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COMMONWEALTH OF MASSACHUSETTS
ESSEX, SS. LAND COURT
MISC. CASE NO. 249120
HENRY KUCHARZYK, TRUSTEE )
OF HEFCO REALTY TRUST )
Plaintiff )
V. )
RICHARD S. ROWEN, ALISON LESCARBEAU )
JOHN SIMONS, RICHARD NARDELLA AND ) POST TRIAL
JOHN V. MAHONEY, AS THEY CONSTITUTE ) MEMORANDUM
THE PLANNING BOARD OF THE TOWN OF )
NORTH ANDOVER, )
Defendants )
INTRODUCTION
This is an appeal from a denial from a dimensional special permit application
from the Town of North Andover. The Plaintiff, Henry Kucharzyk, Trustee pursuant to the
1978 North Andover Zoning By Law (the By-law governing this lot) requested a dimensional
special permit in order to construct a dwelling within 100 feet of a tributary to Lake
Cochichewick. The Planning Board, voting three in favor and one opposed, denied the special
permit application. The Plaintiff claims that the proposed construction will cause no adverse
impact to the water that runs through the property as compared to existing conditions
Therefore, the denial of the Planning Board was arbitrary, capricious and unreasonable.
FACTS
1. On January 29, 1998, Henry Kucharzyk applied to the Town of North Andover
Planning Board for a Special Permit pursuant to Sec. 4.133 of the North Andover Zoning By-
law in effect as of 1979 (Statement of Agreed Facts);
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2. The Plaintiff applied for a Special Permit for construction of a single family
residential dwelling within 100 linear feet horizontally from the edge of a tributary to Lake
Cochichewick (Statement of Agreed Facts);
3. At a Special Town Meeting of the Town of North Andover held on June 26,
1978, the Town of North Andover voted to adopt Article IV of the Warrant which created the
Watershed District in the Town. Section III of said Article 4.133 contained the following
language
Dimensions and No Build Requirements:
a. Boundaries of Watershed District are designated specifically on the
certified North Andover watershed map 1978 and are shown on the
zoning map. These maps are hereby made part of this by-law and are on
file in the office of the Town Clerk;
b. When watershed district boundary divides a lot of record on June 26,
1978 in one ownership, all the zoning regulations set forth in the zoning
by-law applying to the greater part by area of such lot so divided may by
special permit be deemed to apply and governed at and beyond such
watershed district boundary but only to the extent not more than one
hundred (100) lineal feet in depth (at a right angle to such boundary) into
the lesser part by area of such lot so divided;
c. A no cut buffer zone shall exist one hundred fifty (150) feet horizontally
from the annual mean high water mark of Lake Cochichewick and twenty-
five (25) feet horizontally from the edge of all tributaries in the watershed;
d. No construction shall occur two hundred fifty (25) feet horizontally from
the annual mean high water mark of Lake Cochichewick and one hundred
(100)feet horizontally from the edge of all tributaries, except by special
permit. (Statement of Agreed Facts)
4. The Town of North Andover subsequently amended Section 4.133 in 1985 to
prohibit any construction from occurring one hundred feet horizontally from the edge of all
tributaries by deleting the words "except by special permit' and added language stating the
intent was dimensional (Statement of Agreed Facts).
5. The original subdivision containing the property of the Plaintiff was shown on a
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ATTORNEYS AT LAW definitive subdivision plan entitled "Great Pond Woodland" dated August 23, 1976, which was
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approved and endorsed by the Planning Board in December of 1976. Lots 20 and 21 were
part of the subdivision plan (Statement of Agreed Facts).
6. By deed recorded July 27, 1978, Landsail, Inc. deeded Lot 21 to Landsail
Construction Corporation. The definitive plan was subsequently modified by a plan which was
endorsed by the Planning Board on April 3, 1979. The revised plan shows Lots 20A, which
includes a large portion of the former Lot 20 and a portion of the former Lot 21. The property
in question is shown as Lot 20A on a plan entitled "Revised Plan of Land located in North
Andover, Massachusetts prepared for Landsail, Inc., Scale 1" = 40' dated April 2, 1979." This
plan was recorded with the Essex North District Registry of Deeds as Plan Number 8088 and
filed with deed recorded on May 7, 1979 in Book 1369, Page 506. Lot 20A was conveyed by
deed dated April 25, 1979 back to Landsail, Inc. by Landsail Construction Corporation. On the
same day Landsail, Inc. conveyed the remaining portion of Lot 20 to Landsail Construction
Corporation. By deed recorded on January 18, 1982, Landsail, Inc. conveyed Lot 20A to Paul
G. Cote and and Henry Kucharzyk, Trustees of HEFCO Realty Trust (Statement of Agreed
Facts).
7. On March 17, 1998, the Planning Board of the Town of North Andover held a
public hearing on an application of Kucharzyk for a Special Permit relating to the construction
of a single family residential structure within one hundred feet from the tributary to Lake
Cochichewick (Statement of Agreed Facts);
8. Said public hearings were continued until April 21, 1998 and further to May 19,
1998 and June 2, 1998 the public hearing was closed on June 2, 1998 (Statement of Agreed
Facts);
9. On June 5, 1998 the Planning Board with a vote of 3 in favor and 1 opposed
voted to deny the request for Special Permit for construction of a single family residential
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ATTORNEYS AT LAW structure within 100 feet tributary to Lake Cochichewick (Statement of Agreed Facts);
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10. On or about July 22, 1998, Henry Kucharzyk submitted a Notice of Intent to the
North Andover Conservation Commission for construction on the property. (Exhibit 11)
11. On or about September 2, 1998, the Conservation Commission of North
Andover granted an Order of Conditions for construction of a single family house and related
structures on the property. (Exhibit 12)
12. The property is located in an area of single family homes. (Transcript, page
32)
13. Property is presently vacant and in a wooded condition. (Transcript, page 32)
14. The wetland areas on the property are shown on a Determination of
Applicability plan and consists of bordering vegetated wetlands with an intermittent stream
located in the extreme rear of the property. (Exhibit 7)
15. Drainage from the property flows towards bordering vegetated wetlands to the
intermittent stream in the rear of the property. (Transcript, page 35)
16. From the property, drainage travels through the bordering vegetated wetlands
toward the intermittent stream to a farm area through a stream then through a series of farm
ponds under an old underdeveloped way through a series of other ponds before finally
discharging into Lake Cochichewick. (Chart A and Transcript, pages 30-31)
17. The Plaintiff proposed to construct a single family residential structure in
conformance with the setback requirements of the North Andover Zoning By Laws. (Exhibits
8, 9A, 9B, 13A, 1313).
18. The Plaintiff proposes no alteration of any bordering vegetated wetland.
(Exhibits 8, 9A, 9B, 13A, 13B)
19. The Plaintiff proposes a 25 foot no cut area buffer zone extending from the
bordering vegetated wetlands. This no cut area is proposed to be kept natural condition in
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20. The Plaintiff proposes to have a 50 foot no construction zone extending from
the bordering vegetated wetlands and in compliance with the 50 foot no construction
requirements of the North Andover Conservation Commission. (Exhibits 9A-913, 13A-13B)
21. The property is to be serviced by town sewer and they are no septic systems
proposed on the site. (Transcript, page 55)
22. Roof drainage is to be handled by a series of dry wells infiltrating directly into
the ground. (Exhibits 9A-9B, 13A-B)
23. The driveway is proposed to be constructed in the area furthest away from the
bordering vegetated wetlands as is possible. (Exhibits 9A-913, 13A-138)
24. The driveway is to be serviced by a catch basin complete with oil and gas trap
and a water quality swale. (Exhibits 9A-9B,13A-13B)
25. Although it is not required for a project of this size, the driveway with the catch
basis and water quality swale complies with the Stormwater Management criteria promulgated
by the Department of Environmental Protection. (Transcript, page 59)
26. The project will cause no derogation in the water quantity or quality that runs off
the property compared to existing conditions. (Transcript,. Page 68).
ISSUES PRESENTED
i. Whether the proposal to construct a single family dwelling within one hundred
feet from a tributary to Lake Cochichewick complies with the necessary standards for the
protection of the ground water.
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ii. Whether the Planning Board of the Town of North Andover acted
unreasonably, arbitrarily or capaciously in denying the application for a special permit for the
Plaintiff.
SHORT ANSWERS
i. Special permits should be granted on the basis of discernible standards
contained within the zoning bylaw. In the present case, the purpose of the Watershed District
is to protect and preserve the water at Lake Cochichewick. The Proiect as designed will
cause no derogation of the water quality and therefore meets the standards for the issuance
of the special permit.
ii. The action of the Planning Board in denying the special permit application was
unreasonable, arbitrary and capricious since the Applicant has employed the best
management practices in protecting the groundwater as is shown by the issuance of the Order
of Conditions from the North Andover Conservation Commission.
ARGUMENT
In order to be valid, special permit requirements within zoning bylaws must
contain some standards by which a reasonable applicant can anticipate what requirements
and conditions would be appropriate for the grant of a special permit in his circumstance. In
the case of MacGibbon v. Board of Appeals of Duxbury, 356 Mass 635, 637-38, 255 N.E.2d
3471 350 (1970), the Supreme Judicial Court ruled:
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cannot leave the decision subject to the "untrammeled
discretion' or"unbridled fiat" of the board. (Citations omitted.)
The Zoning Enabling Act and the by-law together must provide
adequate standards for the guidance of the board in deciding
whether to grant or to withhold special permit for the excavation
or filing of wetlands. The standards need not be of such a
detailed nature that they eliminate entirely the element of
discretion from the board's decision. It would be difficult, in not
impossible to foresee and specify, by ordinance or bylaw every
circumstance or combination circumstances under which special
permits should be granted or withhold. "the degree of certainty
with which standards for the exercise of discretion are set up
must necessarily depend on the subject matter and the
circumstances."
See Burnham v. Board of Appeals of Gloucester, 333 Mass.
114, 118, 128 N.E.2d 772, 775 (1955)
In the present situation, the requested special permit is for permission to construct a
single family structure within one hundred feet of a Tributary to Lake Cochichewick. In
Section 4.133 (1) of the 1979 Zoning Bylaw, the Town outlines the purpose of the Act:
The Watershed District surrounding Lake Cochichewick, our
source of water supply, is 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.
(Exhibit 1)
In dealing with the standards that should apply to granting a special permit pursuant to this
section of the zoning bylaw, it would seem that the major concern should be the impact of the
proposed construction on the quantity and quality of the drainage water exiting the site and
the preservation of the qualities of the land which assist in the natural filtration process of the
land. In many ways this concern mirrors the concerns of the Wetlands Protection Act M.G.L.
c. 131 sec. 40. The Wetlands Protection Act cites an number of interests the Act is to protect.
Among these are protection of public and private water supply and protection of ground water
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Regulations promulgated thereto have established a number of standards governing
construction and use of property with the intention to protect and preserve drinking and
ground water. It is therefore, reasonable to assume that compliance with the performance
standards set forth in the Wetlands Protection Act and their Regulations provide a reasonable
objective measure to gauge the impact of a proposed project on an area such as the
Watershed District of North Andover.
In the present case, the applicant has employed standards which will fulfill the
requirements of the purposes of the Watershed District. He has obtained an Order of
Conditions issued by the North Andover Conservation Commission for the proposed
construction (See , Exhibit 12) . Additionally, he has obtained approval pursuant to the more
rigorous standards of the North Andover Non Zoning Wetlands Bylaw Chapter 178. (See
Exhibit 12). His proposal contemplates no alternation of any bordering vegetated wetland
area. This has an important impact on the Watershed District since one of the major reasons
why there are limitations on alterations to bordering vegetated wetland areas center on the
filtration and pollution attenuating qualities of these areas. This filtration quality is so
important that the Performance Standards promulgated in the Wetlands Regulations, 310
CMR 10.01 et seq. provide a limitation to the amount of area that can be altered. "While
retention and detention basins and compensatory storage measures can replicate the flood
control value of bordering vegetated wetlands, there are no engineering solutions currently
available that can replace the capacity of such wetlands to renovate water quality or to provide
food, cover and habitat for fisheries." (Preface to the Wetlands Regulations, 1983 Regulatory
Revisions, 310 CMR p457,464-465). The project as designed and presented by the Plaintiff
therefore preserves to the greatest extent possible the natural wetlands features of this land.
In addition to the preservation of all the wetland areas on the site, the applicant also
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These features include the creation of 25 foot no cut area. The Conservation Commission
has inserted an additional requirement that this 25 foot area be demarked by a landscaped
wall so that future homeowners will realize that the area beyond the wall must be kept in a
natural, uncut state. The applicant also proposed that no construction take place within 50
feet of bordering vegetated wetlands. The applicant proposes that roof drainage be directed
to dry wells so that the rain water from the roof may be directed directly into the ground
replicating the natural condition of rain water falling into the ground. Lastly the small amount
of driveway, approximately 1800 square feet of pavement, will be serviced by a drainage
system compliant with the Stormwater Management Criteria.of the Development of
Environmental Protection. These criteria include the installation of a catch basin with an oil
and grease trap and the creation water quality swale which will act to detain the water from the
driveway so that any small amount of pollutants such as salt which may be in drainage water
will settle into the vegetated Swale. Additionally, the property will be serviced by town
sewerage.
These are objective engineering criteria, which demonstrate that the project as
proposed will not adversely impact the quality or quantity of water that flows to Lake
Cochichewick. It should be noted that the town presented no evidence to dispute the
testimony of Phillip Christiansen and Mr. Christiansen opined that this development will have
no impact on the water quality from the lot heading into the Lake. (Transcript, Page 68) The
Planning Board attempted to illicit testimony from Mr. Christiansen that there was a
"possibility" that something that spilled on the driveway, may eventually make its way into the
Lake (Transcript 92-95). Mr. Christiansen also testified that there was a possibility that
dumping may take place on a vacant lot and that could also impact the Lake. (Transcript Page
126) It is unfair to hold an applicant to a standard which would be dictated by every
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falling, earthquakes and any other type of natural phenomenon. The grant or the denial of a
special permit should exist within the realm of reasonably objective standards and in the
present situation the engineering practices demonstrated on the Plans indicate that the
Plaintiff has complied with those standards.
ii. When a special permit granting authority acts unreasonably, arbitrarily, or
capriciously in the denial of a special permit, that denial should be overturned by the Court on
appeal. For example, in the case of Prudential Insurance Company v. Board of Appeals of
Westwood, 23 Mass. App. Ct. 278, 502N.E.2d 137 (1986), a site plan approval was improperly
denied when adequate provisions were made for the traffic to be generated on the site. In
effect, the applicant had met the standards for the impact of this development on the area.
Also, in the case of Mahoney v. Board of Appeals of Winchester, 344 Mass. App. Ct. 598, 183
N.E.2d 850 (1962), the denial of a special permit for an expansion of a nursery was improper
when there was no evidence presented by the Board of Appeals that the addition would have
any impact on the currently existing business.
These cases stand for the proposition that the reasons for denial should be based
upon some sort of objective criteria which can be adequately discerned. In the present
circumstances, the Planning Board has cited only a few reasons why the special permit should
be denied. It first cited that the specific site was not an appropriate location because the
applicant did not seek to obtain a variance. It is an unreasonable burden to place upon an
applicant the grant of exceptional zoning relief to order to met the standard for another section
of the Zoning Bylaw. It seems reasonable in the situation where a special permit would avoid
the need for a variance, that a landowner should attempt to acquire that special permit prior to
requesting the more drastic zoning relief. A review of the plans in this case (Exihibits 9A and
9B) indicate that it would be impossible to construct a dwelling without some portion of it being
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ATTORNEYS AT LAW within a 100 feet of the tributary. The second reason cited by the Board was that the
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construction proposed did not have a sufficient barrier to preserve and protect the tributary
from the erosion of soil. This is simply wrong. No evidence was presented as to that effect.
In fact, the Order of Conditions presented by the applicant showed that adequate safety
measures would be installed to protect and preserve the wetland areas not only during the
construction phase but as a permanent feature. The Order of Condition is prima facie
evidence that the bordering vegetated wetland areas would not be altered by this construction
as suggested by the second reason for denial. Therefore, that reason is unreasonable,
arbitrary and capricious and not based on the actual factual circumstances. The third reason
cited by the Planning Board was that adequate and appropriate facilities had not been
provided for the proper operation. The area cited in simple detail that information was not
provided demonstrating the operation would properly protect the Watershed. Again, it was
presented to the board that the development would comply with the Stormwater Management
Criteria and there was no evidence presented by the board as to any negative impact of the
proposed use. Lastly, the board cites that it is not in harmony with the general purpose of the
Watershed District since not all feasible steps were taken to protest (sic) the Watershed
((Exhibit 3). There has been no evidence presented as to any additional steps that the
applicant did not take to protect and preserve the wetland area. Overall, the reasons for
decision can cite no objective criteria which the applicant has failed to meet but only speak in
generalities citing adverse consequences which are believed to occur.
The Planning Board has argued that certain additional information was supplied to the
Conservation Commission which was not supplied to the Planning Board. The testimony of
Phillip Christiansen indicates that the two plans have only slight modifications between them.
(Transcript Pages 113-119) The Court in this circumstance must review this evidence de
novo. if the Court finds that the evidence presented at trial indicates that there was no
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remand the case back to the Planning Board for a decision in compliance with the Court's
findings. The Court certainly has the power to require that any additional information or
criteria which was part of the Conservation Commission process be incorporated with any
decision. There is simply no objective reason presented by the Defendant that would support
the conclusion that the proposed construction would have any adverse impact on the quantity
or quality of the water draining off this site. Without some evidential support for a denial, the
case illustrates the "untrammeled discretion" feared by the MacGibbon Court.
CONCLUSION
The Defendants project meets the standards for the protection and preservation of the
Watershed District and this Court should order the matter to be remanded to the North
Andover Planning Board for issuance of the special permit in compliance with the plans as
submitted to the North Andover Conservation Commission.
Henry Kucharzyk, Trustee
By his attorney,
Michael P. McCarron, Esq.
BBO#327570
Grenier& McCarron
100 Hathorne Office Park
491 Maple Street
Danvers, Massachusetts 01923
Dated: (978)777-7000
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