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HomeMy WebLinkAboutMAYNARD, JAMES r/ dp rw OFFR`.ES OF: Town of „ „,, 120 Main Street APPEALS <: NORTH ANDOV�� ,.< F North Andover. BUILDING b - �` _ 3 Massachusetts 01845 CONSERVATION `"jg6 DIVISION OF !0`i) ,; �w R (617)6854775 HEALTH µ0r' PLANNING PLANNING & COMMUNITY DEV LQP�T ��QQ J i KAREN H.P. NELSON, DIREC TOR April 13, 1987 Town Clerk, Daniel Lang 120 Main St. North Andover, MA 01845 Re: Approval Not Required Plan Plan of Land in No. Andover, MA dated March 30, 1987 Owner: James Maynard Dear Mr. Long: The purpose of this letter is to formally notify you of the action of the Planning Board regarding the above referenced Form A application and associated plan. Due to the fact that the plan prepared by Cyr Engineering is not a result of a field survey, there is no change in lot lines, setbacks of existing structures are lacking, road width missing, abutters not included, bearings and distances as required are inadequate. Overall, the plan as submitted shows insufficient information. At the April 6, 1987 Planning Board meeting, the board determined that the plan does not need Planning Board signature. The plans are to be returned to the applicant unsigned. Sincerely, For theannin Erich W. Nitzsche Chairman E{NAn c James Maynard, Trustee 740 Main St. Waltham, MA 02154 FORM A APPLICATIGK FOR ENDMSEMT OF PLAN N1 Qr ;aJER BELIEVED NOT TO R4WIRE APPROVAL ' 'lHn 3 f•'J+ i � 'V li.l � � rlly.ft .t J�.-�.. y. .^ `tl t• !-': 1 . f.J .fy � • i , Q j� . .. r:,`. ... . 'ttr . !. '.^.r. .t� ,��{t�fj,4 !'qi�l•! 1:j.at):y,,.. r '! � ..r..4'"�J. (i To the Plaquing ,Board at the Town of North Andoveri i The undersigned wishes.to recard3he accompanying plan and requests a'determination by said Board that approval by it under the Subdivision Control Law is not required. The undersigned believes that auch approval'-is' not required for the,following reaeone 1. The division of laud shown an the acoompagying plan is not a subdivision because every lot shown thereon has the amount of Frontage required by the North Andover Zoning IV-mow end is nun public ways zamelT, Chestnut Street, Salem Turnpike '&' Min Road' or a private ways namely, being land bounded as follows$ Northeasterly by 'Chestnut Street, Southwesterly by Salem Turnpike, and Northwesterly by Mill Road. -2. The division of land shown on the accompanying p;an is not a subdivision for the following reasons: _i 3. Title reference North Essex Deeds, Book R_ T i page • 1 3 1 „i or certificate of Title No. 1 Registration Bock ......... page. -._..,_.. f Received by Town Clerks Chestnu Green Realty Trust, - Date: APPlicantl eignatu • « �CCsGG�' B Time: ,Maynard ,- , stee - A Plic a addresi� ' • 146 lar Street. �... Signatures Y Waltham, MA 02154 Owner's signature and address if not the applicants •_ply Notice to APPLICANT/TOWN CLERK of Action of PlwMing Board on Accompanying Plan, 1. The North Andover Planning board has determined that said plan does not require approval under the Subdivision Control Law, and the appropriate endorsement has been made upga the same.. 2, , The North Andover Boad has determined that said plan shows a subdivision, as' defined by C.L., a* 41, s, 81-7., and must therefore be re—submitted to it for approval under the Subdivision Control Law. Very truly yours, NORTH ANDOVER PLANNING BOARD _ _._ ....- _ . By. Date: RMA TG'f. it APPLICATION FON ENDORSEASENT OF PLAN Fr a" " `'; R BELMW NOT TO REQUIRE APPROVAL i ' .,. 7l ' .. .a� may'{:�yl i4•!til .y S:S,.1)ka •,, ! i• •`. .,' :.1. . To the Plauning,Board of the Totes of North Andovers The undersigned wishes.to record the aoaompanyi•ng Plan and requests a determination by said Board that approval l)y it under the Subdivision Control Law is not required. The undersigned believes that suoh'appraval' is n6t required for the,following reasons 1, The division of land shown on the a000mpa;Wing plan is not a subdivision because every lot shown thereon has the amount of frontage required by the North Andover Zoning By—Law and is on a publio wq, aamly, Chestnut Street, Salem Turnpilt�e `& Ki 11 Road'` " ' or a private ways a4"40 being land bounded ast followai Northeasterly by 'Chestnut Street, Southwesterly by Salem Turnpike, and Northwesterly by Mill Road. ,2. The division of land shown on the aoaompsnyieg peau is not a subdivision for the following reasons: 3. Title referenoe North Essex Deeds,. Book P�_ r Wp, 11 Page i or Certitirate of Title No. , Registration Hook ,„",,,, j Paga: ._��r Received by Town Clerk: S Chestnu Green' Realty Trust, Date: Applioant' signatu dfe �--- Time; a a see e. APphic s addres 74jj. Stre . Signature: Waltham, MA 02154 -Owner's signature and address if not the applicant; r Notice to APPLICANT/TOWN CLERK of Aotion of Planhing Board on A000mpanying Plan. 1. The North Andover Planning Board has determined that said plan does not require approval under the Subdivision Control Lax, and the appropriate endorsement has i` been made upon the same.. r:T, 2. The North Andover Planning Board has determined that said plan shows a subdivision, as' defined•by G.L. ce 41, at and and must therefore be re-submitted to it for approval under the Subdivision Control Lax. I Very truly yours, NORTH ANDOVER PLANNING BOARD Date: I __ WILLIS and WILLIS ATTORNEYS-AT-LAW 160 PLEASANT STREET NORTH ANDOVER, MASSACHUSETTS 01845 JOHN J. WILLIS TELEPHONE 685-3551 JOHN J. WILLIS, JR. April 21, 1987 Daniel Long, Town Clerk Town Hall North Andover, MA 01845 RE: FORM A PLAN OF JAMES MAYNARD PROPERTY LOCATED AT: TURNPIKE STREET, MILL ROAD AND CHESTNUT STREET FILED: MARCH 31, 1987 i Dear Mr. Long: Enclosed you will find a certificate which I would have you execute concerning the above-captioned Plan. You will note that the Plan was filed on March 31, 1987, and no action has been taken by the North Andover Planning Board in connection with whether the Plan does, or does not, constitute a subdivision under the Subdivision Control Law for the Commonwealth of Massachusetts. Under the laws of the Commonwealth of Massachusetts, M.G.L. , Chpt. 41, Sec. 81P, no action so having been taken, a certificate shall issue from the Town Clerk to that effect so that I may record the plan with the appropriate Registry of Deeds. Hoping you will have no difficulty with this request, I remain, S ncere Wi i r. to ney r ames P. Maynk JWJR:psw Enclosure CERTIFICATE UNDER M.G.L. , CHPT. 41, SEC. 81P BY THE TOWN CLERK FOR THE TOWN OF NORTH ANDOVER, MA Now comes DANIEL LONG, as he is the Town Clerk for the Town of North Andover, and certifies as follows: 1. The certain plan entitled "Plan of Land in North Andover, MA, Scale: 1"=40 ' Dated: March 30, 1987, Hayes Engineering, Inc. , Civil Engineers & Land Surveyors, Owner: James Maynard", was filed with the North Andover Planning Board on March 31, 1987 as a plan "believed not to require approval of the Subdivision Control Law". 2. A period in excess of 14 days has elapsed since the, submission of said Plan and no action has been taken by the North Andover Planning Board in regard to a determination "that approval under the Subdivision Control Law is not required". Signed and sealed under the pains and penalties of perjury this day of April, 1987. Daniel Long, Town Clerk Town of North Andover, MA COMMONWEALTH OF MASSACHUSETTS Essex, ss. April , 1987 Then personally appeared the above-named, DANIEL LONG, Town Clerk for the Town of North Andover, and swore to the above to be true. Before me, Notary Public My commission expires: WILLIS and WILLIS ATTORNEYS-AT-LAW 180 PLEASANT STREET NORTH ANDOVER; MASSACHUSETTS 01845 Daniel Long, Town Clerk Town Hall North Andover, MA 01845 pEC „:'L j RUDOLPH, ANDREWS & KRONER DANT: -c Attorneys at Law T0'P",; ' <.K NORT;; 'n9U"VER Sw f-Hove CENT ,u,STRW Poff 0"Im Box 238 JAN 9 3 31 PM '87 GEORGWOVIN,AAA38ACHUMM 01833 Ro"n P.RUDOLPH RoMrr&ANDREM 1BEPHONB M CAUM.E.KaoNM (617)352-8111,352-60M January 9, 1986 Clerk Town of North Andover 120 Main Street North Andover, Massachusetts 01845 Re: Kellner v. Maynard, Trustee, etals Dear Clerk: Enclosed please find for filing Complaint, Notice of Appeal, Certificate of Service and attachments in regard to the above entitled matter which were filed with the Superior Court this day. Kindly file same. Thank you for your courtesy. Ver o Robert RPR/kas Enclosures TYPE OR USE BALL POINT PEN—BEAR DOWN FIRMLY MASSACHUSETTS TRIAL COURT SUPERIOR COURT DEPARTMENT CIVIL ACTION COVER SHEET Essex 88. (To be filed with each Complaint) NO. PLAINTIFF($) DEFENDANT(S) Helen Kellner James P. Maynard, Trustee, etals ATTORNEY(S) (Firm Name, Address,Tet.) ATTORNEY(S)(if known) Robert P. Rudolph, Esqurie, Rudolph, Andrews & Kroner, 64 Central Street, Georgetown, MA Boo# 01833 Place an®in one box only ORIGIN w [11. F01 Complaint ❑ 4. PO4 Dist.Cl.Appeal 0.231,s.97 ❑ 2. F02 Removal to Sup, Cf.0.231,4.104 ❑ 6. F05 Reactivated after Rescdpt;Relief ❑ S. FOS Retransfer to Sup.Ct.0.231,8.1020 from judgmentilorder(mass.R.Cb.P.90) Place an;®M one box only, NATURE OF ACTION CONTRACT REAL PROPERTY MISCELLANEOUS ❑ A01 Services, labor and materials ❑ C01 Land taking (eminent domain) ❑ E02 Appeal from administrative agency. ❑ A02 Goods sold and delivered 12 CO2 Zoning appeal,G.L.c.40A G.L.c.30A ❑ A03 Commercial paper ❑ CO3 Dispute concerning title ❑ E03 Action against Commonwealth nr 58 [3AO8 Sale Or lasso of real estate L] C04 Foreclosure of mortgage Municipality,G.L. El A99 Other(specify) C] C99 Other(specify) ❑ E04 Taxpayer suit,G.L.c 0.4.40 4.53 ❑ E05 Confirmation of arbitration awards, G.L.0.251 TORT EQUITABLE REMEDIES ❑ Eoe Massachusetts Antitrust Act, ❑ BO Motor vehicle negligence-personal ❑ p01 Specific performance of contract G.L.c.93 Injury/property damage ❑ EBB Appointment of receiver ❑ 8 0 Other negligence-personal Injury ❑ D02 Reach and apply,G.L.x214, ❑ E09 General contractor's surely bond, property damage s•3(6)-(9i G.L.0.149,ss.29,29a ' ❑ BO$ Products liability Q DOB Contribution or Indemnification ❑ Eto Summary process appeal ❑ Boo Malpractice-medical ❑ D07 Imposition of trust ❑ Ell Workman's Compensation Q Bot' Malpractice-other ❑ DOB Minority stockholder's suit ❑ E12 Small Claims Appeal (specify) ❑ D10 Accounting ❑ E13 Labor Dispute Q BIiB Wrongful death, G.L. 0:229,s.2A ❑ 012 Dissolution of partnership ❑ E14 Chapter 123A Petition—SDP ❑ 810 Defamation (libel-slander) ❑ D13 Declaratory Judgment,G.L.o.231A ❑ E15 Abuse Petition,G.L.c.209A Q 008 Other(specify) ❑ 099 Other(specify) ❑E16 Auto Surcharge Appeal ❑ E17 Civil Rights Act,G.L.c.12,ss.11H-/ ❑ 00 Qatar(spew') SUPERIOR COURT RULE 29. Requirement of statement as to money damages to prevent the transfer of civil actions to District or Municipal Court Departments. 1. Superior Court Rule 29, as amended requires the statement of money damages on the reverse side be completed. 2. Failure to complete the statement,where appropriate, will result in transfer of this action (Superior Court Rule 29(2). 810 URE OF ATTORNEY OF RECORD DTE: (OPPICIE USE ONLY—DO NOT WRITE BELOW THIS LINE) RECEIVED DISPOSITION 0Y: A. Judgment Entered B. No Judgment Entered DATE: ❑ 1. Before jury trial or non-jury hearing ❑ e. `Transferred to District Court DISP ENTERED ❑ 2. During jury trial or non-jury hearing under G.L.0.231,s1112C ❑ 3. After Jury verdict BY: ❑ 4, After court finding DATE: ❑ 5. Aller poet trial motion Disposition data CLERK'S OFFICE COPY m1c003-07/84 6 RE Un E!"'fr TC0 t .. K wT14o CNER COMMONWEALTH OF MASSACONE f TS3 31 M '10 ESSEX, SS. SUPERIOR COURT DOCKET NO. HELEN KELLNER, ) Plaintiff ) VS. ) NOTICE OF APPEAL FROM GRANT AND APPROVAL OF SPECIAL PERMIT AND JAMES P. MAYNARD, TRUSTEE) VARIANCE UNDER GENERAL LAWS MAYNARD REAL ESTATE, ) CHAPTER 40A SEC. 17 TRUST; FRANK SERIO, JR. , ) CHAIRMAN, ALFRED E. ) FRIZELLE, WILLIAM J . ) SULLIVAN, AUGUSTINE W. ) NICKERSON, WALTER F. ) SOULE, ANNA P. O'CONNOR, ) RAYMOND A. VINENZIO, as } members of the Board of ) Appeals of the Town of ) North Andover, ) Defendants) Notice is hereby given that Helen Kellner the above named plaintiff hereby appeals the decision and approval of the Board of Appeals of the Town of North Andover of the variance and Special Permit of James P. Maynard, Trustee Maynard Real Estate Trust on November 18, 1986 and filed with the Town Clerk on December 22 , 1986 (The complaint is hereby attached and made a part hereof) . Which Appeal has been filed and entered int he Essex Superior Court on January , 1986 . Dated: January � , 1987 - Robert 4chusetts uire L RUDOLPH, NER 64 Centra Georgetow01833 Tel: ( 617 ) 362-8111 i6 COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. SUPERIOR COURT HELEN KELLNER, } Plaintiff ) ) VS. } COMPLAINT and APPEAL UNDER JAMES P. MAYNARD, TRUSTEE) GENERAL LAWS CH. 40A SEC. 17 MAYNARD REAL ESTATE, ) TRUST; FRANK SERIO, JR. , ) CHAIRMAN, ALFRED E. ) FRIZELLE, WILLIAM J. ) SULLIVAN, AUGUSTINE W. } NICKERSON, WALTER F. ) SOULE, ANNA P. O'CONNOR, RAYMOND A. VINENZI09 as } members of the Board of ) Appeals of the Town of ) North Andover, } Defendants) 1 . The Plaintiff Helen Kellner is the owner of a single family dwelling located at 920 Turnpike Street, North Andover, and is an abutter and a person aggrieved by the decision of the Board of Appeals of the Town of North Andover dated November 18, 1986 . 2 . The Defendants Frank Serio, Jr. , Chairman, 250 Hillside Road, Alfred E. Frizelle, 131 Appleton Street; William J. Sullivan, 405 Salem Street; Augustine W. Nickerson, 100 Moody Street; Walter F. Soule, 70 Raleigh Tavern Lane; Anna P. O'Connor, 88 Martin Avenue; Raymond A. Vinenzio, 11 Appledore Lane, are the duly constituted regular and alternate members of the Board of Appeals of North Andover, and all reside in the Town of North Andover. 3 . The Defendant, James P. Maynard, Trustee, Maynard Real Estate Trust has a usual place of business at 740 Main Street, Waltham, Massachusetts , petitioned the North Andover Board of Appeals for a special permit and a four variances on October 23, 1986 to remove an existing residence and construct a commercial building and use the premises for a commercial day care center of approximately 125 children with 22 staff members. Count I 4 . In a decision dated November 18, 1986, and filed with the Town Clerk on December 22, 1986, the Board of Appeals granted a Special Permit under Section 4 . 121 Paragraph 19 of the North Andover Zoning Board, on a petition submitted by the Defendant, James P. Maynard, Trustee, Maynard Real Estate Trust dated October 23, 1986 . A copy of the decision is annexed hereto as Exhibit "A" and made a part hereof. 5 . On November 18, 1986 the members of the Board of Appeals of the Town of North Andover held a hearing to consider not only the Special Permit but all four variances. There was opposition from the Planning Board, the Town Planner, abutters and several residents in the same immediate zone area. The criteria for the granting of the Special Permit and the conditions for approval are contained in the Zoning By-Laws Sec. J0. 3 ( 1 ) . The criteria for obtaining a variance are contained in M.G.L. Ch. 40A Sec. 10 and the Zoning B - y Laws 10.4. The criteria are distinctly different and therefore the hearing for Special Permit using the criteria and evidence for supporting variances is in violation of the Zoning statutes and by-laws. 6. The members of the Board of Appeals of the Town of North Andover have exceeded their authority in granting the Special Permit because they failed to comply with the Chapter 40A Sec. 9 which requires that Special Permits be issued subject to the provisions of the by-law, specifically Section 10. 31 ( 1) a-e of the Zoning By-Laws for the Town of North Andover. Evidence was submitted at the hearing that the location was unsafe for use as a commercial day care center because of its location adjacent to a heavily traveled highway and inadequate accessibility from Chestnut and Mill Street. No conditions or provisions were made for adequate or appropriate facilities. No conditions or provisions were made for the serious hazard to the children during their outside play or during the period when they were picked up or dropped off in regard to their safety and danger to other traveling vehicles. No conditions or provisions were made regarding the control of the children, the hours of operation, parking facilities, playground facilities, traffic patterns, egress and ingress, building plans, handicap requirements, hospital or medical facilities, alarms or fire apparatus,; adequate fences, pedestrian control and the many other provisions which would attend the care and custody of small children not unlike a public school. 7 . The Board of Appeals failed to consider the evidence submitted by the neighborhood regarding the adverse impact to the residential zone and specifically related to but not limited to the conversion of a residence to a commercial use. They also failed ,to consider the enormous safety hazard created by the new use in a residential neighborhood and did not provide safety conditions in violation of the Zoning By-Laws 10.31. COUNT II 8. In a decision dated November 18, 1986 , and filed with the Town Clerk of the Town of North Andover on December 22, 1986, the Board of Appeals granted four variances of Section 7 Paragraph 7 . 3 of the Zoning By-Law and Table two on a Petition submitted by the Defendant, James P. Maynard, Trustee, Maynard Real Estate, Trust. A copy of the decision is annexed hereto as Exhibit "A" and made a part hereof. 9 . On November 18, 1986 the members of the Board of Appeals of the Town of North Andover held a hearing to consider not only the Special Permit but all four variances. There was opposition from the Planning Board, the Town Planner, Abutters and several residents in the same immediate zoned area. The criteria for obtaining a variance are contained in M.G.L. Ch. 40A Sec. 10 and the Zoning By-Laws 10. 4 . The criteria are distinctly different and therefore the hearing for variance using the Special Permit and evidence supporting a Special Permit for approval is in violation of the Zoning statutes and by-laws. The criteria for the granting of the Special Permit and the conditions for approval are contained in the Zoning By-Laws See. 10. 3 ( 1 ) . 10 . The granting of a variance to change the setback requirements from Route 114 exceeded the authority of the Board of Appeals since this setback requirement is consistent with _state policy regarding a public highway and is based on the safety of the traveling public including the ceitizens of North Andover. Modification of this , setback on Route 114 could and would mean an erosion of the entire policy and an unnecessary risk. If a Special Permit of use is granted to provide for the care and custody of small children an even more unsafe and dangerous condition would be created in violation of the criteria contained in M.G.L. Ch. 40A Sec . 1A and also the specific criteria contained in Sec. 10 cif Chapter 40A. 11 . The Board of Appeals further exceeded it authority in granting inducing setbacks on both Mill and Chestnut Street below the necessary 30 feet as shown in table 2 (attached hereto and made a part hereof as Exhibit "B" ) for the applicable residential zone, namely R-2. The Board authorized a 50 percent reduction on both Mill and Chestnut Streets seriously deviating from the Zoning By laws 1 s without justification. There is an existing residential building on the premises would more nearly comply with the setback requirements authorized by the zoning by-law. 12 . The Board of Appeals exceeded their authority in failing to to find or substantiate the criteria contained in Chapter 40A Sec. 10, particularly evidence of substantial hardship. The only evidence submitted was that of a financial loss conditioned on the fact that the present home were removed which is self created hardship. The evidence abd fubdubgs are restricted to the profitability of the sale of the lot. The Zoning by-law created no hardship since the lot is owned and occupied as a residence and can be sold as .a residence. Further, this use conforms with the zone and characteristics of the neighborhood. The size of the project mainly creates the basis for the variance. This is entirely within the control of the petitioner. The new use of the land is also controlled by the petitioner. 13 . The Board of Appeals granted the variances contrary to the interest of the abutters, the neighbors, the Zoning Statute, the Zoning By-laws, the Planning Board, the Town Planner and without satisfactory conditions or safeguards and in excess of their authority. WHEREAS, the Plaintiff requests this HonorableCourt to 1 . Hear all the pertinent evidence and determine the facts ; 2 . Determine and adjudge that the decision of the Board of Appeals approving the Special Permit requested by James P. Maynard, Trustee, Maynard Real Estate Trust on October 23 , 1986 was erroneous in law and fact and exceeded the Board's authority; 3 . Determine and adjudge that the decision of the Board of Appeals approving the variance requested by James P. Maynard, Trustee, Maynard Real Estate Trust on October 23, 1986 was erroneous in law and fact and exceeded the board's authority; 4 . Annul the decision of the Board of Appeals granting the ,Special Permit; 5 .. Annul the decision of the Board of Appeals granting the variance; 6 . Grant such further relief or justice as equity may require. AobertP. mit ed, Dated: January , 1987 , Esquire & KRONER 64 Central Street Georgetown, MA 01833 Tel (617 )352-8111 r77zS y t 4 f } TABLZ 2 SUMKWW OF DIMENSIONAL RRWIREMENTS Res. Res. Res. Res. Res. Bus. Bus. Rus. Bus. Gen. Ind. Ind. Ind. Ind. 1 2 3 4 567 1 27 3 4 Bus. 1 2 3 S Lot Area- 65.340 43,560 25,000 12,500 43,5608 25,000 25.000 120.000 80,000 25.000 60,000 80.000 435,600 50,000 Min. S.F. Height 35 35 35 35 35 35 35 35 60 45 55 .55 55 53 Maximum (ft.) street From- 175 ISO 125 100 150 125 125 300 200 125 ISO ISO ISO 150 tags-Minimum (ft.) Front set- 30 30 30 308 30 30 25 100 SO 25 50 SO 10010 30 back Minimum (ft.) Side set- 30 30 20 15 25 202 252 503 503 252 503 503 20010 202 back Minimus (ft.) Rear sett- 30 30 30 30 30 302 302 503 5o 352 503 503 20010 302 back Minimus (ft.) Floor Area H/A N/A N/A N/A 0.7511 0.30:1 0.75:1 0.40:1 1.5061 H/A 0.50sl 0.5061 0.5081 0.5061 Ratio-Maximsa, Lot Coverage N/A N/A N/A N/A 201 308 351 301 251 351 351 356 35611 351 Maximum Dwelling unit H/A H/A N/A H/A Multi-family=N/A N/A N/A H/A N/A N/A N/A H/A N/A Density-Maxi- - Townhouses? mum/acre CERTIFICATE OF SERVICE I , Robert P. Rudolph, attorney for Helen Kellner in the Foregoing action certify that I have served copies of : Notice of Appeal from Grant and Approval of Special Permit and Variance under MGL Ch. 40A Sec. 17 on the parties to this action by mailing copies thereof this day postage prepaid to: Town Clerk Town of North Andover 120 Main Street North Andover, MA 01845 Dated: January , 1987 obert YV. Ruof , Esquire UDOLPH, AND W do KRONER 64 Central St t Georgetown, MA 01833 (617 ) 352-8111 .. } A ZO RUDOLPH, ANDREWS & KRONER T&O'l Al'l (1`- RIN Atto»M at Law Ndt} 1 4 JAI i S=Y-FOUR CENTRA[.STREET J POST 0"M Box 238 J J GEORGCMWN,MMUCHtrMM 01833 RoUn P.RUDM M ROMW E.AMRMM TMMMNB MnCML S.KRMM (617)352-8111,352-6023 January 9, 1987 Essex Superior Court 34 Federal Street Salem, Massachusetts 01970 Re: Kellner v. Maynard, Trustee, etals Dear Clerk: Enclosed please find Cover Sheet, Complaint, NOtice of Appeal, Certificate of Service and check in the amount of $55.00 as filing fee for filing in regard to the above entitled matter. Kindly file same. Thank you for your courtesy. r ul Robert P. Rud h RPR/kas Enclosures 1 COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. SUPERIOR COURT HELEN KELLNER, ) Plaintiff ) ) VS. ) COMPLAINT and APPEAL UNDER JAMES P. MAYNARD, TRUSTEE) GENERAL LAWS CH. 40A SEC. 17 MAYNARD REAL ESTATE, ) TRUST; FRANK SERIO, JR. , ) CHAIRMAN, ALFRED E. ) FRIZELLE, WILLIAM J. . ) SULLIVAN, AUGUSTINE W. ) NICKERSON, WALTER F. ) SOULE, ANNA P. O'CONNOR, ) RAYMOND A. VINENZI09 as ) members of the Board of ) Appeals of the Town of ) North Andover, ) Defendants) 1 . The Plaintiff Helen Kellner is the owner of a single family dwelling located at 920 Turnpike Street, North Andover, and is an abutter and a person aggrieved by the decision of the Board of Appeals of the Town of North Andover dated November 18 , 1986. 2 . The Defendants Frank Serio, Jr. , Chairman, 250 Hillside Road, Alfred E. Frizelle, 131 Appleton Street; William J . Sullivan, 405 Salem Street; Augustine W. Nickerson, 100 Moody Street; Walter F. Soule , 70 Raleigh Tavern Lane; Anna P. O'Connor, 88 Martin Avenue; Raymond A. Vinenzio, 11 Appledore Lane, are the duly constituted regular and alternate members of the Board of Appeals of North Andover, and all reside in the Town of North Andover. I 3 . The Defendant, James P. Maynard, Trustee, Maynard Real Estate Trust has a usual place of business at 740 Main Street, Waltham, Massachusetts, petitioned the North Andover Board of Appeals for a special permit and a four variances on October 23, 1986 to remove. an existing residence and construct a commercial building and use the premises for a commercial day care center of approximately 125 children .with 22 staff members. r Count I 4 . In a decision dated November 18, 1986, and filed with the Town Clerk on December 22,1986, the Board of Appeals granted a Special Permit under Section 4 . 121 Paragraph 19 of the North Andover Zoning Board, on a petition submitted by the Defendant, James P. Maynard, Trustee, Maynard Real Estate Trust dated October 23, 1986 . A copy of the decision is annexed hereto as Exhibit "A" and made a part hereof. 5 . On November 18, 1986 the members of the Board of Appeals of the Town of North Andover held a hearing to consider not only i the Special Permit but all four variances. There was opposition from the Planning Board, the Town Planner, abutters and several residents in the same immediate zone area. The criteria for the granting of the Special Permit and the conditions for approval are contained in the Zoning By-Laws Sec. 10. 3 ( 1 ) . The criteria for obtaining a variance are contained in M.G.L. Ch. 40A Sec. 10 and the Zoning By-Laws 10.4. The criteria are distinctly different and therefore the hearing for Special Permit using the criteria and evidence for supporting variances is in violation of the Zoning statutes and by-laws. 6 . The members of the Board of Appeals of the Town of North Andover have exceeded their authority in granting the Special Permit because they failed to comply with the Chapter 40A Sec. 9 which requires that Special Permits be issued subject to the provisions of the by-law, specifically Section 10 .31 ( 1 ) a-e of the i Zoning By-Laws for the Town of North Andover. Evidence was submitted at the hearing that the location was unsafe for use as a commercial day care center because of its location adjacent to a heavily traveled highway and inadequate accessibility from Chestnut and Mill Street. No conditions 'or provisions were made for adequate or appropriate facilities. No conditions or provisions were made for the serious hazard to the children during their outside play or during the period when they were picked up or r dropped off in regard to their safety and danger to other traveling _ vehicles. No conditions or provisions were made regarding the 1 control of the children, the hours of operation, parking facilities , playground facilities , traffic patterns, egress and ingress, building plans , handicap requirements, hospital or medical facilities, alarms or fire apparatus ,; adequate fences, pedestrian control and the many other provisions which would attend the care and custody of small children not unlike a public school. 7 . The Board of Appeals failed to consider the evidence submitted by the neighborhood regarding the adverse impact to the residential zone and- specifically related to but not limited to the conversion of a residence to a commercial use . They also failed to consider the enormous safety hazard created by the new use in a residential neighborhood and did not provide safety conditions in violation of the Zoning By-Laws 10.31 . COUNT II 8. In a decision dated November 18, 1986, and filed with the Town Clerk of the Town of North Andover on December 22, 1986, the Board of Appeals granted four variances of Section 7 Paragraph 7 . 3 of the Zoning By-Law and Table two on a Petition submitted by the Defendant, James P. Maynard, Trustee, Maynard Real Estate, Trust. A copy of the decision is annexed hereto as Exhibit "A" and made a part hereof. 9 . On November 18, 1986 the members of the Board of Appeals of the Town of North Andover held a hearing to consider not only the Special Permit but all four variances.. There was opposition from the Planning Board, the Town Planner, Abutters and several residents in the same immediate zoned area. The criteria for obtaining a variance are contained in M.G.L. Ch. 40A Sec. 10 and 2 . Determine and adjudge that the decision of the Board of Appeals approving the Special Permit requested by James P. Maynard, Trustee, Maynard Real Estate Trust on October 23 , 1986 was erroneous in law and fact and exceeded the Board's authority; 3 . Determine and adjudge that the decision of the Board of Appeals approving the variance requested by James P. Maynard, Trustee, Maynard Real Estate Trust on October 23 , 1986 was erroneous in law and fact and exceeded the board's authority; �. Annul the decision of the Board of Appeals granting the Special Permit; 5 .. Annul the decision of the Board of Appeals granting the variance; 6. Grant such further relief or justice as equity may require. PRestAtNER , 77Dated: January y , 1987uire, ANDR 64 Central Street Georgetown, MA 01833 Tel: (617)352-8111 TAX& 2 SUM MAW OF DIMENSIONAL REQUIR>QONTS - Res. Res. Res. Res. Res. Bus. Bus. Bus. Bus. Gen. Ind. Ind. Ind. Ind. 1 2 3 4 56 7 1 27 3 4 Bus. 1 2 3 S Lot Area- 65.340 43.560 25,000 12.500 43.5603 25,000 25.000 120,000 80,000 25,000 80,000 80.000 435,600 50,000 Min. S.F. Height 35 35 35 35 35 35 35 35 60 45 55 55 55 55 Maximum (ft.) Street Fron- 175 150 125 100 ISO 125 125 300 200 125 150 150 150 150 tags-Minimum (ft.) ; Front Set- 30 30 30 308 30 30 25 100 50 25 50 SO 100f0 30 back Minimum (ft.) 1 %D Side Set- 30 30 20 113 25 2022.52 503 503 252 503 503 20010 202 ;D back Minimum Rear Set- 30 30 30 30 30 303 303 503 50 353 503 503 20010 303 back Minimum (ft.) Floor Area N/A N/A ' N/A N/A 0.75:1 0.30el 0.75:1 0.40x1 1.50:1 N/A 0.50:1 0.50:1 0.50:1 O.S0e1 Ratio-Maximuz. Lot Coverage N/A N/A N/A N/A 201 300 351 301 251 350 356 350 35111 351 Maximum Dwelling Unit N/A N/A N/A N/A Mult1-fAmi1y13 N/A N/A N/A N/A K/A N/A N/A N/A N/A Density-Maxi- - Townhouses? swum/acre laws without justification. There is an existing residential building on the premises would more nearly comply with the setback requirements authorized by the zoning by-law. 12 . The Board* of Appeals exceeded their authority in failing to to find or substantiate the criteria contained in Chapter 40A Sec. 10, particularly evidence of substantial hardship. The only evidence submitted was that of a financial loss conditioned on the fact that the present home were removed which is self created hardship. The evidence abd fubdubgs are restricted to the profitability of the sale of the lot. The Zoning by-law created no hardship since the lot is owned and occupied as a residence and can be sold as .a residence. Further, this use conforms with the zone and characteristics of the neighborhood. The size of the project mainly creates the basis for the variance. This is entirely within the control of the petitioner. The new use of the land is also controlled by the petitioner. 13 . The Board of Appeals granted the variances contrary to the interest of the abutters, the neighbors, the Zoning Statute, the Zoning By-laws, the Planning Board, the Town Planner and without satisfactory conditions or safeguards and in excess of their authority. WHEREAS, the Plaintiff requests this Honorable Court to 1 . Hear all the pertinent evidence and determine the facts ; the Zoning� ning B -Laws I0.4 . Y The criteria are distinctly different and therefore the hearing for variance using the Special Permit and evidence supporting a Special Permit for approval is in violation of the Zoning statutes and by-laws . The criteria for the granting of the Special Permit and the conditions for approval are contained in the Zoning By-Laws Sec. 10. 3. ( 1) . 1 10. The granting of a variance to change the setback requirements from Route 114 exceeded the authority of the Board of Appeals since this setback requirement is consistent with state policy regarding a public highway and is based on the safety of the traveling public including the ceitizens of North Andover. Modification of this setback on Route 114 could and would mean an erosion of the entire policy and an unnecessary risk. If a Special Permit of use is granted to provide for the care and custody of small children an even more unsafe and dangerous condition would be created in violation of the criteria contained in M.G.L. Ch. 40A Sec. 1A and also the specific criteria contained in Sec. 10 of Chapter 40A. f i 11 . The Board of Appeals further exceeded it authority in granting inducing setbacks on both Mill and Chestnut Street below the necessary 30 feet as shown in table 2 (attached hereto and made a part hereof as Exhibit "B" ) for the applicable residential zone, namely R-2 . The Board authorized a 50 percent reduction on both Mill 1 and Chestnut Streets seriously deviating from the Zoning By- n n Ryf C! VI 11 AMOLM f•., toss DEC 22 1� 40 PH '86 TOWN of NOR7H ANDov>vx r ,a MASSACHUSW Ts BOARD OF APPEALS 1� Vt;:ceVoi. ';he. Town NOTICE OF DECISION E' Date . . .22R . 1906 Petition No.. . . . . 3.4-0.7. . . . . . . . . . Data of Hearing. . November: 18, 19 86 Petition of James P. Maynard, Trustee, Maynard Real Estate Trust Premises affected . . . . . 7 31 Chestnut S t. . Referring to the above petition for a variation from the requirements of the zoning. :bynlaws Section 7, Para. 7. 3 and Table 2 and a .Special Permit of Section 4.121, Para... .19. ... . . . . . . . . . . . . . . . . . . . . . . . so as to permit . the. -construction -of •a• .clay. care. center . . . . . . . . . . . . . . . . . . . . . . . After a public hearing given on the above date,the Board of Appeals voted to . GRANT. . . . the variances and Special Permit . and hereby authorize the Building Inspector to is= a the petitioner permit to . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . for the construction of the above work, based upon the following conditions: Please see attached e, ' Si8/1Cd �-a-µ -r✓ . . . . Chairman. . . . . . .. . Vi¢e-ghairman in Ox pn.. Gle.rk . . . . .Anna. C'.Conno.r. .. .. .. . . . . . . . . g= . . . . . . . . ;t Board of Appeals rr No concrete information- was presented to the Board regarding any plans' of the State to widen the highway at this location. The / Board feels that any such work could still be accommodated with the building . located as proposed. The impact . of" the proposed design would be minimal and not* hazardous or 'detrimental to the area. The Board recognized and sympathized with objectors, complaints about traffic, but feels the concern is misplaced .with regard to the proposal before the Board. , It is nota problem which would be changed regardless of any action taken on the proposed site. . The Board finds that, of all the uses allowed in an R-2 zone, the proposed child care center is the use most din keeping with the use of the area. ' The site . as proposed will not adversely impact the area, but will act as an allowed transitional use from office and commercial to residential in the area. The Board finds the site with .the improvements as proposed, has adequate and appropriate faci.lities provided to accommodate the intended use. For the aforementioned reasons the Board finds that the provisions of Section- 10. 31 of the Zoning By-Law have been, satisfied and ,further that the provisions of Section 10. 4 have been satisfied, in particular due to the shape of the land in question that a, literal -enforcement of ' the .provisions, of the By-Law world involve a substantial hard-ship financial or otherwise to thep etitioner 'and the owner .of the property , and further that the relief granted herein is not of substantial detriment to the public good and does not nullify nor substantially derogate from intent of purpose of the Zoning By-Law. r }. .... 0. p 7 i } Upon a motion made by Mr. Frizelle, seconded by Anna O ' Connor, the Board VOTED : Four in favor, with Mr. Soule opposed, to grant the Special Permit and Variances as requested subject td the following conditions : 1 . That the sewer' -service from the building be connected to the sewer line in 'the street prior 'to the issuance of a building permit for the construction of the building. 2. That the existing dwelling be moved prior to May 1, 1987. It Ai i} 3. That a' three foot high white picket fence be placed around the parkinglot as shown: on the plan from Mill St. to-:'-*.- " Chestnut St. . 4. That the concrete steps and the shed shown on the plan be removed prior to the issuance of a building permit for the construction of the ,building. The Board finds the, following :. Upon review of the Traffic analysis by Norman 0. Abend the Board finds no significant problems or hazards would be created for either. vehicular or pedestrian traffic by the proposed use as the proposal will utilize Chestnut and Mill Streets for access. and egress which have been shown to be more than adequate to accommodate the proposed use. The Board is mindful of the testimony of residents citing an increase in traffic, however, the objections do not appear to be significant because the day care center traffic would not be a major traffic generator as set forth in the . traffic study. Furthermore, at some future pointin time, the intersection of Mill St. and Route 0114 is scheduled by• the state to have traffic signals installed. The presently .existing structure violates the set back requirements on Chestnut Street and those from Route #114. The proposed use though asking, £or a„ variation to .15 feet from Chestnut Street would constitute a lesser violation than currently exists. The requested variation to 80 Eeet setback -from Route 0114, would' only marginally change the' 90 foot set back violation of the existing building.. The site is unique in that it is a thin triangular parcel bounded on all sides by roads and adjacent to Route #114. At ' fts widest , it is 180 feet deep, making the impact of- the .set back requirements very substantial. A hardship exists in that a literal enforcement of the Zoning By-Law would almost constitute a taking of -the parcel in that by taking off the 30 feet set backs required on Chestnut Street and Mill Street, and the- 100 feet set back required on Route #114, ? -approximately 66, 195 square feet would be unusable on a 72, 745 square foot lot. This amounts to 913 of the property being ,non-usable : The area available for construction would be a thin triangle not readily usable without some exotic building ' design. A literal enforcement would amount to an extreme ' financial . hardship for the property owners with no commensurate benefit to the community. S ... , RECEPIF0 Z,+,.� CAN!FL TOW11i Ci "i ;t WORT" 4o-'-_DYER DEC 22 12 41 PH '86 TOWN OF NORTH ANDOVER MASSACHUSRTTS BOARD OF APPEALS ;1 be iti,� ths James P. stee Gate p{ rOff1Ge o{ the Maynard RealnEstau Estate, �n the 731 Chestnut Street Clerk' Petition # 34-87 December 22, 1986 Daniel Long , Town Clerk Town of North Andover 120 Main Street North Andover, MA 01845 Dear Mr. Long : The Board of Appeals held a public hearing on November 18, 1986, upon the application of James P. Maynard , Trustee, Maynard Real Estate, Trust , requesting a variation of Section 7, Paragraph 7. 3 of the Zoning By-Law and Table Two, and a Special Permit, Section 4. 121 Paragraph 19, so as to permit the construction of a day care center and relief of the 100 foot set back from Route #114, and relief of the 50 foot green space and 30 foot set back on Chestnut St. on the premises located at 731 Chestnut St. , North Andover, MA. The following members were present and voting : Frank Serio, Jr. , Chairman, Alfred E. Frizelle , Esq. , Vice Chairman, Augustine Nickerson, Clerk, Walter Soule and Anna O' Connor. The hearing was advertised in the North Andover Citizen on October 30 and November 6, 1986, and all abutters were notified by regular mail . At the hearing , evidence was received from the petitioner through Attorney John J. Willis , Jr. , which included the following : n (a) Site Plan showing proposed building location, i location of access and egress points, and parking and landscaping details. (b) Traffic analysis by Norman 0. Abend iden`�ifying present traffic patterns and projecting future changes which would occur as a result of the proposed use. (c) Photograph and package from "Children' s World" showing architectural styling , floor layouts , and operational characteristics of proposed structure . (d) Oral presentation of geographical and use characteristics of neighborhood and Route #114 in the vicinity of the site and along highway from Middleton town line to and beyond the site. Evidence was taken in favor of Petition from North Andover Building Inspector and Zoning Enforcement Officer Charles Foster by letter stating that proposal was appropriate for the area and in keeping with intent and purpose of ' the by-law. Letter from Chief of the North Andover Fire Department stating the project met his requirements for safety and access and egress. Letter suggested project might consider sprinkler system in building and that fire alarm systems be direct wired _ tn _the__Eire cation___— Letter from North Andover Planning Board stating standard opposition to variation of 100 foot set back requirement on Route #114. Oral opposition was expressed by residents on Chestnut Street and on Mill Road and vicinity regarding fears of increased traffic. ' Testimony was presented that vehicles travel at excessive rates of speed along Chestnut Street, and that the area was residential and should remain so. Oral opposition was also presented concerning historical character of presently existing structure. No testimony was presented concerning any possible solutions to the Historic Building, except that the Petitioner stated that the owner of the structure intended to relocate it to another site. Upon a motion made by Mr. Frizelle , seconded by Anna O ' Connor, the Board VOTED: Four in favor, with Mr. Soule opposed, to grant the Special Permit and Variances as requested subject to the following conditions : 1 . That. the sewer service from the building be connected to the sewer line in the street prior to the issuance of a building permit for the construction of the building. 2. • That the existing dwelling be moved prior to May 1 , 1987. 3. That a three foot high white picket fence be placed around the parking lot as shown on the plan from Mill St. to Chestnut St. . 4 4 . That the -.'woncrete steps and the shed shown on the plan be removed prior to the issuance of a building permit for the construction of the building. The Board finds the following : Upon -review of the Traffic analysis by Norman 0. Abend the Board finds no significant problems or hazards would be created for either vehicular or pedestrian traffic by the proposed use as the proposal will utilize Chestnut and Mill Streets for access and egress which have been shown to be morethanadequate to accommodate the proposed use. The Board is mindful of the testimony of residents citing an increase in traffic, however, the objections do not appear to be significant because the day care center traffic would not be a major traffic generator as set forth in the traffic study. Furthermore, at some future , point in time , the intersection of Mill St. and Route 0114 is scheduled by the state to have traffic signals installed. The presently existing structure violates the set back requirements on Chestnut Street and those from Route #114. The proposed use though asking for a variation to 15 feet from �..... :-.. Che-&t.L:lit _Str*St would -.rangtir .t than currently exists. The requested variation to 80 feet set back from Route #114, would only marginally change the 90 foot set back violation of the existing building. The site is unique in that it is a thin triangular parcel bounded on all sides by roads and adjacent to Route #114. At its widest , it is 180 feet deep, making the impact of the set back requirements very substantial. A hardship exists in that a literal enforcement of the Zoning . By-Law would almost constitute a taking of the parcel in that by taking off the 30 feet set backs required on Chestnut Street and Mill Street, and the 100 feet set back required on Route #114, approximately 66, 195 square feet would be unusable on a 72, 745 square foot lot. This amounts to 91% of the property being non-usable . The area available for construction would be a thin triangle not readily usable without some exotic building design. A literal enforcement would amount to an extreme financial hardship for the property owners with no commensurate benefit to the community. No concrete information was presented to the Board regarding any plans of the State to widen the highway at this location. The Board feels that any such work could still be accommodated with the building located as proposed. The impact of the proposed design would be minimal and not hazardous or detrimental. -to the area. The Board recognized and sympathized with objectors , complaints about traffic, but feels the concern is misplaced with regard to the proposal before the Board. It is not a problem which would be changed regardless of any action taken on the proposed site. The Board finds that of all the uses allowed in an R-2 zone , the proposed child care center is the use most in keeping with the use of the area. The site as proposed will not adversely impact the area, but will act as an allowed transitional use from office and commercial to residential in the area. The Board finds the site with the improvements as proposed, has adequate and appropriate facilities provided to accommodate the intended use. For the aforementioned reasons the Board finds that the provisions of Section 10. 31 of the Zoning By-Law have been satisfied and further that the provisions of Section 10. 4 have been satisfied, in particular due to the shape of the land in ---` - •- .�fi.lllsL tba" liter&&- emfar'.raa&"t aF t" of the By-Law would involve a substantial hard-ship financial or otherwise to the petitioner and the owner of the property, and further that the relief granted herein is not of substantial detriment to the public good and does not nullify nor substantially derogate from intent of purpose of the Zoning By-Law. Sincerely, BOARD OF APPEALS Fr nk Seri"Jr Chairman AEF/jib ATTEST: . f ATlu® Copy COO* DEC ZZ iZ 1 , tM{ UU TOWN OF NORTH ANDOVER Town 01ork MASSACHUSETTS BOARD OF APPEALS peal s NOV aP �1 c Na ��! G 1� d �J1 •\1'17 W of t� •nom of the James P. Maynard , Trustee nate 0i{ire Maynard Real Estate, Trust jit\ 731 Chestnut Street Petition 0 34 -87 December 22, 1986 Daniel Long , Town Clerk Town of North Andover 120 Main Street North Andover, MA 018'45 Dear Mr. Long : The Board of Appeals held a public hearing on November 18, 1986, upon- the application of James P. Maynard , Trustee, Maynard Real Estate, Trust , requesting a variation of Section 7, Paragraph 7. 3 of the Zoning By-Law and Table Two, and a Special Permit, Section 4. 121 Paragraph 19, so as to permit the construction of a day care center and relief of the 100 foot set back from Route 0114 , and relief of the 50 foot green space and 30 foot set back on Chestnut St . on the premises located at 731 Chestnut St. , North Andover, MA. The following members were present and voting : Frank Serio , Jr. , Chairman, Alfred E. Frizelle , Esq. , Vice Chairman, Augustine Nickerson, Clerk, halter Soule and Anna O' Connor. The hearing was advertised in the North Andover Citizen on October 30 and November 6, 19369 and all abutters were notified by regular mail. , At the hearing , evidence was received from the petitioner through Attorney John J. Willis, Jr. , which included the following : (a) Site Plan showing proposedibuilding location, location of access and egress. points , and parking and landscaping details. (b) Traffic analysis by Norman O. Abend iden" ifying present traffic patterns and projecting future changes which would occur as a result of the proposed use. (c) Photograph and package from "Children' s World" showing architectural styling, floor layouts , and operational characteristics of proposed structure. (d) Oral presentation of geographical and use characteristics of neighborhood and Route #114 in the vicinity of the site and along highway from Middleton town line to and beyond the site. Evidence was taken in favor of Petition from North Andover Building Inspector and Zoning Enforcement Officer Charles Foster by letter stating that proposal ' was appropriate for the area and in keeping with intent and purpose of ' the by-law. Letter from Chief of the North Andover Fire Department stating the project met his requirements for safety and access and egress . Letter suggested project might consider sprinkler system in building and that fire alarm systems be direct wired to- the _fire_stati_on_.___ _- _ -- -- - --- Letter from North Andover Planning Board stating standard opposition to variation of 100 foot set back requirement on Route #114. Oral opposition was expressed by residents on Chestnut Street and on Mill Road and vicinity regarding fears of increased traffic. ' Testimony was presented that vehicles travel at excessive rates of speed along Chestnut Street, and that the area was residential and should remain so. Oral opposition was also presented concerning historical character of presently existing structure. No testimony was presented concerning any possible solutions to the Historic Building, except that the Petitioner stated that the owner of the structure intended to relocate it to another site. Upon a motion made by Mr. Frizelle , seconded by Anna O ' Connor, the Board VOTED: Four in favor, with Mr. Soule opposed, to grant the Special Permit and Variances as requested subject to the following conditions : 1 . That, the sewer service from the building be connected to the sewer line in the street prior to the issuance of a building permit for the construction of the building. 2. That the existing dwelling be moved prior to May 1, 1987. 3. That a three foot high white picket fence be placed around the parking lot as shown on the plan from Mill St. to Chestnut St. . 4 . That the *~oncrete steps and the shed shown on the plan be removed prior to the issuance of a building permit for the construction of the building. The Board finds the following : Opon -review of the Traffic analysis by Norman 0. Abend the Board Finds no significant problems or hazards would be created for either vehicular or pedestrian traffic by the proposed use as the proposal 'will utilize Chestnut and Mill Streets for access and egress which have been shown to be more than adequate to accommodate the proposed use. The Board is mindful of the testimony of residents citing an increase in traffic, however, the objections do not appear to be significant because the day care center traffic would not be a major traffic generator as set forth in the traffic study. Furthermore, at some future point 'in time , the intersection of Mill St. and Route #114 is scheduled by the state to have traffic signals installed. The presently existing structure violates the set back requirements on Chestnut Street and those from Route #114. The proposed use though asking for a variation to 15 feet from C.aestnu..t St_r_cet .wQu1ds.oasti_tute.-..les-scr _­IolatLoa tharL , currently exists. The requested variation to 80 feet set back from Route #114, would only marginally change the 90 foot set back violation of the existing building. The site is unique in that it is a thin triangular parcel hounded on all sides by roads and adjacent to Route #114. At its widest , it is 180 feet deep, making the impact of the set back requirements very substantial. A hardship exists in that a literal enforcement of the Boning By-Law would almost constitute a taking of the parcel in that by taking off the 30 feet set backs required on Chestnut Street and ?Rill Street , and the 100 feet set back required on Route #114, approximately 66, 195 square feet would be unusable on a 72, 745 square foot lot. This amounts to 91% of the property being non-usable . The area available for construction would be a Chin triangle. not readily usable without some exotic building design. A literal enforcement would amount to an extreme financial har(!ship for the property owners with no commensurate benefit to the community. No concrete information was presented to the Board regarding any plans of the State to widen the highway at this location. The Board feels that any such work could still be accommodated with the building located as proposed. The impact of the proposed design would be minimal and not hazardous or detrimental•. to the area. The Board recognized and sympathized with objectors, complaints about traffic, but feels the concern is misplaced with regard to the proposal before the Board. It is not a problem 'which would be changed regardless of any action taken on the proposed site. The Board finds that of all the uses allowed in an R- 2 zone , the proposed child care center is • the use most in keeping with the use, of the area. The site as proposed will not adversely impact the area, but will act as an allowed transitional use from office and commercial to residential in the area. The Board finds the site with the improvements as proposed, has adequate and appropriate facilities provided to accommodate the . intended use. For the aforementioned reasons the Board finds that the provisions of Section 10. 31 of the Zoning By-Law have been satisfied and further that the provisions of Section 10. 4 have been satisfied, in particular due to the shape of the land in _... question that. a Iiteral_atiforcemetit of --the px-uvis.i_ons..of. thr.___. _. By-Law would involve a substantial hard-ship financial or. otherwise to the petitioner and the owner of the property , and further that the relief granted herein is not of substantial detriment to the public good and does not nullify nor substantially .derogate from intent of purpose of the Zoning By-Law. Sincerely , BOARD OF APPEALS -7 Frank Serio Jr. Chairman AEF/jib t • •. pass • ' ►.SgTVW 11' QEC 2Z f2' 40 PH '86 �• H �� TOWN OF NORTH ANDOVER t• :1 l.' fi i�'=: MASSACHUSETTS BOARD. OF APPEALS NOTICE OF DECISION Petition No.. . . . . 34- R7. . . . . . . . . . Date of Hearing. .Novamb r- 18 0. 19 8 6 Petition of .James P. MaXnard, Trustee, Maynard Real Estate Trust Ammises affected . . . . . . . 7 31 Chestnut S t., . . . . . . . . . . . . . . . .. . . . . . . I . . . . . . . . . . . . Referring to the above petition for a variation from the requirements of the zoni-ng, •by-laws Section 7, Para. 7. 3 and Table 2 and a Special Permit of Section 4 .121 , Para . .i9. _. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . so as to permit . the. aonstrucbion• •of •a•-day -care. •center . . . . . . . . . . . . . . •'• After a public hearing given on the above date, the Board of Appeals voted to . GRANT. . . . the variances and Special Permit and hereby authorize the Building Inspector to issue a permit to . . . . . . the petitioner. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . for the construction of the above work, based upon the following conditions: Please see attached Signed - . . , , , , , k'rank, Serio,,, , �r., ,, Chairman• . . . . . . . Vf ge..chairman AuguSt,f pp_. .N;L.cke.Kspn Cle.xk Anna. Q�Connar. . . . . . . . . . . . . . . Board of Appeals Upon a motion made by Mr. Frizelle , seconded by : Anna O ' Connor , the Board VOTED: Four in favor, with Mr. Soule opposed , to grant the Special Permit and Variances as requested subject td the following 'conditions : 1. 1 . That the sewer -service from the building be connected to the sewer line in the street prior 'to the issuance of a building permit for the construction of the building. 2. That .the existing dwelling be moved prior to May 1 , 1987. 3. That a' three foot 'high white picket fence be placed around the parking 'lot as shown on the plan from, Mill St. to::•. Chestnut St. . -4. That the concrete steps and the shed shown on the i plan be removed prior to the issuance of a building permit for the construction of the building._ The Board finds the following : Upon review of the Traffic analysis by Norman 0. Abend the Board finds no significant problems or hazards would be created for either. vehicular or pedestrian traffic by the proposed use as the proposal will utilize- Chestnut and Mill Streets for access and egress which have been shown to be more than adequate to accommodate the proposed use.. The Board is mindful of the testimony of residents- citing an increase in traffic , however, the objections do not- appear to be significant because the day care center traffic would not be a major traffic generator. as set forth in the traffic study. Furthermore , at some future point. in time,. the intersection of Mill St. and Route #114 is scheduled by• the state to have traffic signals installed. The presently existing structure violates the' set back requirements on Chestnut Street and those from Route #114. . The proposed use though asking for a variation to .1S feet from Chestnut Street would constitute a lesser violation than currently exists. The requested variation to 80 feet set back from Route 0114 , would' only marginally change the 90 foot se.t. back violation of the existing building,. The site is unique in that it is a thin triangular parcel bounded on all sides by roads and adjacent to Route 0114. It its widest, it is 180 feet deep, making the impact of- the .set back requirements very substantial. A hardship exists in that a literal enforcement of the Zoning By-Law would almost constitute a taking of the parcel in that by taking off the 30 feet set backs required on Chestnut Street and set back required on Route #114, Mill Street, and the- 100 feet q •approximately 66, 195 square feet would be unusable on a 72 , 74S square foot lot. This amounts 'to 91% of the property being non-usable : The area available for construction would be a � thin triangle not readily usable without some exotic building ' design. A literal enforcement would amount to an extreme financial . hardship for the property owners with no commensurate benefit to the community. No concrete information- was presented to the Board regarding any plans of the State to widen the highway at this location. The Board feels that any such work could still be accommodated with the building . located as proposed. The impactof the proposed design would be minimal and not' 7 } hazardous or detrimental to the area. The Board recognized and sympathized with objectors , complaints about traffic, but feels the concern is misplaced .with regard to the proposal before the Board. . -, It is nota problem which would be changed regardless of any action taken on the proposed site. The Board finds that- of all the uses allowed in an R-2 zone , the proposed child care center is the use most in keeping 'with the use of the area. The site - as proposed will not adversely impact the area, but will act as an allowed transitional use from office and commercial to residential in the area. The Board finds the site with the improvements as proposed , has adequate and appropriate faci.lities provided, to accommodate the intended use. For the aforementioned reasons the Board finds that the provisions of Section. 10. 31 of the Zoning By-Law have been- satisfied and further that the provisions of Section 10. 4 have been satisfied, in particular due to the shape of the land in question that a literal enforcement of the provisions of the By-Law would involve a substantial hard-ship financial or otherwise to the petitioner and the owner . of the property , and further that the relief granted herein is. not of- substantial detriment to the public good and does not nullify nor substantially derogate from intent of purpose of the Zoning By-Law. f i r ` Ilec:ci•tc:d by Town Clerk- TOW lerk-OaW d1'-i ER ��t 3 2 zIPM `86 T( TN CLC NORTH ANDOVER, MASSACHUSETTS BOARD OF APPEALS APPI,ICATION FOR RELIEF PROM THE REQUIRC MENTS OF THE ZONING ORDINANCE JAMES P. MAYNARD, TRUSME OF 740' MAN STREET Applicant mAyNARD REALgATE TRUST_ �_�Address Ng1LTHAM, 1 4=4 1. Application is hereby made: a) For a variance from the requirements of Section 7 . Paragraph 7.3 and Table 2 . of the Zoning By Laws . b) For a Special Permit under Section4.121Paragraph`19_of, the Zoning By Laws 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 731 Street . , Q b) Premises. aff•ected are property with frontage on the North ( ) South ( x) East .( ) West ( ) side of Chestnut Street , and known as No. 731 Chestnut - Street . c ) Premises affected are in Zoning District R2 and the premises a f f ,c ted have an area of l.6WacreMqVj00a0d3mcxt and frontage of 700 feet . 3. Ownership a)' Name and address of owner ( if joint ownership, give all names ) : CHARLES J. CARRELL DaL-e of Purchase. Previous Owner b) If applicant is not owner , check his/her interest in the premises: x Prospective Purchaser _Lesee other (explain) � Sipe of proposed building:' front;_ feet deep; Height stories; _feet . a) Approximate date of erection: b) Occupancy or use of each floor : c ) Type of construction: _ ______ _`__ tA.b� �_ � feet front; feet deep; 5 . sizes of >•xi �tittg building: / r. • a) Approximate A proximate date of erection: b) Occupancy or use of each floor : r. ) Type of construction: 6. Has there been a previous appeal , under zoning, on these premises? No If so, when? Description of relief sought on this petition Special Permit to use thesite for a day care center and variation of the 100 footran - llT equ a enn of no building to an 80 foot setback, and variation of the 50 foot greenspac:e require- menf-o-a'32'-fool grat^►t�`WXMtrdi of�Tie O'3•a'a�s�t aZ�Z' r3�iZ sfrAt�-Sgr�et F3. I ell e tl the Registry of Deeds in Book Page!_----- hand 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 agree to pay the filing fee, advertising in newspaper , and incidental e:cpcnses* natu e ,o f= k�etit oner�s - g Every' application for action by. the Board shall be made on a form approved bNr the Board . These forms shall be furnished by the Clerk upon request . *, ycommunication purporting to be an application shall be treated as mere t -rice of intention to seek relief until such time as it is made on the n;_f.icial application form. All information called for by the form shall :_-U furnished by the applicant in the manner ,therein �prescribed. Every application shall be submitted with a list of "Parties In 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 a!:utters within three hundred feet ( 300 ' ) 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 rusponstiible k 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 . Lavery application shall be submitted with a plan of land approved by the iioard. 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 from the Board of Appeals upon request. LIST OF PARTIES IN INTEREST Name Address Associated Condominium Corp. 793 Turnpike Street, North Andover, MA 01845 Jefferson Office Park 39 Brighton Aye., Allsten, MA 02134 Ragweed Realty Trust Sol Turnpike Street, North Andover. MA 01845 Watts Regulator Co. P.O. Bax 6280 Laxarence, MA 01842 Bredbury Frayne 710 Chestnut .Street.•North Andover, MA 01845 (use additional sheets if necessary) ` Re: James P. Maynard, Trustee The property for which the variances and special permit is requestedr is unique in that due to its shape and location adjacent to Turnpike Street, a literal enforcement of the zoning by-laws would effectively make the lot non-usable. This would lead to an extreme economic hardship in that the lot would be non usable. The variances requested could be granted without any substantial detriment to the public good or without derogating from the intent or purpose of the by-law. The special permit for a child day care center may be granted as the area of the site is appropriate for the use intended. Traffic will be controlled thresh access and egress auto roads off the highway, without creating any vehicular or pedestrian hazards. The site when develgoed► will be an asset to the area aethetically and economically. Finally, at this. location, the use will blend with the surrounding usages in keeping. with the general intent and purpose of the by-law. ,n Oversized Maps on file with the Town