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HomeMy WebLinkAbout2008_03_12 Planning Board Minutes 3-12-08 minutes pagel 04 4 Town of Mamaroneck Planning Board 94 Town of Mamaroneck Planning Board Minutes March 12, 2008 Present: Marc Rosenbaum, Chair C. Alan Mason, John A. Ortiz Ellen Dunkin Virginia Picciotto George Roniger Edmund Papazian Absent: Nancy Seligson, Liason Elizabeth Paul, Environmental coordinator Also Present: Ron Carpaneto, Director of Building Kevin G. Ryan, Counsel Anthony Oliveri, P.E Wanda Spevadula, Public Stenographer Carbone&Associates, LTD. 111 N. Central Park Avenue Hartsdale, New York 10530 Francine Brill, Recording Secretary 1. Minutes On motion of Dr. Mason, seconded John Ortiz the minutes of February 13, 2008 were corrected and approved unanimously. 2. Application of Steven Emanuel, 2 Rocky Hollow Drive, for Fresh Water Wetlands and Water Courses Permit PUBLIC HEARING Continuation of Public Hearing. Leonard Brandes applicant's architect and Steven Emanuel the applicant appeared and addressed the Board. Mr. Brandes stated that he is requesting permission to complete the pool and patio project and put up the state required pool fencing. The Board discussed the plans identified as "SY-001," dated 4/07, and amended 1/15/08. 3-12-08 minutes page2 The Board stated that it was just brought to its attention that the fence depicted on the plans would be placed in a conservation easement area that does not allow structures. Mr. Emanuel stated that he was aware that the state required a fence around a pool from the beginning of the project, but that it does not specify the distance or placement of the fence. Mr. Emanuel stated that he did not want the fence close to the pool as he felt it would bisect the property destroying the visual flow of the property. He added that he purchased the property in part because of the extensive rear yard extending to the wetlands area. Mr. Ryan stated that because the Town of Mamaroneck is the grantee of the conservation easement it is up to the Town Board to decide whether the proposed fence can be placed within the easement area. In other words, it is a jurisdictional issue whether the Planning Board even has the authority to approve the plans showing the placement of the fence in the conservation easement area. The Board felt that they should hear from the environmental coordinator, Elizabeth Paul, with regard to the fence in the easement area. Ms. Paul was not present. The Board reviewed a letter concerning the application, dated March 11, 2008 from Mr. Oliveri of Dolph Rotfeld Associates, the Consulting Engineer to the Planning Board. The Board discussed whether a permit could be issued under the circumstance and given the evidence that was presented. In view of the partial work already completed at the project site and the mitigation measures implemented by the applicant, the Chair called upon the members to adopt a nun pro tunc (i.e., retroactive) wetlands permit, subject to certain conditions set forth below. On Motion duly moved and seconded, the Board voted to close the Public Hearing. The Chair asked for a motion. On motion of Mr. Ortiz, seconded by Ms. Picciotto the following resolution was proposed and ADOPTED 6-1 Dr. Mason voted no with explanation. CERTIFICATION As Chairman of the Planning Board of the Town of Mamaroneck, I hereby certify that the following is the Resolution adopted by the Planning Board at the meeting held on March 12, 2008 WETLANDS AND WATERCOURSES STEVEN EMANUEL WHEREAS, Steven Emanuel ("Applicant") has applied for a Wetlands and Watercourses Permit pursuant to the Wetlands and Watercourses Protection Law of the Town of Mamaroneck (Local Law 6-2003) Town of Mamaroneck Code, Chapter 114 (the 3-12-08 minutes page3 "Wetlands Law") for the premises located at 2 Rocky Hollow Drive and known on the Tax Assessment Map of the Town of Mamaroneck as Block 310, Lot 2; and WHEREAS, this Planning Board (the "Board) has previously determined that the proposed action is a Type II action under SEQRA and, accordingly, no further review is required under SEQRA; and WHEREAS, the Planning Board conducted a Public Hearing pursuant to Wetlands Law §114-7(C) on February 13, 2008 and March 12, 2008; WHEREAS, in accordance with Wetlands Law §114-7(D), and as set forth in the report by the Town's Consulting Engineer(s) and/or other agent(s), which is attached hereto and made a part hereof, the Board has considered: 1. any reports from other commissions,including the Coastal Zone Management Commission, and Town, County, State and/or Federal agencies; 2. all relevant facts and circumstances,including but not limited to: a. the environmental impact of the proposed action; b. the alternatives to the proposed action; and c. the impact of the proposed activity on wetland functions and the benefits as set forth in Wetlands Law §114-1; 3. the availability of preferable alternative locations on the subject parcel; 4. the availability of further technical improvements or safeguards that could feasibly be added to the proposal; 5. the possibility of further avoiding reduction of the wetland's or watercourse's natural capacity to support desirable biological life, prevent flooding, control sedimentation and/or prevent erosion, facilitate drainage, and provide recreation and open space; and 6. the extent to which the public or private benefit derived from such use may or may not outweigh or justify the possible degradation of the wetland or watercourse, the interference with the exercise of other property rights, and the impairment or endangerment of public health, safety, or welfare; NOW THEREFORE, BE IT RESOLVED THAT the Planning Board finds, pursuant to Wetlands Law §114-7(E),based on the record before it, that the Applicant's proposed regulated activity is consistent with the purposes of the Wetlands Law, as set forth in §114-1(A): 1. to preserve, protect and conserve the Town's tidal and freshwater wetlands and watercourses; to prevent 3-12-08 minutes page4 despoliation and destruction; to regulate their use and development; and to secure the natural benefits of wetlands and watercourses that is consistent with the general welfare and beneficial economic and social development of the town; and 2. to ensure maximum protection for wetlands and watercourses by discouraging degradation within them and within their buffers that may adversely affect these natural resources; and to encourage restoration of already degraded or destroyed wetlands,watercourse and buffers, and to ensure "no net loss" of wetlands and watercourse areas. BE IT FURTHER RESOLVED, that the application of Applicant for a Wetlands and Watercourses Permit is hereby GRANTED subject to the following terms and conditions: 1. This permit authorizes the work shown on the drawing identified as "SY-001" submitted by the Applicant to the Planning Board,last revised January 15, 2008, and no other, except that the black vinyl coated chain link fence shown on such plans to be located in the conservation easement area as shown on such plan shall not be constructed as shown on such drawing without the prior agreement and approval, of the Town Board on behalf of the Town of Mamaroneck as grantee of the conservation easement. In the event the Town Board disapproves construction of the fence as aforesaid, the applicant shall submit a new application under the Wetlands Law prior to placement of the fence within any regulated area. 2. Prior to the commencement of work pursuant to this permit, the Applicant shall post a bond in the amount of$1,500.00 to ensure the satisfactory completion of the project in accordance with the conditions and limitations set forth herein and the rehabilitation of the affected or disturbed area. 3. At least five days prior to the commencement of the work authorized hereby, the permit holder shall notify the Building Department of the date on which the work is to begin. 4. Work conducted pursuant to this approval shall be open to inspection at any time,including weekends and holidays by the planning Board or its designated representatives. 5. Work pursuant to this permit shall take place from Monday through Friday between the hours of 8:00 a.m. and 6:00 p.m. 6. Within 30 days after completion of all work authorized hereby, the Applicant shall notify the Director of Building of such completion. Upon such notification, the Building 3-12-08 minutes pages Department shall follow the procedures set forth in Town Code § 114-9. 7. This permit shall be prominently displayed at the project site during the undertaking of the activities authorized hereby 8. Final Restoration of the Wetlands must be reviewed, approved and inspected by the Town Environmental Coordinator. 9. All wetland plantings must be installed by hand. 10. This permit shall expire one year from the date of its issuance. 3 PROPOSED LOCAL LAW PUBLIC HEARING The Planning Board held a discussion with regard to a proposed amendment of the Town Code, which would add new Section 240-72 to Chapter 240 of the Town Code, i.e., the Zoning Code. New Section 240-72 would make the defense of a prior legal nonconforming use an affirmative defense in prosecutions for violation of use restrictions under the Zoning Code. In accordance with Town Code Section 240-92B regarding proposed amendments to Chapter 240 of the Town Code the Town Board must refer such proposed amendment to the Planning Board for its report and recommendation. William Maker Jr. Town Counsel appeared and addressed the Board. Mr. Maker stated that the purpose of the amendment is to shift the burden of proof from the Town of Mamaroneck to the individual. Mr. Maker opined, that the amendment no longer involved the New York Penal Code, although there is still a possibility of incarceration up to 6 months. Instead, the current version of the proposed amendment is based on authority under Section 268 of the New York Town Law. According to Mr. Maker, the law is not designed to make currently legal prior nonconforming uses illegal. Instead, the purpose is to ease the Town's burden of proof in disproving the defense of a prior legal nonconforming use in prosecutions of use violations under the Zoning Code. According to Mr. Maker, the concept behind the proposed shift of the burden of proof from the Town to the land owner is that, as the law currently stands, if the Town brings an enforcement action alleging a violation of use restrictions under the Zoning Ordinance, and if the defendant asserts that the use in question is a prior legal nonconforming use, the Town must disprove this defense beyond a reasonable doubt. Because the Town may have limited records concerning the 3-12-08 minutes page6 use at a particular location, this could amount to the impossible task of proving a negative. On the other hand, according to Mr. Maker, the property owner may possess tax records, for example, indicating the prior use thus enabling the property owner/defendant to prove the defense by a preponderance of the evidence. Members of the Planning Board responded that, to the contrary, the Town may possess more records relating to the use of the premises, particularly if the alleged prior use goes back many years. Also, Board members noted that the Town has more staff resources than the average property owner to do the research concerning prior uses of the premises. The Board noted as well that, although Mr. Maker claims that the current version of the proposed Zoning Code amendment is not based on authority under the Penal Law, it would still provide up to six months of incarceration. In the view of several Board members, where such an amount of jail time is involved, it should remain with the prosecutor to prove the elements of the violation or to disprove any defense beyond a reasonable doubt. Further, Board members expressed concern that a new buyer of a property at which a use is ongoing could be unaware of the illegality of such use. Mr. Maker responded that, in most cases where the purchase of property is financed through a bank, a title report is prepared. Title insurers typically flag uses not in conformity with zoning or for which there is no certificate of occupancy of record. This would put the buyer on inquiry notice, in which case the buyer should not be able to assert innocent belief in the legality of a use. Both Mr. Maker and Mr. Ryan agreed that there is ambiguity in the wording of Town Law Section 268, the suggested authority for the current proposed amendment, with regard to the treatment of violations thereunder as misdemeanors. This section of the Town Law states, "for purposes of conferring jurisdiction upon courts and judicial officers generally, violations of this article or of such local law, ordinance or regulation shall be deemed misdemeanors and for such purposes only, all provisions of law relating to misdemeanors shall apply to such violations." Although Mr. Maker believes this language is merely intended to provide the Town Justice Court with jurisdiction to hear enforcement actions under this section, Mr. Ryan suggested that there is authority for the view that this language means that such cases must be prosecuted as misdemeanors, including the usual allocation of proof burdens between the prosecution and the defense. Mr. Ryan added that full criminal due process, including the "beyond a reasonable doubt" standard for the prosecution might be waivable if the maximum incarceration period were reduced to less than 15 days or incarceration were eliminated as a penalty altogether. 3-12-08 minutes page7 Mr. Rosenbaum summarized the Planning Board's objections to the proposed Zoning Code amendment to shift the burden of proof to the defendant with regard to the defense of a prior legal nonconforming use: • The penalty of a possible incarceration for up to six (6) months is too draconian for a zoning violation when coupled with shifting the burden of proof onto the defendant (albeit with the lesser standard of proof of a preponderance of the evidence); • Further, the Planning Board members believe that the Town is in as good a position, if not a better position, to gain access to relevant evidence in situations where relatively new owners are concerned; and • The Town is not currently facing a serious problem of non- conforming use violations so as to require a change in the law at this time. On motion, seconded and unanimously adopted, the Planning Board closed the public hearing concerning the proposed amendment to add new section 240-72 to the Zoning Code. Based on all of the above, the Planning Board unanimously voted to report and recommend to the Town Board that the proposed amendment not be adopted as set forth below. RESOLUTION WHEREAS, on January 2, 2008, the Town Board of the Town of Mamaroneck resolved to refer a proposed law (annexed hereto) to the Planning Board for a report as required by section 240-92 B of the Mamaroneck Town Code (the "Town Code"); WHEREAS, on January 4, 2008 the Town Attorney, William Maker, Jr., forwarded to the Chairman and Members of the Planning Board of the Town of Mamaroneck a memorandum making such referral and explaining the purpose of the proposed amendment; WHEREAS, the proposed amendment would add a new section 240-72 to Chapter 240 of the Town Code concerning Zoning (the "Zoning Code"); WHEREAS, the substantive provisions of proposed new section 240-72 read as follows: §240-72. Nonconformity as an affirmative defense. In any prosecution of a violation of this chapter, the defense that either the use of land or the use of a building was a lawfully permitted use at the time that this 3-12-08 minutes page8 chapter was adopted or amended shall be an "affirmative defense" which the defendant in such prosecution shall be obliged to prove by a preponderance of the evidence; WHEREAS, the purpose of the proposed new section 240-72 is explained as follows: Under the current Mamaroneck Code, if the Town prosecutes a violation of the zoning ordinance and the landowner professes innocence on the ground that the property is a nonconforming use or building, the Town is required to prove beyond a reasonable doubt that the nonconformity did not exist before the enactment of the zoning ordinance. It is nearly impossible for the Town to sustain such a burden of proof in most cases. This local law shifts the burden of proof to where it belongs - to the landowner—who would have to prove the existence of the nonconformity by a preponderance of the evidence; WHEREAS, a memorandum, dated December 21, 2007, by Town Attorney explains that "the Town Board derives its power to provide a mechanism to enforce its zoning laws from both section 10(4)(b) of the Municipal Home Rule Law and section 268 of the Town Law;" WHEREAS, both the Town Attorney and Planning Board counsel agree that section 268 of the Town Law is ambiguous with regard to the procedures which must be followed by the court in prosecutions under that section, including specifically the required burdens of proof of the prosecution and the defense; WHEREAS, the Planning Board believes that, in the case of a recent purchaser of property, the Town would have an equal or superior capacity to develop evidence concerning the use of a piece of land or a building; WHEREAS, the proposed amendment would not reduce the possible maximum penalty of incarceration for six-months upon conviction for a violation of the Zoning Code; WHEREAS, it is the Planning Board's belief that six months in jail is a serious criminal penalty, whether or not a zoning violation is formally classified as a misdemeanor or is merely to be treated as such for purposes of Justice Court jurisdiction under New York Town Law section 268; WHEREAS, in view of the seriousness of this available penalty for a violation of the Zoning Code, the Planning Board believes that a defendant accused of such a violation should be afforded all the procedural protections normally afforded in the case of a prosecution for a misdemeanor; and WHEREAS, the Planning Board is not aware of any ongoing problem in the Town of accused zoning violators gaining acquittal by asserting a prior legal 3-12-08 minutes page9 nonconforming use defense which the Town has been unable to disprove beyond a reasonable doubt; NOW, THEREFORE, BE IT RESOLVED that the Planning Board hereby reports to the Mamaroneck Town Board that, for the reasons outlined above, the Planning Board believes that the proposed amendment to the Town Code which would add new section 240-72 designating the defense of a prior legal nonconforming use as an affirmative defense in prosecutions under Chapter 240 would not further the purposes set forth in section 240-2 of such chapter. BE IT FURTHER RESOLVED that the Planning Board therefore recommends to the Mamaroneck Town Board that it not adopt the proposed amendment to the Mamaroneck Town Code which would add new section 240-72 designating the defense of a prior legal nonconforming use as an affirmative defense in prosecutions under Chapter 240. ADJOURNMENT The meeting was adjourned at 10:00 PM. If anyone wishes to review the audio tape of the meeting of March 12, 2008, it will be available at the Building department, after the certification is signed by the chairman and filed with the Town Clerk. Francine M. Brill, Planning Board Secretary