town Clerk on June 12, 1995. A true and attested copy of the decision is attached hereto. -5- CLAIM FOR RELIEF - G.L. c. 40A, 517 18 . Plaintiffs reallege and incorporate as if stated herein the allegations contained in paragraphs l through 17 of the Complaint 19 . The approval of the special permit by the Planning Board with conditions was an abuse of the Planning Board' s discretion, exceeded the Planning Board' s authority and was on grounds that are legally untenable, unreasonable, whimsical, and arbitrary and capricious for the reason that the special permit was made subject to conditions which tied its validity to approval by other town boards and agencies, in particular the Board of Appeals, and for other reasons. 20 . There was no evidence from which the Planning Board could reasonably find that the wetland on the Property is a tributary of Lake Cochichewick. 21 . The Planning Board arbitrarily and capriciously applied the Watershed Protection District provisions of the By-law to the Property. On information and belief, neither the Town of North Andover nor the Planning Board required the issuance of a special permit for the similarly situated adjacent and nearby lots on which construction has occurred within one hundred feet of the same wetland resource as the one on the -6- Property. Similarly, no special permit was required, and a building permit was issued for construction on the Property before it was purchased by the plaintiffs. 22 . The plaintiffs are aggrieved by the decision of the Planning Board. WHEREFORE, the plaintiffs request that the Court grant the following relief : 1 . Hear the evidence and annul the conditions on the granting of the special permit found in the decision of the Planning Board; 2 . Enter judgment ordering the issuance of the requested special permit without conditions; 3 . In the alternative, issue a judgment declaring that pursuant to the By-law as it affects the Property, the plaintiff is entitled to construct a single family dwelling as proposed as a matter of right without any requirement for the issuance of a special permit; and -7- 5 . Such other relief as the Court deems just and proper. KENNETH P. WILLNER and JACQUELINE D. BEST-WILLNER, By their attorney, Howard P. cher/BBO#474380 DAVIS, MALM & D-AGOSTINE, P.C. One Boston Place Boston, MA 02108 Dated: June 28, 1995 (617) 367-2500 JASPE ICHERMI LLNEMCOMPLNT2.P8 -8- P�AM�IHG 80A80 JOYCE BCiVEO � CLERK W TOWN OF NORTH AN DOVE RNORTNTOWN ANDOVER H A S S A C H U SETTS Any appeal sha!l be filedNORTH SUN �2 I 1.7 P� within (20) days after the o 41 date of filing of this Notice R in the Office of the Town ;�•...... �5' SSACMUSE' Clerk. NOTICE OF DECISION ATTEST' .i ES i A True Copy "Or a&o - Date. . June 9. 1995 . . . . . . . . . . . . . Town ClerkDate of Hearing , June. 6.,. 1995. Kenneth P. Willner and Jacqueline Best-Willner Petitionof . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Carriage Chase Premises affected . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . Referring to the above petition for a special permit from the requirements North Andover Zoning BylawSection 133 Paragraph (3). . .(d) as in .effect of the • • . • in 1984. so as to p d .4114;y.tbe.Caustruction.Qf .a .single .Eamily .dwelling -and -related improvements within the Watershed Protection District. After a public hearing given on the above date, the Planning Board voted conditionally rove SPECIAL PERMIT to a EQ . . . . . . . .the . . . . . . . . . . . . . . CC: Director of Public works based upon the following conditions Building Inspector Natural Resource/Land Use Planner Health Sanitarian Assessors Signed n Police Chief airman Fire Chief Joseph . .. . . .ahoney.. . ... .. .. . . . . . . . Applicant . Richard Rowen, Vice Chairman Engineer • ' . . File Interested Parties Alison•Lescarbeau, Clerk • . • _ .• Richard A. Nardella John Simons • • . . . .planning .Board. .. . . . . . Town of North Andover , „oRT►, 1 OFFICE OF COMMUNITY DEVELOPMENT AND SERVICES p 146 Main Street "SsgcMus�`�5 KENNETH R.MONY North Andover,Massachusetts 01845 Director (508)688-9533 June 9, 1995 Ms. Joyce Bradshaw Town Clerk 120 Main Street North Andover, MA 01845 Re: - Special Permit - Watershed Protection District Lot 15 (#15) Carriage Chase Dear Ms. Bradshaw: The North Andover Planning Board held a public hearing on Tuesday evening, June 6, 1995 in the Senior Center behind the Town Building, upon the application of Kenneth P. Willner and Jacqueline Best-Willner, 55 Union Street, Boston, MA 02108 requesting a Special Permit under Section 133, Paragraph (3) (d) of the Zoning By-law as in effect in 1984. The legal notice was properly advertised in the North Andover Citizen on May 17 and May 24, 1995 and all parties of interest were duly notified. The following members were present: Joseph Mahoney, Chairman, Richard Rowen, Vice Chairman, Alison Lescarbeau, Clerk, Richard Nardella and Alberto Angles, Associate Member. The petitioner was requesting a special permit to allow the construction of a single family dwelling and related improvements in the Watershed Protection District. Ms. Lescarbeau read the legal notice to open the public hearing. Atty. Howard Speicher Was present representing the Willner's. Ms. Colwell stated that there was concern over the drainage system and where the water will flow. The applicant added a drainage system to handle stormwater. Awaiting certification that the plan addresses all issues regarding quality of water entering the lake. On a motion b . e y MsLescarbeau, seconded. by Mr. Rowen, the Board - voted unanimously to close the public hearing. BOARD OF APPEALS 688-9541 BLMJ)ING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D.Robert Nicetta Michael Howard Sandra Starr Kathleen Bradley Colwell At the same meeting, on a motion by Mr. Rowen, seconded by ,Ms. Lescarbeau, the Board voted unanimously to approve the special permit as written and amended. Attached are those conditions. sincerely, North Andover Planning Board (Joseph Mahoney, airman Lot 15 Carriage Chase Special Permit Watershed Protection District The Planning Board grants this special permit under Section 133, Paragraph (3) (d) of the Zoning Bylaw in effect in 1984, for the purpose of allowing construction of a dwelling and related improvements in the Watershed Protection District, on land known as Lot 15 Carriage Chase, owned by Kenneth P. Wilner and Jacqueline D. Best, 55 Union Street, Boston, MA 02108 The granting of this special permit is in accordance with the settlement of Massachusetts Land Court Mise. No. 205479. FINDINGS OF FACT: 1. The lot was created as part of the Marbleridge Subdivision. The preliminary subdivision plan was filed in the Spring of 1984 . The preliminary plan was followed by a definitive plan which was approved by the Planning Board on January 8, 1985. The plans were endorsed on March 13, 1985. As such, the property herein is considered subject to the North Andover Zoning Bylaw as it was in effect at the time of submission of the preliminary subdivision plan in May of 1984 for eight years from endorsement of the plan on March 13, 1985 as extended by the period of any litigation involving the right to develop the property. 2. The property was the subject of litigation with the North Andover Conservation Commission which commenced prior to March 13 , 1993 and was resolved favorably to the plaintiffs by a settlement. Therefore the property herein is considered subject to the North Andover Zoning Bylaw in effect in May of 1984 . 3 . Under the 1984 North Andover Zoning Bylaw, no construction may occur one hundred (100) feet horizontally from the edge of al tributaries, except by Special Permit issued by the Planning Board. Upon reaching the above findings, the Planning Board approves this Special Permit for the construction of a single family home within one hundred (100) feet horizontally from the edge of a tributary based upon the following conditions: SPECIAL CONDITIONS: 1. This decision must be filed with the North Essex Registry of Deeds. The following information is included as part of this decision: Plan of Land in No. Andover, MA Scale: 1" = 20' i Hayes Engineering, Inc. 603 Salem Street Wakefield, Mass 01880 August 18, 1993; last revision date 5/1/95 Any changes made to these plans shall be approved by the Town Planner. Any changes deemed substantial by the Town Planner will require a public hearing and modification by the Planning Board. 2. Prior to any work on site: a. The applicant must submit to the Planning Department written certification by a Registered Professional Engineer, or, other scientist educated in and possessing extensive experience in the science of hydrology and hydrogeology, stating that no significant degradation of the quality or quantity of water in or entering Lake Cochichewick will occur as a result of the development of this lot. b. The applicant must submit a statement that there is no reasonable alternative location outside the one hundred (100) foot no-construction zone for the structure. C. A performance guarantee of two thousand ($2,000) dollars in the form of a check made out to the Town of North Andover must be posted to insure that construction will take place in accordance with the plans and the conditions of this decision. This will also insure that an as-built plan will be submitted. d. All erosion control measures as shown on the plan including hay bales and silt fence must be in place and reviewed by the Town Planner. All work on the site will be monitored by the Planning Office and/or the Division of Public Works on a regular basis e. The site shall have received all necessary permits and approvals from the North Andover Conservation Commission, Board of Health, the Zoning Board of Appeals, and the Department of Public Works 3 Prior to FORM U verification (building permit issuance) a. All plans for the tie-in to the municipal sewer must be reviewed and approved by the Division of Public Works. 4. Prior to Planning Board verification of the Certificate of Occupancy: a. The roof drains and stone trench must be constructed as 2 shown on the plan. b. The stone masonry retaining wall must be constructed as shown on the plan and reviewed by the Town Planner. 5. Prior to release of the Performance Bonds a. The applicant shall submit a certification by either a Registered Professional Land Surveyor or Practicing Engineer that the site has been constructed in accordance with the approved plan. b. The Planning Board must by a majority vote make a finding that the site is in conformance with the approved plan and that any unforeseen circumstances have been adequately addressed by the applicant. 6. Upon conveyance of the property by the current owner, the deed must contain language restricting the area of maintained lawn to those areas outside of the proposed stone masonry wall as shown on the plan. Areas between the stone masonry wall and the wetland resource area are to remain in their natural state. 7. Fertilizers utilized for landscaping and lawn care shall be organic and not greater than 5% nitrogen content, and shall be used in moderation. Pesticides and herbicides shall not be used within 100 feet of a wetland resource area. 8. In no instance shall the applicants proposed construction be allowed to further impact the site than as proposed on the plan referenced in Condition # 1. 9. No open burning shall be done except as is permitted during burning season under the Fire Department regulations. 10. The Contractor shall contact Dig Safe at least 72 hours prior to commencing excavation. 11. The provisions of this conditional approval shall apply to and be binding upon the applicant, it's employees and all successors and assigns in interest or control. 12 . This permit shall be deemed to have lapsed after a two (2) year period from the date on which the Special Permit was granted unless substantial use or construction has commenced. Therefore the permit will expire on U'U11c, /-?A /997 CC. Director of Public Works Building Inspector Health Agent Assessor 3 Conservation Administrator Police Officer Fire Chief Applicant Engineer File Carriage.settle 4 DAVIS, MALM & D'AGOSTINE P.C. BANKOF BOSTON 0002019 ONE BOSTON PLACE THE FIRST NATIONAL BANK OF BOSTON BOSTON, MA 02108 NO. 5-39/110 DATE AMOUNT 06--28 95 $110. 00 PAY01111:_ HUhl.Dltl::.' OND (00/1.00 DC71..1_ARS TO THE ORDER NE ACCOUNT OF Lc1T7CE t.(�Rl'f 11900 20 i 9u' 1--O "0003904- S01,-61207111 L i • r' TOWN OF NORTH ANDOVER MASSACHUSETTS PLANNING BOARD APPLICATION FOR SPECIAL PERMIT NOTICE: This application must be typewritten Kenneth P . Willner and 55 iJnion St Applicant: Jacqueline D. Best- Address: Bosfon, MA � g�8 Willner 1. Application is hereby made (a) For a Special Permit under Section4, 1 13 , Paragraph(344-d) of the Zoning Bylaw.* *as in effect in 1984 2 . (a) Premises affected are land and buildings numbered15 (lot 15) ZT)t3tXJM Carriage Chase (b) Premises affected are property with frontage on th,� North South X East West side oi Carriage Chase . SX iktA, known as No. 15 (lot 15) Carriage Chase A-Jrn�X (c) Premises affected are in Zoning District Rl arj the premises affected have an area of 44 , 075 and frontage of 150. 05 feet. 3 . Ownership: (a) Name and Address of owner (if joint ownership, give al ! names) : Kenneth P . Willner and Jacqueline D. Best-Willner Date of purchase 12/31/91 Previous ownelMarbleridge Dv�g (b) If applicant is not owner, check his interest in the rp' premises: Prospective purchaser Leasee Other (explain) 4 . Size of proposed building: 128 front: 3R feet deer Height: 2 stories: 35 feet. (a) Approximate date of erection Spring, 1994 (b) Occupancy or use (of each floor)Single Family Residential (c) Type of construction Wood Frame 5 . Size of Existing Building: r_,.. feet front: feet deet. Height: stories feet. (a) Approximate date of erection (b) Occupancy or use (of each floor) i 6. Has there been a previous application for a Special Permit from the Planning Board on these premises? unknown If so, when 7 . Description of purpose for which Special Permit is sought on this petition: See attached 8. Deed recorded in the Registry of Deeds in Book3377 Page 261 or Land Court Certificate No. Book Page 9 . The principal points upon which I base may applicacion are as follows: (must be stated in detail) . See attached I agre to pay for advertising in newspaper and postage fee for mail leg ce to "P ies iIn r t" AJ (P it' oner' s Signature) Every application for action by the Board shall be made on a form approved by the Board. These forms shall be furnished by the Clerk upon request. Any communication supporting to be an application shall be treated as mere notice of intention to seek relief until such time as it is made on the official application form. All information called for by the form shall be furnished by the applicant in the manner therein. Every application shall be submitted with a list of "Parties in Interest" which shall include the petitioner, abutters, owners of land directly opposite on any public or private street or way and abutters to the abutters within three hundred (300) feet of the property line all as they appear on the most recent applicable tax list, notwithstanding that the land of such owner is located in another city or town, the Planning Board of the Town and the Planning Board of every abutting city or town. LIST OF PARTIES IN INTEREST NAMES ADDRESS See Attached Add additional sheets if necessary Any question should be directed to the Planning Office 4 LIST OF PARTIES OF INTEREST SUBJECT PROPERTY MAP PARCEL LOT NAME ADDRESS ABUTTERS ADDRESS MAP PARCEL LOT NAME See At ached H stin ATTACHMENT SPECIAL PERMIT APPLICATION FOR LOT 15 CARRIAGE CHASE The applicants seek approval of a special permit from provisions of the Zoning By-law as it was in effect in 1984 , pursuant to the zoning freeze provisions of Massachusetts General Laws, chapter 40A, Section 6. Specifically, the applicants request the issuance of a special permit for construction of a dwelling in accordance with Section 4 . 133 (3) (d) , the Watershed Protection district, as in effect in 1984 ,, The conditions for the granting of the special permit are met and the special permit should be granted for the following reasons: A. The specific site is an appropriate location for the use, structure or condition. The site is presently in an R-1 single family residential zoning district. The proposed use and structure is a single family dwelling consistent with the allowed uses in the district. The property is also in the Watershed Protection overlay district and as such is subject to the special permit requirements of the By-law if the proposed construction is within 100 feet of a tributary of Lake Cochichewick.l The proposed dwelling is located as far as is practically possible on the site from the wetlands on the site. There is no location on the property where the dwelling could be constructed without being within the 100 foot buffer zone from the wetlands. B. The use as developed will not adversely affect the neighborhood. The single family use proposed for the property is consistent with the single family character of the neighborhood and will not adversely affect the neighborhood in any way. Conditions on the development of the property contained in the Order of Conditions issued for the property by the North Andover Conservation Commission further assure that there will be no _ adverse impact or effect on the mons t construction ighrhood or on on and huse rof kthe ing water supply as a result of property. 1 The applicants take the position that the property is not subject to the Watershed Protection provisions of the By-law on the ground that the wetlands on the property e r the applicants"tributary" By-law. Therefore, within the meaning of the y ermit and the the position that the granting of the special p lawful � 4 . 133 (3) c is not necessary for the lata variance from Section ( ) licants have agreed construction of the proposed dwelling. Thermitt but reserve their to apply for the variance and special p rights regarding this matter. ATTACHMENT SPECIAL PERMIT APPLICATION FOR LOT 15 CARRIAGE CHASE The applicants seek approval of a special permit from provisions of the zoning By-law as it was in effect in 1984 , pursuant to the zoning freeze provisions of Massachusetts General Laws, chapter 40A, Section 6. Specifically, the applicants request the issuance of a special permit for construction of a dwelling in accordance with Section 4 . 133 (3) (d) , the Watershed Protection district, as in effect in _19840 The conditions for the granting of the special permit are met and the special permit should be granted for the following reasons: A. The specific site is an appropriate location for the use, structure or condition. The site is presently in an R-1 single family residential zoning district. The proposed use and structure is a single family dwelling consistent with the allowed uses in the district. The property is also in the Watershed Protection overlay district and as such is subject to the special permit requirements of the By-law if the proposed construction is within 100 feet of a tributary of Lake Cochichewick.1 The proposed dwelling is located as far as is practically possible on the site from the wetlands on the site. There is no location on the property where the dwelling could be constructed without being within the 100 foot buffer zone from the wetlands. B. The use as developed will not adversely affect the neighborhood. The single family use proposed for the property is consistent with the single family character of the neighborhood and will not adversely affect the neighborhood in any way. Conditions on the development of the property contained in the Order of Conditions issued for the property by the North Andover Conservation Commission further assure that there will be no adverse impact or effect on the neighborhood or on the drinking water supply as a result of the construction on and use of the property. 1 The applicants take the position that the property is not Watershed Protection provisions of the By-law on the subject to the Water J ground that the wetlands on the property are not a "tributary" within the meaning of the By-law. Therefore, the applicants take the position that the granting of the special permit and the variance from Section 4 . 133 (3) (c) is not necessary for the lawful construction of the proposed dwelling. The applicants have agreed to apply for the variance and special permit but reserve their rights regarding this matter. C• There will be no Pedestrians- nuisance nc a ns e or serious r ' The sous roadway proPert hazard to vehicles or y and will Y is located on an approved subdivision with the d will subdivision used for a single famil kion approval. Y dwelling in accordance D• Adequate and appropriate Proper facilities p ,ration of the will be the benefit of proposed use. Provided for town water and sewer facilities, property will have the watershed system, from the adverse effects of thereby protecting Burin The property will also the use of g construction asbe subject to other a Septic These include the c as provided tion of for oe protections edge of theOrder of Conditions. wetlands on the pro ert retaining wall 20 feet cutting, grading or other p Y► a restriction from the and the addition of activities within 20 against any and the watershed. a pond which will be beneficial to the wetlands the wetlands E. The use is in harmony Of the By-law. y with the general Of the g The purpose of the Watershed Protection and intent By-law is to protect the integrity Provisions a supply of drinking water, g Y of Lake Cochichewick as Proposal before the That purpose is amply protected by the any, is arguable and is ads a tributar �► involvement of the time, Y of Lake Cochichewick, if the proposal best marginal in an wetlands o affords more than Y Case. At the same I part of the water property to the extent that they protection to the Of r water supply. Standard Y function at all as Y bales, will be taken precautions, such as the use construction to facilitate erosion control.rotect the been taken for wetlands during These protection of the watershed ther Precautions have include a prohibition a construction. of town water and sewer facilities underground fuel storage; a Well or septic Y , thereby avoidingg use Pesticides and herbicides a prohibition the need for requirement within against the use of that only100 feet of the wetlands; a content be used • organic fertilizers with a the integrity and construction of a low nitrogen Y of the 20 foot retaining wall to protect Provisions specified in the Orderlofu Conditions bance zone as Well as other -2- ` a jt-1ST OF PARTIES OF INTEREST I i SUBJECT PROPERTY t MAP ]PARCEL 'LOT (NAME (ADDRESS I w � •il' 1 ABUTTERS 'MAP !PARCEL ;LOT INAME JADDRESS ' 01�•CC"i 3 3 y I Cc>N Nuc�c u i R N hNo m I ti A 6F-- C I I f1S`� fj. f1�L t/Z �✓ 250'3- 1 0o I m�S R. C ZEN c b c[\Siz M4Iz� � I (�('uTTT )ZS 6C'��t�4RS tv�ix�r� �>ocD OFu6Y-ECT f'wf A r• 3 to ' ' �Aqq i A A2(� G�ASs D D 4 C &6bir,Q_ a k y 5 334. 1 r P, CAvn1-Ln2JSi1� IY�`c2`L ti LoMtJ6 5 nsz M4�� CONCN MA.S Llklr'l�- 11 nS to 100 f\W. 4-SUSNr3 . P P�- l A I qq Caco Mva'S I, ' 3�0 o a. `ASA 0 Tic-r- 1j:k6V \u. A _ __ h pA� ►� C�N2 G� c hs _ .> f I I 'f I IS t . a i i Q a I , 1 � I 1 i TOWN OF NORTH ANDOVER $-al; MASSACHUSETTSI� � DOVER oer It�a�! ' OiNao �'�qO }YS . Any appeal shell be filed within (20) days after the date of filing of this Notice NOTICE OF DECISION in the Office of the Town Clerk. Date. March. 29, 1994 ' Ma'rbh' I','1Y)4' ' . March 15, 1994 Date of Hearing . . . . . . . . . . . . . . . . . Petition of . Kenneth P. Willner Premises affected . , Lot .15 Carriage .Chase , . . . . . . . . . . . . . . . . Referring to the above petition for a special permit from the requirements of the North Andover Zoning BYlaw Section 4.133, as in effect .in .1984 ' . . So as to permit ,the .construction .of a.dwelling .within.100 .feet.of ,a.wetland. . After a public hearing given on the above date, the Planning Board voted DENY to . . . . . . . . . . . . . . . .the . .SPECIAL.PERMIT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . based upon the following conditions: Signed A&&w— a- /tkf'r' CC: Director of Public Works Richard A. Nardella, Chairman Building Inspector . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . Conservation Administrator John Simons, Vice Chairman Health Sanitarian Assessors Joseph Mahoney, Clerk Police Chief . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . Fire Chief John Daghlian Applicant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Engineer File ' ' ' ' ' ' ' 'Planning Board Interested PArties NONrN KAREN H.P.NELSON o Director Town of 120 Main Street, 01845 Y° NORTH ANDOVER (508) 682-6483 BUILDING ; `�:i:a;�.,sm CONSERVATION ,8s'°��9`t DIVISION OF HEALTH PLANNING PLANNING & COMMUNITY DEVELOPMENT March 29, 1994 Mr. Daniel Long, Town Clerk Town Building 120 Main Street North Andover, MA 01845 Re: Special Permit Watershed Protection District - Lot 15 Carriage Chase Dear Mr. Long: The North Andover Planning Board held a public hearing on March 1, 1994, in the North Andover Senior Center, behind the Town Building upon the application of Kenneth P. Willner, requesting a Special Permit under Section 4. 133 of the North Andover Zoning Bylaw as in effect in 1984, so as to permit the construction of a dwelling in the Watershed Protection District on the premises located at #15 (Lot 15) Carriage Chase. The legal notice was properly advertised in the North Andover Citizen and all parties of interest were duly notified. The following members were present: Richard Nardella, Chairman, Joseph Mahoney, Clerk, Richard Rowen and John Daghlian. John Simons was absent. Howard Speicher, attorney for the Willners: settlement with Conservation Commission concern about placement of house on the lot, moved house as far as possible from wetland need a side yard and front yard variance creating a pond on Town water and sewer 20 ' no disturbance zone Ms. Colwell - Construction is entirely within 100' non- disturbance zone. Board has never approved a house within non- disturbance zone and should deny application. Discussion of Conservation commission settlement. Board needs statement from Conservation Commission as to their position on this project for the next meeting. Mr. Perna - Beaver dam has caused increase in the wetland area, additional pond created, therefore extra wetlands. Page 2 : Lot 15 Carriage Chase Attorney Speicher Plan does everything it can to protect the watershed. Mr. Nardella asked the Board if they wanted to consider this. Mr. Mahoney would like to have time to review the plans. Mr. Perna suggested the Board take a site walk. Mr. Daghlian was not comfortable with construction that close to the watershed. Continue to March 15, 1994 Mr. Robert Nicetta, Building Inspector: Zoning Board of Appeals will not act until the Planning Board makes a decision. Mr. Nardella not in favor of approving this and would be willing to vote on this tonight. Attorney Speicher believes that they do not need a Special Permit because wetland is not a tributary to Lake Cochichewick. willing to submit to some conditions applicants are addressing all of the issues related to the Watershed Protection District. Mr. Nardella: Need an opinion in writing from the Conservation Commission, not the Conservation Administrator, regarding their position. Mr. Willner Conservation Commission has approved this with 20' no cut zone and retaining wall. On a motion by Mr. Mahoney, seconded by Mr. Rowen, the Board voted to continue the public hearing to March 15, 1994. Mr. Rowen wants to walk the site with the Conservation Commission. On March 15, 1994 the Planning Board held a regular meeting. The following members were present: Richard Nardella, Chairman, John Simons Vice Chairman, Joseph Mahoney, Clerk, and John Daghlian. Richard Rowen was absent. Mr. Mahoney read a memo from the Conservation Commission to the Planning Board. Page 3: Lot 15 Carriage Chase Mr. Nardella asked if there was any way to reconfigure house to better fit on the lot? Mr. Willner told Mr. Nardella he did reorient the house. Mr. Simons: lot is now in area with 2 acre zoning require 75% CBA large house for the lot not willing to approve it Mr. Nardella asked if there was anything the Board could suggest to create an acceptable lot. There was no comment. Attorney Mark Johnson: none of the other houses in the subdivision were required to obtain a special permit in 1984 building permit was issued on the site in 1986 Willners bought the lot with the understanding that it was a buildable lot Mr. Michael Kasabuski, developer: He was allowed to affect wetlands in that subdivision without a permit states that standing water was required for a wetland Nicholas Petrucci, 56 Castlemere and John Pollano, 10 Carriage Chase both support the application. Attorney Johnson: applicant is protecting existing wetlands on site creating more wetlands On a motion by Mr. Simons, seconded by Mr. Mahoney, the Board voted to close the public hearing. Mr. Mahoney made a motion to approve the special permit. There was not second. On a motion by Mr. Simons, seconded by Mr. Daghlian, the Board voted to deny the special permit. The Chairman voted in the affirmative. Mr. Mahoney voted in the affirmative. Staff to draft denial. Mr. Simons to review prior to filing. Page 4: Lot 15 Carriage Chase Attached are the reasons for denial. Sincerely, North Andover Planning Board Rtr-&t-Z a -�Ca,4 a- Richard A. Nardella, Chairman attachment cc: Director of Public Works Building Inspector Conservation Administrator Health Sanitarian Assessors Police Chief Fire Chief Applicant Engineer File LOT 15 CARRIAGE CHASE KENNETH P. WILNER/JACQUELINE BEST-WILNER WATERSHED PROTECTION DISTRICT SPECIAL PERMIT The Planning Board herein DENIES the Special Permit requested by Kenneth P. Wilner and Jacqueline D. Best-Wilner, 55 Union Street, Boston, MA 01208, dated February 11, 1994, for the construction of a single family dwelling within 100 feet of the edge of a wetland resource area (tributary) of the Watershed Protection District. FINDINGS This lot was created as part of the Marbleridge Estates Subdivision. The preliminary plan for the subdivision was filed in May of 1984 with a definitive plan filed in October of 1984. The plan was subsequently approved in January of 1985 and the plans endorsed on March 13, 1985. This lot has never been developed thus the question arose of which zoning bylaw should be applied to the special permit request. The Board determined that although eight years has passed since the endorsement of the plans, litigation with the Conservation Commission may have tolled the running of this time period. (Kenneth P. Wilner v. George P. Reich, et al. Essex Superior Court C.A. No. 93-0126) However, as the litigation is unresolved, the Planning Board was unable to establish definitively, pursuant to M.G.L. Ch. 40A, Sec. 6, which zoning bylaw to apply. If the litigation is finally adjudicated "in favor" of the Wilners, the Wilners may be able to assert that the 1984 zoning bylaw should apply. However if the litigation is finally adjudicated "in favor" of the Town, the current zoning bylaw will apply. Due to the unresolved litigation, the question of which zoning bylaw to apply was unanswered at the time of the public hearing. Therefore the Planning Board considered the application under the principles of both bylaws. 1. Both bylaws create a no-construction zone within one hundred (100) feet from the edge of all wetlands ("tributaries" 1984) ("wetland resource area" 1993) as a mechanism for protecting the Town's water supply. Both bylaws allow for construction within this zone if a special permit is granted by the Planning Board. However, a special permit to construct is not granted unless the Board finds that the project will not be detrimental to the quality of the water supply. The Board finds that construction of a home and driveway entirely within the no- 1 construction zone is detrimental to the quality of the water supply. 2. Both the 1984 and the current Watershed Protection District Bylaw have the same purpose. Both bylaws are "intended to preserve and maintain the filtration and purification function of the land, the ground water table, the purity of the groundwater and the lake, to conserve the natural environment, and to protect the public health, safety, and welfare. " ZBL 4. 133 (1) 1983; ZBL 4.236(1) 1993 . The Planning Board finds that the construction of a single family home entirely within the 100 foot no construction zone would adversely affect the filtration and purification function of the land, the ground water table, the purity of the groundwater and the lake, and the natural environment. 3 . Under both bylaws the Planning Board "shall not" approve any application for a Special Permit unless the Board finds in its judgment that all of the required conditions are met. ZBL 10.31(1) 1984, 1993. These conditions are as follows: a. The Board finds that the specific site is not an appropriate location for the construction of a single family home, driveway, and associated changes to the landscape. As stated in the Lake Cochichewick Watershed Plan (1987) p. 72, development in the watershed leads to increased nutrient loading and urban stormwater runoff. The Plan recommends limiting development to the least sensitive areas and mitigating water quality degradation as important factors in protecting the future of the lake. This project is entirely within the most, sensitive section of the watershed and no mitigating measures have been presented.. b. The Board finds that construction of a single family home, driveway, and associated land changes in this location will adversely affect the neighborhood. Erosion of soils in areas of new construction is one of the primary sources of elevated suspended solids, nutrient and bacteria concentrations in the Lake. "Lake Cochichewick Watershed Plan" (1087) , p. 72. The entire project is located within the 100 foot "no construction zone" Absent a showing to the contrary, the erosion of soil due to the new construction will affect the quality of the, lake. C. The Board finds that there will be no nuisance or serious hazard to vehicles or pedestrians. d. The Board finds that adequate and appropriate 2 f other scientist similarly educated) that the quality and quantity of the water in or entering Lake Cochichewick will not be significantly degraded as required in Section 4.136(7) (c) of the Town of North Andover Zoning Bylaw (May 1992) . d. The applicant failed to demonstrate that all on-site preparation including but not limited to, construction, wastewater disposal, and fertilizer applications will not create concentrations of Nitrogen in groundwater, greater than the federal limit of 10 mg/Liter at the down gradient property boundary as required by Section 4 . 136(7) (d) (2) of the Town of North Andover Zoning Bylaw (May 1992) . e. The applicant has failed to provide the Planning Board with projections of down gradient concentrations of nitrogen, phosphorus and other relevant chemicals at property boundaries as required by Section 4 . 136(7) (d) (3) of the Town of North Andover Zoning Bylaw (May 1992) . CONCLUSION Given the above findings the Planning Board voted to DENY the applicant's request for a special permit. The following plan shall be deemed part of the denial: Plan of Land in North Andover, MA Scale: 1" = 20' Date: August 18, 1993; rev. 12/13/93, 12/15/93, 12/17/93, 12/28/93 Prepared by: Hayes Engineering, Inc. 603 Salem Street Wakefield, MA 01880 cc: Director of Public Works Building Inspector Health Administrator Assessors Conservation Commission Administrator Police Chief Fire Chief Applicant Engineer File Lot15.CarriageChase 4 facilities have not been provided for the proper operation of the proposed use. Construction of a single family home will affect the- quality of the lake. As stated in Finding 4 below, no information has been provided demonstrating that the operation of the proposed use will properly protect the Watershed. e. The Board f inds that in the absence of a showing that the Watershed will be protected, the construction of a single family home within 100 feet of the edge of a wetland area within the non-disturbance zone of the Lake Cochichewick Watershed Protection District is not in harmony with the general purpose and intent of this bylaw. The Planning Board finds that the applicant meets only one of the five conditidns that must be met prior to the issuance of a Special Permit. 4. The Watershed Protection District bylaw was amended in 1988 as a result of a study conducted on the watershed of Lake Cochichewick. Many of the policies followed by the Planning Board under the earlier bylaw were codified at this time. Thus, although these standards are not specifically stated in the 1984 bylaw, they had been considered by the Planning Board when enforcing the bylaw. Thus the Board also considered the requirements of the current bylaw in its review of this application. a. The Planning Board makes the specific finding as required under section 4. 16(7) (c) of the current bylaw that the proposed use in conjunction with other uses nearby will cause a significant degradation in the quality and quantity of water in or entering Lake Cochichewick. b. The proposed construction is within 100 feet of the edge of a watershed wetland. As such, the applicant must take steps to insure that any runoff from impervious surfaces (other than driveways, rooftops, walkways and patios servicing single family dwellings) shall, to the extent possible, be recharged on site and diverted toward areas covered with vegetation for surface infiltration. Where this is not possible, other mitigating measures such as sedimentation ponds shall be used after approval by the appropriate Boards as listed in Section 6(b) of the Zoning Bylaws. The applicant did not present any proof to the Planning Board of any mitigation measures. C. The applicant failed to provide at a minimum, a written certification by a registered Professional Engineer (or 3 3 0 RE ivLl) r . DANIEL L 3NG IL TOWN CLUIK NORTH A flvER �a CHU TOWN OF NORTH ANDOVER MASSACHUSETTS BOARD OF APPEALS NOTICE OF DECISION Date gbruary, .!4, . 199A . .. . . . . . Petition No.. . D.Q8-94. . . . . . . . . . . . . Date of Hearing. . .I�ebx'uary. .8. . 1994 Petition of . . . . .Kenneth .P. WiUner. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Premises affected . 15. Carriage. .Chase. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Special Permit Referring to the above petition for a XAMM from the requirements of)EM Section .4-133'. Paragraph, .0) M. of, ,the, Zoning,Bylaw An.effect ,in, 1984 . . . . . . . . . . . . . . . . . . . . . . . . . . so as to permit .construction. of. .a .dweil.ing,in, ,the waterahed ,no-ds.turbence, zgne,. . After a public hearing given on the above date, the Board of Appeals voted to . ALLOW. . . . . the PREJUDICE. PETITIONER .TO.WITHDRAW.WITHOUT. .YMM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Signed ��4 . . . . . . . . . . .Frank .Serio,. Jr.., . . . . . . . . . . .Walter. .Soule.,. Clerk. . . . . . . . . . . . . . . . .Raymond .VivenziQ . . . . . . . . . . . . . . . . . . . .Robert .Ford. . . . . . . . . . . . . . . . . John .P.allone. . . . . . . . Board of Appeals Any appeal shall be f"ad within (20) days after tle N , lit4 E ORTH TOWN C l i_iM '?t2 of filing of tats ��� ,. 3?OtT` "00 RTHtiuf) ER she Office of tt w p fES 14 11 49- N � O 1eyM S�CHUSES TOWN OF NORTH ANDOVER MASSACHUSETTS BOARD OF APPEALS * Kenneth P. Willner * DECISION 15 Carriage Chase North Andover, MA 01845 * Petition #008-94 * The Board of Appeals held a regular meeting on Tuesday evening, February 8, 1994 upon the application of Kenneth P. Willner requesting a Special Permit under Section 4. 133, Paragraph (3) (d) of the Zoning Bylaw in effect in 1984 so as to permit construction of a dwelling in the watershed no-disturbance on the premises located at 15 Carriage Chase. The following members were present and voting: Frank Serio, Jr. , Chairman, Walter Soule, Clerk, Raymond Vivenzio, Robert Ford and John Pallone. The hearing was advertised in the Eagle Tribune on January 25 and February 1, 1994 and all abutters were notified by regular mail. Upon request of the petitioner, a motion by Mr. Vivenzio and second by Mr. Soule, the Board voted unanimously to ALLOW THE PETITION TO WITHDRAW WITHOUT PREJUDICE. Dated this 14th day of February 1994. BOARD OF APPEALS Frank Serio, Jr/ Chairman Any appeal shall be filed S '""'"" within (20) days after the rV ER +,�•. �, �. date of filing of this Notice }AI , 43 A '` HU in the Office of the Town TOWN OF NORTH ANDOVER a "! MASSACHUSETTS BOARD OF APPEALS NOTICE OF DECISION Date . .MaY. ?x,. .1994. . . . . . . . . Petition No.. . 007-94. . . . . . . . . . . . . Date of Hearing. May. 10, 1,994. . . . Petition of . . . . .Kenneth .P, ,W?Ilner. . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Premises affected . . 15. .cerriag.e. .Chase. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Referring to the above petition for a variation from the requirements of AU . .S e c t ion .4,13 3, Paragraph .3(C). and Table. .2 .of. the. Zanixig. Bylaw.in. ef.£ect. in. .1.9.84 . . . . . . . . . . . . . . . so as to permit .const,ruction .of .a.dwelling.in. the .vat er.shed.no-disturbance. zoue.. . After a public hearing given on the above date, the Board of Appeals voted to . ALLOW. . . . . the PETITIONER TO WITHDRAW .WITHOUT PREJUDICE , . . . . . . . k �g ilX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . f > liti Signed _ . raerio, Jr. , Chairman . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Walter Soule, Clerk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Robert Ford Scott Karpinski . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Board of Appeals G K Any appeal shall be filed �•i I NORTH Y ER within (20) days after the 0 date of filing cf t,iis 1otice ft A M 43 AY in the Office of the Town SACHUS TOWN OF NORTH ANDOVER MASSACHUSETTS BOARD OF APPEALS Kenneth P. Willner DECISION 15 Carriage Chase North Andover, MA 01845 Petition #007-94 The Board of Appeals held a public hearing on Tuesday evening, January 25 continued to February 8, March 8, April 12 then continued to April 19 for a Special Meeting where the public hearing was re-opened then continued to May 10, 1994 upon the application of Kenneth P. Willner requesting a variation of Section 4. 133, Paragraph 3 (c) and Table 2 of the Zoning Bylaw in effect in 1984, so to permit construction of a dwelling in the watershed no-disturbance zone on the premises located at 15 (Lot 15) Carriage Chase. The following members were present and voting: Frank Serio, Jr. , Chairman, Walter Soule, Clerk, Robert Ford and Scott Karpinski. The hearing was advertised in the North Andover Citizen on January 25 and February 1, 1994 and all abutters were notified by regular mail. Upon a motion by Mr. Soule and second by Mr. Ford, the Board voted unanimously to ALLOW THE PETITIONER TO WITHDRAW WITHOUT PREJUDICE. Dated this 20th day of May 1994. BOARD OF APPEALS Frank Serio, Jk. Chairman JOV Received by Town Clerk: NORTH A14C,0VER TOWN OF NORTH ,ANDOVER, MASSACHUSE 5 BOARD OF APPEALS APPLICATION FOR RELIEF FROM THE ZONING ORDINANCE 55 Union Street Applicant Kenneth P. Willner Address Boston, M 02108 and Jacqueline D. Best-WillnerTel. No. ( 617)_ 227-9090 1, r Application is hereby made: -4. 133 1 a) For a variance from the requirements of Section_______ Paragraph (3) (c) and Table 2 of the Zoning Bylaws,* as in -effect in 1984. b) For a special Permit under section_ ,Paragraph of the Zoning Bylaws, as in effect in 1984. c) As a Party Aggrieved, for review of a decision made by the Building Inspector or other authority. 2. a) Premises affected are land and building(s) numbered 15 - (Lot 15) CarriageCF—ase - Street. b) Premises affected are property with frontage on the North ( ) South ( x) East ( ) West ( ) side of Carriage Chase street.15 (Lot 15 ) Carriage `Chase Street, and known as No. Street. C) Premises affected are in Zoning Di tric44, 075 R15 ,are anditthe premises affected have an area of and frontage of 15._` feet. 3. Ownership: ' a) Name and address of owner (if joint ownership, give all names) : -Willner Kenneth P. Willner and Jacqueline D. Best -l9illn?r Date of Purchase 12/31 91 Previous Owner MarblepLdge Dev. Corp. b) 1. ; If applicant is not owner, check his/her interest in the premises: Prospective Purchaser Lessee Other 2 . Letter of authorization for Variance/Special Permit required. 4 . Size of proposed building: 128 front; 38 feet deep Height 2 stories; 35 feet. _ a) Approximate date of erection: S:umme r.,. 19-95. b) Occupancy or use of each floor: Single family residential C) T pe of construction: wood frame Y a . j 5. Has there been a previous appeal, under zoning, on these premises? Unknown If so, when? 6. Description of relief sought on this petition 7. Deed recorded in the Registry of Deeds in Book3377 Page 261 Land Court Certificate No. Book Page The principal points upon which I base my application are as follows: (must be stated in detail) See attached. I ag ee to pay the filing fee, advertising in newspaper, and i ental expenses Signatur D Petitioner(s) Every application for actio by the Board shall be made on a form approved by the Board. These forms shall be furnished by the Clerk upon request. Any communication _purporting to be an application shall be treated as mere notice of intention to seek relief until such time as it is made on the official application form. All information called for by the form shall be furnished by the applicant in the manner therein prescribed. Every application shall be submitted with a list of "Parties of Interest" which list shall include the petitioner, abutters, owners of land directly opposite on any public or private street or way, and abutters to the abutters within three hundred feet (3001 ) of the property line of the petitioner as they appear on the most recent applicable tax list, notwithstanding that the land of any such owner is located in another city or town, the Planning Board of the city or town, and the Planning Board of every abutting city or town. *Every application shall be submitted with an application charge cost in the amount of $25. 00. In addition, the petitioner shall be responsible for any and all costs involved in bringing the petition before the Board. Such costs shall include mailing and --- publication, but are not necessarily limited to these. Every application shall be submitted with a plan of land approved by the Board. No petition will be brought before the Board unless said plan has been submitted. Copies of the Board's `-requirements regarding plans are attached hereto or are available the Board of Appeals upon request. Rev. 4/93 P Irv•;. ,,ST OF PARTIES OF INTEREST SUBJECT PROPERTY ,MAP IPARCEL 'LOT (NAME ADDRESS ( I � ABUTTERS ;MAP ;PARCEL !LOT INAME ADDRESS I I I I j I . - ,I I I i I i I t � I I � I I i I i I i i� ATTACHMENT TO VARIANCE AND SPECIAL PERMIT APPLICATION FOR LOT 15 CARRIAGE CHASE STREET The applicants seek approval of variances from three provisions of the Zoning By-law as it was in effect in 1984, pursuant to the zoning freeze provisions of Massachusetts General Laws, chapter 40A, Section 6 . Specifically, the applicants request the issuance of variances from Section 4 . 133 (3) (c) (Watershed no- disturbance zone) and Table 2 (dimensional requirements) for front yard and side yard setbacks, all as in effect in 1984 .1 The conditions for the granting of the requested variances are met and the variances should be granted for the following reasons: A. There are circumstances relating to the soil conditions, shape or topography of the property which especially affect the property but not generally the zoning district in which it is located. The property is a long, rectangular lot, twice as long front to rear as it is wide. A narrow projection of wetlands, only about one-fifth the width of the lot, extends from the rear of the lot for almost two-thirds of the length of the lot, for a distance of about 180 feet of the 300 foot length of the lot. A subdivision roadway cul-de-sac also infringes on the front 20 feet of the lot. These conditions relate specifically to the soil conditions (wetlands) and shape (cul-de-sac infringement) of the property in a way which is unique to the property and which does not affect generally the zoning district in which the property is located nor.. for that matter other properties in the district. g B. Owing to the above conditions, a literal enforcement of the provisions of the By-law will involve substantial hardship, financial or otherwise, to the applicants. The extension of the wetlands over the rear 180 feet of the lot and the infringement of the cul-de-sac over the front 20 feet leaves only about 100 feet in which to locate a house. That 100 feet is entirely within the buffer zone under both the Watershed Protection provisions of the By-law and the Wetlands Protection Act, G.L. c. 131, Sec. 40. The Conservation Commission as well as the purpose of the Watershed Protection provisions of the By-law call for maximizing the distance of disturbance and construction from the wetlands on the property. Given the tight space between the edge of the wetlands and the cul-de-sac, it is impossible to provide an acceptable zone 1 The applicants take the position that the property is not subject to the Watershed Protection provisions of the By-law on te round that the wetlands on the property are not a "tributary" g applicants take within the meaning of the By-law. Therefore, the .app the position that the granting of a variance from Section 4 . 133 (3) (c) is not necessary for the lawful construction of the the proposed dwelling. The applicants have agreed to apply for variance but reserve their rights regarding this matter. i 01 of no-disturbance and no-construction from the edge of the wetlands without invading the front and side yard setbacks required by the j By-law. Even then it is impossible to do so without reducing the width of the no-disturbance area from the edge of the wetlands to some extent, in violation of the 25 foot requirement in Section 4 . 133 (3) (c) of the By-law. Because of the conditions noted above, it is impossible to build a single family dwelling consistent with the neighborhood which will comply with the front and side yard setback provisions of the By-law and which will comply with the no- cut provisions of the Watershed Protection provisions of the By- law. Furthermore, the Conservation Commission has agreed to issue a modified Order of Conditions, referred to above, which will allow the proposed dwelling and related grading and cutting, to come no closer to the wetlands than the 32 feet for the house and 20 feet for grading and cutting shown on the plan submitted in conjunction with this application. As a result, a literal enforcement of the noted provisions of the By-law will render the lot, as a practical matter, unbuildable, with the resulting financial and practical hardship to the applicants, who purchased the property in order to build their home on it and live there. C. Desirable relief- may be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent or purpose of the By-law. The granting of the requested relief will actually further rather than derogate from the intent and purpose of the By-law and will not involve any detriment to the public good. The requested variances will further the goal of protecting the watershed by maximizing to the extent possible the distance of the cutting, grading and construction from the wetlands while preserving as much of the front and side yard setbacks as possible and minimizing any intrusion on the existing cul-de-sac, which is encroaching on the property without the benefit of an easement, to an extent acceptable to the Town' s Public Works Department . Since there are only three houses on the street, the slight intrusion into the front and side yard setbacks will have little if any negative effect on neighboring properties, and the owner of the abutting lot on the affected side of the property has expressed no opposition to the granting of the variances. The variances requested are the minimum variances that will accomplish the intended purpose. -2- z J l� For the reasons stated above, and others which will be stated j at the public hearing, the applicants respectfully request that the Board grant the requested relief. Kenneth nnet P. Willner and Jacqueline D. Best-Willner, By their attorney, Howard P. p ' c er Davis, Malm t D'Agostine, P.C. One Boston Place Boston, MA 02108 (617) 367-2500 -3- LIST OF PARTIES OF INTEREST x SUBJECT PROPERTY t MAP PARCEL LOT !NAME iADDRESS 1 S2 0 i lmI i GI wc��+ P. w1�>,� �No o5 ufiloti sxRli-5-k ABUTTERS MAP !PARCEL :LOT INAME JADDRESS �I Q..rcC,T PS13(�1.�RiS - 3 + 3 i y 8i Cch�N�cc 1Cu T Ft N IMS(-1 M 1 N r ' A G E C EIASS� N, A�Kt1Z Q ; �U5 I NANDa r GILDA II A51 2 oo 15 m�CS �- Cc;2�N� �c� 6 c PtSi�4 M41Z •: � � ' + �� M t C h C7 L PtN U p C,.,t1 (L�►�s�, t..ti�S`c._. i1 A iA('SuiTFd8 lw►%lAtN aoD f--rlT Pa oPIYA 3 3 R IqyL-L t ► n2n G WNss D 104 C Psi 4,M4R�- Ai�jow`t 6 45 + 33%+. 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