HomeMy WebLinkAbout1000-121.-2-2 WHEREAS, o petition was heretofore filed with the Town Board of the
Town of Southold by .....~..o...~..t..h.....F._.o.~.k_.._...b~...n._.o..~..:...~..n.?.... ..............................
requesting a change, modification and amendment of the Building Zone
Ordinance including the Building Zone Maps made a part thereof by chang-
"A" Resictential ,
in-from and Agrzcultura- ~. "B" Light Business
~ ............................................ u~strict to ...........................................
District the property described in said petition, and
WHEREAS said petition was duly referred to the Planning Board for its
investigation, recommendation and report, and its report having been filed
with the Town Board, and thereafter, a public hearing in relation to said
petition having been duly held by the Town Board on the .... .1..~.t...b: ...... day
of ................. ..~.p..~..~.l. ................... , 19...?-..8.., and due deliberation having been
had thereon
NOW, THEREFORE, BE IT RESOLVED that the relief demanded in said
petition be, and it hereby is GTL/~TED.
DATED: MAY 23, 1978
BY ORDER OF THE SOUTHOLD TOWN BOARD
JUDITH T. TERRY, TOWN CLERK
WILLIAM WICKHAM
ERIC J. BRESSLER
ABIGAIL A.WICKHAM
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LAW OFFICES
WILLIAM WICKHAM, P.c.
MATTITUCK, LONG ISLAND
NEW YORK \1952
516 - 298-8353
Decenber 7, 1977
Mr. John wickham
Chainnan
Planning Board
Town of Southold
MainRbad
Southold, N.Y. 11971
Re: North Fork Molnar, Inc.
Dear John:
I have subni tted an application f= a chancre of-zone on
behalf of North Fork Manor, Inc. to the Town Board. 'Ihis
matter will undoubtedly be referred to you for your review
and carments.
I would like the opportunity to appear before you and
present evidence in support of this application in the
fonn of a written report fran a planning expert and have
the expert available for your examination. We anticipate
that the planner's report will be ready ea:uly in January.
Accordingly, would you defer your consideration of this
matter until such time and notify me of the time at which
the matter will be considered so that I may appear with my
evide."1ce.
Thank you for your cooperation.
Very truly yours,
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Eric J. Bressler
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Southold. N.Y. 11971
JOHN WICKHAM, Chairm3ll
FRANK S. COYLE
HENRY E. RAYNOR, Jr.
FREDERICK E. GORDON
JAMES WALL
TELEPHONE
765. 1938
March 13, 1978
Southold Town Board
Town Hall
Southold, New York 11971
Gentlemen:
The following action was taken by the Southold Town Planning
Board at a regular meeting held January 30, 1978.
RESOLVED to recommend to the Southold Town Board denial of the
application of North Fork Manor, Inc., Case No. 237, for a change
of zone for property located at Mattituck, New York, from "A"
Residential and Agricultural District to "B" Light Business
District because it is not in conformity with the use laid out
of development of a high speed access road and the discouragement
of business on that road is laid out in the development plan of
the Town of Southold.
Mr. Wickham stated that the original site plan is' in violation
since the barrier to access to Route 27 was removed, apparently,
by the operator soon after it was erected. It is our opinion that
a business is not viable in this location because of the physical
nature of the interchange. The removal of the barrier under-
scores the fact that a business cannot be operated here without
direct access to County Road 27.
Yours truly,
~.j..uud. :>!~~
Muri€1 Brush~~etary
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Suffolk County Department of P1anninr,
H. Lee Dennison Executive Office Bui1~ing
Veterans Hemorial IU!!m~ay
Hauppauge. New York 11707
(516) 979-2918
Town of Southo1d
Planning Board
March 3, 1978
Petitioner:
Mun. File No.:
Zoning Action:
North Fork Manor. Inc.
237
"A" Residenta1 & Agricultural to "B"
Light Business
S.C.P.D. File MO.:
SD-78-S
Gentlemen
Pursuant to the requirements of Sections 1~23 to 1332 of the Suffolk County
Charter, the above captioned application which has been referred to the Suffolk
County Planning Commission is considered to be a matter for local determination.
The decision of local determination should. not be construed as either an approval
or disapproval.
Comments, Sub;ect to compliance with any requirements set forth by the Suffolk
COunty Dept. of Public Works. Appropriate vehicular access. use and buffering
restrictions warrant consideration.
Very truly yours,
Lee E. J"'..oppe1man
Director of Planning
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by / ...J(.J"O .--J
Gerald G. !1ewman
Chief Planner
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cc: Town Clerk
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February 27, 1978
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Suffolk County Planning Commission
Veterans Memorial HighWay!
Hauppauge, New York 11787!
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Gentlemen: I
Pursuant to sectionsi132:3 to 1:3:32 of the suffoit'county
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Charter, the Planning Board of the Town of Southold hereby refers
the fOllowing proposed zo~ing action to the SUffolk County
Planning Commission: ,I
Amendment of zoning ~ap (change of zone) ~
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Location of affectediland: intersection of
County Road 27 in Mattitufk"Town of Southold
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within 500 feet of: Co~y Road 27
Comments: The Southold lwn Planning 'Board tqokthe,; foUowl~g
action on January 30,1971. RESOLVED to recommendtf the
Southold Town Boarddenia~ of theappl1cation of NOrit;h Fork Manor,
Inc., Case No. 237, for l!I4 change of zone for Propertt lOCllted at
Mattituck, New York, fI'9111< "A" Residential and Agrj,cultural
District to "B" L ight rw.~s' ness District b eeause lt U>" not, in
conformity with the use id out of development ofa!hlgh speed
access road and the ,dl,SC', agement of bUSiness, on, tht.tr, oa, d is
laid out in the deve]:opm1t plan of the ToWll, of, Soutf1ol,d:. Mr .
Wickham stated that the iglnal site plan islnvloiatlGft'since
the barrier .llG,,411~\,;ess to oute 27 was removed ,apPfU'ently, 't:Jy IlIlv
operator soon at'ter it wa)! erected. It is ow::!oPin~ "that,a
business is not v,lable il1l thi, S 10cat,10n be>cauae.. of, tile physlcal
nature of the lnterchange~ The removal of the;barrfer underscores
the fact that a business fannot be ollprated her~ without IUr,ect
access to County Road 27. > "
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Avenue and
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Yours truly,
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Muriel Brush, Se~ret.ry
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JUDITH T. TERRY
T OWN CLERK
REGISTRAR OF VITAL STATISTICS
TELEPHONE
(516) 765-1801
Southold, L. I., N. Y. 11971
December 7, 1977
Southold Town Planning Board
Southold, New York 11971
Gentlemen:
Transmitted herewith is petition of North Fork
Manor, Inc. requesting a change of zone from "A"
Residential and Agricultural District to "B" Light
Business District.
You are hereby instructed to prepare an official
report defining the conditions described in said petition
and determine the area so affected with your recommenda-
tions.
Very truly yours,
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Judith T. Terry
Town Clerk
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CASE NO: .._.~7.....
STATE OF NEW YORK PETITION
TOWN OF SOUTHOLD
h'r THE. MATTER OF THE PETITION OF NORIH FORK MAl,OR, Th\::.
FOR A CHANGE, MODIFICATION OR l01El',TI;\IENT OF THE BUILDING ZONE ORDIN-
At"'CE m' THE TOWN OF SOUTHOLD, SlJFFOLK COUNTY, NEW YORI{.
TO THE TOWN BOARD OF THE TOWN OF SOUTHOLD:
1 I """lYTU ~Ri..:.:aiC................. , residim!: at ;:!9.~g_.!'!~9.?-...~;i,Y~.z..kl<\t:tit.1,lck, N.Y.
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(insert name of petitioner)' 11952
Suffolk County, New York, the undersigned, am the owner of certain real property situated at
Sound Avenue & Counq Road
............._............IRL,.............:.~.:..:=:::._ and more particularl~' bounded and described as follows:
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BEGINNING at a Point on the northerly side of Scim,d Avenue where same is inter-
sected by the westerly side of land DOW or fonni:trly of IDng Island Lighting Co.
and running t..'1ence along the northerly sided' Sound Avenue, the foll=ing:
(1) North 85003' 20" ,vest, 180.80 feet; (2) North 790 56' West, 108.88 feet;
(3) Nort:J::westerly along a curve bearing to the right and having a radius of
667.97 feet, a distance of 135.60 feet; (4) Northwesterly along a curve which
bears to the right and has a radius of 390.0 feet, a distance of 134.34 feet;
thence along a =e which connects the northerly side of Sound Avenue \~ith the
southerly side of ~1iddle Road, northerly and northeasterly along a curve which
bears to the right and has a radius of 40.0 feet, a distance of 83.68 feet;
thence along the southerly side of *ddle Road, the foll=ing: (1) Easterly
along a curve which bears to the right and has a radius of 2908.79 feet, a
distance of 287. 69 feet; (2) easterly along a =e which bears to the right and
has a radius of 2820.79 feet, a distance of 109.39 feet; thence along land n=
or fonnerly of Joseph Gilles, South 350 38' 50" East, a distance of 169.94 feet;
thence along land now = fonnerly of IDng Island Lighting Co., the follryNing:
(1) South 540 44' West 100.0 feet; (2) South 350 16' East, 183.72 feet to the
--"non:n:erly.sideof.Sound.'Avenue-at the point-or place of BEGmNmG.
2. I do hereby petition the Town Board of the Town of South old to change, modify and
amend thE: Building Zone Ordinance of the Town of Southold, Suffolk County, New York,
including the Building Zone Maps heretofore made a part thereof, as follows:
'ib change the above described parcel, presently zoned as A-Residential-
Agricultural, to B: Light Business.
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3. Such request is made for the following reasons:
Petitioner acquired the subject parcel when it was zoned "E:. A restaurant was
erected in confo:rmity with the then existing law. Subsequent rezoning to
"A has rendered the parcel unsaleable for all business uses other than the exact
one on the site presently. 'TIle parcel is totally tmSuited for either residential
or agricultural purposes and is not marketable as such. 'TIle parcel is
located on C.R. 27 at the Sount Avenue inler section and is irregularly
.<.shaped. All of the similarly located properties are zoned "E or
"C". Petitioner requests a rezoning to "E" so that it may realize a fair
return on the property.
IDR'lH EDRK MANOR, INC.
(L. S.) ~~.~~~........
Gabriel Kousour.os
STATE OF NEW YORK,)
) SS:-
COUNTY OF SUFFOLK, )
tioner
.. ~~~ .~~~.~'. .~7.~:if!.~:t: .<?:!=. !?~t;~( , BEING DULY SWORN, deposes and says that
he is the petitioner in the within action; that he has read the foregoing Petition and knows
the contents thereof; that the same is true to his (her) own knowledge, except as to the matters
therein stated to be alleged on information and be lief, and that as to those matters he believes it
to be true.
(L. S.) m..~~.:-;,.........
Sworn to before me
this .+?.. day of . .~9Y~............, 19. n
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~' Notary Public.
.-/l\BIGAIL: A. WICKHAM
Notary Public, State of New Yo1Ft
No. 52-46(1,2871
Qualified in Suffo:'- C0~Jnt)'
Term Expires Marcil 30,197.1'
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I TO:
ELWARD P. GIlLES
North iliad
Mattituck, N.Y. 11952
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LILCD
250 Old Conntry iliad
Mineola, N.Y. 11501
PLEASE TAKE NOTICE that NORm roRK ]VIJ\NOR, INC., the owner of
real property located at Sonnd Avenue and Connty iliad #27, proposes to petitio
the 1bwn of Southold requesting a change of zone classification from A: Resi-
dential/Agricultural to B: Light Busrness.
'!he subject property is described as follONs:
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BEGINNING at a point on the northerly side of Sound Avenue
where same is intersected by the westerly side of land nON
or formerly of Long Island Lighting Co. and running thence
along the northerly side of iSound Avenue, the follONing:
(1) North 850 03' 20" West, 180.80 feet; (2) North 790 56'
West, 108.88 feet; (3) Northwesterly along a curve bearing
to the right and having a radius of 667.97 feet, a distance
of 135.60 feet; (4) Northwesterly along a curve which bears
to the right and has a radius of 390.0 feet, a distance of
134.34 feet; thence along a curve which connects the northerly
side of Sound Avenue with the southerly side of Middle fuad,
northerly and northeasterly along a curve which bears to the
right and has a radius of 40.0 feet, a distance of 83.68 feet;
thence along the southerly side of Middle iliad, the following:
(1) Easterly along a curve which bears to the right and has a
radius of 2908.79 feet, a distance of 287.69 feet; (2) easterly
along a curve which bears to the right and has a radius of
2820.79 feet, a distance of 109.39 feet; thence along land now
or formerly of'Joseph Gilles, South 350 38' 50" East, a distance
of 169.94 feet; thence along land neM or formerly of Long Island
Lighting Co., the follmving: (1) South 540 44' l'iest 100.0 feet;
(2) South 350 16' East, 183.72 feet to the norb'1erly side of
Sound Avenue at the point or place of BEGINNING.
'!he present zone classification is: A: Residential/Agricultural.
'!he requested zone classification is: B: Light Business.
PlEASE TAKE FURIHER NOrICE that petition for such zone reclassi-
fication will be filed in the Southold '!'aNn Clerk's office, Main iliad,
Southold, New York, within five (5) days of the date of this notice, and my
then be examined during regular business hours.
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PLEASE TAKE FURlllER NOTICE that a public hearing with respect to
;1 such petition must be held by the Southold 'Ibwn Board before such change of
Ii zone can become effective. You or your representative have the right to
'Ill appear and be heard at such hearing; and a notice of such hearing will be
published in the official town newspaper not less than ten (10) days prior
I to such public hearing.
Dated: Noverrber 15, 1977
WILLI1\IIl \-IICKHAM, P.C.
Attorney for petitioner
Main Road Box 1424
Mattituck, N. Y. 11952
(516) 298-8353
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RE: NORl'H FORK MAlDR, INC.
APPLICATION FOR ZCNING RECLAsSll'ICATION
STI\'I'E CF NEW YORK )
:55:
CDUNTY OF SUFFOLK )
ELLEN PRES'ION, being duly sworn, deposes and says that she is over
21 years of age, and resides at 903 Main Street, Greenport, N. Y.
That on the 15th day of NovEmber, 1977, she mailed the annexed
notice of petition on behalf of North Fork Yenor, Inc. to each of the follow-
ing at the addresses indicated:
lliward P. Gilles
North Road
Hattituck, N.Y. 11952
LILCO
250 Old Country Road
Mineo1a, N.Y. 11501
by certified mail, return receipt requested, at the United States Post Office
rnaintained at Love Lane, Mattituck, N. Y.
avorn to before me this
16th day of NoVEmber, 1977
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Notary Pub ic
((,~ {;k!:d:o IJ
Ellen Preston
CCROTHYHfNDE~SON
W::rJ:A~Y PUBLIC,. Stat. .f NOw 1.i!
iNo. 30.6848100
". ~a!jfied i~ Nas.s...~iJ Cbunty ~ ,
~rnlS5tO'h EX;:lIres Me-i'ch;"30,";7f
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PLANNING & ZONING REPORT
VICINITY MIDDLE ROAD & SOUND AVENUE -
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MATTITUCK ~
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PlANNING & ZONING REPORT
\fr'~INITY MIDDLE ROAD & SOUND AVENUE
MATTTTUCK
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Frederick F. Meyer
Munic i'~al Planner
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The zone change application under discussion by the
Planning 'loard on January 10, 1978 and that will subsequently
also be the subject of discussion at a public hearing to be held
by the Town 1'loard, is to amend the official zoning map of Southold
from Residence A back to B Light Business District.
Tf-IE SITE
The subject parcel is located at the intersection of Suffolk
Co\mty Route 27 (Middle Road) and Sound Avenue and contains 2.65
acres of land. It has 400 lineal feet of road frontage on Middle
.
;\oad and S')':' lineal feet on Sound Avenue plus 83 feet on a
connecting roadway, for a total road frontage of 1042 lineal feet.
The average depth of the parcel is 260 feet. It is a level site,
containing a soil composition known as Plymouth loamy sand. The
parcel contains no trees or any other vegetation except 1'01' ~Iild
grasses. It has a 60 foot LILCO easement running through a
Dortjon of the easterly end of the parcel.
Situated on the site is a one-story concrete block structure,
containing approximately 900 square feet and presently used as a
seasonal restaurant, known as "The Hut". Other improvements
located on the site consist of bluestone surrounding the structure
and consisting of approximately 28,950 square feet of area, upon
which customers park in an unrestricted manner. The bU1.1d:i..ng and
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bluestone parking area cover approximately 34 per cent of the
total site, but the building only covers.85% of the site.
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'eighty-three feet of concrete curbing exists at the apex of
the triangle, apparently installed with the improvement of
';ounty Hoad 27 -- Middle Hoad.
LAND U:3E AND ZONING OF OTHER PARCELS
The sub.ject is generally the shape of a triangle, except
that the apex i.s rounded, and so it virtually has road frontage
along three highways. Opposite each of these are privately
owned Droperties, all of which are zoned either business or
industrial. This can readily be seen in Exhibit A. Parcell,
located at the northeast corner of Middle Road and Cox Neck
Road is zoned B Light Business having a frontage of 1300 feet
and a depth of L~OO feet. It is vacant and can be seen in
... photograoh #1. Parcel 2, located on the northwest side of
:.iiddle Road and Cox Neck Road is zoned 13 Light Business having
a frontage of 920 feet and a depth of 400 feet. It is vacant and
can be seen in Photograph #2. Parcel 3 is located on the south
side of Middle Road west of the intersection with Cox Neck Road;
it is zoned R Light Business and is improved with a business
building known as the Doric Dimensions Corporation. T'li s can be
"een in photograph 113. Parcel #L~ is directly behind, EaVlng
limited frontage on the south side of r-.liddle Road; It too is
zoned B LLght Business and is improved with a precast cessDool
manufacturing plant. 'rhis can be seen in photograph
Parcel
:05 is contj_guous to Parcel #3 and is zoned B Light Business, in
all, Parcels li3, 1/4, and #5 have a combined road frontage on the
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south si.de of "dddle Hoad and Sound Avenue of 10110 feet -wtth an
average depth of goo feet. Parcel #6 is directly opposite a
portion of the subject parcel, lying on the south side of Sound
j,venue and i.s zoned C Industrial. It has a frontage on Sound
Avenue of 880 feet, and extends southerly to the LIRR r-o--w for
an overall depth of 1300 feet. This tract is unimproved except
for a E;i.ngle family residential structure; it can be seen in
ohotograoh
To the rear of the SUbject is a 60 feet LILCO easement
that brings electric power from Port Jefferson to the Mattituck
substation, which is located adjacent to the southeast corner
of our parcel; see photograph #6.
~ihen examined overall, the subject is currently surrounded
by divergent zoning patterns and is virtually an island of
residentially zoned land, in fact used for business. Undoubtedly
all of the business or industrially zoned parcels will in due
time develop wi.th some permitted use, in accordance with their
current zoning district. It is unlikely that the sub:;ect would
or could at this point in time develop with 40,000 square foot
single family residential home sites, as it is currently zoned.
In the first place i.t 1s improved -with a commercial structure,
has been assessed as such and taxes are paid on the basis of a
commercial entity. Therefore, the land and improvement has an
ascribed value based upon its prior business zoning and the
business i.mprovement thereon. To build residences, therefore,
would greatly diminish the existing and potential business value.
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~ In the second place the site does not lend itself to development
1~ith single fami.ly dwellings because of the highway exposure
(5,200 vehicles per day on Middle Road), and the lack of any
vegetative or topographic assets that would offset the highway
liabilities. The two dwellings (see exhibit B) that could be
erected there would be totally isolated from any residential
neighborhood. It is also highly unlikely that any d'screet
buyer would make a financial commitment, knowing that he will
one day face commercial or industrial land uses.
REZONING IN ACCORDANCE WITH GOOD PLANNING
It would be good and practical planning to restore to the
sUb,ject, B Light Business, zoning classification. At this time
. it seems reasonable to terminate the business zone at the bound-
ary of the LILCO high tension power lines, as has been done with
the parcel on the north side of Middle Road and the south side of
Sound Avenue. Municipalities have traditionally used utility
lines, railroad lines, rivers, abrupt changes in topography or
ma.jor highways to separate zoning districts.
While it is with good reason that the Town's Master Plan
emphasizes the retention of agriculture in the Township, it is,
however, unrealistic to place the sub.ject in that classi.fication,
because it had previously been zoned business and because the
site is too small to ever be considered for the raising of crops.
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THE PRACTICAL AllD FINANCIAL ASPECTS OF NONCONFORMITY
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As was stated previously, the sUb,ject parcel is developed
commercially v/i th a small restaurant occupying only a portion
of the 5i te. i~i.nce the Town Board changed the zoning classifica-
tion from business to residential, the use is now nonconforming.
It did conform to local zoning insofar as use and setback re-
quirement are concerned when built in 1971. When the zoning was
changed to residential the use bec8J1le nonconforming. [..lore
specifically, it no longer complies ,~ith the list of permitted
uses in that di.strict. As such, the current owner and any future
owner is severly limited as to the improvements he may make to
the restaurant. For example, it may not be reconstructed or
structurally altered by more than 50)"b of the value of the build-
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ing. i3ince the current building is of modest size and occupies
only a small portion of the site, the reasonable development
capabili ties can never be realized under i.ts current status. The
addition of more seats, a dance floor or the enlargement of the
kitchen facilities are virtually eliminated.
A change of use to one previously permitted in the business
zone is nc longer permitted. A nonconforming use may not be
substituted for another. Other limitations imposed upon n:.moon-
forming uses are addressed to repair in case of d8J1lage by fire
and discontinuance of the use entirely if it is closed beyond
a certain period of time. All of these restraints are obviously
imposed for a single purpose, that is to cause the ultimate demise
.
-6-
.
of a use as it loses its vitality. This is acceptable if there
is a reasonable alternate use for a given site. The existing
use, however, will deteriorate (due to the virtual prohib:tion
of improvements), and as such it will deter other potential
users from developing on their surrounding business properties.
The Town has initiated the groundwork for the alteration of the
area in a negative manner and has not exercised its zon1ng power
in the best interests of the welfare of the community.
The present owner is desirous of selling the land and
build lng, but carmot do so under present conditions. No prudent
purchaser \'iOuld be "illing to purehase the restaurant with the
intention of carrying on such a use without the prospect of grow-
ing in accordance with the capabilities of the land and pursuant
. to the needs of the existing and future needs of the community
as population centers shift and grow.
THE LOGIC IN CHEATING A NONCONFORMING USE
It is sometimes reasonable for a municipality to "zone out"
existing uses. 'rhis may be true where a use is inconsistent
with the immediate neighborhood; or perhaps noise, smoke, vibration,
fumes, dust, odor or excessive light violate the health, safety
and general welfare of the community. In such a case tCle govern-
ing body has a right to protect the neighborhood, and onc of the
ways to do so is to eliminate the obnozious use from the list of
permitted uses in the particular zoning district, or by changing
the zone. The former method is most reasonable, since it pre-
. serves the establi.shed value of the land and building. In the
instant case, however, the use is not obnoxious and there is no
.
.
.
-7-
established residential neighborhood in the usual sense, i.e.
a colony of dwellings that support an elementary school. Yet
the Town Board rezoned the parcel out of any business or i.ndustrial
district and placed it in the most restrictive residential district.
This is unconscionable. It is an unwarranted act and without prov-
ocation since the restaurant use was and still is a r.1ermitted use
in the Business zoning category. Furthermore, neither it, nor any
of the other permitted uses normally have characteristics warrant-
ing the Town to make them nonconforming.
To take the inconslstency one step further, all surrounding
properties (previously described) that are zoned for business
or industrial uses, but are vacant, have retained the'r zoning
status b'~t the subject upon which there exists an established
business use has vtrtually been zoned out of business -- i.n both
senses of the \-IOrd. If in fact it could be proven that the use
is obnoxious and that it should be terminated, then the use should
be eliminated from the perm1tted l1.st within the Business District.
Because if'.t 1.s obnoxious at one location, then too :Lt would be
elsewhere. Also, if it was determined after due study that Business
and Industrial zoning in general will not be needed to serve the
communi ty, them all parcels should have been rezoned. Therefore,
the Town's act was arbitrary, capricious and discriminatory
against one property o~mer. He will suffer irreparable los s, to
the point where no value whatever remains so long as it is zoned
Residence A. He has been unreasonably prohibited from improving
and carrying on such activities that will enhance and Dreserve the
value of the property. Instead, the action provides for the
ultimate elimination, by attrition or otherwise, of the instant
use.
-8-
.
Ft"rnaDs U, 1'1 a:, the TO\'ln's desire to minimize the anticiJ'ated
condemnati on co:;ts by the State of New York. In lC),',:) a Dre-
li,mi,nary planni nr; stuuy was made by the New York State :JeDart-
ment of TransDortatirnl indicating a possible extension of the
Long Island Expressway easterly from its present termInus in
Piverhead Town to the new County Road 27. Th'1t was a study that
still has no status; there are no funds set aside for contract
drawings, land acquLsition or construction. There are no funds
for advanced l~,nd acquisition and the proposal is not '.neluded
In the D9p8rtrnent':-) IJ-year program. If it does gai,n status, con-
struction ,~ould be 10 years plus. At any rate, the contrel of
land use to mInimize condemnation costs has not been 'JD":('ld in
.
the courts. I t is not the functi on of zoning to virtlla.1..ly condemn
Land so that the minicipality will be able to purchase nt a Drlce
lower than the fair mS.rket value.
SUMHARY
It appears, after a physical examinatJ.on of the site and
the surrounding area, that the zoning pattern established some
tim~ ago in the vicinity of Middle Read and Sound Avenue was reason-
able. There is no a:pparent reason to change that zoning Da t tern
at this time, and especially on a site already used for bu"iness
purcoses. To do so is spot zoning in reverse. To do so is tanta-
mount to confiscati.on of property without due process of the law
and without any valid reason. The municipality has abused its
"police power", to promote the health, safety and general \'Ielfare
. of the community. vlith the previous rezoning of the sub.!ect, the
munic'j Dali ty has violated one of the objective s of zoning, whi.ch
-9-
. is to conserve property values. Instead, the rezoning has
resulted in depressing the value of the subject and it l'Ii11
result in changing the character of the area.
All traditional planning concepts support the argu'11ent in
behalf of returning the subject to its original business zoning
classification. Therefore, it is respectfully requested that
the subject parcel be rezoned in its entirety from Resi.dence /1,
to B Light Business District.
.
.
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M~p TO ACCOMPANY ~PPLlC~TrON
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r:!OCJeIZICf<. VAN TuyL., P. C
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G~tfporl' - New Yo..-t:..
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