HomeMy WebLinkAboutZBA-02/28/2002 HEARSOUTHOLD TOWN BOARD OF APPEALS
TRANSCRIPT OF PUBLIC HEARINGS
HELD FEBRUARY 28, 2002
(Prepared by Paula Quintieri)
Present were:
Chairman Goehringer
Member Tortora
Member Homing
Member Oliva
Member Orlando
PUBLIC HEARINGS:
6:55 p.m. (Carryover from January Hearing) Appl. No. 5034 RUST FAMILY
PARTNERSHIP. Interpretation and/or Relief for Addition with setback variances from
front lot line and bulkhead, at 4680 Wunneweta Road, Cutchogue; 1 l 1-14-34. R. Lark,
Esq. for the applicant; P. Moore, Esq. (for J. Cella)
CHAIRMAN: Good evening Ms. Moore.
PAT MOORE, ESQ.: Good evening. Code talks about lots being 40,000 to 59,999
requiring a front yard setback of 50, side yard, both side yards 40, so it's 20 and 20 and
rear yard 60. When I reviewed the transcript there was reference to 15 feet being what is
requested and 15 feet, presuming no variance a front yard variance from the right-of-way,
Mr. Lark mentioned and I don't know if that was an error but no variance would be
required. I would disagree with that, that based on the schedule that regardless of which
application you use, whether it's a front yard setback from the fight-of-way or it's a side
yard, in either event you would need a variance. That's what I'm basing my argument on,
as far as, what would be the legally required setbacks. There are new Members of the
Board and I know you've studied what the standards are for a variance, and please bear
with me it's for my own purposes of keeping organized I don't mean to insult you but I'm
going to go through the standards and how I believe that the standards one, have not been
met and secondly, I think are a significant impact on the neighbor which is always
something when you're balancing the interests of both parties and you're going to do this
all the time I want you to keep in mind Mr. Cella's interest as well. But the first point I
want to make is that the argument being made by Mr. Lark is that there will be no
undesirable change produced in the character of the neighborhood or detriment to nearby
properties. Well, obviously we strongly disagree with that. The Rust Family residence
has a side yard of about 46'. The Cella residence from, again talking about side yards
leaving that 15 feet of no-man's land which nobody can really identify what that is, but
going to the property line each parcel has approximately 46' of the side yard setback. I
asked Mr. Cella and I remembered from my inspection of the property that most of the
properties in the Nassau Point community are actually large parcels, estate parcels, with
very large side yard setbacks, very large setbacks because in that area, privacy is really a
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Town of Southold
very important part of their development. So the community at large has developed with
larger setbacks. So Mr. Cella had very kindly provided tbr mc, very nice photographs
which are actually taken around the pond which are the most neighboring properties and
we will see there are, as he makes his circle around thc pond of developed propertics, you
will see absolute every parcel has a very large setback probably in line with 50 to 60 feet
certainly not the 15 feet which is being proposed. So to being with I would like to make
these photographs part of the record. We can make copies and give it to Mr. Lark, but
unfortunately I only have the one set. So I do want to present that to the Board.
CHAIRMAN: Mrs. Moore what did you say the setback was to the Cella house to that
15 feet?
PATRICIA MOORE, ESQ.: From the survey, Mr. Cella's survey it looks to be about 46
feet.
MEMBER TORTORA: To the fight-of-way?
PATRICIA MOORE, ESQ.: To the right-of-way.
CHAIRMAN: So it would be 46 and 15 which would be about 61, to the actual, to the
Rust Family Trust.
PATRICIA MOORE, ESQ.: Keep in mind that the Rust property has again, also 46 feet
to the their survey, excluding addition. So both properties are developed very similarly.
MEMBER OLIVA: That's from the garage to the
PATRICIA MOORE, ESQ.: From the garage, yes, and the existing garage. So, again,
the character of the neighborhood here is to maintain larger side yards. This would be a
deviation from the character of the community. In addition I looked from the record, and
again I'll stand corrected, because this was not real clear, whether this is a two-story
addition. But it looks to be a two-story addition, being 31 feet in width and running 63
feet along the property line. Again that is a significant addition on the side of the Cella
property which if you consider these kind of setbacks, 15 feet, in my neighborhood which
has half and quarter acre parcels, in Captain Kidd and a lot of the neighborhoods in the
area 15 f~et seems very reasonable and certainly with the extra 15, the DMZ zone, the no-
man's land, again this area it is not reasonable and it's certainly not reasonable to Mr.
Cella. While personal hardship I understand is never an issue tbr either side, we do want
to put on the record that the reason Mr. Cella is so strongly opposed to this is that the
view of this addition, not the waterfront, that's not an issue because the waterfront will be
impacted because of waterfront house. It's the actual what he sees offthe window of his
bedroom is going to be this entire 63 feet of expansion. And, with Mr. Cella's
permission, I state to you that his wife, who hasn't been here, is very seriously ill. She is
house bound, she is bound to her bedroom and the only activity that she sees, the only
enjoyment she shares is out of her window. The beautiful setting which she sees out the
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window. I have a photograph of what she prescntly sees out her window, and you will
see that it is really vcry nice, very pastoral and it is again, consistent with the Nassau.
CHAIRMAN: Mrs. Moore can you tell us which, where her bedroom is'?
PATRICIA MOORE, ESQ.: Yes it's right there on the side.
CHAIRMAN: On this side?
PATRIC1A MOORE, ESQ.: That photograph, I asked him to take a picture right from
the window, so you see a little bit of shading which is actually from a closed window.
That's the picture she sees. The second standard that this application must present is that
the benefits sought by the applicant cannot be achieved by some method, some other
method feasible ~br the applicant to pursue other than this area variance. Again,
reviewing the file, the Rust Family has actually three residences that are in their control.
It appears that this house is on a separate parcel from the other house, but all of them,
there are encroachments going on, however, they are all under their control. The main
house, again pictures are worth a thousand words, we have a photograph that shows the
main house, which is being proposed. There is another substantial house, certainly bigger
than my home, but it's small in comparison to the other homes, which is closer to the
road. And then there seems to be a seasonal cottage, ~vhich is by the dock. So there is an
abundance of residential space here on this property. There is also plenty of room on the
other side; certainly not impacting the neighborhood, only impacting themselves would
be an expansion on the easterly side of the property. So, again, the photographs show
CHAIRMAN: You're referring to southeast aren't you?
PATRICIA MOORE, ESQ.: Southeast. Southeast side of the property shows the three
residences, the one photograph shows that. I also have individual photographs of the
smaller house and then the cottage.
MEMBER TORTORA: 1 know you submitted these up, but they're not identified.
PATRICIA MOORE, ESQ.: Yes, I'll do that, some of them are new that he brought for
me, so I will, if you like after the meeting 1'11.
CHAIRMAN: Let me just get one thing straight here, so you are and you're client, are
not in any way suggesting any cutting back of that side yard. You basically want the
Rust Family Trust to build the addition on the opposite side?
PATRICIA MOORE, ESQ.: We would certainly prefer, we implore the family to please
build the addition on the other side. We think that there's adequate room, there certainly
is no need for this variance, particularly again, referring to the character of the area,
they're asking us to accept an addition encroaching on an area that has remained in its
current status and certainly is unacceptable to Mr. Cella. So, yes, I would agree. We
don't want any addition on that side. Depending on how you rule, there might be a
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construction as of right. Now, whether when you tell them, well we'll not branch of the
variance, whatevcr thc Code dictates you're allowed to build, if that's suitable for the Rust
family well maybe it is, maybe it isn't. We don't have much say in it. Would we like it if
they would've agreed to build it on the other side, of course? But there's also the fact
that you're jurisdiction is only to the point that there's a variance. After that we hope that
their reasonableness will prevail. We've already talking about whether or not this
variance is substantial; again, I refer you to the development of the area and whether or
not it's substantial in light of the community around the pond. Whether the Variance will
have adverse affect or impact on the physical, environmental conditions in the
neighborhood or district. Well, we know that the Trustees have approved this. However,
the construction if it were on the east side, would be further away from the bulkhead,
further away from the flood zone and possibly out of the jurisdiction of the Trustees
altogether. So, certainly environmentally it's a more suitable place on the other side. We
defer to a great extent to what the Trustees do when it comes wetland permits and the fact
that they have to put in hay bales, but again its an issue that you have to address; whether
the difficulty was sell-created, the way I interpret that is you haven't built and now they
are asking in advance of building, ls this the minimum variance practical given the
personal benefits anticipated by the applicant? Again, I don't opposition now is this
reasonable, no; they're going to say the opposite. Those are my points, and again I thank
you for the opportunity to be here and continuing this hearing for that purpose.
CHAIRMAN: Thank you. Mr. Lark?
RICHARD LARK, ESQ.: It is my understanding that the Zoning Board is 15 feet side
yard. Is that correct?
CHAIRMAN: Total of 35, 15 and 20.
MEMBER TORTORA: Here's where the confusion comes in. The Building Department
has determined that, that lane is, in fact, a front yard.
RICHARD LARK, ESQ.: That's correct, that's why the _application. And I
asked the Board under 280A, which is as an objector remark, to make that determination
because there is no relevancy to the house that the front yard is Wunneweta Road and I
pointed out in the second part of the application that that can't be in any shape or form
constrained as a street as defined in the Town Law. And as I also pointed out to the
Board ! gave, which is the basic application that the builder gave to the Building
Department initially when he started this a year ago, a year ago this month, and that
Building Inspector Mr. Forrester determined that was indeed just a side yard, that wasn't
a street. And some six or seven months later that the Building Department reversed its
position and decided that was a street, and we would be required to get a variance on that.
And when I realized what was happening there, that's why I made the application. The
standards are the same by the way, under 280A of the Town Law as well as 267; they are
the same standards that the Board considers. The legislature made an amendment to the
statute and I think, I handed that up, and that they recognize this and the key there is that
the Board would have to make the determination under the Town Law that the house, the
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ZBA Public l tearing Transcdpt
structure, the proposed addition, the neighborhood that this is not a strcct and the
buildings have no relevance to it. Because 280A, if you read all of 280A was for acccss.
I was teasing the builder, thc applicant, Flowcr Hill here, that this would'vc been a real
issue if we decided to use the so-called no man's land for egress and digress for the
driveway and eliminate the driveway which comes over, because one of the reasons that
the whole application for the addition was that we put on this side of the house was
because of thc way the topography of the land is in the existing garage area is where it
comes out from Wunneweta Road and goes across the whole front of the house to get to
this area because of the dip if you go over, as you come in off the road go to the left, it
doesn't work out. So that's the reason why they sited it over on this side, because there
was the existing garage, which has been converted into living space inside the house and
in order to keep the roof lines and everything the same to keep the symmetry of the whole
situation that's why it was done. But we would never come betbre the Board except for
the rear yard portion of it which the Trustees had given approval except for the fact that
the Building Department decided to call this a street, this 15 foot no man's land which we
pretty much exhausted that in all those two hearings, and 1 gave you ail the historical
background on that in your application. So, if the Board decides, I guess the Board will
have to decide whether that no man's land is a street or not a street under the Code, and if
it is not a street then we don't need a variance for the side yard because we conform to the
15-foot. That's what the Code says. And then we're just, then the other part of the
application, of course, for the area variance would be for the rear yard which is the 75
feet and this is 64 which they got approval from both the non jurisdiction from the
D.E.C., as you saw and also they got a Trustees permit which you saw.
MEMBER TORTORA: Could I ask you a question?
RICHARD LARK, ESQ,: Sure.
MEMBER TORTORA: I know I asked you; I just want to understand this clearly. No
one owns the right-of-way? There's no deed of record?
RICHARD LARK, ESQ.: No ma'am.
MEMBER TORTORA: There's nothing?
CHAIRMAN: There's no tax map number?
RICHARD LARK, ESQ.: No tax map number. It's on the map.
MEMBER TORTORA: On what map?
RICHARD LARK, ESQ.: The original map of Nassau Point filed back in 1922.
MEMBER OLIVA: What was it filed as?
CHAIRMAN: Access to Wunneweta Pond.
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ZBA Public Homing T~ansc~ipt
RICHARD LARK, ESQ.: Yes. It just 15 feet.
MEMBER OLIVA: In other words it's just that from the other roads in town that have
been kind of put there as the road ends and then gradually filled in.
RICHARD LARK, ESQ.: Yes. And this has been respected, as you can see, xvhere the
dent to the property they've got sort of like a stone wall right on the Rust side of the
property line and to Mr. Cella's credit and the predecessor before him Dr. Camew, they
kept that land up they didn't let it go to weeds or anything, they let the trees grow, they
pruned them they cut grass and so on, and so forth. But no one's ever used it in that sense
of losing it as an ingress and egress to it.
MEMBER TORTORA: We've had similar cases to this in the past and the Board has
ruled on these cases in the past, not under 280A actually an Interpretation we did in the
past. At this point, really the burden of proof is on you to prove sufficiently it isn't a
right-of-way, a street excuse me, under the Town Code. In the event that it is a street
under the Town Code, let's go to a couple of things tight of way. Let's go to, and we
touched on this the last heating, alternate sites. Why can't this be put into a conforming
area on the southeast side?
RICHARD LARK, ESQ.: Well I submit it is in a conforming area on the side that it is,
it's just this Interpretation of the Building Department. Now, in other words put the
addition on the other side of the house. Well, I've got the builder right here, he can
answer that question because he's been working directly with the owner and they've
developed the plans last January or February, a year ago. Do you understand the
question? Forget Zoning, why can't it be put on the other side?
CHAIRMAN: Just state your name tbr the record?
CHRIS UHL: Chris Uhl for the Trust. I believe you have the final, the sketch drawn by
the Building Inspector.
CHAIRMAN: Right.
CHRIS UHL: The house is on the comer lot and the addition to the setbacks from
Wurmeweta Road, there are setbacks from Bayberry Road and from the bulkhead in the
back. In addition, there are also setbacks that would be required from the guesthouses
currently there. There is no way an addition of this size could fit on the opposite side,
given all those setbacks from four different places.
CHAIRMAN: Mr. Uhl is it tree that the backside of the house houses the bedroom area
of the house?
CHRIS UHL: Which
CHAIRMAN: Thc southeast side, the present house as it exists'?
CHRIS UHL: Yes, the southeast side does have a bedroom.
CHAIRMAN: Where the side that you're proposing this addition, is basically part of the
living area of the house, is that correct?
CHR1S UHL: Currently, there's a garage on the north side. There will be a master
bedroom in the proposed addition.
RICHARD LARK, ESQ.: He means in the existing house.
CHAIRMAN: That's converted to living area.
RICHARD LARK, ESQ.: That's converted to living area and then you have the kitchen,
and the living room.
CHRIS UHL: The kitchen is in the middle of, roughly the northeast side.
MEMBER OLIVA: Mr. Uhl, do you have two lots here, 219 and 220 and what are the
two structures on lot 2197 There's one story a far house?
CHR1S UHL: There's a one story, that's the guesthouse.
MEMBER OLIVA: And how about the other one to the southeast, a shed and a
boathouse?
CHRIS UHL: Right, correct that is not, there's no living space there.
MEMBER OLIVA: That's one lot?
CHRIS UHL: Yes.
CHAIRMAN: Any other questions ladies and gentlemen?
MEMBER ORLANDO: One tax lot.
CHAIRMAN: Any other questions of Mr. Uhl, anybody?
RICHARD LARK, ESQ.: Wait a minute, does that answer your question Ms. Tortora, as
to why they did site it on the other side of the easterly side? Okay.
CHAIRMAN: You're going to pose this question to us?
PATRICIA MOORE, ESQ.: How would you like it?
Pagc 8, Febtxmty 28, 2002
ZBA Public Hearing Tmnsc~qpt
Town ol South~qd
CHAIRMAN: Pose it to us.
PATRICIA MOORE, ESQ.: Okay.
CHAIRMAN: Wait a minute Mr. Uhl; I think this question may involve you.
PATRICIA MOORE, ESQ.: Has the existing garage on the side of the Cella property,
has that been enclosed into a living space or for perspective living space?
CHRIS UHL: Yes.
PATRICIA MOORE, ESQ.: Do you understand that?
CHRIS UHL: Yes.
PATR1CIA MOORE, ESQ.: So it's no longer a garage?
CHRIS UHL: It is no longer an active garage.
PATRICIA MOORE, ESQ.: And on the easterly side, you said the kitchen was in the
center area, okay. Then on the easterly side of the property, the house, pardon me that
also am the bedroom area, correct on what you've described?
CHRIS UHL: Yes.
PATRICIA MOORE, ESQ.: Okay, and what they've proposed as far as an addition is a
garage first story, correct?
CHRIS UHL: Correct.
PATRICIA MOORE, ESQ.: And then the second story being bedroom/living area?
CHRIS UHL: No the garage is a single story and off the garage is a single story addition
built into the side of the hill. The first story containing a new master bedroom and the
lower story is vacant space.
PATRICIA MOORE, ESQ.: Okay. So it's a combination of bedroom and garage in that
addition?
CHRIS UHL: Yes. All one story tall.
PATRICIA MOORE, ESQ.: Okay, so you're two stories is actually first floor into the
basement and then a walkout?
CHRIS UHL: Correct.
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ZBA Public Hearing Tlansc~ipt
PATRICIA MOORE, ESQ.: Okay, good. All right. This is not really a question, this is
more of a statement, that the design that they've proposed would work equally well on the
easterly side given that both sides now are living space. The easterly side is a bedroom
area with the addition being bedroom area and garage so thc fact that the use has been,
you've designed a certain use, you're still talking about the same garage bedroom
combination as part of that 63 foot, 31 foot addition.
CHRIS UHL: There is property lines setbacks on the opposite side.
PATRICIA MOORE, ESQ.: But I thought it was one piece of property?
CHRIS UHL: It's separate tax lots here.
PATRICIA MOORE, ESQ.: So it's two lots?
CHRIS UHL: As far as the Building Department is concerned, we would have to have a
setback offthe property line that intersects the properties. The line labeled 81 degrees
PATRICIA MOORE, ESQ.: Yes,
CHRIS UHL: Right, we would need a setback off of that line, according to the Building
Department.
PATRICIA MOORE, ESQ.: Well, I don't have a ruler here but what would you have
estimated from the survey looks to be pretty generous. It looks to be at least 60, 70 feet
more or less as on the angle.
CHR1S UHL: Yes, the addition is 30 some odd feet wide and it wouldn't fit in that.
PATRICIA MOORE, ESQ.: Even if you have 31 feet following the length back, the
same direction, just flip it, wouldn't you still have about 30 or 40 feet to the property line.
So the Building Department shouldn't give you a problem with that side yard.
CHR1S UHL: Well, you can examine for yourself the map that
PATRICIA MOORE, ESQ.: I have the map, that's what I'm looking at.
CHRIS UHL: No, not this map, the map that the Building Department gave us.
CHAIRMAN: Marked up in the file.
MEMBER OLIVA: Mr. Uhl, then that gnesthouse actually extends into both lots?
CHRIS UHL: Yes it does and if they ever want to sell this piece of property, that has to
be addressed.
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ZBA Public Hearing Transcript
MEMBER OLIVA: Did they build this house or was that pre'?
CHRIS UHL: This house was built in the 1960's and thc Rust Family built it but, and
they have a C.O. for it and they have all the paperwork tbr it.
MEMBER OLIVA: On the guesthouse?
CHRIS UHL: Yes.
PATRICIA MOORE, ESQ.: It would see to me that the Building Department wouldn't, 1
mean aside from your title issues of encroachments, which could be worked out, you're
attorney could advise you how it gets worked out. But that's not such an insurmountable
problem. The setbacks that the Building Department should be considering, I think
there's more room on that side than there is on the other side. So I don't know that, maybe
the Building Department was in error and might be helpful to try to stop the surveyor so
that you know for sure. Quite frankly it looks to me like there's plenty of room.
CHRIS UHL: Well you can examine the map that the Board has that the Building
Department gave to us.
PATRICIA MOORE, ESQ.: I understand that, I sometimes, I many times do not agree
with the Building Department. That's why we're here a lot of times.
CHRIS UHL: We can only follow what the Building Inspector tells us.
PATRICIA MOORE, ESQ.: l understand, but I think it would be helpful before you
come to a conclusion it can't be done, to actually have a surveyor who has the proper
dimensions to tell you that. I think that the Zoning Board should be asking for, I would
ask the Zoning Board that they should ask that it be properly plotted so that we know
whether or not it's a legitimate argument that it can't be done on the opposite side; where,
again, it only impacts that family, not anyone else. And again, from what Mr. Uhl has
already pointed out, the design quite frankly looks like it could even be used on the other
side because you do have a stone gravel driveway that looks to run, could easily go into,
since it ends at sort as the east, it could easily enter and go into the garage on the east
side. So there is certainly flexibility here. This is a large piece of property and there's
plenty of room to re-design or even use the same design on the opposite side.
CHRIS UHL: The driveway is not the issue, the issue is the setbacks from the property
line and as far as the Building Department is concerned you have two pieces of property
and there are setbacks from both and from the from and from the rear, the zone line
PATRICIA MOORE, ESQ.: I understand that.
CHRIS UHL: And I do not believe according to their map that there's enough space to
have this addition on the other side.
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I own of Soulhold
PATRIC1A MOORE, ESQ.: We are certainly not opposed to any application of a
variance from a front yard, if you even need it, because I don't think you do. And from a
side yard from the other side, which I don't think you do either. So, as to Mr. Uhl's
arguments 1 don't believe that they're strong enough to change the character of the area.
Let mc go back to the issue that as far as which setback applies. When you'rc dcaling
with, if you were building, creating a lot out of a sub-division and you were in a R40
Zone, you'd look at that schedule. When you have lots even though they're in an R40
Zone than the other size criteria, I've always been under the impression, and I think that
the Buikling Department would agree, you apply 102-44; which has differing setbacks
depending on the size of the property. Because, even though you're in an R40 Zone, if
you have two acres, you're not supposed to apply the one-acre setback. So I think that the
Building Department again, I would disagree with their initial review of this application
and that, at best, they must keep to 20 feet given their argument and depending on how
you rule on the fight-of-way 50.
CHAIRMAN: Mr. Uhl what is thewidth ofproposed addition?
CHRIS UHL: Approximately 31 feet.
CHAIRMAN: 31 feet wide?
CHRIS UHL: Correct.
MEMBER TORTORA: 31 by 63'?
PATR1C1A MOORE, ESQ.: 63, that's what the survey shows.
CHAIRMAN: Mrs. Moore is there anything else; we would like to move this along?
PATRICIA MOORE, ESQ.: No, thank you.
CHAIRMAN: Anybody else? Seeing no hands, I'll make a motion closing the hearing,
reserving decision. Thank you all for coming in.
SEE MINUTES FOR RESOLUTION
7:26 p.m. Appl. No. 4927 KACE LI, iNC. (Carryover from January 24, 2002.) This is
an Appeal requesting Reversal of the Building Inspector's Notice of Disapproval dated
August 13, 2001, which disapproval denied an application for a building permit for two-
family dwellings under Article IV, Section 100-42A.2. The reason stated in the Notice of
Disapproval is that the proposed project indicates several two-family dwellings on a
single parcel, and that the Code allows only one such structure per lot as a permitted use.
Zone District: Hamlet-Density (HD). Location of Property: South Side of North Road or
C.R. 48, 500+- feet east of Chapel Lane, Greenport; Parcel 40-3-1, now or formerly
referred to as "Northwind Village" site. M. Pachman, Esq.; A. Tohill, Esq.
Page 12, FcbmaI3, 28. 2002
ZBA Public [leafing q ~m~sc~ipl
CHAIRMAN: I would like to re-open Appeal ,04927. Mr. Pachman? 1 would like to just
set some quick ground rules on this. What I would like to do is, after your presentation of
course, we'll take any information from counsel, opposing counsel and I guess we'll give
opposing counsel some time to react to what you say tonight, both of you actually.
MATTHEW PACHMAN, ESQ.: I don't mean to interrupt you Mr. Chairman. Do you
mean additional adjournment?
CHAIRMAN: No. As I said this would be reduced to writing. That's basically it. So we
will ask yon to proceed sir.
MATTHEW PACHMAN, ESQ.: Thank you Mr. Chairman, Members of the Board.
Good evening, it's nice to see you again. I know that the first time that the applicant
appeared on this application was in September, so we're at about our half-year
anniversary. I'm glad to hear Mr. Chairman that we are close to being able to give this to
the Board tbr its decision. When we were here last time we heard a presentation by Mr.
Emilita, those of the Board that were here. And a discussion of certain cannons of
statutory construction by Mr. Tohill, and I was struck by two things listening to that
presentation. The first is that most respectfully Mr. Emilita's presentation was, I would
suggest replete with possibility inadvertent errors of both law and tact and that Mr.
Tohill's discussion of statutory cannons were for the most part absolutely correct, but we
would submit when applied to this case, (re-adjustment height of microphone) but that
when those cannons are applied to this case, they inure to the benefit of the applicant and
I would like to take a moment to explain why. First I wanted to insure that the Board was
not overly taken with the fact more than a decade ago, for a period of time, Mr. Emilita
was a consultant to the Town. So I asked, who ! think we can all agree is, possibly the
pre-eminent expert on planning and land use matters in this county, Dr. Lee Koppelman
to do an independent review of the application and of Mr. Emilita's analysis and come to
his own conclusions for the Board's benefit. Now although Mr. Koppelman is teaching
as his royalized professional political science and director of the center for regional
policy studies at SUNY/Stonybrook tonight, he does have this affidavit that I would like
to submit to the Board. And the record should reflect I've given a copy to Mr. Tohill. I
know that you have some members sitting up on the dais who have not been part of this
application before. I don't know if they are going to participate in the decision-making, I
do know that Mr. Tohill's application and submissions have been filed for several weeks.
So, Mr. Chairman, with the Board's permission I would just like to read a few sections of
Mr. Koppelman's Affidavit for the edification of the Board. He lists or he goes through
each and every paragraph of Mr. Emilita's analysis and he notes that Mr. Emilita, his
objections pretty much can be put into six sections. The Thursday's that the mention of
the site plan is no longer valid according to Mr. Emilita, well, again, Mr. Chairman and
Members of the Board the Building Inspector has listed only one basis for a Disapproval
and his Notice of Disapproval and that's the only issue that has been before this Board,
The issue is limited, narrow and focused. Any other issue such as the validity of the 1983
site plan is beyond the scope of this application. Mr. Emilita's second claim is that more
than one family or one two-family dwelling is considered a multiple dwelling under the
Code. Now, Mr. Chairman and Members of the Board, this is very important because
cmnuli and indisputably that's not correct. The (:'ode defines what a multiple dwelling is
and a multiple dwelling is a building with three or more dwclling units which absolutely
bas been said over and over again, is not what the applicant is looking to building. This
is what Dr. Koppelman says about Mr. Emilita's analysis. He says, upon closer scrutiny
the reason ilar Mr. Emilita's attempt at statutory Alco my as the affidavit says, becomes
clear. Without this, under his theory the applicant can building only one two-t:amily
house but may multiple dwelling units. Which, Mr. Chairman and Members of the Board
are listed as a conditionally permitted use and we ali know that a conditionally permitted
use actually constitutes a legislative finding that such dwellings are in harmony with the
community's general zoning plan and are not adversely affcct the neighborhood. And
this is exactly the position which the Building Inspector has taken in his ietter to the
applicant dated August 9, 2001, a copy of which is attached and I believe is already in
your file. In other words, the reason why Mr. Emilita tries to change the very clear
reading of what a multiple dwelling is because he understands that otherwise the absurd
result is the one that the objectors are bringing forth. You can actually have multiple
dwelling units on that property as a legislative determination that it fits with the character
of the zoning plan and will not adversely affect the neighborhood and under their
interpretation you can only have one two-family dwelling. His next objection is that one
must read the Code Section we're talking about, 100-42A in the context of the entire
Code. Well we all dream of that and this again highlights the flaw in Mr. Emilita's
analysis because as we've discussed, in every other residential zoning district in the Town
of that's AC, R80, R120, R200 and R400 there limiting language which says one-family
detached dwellings not to exceed one dwelling per each lot. The Code is clear, it's
consistent and it is unambiguous when it wants to limit the dwellings to only one per lot.
In stark contrast 100-42A does not have such limiting language. The next objection is
that according to Mr. Emilita by a coronary reasoning process, they would be required on
a near application for a Building Permit, one would be allowed to build more than one
two-family dwelling without reference to the dimensionaI requirements of the Code, the
site plan requirements of the Code, without consideration of the availability of public
water or public sewer and would read Section 100-42B, that's the conditional permitted
use section out of the Code. Mr. Chairman and Members of the Board that quite frankly
and most respectfully is flat wrong. The application that the applicant has put forth
complies with all of the bulk and dimensional requirements as contended in the Code.
For example if the one half acre density of the 20,000 square feet density, the applicant
could construct 44 structures and the site plan only shows 27 structures. It has never
showed issuance of the Building Permit prior to the availability public water or sewer or
without site plan approval and the proper interpretation of this Code Section would leave
those requirements unaffected this argument is nothing more than a red herring. The next
objection in Mr. Emilita's analysis is that the proper interpretation would read, Section
100-42B the conditional permitted use out of the Code again, that's simply not correct.
Kace has never made such a claim and there was no such Interpretation before the Board.
Multiple dwellings do and would still be required to get a Special Permit or Special
Exception approval by this Board. Finally, he says the legislative intent supports the
Building Inspector's Interpretation as contained in the Notice of Disapproval. As we
have discussed there is no need to look to legislative intent if the Code as here is
Page 14, Februm7 28, 2002
ZBA Public Fleming Ttanscripl
unambiguous. But, you have to recall what I said before, that it is under Mr. Emilita's
analysis which the absurd result would occur because you could comment in here, meet
thc conditions of the Special Exception which has been determined legislatively to feed
within the Zoning Board of Southold Town that you could finally build one two-fhmily
house. Thus, Dr. Koppelman says that in his opinion, the relief requested by the
applicant should be granted. With respect to the statutory construction analysis that Mr,
Tohill discussed last time he referred to the case books on statutes and the general
construction law and I would like to just re-emphasize some of the things that he said
because, again, we respectfully submit that those very general, those very cannons, if
they are necessary to be applied fully support the applicants position. (break in tape)
First, one that Mr. Tohill did not or a rule that Mr. Tohill did not raise, is that its
hornbook law, Members of the Board, zoning restrictions are in derogation of the
common law property fights and must be strictly construed in any ambiguity, if there is
one in the Code, must be resolved in favor of the property owner. Second, the legislative
intent is to be ascertained from the words and the language used and that's McKinney's
Statute Section 94, and the Code has to be read as a whole. All the parts have to be read
and construed together; you must get the effect and meaning to the entire Code and to
every part thereof. And that's why you must read the limiting language in Section 100-
31, the Section which talks about every other residential zoning district in the Code and
compare it to the absence of such limiting language in 100-42. Second, pursuant to the
General Construction Law Section 41, and the New York State Town Law Section 63
and Members of the Board this is very important because this addresses one of Mr.
Emilita's arguments. A Town Board acts in each instance in one way and only one way
to run affirmative vote of the majority of its members and it does not act by the opinions
of its consultants or its attorneys and so this argmnent that the reason that Section 100-31
has limiting language and 100-42 doesn't is supposedly because a consultant wrote one
section and an attorney wrote another section is absolutely irrelevant. The Town Board
adopted the Code, it adopted the Code at the same time, and it adopted the Code as an
integrated whole and each part of that Code must be read together and harmonized. The
Sections were adopted simultaneously, and the distinction between the limiting language
in the first Section 100-31 and the conspicuous absence of that same language in 100-42
was not inadvertent. Finally, when the law expressly describes a particular thing to
which it should apply, like this limiting language, there is according to statute Section
240, an inference that what was admitted or it is not included was intended to be omitted
or not included. That's the omission of the limiting language in 100-42, which was
expressly put into 100-31. And there is an expression, it's a Latin expression, I'm going
butcher it I'm sorry but I'm going to give it my best shot here, expressio unis es excusio
auterios and the reason I say it is absolutely a very important rule of statutory
construction and that says, when language such as a limiting language is expressly
provided in the five other pertinent residential sections of the Code and not in Section
Code 100-42 it was intentionally omitted and excluded from that Section. The inclusion
of something in one part means that the exclusion of it in another part was intended.
Also, just as Mr. Tohill said, statute Section 145 says it is presumed that the Town Board
intended to map something which was reasonable and that no unreasonable or absurd
result was intended from the Board and should be interpreted by this Board and that's
exactly correct. It would be absurd to say that you could only build one two-family
Page 15, Feb~ um~ 28. 2002
ZBA Public llcm'ing Tmnscdpt
house on that lot, but you could build multiple dwellings, many multiple dwellings on
that same lot pursuant to a conditionally permitted use which again, is actually a
legislative determination that such is in harmony with the community's general zoning
plan and will not adversely affect the neighborhood. Finally, a legislative body such as
the Town Board has the right to define any word or phrase it chooses to in the statute,
that Statute Section 75.B and that's what the Town Board did when it enacted Section
100-13A which reads word usage, the singular number includes the plural and the plural
the singular. Not only that, Members of the Board but the General Construction Law says
the same thing. It says in the General Construction Law Section 110, and you know
what, the General Construction Law says that that is applicable to every statute. It says in
Section 35, words in the singular number include the plural and the plural in the singular.
Thus, Section 252 the section of the statute that Mr. Tohill refers to is superceded by both
Code Section, Southold Code Section 100-13A and General Construction Law Section 35
and is inapplicable to this matter. Last, another phrase that Mr. Tohill used last time, he
parried material. Well that's correct. When different terms are used in various parts of
the statute like the Zoning Code you must assume the distinction between the terms is
intended and you must read the entire Code together. Mr. Chairman and Members of the
Board when you clear the smoke away we respectfully submit this application is clear
and its relatively simple. The Interpretation of by the Building Inspector flies in the face
of the unambiguous reading of the Code as a whole, it leads to an absurd result and it
should be overturned. Thank you very much.
CHAIRMAN: Any questions of Mr. Pachman before he sits down? Mr. Tohill how are
you tonight?
ANTHONY TOHILL, ESQ.: Good evening Mr. Chairman and Members of the Board.
My first question has to do with housekeeping, and I would like to know whether Miss
Oliva and Mr. Orlando have a copy of the package that I presented at the last meeting and
if they don't, l did knock down a cherry tree this afternoon and I have two more packages
that I'm ready to hand them up right now.
MEMBER TORTORA: Its not necessary, the Board Members have familiarized
themselves with the full record, have ready all the transcripts, have read all the record
including the handups that you presented at the last hearing.
ANTHONY TOHILL, ESQ.: I'm asking as a courtesy from me to the Members of the
Board whether or not they have separate copies of all the packages that I handed up. Is
the answer yes?
CHAIRMAN: I do not Mr. Tohill. You did not give me one, you gave one for the
record, and I was reading in the office on Saturday morning, so I would love one.
ANTHONY TOHILL, ESQ.: Okay.
CHAIRMAN: Thank you sir.
MEMBER TORTORA: We were so conscious about this that we gave the Chairman's
file to the members.
ANTHONY TOHILL, ESQ.: Let me bring this back to a context that is as practical as 1
can make it practical. (microphone adjustment) that got us here to the Zoning Board of
Appeals. Each of those tbur Building Permits recites the intended use of the property.
Not my language, it's the applicants language, multi-family use as per approved site plan;
two different concepts. We're here because the Building Inspector denied the application
for Building Permits, not recipes for chili contests, Building Permits. That means that if
the Building Permits am issued, bulldozers go there and they start building buildings.
But buildings that they build, according to the applications that are the only records
before the Town, four of them, are multi-family use as per approved site plan. So that's
the first point. Second, how many two-family houses are you allowing that you draft the
relief requested. Don't all answer at once because you may speak in lbur different
tongues, and in thct, if Matt Pachman and I are given a chance to speak, we may raise it
to six and if we give everybody in the audience a chance, we may raise it to a infinite
number and the reason is, there is no number, there is no number at all. Nobody knows
the number. However, if you deal with this on the level of abstraction that was offered to
you as the path to redemption by the applicant's attorney here this evening, you have to
appreciate that you are going to allow a Building Inspector, you are authorizing the
Building Inspector to issue four Building Permits for an unknown number of multi-family
use as per approved site plan. However, you do know that there is a site plan, the 1983
site plan, you do know that that site plan became invalid in 1985 under Local Law I 1 of
1985, it was enacted twice. You do know that that site plan became dead again, more
dead than it was under Local Law 11 of 1985, under Local Law 1 of 1989 because the
Town Board again changed the district to HD then light residential, multi residential and
increased the density so that that as per approved site plan that was now sent to you four
times because it says so four times in the site plan application, is no approved site plan.
So, if that's the way it's going to be handled then the level of obstruction is no rule out of
this, that means that everybody in this town who has a single-family residence in a single-
family residential district, you just read one hell of a Code. In fact any place that there's a
nmnber you read it out of the Code and the reason is none of us knows what the number
is as a matter of fact. That's why this whole argument is what I told you the last time
holding up meets the mischief that you have here is that you're going to
encourage not to read all of Chapter 100. Never see that presentation with a straight face
before any agency, I cannot imagine what it would be like in this Court of law to say to a
judge, judge don't read all of the law, don't go to law school for three years, go to law
school for one week. lts much more economical, you'll start earlier, you will make more
money don't waste your time spending those additional three years or whatever it is in
school. Here you are actually being encouraged to hang a premium, a premium on
ignorance don't read Section 250 of Chapter 100 that says you can't have this land use
without site plan approval, l want to ask you also; you solicited the opinion of your
Planning Board in the document that I handed up, the booklet that looks like this. That
document is Exhibit Z, the last letter in the alphabet. It's a September 22, 2001 memo
from the Chairman of the Planning Board. He's either taken leave of his senses
altogether, lost all track of any understanding of land use or he made an error, an
absolutely terrible error. He said to you that this application, these applications, we're
going with can't perceive. He said because there's no site plan approval. He said it needs
SEQRA review, he said it needs Suftblk County Power Commission approval. He says it
needs Suttblk County Health Department approval; he says it needs Suffolk County
Department of Public Works approval; he says it's not for the use that was approved in
1983. He says it's i-bt a different project from the approved site plan, as per approved site
plan. He has not taken leave of his senses. He's speaking in complete sense. This is an
application l-hr four Building Peianits. Understand the implications of what you're being
asked to do. You're being asked to direct the Building Inspector, to authorize the
Building Inspector to approve those Building Permits. When Mr. Pachman argued to
you, don't look at anything else, that encourages you to be embarrassed in front of many
of us who have nothing but respect for this institution and for each of you. Because if
you were ever to buy into that line, can you imagine what would happen in the weeks
ahead at Mike Verity's desk. We don't know what was approved, we can't it; when he
wrote the denial letter he had no obligation to act as a lawyer, he had no obligation to
send to you a memorandum of law, which by the way was left with you this evening as if
I were alone with the Chairman, chicken liver, he doesn't get a copy of anything and 1
don't even get a response to what I spent all that time writing. I assure you that when this
case, if it ever does, get to a court of law, we will not be hearing the argument that you
heard as the whole presentation seeking by the applicant. Don't read the entire book,
you'll get confused, it has nothing to do with anything, just handle one section. Thank
you.
CHAIRMAN: Mr. Tohill you did get a copy of Mr. Pachman's response, did you not?
ANTHONY TOHILL, ESQ.: I'm sorry?
CHAIRMAN: You did get a copy of Mr. Pachman's response?
ANTHONY TOHILL, ESQ.: You mean this copy of this Affidavit?
CHAIRMAN: Yes.
ANTHONY TOHILL, ESQ.: I just got it here this evening, 1 haven't read it and I am
going to ask as you offered before to respond.
MATI'HEW PACHMAN, ESQ.: Mr. Chairman, 1 apologize did I a copy of Memo of
Law to Mr. Tohill I didn't, I apologize.
ANTHONY TOHILL, ESQ.: l have nothing except the copies of
handed in?
· When was it
CHAIRMAN: Just now.
ANTHONY TOHILL, ESQ.: Oh, I didn't see you hand that in.
Page 18, Feblxmly 28, 2002
ZBA Public Hcm-ing Tlansc~ipt
MATTHEW PACHMAN, ESQ.: Did 1 get it up to the Board?
MEMBER TORTORA: A Memorandum of Law from you?
MATTHEW PACHMAN, ESQ.: Yes, the Memorandum of Law.
MEMBER TORTORA: No, we have the Affidavit of Mr. Koppelman.
MATTHEW PACHMAN, ESQ.: Mr. Chairman, I am handing up copies of the Memo of
Law, I apologize. I thought I had and I'm giving a copy to Mr. Tohill. If I might briefly
respond to Mr. Tohill's statements because I feel as if Mr. Tohill, fbr whom 1 have great
respect, didn't hear the arguments that I was making; indeed it is the opposite of his
claim. You must, in fhct, read the entire Code. Now, Mr. Chairman and Members of the
Board, l continue to say what I said at the last meeting, and what I said at the meeting
befbre, because it doesn't matter how many times the opposition makes the claim, there is
only one issue and one issue alone bdbre this Board and that's the Interpretation, excuse
me, the Notice of Denial it is the amended Notice of Denial of the Building Inspector
dated August 13, which denied the application on one ground. The reason why I didn't
comment on Mr. Tohill's Memorandmn of Law but I will now; because that
Memorandum of Law whether its contents are right or not right, whether I would agree or
would not agree, talk about issues which are absolutely irrelevant to this application
because that entire memorandum of law deals with whether the 1983 site plan is still
valid. And Mr. Chairman and Members of the Board, 1'11 say it for the third time tonight,
maybe for the tenth time during this entire application, that's not the issue before the
Board, that's not the issue that the Building Inspector denied the application on, this
Board has a limited jurisdiction, it is to interpret and review the determination of the
Building Inspector as contained in that August 13th Notice of Disapproval and that is the
only issue and that is the only jurisdiction of the Board.
MEMBER TORTORA: I have a question for you Mr. Pachman'?
MATTHEW PACHMAN, ESQ.: Sure.
MEMBER TORTORA: Mr. Tohill suggested that there are four Building Permit
Applications. For the record, have you or have you not withdrawn all prior applications
before this Board?
MATTHEW PACHMAN, ESQ.: Yes, other than the one that led to the August 13th
denial l?om the Building Inspector.
MEMBER TORTORA: Have they all been formally withdrawn as a matter of record?
MATTHEW PACHMAN, ESQ.: Well, I believe they have because I believe that in the
file we have a
MEMBER TORTORA: We have correspondence, yes.
MATTHEW PACHMAN, ESQ.: correspondence. They absolutely have it, there is
correspondence to the Building Inspector, and if there's any ambiguity, wc will continue
to say it, we'll say it today, we'll say it later on if the Board wants; there is one Building
Application which is before the Town at this point, it was the one that led to thc Notice of
Disapproval in August 13th, it was the one that was the basis of the amended Notice of
Disapproval and the one that we are before here today.
MEMBER TORTORA: Okay, for the sake of time could we wrap this up so and we
would like to close this hearing tonight.
CHAIRMAN: No we're not closing it, we're closing it to verbatim only.
MEMBER TORTORA: Exactly.
CHAIRMAN: What we're requesting is from Mr. Tohill is approximately ten day
response.
MEMBER TORTORA: Ten days, both of thern.
CHAIRMAN: Yes, and a ten-day response from Mr. Pachman.
MEMBER TORTORA: Both of you, ten days.
CHAIRMAN: That puts us at the 21s~ meeting.
ANTHONY TOHILL, ESQ.: Let's do a quote, ten days from today and be done with it.
CHAIRMAN: Well because
ANTHONY TOH1LL, ESQ.: It'll go on and on and on and on.
MEMBER TORTORA: No ten days for both of you, not ten days for you and ten days
for him.
ANTHONY TOHILL, ESQ.: That's exactly what I'm saying.
MEMBER TORTORA: Ten days for both of you at the same time.
MATTHEW PACHMAN, ESQ.: Then I may receive his on the tenth day, you know
ANTHONY TOHILL, ESQ.: I'll hand deliver it.
MEMBER TORTORA: In fact, we will all receive the same information on the same
day.
Page 20, February 28, 2002
ZBA Public llearing Tr*mscript
Town ot~ Southold
ANTHONY TOHILL, ESQ.: Exactly.
MEMBER TORTORA: But we can't go back forth, with you responding to him and you
to responding to. There's more than sufficient evidence on the record at this point, for
this Board to make a determination. Make your closing statements; let's be done with it.
ANTHONY TOHILL, ESQ.: I agree, goodnight Grace.
CHAIRMAN: Trust me it's not going to happen.
ANTHONY TOHILL, ESQ.: So ten days from today?
MEMBER TORTORA: Correct.
MATTHEW PACHMAN, ESQ.: As I understand it, if Mr. Tohill hand delivers this to
me on the ninth day, then I have a day to respond?
CHAIRMAN: No, that is not correct.
MEMBER TORTORA: You both have ten days.
ANTHONY TOHILL, ESQ.: Jerry, let's do a Monday; what's a Monday, not this coming
week but the following week? Does anybody have a calendar? The 1 la'? March 11~',
everybody submits on that day and that's it.
MATTHEW PACHMAN, ESQ.: That's precisely what the Chairman is not saying;
normally the applicant has the last word because it's the applicant's application.
CHAIRMAN: We'll give everybody until the 15th.
ANTHONY TOHILL, ESQ.: Okay, the 15th and that's it.
CHAIRMAN: Right. If there's any problem Mr. Pachman, let us know. Please
remember before you two gentlemen leave that we will be closing the hearing on the 21~t.
MATTHEW PACHMAN, ESQ.: Thank youMr. Chairman and Members oftheBoard.
(break at 8:05)
CHAIRMAN: For the people who have not been before the Zoning Board of Appeals,
we do have another member who is a Fishers Island Member who comes over religiously
for every Regular Meeting, this is a Special Meeting, which we quite honestly don't have
Public Hearings at. And I'll make a motion going back into Public Session.
8:10 p.m. Appl. No. 5051 - CLIFF AND PHIL'S LOBSTER HOUSE/RESTAURANT -
Based on the Building Department's Notice of Disapproval issued November 13, 2001,
Page 21, Febnlary 28, 2002
ZBA Public Hearing Transcript
Town of Soutbold
amended November 14, 2001, applicant is requesting: (a) an Interpretation under Article
XXIV, Section 100-243 to Reverse the Building Department's determination which stated
that the proposed addition/alteration to an existing restaurant establishment is not a
permitted use in the residential R-40 District, o~r alternatively a Variance under Section
100-243A authorizing the proposed addition to the existing restaurant, a nonconforming
use in a nonconforming building; and (b) a Variance under Section 100-244B to locate
the proposed addition maintaining the same nonconforming setback at less than 35 feet
from the property line; and (b) a Variance under Section 100-244B for a total lot
coverage in excess of the code limitation of twenty (20) percent of the total lot area.
Zone District: R-40 Residential. Location of property: Corner of the East side of
Kenney's Road and the South side of North Sea Drive, Southold; County Tax Map Parcel
1000-54-5-22. George Tsunis, Esq.
CHAIRMAN: I want to say Mr. Tsunis that we agreed to have this hearing be held
tonight, however, as you know there are now three Notices of Disapproval.
MEMBER TORTORA: Two.
CHAIRMAN: Are there not three? Didn't we receive one today? We did not receive
another one today?
GEORGE TSUN1S, ESQ.: No, I have no notice, not that I'm aware ot~
CHAIRMAN: All right, well then let's go back on this then. We have two Notices of
Disapproval. The Public Hearing is based upon the first Notice of Disapproval. And we
may restrict you to a specific situation tonight because this is going to be a preliminary
hearing, and we are going to complete this hearing on the 28th of March, at which time
we will re-advertise the second, both the first and the second Notices of Disapproval. By
law, we discussed this with counsel last night and we cannot complete this hearing
tonight because we are only dealing with that Notice of Disapproval, which was first
given to us when it was filed by the applicant prior to you being on Board. Just so you
are aware of that situation. I would appreciate it tonight if you could get into some of the
use variance aspects of this case, and we'll go from there.
GEORGE TSUNIS, ESQ.: Mr. Chairman, just for my own edification, it was my
understanding that before the public notice came out I mailed a letter to yourself, also to
the attention of Linda and Paula in the Zoning Board Office dated February 13, it went by
telecopy asking that the application be amended to include both the Code Interpretation,
as well as, the Use Variance. It is my understanding that was received by the office
before the public notice was made, and they would be able to put on both applications
and try to provide you with both sets of proof. If that is not the case, Mr. Chairman, I am
rd
more than willing to come back on March 23 , at your indulgence, and provide whatever
you need.
MEMBER TORTORA: We do have the amended Notice of Disapproval. The problem
probably isn't yours. What happened was the original Notice of Disapproval was issued
Page 22, Fcbmmy 28, 2002
ZBA Public Hearing I mnsctipI
MEMBER TORTORA: Yes, I'm sure. To make a long story short, what happened
subsequent to that, was you then went back and had a survey donc, developed the
blueprint elevations, revised the site plan three times, the calculations on the revised site
plan the Building Department simply hasn't seen any of those. So, between Novcmber
and all of the revisions and the plans that you developed have not been reviewcd by the
Building Department. So, at this point, we can't sit in judge and jury of ourselves and our
jurisdiction, as you well know, is appellate only.
GEORGE TSUNIS, ESQ.: I don't blame you; I'm very sensitive to that. We'll be happy
to finish it up on March 28th. It would be a privilege to appear before you again. Let me
start by apologizing at the outset. The relief that I'm requesting from this Board is both
under Town Law 267B.1 Code Interpretation, and 267B.2 Use Variances. There are
some similarities in places; my comments are peppered, so if I'm a little redundant and I
inadvertently get into matters that are published, please fbrgive lne. I'll try to keep my
comments to on the Use Variance application.
CHAIRMAN: Symmetrically what I said in the beginning, we would like you to take
whatever has not gone to the Building Department and give it back to me, so in case we
get a third interpretation, which I was misconstrued about tonight, we can incorporate
one, two and three into a final public hearing notice which will then allow us to complete
the process of this particular project.
MEMBER TORTORA: So they can review it. In other words, they can review all the
revisions you made and
CHAIRMAN: And I honestly think you can do that in 30 days.
GEORGE TSUNIS, ESQ.: Yes, I will be happy to come meet with the Building
Department, with the Zoning Enforcement Officer and work everything out.
CHAIRMAN: Right.
GEORGE TSUNIS, ESQ.: Thank you. Good evening Mr. Chairman, Members of the
Board. My narne is George Tsunis; I'm with the law firm of Ritkin and Radler,
Uniondale, New York 11556. I am the attorney for the applicant, Cliff and Phil's Lobster
House, Inc., more commonly known as the Elbow East Restaurant. The premises are
located on 50 North Sea Drive, which is on the comer of Kenny's Road in the Hamlet of
Southold. The parcel is approximately 22,000 square feet. The current use of the
restaurant is pre-existing, non-conforming. 1 think it's fair to mention that the parcel was
also the subject of an up zoning approximately ten years ago. The site has had an
existing family restaurant of approximately 2800 square feet for as long as I'm told
anyone could remember. It's been in that community for decades and decades, a fairly
famous restaurant. And the community has grown in the short around this restaurant. It
pre-existed the later residential uses. Our proposal and the issue before this Board is to
seek relief to renovate the existing restaurant and to do an expansion of approximately
[~age 23, February 28, 2002
ZBA Public Heating Tt'ansc~ipt
Town of Southold
1400 square feet, which would provide fbr proper handicap access into the premises. A
suitable foyer and proper bathrooms, which would be A.D.A. compliant. As this Board is
very familiar, some years ago, congress passed the American Disabilities Act, and many
premises quite frankly have been slow to recognize and to spend their dollars to provide a
suitable and compliant facilities with the American Disabilities Act. The applicants are
willing to spend those sums to better service their clientele and their community. There
is a handicapped lifi that will be installed so patrons can access the upper portion of the
restaurant. If you've ever been there, or if you've seen the site plan, it's literally on two
levels and clearly someone in a wheelchair could not get up the stairs and we feel that
this is very sensitive and very appropriate. There's also a smoking area, an enclosed
smoking area. We want to enhance the lounge. Second-hand smoke has been one of the
largest problems that we face, so much so that thc Suffolk County Legislature and I think
legislatures all over this country have passed anti-smoking legislation. And what that
does is it mandates that restaurants provide a smoke-f?ee environment to their diners.
And if you're going to have a smoking area, you need to have an enclosed area, usually
by the bar. And if you're going to have an enclosed area, usually by the bar, it makes
some sense to provide some tables for those patrons that are smokers so we don't
discriminate. So patrons who are non-smokers can have a smoke-free environment and
enjoy their meal, and people who are smokers can also go into a small-enclosed area and
enjoy their meal. My request, 1 had two requests before you. Town Law 267B.1 gives
this Board tremendous latitude and powers to interpret the Code. My argument on March
28th is going to permeate that the Zoning Enforcement Officer did not factor in this
Federal and County law. And within this discretion that is given to you I'm going to ask
that those factors be taken into consideration. There will be a tremendous amount of case
law that ! will quote for you, where in the Court of Appeals in the Appellate Division
have done very similar things and I hope that's something that expositive in making more
decisions. We see use variances, especially in this case. When the applicant has special
circumstances the enabling acts provide more zoning powers, especially to this Board.
The standards to grant such variances were designed to give the Board a maximum of
discretion, a maximum discretion. Which means you have to consider the criteria which 1
will go into, you have a tremendous amount of discretion. If the application is proper and
special circumstances, the case law says special circumstances, exist to grant the reliefi
Any discussion of the Use Variance must start with unnecessary hardship. This is
something that the legislature codified into statute from the of 1939. Simply put
to achieve unnecessary hardship for it to exist, no reasonable return on an investment can
take place. No reasonable return on investment. That doesn't mean that they have to be
losing money. You have to determine that they can't make a reasonable return on their
investments. As a matter of fact, that's quite clear in a Court of Appeals decision in
Fayetville. You have to demonstrate factually by dollars and cents proof an inability to
yield a reasonable return. Dollars and cents proof.
CHAIRMAN: Mr. Tsunis, any case law that you intend to present to us, we would
appreciate copies of, and I see you have copies possibly in front of you.
GEORGE TSUNIS, ESQ.: I'll have that for the 28th sir.
Page 24, Febl'ualy 28, 2002
ZBA Public Hearing Transcript
CHAIRMAN: Okay, thank you.
GEORGE TSUNIS, ESQ.: As I said, dollars and cents proof. 1 have, and I would like to
submit as an exhibit fur this Board a letter from the applicant's accountants, which 1
would like to read into the record. The principal shareholdcrs are not receiving a return
on their investment. In order to provide necessary working capital, they're accepting less
enmneration than they could expect if they were employed by a business in the industry.
However, Ms. Volinski states that their losses have been reduced and it is reasonable to
expect that a positive rate on their investment could be achieved if we provide them with
an increased amount of business. I have certified financial statements by the applicant's
accountant, l provide two copies ['or you. If you would indulge me for a moment, page
one is a letter from the accountant certifying these financial statements. Page two has a
confirmation of the financial statements of the restaurant. If you notice for the year 2000,
the restaurant had a net loss of $21,000. No matter what they paid for it and I can tell you
they paid a pretty penny for it, a negative $21,000 is not a reasonable return on your
investment. In 2001, they lost approximately $4500. Clearly, I think you all can be
sensitive that these hard working taxpayers don't go into business, don't go into this very,
very difficult service business, work long and hard hours to lose money. The standard is
not even losing money. The standard is not achieving a reasonable return on our
investment. I would go further because here we're met with two standards, not one.
Because it's not an easy application, I'll grant you that. Each and every use permitted
now, can't achieve a reasonable return. The only thing that could be permitted now, god
forbid if the place was no longer there, is one single home. For the amount of money that
they paid for this commercial propcrty, what were a commercial property and an existing
business, mentioning knocking it down, clem'ting it up, cost, constructing one
house. It is extremely difficult; it's impossible to make a reasonable return on the money.
People do not buy existing commercial predecease operating for a couple of years, take
losses, then knock them down to construct one home. I think we meet that burden criteria
number one. As a matter of fact, I'm going to add it to another case, St. Albens
Springfield Corp. precana. We're going to require bank financing and this is where this
case speaks. We're going to require bank financing to do this. And I can tell you that the
lending institution is no fools. Sec a building, and this is the current state and I'll hold it
up and 1'11 show it to the audience. This is the current building. Quite frankly it leaves a
little to be desired. It leaves a little to be desired. This is the building. It looks like a
box. Quite frankly, it doesn't conform with the character and the nature of the
community from an esthetic point of view. And if you can see the proposed construction
area, I think that you'll see it rather modest. This is the current building, this is how it
looks; its gray, its clapboard, it could be better, it should be better, it should be beautiful.
We want to make it beautiful. We want to make it handicap accessible, We want to
provide big, beautiful bathrooms. We want to provide a foyer and an entranceway, so
people are not as you walk in, and you're allowed to take traditional notice on your own
personal experiences, if you've gone to the restaurant, you're permitted to do that. If you
go into the restaurant and you happen to have to wait Ibr a table on a Saturday evening in
the summertime, the only areas to wait are outside or you're literally right on top of the
patrons that are dining. It is very difficult to get into the bathroom because you literally
have to walk through tables, there's really no space. And the bathrooms are inadequate.
Page 25, Fcbmmy 28, 2002
ZBA Public Hearing Tlanscript
Like I said, it pre-existed tbr many years. That was permissible back then. It might have
been appropriate back then, but it's clearly not appropriate today. It's clearly not
appropriate today. What would wc like to do'? This is the proposal, I would venture to
say and this is the last criterion, more in keeping with the character and nature of the
community. This is the new building, or the proposed building I should say. Look at it,
it's stunning. It's beautiful, lt's obviously going to cost a lot of money.
CHAIRMAN: Before we conclude this hearing, ladies and gentlemen tonight, we'll have
these pictures up here and you'll be able to study them a little bit better.
GEORGE TSUNIS, ESQ.: Certainly, Mr. Chairman. It's a beautiful building. It's more
in keeping with the character and nature of the community. I think neighbors would be
happy, happier to have this proposed building. They would be happier to have this
beautiful building, one that's esthetically pleasing. One that is similar, closer to what
exists today in terms of style, esthetics and architecture. There has been case law, and I
quoted the St. Albins case, where banks when you have situations that render the uses in
the ordinance unfeasible create an unnecessary hardship. We're going to need bank
financing for this. So we've gone to banks and they said this is what you want to do, you
want to spend a lot of money, you're business isn't making any money and you want us to
believe in a dream and lend you money so you can renovate and make a more beautiful
restaurant. Well, we're going to require that you have a rate of return and it's exhibited in
the last two years through financial statements that you can't get a rate of return the way
the building is situated. You can't accommodate those customers and make a rate of
return. So to get the bank financing, they said you're going to have to make a business
that has an opportunity to make a profit so you can pay us back. This exists today, if 1
can analogize that case, we need a little bit more space so we can enclose a smoking area
so we could serve some more patrons, better, and so we can make a rate of return. The
second criteria tbr use variances are __ circumstances. We don't have to be the only
situation in the community. We have to be less than a majority. That's what the
Douglaston case teaches us. We have to be less than a majority. What the courts were
afraid of is that a Zoning Board would go ahead and once, it's a slippery slope, once they
gave one applicant this relief, then everyone would come out of the woodwork and get
similar relief. Well that's not the case here. There are no other restaurants in that
community. This is the only one; I think we can take traditional notice that it's the only
restaurant in this community, in this area, on that block. So if you grant the relief we're
requesting, you can do so without any fear that tomorrow there'll be another restaurant
that seeks to expand next door or across the street. Like I said, this restaurant has been
the subject of an up zone back in the early 1990's.
MEMBER TORTORA: Please don't comment while the speaker is commenting, let's
show everyone respect.
CHAIRMAN: Everybody will be sworn in, everybody will have the right to speak.
GEORGE TSUNIS, ESQ.: There's no self-created hardship here. There was up zone,
there was an up zone while it was a restaurant. There was an up zone while there was a
Page 26, Fcbrums, 28, 2(}02
ZBA Public Hearing h'anscnpt
restaurant. And it's equivalent to a take-in. The government took something that did not
belong to them and did not provide proper compensation or consideration fur it. And if
you look at the Muller's case when the courts upheld that, where moncy has been spent in
good faith, on a permitted use, which is no longer permitted, it's proper fur the Board to
consider the fact, notwithstanding that the hardship was self-created, lts proper tbr the
Board to consider that and it is. And I think everyonc would say that up zones, when
there's no compensation fur it, is fundamentally unfair. This has been a pre-existing
restaurant and if it was not for that up zone, we would not be here today. We would
literally go to the Building Department, stamp our approvals, provided that we meet all
the other codes, and we would be able to have what I'm asking for. We wouldn't need the
relief, but not for the up zone. The last criteria are no change in the character of the
neighborhood. I call this a practical common sense test. This would bring these premises
closer to the character and nature of the community. Like I showed you before, look at
the contrast. This is what exists today, not very, doesn't look a lot like a house. This is
what we're proposing to look at. Look at it, you would think it would be somewhere
between a church and a house; with peaked roofs and donners and beautiful, traditional
windows and clapboard. I think we've spent a lot of fune, and a lot of effort, and a lot of
money to design something and seek to build something that is more in k¢cping with the
character and nature of the community. We want to provide something that is
esthetically pleasing, that is more beautiful. That looks more like what is there today,
existing in the community. You will get a newly renovated restaurant. What does that
mean? That means brand new compressors, which are quite and state of the art. We
don't have to do that right now, but we'd like to, because we think its sensitive. And we
are very cognizant that we live amongst residents. And 1 think most people would say,
that they've been a good neighbor. In fact, I was told today, 1 was at the premises earlier,
and I was told that in the thirteen years there hasn't been an altercation. You don't have
thc police or code enforcement running down there every weekend. This is a quite,
family restaurant. We want to enhance the service; we don't want to change what we are.
Landscaping, very important because there's a complete lack of it quite frankly. It should
be enhanced. There should be more. It should also be prevalent around where the most
impacted neighbor would be. This is the parking lot of the restaurant. This is the one
single tree. What we're proposing, if the Board allows us to, and we can work this out
with the impacted neighbor; at our own costs and expense we would like to provide a
landscaping plan where, if approved, we would provide mature landscaping, mature
evergreen type trees around the entire parcel so as to limit the site visibility onto the
neighboring parcels. This is the one existing tree that currently exists. And we would
like to put these trees throughout the entire parking lot. This, l'm sure you would agree
would provide a much needed and very appropriate buffer to the neighbors. There is
another benefit. We're seeking to move the entryway to the side, where the parking lot is.
Currently the entryway is literally fight at the street. So you have patrons lingering
outside, or you have patrons lingering around in the dining room right on top of people.
We would like to take that entryway and close it off; because that's what's visible and put
it toward the side of the restaurant where the parking lot is creating nice landscaped area
perhaps a park bench, traditional lighting and make a beautiful entryway but take it out of
where it is now. So it doesn't impact any of the neighbors. We've prepared for you; this
is the existing premises right here that's not colored in. The existing premises roughly
Page 27, FebrumT 28, 2002
ZBA Public llcming Tmnscupt
lown o] $outbold
approximately 2200 square feet. What's colored in is thc proposed expansion. Wc create
an entryway that's off' the parking lot, not over here where it currently exists, very, very
close to the street. It's off the parking lot and it's away from the street. There is an
entryway. What also happens is that you open up the door; I mean everyone gets a nice
case of that wind that comes off the ocean. You have a nice entryway; you have adequate
handicapped bathrooms right here. You have that lift that we were talking about you
have that lift that we were talking about that allows access to the dining room tbr non-
smoking customers, because right now we, its very difficult to accommodate them. You
have the entranceway into the bar and you have some stools, as you will see, there's no
dance floor or anything like that its just a bar with some stools. And then you have a
smoking area off the bar used to accommodate smoking patrons. I'm not going to. Yes
MEMBER TORTORA: The entryway, that's a new entryway?
GEORGE TSUNIS, ESQ.: That's a new entryway. The entryway is right here currently.
MEMBER TORTORA: Right, is that calculated in the?
GEORGE TSUNIS, ESQ.: Yes it is.
MEMBER TORTORA: Because I didn't see it on there.
GEORGE TSUNIS, ESQ.: Yes.
MEMBER TORTORA: The ramp entryway on your calculations.
GEORGE TSUNIS, ESQ.: The ramp entryway is a portico. It's really
CHAIRMAN: It's an outside portico.
GEORGE TSUNIS, ESQ.: It's an outside plan. There was a mistake made, that wasn't
figured into what. You can see this area here; this entryway, this foyer and the bathrooms
are approximately 364 square feet. There's a utility area here, its about 116 square feet.
There is a bar area which is about 480 square feet with access, you have the steps here.
And then you have a casual dining area to accommodate the smokers, that's about 495
square feet. I'll leave this here for everyone to see.
CHAIRMAN: Mr. Tsunis that again goes back to the discussion that we had in the
beginning of this hearing and that is as long as you review every element of this plan with
the Building Department, so that we have those ilk,rares concrete because the original site
plan talks about 2600 existing building area, 2650 square feet, you say the existing
building area is about 2200 square feet. All of these figures have to come in and they
have to gel so that we have them. Because, as you know and as Mrs. Tortora had told
you, that our jurisdiction is based upon this Notice of Disapproval. And it has to be
complete, so that's why I don't mean to be redundant about this but
Page 28, Febmm3, 28, 2002
ZBA Public Hem'ing '[ransc~ipt
GEORGE TSUNIS, ESQ.: No Mr. Chairman you're absolutely right, frankly the Notice
of Disapproval was achieved before I was retained. I hadn't had an opportunity to visit
with the Building Department but I assure you that I will be doing so in the near future.
CHAIRMAN: Along with the portico please?
GEORGE TSUNIS, ESQ.: Along with?
CHAIRMAN: Along with the portico.
GEORGE TSUNIS, ESQ.: Along with the portico.
CHAIRMAN: Make sure you show that to them also.
GEORGE TSUNIS, ESQ.: I certainly will. In conclusion, I would like to say that courts
have recognized the ZBA with important and special functions of granting these
variances. Before the Manor Reform Church there has been confided to the Board by no
less than Justice Benjamin Cardozo. There has been confided to the Board a delicate
jurisdiction and one easily abused. I will submit to you that these should not be granted,
cavalierly. There needs to exist special circumstances. Upon a showing of unnecessary
hardship, general rules are suspended for the benefit of individual owners and special
privileges established where the burden of a general restriction creates a special hardship,
which I submit to you. Upon a particular owner and the grant of the special privilege to
him can in truth, promote equal justice. Promote equal justice. Courts have said that it
is encumbered by you with such special circumstances and unnecessary hardships exist, it
is recumbent on this Board to promote equal justice. And when I tell you that this
property was a subject of an up zone, without any compensation, I respectfully ask you to
promote equal justice and grant us the relief requested. Mr. Chairman, Members of the
Board, this concludes my presentation. I only ask that, I know that there are a lot of
neighbors and, of course, and counsel here, myself and the engineer are here to answer
any questions that this Board or the community may have and I would just like to submit
to you 159 signatures that were collected by my client. A petition in support of the
Elbow East restaurant for their expansion and their renovation. Of the 159 signatures,
every single one of them is a resident of the Town of Southold. There are no employees
of the restaurant that are signatories here, and approximately half of the 159 signatures
are residents of the Hamlet of Southold. Clearly an overwhelming amount of these
neighbors recognize that this is a good quality restaurant and would like to see this relief
planted. Thank you.
VINCENT ORLANDO: George one quick question?
GEORGE TSUNIS, ESQ.: Certainly Mr. Orlando.
Page 29, February' 28, 2002
ZBA Public Heariug Tmusctipl
Towu of Southold
VINCENT ORLANDO: In regards to the smoking section, does New York State require
you to have a smoking section, or is that the option ora restaurant to be smoking or non-
smoking?
GEORGE TSUNIS, ESQ.: There's no requirement. I think Suffblk County is very
aggressive in this, legislation was passed that, for fear of second-hand smoke and they've
limited only in public areas such as restaurants that there should be a separate enclosed
area tbr them so they can enjoy an evening out and diners who do not smoke can also
enjoy the evening out without the burden of second-hand smoke.
V1NCENT ORLANDO: But this could be a non-smoking restaurant, if the owner chose
to?
GEORGE TSUNIS, ESQ.: Well Mr. Orlando, I've discussed with you that this restaurant
is already losing money by limiting this restaurant further to non-smoking people, I think
it will further lose money and I think they'll be no restaurant. It will be a catastrophe for
the applicant.
CHAIRMAN: I am going to reserve my option of questioning anything of either you or
Mr. Whelan regarding this plan at this time, only because of the perimeters that I've set in
the beginning of this hearing.
GEORGE TSUNIS, ESQ.: Certainly Mr. Chairman.
CHAIRMAN: However, I do want to discuss on the 28th with Mr. Whelan, as well as
yourself, the ceiling heights, I'm sorry the roof heights, the overall height of the restaurant
itself, the proposed restaurant and so on, and so forth, l'm sorry Mrs. Tortora?
MEMBER TORTORA: I just, all of the case law that you sited or you quoted from, if
you could hand us up a copy of the entire decision?
GEORGE TSUNIS, ESQ.: Certainly.
CHAIRMAN: And before the 28th.
GEORGE TSUNIS, ESQ.: Certainly. Thank you.
CHAIRMAN: Ruth any questions?
MEMBER OLIVA: No.
CHAIRMAN: Vinny, any other questions?
MEMBER ORLANDO: No.
Page 30. Febmm~' 28, 2002
ZBA Public Hearing l~ansc~ipl
CHAIRMAN: The question I have at this particular time is, does anyone in the public
want to see these pictures prior to the objectors?
CONSTANTINE GEORGOPOLOUS: My name is Constantine Georgeopolous. 1
would like to see the plan that provides the proposed parking space for thc new use of
these premises.
CHAIRMAN: Okay, what I think we'll do then is, we'll just, if Mr. Tsunis and
whomever would place all of those on this table back here, so that there's no multiples
that can stay there. And if Mr. Tsunis or Mr. Whelan would depict that fbr you sir, and
then at that particular point we're willing to view the other aspects of it. Excuse me one
second Mr. Tsunis. Go ahead sir. Could you state your name for the record please?
(NAME INAUDIBLE): Quick question.
MEMBER OLIVA: Please use the microphone so that the secretary can pick you up on
the tape.
CHAIRMAN: And if you're asking a question, I have to swear you in sir.
(UNKNOWN NAME) Just a quick question.
CHAIRMAN: Just one second, state your name again9
PAUL STETH: My name is Paul Steth and I own property at 270 North Sea Drive.
CHAIRMAN: Would you raise your right hand? Do you solemnly swear that the
infbrmation you are about to give us is the truth to the best of your knowledge?
PAUL STETH: Yes, it is.
CHAIRMAN: Thank you.
PAUL STETH: A question about the smoking. Are there any laws in place from County
of Southold, Town of Southold, and Suffolk County concerning public restaurants in
smoking?
CHAIRMAN: All that I know is that the County legislature voted that if you're going to
have smoking you have to designate an area.
MEMBER ORLANDO: With proper ventilation.
CHAIRMAN: With proper ventilation.
PAUL STETH: But there's no restriction?
MEMBER ORLANDO: That was my question, it is not required.
PAUL STETH: It's not required. So it is not a detriment to income? If its not required
its not a detriment.
MEMBER TORTORA: You're drawing a conclusion.
PAUL STETH: No, I'm asking a question. They've made a point saying if we don't have
smoking it's a detriment to our income.
CHAIRMAN: That's a matter of opinion.
GEORGE TSUNIS, ESQ.: There's a case study out there defining that.
PAUL STETH: So it's a mute point.
CHAIRMAN: Thank you. Alright, my colleagues seem to want Ms. Moore to have all
those persons that are in favor of this application to come forward first. Okay. I guess
the first question we normally ask are there any spokespersons, if there are not, we'll start
with the center of the room. In other words, a spokesperson in favor or speaking for a
group. Mr. Sullivan? Mr. Sullivan would you raise your right hand please? Do you
solemnly swear the information that you are about to give us is the truth to the best of
your knowledge?
GEORGE SULLIVAN: I do. My name is George Sullivan and my wife Margaret and I
have been a resident of the Town of Southold for approximately thirty years. The current
law that the Town allows for a quasi-judicial body, the Zoning Board of Appeals, which
provides its residents possible remedies and variances against hardships encroaching
restrictions. I have previously served as the Receiver of Taxes and a Member of the
Town Board, and have experience in legitimate areas, cases, whereby residents deserve
relief and consideration from the current statutes. I believe the application before this
Board deserves that consideration. I've known the families of the applicants, the
Rutkowskis and Berliners for approximately twenty-five years, both on a business and
social basis and have always found them to he hardworking and community minded.
Their desire to improve the present restaurant facility will, in my opinion, esthetically
enhance the existing location, facilitate the restaurant operation, for both patrons and
employees and not encroach on or diminish the quality of life for the residents of the
Kenny's Beach area. The improvements requested will only add to the beauty of the
town, as they're not intended to greatly expand operations for improving with no burden
to the surrounding community. The concerns of the voice in opposition of letters
submitted are, I believe, not valid. The restaurant theme is that of a family one, not a bar
or an establishment with loud music. In its many years of operations, there has not been
one altercation involving the police. Not one complaint about noise, or any other legal
activity occurring at the restaurant. In addition, I have never seen refuge or papers strewn
in the parking lot or on the ground. I am somewhat familiar with the special needs of the
physically disabled, as I am one. 1 am fortunate in my situation, that many of my fellow
Page 32, Fcbrum-~' 28, 2002
ZBA Public Hearing Tmnscrip~
amputees and others suffering disabilities should have access and comfort if they chose to
dinc out. Thc applicants wish to provide this and the new restaurant fhcilities and
entrance dcsign will greatly assist the handicapped and the elderly. In making their
decisions the Board must consider the good of the entire town, not the specific
complaints of a few whose interest may not be that encompassing. I hope the Board will
make that correct decision. In summary, I support the application submitted without
reservation. Thank you for your consideration.
CHAIRMAN: Thank you Mr. Sullivan. Again we're going with the center of the room.
Is there anybody else that would like to speak in favor? Mr. Zimnoski you had your hand
up before'? No. You're going to go with that? Sir, this is in fb. vor now. Kindly state
your name?
JOHN NICHOLS, JR.: John Nichols, Jr., Southold Business Alliance.
CHAIRMAN: Would you raise your right hand? Do you solemnly swear the
information you are about to give us is the truth to the best of your knowledge?
JOHN NICHOLS, JR.: Yes.
CHAIRMAN: Thank you.
JOHN NICHOLS, JR.: Good evening to the Members of the Zoning Bom'd of Appeals.
The Southold Business Alliance would appreciate the Board's consideration of this
matter. It appears to us that this may be another situation where a pre-existing business
has been in operation fbr a very long time. Besides the obvious questions about setbacks
and lot coverage, there is a bigger question, that is on the minds of business people, and
others whose property is considered non-conforming, either by property size, the existing
setbacks, or by its existing use. We recall a long, drawn out battle between neighbors in
the vicinity of Cedar Beach and a pre-existing, non-conforming use of what used to be
the General Wayne. That building still languishes unfinished because the neighbors in
Town made it so difficult for the owner that he is out of business now. So I have to ask,
because a business exists with non-conformities, use or otherwise, are we going to take
the path that completely restricts these businesses from making improvements that they
deem necessary for the survival of their business. Or, are we going to allow these
businesses some of those entrepreneur freedoms, if not all of them, that other businesses
in the town currently enjoy. Just about everything has some kind of non-contbrmity in
my opinion. You may have another thought about that. We would like to think that the
very limited amount of business in Southold Town, and I believe its something like 3% of
all properties in this town, are business properties. That they will always be able to come
before this Board with a fairly good chance of obtaining relief from a Code that often
makes it very difficult to do business in this town or to make an improvement to that
business. We from the Southold Business Alliance appreciate your careful consideration
on this matter, and we ask you to grant the owners of the Elbow East restaurant the
reasonable variances that they request. Thank you.
Page 33, Fcbmm-/28, 2002
ZBA Public Heamlg Tmnscripl
CHAIRMAN: Thank you sir. Again, anybody on the east side of this room, speaking in
t~avor, we'll go over to the West side of the room, anybody over there that would like to
speak in favor? Mr. Goldsmith how are you tonight sir?
MR. GOLDSMITH: Fine thank you.
CHAIRMAN: Would you raise your right hand and do you solemnly swear that the
int:bnnation you are about to give us is the truth to the best of your knowledge?
MR. GOLDSMITH: Yes sir.
CHAIRMAN: Thank you.
SKIP GOLDSMITH: My name is Skip Goldsmith and I am a lifelong resident of
Southold and a local businessman, and I can tell you that the rules and regulations that
are coming down the road of businesses today are very, as well intended as they may be,
they're very burdensome, and very costly. I felt compelled to come to the Board tonight
to express my wishes that this application of the Elbow East be granted. 1 happen to pick
up the Suffolk Times today and I quote you from Gwendolyn Grucock's story that"
between a Sports Bat', more traffic, parking, vandalism, speeding, drinking, drugs, late
night hanging out, I thought the next thing would be the world coming to an end." And I
couldn't believe a project like this could draw this kind of criticism. Most of these
problems are not only town wide, but they are nationwide. And I don't see any
compelling reason why this should have any effect on this project. My wife and I and
family frequent the Elbow East regularly, at risk of an advertisement, I have to telI the
food is good, the service is great, the people that run the place and own the place are
quality individuals and their main concern is to see that their customers, their clients get
the best service and have the best accommodations. That is why I feel very strongly that
the Board should recommend this proposal and they be granted their application. Thank
you.
CHAIRMAN: Thank you sir. Mrs. Moore, 1 guess we're ready.
PATR1CIA MOORE, ESQ.: I have memorandum, which I didn't give you copies of the
cases, but I will after the fact.
CHAIRMAN: We've received a lot of late night reading material this month.
PATRICIA MOORE, ESQ.: I think you pointed out right from the beginning that there
were inconsistencies in the paperwork that was submitted in the file. And so some of my
memorandum is dealing with plans that may be superceded at this point, but I will
address them to the extent that they are in the file presently and, if anything, they will be
clarified. My first point is that what I saw/'rom the record is that the site plan consists of
a plot area which is there's no dispute of us to that, 21932 square feet. There's an existing
building, which, again seems to be consistent. Then there's a proposed extension with a
cooler area with an entry and ramp. What I did is add up the extension, cooler area, entry
Page 34, Fcbmm~J 28, 2002
ZBA Public Hcmlng Transcript
and ramp and get a total square footage. I don't know if subsequent plans have done that,
but what I see is an expansion from before and after being a size of 4,426 square feet.
That is a sizeable expansion. In one notation in the file there's a, they say that its 48%
increase in thc expansion of the use. My calculations show 59.6% ahnost 60% expansion
of the use. We are dealing with a pre-existing, non-conforming use. That usc has,
certainly nobody is arguing here that they have to shut down their door and that we are
asking them to cease their use. What we are asking is that the expansion be denied. That
is something that you're well within your rights to do. The law I site in point 1, which is
the standards, which you have to follow, the fact that zoning intends to eliminate non-
conforming, the goal of zoning is to eliminate, phase out non-conforming uses. And then
some examples of where expansion was reviewed and non-conforming use was not
permitted to expand; mobile home parks, a change fi'om a seasonal use to a year-round
use required special review by the Zoning Board or applicable jurisdiction in that
particular community. What we see when we look at these plans, particularly the layout,
the internal layout of the structure is that the expansion is primarily in the bar. What we
look at when we see this proposal is an effort to build out a restaurant and bar that is
comparable and competitive with Legends, which is in an area that is a commercial area,
and receives a lot of activity, is considered a meeting place and a place to have a couple
of drinks. I can tell you from nay own personal experience that I have represented many a
D.W.I. that have been stopped in the Legends area. That is a very lucrative area for most
of the local practitioners that appear before the local justice court. That is not to say that
this applicant or any restaurant should be penalized by the illegal acts of others. Whether
it's littering or anything else. But the reality is that this restaurant is being developed and
expanded into a bar, a significant bar in a very residential area. I'm going to skip a
couple of points out of my memo, only because it, I think its more irrelevant. The
character of the area, if you look back and some of you certainly have a lot more history
than many of us that are neighbors and myself, the history here is that this restaurant
started out relatively small, as a snack bar, in an area that was predominantly summer
bungalows. And you can see that from the history of the Zoning Board of all the
variances that have been granted to the residences in this area, which are little bungalows,
then being improved into year-round residences. And now, based on the value of the
properties in the area, you are seeing actually many more applications for very significant
residences. And the neighborhood has turned into a very exclusive, very nice
neighborhood with homes that, fi'om your own common knowledge and observations,
range anywhere from $600,000 to over $1,000,000 depending on which house you look
at. So, again, your own files show that the type of expansion, the type of improvements
fbr the residences. So what started out as a quaint little restaurant has expanded over
time? But now it's in the middle of a very nice, very, i want to say exclusive in the sense
of being snobby, but certainly in a valuable residential area. So the character has
significantly changed and it would make sense that the zoning whether it started out in a
conforming use in a commercial area, the restaurant, is now consistent with the rest of the
neighborhood, which is a residential zoning district. I point out some issues in my
memorandum which are red flags and its actually, why fight this if there are substantial
state issues, state code issues that are going to affect whether or not they can or will have
aware of it all to make the improvements. The first issue, which I think they need to
address with the D.E.C. and with the architect is that, well I'll back up, with the Building
Page 35, February 28, 2002
Z[~A Public Heating TIanscrlpt
Department and their architect is under New York State Fire Prevention of Building
Code. When you have a substantial expansion of the structure it triggers the requirement
that the entire structure be brought up to Code. This expansion is significant, it is
substantial and t~?om very brief review by one of the Building Inspectors, it may in fact
trigger the balance of the building to be brought up to Code. Whether or not that actually
takes place, I think it's unthir fbr me to say that the Building Inspector will rule that way.
I think it really depends on the plans, it depends on the improvements; and I raise that as
an issue because, if in fact, and I have this for many clients that come in with a plan that I
sit them down and I say look at this its not the zoning alone, look at how your
construction is going to be affected and whether or not you can ai-tbrd to make the
improvements under the State Code. So that is an issue which isn't clear from here, I
raise it because why have this entire community get into a confi'ontation when the owner
is going to find himself financially burdened by the renovation of the entire structure. So
that's the first issue. The other issue is the F.E.M.A,, the Federal Emergency
Management Act. The D.E.C. and the local Building Department reviews F.E.M.A.
issues. I know this for a fact because l've represented homes that have been improved
right along North Sea Drive; do I have the right street? Right alone the water, that if they
are in the V Zone, and I could not find what Zone this particular property 12ails in, but
certainly adjacent properties are on piles and other properties that I've been involved in
have been required to comply with F.E.M.A. Now F.E.M.A. has a 50% window, which I
dealt with on another application. Which you have to prove to them that 50% of the
value of the existing structure that you're not exceeding 50% of the value of the existing
structure. It is not fair market value, it is not construction costs, it is a amorphous value
figure that's a little hard to finn up and what happens is, the F.E.M.A. will look at the
existing structure, figure out what the value of it is and sometimes we use construction
but its usually old structures so therefore you are not replacing it with $125 a square foot
or $150 a square foot using some deviation from that. And F.E.M.A. then says well if
you exceed that figure, you now have to bring the entire structure into compliance with
F.E.M.A. regulations, which depending again on which develops, may require that the
ground, the ground floor elevation be at eight feet or at fourteen feet, depending on which
it falls in. I looked at the plans and the plans say, at least one of the set of plans, I
don't know if it's a most recent one, it talks about that the existing finished floor elevation
of the existing restaurant is five feet, the proposed bar is at eight feet, I'm not sure that
that would even comply with the F.E.M.A. regulation. So that is an issue that I think they
need to address for their own sake, as well as whether or not we should even be fighting
because, again, if F.E.M.A. says, hey guys this is beautiful, there's no zoning issue here
whatsoever, hypothetically there's no zoning issue. F.E.M.A. may say __.again that is
a cost prohibitive renovation that they may not consider and words of wisdom think about
it now, because you don't want to be at the end of the process when this comes about. I
know this from personal experience, on behalf of the applicants, that you start out within
the 50%, change orders have to be done throughout the construction process and, this is a
public record because it was a previous application to this Board, this Von Zuben case,
right there, same street. It started out we were well within the 50%. It was purely a
renovation of the exterior, same fuotprint, windows, and things like that. Any time you
do a renovation, you find things that you didn't think you had. All of a sudden that
number goes very close to that 50% and you start having to decide whether or not to keep
Page 36, FcbmalT 28, 2002
ZBA Public Hearing Transcript
looking over your shoulder on whether or not you're going to comply or not, so that the
bottom line is that you bring the whole structure up to the proper elevation so you can
find the F.E.M.A. That is something that could easily happen in this situation, again, it
depends on what flood zone, 1 don't want to give them the worse case scenario, but give
them the neighborhood and the other homes in the area it looks like you'd probably have
to be up on piles or at least have break-away walls or all kinds of special methods of
construction under the F,E.M.A. regulations. Even if the construction itself is below
50%, presently on this application, F.E.M.A. does deal with cumulative expansions, or
cumulative improvements. The regulations say, and it makes sense, you're not going to
come in peace meal, just under the wire every couple of years to try to stay under the
F.E.M.A. regulations of the 50%. I went back m~d I looked at the history of this property
and the improvements that have been made on this property, tbllowed the Building
Department, in 1983 Pastaldi and Vanderlask, they purchased the property. At that time,
it was a one-story frame block building with a wood deck. It was relatively small, and I
have as Exhibit A, the site plan or the drawing of the structure. You can see its pretty
limited, pretty small. In 1984, the Zoning Board actually was asked for a variance. The
variance that was requested was denied. Alternative relief was granted. Now I don't
know what the zoning of that parcel at that time, because he said it was up zoned.
presumed it was non-conforming but it could have been about the time when it was the
change of zone occurred, because it says 164. When I go back tomorrow, I'm going to
check and see if 164 what zoning district that was in. Was that residential or was that
under the commercial. Either way, if it was commercial and you applied and you granted
a variance, even at that time, if it was conforming, you believed that it was inappropriate
to grant more relief than what was requested. At the time, they asked for a small 10 x 35,
well they requested 12 x 35 seating area, they were granted 10 x 35 seating area and a
small vestibule entrance on North Sea Drive. So they dealt with the entrance, they
changed the entrance at that time. At that point, in 1984, the Zoning Board granted the
minimum relief necessary. In 1989, Cliff and Phil's obtained permits fbr repairs, Now
what I have, let me see what exhibit I have, I think its exhibit C, yes exhibit C. Without
much fanfare it looks like, I don't know that they went through site plan, I don't know that
they went through anything. It looks from the record that they may have had a kitchen
fire, which anytime that an existing business has a casualty like that, a fire or an
unexpected casualty there is relief, there is consideration. The Building Department took
it upon themselves without further review from any other board to allow further repair of
the root', replacing the framing members which no longer are structurally sound, so
structural repairs, replacing all the windows, replacing the wood flooring, removing
existing wall coverings, insulation, installing new insulation and wall coverings so its
consistent with fire and the kitchen was brought to Code standards. This was
all done, again, in 1989, so there was, the present building right now works. It has
worked and it has been improved since 1989 and received quite a number of
improvements. Again, going back to my F.E.M.A. argument, those improvements, if
they were done at one time today, you do evaluation, you figure out how much whether
its under the 50%. That, together with today's application, which is the current
application, I think throws it so far over that 50% that I can't see how F.E.M.A. would
look at this in any other way. So, again, I don't like to see whether its in opposition to an
application or in favor of an application, an applicant going through an exercise in futility
[~agc 37. Febtualy 28, 2002
ZBA Public Hearing Transcript
if he cannot financially pursue this, don't make the adjacent property owners, because
who I represent are the adjacent property owners, with all duc respect to the patrons and
other residences, I know them all, they're all fine, upstanding citizens of the community,
the people that are here and who hired me, are the adjacent property owners who are
directly effected. Finally, certainly you're familiar with the Health Department
regulations, sanitary systems would require review; that is certainly not within your
jurisdiction, it's the County Health Department, however, this is an environmentally
sensitive area and it is an issue that you should keep on your mind.
CHAIRMAN: Mrs. Moore I just want to tell you, you know you have a second chance at
this.
PATRICIA MOORE, ESQ.: Yes, but now's the time. Because there will be more l'm
sure later on. I'll try to wrap it up for you, so you can go home. Lot coverage obviously
is an issue here; it was, from the documentation it looks like the 78 persons are presently
permitted to occupy. It's not clear from the site plan, what the occupancy is going to be
with this proposal. I think that that is something that we would all want to know. Issues
that are inadequate at this point are parking requirements. They are proposing to put
parking along North Sea Drive and Kenny's Road which would require backing out onto
the street into a residential area in a public beach area. Also, the fact that they have used
the Town Beach part of their numbers, or attempt to use part of their numbers for
parking, the residents have told me that many times the beach is blocked off because of
piping clover, nesting areas, so we can't count on that and it does create a problem down
there. I haven't seen the proposed site plan with the landscaping and so on, certainly
there is some natural gl'owth there, the proposal we have to review it. But there was
nothing in the file that showed any landscaping and I will hold onto any comments until
we review it. Also, another issue that is very significant to the neighborhood is the fact
that you are, the intensity of the use, not only structurally in expansion, but also thc use,
certainly they want to increase the business and we understand that. The hours have
historically been lunchtime to 9:00 p.m. This is going to be significant expansion to the
bar. Under the New York State regulations, bars are permitted to stay open, the time I had
I believe its 4:00 in the morning, anywhere from 2:00 to 4:00 in the morning. They
would supercede any attempts by the Town to limit those hours because the State
overrides any conditions of that nature. The Use Variance criteria, have not
been met. They bought this building within the last two years I believe. They knew what
they were buying when they bought it. The fact that they want to make it handicap
accessible, that's admirable. And that can certainly be accomplished with no expansion
of the use or no expansion of the structure; it can be done with access ramps and the rest,
which nobody, I think reasonably, would object to an access ramp. That is not something
that, we have neighbors who are also handicapped and that is not a reason to expand the
structure by 1400 square feet, almost doubling the size. Architecture improvements, well
yes, we agree that this place could look a lot nicer, but again, that does not require an
expansion. It's a lovely design, in my opinion personally, however, in a commercial
zoning district this would be a lovely restaurant. In this, at this piece of property it
should be what it is now in size, with architectural improvements. And that again, does
not require any relief from this Board. It is not a taking to have an up zoning that, the
Page 38, Fcbmm~ 28, 2002
ZBA Public Heming Transcript
Board is well awarc of that and given the character of the neighborhood was appropriate
at the time it was done in the 1980's. We will certainly continue you this in March, and
wc will certainly be happy to answer any questions that you might have. I think that some
of the issues I raised are very important ones that I think the applicant will probably
check because I think that they're important for them, not just for us. Thank you.
CHAIRMAN: On the east side is there anybody that would like to speak against this
application? Yes sir. Please state your name for the record sir'?
CHRISTOPHER POPPEI: My name is Christopher Poppei.
CHAIRMAN: Do you solemnly swear the information you are about to give us is the
truth to the best of your knowledge?
CHRISTOPHER POPPEI: I do. First of all I want to say that I don't have any objections
to the restaurant. I bought my house about a year and a half ago, and when we moved in
we went and spoke to Mr. Forrester who was then at the Building Department, and we
asked him, the restaurant was next to us, could he expand or could he do with anything
with the restaurant. We were told by him, definitely not, don't worry about it; buy the
house, there's no problem. I myself used to go over and have a beer and a burger in the
restaurant. What disturbed me was I went in there about two months ago and the
bartender was standing there with the plans out on the bar telling everybody about this
gigantic bar they are going to put in there and how they're going to put in TV sets and
they're going to have a bar on this side, a bar on this side. We're going to have the entire
crowd; we're going to steel all the crowd from Legends. This is what got me really
uptight. He's telling the whole crowd that was in there how we're going to have this big
bar and and we're going to get all the locals to come in here and everything else, and I
think the whole handicapped thing and everything else is great, but I think he's looking to
put a big bar in this place. The third thing I wanted to say is my house, can I show you
this picture, and this is my house right here. This is a large leeching field, okay. The
prior owner of my house called me and said that she was tbrced to sue the owner; the old
owner of the restaurant and the builder who was building this house also was involved in
the suit. They were forced to sue him to have him move both their wells, because this
leeching field contaminated both wells. They won the suit and they had to have these
wells moved to both the other sides of the houses. Some of the other wells in this area
are all contaminated because of this leeching field down here. She tells me and I can't
swear to this that it was improperly installed by the old owners not by the new owners,
which I think is a very important health thing fbr the whole area and the environment.
The last point I want to make is, he wants to put an entrance on the side. He wants to put
a side entrance in. The side entrance will face right here to this gentleman's house and
this house right here, and there's another house over here that isn't in the picture. The
side entrance, people will be coming right out into the lot, right next to this gentleman's
house, Mr. Steth's house when he put the side entrance in over there.
CHAIRMAN: Anybody else on the east side, yes ma'am? Could you kindly state your
name for the record?
Page 39, tcbrm~y 28, 20(12
ZBA Public Hem mg TnmsctJpl
PATRICIA POPPEh Patricia Poppei, 282 North Sea Drive.
CHAIRMAN: Do you solemnly swear the infbrmation you are about to give us is the
truth to the best of your knowledge?
PATR1CIA POPPEI: I do sir. Thank you. I have a couple of kind of rhetorical questions
that may not be answered this evening. They may have to wait until the meeting of the
28th. As my husband just said, prior to the purchase of our home we checked with the
Building Department here and spoke with Mr. Ed Forrester. He assured me that there
could be no alterations, amendments, expansions, etc. to this particular restaurant because
it was non-conforming in many different uses, the building, the lot, and the fhct that the
restaurant was a non-conforming use or business in a residential area. I think when the
new owners purchased the restaurant; I think they probably knew these things as well. 1
also apologize if I'm being a little redundant. When they purchased the restaurant, I knew
the restaurant was making money. I've been coming to Southold since 1978 and the
restaurant was always a busy place. However, it was only a seasonal restaurant, as many
of you remember. It was open during the wanner months, the spring, the summer and the
fall. Now, of course, with new owners, they're keeping it open all year round. I don't
know if they checked to see if the restaurant was making any money before they bought
it. I think when you buy a restaurant, or any business, you certainly don't buy if you
know you are going to have negative backflow, you're not going to make money on it.
So I really don't feel that it's my responsibility or the other residents in the North Sea,
Leewood Drive, Kenny's Beach area, or the Kenny's Beach Association Membership to
be worried about whether or not his purchase of the business is making money tbr him.
Our concern is our quality of life. Rhetorically also, we should sacrifice our quality of
lilb for smokers, I don't think so. Up zoning - up zoning allowed this particular business
to remain in existence. Nobody said, we're wiping you out, you are allowed to stay, and I
think that there are older residents here who remember when it was, as mentioned betbre,
a little tiny snack bar, which has grown like topsy. I think it's grown to the size that it
belongs. I am more than happy to see it remain that way. It is a comfbrtable, nice
restaurant with a nice family atmosphere. However, l have noticed this winter, the noise
has increased. I haven't called the police. Maybe 1 should so that it is on record. I have
seen garage, I have seen people leave their dogs locked in the cars while they go into the
restaurant and the dogs yap all evening long. In addition, the entrance is being moved, I
might add to my husband's comments the entrance will now not be on North Sea Drive,
where there seems to be a little bit ora buffer, but now they will face this large portico or
whatever it is on my bedroom window, Mr. Steth's bedroom window amd our other
neighbors offour right-of-way. I feel that this is not a proper thing as well. Reasonable
return, I'm really sorry. Everybody goes into business, some people make it, and some
people don't. I invested in my real estate; I don't want to lose value either. But it looks
like there's a possibility. A restaurant losing money, their investment, once again, did
they check into it before they purchased it as we checked and were assured by the Town
that nothing could happen to change this restaurant and the way it existed? Esthetically
pleasing, I don't think that's esthetically pleasing to me. I live there with all my other
Page 40, Fcbin. m~y 28, 2002
ZBA Public Hcm'ing T~ansc~ipt
neighbors, its very pretty, it belongs a suburbanized, more commercial area. It does not
belong in thc Kenny's Beach area. Thank you very much.
CHAIRMAN: Thank you, Is there auybody else on the cast side'? Seeing no hands, we'll
go to this side. Yes sir? State your name for the record'?
JOHN CASAMAT1S: John Casamatis, 3735 Kenny's Road, north and across the street
from the restaurant.
CHAIRMAN: Kindly raise your right hand; do you solemnly swear the infbnnation you
are about to give us is the truth to the best of your knowledge?
JOHN CASAMATIS: Yes it is.
CHAIRMAN: Thank you sir.
JOHN CASAMATIS: I have several questions also. In my opinion, 1989 it was
refurbished. Many of those compressors had to go up on the roof because of F.E.M.A.
flood zone. They couldn't be down on the ground level. I don't see any compressors on
this roof here. I hear those compressors all night long. So if this place is going to
become bigger, we're going to have bigger compressors. They're going to make a lot of
noise. You're taking up a lot of parking. Kenny's Road is parking by permit only. Do
we start calling the police every time somebody parks on Kenny's Road to go to the
restaurant? Is it our responsibility to provide parking for a non-conforming business in a
residential area? I like the restaurant the way it is. 1 frequent the restaurant. I think it fits
right there the way it is. To expand it like this, I think the counsel made a great ar~,mment
for the handicapped and I think they get into most of the restaurant. I don't see where it's
our responsibility, as a community; to make this to me it appears it's a rule to make this a
Legends on the Sound. And if that's what it is, once you give the approval, like the
opposing counsel said, State Liquor Authority takes over and they can stay open till four
o'clock in the morning. But I ask a question; does the Town of Southold have cabaret
licenses?
CHAIRMAN: No to my knowledge.
JOHN CASAMATIS: So that means live music could be placed in that restaurant
without any permit of any type from the Town of Southold correct?
CHAIRMAN: That's a very interesting question. I don't know the answer to that right
JOHN CASAMATIS: Neither do I, but I pose that question. And since we don't have
any noise ordinances in this town and we hear from the vineyards, people that are living a
thousand, two thousand feet away from churches that have festivals and it becomes a
town wide controversy, my neighbor here is only less than 100 feet away from the
restaurant. I'm lucky; I'm four or five hundred feet away. The other neighbors here are
Page 4 I, Febmmy 28, 2002
ZBA Public Hearmg I'ransctipt
only a few fcet away. So this is a consideration. I didn't hear anything about live music,
noise ordinances or anything like that. That's something that should be considered. I
know you cannot force them to make any guarantees. So this is something that 1 think
you should consider.
CHAIRMAN: We can force them to do anything we want that's reasonable.
JOHN CASAMATIS: Is it enforceable?
CHAIRMAN: Anything we want that's reasonable.
JOHN CASAMATIS: But is it enforceable?
MEMBER TORTORA: I don't agree with that.
CHAIRMAN: You don't? Okay.
JOHN CASAMATIS: That's all I have to say tonight. Thank you.
CHAIRMAN: In the center again? Sir? You've been very patient, would you pull that
microphone over to you a little bit. Please state your name for the record?
CONSTANTINE GEORGOPOLOUS: Constantine Georgopolous, 1330 North Sea
Drive.
CHAIRMAN: Raise your right hand please. Do you solemnly swear the information
you are about to give us is the truth to the best of your knowledge?
CONSTANTINE GEORGOPOLOUS: Mr. Chairman, Members of the Board I have
been a resident of the Town of Southold since 1990 and I've been vacationing here since
1966 and have been in the Kenny's Beach area since 1970. Indeed, the restaurant once
upon a time was a refreshment bar. I remember, Mr. Tsunis said he doesn't think that
there's anybody who could remember it, but I can assure him, I remember it and some of
my neighbors very well remember it. It was a frankfurter stand, and it's grown now into a
restaurant. Most of my comments have been addressed by other speaks this evening, but
there are a few items that I would like to take up. Although there appears to be a 47 or
51% increase in the space, Mr. Tsunis did not explain how did they account for the loss
of the parking space. But of course, naturally, the loss of that parking space will spill
over into North Sea Drive and also onto Kenny Road. We all know that there are no
sidewalks either on North Sea Drive or no sidewalks on Kenny Road. We also know that
there is no city lighting on either of those roads. Again, I know from personal knowledge
in the evening and on weekends, there are many pedestrians walking either east or west
on North Sea Drive, and north and south on Kenny Road, children on bicycles, and
mothers with baby carriages. In the evening, I've been witnessed to speeding cars going
north and south on North Sea Drive without the proposed restaurant as the owners plan to
construct it. As it is now, there is some, I don't want to say drag racing, but because its
Pagc 42. Fcbmats/28, 2002
ZBA Public Homing ]'mnscfipt
Town ill' Southold
not two automobiles, but there are speeding cars in thc evening. What's going to happen,
what will happen when this proposed bar, and by the way, it was a speaker who spoke in
support of the restaurant that sports bar. What's going to happen if there is going
to be a sports bar there, and then you have patrons leaving at 1:00 and 2:00 and 3:00
speeding up and down these roads. It's going to be a problem, a very serious problem.
It's going to be a problem in the evenings with pedestrians on those roads. We don't want
this to become another Claudio's with what goes on in Claudio's. Last time l recall
reading in the newspaper that there were New York State Police undercover agents at
Claudio's watching out for drag deals. I don't think we want that in a residential, we don't
want it at all. Certainly not in a residential area. Again, this is a residential area; it's
certainly not a commercial area. We don't want that here. We also don't want a repeat of
Lizzie Grubman's episode in the south shore. Not that we know if it will happen, but we
don't want those types of people in this area. As it is now, I see families going there. My
wile and I patronize the restaurant from time to time. I see elderly senior citizens; I don't
see motorcycle patrons in there now. I don't know if there will be motorcycle patrons in
the future, but there may well be. To quote Mr. Tsunis, he referred to "quote hard-
working" people that own the business. What about the hard-working residents that are
paying mortgages and that are paying taxes. Not one or two or three but all of' them.
What about their interests, don't they have rights, don't they have interests? I believe they
do. I also believe that the petition that Mr. Tsunis presented to the Board should be
looked at critically to see how many of those signatories were north of the North Road
and within the boundaries of lqorton's Point, Horton's Lane, Kenny Road and Lake Drive
and __Drive. I would be curious to know how many local residents in the Kenny
Beach area signed that petition, l think its if I may say so. That terminates my
address to the Board this evening. Thank you.
CHAIRMAN: Ma'am in the back? Come up and use the microphone ma'am. Kindly
state your name tbr the record ma'am?
MARYANN MURTAGH: My name is Maryann Murtagh.
CHAIRMAN: Could you raise your right hand please? Do you solemnly swear the
intbrmation you are about to give us is the truth to the best of your knowledge?
MARYANN MURTAGH: Yes it is. I live on Soundview Avenue, not too far from
Kenny's Lane. Our home has been there for a very long time. My parents lived there and
my grandparents before that, and I must say that we used Kenny's Beach all the time. We
have for many years, probably going back to the 1940's when my grandparents moved
there. My grandmother was Agnes McCabe, whose family McCabe's Beach was named.
I must say that I feel that I need to speak out a bit on this. I must commend the owner for
their wish to improve the outside of their building; I think that should be done. I think
they're some improvements that should be done regardless of the expansion aspect of
their project. I think, the part of the building near Kenny's Road needs definitely to be
improved. Essentially when you walk up toward the beach, alongside the restaurant
virtually you see hanging out in the back because Kenny's Road view includes
both the back of the restaurant. I think that definitely should be improved, it the
Page 43, Fcbmaw 28. 2002
ZBA Public Hearing hanscript
TOWI1 ol' Southold
neighborhood to have that aspect of the restaurant so protninent as you walk up the street.
However, I think the tact that apparently they want to improve the sports bar or have an
active bar as opposed to a bar that just delivers drinks to tables, I think should not be
allowed. I don't know how that is controlled by the zoning aspect of the problem, but the
fact of thc matter is, if indeed as the lawyers said, this is a family restaurant. There
should be no reason to have a sports bar. In fact the emphasis in any expansion, if its
allowed, should be with the emphasis on using it as a formal restaurant, not for a sports
bar and active bar. One of the main issues that I have great concern about is, in fhct, the
water supply in our community. We have adequate, but limited water supply at our local
field wells. We do obviously have now access to Suflblk County Water, but the fact is
Suftblk County Water provides in the local community from the local field wells and I
don't see that having an expansion in this project will, I actually feel concern that an
expansion in this project will over the years contribute to the jeopardy toward the
quantity of that water. We are expecting to have a problem with water in the future in
general. 1 don't think we need to have greater stress on our local field wells and the next
spills over to, what about the septic tanks? If you have a greater need for water, you're
going to have a greater need for disposal of your waste. That concerns me really a great
deal. As far as the issue of parking is concerned, I have to tell you that several times
during the summer I walk up to Kenny's Beach parking lot and do my own private
canvassing, to just see how many cars have Southold stickers. And ! have to tell you that
I've been there three times last smnmer, basically between 30 40% of the cars don't
have stickers. I don't know if some of those people are in the restaurant or not, I'm sure
some of them are right on the beach. But I can tell you that the police don't keep the
numbers down in that regard. So if they don't keep the numbers down in regard to the
number of cars that arc in the parking lot without stickers, and also they don't keep the
speeding cars from coming up on North Sea Drive. Because I can hear them in my house
and I live on Soundview Avenue. I don't even live up on North Sea Drive, but in the
summertime, you can hear those cars on weekend nights, and its bad. I really feel for the
people that live up on North Sea Drive. Now if the police don't keep those two issues,
those two problems under control now, and then you add on more cars coming up to this
restaurant, and a so-called sports bar that would stay open at night. I think you have a
very big responsibility to see that, in fact, the laws of this community are obeyed, that is
the Zoning Laws, and that in addition to that the people the community where this
restaurant is, are respected and their wishes carried out. Thank you.
CHAIRMAN: Thank you. Is there anybody on the west side? Seeing no hands. Mr.
Tsunis 1 would really like to wrap this up tonight.
GEORGE TSUNIS, ESQ.: I will be very brief Mr. Chairman.
CHAIRMAN: Hold on, yes after him.
GEORGE TSUNIS, ESQ.: Mr. Chairman I appreciate the opportunity to respond, 1 think
some of the neighbors concerns are well placed, we sympathize with them and its our
desire to work with them. And perhaps I could meet with learned counsel and some of
the neighbors to see where we can find the areas of compromise in working together,
because it is our intent on doing something that is sensitive and working with the
community and I'll make an eflbrt to reach out. Begging Mr. Forrester's pardon, there is
a mcchanism in the Town Code that the legislative body enacted that allows a non-
confurming use to be expanded. It is Chapter 100-243AIB. You have to go to the
Planning Board, granted, but I'd like to analogize it, that you can increase your current
building by 30%, which is approximately 850 square feet. It produces substantial
enhancement of the overall site landscaping and natural vegetation which we're proposing
to do, and improvement of the best visual practices by upgrades to existing building
facades and/or designs of new buildings to make it more historic in existing of rule of
character which we're also trying to do, so that there is a mechanism to expand non-
confbrming uses. l think the legislative body took great pains to say; in special situations
we do recognize that there is such a need. Secondly, Mr. Chairman there was a lot of
discussion about the exclusive nature of the neighborhood. Learned counsel Moore
spoke about the increase value of homes. Those homes are going fur $600,000 to
$1,000,000. I would venture to guess that this restaurant has been here for a long time
and I think in the last years, the property values have gone nowhere but up with the
restaurant there so I think we have been a neighbor that has a lot of property values to
increase. Now there are many safety valves and layers of approvals in any project.
Whether it be the New York State Fire Prevention and Building Code, F.E.M.A., the 20%
lot coverage, Health Department, I will stipulate to you right now, we will follow all of
them. We will comply with all of them, and if we can't get those approvals, this project
doesn't happen. And that's the way zoning and Building is designed. But it's not the
issue before you. ! think it serves to skate a little bit, but I will say that we will
stipulate that we will comply with F.E.M.A. We will comply with the Health
Department. As far as, the young gentleman mentioned compressors. I stated that in my
application, that with a new and improved restaurant where a lot of money will go into
refurbishment and improvements, you will have an enhanced sanitary system. You will
have brand new compressors. You will have a more beautiful building. You will have a
restaurant that is more sensitive to the area. I appreciate the comments that came from
the neighbors and counsel. I think what people have is a fear of the unknown sometimes.
And perhaps its incumbent on us, the applicants, to sit down with them and explain to
them very, very seemingly and clearly what we're proposing to do. There is a concern
that we are going to become a Legends. We're not Legends, we're not even close to
Legends. I don't think anyone would remotely call us that. It's a family restaurant. It is
smaller than the Legends. The bar is certainly smaller than Legends; the entire restaurant
is smaller than Legends. It's a different clientele. It is one that several of the neighbors
who have apprehension here, have admitted that they frequent and that they enjoy. These
don't seem to me the type of people that are bikers and drug addicts, and things like that.
They seem like good neighbors who go there to enjoy a nice meal. It is not the owner's
intent to create Legends. It is not the owner's intent to create a sports bar. Some of the
neighbors said, well can we force them to do that? Mr. Chairman, you said yes you
could. I agree with you. Respectfully, Mrs. Tortora disagrees with you. 1'11 tell you what
can be done, covenants that run with the land. We'll sign covenants; we'll file them with
the clerk that addresses many of these concerns. Covenants that will not allow this place,
that is completely enforceable. They will always run with the land and can't change, so it
Page 45, Febtxtm7 28, 2002
ZBA Public Hcat'ing TIanscript
does not become a Legends and it just becomes a better thmily restaurant; something it's
always been. Thank you very much.
CHAIRMAN: Before you sit down, Mrs. Tortora?
MEMBER TORTORA: Who arc covenants enlbrceable by?
GEORGE TSUNIS, ESQ.: Ma'am you have a Code Enforcement Department here?
MEMBER TORTORA: No, who are covenants enforceable by?
GEORGE TSUNIS, ESQ.: They are enforceable by anyone. In an action, in a court of
law; they're enforceable by the Zoning Board. Any grant, any grant that this Board
makes, is revocable if the conditions and covenants are not met. If you say, Mr. Tsunis
we're going to grant such and such expansion or such and such a use or such and such a
relief provided that you comply with X, Y and Z. If you don't comply X, Y and Z that
grant is lifted. That grant is lifted. So its enforceable by this Board and enforceable by
your.
MEMBER TORTORA: You would be willing to agree to covenants, for example, I'm
serious, let's go down this road. That would address the concerns, it would not become a
drinking establishment, it would not become, not now or ever, you would sign such
covenants'?
GEORGE TSUNIS, ESQ.: You know Brandise once said; the best thing to septic is
sunlight. Let's get it out in the open; we're a restaurant that has a bar. We do a modest
bar business, but if you look in our bar on a daily basis, I think you'll find people ti'om the
community, people that are a little bit more mature and not the type of patrons that
Legends has. We have heard a lot about the surrounding property owners being hurt, if
the drag racing and drugs and all this sort of things come into our community, I can't
agree more. The person who would be most hurt would be my client, the applicant, they
certainly don't want that; they've never been that type of establishment. They're not
seeking to be that type of establishment. So with learned counsel, Ms. Moore, in
consultation with her clients and the neighbors, with the Town Attorney's office, I would
be happy to sit down and draft some reasonable clients that speak to these valid issues
that the neighbors have.
MEMBER TORTORA: Thank you.
CHAIRMAN: Mr. Tsunis last point, and again I hate to be symmetrical, but you will
leave no stone unturned in reference to what's been presented to you. Of what you've
presented, what your clients have presented and what Miss Moore has dealt with tonight.
GEORGE TSUNIS, ESQ.: Mr. Chairman, I'm a little embarrassed. I agree with you and
quite frankly I agree with Miss Moore as to the site plan. We can do better, we should do
better, and I will clarify things. I would also like an opportunity to meet with Miss
Page 46, February 28, 2002
ZBA Public Heating I mnscripl
Moore if I could and if we could have a little bit more time. If you can schedule us in
April, instcad
Of May 28th, it will give us a little bit of time to possibly work things out.
MEMBER ORLANDO: One more question, Mr. Chairman?
CHAIRMAN: Surely.
MEMBER ORLANDO: Have you done any calculation on how many parking spots you
can get on your property'?
GEORGE TSUNIS, ESQ.: Yes sir. There are, a number of neighbors felt about that.
This building is not going into the parking area. The proposed expansion, if all of it is
granted, it does not go into the parking area. The parking area is currently unstriped.
This provides a tremendous opportunity to stripe it, to pave it, to make it better. We have
a site plan that has 43 parking spaces that will comply with Code and no part of the
proposed expansion goes into the parking lot. We are able to completely park this
structure on the premises. Do not need a municipal lot and do not need parking on
Kenny's Road or the neighborhood to do that.
MEMBER ORLANDO: So 43 is enough to accommodate your client?
GEORGE TSUNIS, ESQ.: 43 is enough.
MEMBER OLIVA: Then where is the expansion going to take place?
GEORGE TSUNIS, ESQ.: If I may? This is the parking lot. This is the proposed
construction area. As you can see it's this grassy area to the side. That's where the
proposed construction area will be. It's not onto the impervious surface space where the
parking is.
MEMBER OLIVA: That's going to be 1700 square feet, right in there?
GEORGE TSUNIS, ESQ.: No ma'am, we're going to have, its probably closer to 1400
square feet. In the calculations, and we clearly were ambiguous, its not Miss Moore's
fault. We included a cooler area, that already exists in the building. It was included in
the proposed expansion. That clearly is 115 square feet that lessens it by. They also
included the portico area as building areas and you see it's just a column where it's really
not considered closed floor area. So that was inadvertently included, it would lessen the
amount of square footage that we're seeking. But again, like I said, that is our oversight,
we'll correct that, and I'll have something.
CHAIRMAN: Will you stay for a couple of minutes after the hearing to show everybody
who hadn't seen the privilege of your?
GEORGE TSUNIS, ESQ.: I would be glad to.
I~agc 47, FebmalS, 28. 2002
ZBA Public Hearing Tntnsc~ipt
CHAIRMAN: Last issue, everything that is bcfore us, must go back to the Building
Department. You must get this corrected Notice of Disapproval. My suggestion to you
and your client is that we recess it without a date, you call us and since we have to re-
advertise anyway with the latest Notice of Disapproval, it will then at that time that we
will address all these final issues.
GEORGE TSUNIS, ESQ.: I don't think it benefits anyone to rush this process. We want
to do it right and we want to do it with input with the community. 1'11 be happy to do that.
CHAIRMAN: Man with the red shirt, you were first. Remember you're still under oath.
PAUL STETH: Paul Steth, I talked to you before, I live at 270 North Sea Drive. Maybe
we covered some areas that are kind of redundant. If you want to have smoking or not
smoking, that shouldn't be a consideration. That's like gold chandeliers or smoking or
non-smoking that should not affect you. The second thing I want to bring up here is
parking. Currently, on a Friday, Saturday or Sunday night the cars are overflowing in
the existing restaurant. Now they say they have 40 spots, that's 80 people, that's 40
tables. I assume they don't have that problem. But obviously there are in parking. When
I walk down my property line the cars are parking in the road. They're not in the parking
lot. There's no buffer zone around the property. They're parking right up to my property
line all the way around. There should be a ten-foot zone all the way around. So already
you're going to lose 40 cars. The other thing I want to bring up is they seem to have 350
feet of access to this property. There's no driveway cut. I have an access to my property
of 12 feet to my driveway. Everyone else here has about 12 feet of access to his or her
property. If you go there you can pull into this property, 120 feet down Kenny and 200
feet down North Sea Drive. Now they're going to eliminatc this? This is going to get
curbed, where
CHAIRMAN: 1 hate to be
PAUL STETH: This is what I'm saying should be considered when they're drawing these
plans. Because they're making it sound like it exists as it is.
CHAIRMAN: First of all we don't do parking. Parking is done by the Planning Board.
PAUL STETH: Well I'm just bringing this up, because when they draw this up they're
going to drop a plan that exists like it exists now. You're referring to an improved
community. You want to make it nicer, put in ramps. They haven't put in a ramp yet, but
they're going to do it after they get the improvements. They haven't yet put in a ramp for
people to go in, for handicapped. They haven't done this yet. I don't know why they
haven't. I don't know why they haven't limited the parking. I don't know why they
haven't fixed up what they want to do. So if they haven't done things that don't require
your approval to make us feel it's wonderful. Let's listen to what they have to say. They
want us to approve everything first, put in the ramp, fix up the parking, solve the problem
then come back to us and say now we have a problem. But they haven't done that, they
Page 48, Feb~um~ 28, 2002
ZBA Public Hearing Tnmscript
want us to give them everything first. Put io the handicapped ramp, solve the parking
problem, stop parking in thc street, create the buffer zones, get rid of the loud noises, get
rid of the fans running all night, solvc all your other problems. Then come back and say
okay, wc've done everything just to make it nice for the community. We need help, then
we'll help you, but not before that. Okay, thank you
CHRIS POPPEI: There are a tremendous amount of residents down there that are older
couples that live in Florida, or go away for the winter that are not around this time of
year. I got a call I¥om a lady in Florida, another one from France who are very interested
in this, and would love to be here. I'm wondering counsel I see wants to wait a month or
two, I wondering if we should put this offto maybe May or June and when all these other
summer residents, people who own houses down there can be here and voice their
opinion too. There is a tremendous amount of people I tried to get in touch with that are
not around this time of year. They own houses down here, they've owned them for many
years, they're taxpayers and they have a right to say something too. It's being done in the
middle of the winter and a lot of people are not around, so maybe this is something you
could take into consideration. The second thing I was going to say is, the parking
business, I knoxv you don't, if you add another extension he's going to need more parking.
CHAIRMAN: We would urge you please to get in touch with these people and have
them reduce their opinions to writing.
CHRIS POPPEI: A lot of them did that, because I know
attention. Thank you.
to your
CHAIRMAN: What's the question, sir? Give me the scope.
UNKNOWN GENTLEMAN: The reason for the size of the sports bar.
CHAIRMAN: It's not a sports bar.
UNKNOWN GENTLEMAN: The large bar.
CHAIRMAN: I assure you we are not granting, if this Board grants anything it will be an
addition to a family restaurant. That's only if it intends to do so. Ma'am last time. I need
you to use the mike and please not as lengthy as you were before.
MARYANN MURTAGH: If you have a hole in the wall, if you have a good enchilada
people will come. They don't really need the expansion to make more money, what they
need is better ~tbod.
CHAIRMAN: Sir, the man in back of Mr. Tsunis, you did not speak tonight sir?
Gentleman in back of Mr. Tsunis. You need to state your name for the record because
you didn't get up.
Page 49, Febllla15, 28, 2002
ZBA Public Hearing Transcript
(nmne inaudible) My name is
the restaurant.
from 3070 Kenny's Road right across from
CHAIRMAN: Do you solemnly swear to speak'?
(NAME): The seating capacity for the expanded restaurant in numbers?
CHAIRMAN: We're going to get that. We are going to get every possible, single
element that we can possibly imagine before this thing will be closed.
(NAME): Thank you,
CHAIRMAN: Mrs. Moore knows what we request. Mr. Tsunis we haven't had the
pleasure of you being before us. But I think we've had some family members in the past
before us. You might want to talk to them. But we will leave no stone unturned. So
whatever you can do for us only makes our job much easier. Okay. Thank you again Mr.
Tsunis as you offered to stay around just to point out a couple of things to anybody, we
will appreciate it.
10:00 End of Public Hearing