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HomeMy WebLinkAbout6010Office Location: Town Annex/First Floor, Capital One Bank 54375 Main Road (at Youngs Avenue) Southold, NY 11971 53095 Main Road P.O. Box 1179 Southold, NY 11971-0959 http://southoldtown.northfork.net BOARD OF APPEALS TOWN OF SOUTHOLD Tel. (631) 765.1809 Fax (631) 765.9064 COVER SHEET WITH ZBA FII,F, STATUS OF FILE ZBA# ~20l0 [ ] Refund issued: CANNOT activate or reactivate file (Applicant has withdrawn application). [ '~ NO REFUND DUE, based on time spent for Town to process application and hearings. [ ~ ] Obsolete & expired; CANNOT reactivate this file: NEW APPLICATION NECESSARY: Extensive time has passed; Zoning Code changes are now in effect and this application expired. NOTE: Applicant may apply for a new application with Bnilding Inspector for a new Notice of Disapprova! and submit NEW application with all documents and current maps:to ZBA, or modify plan to conform to the current code. This Town file based on applicant's previous year requests has expired. [ ] No ~onns to be scanned; FILE # VOID: APPLICATION RETIffRNED. (All forms were returned to applicant early in process, as requested by applicant.) ~2 APPEALS BOARD MEMBERS James Dinizio, Jr., Chairman Gerard P. Goehringer Ruth D. Oliva Michael A. Simon Leslie Kanes Weisman http://southoldtown.northfork.net ZONING BOARD OF APPEALS TOWN OF SOUTIIOLD Tel. (631) 765-1809 · Fax (631) 765-9064 Mailing Address: Southold Town Hall 53095 Main Road · EO. Box 1179 Southold, NY 11971-0959 Office Location: Town Annex/First Floor, North Fork Bank 54375 Main Road (at Youngs Avenue) Southold, NY 11971 September 10, 2007 Ms. Mary S. Zupa 4565 Paradise Point Road Southold, NY 11971 Re: Your August 23, 2007 Letter -ZBA File # 6010 Dear Ms. Zupa: We are in receipt of your August 23, 2007 letter. As set forth in our April 9, 2007 resolution, you must file a variance application to permit the continuing use of the legal non- conforming marina use or alternatively, have it removed, so as to comply with the Zoning Board Determination # 5266 adopted August 2, 2004. That determination granted your variance request subject to that express condition, which was sustained by the Supreme Court and Appellate Division, Second Department. The matter was adjourned on April 9th so that you could apply for the variance as required in Determination # 5266. The September 15, 2006 resolution you reference did not change that determination in any respect. Thank you for your attention. V~ truly ~s, OFFICE LOCATION: Town Hall Annex 54375 State Route 25 (cor. Main Rd. & Youngs Ave.) Southold, NY MAILING ADDRESS: P.O. Box 1179 Southold, NY 11971 Telephone: 631 765-1936 Fax: 631 765-3136 LOCAL WATERFRONT REVITALIZATION PROGRAM COORDINATOR TOWN OF SOUTHOLD To: James Dinizio, Chair Town of Southold Zoning Board ~ ~ From: Mark Terry, Principal Planner LWRP Coordinator Date: March 28, 2007 Re: ZBA File Ref. No. 6010 (Zupa) SCTM#1000- 81-01-16.7 MAR 2 8 2007 The proposed action has been reviewed to Chapter 268, Waterfront Consistency Review of the Town of Southold Town Code and the Local Waterfront Revitalization Program (LWRP) Policy Standards. Based upon the information provided on the LWRP Consistency Assessment Form submitted to this department, as well as the records available to me, it is my recommendation that the proposed action is INCONSISTENT with the denoted following Policy Standards and therefore is INCONSISTENT with the LWRP. I Policy 6 Protect and restore the quality and function of the Town of Southold ecosystem. ] 6.3 Protect and restore tidal and freshwater wetlands. A. Comply with statutory and regulatory requirements of the Southold Town Board of Trustees laws and regulations for all Andros Patent and other lands under their jurisdiction. 1. Comply with Trustee regulations and recommendations as set forth in Trustee permit conditions. The proposed setback from the house to the northern bulkhead/wetland boundary is 75 feeh and the proposed setback from the house to the wetland boundary is 83 feet; a minimum setback distance of 100' is required pursuant to Chapter 275, Section 275-3~ D. In addition~ pursuant to Article XXIII Section 280-116 of the Town of Southold Town Code a minimum setback of 75 feet is required from a bulkhead. Note that thc applicant does not show a pool de-watering drywell. To further Policy 5 "Protect and improve water quality and supply in the Town of Southold" please require that a drywell be installed. Pursuant to Chapter 268, the Zoning Board of Appeals shall consider this recommendation in preparing its written determination regarding the consistency of the proposed action. Town Hall, 53095 Main Road P. O. Box 1179 Southold, New York 11971 Fax (516) 765-1823 Telephone (516) 765-1802 Your Building Permit application is being returned as incomplete for the following reasons; / DATED: ),=~..-~.. ~- I~ b Disa~rowd ExpJratlon ........................ ~ 20 Building Inspector APPLICATION FOR BIYlL4MNG PERMIT Date ......... ~, 20 O~ INSTRUCTIONS a. ~ applicatiam MUST be completely ~ in by qq~vriter or in ink and submitt~ to the Building Inspector with 3 sels of plans, accora~ ploi phm to scale. Fee a~:x~l~_ ~o sc. hedu~ b. Plot plan ~ loemtiun oflo~ and of Imildings ~ ~ip to adjoining premises or public stl~ets or areas, and wsi~',~ys. , · , ¢. The work C~verad }my this applicmtiun may not be ~ hefm~c ~ al'Building Perrmt. d. Upou splxoval of this applicadun, thc Building ~ will ~mc ~ B~ldin8 Permit m the applicant. Such a pcmut shall be kq~ o~ il~ l~mi~s available for inspection throughom tbe work, e. No tmildi~ shall be occupied or used in whole or in part for ~my purpose what so ever until thc ~ Inspector issu~ ,, Certifita~ of Occupancy. L Every building permit shall expire if thc work authorized has not co~ within 12 momhs after the d~te of lssu~n~ or has not b~n completed wflhm 18 mouths from such date. if no zo~ng aanemim~ts or Other ~ ~lt~ting the ~y have be~m {umcted in the interim, the Building Inspector may authorize, in writing, the exienskm of the permit for mn addition six months. TIlurlmih~, a new Pcrlmt shall be requil-ed. APPLICATION I$ HEREBY MADE to the Bsfildin8 ~t for the issuauee of a Buikting ~ ~ to the Building Zone Ordi.q~Iee ofil~ Tc~nl of Southold, Suffolk Co~lty,~ York, and other applicable Lnwtg ~ or Regulations. for the coustn~ion of buildings, additions, or altemtio~ or for removal or demolition as herein ~ The applicant agrees to comply with all applicable laws, or~ ~ ¢o~, hOUSing code, ~md rugulafious, {md to admit au~Jaomed respecters on pr~mis~ and in building for nec'~s~ry ~cas. fSignam~e of ~Plm! or mine, if a corpor~on) /~4~- (M~Jlj.~llddr~ssof~licnm) State whether applicant is owner, lessee, agent, architect, engineer, general contractor, electrician, plumber or builder Builders l.icease No. Plumbers License ~.: ~ Electricians t iccnse No. Other Trade's I.iccnse No. Location of land on which pJcOposed work will bc done: House Numb~ S~t Hamlet County Fax Map No. 1000 Sex:non ~, t Block / Lot / /~% ~ Subdi~isi~m Filed Map No .. Lot .... (Name) Nature of work (check which applicable): New Building Repair Removal Demolition State exiatin~ usc and occupancy of premises and intended ~e and .~o~up~cy o~?opo~d co?stm~on: A~fi~ A~n ~ Wo~ (~on) 4. Estirmted Fee 5. lfdwellmg, nmrd~erofdwellmgun ts If garage, number of cars ~ (To be paid (aa filing this application) Number of dwelling units on each floor 6. If business, commercial or mixed occupancy, specify nature and extent of each type of use. 7. Dimensions of existing structures, if any: Front__ . Rear H~ight Numtmr of Stofl~s Dimensions of same slructure Wi~ ~ttemfions or additions: Fro~ Depth. Height Number of Stories 8. ~iousofenfirenewconstmctinn: Front ~ ~ ~: Height ~/' Number of Stories 9. Size of Iot~:'Front Rear 10. Date of Purchase ~l Ob Name of Former Owner Re= ? Z ! Dq h 1 I. Zone or use district in which pmm~ are situated ~: gO 12. Does pmposed construction violate any zoning law, ordinance or regulation? YES NO 13. Will lot be re-grmted? YES NO_~_Will exce~ fitl be removed from premises? YES__ NO. 14, 1'4runes of Owner of oremises~Address. Phone No. Name of C~or 3a ~k ~ ra ,~- - ,Address Phone 15 a~ Is this property within 100 feet of a tidal wetland or a fieshwater wetland? * [F YES~ SOUTHOLD TOWN TRUSTEES & D,E.C PERMITS~MAY BE REQUIRED. b, ls this property within 300 feet ora tidal wetland? * YES '~ ?r-NO ~ ~) e ~ ct', ?r dZ.-~-~ c, ~ ~'d * IF' YES, D.E,C, PERMITS MAY BE REQUIRED t6, Provide survey, to scale, with accurate foundation plan and distances to property lines. } 7 If elevation at an), point on property is at t 0 feet or below, must provide topographical data on survey. STATE OF NEW YORK) SS: !'~/'[ ~[ 'q ,,~,-~ ~0 ~ bcmg duly sworn, de~ and says thai (s~he is the ~licant (Name of ihdivickml signing c-ontmcO above tS)He is the (( ,retractor, Ager~t. Corporate Officer, etc,) of said owra.~r or ownea's, and is duly authorized to perform or have l~a'formed the said work and to make and ~ ~ ~Ca~; that al} slatements contained in th: applicat/on ~c e to ~ e best of his knowledee and belicC ~m<~ thai ]:~. work will be Planning Board -4- June .1, 1981 spondence from =he"Suffolk County Department of Health Services re- garding the SEQRA, correspondence to the Suffolk County Planning Commission, copy of the legal notice, metes and bounds description, correspondence from the applicants attorney, sketch plan approval for this subdivision on March 26, 1980, I would assume it is March 1981, also declaration of lead agency status wl~h Sou=hold Town Planning Board, application for approval of plot, short environmen~l assessment form. This completes :he file. This is a tract of prop- erty that's being divided into two. The tract of property consists of fifty-nine and one-half (59%) acres, one plot .being ~hirteen acres =o =he north, the second plot being four:y-six acres to the south. AS is :he procedure of public hearings, I will ask is there anyone present this evening who would like to speak in opposition =o this proposed minor subdivision of the Henry Jennin~s Estate? Hearing none, is there anyone present this evening who would like =o speak in favor of this proposed minor subdivision of the Henry Jepnin~s Rudolph Brier: On behalf of =he estate, I would just like to re- irradiate what I spoke to you gentlemen earlier on the site pian approval. The purpose, I represent the estate whose selling it subject to the division of the property, we've been advised by the proposed purchaser, a Dr.. Damianos, =hat it would be used for =grape growing purposes and :he purpose of =he.' splitting of it is that =he larger piece is going to be used as a farm. Respectively, we ask the board to allow the division of the property, thank you. Mr. Raynor: Is there anyone else present this evening who woul~ like =o speak in favor of =his proposed subdivision? Is =here anyone present this evening that has some information t-hat ~%y be neither pro nor con but should come before this board at this time? Hearing none, is there any member of the board =hat has any questions? Mr. Orlowski, Mr. Latham, Mr. Wall, Mr. Mullen? Ail answered in the negative. ~4r. Raynor: There being no further questions we will deem this hearing closed and thank you for coming down this evening. Mil:on Mehlman minor subdivision. Johh $:rong appeard before the board to discuss with :hem his request :hat :he right-of-way be =hanged from 50 fee: to 25 feet. The board feels =ha: 50 fee=for :he right-of-way is needed if no= at this time but for the fu:ure. Mr. Sprong's request has been. denied. On ~=ion made by Mr. Orlowski, seconded by Mr. La=ham, i= was P. ESOLVED =o set-off as indicated of :he minor subdivision Paradise Point Corporation lots entitled "Club House" of two and three ~uarter acres and an unnu~nbered lot on Sou=hold Bay consisting of 1.7 acres directly east of the inlet basin. Vote of :he Board: Ayes: Raynor, Wall, Orlowski, Mullen, La=ham $ B9'23'08" E 21.63' TEST :~OLES DATA N SUFFOLK COUNTY, NEW !YORK S.C. TAX No. 1000-81-01=-1'6~ SCALE 1"=30' JANUARY, 7, 2002 JANUARY 29, 2002 REVISED LOT ~REA NOTATION FEBRUARY 14, 2002 REVISED DRIVEWAY LABELS SURVEY OF PROPERTY SITUA TED A T BAYVIF TOWN OF SOUTHOLD MAY 15, 2002 AUGUST 5, 2002 REVISED WETLANDS LINE, LOCATED WETLANDS & ADDE9 TOPOGRAPHICAL SURVEY JUNE 1, 2002 ADDED SiTE PLAN SITE PLAN & ADDED TEST HOLE No. 2 LOT AREA INCLUDING THE BULKHEAD AREA AT THE NORTHWEST PORTION OF = 75,687,56 sq.. ff. THE LOT PROJECTING INTO SOUTHOLD BAY (TO BULKHEADS & T~E LINES) 1.758 LOT AREA EXCLUDING THE BULKHEAD AREA AT THE NORTHWEST PORTION OF = 72,747.53 lq. ft. THE LOT PROJECTING INTO SOUTHOLD BAY (TO BULKHEADS & TIE LINES) 1.670 CHICAGO "~,~ MARY S. INSURANCE COMPANY SO UTHOLD (TOWN HARBOR) WETLAND BOUNDARy FOLLOWS N BB'54'O2" [:' THE FACE .2./ 134.02' pAD "29" E BOAT BASIN N Y B, IJc. No. 49668 Joseph A. Ingegno Land Surveyor PHONE (JiB ~ )727-2090 Fax (630727-1727 1. ELEVATIONS ARE REFERENCEB TO N,G.V.D. 1939 DATUM EXISTING ELEVATIONS AP,[ SHOWN THUS:~L~ EXISTING CONTOUR UNES ARE SHOWN THUS: ..... 5 ..... 2. FLOOC ZONE INFORMATION TANEN FROM: FLOOD INSURANCE RATE NAP No. 35105C0167 O ZONE AE: BASE FLOOD ELEVATIONS DETERMINED ZONE X*: AREAS OF 5CO-YEAR FLOOD; AREAS OF IO0~-YEAR FLOOD WITH AVERAGE DEPTH OF LESS ~ 1 FOOT OR WiTH ~N/~3E ~ LESS THAN I SQUARE MILE, AND AREAS PROTECTED ~Y LEVEES FROM IO0-YERR FLOOD. ZONE X: ARF-&S DETERMINED TO BE OUTSIDE 500-YEAR FLOODPLAIN. Office Notes: For Office Use Only Date Assigned/Assignmen! No. ,JAN 2007 APPLICATION TO THE SOUTHOLD TOWN BOARD OF APPEALS Basin Road Southo:1d Parcel Location: House No. 5@0 Street Hamlet R-80 SCTMl000Section 8:1 Block 1 Lot(s)_:16.TLotSize 1.7a Zone District 1 (WE) APPEAL THE WRITTEN DETERMINATION OF THE BUILDING INSPECTOR DATED: December 22. 2006 Owner as Applicant: Mary S. Zupa Mailing Address: 4565 paradise Point Road, Southold, NY 11971 Telephone: 631 765 6112 Fax: 631 765 6119 NOTE: If applicant is not the owner, state if applicant is owner's attorney, agent, architect, builder, contract vendee, etc. Authorized Representative: Address: Telephone: Fax: Please specify who you wish correspondence to be mailed to, from the above listed names: [gApplicant/Owner(s) [] Authorized Representative [] Other: WHEREBY THE BUILDING INSPECTOR DENIED AN APPLICATION DATED :12/2 1/06 FOR: ~XBuilding Permit [] Certificate of Occupancy [] Pre-Certificate of Occupancy [] Change of Use [] Permit for As-Built Construction [] Other: Provision of the Zoning Ordinance Appealed. Indicate Article, Section, Subsection and paragraph of Zoning Ordinance by numbers. Do not quote the code. Article Section 100- Subsection Type of Appeal. An Appeal is made for: []cA Variance to the Zoning Code or Zoning Map. [] A Variance due to lack of access required by New York Town Law-Section 280-A. ~2 Interpretation of the Town Code, Article_ I Section 2 8 0 + 4 ~:ReversalorOtherg~a~ D~c~cm-~q2~: R/2./04 ~ncl Zg~ ~qcll~ g,/'15/06 A prior appeal ~has E has not been made with respect to this property UNDER Appeal No. 5 2 6 0lea r~2.d)~L4_. Page 2 Owner: Mary ~. Zupa REASONS FOR APPEAL (additional sheets mav be used with applicant's signature): AREA VARIANCE REASONS: (1) An undesirable change will not be produced in the CHARACTER of the neighborhood or a detriment to nearby properties if granted, because: See Attachment (2) The benefit sought by the applicant CANNOT be achieved by some method feasible for the applicant to pursue, other than an area variance, because: (3) The amount of relief requested is not substantial because: (4) The variance will NOT have an adverse effect or impact on the physical or environmental conditions in the neighborhood or district because: (5) Has the alleged difficulty been self-created? ( )Yes, or ( )No. This is the MINIMUM that is necessary and adequate, and at the same time preserve and protect the character of the neighborhood and the health, safety, and welfare of the community. Che~k thk box ( ~ IF A USE VARIANCE IS BEING REQUESTED, AND PLEASE COMPLETE THE ATTACHED USE VARIANCE SHEET: (Please be sure lo consult your attorney.) See Attachment Sworn to before me this dayof Dec ,20 Q(~ Notary Pubh~ SignatuL~of~l~ant or Authorized Agent (Agent mast s~mlt ~tten Authorization from Owner) CONSTANCE SZYIdGZAK No. 01SZ.,61~5616 Comml km Expk Aid lC. - ATTACHMENT TO ZBA APPEAL APPLICATION DATED January 11,2007 ZBA decision #5244 of August 2, 2004 grants an area variance to permit construction of a home, "on condition, however, that no building permit be issued until the nonconforming marina use is removed or a variance is granted to permit its continued use in conjunction with a residential use." The decision cites {}280-121G for support. On September 15, 2006, however, the ZBA ruled that Section 280-121A prohibiting the rebuilding of non-conforming uses was not applicable, and that the Association could rebuild and relocate its docks. This moots the conditions of the 8/2/04 grant ora variance, i.e. removal of the docks, or a variance for a "marina use" of the 580 Basin Road property. In doing this, the ZBA decided that the Association docks did not constitute a non conforming "marina use" of the 580 Basin Road property, but a "non-conforming use of a non-commercial boat basin" owned and controlled by the Trustees." (On September 29, 2005, the NY Supreme Court (Cohalan, J.) decided that the Basin was not owned by the Association but by the Trustees). The minutes of the 7/17/06 hearing indicated that the Association docks should never have been called a "marina." In short, if the zoning code is not applicable, and specifically Section 280-121A, neither is 280-121G. The ZBA decision of 9/15/06 has mooted the conditions for removal of the docks, or for a variance, which were attached to the issuance ora building permit. However, to the extent a use variance is required, this application is an appeal for a variance. Mary S. Zupa 580 Basin Road, Southold, NY SCTM # 1000-81-1-16.7 Town of Southold ' LWRP CONSISTENCY ASSESSMENT FORM ~ ~ A. INSTRUCTIONS 1. All applicants for permits* including Town of Southold agencies, shall complete this CCAF for proposed actions that are subject to the Town of Southold Waterfront Consistency Review Law. This assessment is intended to supplement other information used by a Town of Southold agency in making a determination of consistency. *Except minor exempt actions including Building Permit and other ministerial permits not located within the Coastal Erosion Hazard Area 2. Before answering the questions in Section C, the preparer of this form should review the exempt minor action list, policies and explanations of each policy contained in the Town of Southold Local Waterfront Revitalization Program. A proposed action will be evaluated as to its significant beneficial and adverse effects upon the coastal area (which includes all of Southold Town). 3. If any question in Section C on this form is answered "yes", then the proposed action may affect the achievement of the LWRP policy standards and conditions contained in the consistency review law. Thus, the action should be analyzed in more detail and, if necessary, modified prior to making a determination that it is consistent to the maximum extent practicable with the LWRP policy standards and conditions. If an action cannot be certified as consistent with the LWRP policy standards and conditions, it shall not be undertaken. A copy of the LWRP is available in the following places: online at the Town of Southold's website (southoldtown.northfork.net), the Board of Trustees Office, the Planning Department, all local libraries and the Town Clerk's office. B. DESCRIPTION OF SITE AND PROPOSED ACTION SCTM# 81 1 16.7 The Application has been submitted to (check appropriate response): Town Board Planning Dept. Building Dept. X Zoning Board of Appeals 1. Category of Town of Southold agency action (check appropriate response): (a) Action undertaken directly by Town agency (e.g. capital construction, planning activity, agency regulation, land transaction) (b) Financial assistance (e.g. grant, loan, subsidy) (c) Permit~ approval~ license~ certification: Nature and extent of action: Construction of sin.qle family dwellin.q, i/.q pool, on-site sewa.qe disposal system and associated site improvements as shown on attached plan. All proposed activity >75' from wetland. Mary S. Zupa 580 Basin Road, Southold, NY SCTM # 1000-81-1-16.7 Location of action: 580 BASIN ROAD, SOUTHOLD Site acreage: 1.7 A Present land use: VACANT Present zoning classification: R-80 2. If an application for the proposed action has been filed with the Town of Southold agency, the following information shall be provided: (a) Name of applicant: MARY S. ZUPA (b) Mailing address: 4565 PARADISE POINT ROAD~ SOUTHOLD~ NY 11971 (c) Telephone number: 631-765-6112 (d) Application number, if any:.__ Will the action be directly undertaken, require funding, or approval by a state or federal agency? Yes No If yes, which state or federal agency? NYSDEC, SCHD DEVELOPED COAST POLICY Policy 1. Foster a pattern of development in the Town of Southold that enhances community character, preserves open space, makes efficient use of infrastructure, makes beneficial use of a coastal location, and minimizes adverse effects of development. See LWRP Section III - Policies; Page 2 for evaluation criteria. Yes No Not Applicable Development of this site is proposed in a manner consistent with the current standards and is consistent with the "pattern of development in the town". Policy 2. Protect and preserve historic and archaeological resources of the Town of Southold. See LWRP Section III - Policies Pages 3 through 6 for evaluation criteria Yes No Not Applicable The proposed project is not located near any historic sites or districts Policy 3. Enhance visual quality and protect scenic resources throughout the Town of Southold. See LWRP Section III - Policies Pages 6 through 7 for evaluation criteria Yes No Not Applicable Development of this site is proposed in a manner consistent with the neighborhood in which it is located. Afl proposed activity designed in accordance with requlations, laws and current standards. Mary S. Zupa 580 Basin Road, Southold, NY SCTM # 1000-81-1-16.7 NATURAL COAST POLICIES Policy 4. Minimize loss of life, structures, and natural resources from flooding and erosion. See LWRP Section III - Policies Pages 8 through 16 for evaluation criteria Yes No Not Applicable Development of the site will be done in accordance with FEMA standards, NYSDEC regulations and Chapter 275 of the Town Code. Policy 5. Protect and improve water quality and supply in the Town of Southold. See LWRP Section III - Policies Pages 16 through 21 for evaluation criteria Ye~s No Not Applicable Development of the site will be done in accordance with FEMA standards, NYSDEC regulations, Chapter 275 of the Town Code and Article 5 and Article 7 of the Suffolk County Sanitary Code. Policy 6. Protect and restore the quality and function of the Town of Southold ecosystems including Significant Coastal Fish and Wildlife Habitats and wetlands. See LWRP Section III - Policies; Pages 22 through 32 for evaluation criteria. Yes No Not Applicable Development of the site will be done in accordance with NYSDEC regulations and Chapter 275 of the Town Code. Policy 7. Protect and improve air quality in the Town of Southold. See LWRP Section III - Policies Pages 32 through 34 for evaluation criteria. Yes No Not Applicable It does not appear that Poficy 7 is relevant to development of this site. Policy 8. Minimize environmental degradation in Town of Southold from solid waste and hazardous substances and wastes. See LWRP Section 1II - Policies; Pages 34 through 38 for evaluation criteria. Yes No Not Applicable As in all other residential development, it is expected that the occupant will comply with the expected treatment of residential solid waste, yard waste and recyclable material. I Mary S. Zupa 580 Basin Road, Southold, NY SCTM # 1000-81-1-16.7 PUBLIC COAST POLICIES Policy 9. Provide for public access to, and recreational use of, coastal waters, public lands, and public resources of the Town of Southold. See LWRP Section III - Policies; Pages 38 through 46 for evaluation criteria. Yes No Not Applicable Development of this site has no impact on pubfic access to, and recreational use of, coastal waters, etc. WORKING COAST POLICIES Policy 10. Protect Southold's water-dependent uses and promote siting of new water-dependent uses in suitable locations. See LWRP Section III - Policies; Pages 47 through 56 for evaluation criteria. Yes No Not Applicable It does not appear that Policy 10 is relevant to proposed development of this residential lot. Policy 11. Promote sustainable use of living marine resources in Long Island Sound, the Peconic Estuary and Town waters. See LWRP Section III - Policies; Pages 57 through 62 for evaluation criteria. Yes No Not Applicable It does not appear that Poficy 11 is relevant to proposed development of this residential lot Policy 12. Protect agricultural lands in the Town of Southold. See LWRP Section Ill - Policies; Pages 62 through 65 for evaluation criteria. Yes No Not Applicable It does not appear that Poficy 12 is relevant to proposed development of this residential lot Policy 13. Promote appropriate use and development of energy and mineral resources. See LWRP Section III - Policies; Pages 65 through 68 for evaluation criteria. Yes No Not Applicable It does not appear that Policy 13 is relevant to proposed development of this residential lot APPLICANT'S PROJECT DESCRIPTION (For ZBA Reference) Applicant: Mary $. Zupa Date Prepared: I. For Demolition of Existing Building Areas Please describe areas being removed: HA 12/26/06 Il. New Construction Areas (New Dwelling or New Additions/Extensions): Dimensions of first floor extension: 4 0×7 0 Dimensions of new second floor: 40x? 0 Dimensions of floor above second level: Height (from finished ground to top of ridge): 31 ls basement or lowest floor area being constructed? If yes, please provide height (above ground) measured from natural existing grade to first floor: Ill. Proposed Alterations or Interior Structural Changes without enlargement/extension (attach extra sheet if necessary) - Please describe building areas: Number of Floors and General Characteristics BEFORE Alterations: Number of Floors and Changes WITH Alterations: IV. Calculations of building areas and lot coverage (from surveyor): Existing square footage of buildings on your property: 0 2000 Proposed increase of building coverage: Square footage of your lot: 75,000 Percentage of coverage of your lot by building area: 3 % V. Purpose of New Construction Requested: family residence VI. Please describe the land contours (flat, slope %, etc.) as exist and how it relates to the difficulty in meeting the code requirement(s): none Please submit seven (7) photos, labeled to show all yard areas of proposed construction after staking corners for ney* construction), or photos of existing building area to be altered (area of requested changes). 7/2002: 2/2005; 1/2006 VICTOR J. ZUPA ATTORNEY AT [,AW 4565 PARADISE POINT ROAD SOUTHOLD, NEW YORK 11971 E-MAIL vzupa~optonline.net ADMITTED: NY,CT,DC,MD TELEPHONE (631) 765-6112 FACSIMILE (631) 765-6119 Certified Mail December 20, 2006 Mr. Michael J. Verity Chief Building Inspector Southold Building Department Southold Town Hall 53095 Main Road Southold, NY 11971 Re: Application for Building Permit on 580 Basin Road Dear Mr. Verity: Enclosed please find the following documents: 1) Southold Building Department application; 2) Four sets of building plans; 3) Survey of 580 Basin Road; 4) NYS DEC permit; 5) Southold Trustees permit; 6) Suflblk County Health Department approval; 7) NYS Energy Conservation Construction Code plan; 8) Planning Board Resolution approving 580 Basin Road as a lot; and 9) Check in the amount of $I50. This is a new application for a building permit based on changed circumstances. A prior application for a building permit on this property was denied in November 2002 on the basis that the existence of certain docks constituted a "marina use" of the property, and that a residence would constitute a second use. On August 2, 2004, the ZBA issued a building permit on condition that the docks or -marina use" be removed. However. on September 15, 2006, after the NY Supreme Court determined that the Basin was owned by the Southold Trustees, the ZBA decided that the docks were not a "marina use", and that any non conforming use was on the Basin---not on the property of Mary Zupa. Since the docks do not constitute a "marina ase" of the property of Mary Zupa, a building permit should issue forthwith. The ZBA decisions of August 2, 2004 and September 15, 2006, and the minutes from the July 27, 2005 hearing on which the September 15, 2006 decision was based, are enclosed. It would be appreciated if you would act on this permit application in an expeditious manner. If you have any questions please call me Sincerely, Victor J. Zupa Cc: Hon. Scott Russell, Southold Town Supervisor Hon. James King, President, Southold Trustees PROJECT I.D. NUMBER ~ 617.20 I Appendix C State Environmental Quality Review SHORT ENVIRONMENTAL ASSESSMENT FORM For UNLISTED ACTIONS Only .FART I--PROJECT INFORMATION (To be completed by Applicant ct Project sponsor) SEQR APPLICANT/SPONSOR Mary S. Zupa PROJECT NAME 3. PROJECT LOCATION: Town of Southold Suf.folk 580 Basin Road, Southold, NY Construction of one family residence 9. WHAT IS PRE~ENT I. AND USE IN VICINITY OF PROJECT? Suffolk County Health, Southold Trustees, NY DEC ~No Mary S. Zupa Oat~ If the action is in the Coastal Area, and you am a state agency, complete the Coastal Assessment Form before proceeding with this assessment 12/2~/06 OVER )ART II--ENVIRONMENTAL ASSESSMENT (To be completed by Agency) WILL THE PROJECT HAVE AN IMPACT ON THE ENVIRONMENTAL CHARACTERISTICS THAT CAUSED THE ESTABLISHMENT OF A CEA? IS THERE, OR iS THERE LIKELY TO BE, CONTROVERSY RELAYED TO POTENTIAL ADVERSE ENVIRONMENTAL IMPACTS? ~ Yes [] No Il Yes. explain brielly PART Ill--DETERMINATION OF SIGNIFICANCE (To be completed by Agency) INS?RUCTfON$: For each adverse effect identified alcove, determine wttether it is substantial, large, impo~ant or otherwise significant. Each effect should be assessed in connection with its (a) setting (La. urban or rural}; (bi probability of occurring; (c) duralion; (d) irreversibility; (e) geograpi3ic scope; and (f) magnitude. If necessa~', add attachments or reference supporting materials. E~su~e that explanations contam sulficient detail to show that all relevant adverse impacts have been identlfieo an0 adeguately addressed. If' guestion D of Par1 II was checked yes, the determination and significance must evaiuate the potential impact pi the prop(~sea action [] Check this box if you have identified one or more potentially large or significant adverse imr!5~cts which MAY occur. Then proceed directly to the FULL EAF and/or prepare a positive declaration. [] Check this box if you have determined, based on the information and analysis above and any supporting documentation, that the proposed action WILL NOT result in any significant a0verse environmentaJ impacts AND provide on attachments as necessary, the reasons supporting ti3is determination: VICTOR J. ZUPA ATTORNEY AT LAW 456S PARADISE POINT ROAD SOUTHOLD, NEW YORK 11971 E-MAIL vzupa(~/~optonline.ne t ADMITTED: NY,CT,DC,MD TELEPHONE (631) 76S-6112 FACSIMILE (631) 765-6119 CERTIFIED MAIL January 11,2007 Southold Zoning Board of Appeals 53095 Main Road Southold, NY 11971-0959 Dear Board: Re: Appeal of Mary S. Zupa 580 Basin Road (SCTM 1000.81.1.16.7) Enclosed please find the following documents in support of an appeal to the ZBA from the building inspectors erroneous interpretation dated December 22, 2006 denying Mary Zupa a building permit: 1. ZBA appeal application form with attachment; 2. environmental assessment form; 3. project description: 4. application of December 21,2006 to the building department for a permit; 5. building inspectors December 22, 2006 denial of the application; 6. acheck in the amount of $250; 7. a survey of the property showing the proposed location of the one family residence; 8. Minntes of ZBA hearing of 7/17/06; 9. ZBA decisions Nos. 5914 and 5266; and I 0. 1981 Planning Board Resolution approving the lot. The ZBA's decision (#5266) granted an area variance to permit construction ora home, "on condition, however, that no building permit be issued until the noncontbrming marina use [of the property] is removed or a variance is granted to permit its continued use in conjunction with a residential use." The decision cites Southold Zoning Ordinance §280-121 relating to the continuation of non contbrming uses. However, the recent ZBA decision (#5914) decided with respect to the same "marina" that {}280-121 was not applicable since, not only xvas there no "marina", but any non conforming use was on the Basin i.e. lands o~ ned by the Trustees. Further, ilo use variance is required for Paradise Point Association's usc Since there is no "marina use" of the property for Paradise Point Association purposes, there can be no "marina use" or'the property tbr MarL Zupa's purpose. Effectively. the conditions have been mooted b.', material changes, and a building permit shonld issue. The application for a building permit submitted a few days ago is complete in all respects, except for the building inspector's erroneous interpretation that ZBA decision #5266 precluded the issuance of a building permit without taking into account the recent ZBA decision (#5914). This appeal is made from that erroneous interpretation. To the extent the ZBA concludes a use variance is required for Mary Zupa to construct a residence on the property, this appeal requests one. Cc: Hon. Scott Russell Hon. James King Sincerely, ELIZABETH A. NEVILLE TOWN CLERK REGISTRAR OF VITAL STATISTICS MARRIAGE OFFICER RECORDS MANAGEMENT OFFICER FREEDOM OF INFORMATION OFFICER Town Hall, 53095 Main Road P.O. Box 1179 Southold, New York 11971 Fax (631) 765-6145 Telephone (631) 765-1800 southoldtown.northfork.net OFFICE OF THE TOWN CLERK TOWN OF SOUTHOLD TO: FROM: DATED: RE: Southold Town Zoning Board of Appeals Elizabeth A. Neville January 30, 2007 Zoning Appeal No. 6010 Transmitted herewith is Zoning Appeals No. 6010 of Mary S. Zupa - the Application to the Southold Town Zoning Board of Appeals. Also enclosed is the Applicant's Project Description, Short Environmental Assessment Form, Application for Building Permit, LWRP Consistency Assessment Form, letter from Victor J. Zupa; Attorney at Law to the Building Department regarding the Application for Building Permit, letter from Victor J. Zupa; Attorney at Law to the Southold Zoning Board of Appeals regarding the Appeal of Mary S. Zupa, Board of Appeals Finding, Deliberations and Determination for Appeal No. 5266, Zoning Board of Appeals Findings, Deliberations, and Determination for Z.B.A. File #5914, page number 4 of the June 1, 1981 Planning Board meeting, Transcript from the Zoning Board of Appeals meeting of July 27, 2006, and a Survey of the property prepared by Joseph A. Ingegno; Land Surveyor. Town Of Southold P.O Box 1179 Southold, NY 11971 Date: 01/29/07 * * * RECEIPT * * * ReceiptS: 745 Transaction(s): 1 1 Application Fees Reference Subtotal 6010 $250.00 Check#: 745 Total Paid: $250.00 Name: Zupa, Mary S 4565 Paradise Point Rd Southold, NY 11971 Clerk ID: MICHELLE Internal ID: 6010 ESSEKS, HeFTeR & ANGEL, LLP WIlLIam W. ES$eKS MARCIA Z, HeFTER STEPHEN R. ~ngel CARmE~ M. DI TALIA ~nTHONY C. PASCA COUNSELORS AT LAW 108 EAST MAIN STREET P. O. BOX 279 RIVERhEAD, N.Y. 11901-0279 (631) TELECOPlER NUMBEr (631) 369 2065 MAR 2 $ 2007 March 28, 2007 WATE~ MILL OFFICE MONTAUK HIGHWAY P. O. Box 570 WATER MILL, N.Y, 11976 (631) 726-6633 Zoning Board Of Appeals 53095 Main Road P.O. Box 1179 Southold, NY 11971-0959 Re: Application of Mary S. Zupa, 580 Basin Road Dear Board Members: As you may recall, we are one of the attorneys for the Paradise Point Association, Inc. ("Association"), which owns docks and is benefited by decisions of this Board regarding the Association's legal, nonconforming marina/community docking facility on the property known as 580 Basin Road. We understand that the fee owner of that property, Mary' S. Zupa, is currently applying, yet again, for a permit to construct a house on that property. While we intend to appear at the hearing on the application, we are offering this letter and the accompanying exhibits in advance of the hearing, in order to provide the Board with certain background facts, including copies of the many court decisions and adininistrative decisions that pre-date the current application. As this Board will see, the current application appears to be nothing more than another attempt by the Zupas to circumvent not only this Board's prior decision, but the Supreme Court and Appellate Division decisions that upheld this Board's prior decision. Not only is the new application barred by the doctrines of res judicata and collateral estoppel, but the Board lacks jurisdiction to entertain the appeal based on a decision issued yesterday by the State's highest court. HEFTER ~, ANGel, LLP COUNSELORS AT LAW Zoning Board of Appeals Page 2 of 11 Background Facts The underlying controversy involves several properties located in Paradise Point. For ease of reference, I am attaching as Exhibit A to this letter a copy of the 1963 subdivision map entitled "Map of Section One, Paradise Point at Bayview," which shows the Basin, the Canal, the Zupas' "365 Basin Road Property" (lot numbered 5 on the map) and the "580 Basin Road Property" (shown on the map as an unnumbered lot with a proposed road labeled "Future Extension" running through it). The Association is a not-for-profit corporation formed in 1961 as a homeowner's association for the Paradise Point community. The Association's community has 26 families, including the Zupas. The Association's Certificate of Incorporation expressly states that the purpose of the Association, from its inception, included maintaining the community's boating and recreational facilities, i.e., [t]o provide for the care and maintenance of the Beaches, Waters, Boat Basins, Bulkheads, Roads, Club Houses, Buildings or other structures, and other recreational facilities, to supervise recreation, sports, boating, bathing, etc., to perpetuate the standard and tone of the community; to promote health, welfare, morals, pleasures, recreation, indoor and outdoor games, etc., and to promote sociability and good fellowship for the members of the [Association]. As described in one of the court decisions discussed further below, for over forty years, the Association has operated a community docking facility in the Basin, using the 580 Basin Road Property as upland access to the docks. The original developers of the subdivision recorded "Covenants and Restrictions" that expressly recognized the need for the community to contribute to the Association's maintenance of the marina and the Basin. Although the Association has operated the marina since the 1960s, it formally acquired a number of deeded property interests from the then owners of the 580 Basin Road Property by virtue of a deed dated February 23, 1989. (Exhibit B). The Zupas' acquired the 580 Basin Road Property in 2002, subject to the rights that had already been granted to the Association in the 1989 deed. EsseK$, HEFTER ~ AngeL, LLP COUNSELORS AT IAW Zoning Board of Appeals Page 3 of 11 Among other interests, the deed conveyed to the Association all of the property shown on the 1963 subdivision map as the "Basin," and the "Canal," and all interests the owners had in the jetties protecting the Canal (one of which extends from the 580 Basin Road Property into the bay). Another key interest granted by this 1989 deed to the Association is an express easement over the entire portion of the property adjacent to the Basin. Most importantly for purposes of this Board's review of this matter, the deed expressly articulated the purposes of the easement as providing the Association with "free and unobstructed access to the Basin" including for "the construction and maintenance of ... docks, etc., as may be deemed appropriate by the [Association]," and for such other purposes that are "consistent with the [Association's] Constitution... including, but not limited to: Providing for the care and maintenance of the Beaches, Waters, Bulkheads... or other structures and other Recreation Facilities; supervising recreation, sports, boating, bathing, etc .... "(Id.) The ZBA's August 2, 2004 Decision Granting Mary S. Zupa a Conditional Variance Central to the current application is a decision of this Board, issued on August 2, 2004 on a prior application made by the Zupas. (Exhibit C). That decision granted the Zupas' application for an area variance to permit construction of a single family home on the 580 Property. The decision specified, however, that no building permit could be issued until the pre-existing nonconforming marina use of the property was either discontinued by the Association or a variance was granted allowing the pre-existing marina use to coexist with the residential use proposed by the Zupas. The ZBA found that the Zupas' 580 Property was "burdened with a pre- existing non-conforming use," and that the Association's marina was a "legal, nonconforming marina use" of the property. Thus, this Board has already granted the Zupas permission to construct a house on their property, provided that either the Association abandon its marina or the Zupas seek a variance to allow the marina to co-exist with the house. To our knowledge, the Zupas have not accepted this Board's invitation to make that variance application. ESSEK$, HEFTER & ANGEL, LLP COUNSELORS AT LAW Zoning Board of Appeals Page 4 of 11 Mary S. Zupa v. Zoning Board of Appeals and Paradise Point Association ("Zupa I"): Zupa's Action to Challenge Zoning Board Decision Upholding Legality of Association's Docks As this Board may recall, the Zupas appealed the Board's determination to the courts, in a proceeding entitled Mary S. Zupa v. Zoning Board of Appeals of the Town of $outhold and Paradise Point Association, Inc., Suffolk County Index No. 04-19605 ("Zupa I"). The Zupas specifically argued that this Board's condition for obtaining a building permit (i.e., either abandoning the marina or obtaining a variance to allow the two uses to co-exist), was improper and unauthorized. The Supreme Court Suffolk County rejected the Zupas' arguments, denied the petition, and upheld the Board's determination in an April 14, 2005 decision of the Honorable Daniel J. Loughlin. (Exhibit D). Justice Loughlin concluded that the ZBA's determination that the marina use constituted a "pre-existing nonconforming use of the property" under the Town of Southold's zoning code was rational and that the ZBA had made appropriate findings regarding the pre-existing nonconforming use and conditional area variance. The Zupas appealed Justice Loughlin's decision, but the Appellate Division agreed with Justice Loughlin, holding that the "determination of a zoning board regarding the continuation of a preexisting nonconforming use must be sustained if it is rational and is not illegal or an abuse of discretion, even if the reviewing court would have reached a different result" and that the Board's determination met those criteria. (Exhibit E). With respect to this Board's condition of requiring either an abandonment of or variance for the marina, the Appellate Division specifically held as follows: a zoning board may impose conditions when granting a variance, as long as the conditions are reasonable and are directly related to the real estate involved, without regard to the person who owns or occupies it, and to the underlying purpose of the zoning code... Based on our review of the record, the determination of the respondent Zoning Board of Appeals of the Town of Southold was rational and was not illegal or an abuse of discretion, and the condition imposed was reasonable and directly related to the use of the land and the underlying purpose of the zoning code. ESSeKS, HefTeR & ANGEL, LLP COUNSELORS AT Law Zoning Board of Appeals Page 5 of 11 In short, the decisions of this Board and the courts (Exhibits C, D, and E) both upheld the legality of the Association's docks and gave the Zupas permission to construct a home on the 580 Basin Road Property, so long as they sought a variance to co-exist with the Association's docks. Paradise Point Association v. Mary S. Zupa ("Zupa II"): Association's Action to Enjoining Zupa From Interfering With the Association's Property Rights Shortly after this Board issued its decision of August 2, 2004, the Supreme Court also resolved another action against the Zupas, entitled Paradise Point Association v. Mary S. Zupa (referred to hereinafter as "Zupa II"). That action had been commenced by the Association after the Zupas' improperly blocked the Association from access to its property interests in the 580 Basin Road Property. Zupa II resulted in a Decision in favor of the Association by then Supreme Court, Suffolk County (now Appellate Division, First Department) Justice James M. Catterson, dated October 27, 2004. That decision was unanimously upheld by a panel of the Appellate Division, Second Department 22 A.D.3d 818, 803 N.Y.S.2d 190 (2d Dep't 2005). And the New York Court of Appeals denied the Zupas request for permission to appeal to that court. Justice Catterson's decision includes a recitation of many of the key facts related to the ongoing dispute between Zupas and the Association. I am attaching a copy of the October 27, 2004 decision as Exhibit F hereto. As explained in that decision, Zupa II involved not only the 1989 deed to the Association referenced above, but also the Association's prescriptive claim to a private roadway that the Association used on the 580 Basin Road Property for approximately forty years as a turnaround and as a parking area for the docks, Basin, and jetty. After the Zupas (who had been living in the adjacent 365 Basin Road Property since 1998) acquired the burdened 580 Basin Road Property in 2002, they erected a fence to block the Association and its members from using the private roadway that had been used since 1961. The Association's claims were tried before the Hon. James M. Catterson over a five-day trial. ESSeKS, H£fTER & ANgeL, LLP COUNSELORS At LAW Zoning Board of Appeals Page 6 of 11 Justice Catterson, after hearing all the testimony, issued the October 27, 2004 decision and judgment, which awarded the Association all of the relief it requested. Specifically, Jtistice Catterson granted the Association a judgment (1) declaring the validity of the Association's deeded easement on the 580 Basin Road Property; (2) declaring that the Association had acquired a prescriptive easement over the private roadway on the property; (3) barring Mary Zupa from all claims to the jetty extending from the property; and (4) enjoining Mary Zupa from interfering with the Association's use of the deeded easement area, roadway, and jetty. The Appellate Division, Second Department upheld all of those findings and conclusions in its Decision & Order dated October 31, 2005. See Paradise Point Association, Inc. v Mary S. Zupa, supra. 22 A.D.3d 818. (See Exhibit G). The Appellate Division denied the Zupas' motion for re-argument on January 6, 2006. (See Exhibit H). The Court of Appeals refused to consider the Zupas' appeal of the Appellate Division's decision. (See Exhibit I). The Zupas refused to accept the findings of the courts in Zupa II, and their defiance of the decisions actually resulted in a judgment of contempt against Mary Zupa, sentencing her to be incarcerated if she did not purge her contempt. The original decision by Justice Catterson (which was upheld on appeal) had directed the Zupas to remove the fence that blocked the Association from its access to the roadway and also enjoined the Zupas from interfering with the Association's property rights. The Zupas refused to remove the fence and continued to maintain intimidating signs on the property threatening the Association and its agents, thereby forcing the Association to make an application of contempt. The matter was referred to the Hon. Mary M. Werner, who held a fact hearing and then issued her order dated June 8, 2006 (Exhibit J). That order found Mary Zupa in willful contempt and sentenced her to ten days incarceration in the Suffolk County Correctional Facility, though the execution of sentence was stayed for twenty-one days to give her the opportunity to purge herself of the contempt by removing the fence and intimidating signs. Mrs. Zupa's attempt to obtain a stay of that decision from the Appellate Division was denied. (Exhibit K). Finally, after four years, the Zupas removed the fence they erected in 2002 in order to avoid Mrs. Zupa's incarceration. Victor J. Zupa & Mary S. Zupa v. Paradise Point Association, et al ("Zupa III"): Zupa's Action to Challenge Association's Docks on "Riparian Rights" Theory Also shortly after this Board's prior decision, on September 10, 2004, the Zupas commenced an action against the Association (as well as against the Southold Town HEfTER & ANGEL, LLP COUNSelORS AT LAW Zoning Board of Appeals Page 7 of 11 Trustees and State of New York), raising claims regarding their alleged riparian rights of access to navigable waters in the Basin. This action is entitled Victor J. Zu£a and Mary S. Zupa v. Paradise Point Association, Inc., Board of Trustees of the Town of Southold, and The State of New York, Index No. 04-22180, and is pending before the Honorable Peter Fox Cohalan. The riparian rights action has not been conclusively resolved at this time, but it has generated orders against the Zupas by both the Supreme Court and Appellate Division. First, the Hon. Peter Fox Cohalan issued an order, dated September 29, 2005, denying the Zupas' motion for summary judgment (Exhibit L), which was affirmed by the Appellate Division on July 11, 2006. (Exhibit M). As explained in Justice Cohalan's order, the Zupas in that case are claiming title to a portion of the basin in front of their 365 Basin Road Property and are arguing that the Association's docks interfere with their riparian rights. Justice Cohalan found that the Zupas were "not entitled to exclusive ownership of a proportionate area of the Basin and have introduced no evidence that the defendant Association's use is unreasonable." That finding was based on, among other things, the facts that "the Association dock was in existence well before plaintiffs purchased their property" and that the Zupas had "constructed a dock of their own in 1998 with knowledge that they were restricted by the Town Trustees in size and proximity to their bulkhead in order to provide reasonable access to the Association members at its marina and dock." Justice Cohalan further opined that, in light of the covenants and restrictions in the Zupas' own chain of title contradicting their claims, they had not even made a prima facie showing of entitlement to summary judgment. Mary S. Zupa and Victor J. Zupa v. The Board of Trustees of the Town of SouthoM and Paradise Point Association, Inc. ("Zupa IV"): Zupa's Proceeding to Challenge Association's Dock Permits In another proceeding entitled Mary S. Zupa and Victor J. Zupa v. The Board of Trustees of the Town of Southold and Paradise Point Association, Inc., Suffolk Co. Index No. 06-02080 ("Zupa IV"), the Zupas unsuccessfully challenged two decisions by the Board of Trustees of the Town of Southold approving requests by the Association to reconstruct the docks, a project which would result in a smaller, reconfigured marina. The application made to the Board of Trustees originally proposed to reconstruct the docks "in kind," meaning that they would be reconstructed in their present configuration. The Zupas objected to that application, complaining that the current dock configuration interfered with their ability to access navigable waters from their 365 Basin Road Property. ESSEK$, HeFTER & ANgel, LLP COUNSELORS AT LAW Zoning Board of Appeals Page 8 of 11 The Board of Trustees, taking the Zupas' objections into account, approved the reconstruction but only on the condition that the docks be reconfigured. (Exhibit N). The reconfiguration would result in a more compressed dock facility that would not extend as far into the Basin and would be relocated further away from the Zupas' 365 Basin Road Property. The Zupas apparently were not satisfied with the reconfiguration (which would work to their benefit), so they brought an Article 78 proceeding against the Board of Trustees and the Association. That proceeding was submitted to another judge, the Honorable Edward D. Burke, who dismissed the proceeding in a decision dated October 11, 2006. A copy of that decision is annexed hereto as Exhibit O. Justice Burke found the Trustees' decision to be proper in all respects. In fact, Justice Burke explained how the reconfigured docks are superior to the pre-existing docks: In reviewing the application the Board requested respondent Paradise Point to offer various alternatives to its original proposal in order to allow the existing dock to better conform with the regulations for newly constructed docks. As a result the proposal for respondent Paradise Point's reconstructed dock which was ultimately approved by respondent Board provides for a single, smaller dock to be constructed in a configuration which is less intrusive upon [Zupa's] property, in particular, and the Basin, in general. Moreover, two of the three pre-existing docks are eliminated in the proposal approved by the Board. Under these circumstances, the Board's determination to grant respondent Paradise Point's application for a wetlands permit was supported by the substantial evidence, had a rational basis and was not arbitrary and capricious. Zoning Board's 2006 Interpretation On Referral From Trustees More recently, this Board issued another decision related to the Zupas' 580 Basin Road Property and the Association's docks. HEr?er & ANGel, LLP COUNSELORS At LAW Zoning Board of Appeals Page 9 of 11 As a result of the Zupas' argument that the Trustees-mandated reconfiguration of the docks would not be permitted under former section 100-241 (now Section 280-121) of the zoning code, the Trustees referred to this Board a question of town-wide interpretation of that zoning code provision in order to answer the following question: "Where a legal nonconforming, pre-existing dock/marina use is issued a wetlands permit that requires docks to be relocated in the same general area and reduced both in size and number, would compliance with those conditions cause the docks/marina to lose their legal nonconforming status under section 100-2417" This Board held a hearing on that question and issued a determination, dated September 14, 2006 (Exhibit P), which found that the reconfiguration would not violate section 280-121A. The Zupas have since challenged this Board's September 14, 2006 decision in a proceeding entitled, Mary S. Zupa and Victor J. Zupa v. Zoning Board of Appeals of the Town of Southold, The Board of Trustees of the Town of SouthoM and Paradise Point Association, Inc., Suffolk County Index No. 06-29166 ("Zupa V"). That proceeding is not yet decided. The Zupas' Current Application At the same time the Zupas are challenging this Board's September 14, 2006 decision, they are now apparently claiming that the September 14, 2006 somehow nullifies this Board's earlier August 2, 2004 decision and therefore opens the door to them obtaining a building permit without complying with the condition of the August 2, 2004 decision. Respectfully, the Zupas' argument is frivolous. Nowhere in this Board's generic, town-wide interpretation dated September 14, 2006 did this Board suggest -~ even implicitly -- that it was purporting to nullify its prior decision. Nor does anything in the decision contradict the prior decision, as the Zupas appear to suggest. On the contrary, this Board's prior decision found the Association's docks to be a legal, nonconforming use under zoning, and the September 14, 2006 decision began with the assumption that the docks were a legal, nonconforming use under zoning. Any argument that the September 14, 2006 decision "nullifies" or changes the original August 2, 2004 decision is frivolous. E$$EKS, HefTeR & ANgel, LLP COUNSELORS AT Law Zoning Board of Appeals Page 10 of 11 Res Judicata As a pure matter of law, the Zupas' application must be rejected based on this Board's prior decision, which was upheld by the Courts. A zoning board's decision is entitled to "res judicata" and "collateral estoppel" effect, which precludes applicants from making successive applications where the zoning board had previously denied applications for the same or substantially similar relief. See, e.g., Timm v. Van Buskirk, 17 A.D.3d 686, 793 N.Y.S.2d 520 (2d Dep't 2005); Kam Lee v. Zoning Bd. of Appeals, 1 A.D.3d 600, 768 N.Y.S.2d 26 (2d Dep't 2003); Freddolino v. Village of Warwick Zoning Bd. of Appeals, 192 A.D.2d 839, 596 N.Y.S.2d 490 (2d Dep't 1993); Crandell v Wigle, 148 A.D.2d 943, 539 N.Y.S.2d 184 (4th Dep't 1989); Kennedy v. Zoning Bd. of Appeals, 145 A.D.2d 490, 535 N.Y.S.2d 638 (2d Dep't 1988); Jensen v. Zoning Bd. of Appeals, 130 A.D.2d 549, 515 N.Y.S.2d 283 (2d Dep't 1987). These doctrines also preclude a zoning board from making a different interpretation on the same issue with respect to the same applicant in a subsequent application. See Waylonis v. Baum, 281 A.D.2d 636, 723 N.Y.S.2d 55 (2d Dep't 2001). The August 2, 2004 decision on the Zupas' prior application is controlling. The only thing that has "changed" in the intervening years between the August 2, 2004 decision and the current application is that the Courts have ruled against the Zupas a number of times and have conclusively established the Association's rights with respect to the 580 Basin Road Property. Since the Zupas are seeking the identical relief here that they sought in 2004 -- i.e., the same building permit based on the same plans -- the Board's 2004 decision precludes the current application from even being considered. Lack of Jurisdiction In addition to the bar of successive applications to this Board, the Board also lacks jurisdiction over this appeal because there is no "appealable" decision. Yesterday, the New York Court of Appeals issued a decision in which it explained that a zoning board's jurisdiction is limited by the State law requirement that there be a new determination of a building inspector before the Zoning Board has jurisdiction to consider an issue. See Palm Management v. Goldstein, 2007 NY Slip Op 2589 (N.Y. Court of Appeals, March 27, 2007). In that case, the building inspector had issued a new certificate of occupancy repeating some findings made in prior certificates of occupancy, and the zoning board incorrectly treated that as a "new determination." The Court of ESSeK$, HEFTER & ANGEL, LLP COUNSELORS AT LAW Zoning Board of Appeals Pagellofll Appeals annulled the zoning board's action, holding that the mere repetition of a prior decision was not a new determination that would give rise to the zoning board's jurisdiction. If anything, the circumstances here are more egregious than in Palm Management, since the building inspector here did not issue any determination at all for the Zupas to appeal. In other words, the Zupas are trying to appeal a non-decision. If the zoning board lacked jurisdiction in Palm Management to consider an actual determination simply because there was nothing "new" in that actual determination, then this Board cannot have jurisdiction to consider the Building Inspector's non-decision. The Board should therefore reject the Zupas' application as a matter of law. cc: Kieran Corcoran, Esq. (ZBA counsel) 36a Exhibit B- Plaintiff's Deed Recorded February 24, 1989 [Pages 36a-40al .0S04 T~ and no/100 ($10.90) ~- - - ' ~ ~ / ~ Ro~, ~an~ ~* arim~ Lane, ca~l, ~as~n. a~ Dr~n Xocate~ ~- ~ ~/~0~ ~ap o~ s~c~ion o.~, pava~.- ~o~n~ a~ ~a~e~," and :~.~ ~- ~ ~ the foll~ng three course~ a~ dta~n~s~ i) NO~ 85 degrees 30 - ~nuues WuSL, 90.00 feet~ 2) South 4 d~ree~ 30 ~t~ Wes~ 32~,00 38a G& ~ K; l 1~2 nj 40a 'STATE OF ~ ¥01tI~ ss.: I,~W .... o~b~g a ~~r~) DO ~ ~I of N~ Yo~k m ~ ~r ~d ~ (~a ~ ........ ~,.tn Set ~ ~~dCO~ ........................................... ~~~...~; ..................... FannNo. 104 . :~ 52a Exhibit G-Third Determination of *me ZBA, Rendered August 2, 2004 [Pages 52a - 58a] FIND/bi,OS DF FACT In.s~o~anm ~ ~ Mmy.~k 20~, Supreme Cau~ O~ion 0~ l~e Hon. James ~e~ J~U~ M tho N~ Y0~ ~ SUpreme Cou~ ~e ~ hereby me~s the Ma~ The ~ning.~ '~ A~eaJs halU a public heafipg'on ~b ~n on Mash 20, ~. Ju~e 5, ~, July 24, 20~, ~d ~gust 2% 2003,~,a[ whi~ ~ce ~m pm~. ~d upon all tha .~'mony;. ins~e~ efta p~, ~ ~h~ evi~nm, ~e Zon~g~B~rd~fin~s ths.~ll~ng d~e~ 0~ 30, 2~2 ~d aEe~tiveiy s~ vafisnoe under ~o~ ~0~4(B) and 1O0-~ ~ the Tewn ~aa to ~m~'~n~n of a .single fa~ly dwellln 2. The appli~ ~ ~ d~appm~. ~.~e Building ~ on the grounds ~ 1)~n~on ~ a ei~g~ fatuity dwelling'on a nmn~g 75,687 53a ~tque ~ and Nmu~ hem' would. ~nt~ the~nt,of.'~ a~ a~ varianm ~ ~e ~= ~ ~a pmpe~ ~s b~ an~ ~nu.;. ~ ~e used in 54a ~ ~ Nn, ~,en. M, 2upa CTM Par=et I~: applicant r. laiming Itmt ~ maflna tree is 'Illegal", The Bgan:l I~ a='vtnecl that the ~lm was ~tl~mm~ ~ thn Supreme C~u~t un pn~eduml ~anding grounds ~nly.and-not on the unciarly~ mer~ 11. The marina !s ptinoi~lly u~'liznd by the ~plt~an~'s nelghbom, manli~r~ of the u~ ~ ~ ~ ~n~ 14..U~ ~ I~1(~} ~ ~ T~ ~, miB pm~d ~ange m a ~n~ng ~ ~n only ~r ~ e~er ~e ~n~i~ use is a~ ~ey, a ~n~ ~ aoug~ ~ pe~ ~ no~ing uae ~ ~n~ ~ng w~h =~ing u~. The ~ ~ ~ 1~1(~) ~= ~ ~ m~g uae, an~i~ In ~e ~. ~ t~ mmmW ~i~ing, ~ng ~e ~ au~ pmm~s ~11 no lo~ ~ ~d unla~ a no i=ng~ ~a~ u~s a ~ I~ groined ~l~g it m ~er ~ ~e, pm~ o~s a~=~n~s ~ ~n~o~ing u~ on E and ~uld e~ar ~ da~ ~ u~ or app~ ~r a ~n~ under 8e~n 10~241 remain ~ a ~i~ ~ ~ e~ed ~ p~y, Hem, ~even ~e n~ing 55a ~ontemlalated in 8ec~on 100-241(0) ~n~u~~ 17. ~'~ p~ ~ n~ ~y b. ~ g~t ~"~da~ ~ n~ ~uM an und~JmbJe ~ange ~ ~e ~m~ d the ~h~ bemuse cl. The benetit go~Jght by the appllaant ~annot ~ aohle~ by a~er f~le ~ other ~an anam; ve~n~. In o~r~ ~n~a ~ouse ~n t~e ~e~. · , app~nt ~ms, v~ ~ ~e ~ a~ ~ ~ phial or en~mnma~ mndWon8 in ~e nagh~. Depart ~ ~1 ~n~on and the T~n Tms~. The ~1 is ~uat~ Vine ~ ~e a~ 'A~s: Mem~ OINa (Ch~oman}~ :G~hfln~r, ~d Toxin. R~H D;OL~.~AIRWO~ R~ D. Ol{v~. Ok&lrwom~z · . C,m~ ~. ~ hmm Dhlzio, ~. 7.ONING BOA.g,D Ol~ al'l'il, AJ~ TOWN OF $OL~'~OLD Sep. 19 ~ E~3:431:1'1 P1 FINDINGS, DEUBEI~'I1ON$, AND DETERMINATION MEETING DATE:. ~ File ~ 5g14 * BO~F TOWN ~E~, T~I~ ~ ~ ~1~ ~ ~ ~q4~ (~ 1~241) i~ ~ a ~s pe~ ~ mq~ d~ks a~ and ~ ~ ~ s~e and num~, ~u~ ~ ~ ~ ~{~ I ON'. T~ ~ing ~ ~ ~le ~ v~ted t~ p~ under ~d~ ~ ~ll a~l~on and de~l~ ~a~ ~ ~i~ fa~ ~r ~e ~ II ~ ~a ~'s L~ ~ ~o~, ~o~ ~ ~. DA~ DP ~ H~I~G: The ~ ,~ll~n ~ ~ ~, 2~, e~ ~ ~ ~ and ~1 ~n~ w~ ~ fifl~ ~ ~ fa~ ~ ~ ~e and ml~ ~e ~1~ ~ ~ ~els r~ an a~p{l~6~ f~ ~ ~ d Tmste~ ~uant ~ W T~ ~e 6e~lo~ 1~I(D) [~ ~n 28~46(D)~ ~ an ~E ~1~8' I~SU~E ~ PERM.S FOR ~ ~ES N~ REQUIRE BUILDIN~ PER~ ~. ~ A ~LT, ~E~ 18 NO MEC~ISM FO~ THE ~ILDIN~ IN~E~OR ~ A~ ~ND ~US NO A~ RIG~ ~ ~E ~. TH~, AN ~PLI~ ~S NO P~CEDURE TO OBTNN T~ A~ TO THE ~E~ION B~OW T~T ~E ~U~ES BEEI~E Wl~ ~CUR F~M ~IME ?O WHERE A LEGAL NONCONFORMING, PRE-EXIS'rINO DOCK/MARINA UaE la~JED A WETLAN~ PERMIT THAT REQUIRES DOCKS TO BE RELOCATED IN THE ,~IE GENERAL AP. EA AND REDUCED BOTH IN SlZ~ AN[:) NUMBER, WOULD COMI=LJANCE WITH THO.~i CONDITIONS CAUSE THE DOCK~MARINA TO LOSE THEIR I.EGAL NONCONFORMING STATUS UNDER SECTION 'I00-LMI ." F~X HO. : 631-078 ~'-55~1 Sep. 19 ~ ~:43AM the Beard ~ TJu~t~lm dmt~l M~y 12, 2006 from mi attorney8 for the Pamrlise pol~ Tile Z~nlpg Boers of Appaa~ hek~ & public .",e~ng on July 27, L~Oe at whieh time written and oral evidence ~re presented. Be~ upon ali teMJmeny, do~umentalJon. and ~er evidence, tflg Zoning Boerd ma~e$ the f~llOWing cletermiflauon. JURIgDICI'ION OF Z/3NJ~G BOARD Section 260,1460 aut~ria~ U,a Zaning Board ~, amo~g oU~er t~inga, 'detem~ne the meaning ~ any lar~,~n in this ~hapteP "on request of any Town c~k:~r, i~a~ or agenc),." FINDINGS OF FA~'T/DETERMINA TION 1. The Town Trustees have requimtgd the,Zoning Board's intarpm',ation of the nam eonfomlblg Lmm provlsior~ of the C. aade bm;au~ they ha~ luu~d a permit to a non. ~nf~rming boat basin that would require a m~a'lfig~atia~ of the exisdng d~ rather men allow an in kind repairlreple~emenL The Tn~le~ regard the mee~gum~ion aa mo~e ~e~Jrablo sln~e it brings the d~ Ir~ greater ¢oafe,-mlty wib~ Trustee requirements. 1'ne change was instituted at.t~e Trustees' r~quea~t and was not sought by the e, opacan~ 2. ~ 07-28 or the Town Code s~ta Forth the 8tendards for Is~Jmx:e ~ Permits by the TOW~ Tn,~toee as fOlioWs: 'The .T. msteea~ may adopt · reaolu~on dlnFeting the i~suance ~ a permit to perfo.~n O~4,11U~ Ipp~iid for t~dy if it dstermlrtea~at such oloeraUons will riot saabstantiaJly: A, Adversely affe~ Ne ~etlanda of the B. ~ ~mage ~m e~ ~id~, ~ liRa~n. C. ~ ~l~a~ In~ ~ ~ ~h ~r ~ ~ ~ T~n. O, ~e~ a~ ~, ~he~mh ~ ~r ~n~al mad~ ~, mqua~ ~ a~ ~ or ~e ~mi h~ ~. F. ~e~ aff~ ~v~n ~ ~1 We~ or ~ ~ ~w of T~. Q. ~a~e ~e ~e ~ a~ ~annel ~ ~a ~N~ ~m~t ~ flow ~ any w~. ~T~. J. ~w~[Y ~ ~ a~be~ vai~e ~ ~ ~fl~d and ~a~ .N~peal Ne. ~t4 - l~lterlw'etaUa~ (ToWn Tru~lee.) P,~ 03 8. aeallan 280-121A ~ the Town Cadre proVidM In pe~dnant pa~ e.~Ming ~ the efhmOv~ date of t~s d~apfl~' or au~ by a bui~ling permit t~ued prl~ ~emt~, mgardle~e af change of title, poese~aie~ or oc. aupanc'y or fight thlreof, ~ay be c~nued Irgteflflitef¥, except ~ilt such building ar use: of ~i~ ~naptar, nor shall ~y red.mai eviae~ce of such use be Increased by any ~ ,d,~eJl~.# ~ On rn~ion offered by Ct~rwoman Ohm, ~o~ndad by IVm'nber RE~OLVED. ~at the re-allgnme,n~ of ~ baeir~n d'a~J~$ as racluired C,y the Tru~teee does no~ con~ibAe a che~ge that would be prohibited under Section Vote af ~e Board: Ayes: Membera O;va (Chalrv~-nim), Goehdnger ~d WeMman. (~Mm ~o ~ ~ ~ ~t.) ~ ~u~on ~a d~ty ~d (3~). ~ D. Oli~ ~6 A~ for FBIng 7a Decision of Loughlin, J., Dated April 14, 2005 [Pages 7a-14a] i¥IE M O ltA N'D U M COURT, SU'E~OLK COUNTY X 1Vi~2~Y S. ZUPA, : : Petition=, : : for aju~ p~to Ardcle 78 df, he : Civil Practic: Law and Kui~s, : : Z03i]NG BOARD OP AFEF_hLS O1' TH~ TOV~: OF SOU'fi/OLD ~nd PAk&DlSE POINT : A~S0CIATI01~, INC. : X LA.R. PA_~T 12 By:. Loushl~ Dat~: April I'~ ,2005 Index No. 04:-19505 Mot. S~m.. # 002 - CDL~P~Tltl P,s~n Date: 8-31-04 3..djom:n~d: 1-6-05 WI~ B1LESm.~:m. GOP,.DON & OF. ASA, P.C. Attomcys fur 13015 Mair~ Road, PO Box 1424 Matlima~ 'KY 11952 31~t ri-i, ~ ~ .S'J.'itlN, LUNDBILKG, Attorneys for P,z~oadcm Board 456 Gri~ng Avmme, PO Box 389 Riv~ead, ~ 11901 ESx~.z~ l-l~'~.~. & ANGEL Attm~s f~- Rmpo~E~mt Paradise Point 10B Ea~ Mai~ S~m~t~ PO Box 279 P-,.iverh~d, NY 11901 aa . Zv~ v ZBA, To, am ef 5outhald Ind~ No. 04-19605 l~ag~ No. 2 In O~tobez, 2002, pctkioner who purebred the p, ~ ~. ~ ~1~ ~ d~ p~a applioafi~ for · at ~p~'s ~mt ~e ~ ~ of a ~;,~: H~ c~ Following public hem'bags held on the applicatio~ im March 20, 2003, June 5. 200B, Inly 24, 2005 and A~guat 21, 200B, ;=spondent Board, in a det='~;,,,6o~, dared September 30, 20~3, denied p=tition=r's applicmio~, vitlumt pre}~.dic= to ~n~wal VlXm the teaolution of two pl:m~T ac~io~ pmding ~ petitione: actio~ so-~t a der, larmion that 1~ paralac Peint A.vociation, Inc. possem~cl bo~ a valid ,md e~ffer~ble easement o~er aha at,oas the subject pa.reel by vi, L~e o~ ~ lg89 ~ and also by pr~sc~onJ The Assoniahon also aought an injun°ti°~ e~*i"i"~l~is' 7'up~ fr°m imwxreri~ g operalion ofth~ mmim~ on thc subject ~ The action is entitled Parrdise Poi~.4.s'~clm'/on, Inc. a,~ziar~ filed u~ler Suffolk Cotmty !.udex lqo. 02-22~01. ~ Thc ~ is entitied, ~'K~or Y. Zup'a, Mmy E. ?,upa ami Yam~ Mtller Poi~t,L~so~ztion, Inc.. and is filed tmd=r Suffolk Cotmly Index No. 02-25843. ~ Thc first Article ?g procccding is a~tifi~dMary $. Zupa.agafn,~ Town of ,~oudmkt Zo~i~, .~oard of ,4ppeals a~d Par,,dise poi~zl.4ssoc~,~r~, .~c. and is ~ed ~md~r Suffolk ~oonty lndax No. Zupa v ZBA, Town of Southold lnd~ ~%..04-19605 Page 31o. 3 Upon ~,~d, thc ~Board of App~la, in a d~on, datcci D~c~-nher 4, 2003, aoacludedthat Ms. Zup~'s ~ppeal f, um ~ Buildin§ Ina'pactor's tt~ni.l ofh~r application for a lmildiagp~n~nlt was barced by the doalzin~ of r~s judicata and collat~al ~mppel as a ~ of the Board's ~a'mi~tian of aa earlicr appeal bmugl~ by .~,~,'s and Halca lViill~, aa contn~t v=ndo~ of the subj~-t parcel in 1995. Th~ ]vl'ill~ h~rt st~al~l to th~ Board from t~ Blll'ldillg Inspc~au's 6cnial ofthoir own X~Clu~st for a buildingpc~nit on tho subjsat paxcel b~cauac to do so world slinw two lainoipal us~ o~ tho g~p~y (a non ~r~-,.~i,,~ prong ~ and a I~. Zupa coma~aned a ~ond Artinlc 78 proccc6iag~ ~-h.~nging dat.~.m,;,,.tion, 'l-~'~.Dccemhcr 4, 2003 and the Court, by ~d~r, clate~l May 6, 2004 that tl~ do=trines of ros judi~.~t, ami Collat~al eatopp~] w~rc~ot applkable sinac Ma. Zupa was not a party to the 19~$ applicalJrm by th~ l~l~ll~s and the record did not rdl~t thc a.nist~a~ of in thc ~ b~.'wcan thc issuance of thc Boast's dcmrmlnatian h D~, ~03 ~ a~ ~ To~ Mw ~268 ~ ~ ~d not ~ ~ "~i~ ~ ~ ~ ~ ~ oi~t j~ ~ p~f h ~o A~ ~ for ~e ~d ~ D~t Upon rccimsidcralion of Ma, Z~pa's appeal in ac~ordaanc with lnsllce Cat~rson's judgment o£May 6, 2004, r~spondent Boa..d i~su~i a ~ ~e~on, ~ted ~ ~ 1004, ' Tho.s~on6 Arti~l~ 78 proa~,,ding ii' aniiIl~ Mary £ Zupa against 2aning ~onrd of App~ds of th~ Tov, m of $outhold and Paradtss Point Association, Inc. and is ~flcd andar Su/~olk Co~mty I.~d~,.No. 03-29553. Zup~ v ZBA, Town of Southo]d Index No. 04-19605 Page No. 4 p~m~i: io M~. Zupa trpon ~ith~lh~ dis=onfinuance of ~he nouconfom/ng marina as~ of i~opml'y or h~r arraying, use variance to p~'m/t thc ~nfinuerl usc of lb= prop=ny ~s co~vac'fion with a r~sidential ~. On or about A%mmt 24, 2004. petitioner c~mr~.cl the immmt Article 71 Woe~ding ~l~.n~ngiai respondent Btmrd% dotnmdnation, dated August 2, 2004, as irmfimml, unsaplmrted tU substanlial ovid:nee, arbitmay and capfi~io~ amd an alms~ ot'dis:r~ion. of appeala, judi-ial r~iew is !im!tzd ~ a~canaiting wl~th~ the aation x~ras illel~l, ~rbiirary and ~'apri~o~, or an alms¢ o/dis~fio~ t~ additi~, a zonhg board% inmrpmation ofita zoning ardinatw, e is ~ntiflexl W a Iv~az d=al of d~fea~n~% and will no~ be overmrn~ }U a :oust mfl~ ~ of$o.~.h~mja'on, 7 AD3d 710, 776 NYS2d g20 [2004]). It is v~ll s~d ~ the soop~ of judicial to an ~r.m~on ofwh~h~'it has aratio~s] basis and/s support~l by subs~al evidence (Ar~' V~z~,~ ~ p ~adI, 21 law (Smith ~ l~om~d of Ai~pazts of the T~n ~t~ 20t ~2d 674, ~9 ~d 912 [1994]). of Yogin, ~ 8 ~2d 417, 656 ~26 3 B [199~). -' Tho Co{~ of 'the Town of Soutlmld de. finm a l~gal nonconformi'ag us= as a ~a,', whtther of a building, sign ~r ~ 6flanrt, or c ombinati~n 0f thesa, l-g~lly ~sting o- the =ff,'ctiw ~ of th= zmaiag ~od~ which do~ ~ot canfonn ~ the pms~n us,, :~iion~ of ih. district ia which In ils findings thc Boazd spedi=i=ally norad thai k had previmmly ~onelu~6 in &'hying the 1995 Miller appl/ca'don ~nat th= marina us= of th=property mnsfimlefl a ta't~ting tla v ~ Town of Southold imdax No. 04-196{)5 No. 5 While ~ ~ of relief by a zo.l-S board of apptmls do~s n~ ~ ~ n~ie~.t ~m ~ ~ ~ Bo~d of ~g & Ap~nI.e of ~ T~ of ~ 2~ ~ 8~, 1~ ~ 7~ [1953]; S~ ~o, ~Wnno v S~r, 131 ~ 679, 516 ~ 758,Dgg~, ~ d~ ~A.~ ~ to ~ (~ v Bo~ of ~ & ~ ~ d~ ~ ~ of B~ ~, 280 ~ 792, 1 I2 ~2d 9~ ~52]). ~e B~ +~"" on~C.~ im ~or ~gApp~ of~ r~ ofSo~p~ 5 ~3d ~9, Wi ~Bid 188 ~0~] ~ d~ 3 ~d ~4, 784 ~S2~ I~, 202 ~d ~4, · e choi~ ~de by ~c ~n~g b~ ~ ~c ~ ~ ~ ~ ~om f~ ~oi~ Whmov~r a nonconforming use afa building or pre-iaea im be~n ...changed to a codOxming usc, anyrhi,g in tiffs Axt~l~ ~o tho conmey notwithstanding, the non- eozdo~ u~e of stab building or p~ouxiara ahall no lonl~r bep=mi~d uut~ss a variance therdor sh~ll haw bc~n gmnt~d by ~e Board of Apl~als. 12a Zupa v ZBA, Town of 8outbold Iuclcx No, 04-19605 No. 6 In it~ findings, thc Board acknowledged that the subject ~,,,,y~-ty p~soa~, m~ unusual ~i~'umstance s/ncc thc noncon/iuming ~ is owncd m~d c~ olled by r~spondcnt Assoc/ation and not thc title owner of thc ~ uy=ty a~t thc two ~rpear ~o bc in .~'~,~.ly opposcd to ~r./stc~cc. N~czthe. less, respondent Board/nm~ the aforemcnficmed s~tion as mandating 'l:h~t petitioner either dis~mtipne the m.~in~ use of mc pmpezty cz ob~ai~ a usc variance ~.~dtting her m~dnta/n two prhdpa] ~ of thc prop~y, that is, a rea/den/iai us~ 'usc. T~,,-.,w.h as a ]ooal zoning boerd ~s uutrosted 'wi~ a rcesonabio measure ofdisc~ion the int~pretatlon of i~ .own otdimmces and li~ judicial fimc~on in r~wiow/ng the bozrd's d~iaion is e ]imfled onc~ a board's determb,6on shouM not be c~st asicl~ unless m,~c ks a showing of ill~lhy, arMU,;..*ss or an abus~ of discretion (R/chard/hu/ys~n Contr. .Zoning Boar~ Of ARP~ds of th,, Town ofMeun~ P/.ea~m~ 255AD2d 445, 680 NYS2d [1998] ~ng Boeld~ v Kays~r, 112 AD2d ?~?. 491 ~ 438 [1985]; ~e~ a/so, Tmi,~t of H~mt/~oto~ v ~ Tom~ C~I/e~e Rral/~e~y Trun~ 293 AD2~ 467. 740 NYS~d 107 [2002]). The Co~n ~nuz ~n~h,~ thet respondent Boer% cl~m~i~n ~ p~-ficn~r wee requi~d ~o ob~.h~ a usc vu~.r-~ or a ~iscc~,~e of tim n~-;., usc ofFrop~ty of~e prop,='cy l~fom a b,,;lm.~ p~...:t ~or thc pmpcr~y r~mld b~ issumi for the comsu u~io~ of a zcsidcucc on thc pro!o~~ ]md a mtionsJ basis. P=GLion= aho challenges thc porl/on o~mspo~dent Board's dem0-m;,~on rc~olv/ng p=tit/on~'s appeal fro~ thc Building Inspector's det~...~;,~lion that a b~//ng l:~,...'t could not bc ismmd to p.~JG,m= becmme the subjec: parcul is subsmadard in t~,.- notr~c%~i,,.,d madcr thc zon/ng code by ~ issuencc of an erce retrace. P=tifioncr th.~ no arm varianr~ is ncc~sa.,-y since t~c m~bjc~t~ con~t~,s a lot un,er thc Town Co~. In its flnclin~s tl~ Board noted tba~ it did not fim:l the evident- in thc record .with rcl~rd to thc status ofp~tiGoner~s Parco1 aa a lcgal m,~idential building lot tn pc'nma~vc a~ thc pcfition=, Thc Bared concluded, how~cr, that auch issue ~ic byth~ pefiti~r'; alternative request for an eme vnri~ce. Looai zoning boazd~ haw broad &~-c~ .tlon in consid~ing applications fl~r variances tim jugiciifl function in reviewing such dccisions is a limited c%. ~ouns may set aside a zoning . de~, mm~lion only wh=c th~ i~co~ revcah m~t thc board acted illc~lly or arbJtmri~, or ab~e~ its d~, c; ~eet fl n-~e~ sucemnb~ ~ the ~-n~r~l;~i conmmnity ~,sem'~. A dctm'~.tion of a zoning board should be sustained on judicial r~ricw if it has a rational basis and is supported by sub~Um~al evidence (Peeoraro 'p .Bo~ of A!~m~ls of t~ l'o~n of. H~nq,~ad, 2 NY3d 60~, 7~I NYS2d 2~ [2004]), The consideration of'subst~iial cvidencc" is limitcd to determi~in~ '~h=thcr th~ rcco~ coz~i,~ st~icicnt cvklence to suppor~ fac rationality of thc ['l~spondmt's] de:~mation" ($asso v Osgood, 86 NY2d 374, 533 NYS2d 13a Zupa v ZBA~ Town o? Sou~hold I~d~x No, 04-19605 Page No. 7 d~ ~ b~ ~ (Yo~on v ~ge of ~t~ ~eh, 2~ ~2d335, 663 ~S2d 663 [199~; ~ ~o, ~e v T~n of P~ford Zon~g ~o=~ ~A~, 306 ~2d 898, 7~ ~S2d 7t4 ~O~];~a v B~, ~00 ~ 665, 75~ o~ a ~ on a lot ~ ~ 1~ ~ ~ re~ 80,0~ ~ f~t lot ~ p~t. Th~ Corot conclud~ that petificam~ has misconstrued respom:l~ Bx~rd:s 7m its decision, it~ Board stat~l, '~V30LVED, ...the Board grants the area varisr~= sought'by th~ applicant to p~mit consu~ciion of a sinElm fsmily honm o~ k'ss that Isis] 80,000 SClUm~ fe~t with ~ co~plia~c~ with all smba~k nnlalr ~i~ on oondifio~ how~, thax no boilding permit be issued until the nonconfur,,,ing malina us~is r~mnved or a ['aS"] vax*imco ia g~gd to permit th~ cantinu~ us~ in conjun~on with a residemial use. Thua, thc . condilion d~'ly has i~ I~m~is in thc Board's d~nial of imitioner'; aggca~ of the Building luspcct~' s rc~x~al to issue petitioner a building p--, ~-Mt on lh~ basis thnt- t~e pI'opo~d constitutes a knp,~mism'blc s~cond u..~ of thc propertY. The oo~diiien'does not relate W thc re'ca varia~ which is ctimmzd solely to the dimensional inadequacic~ ofpetitian~'s parcel. restriction is thus aot au inappropri~ ~oadiflon imposed upon thc grant of an area rather it is a con~afion cd the cod~ restriotions upon the use of the property. Zupa v ZBA, Town o£Southold tm dc~x No. 04-19605 ?agt~ No. 8 Under:the ~rcrnrn~'~, th~Bom'd'a dm~m~m~tio,~ nmm be uph~lcl a~ it ia rational and g7 NY2t1344, 639 NYS2d 302 [1996] r~h~ati~g d~ g7 NY2d 1056, 644 NY~d 14g). Accordingly, th~ p~ifio,~ is dmi~d ~ lh~ proof-ding is cllm4ssefl. $¢~ ~t gn Noti~. Matter ofZupa v Zoning Bal. of Appeals of Town of Southold (2006 NYslipop 05648) Page 1 of 2 Matter of Zupa v Zoning Bd. of Appeals of Town of Southoid 2006 NYSlipOp 05648 July 11, 2006 Appellate Division, Second DeparUaent Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. As corrected through Wednesday, September 20, 2006 In the Matter of Mary S. Zupa, Appellant, V Zoning Board of Appeals of Town of Southold et al., Respondents. --[*il In a proceeding pursnan~t to CPLR article 78 to review a deteimination of the respondent Zoning Board of Appeals of the Town of Southold dated August 2, 2004, which, inter alia, granted the petitioners' application for an area variance to permit construction of a single-family home on the condition that no building permit be issued until a nonconforming marina use is discontinued or a variance is granted permitting the marina use in conjunction with the residantial use, the petitioner appeals from a judgment of the Supreme Court, Suffolk County (Loughlin, J.), entered May 26, 2005, which denied the petition, confnmaed the determination, and dismissed the proceeding. Ordered that the judgment is affirmed, with one bill of costs. When reviewing a determination ora zoning board, a court is limited to determining whether the zoning board's action is illegal, arbitrary, or an abuse of discretion (see Matter oflfrah v Utschig, 98 NY2d 304, 308 [2002]). The determination ofa zomg board regarding the continuation of a preexisting nonconforming use must be sustained if it is rational and is not illegal or an abuse of [*2]discretion, even if the reviewing court would have reached a different result (see Matter of P.M.S. Assets v Zoning Bd. of Appeals of Vil. of Pleasantville, 98 NY2d 683, 685 [2002]). Moreover, a zoning board may impose conditions when granting a variance, as long as the conditions are reasonable and are directly related to the real estate involved, without regard to the person who owns or h~'~.ltv~'w ermrt~ ~t~t~ nv.n.~/re, nnrter/3d~erie.q/2006/2006 0564g.hlm i0/12/2006 Matter of Zupa v' Zoniag Bd. of Appeals of Town of Southold (2006 NYSlipOp 05648) /~age 2 ~of2 occupies it, and to the underlying purpose of the zoning code (see Matter of St. Onge v Donovan, 71 NY2d 507, 515 [ 1988]; Matter of Finger v Levenson, 163 AD2d 477 [ 1990]). Based on our review of the record, the determination of the respondent Zoning Board of Appeals of the Town of Southold was rational and was not illegal or an abuse of discretion, and the condition imposed was reasonable and directly related to the use of the land and the underlying purpose of the zoning code. Accordingly, the Supreme Court properly denied the petition, confirmed the determination, and dismissed the proceeding. We do not pass on the issue of the legality of a certain nonconforming marina, the subject of which is being litigated in an action entitled Zupa v Paradise Point Assn., pending in the Supreme Court, Suffolk County, under index No. 25843/02. Miller, J.P., Adams, Goldstein and Covello, JJ., concur. htm:l/www.courts.smte.nv.us/reoorter/3dseries/2006/2006_O5648.htm 10/12/2006 3a Decimon and Judgment of Cattereon, J., Entered October 29, 2004, Appealed From [Pages 3a - 9al IvI~MOKANDUM DRCISION ~TDE~ NO. 22401/02 SUPK]BIM~ COUP. T- STATE OF NEW YORK IAS PART X/LK'v~II ~ COUNTY ' ~ERESENT: Honorsble JAMES M. CATTI~;ON MOTION NO. Memorandum Trial D~sion PARADISE POINT ASSOCIATION, INC., MARY s. ZUPA, x x PLAINTIFF'S ATTORNEy 214 Roanoke Av~ P.O. Bo:/757 .Rive~a~d, N.y. 11901 DEFENDANT,S ATTORNEY 13015 M,~ Road ~.0. B~ 1424 ~t~ N.Y. 11~52 UPON DUE DI~r.mERATiON AND CONSIDERATION BY THE COUKT of th~ foregoing, and the bench trial hold in thin Court on Febnmry 11, 2004-February 26, 2004 tho trial is docided ~s followm ~ ORDERED that it is declared th,,* the phintiffposseases a valid and existing easement over and across the z~bjeet premises owned by the defendant as described in the 1989 deed to · plaintiff, and the defendant is enjoined bom interfering with the plaintiff's me end possession of the easement; it is further ORDERED that it is declared that phintiffhas a valid and existing prescriptive easement over and across the private roadway on the subject promises owned by the defendant, rnn,~ng /rom the wesm-n termimm of Basin Road in a general northwest~ty direction to the plaintiff's deeded e~ement area and to the jetty located at the end ofth~ deeded easement area which promades into Southold Bay;, and it is further ORDF./~D that th~ defend-hr must remove the £enoe blo-.lri~g ~e m~ to ~t pfiva{e ~Y c~t fi~ O~E~D ~t ~ def~t md h~ ~ ~ b~ ~m ~ o]~im to ~ ~c or ~t~ ~J~ · ' " A b~ fono ~soci~ ~e 1951 for ~ b~t of~e p~ilse Po~t ~.,,~mi~. M~b~ of~ Po~ To~ of S~ol~ C~ of S~o~. Po~t ~ ~ob~ 13, 1989, d~f~ ~ ofB~ ~ (~ ~e ~ bo~e of ~c d~i'~t's ~), i~g ~ ~o~li~e of ~ bo~ ofw~ w~ bo~ (~o ~o~ ~ ~ ~out 1970, a je~ ~ ~ Fio~ ~to To~ ~or a ~ ~ of w~t is now ~ ~sociafi~'s Po~t Co~ 1989, by~e ~ove ~i~t~in~ by ~ ~soc~on ~cl~vely. 'D~f~n~,~t rccdved titl~ by deed f~n Cban~ D. ~, ~ Si~ning ~a ~ of~c O~ H~b=~ ~mt~t ofT~ A~e~t ~ ~ of A~ 16, 1999, d~ w~ ~d~ ~ ~e O~ce of~ Cl=k of S~o~ Co~ ~ A~ 23, 2002. ~ d=f~t ~d h= h~b~ how~=, b=c~ ~ m ~= P~c Point h~= m~b~ of ~ ~soci~on ~ 199~. ~e ~tors w~ co~d ~e e~t w~e ~e ~edec~so~ ~ ~e to ~e who co~ed ~ p~ ovg w~ ~e ~ i~ loc~ to ~ def~t. 2 Sa lot was created by subdivision as shown on a subdivision map filed in 1963 :, Paradise Point Corporation. All of the. principals of the Paradise Point · qince prior to 1961, a _p!ivate roadwayhas ill ilf~le !nm~i~ from the w~t~Ill t~a ,',,triLls of Basin Road in a general a to the dcaded easement area and to thc j=tty located at th~ end of that 2002 when the defendant arected a fence across the roadway, i this private roadway for vehicular and pedeslxian access to __ 8outhold Bay, and the jetty. The A~sociation used the private roadwayin the use of the Basin, the Canal and the je~, as a turning area over Basin Road; as access and use by contractors conducting dredging ; and for general x~a~ional pmposas. 1970 to 2002, the Association m,*~t~i,,,,xl and improved the lnivate , at its sole cost and expense. During the period from at least 1988 to 2002, the adjacent to the private roadway stml'ing "Paradise Poix~ Private No Trespassing, Residents Only." In addition, the cost of dred~ng the Basin was ~y thc Association almost e0cclusively for decades. In May of 2002, thc Association scat a who was a shareholder of Paradise of Southold, Inc., which owned a two in the property, requesting p~',,,ia.ion to use the roadway for dredging work to ' the Town of Southold's requirements for a dred~ng permit, John Si,ming, while a 'Paradise of Southold. Inc., was the President of thc Association fi~n 1985 to and in his dual capacity he granted pa, ,,,i.sien to the Association to usc the roadway over ' to facilitate the Association's dredging activities. In 2002, the defendant obstructed the Association's use of the roadway and prevented -,access and passage over that private roadway by member~ of the Aasociafio~ This action The AasociatiOll'S first cause of actioll la to d6t~a ,,,ina the Clalm~ Of the pal~d~s 'with ,ragard to the deeded easement. The defendant argues *h~ the southerly or scawa~d sid~ ofth~ d~-_,ded easement cannot be determln~ by the deed language alone and that the Association has not proven that the deeded easement bunlens the defcadant's property without a proper metes and bounds desoripfio~. The Court eradits the testimony of the Aasociation's ~zritncases anti.the. deed that was submitted into evidence with regard to the deeded cas~aent. What is indispmablc is that by this emsemcat, the parties to the d~l intended to give the Aasovlat4on "fi'ce ann unobsmieted access" (via foot traffic) to the Basi~ CanaL bu~rheads, c~ibs, jetties, docks, em. Also elea~ is the language of the deed in evidence that specified that the southerly boundary of the easement on the Canal and Basin side is the shoreline and the noxthcrlybotmdary on the Southolrl Bay side is the ordinay high water mark. The deed did not relate merely to the southerly shoreline or the northerly ordinary high watermark then existing but to such line wherever it might thereafter be located. Matter of the CiW of New York [West Tenth ~t.], 267 N.Y. 212, 221 (1935). ffthe defendant's contention were co~reet, then the words in "in a westerly, nm'thwestcrly and northerly direction along the shore of said Basin and Canal as it 3 winds and tums.., to the or~,ry high water mark of Town Harbor... thence in an essterly direction along the ordinary high water mark of Town Harbor..." would be surplusage, and the parties would have nm this 1/ne solely by metes and bonnds, Id. ~'ku~h*. ~uore, contrary to the defena.-t's ~amen~ no survey was necesasry to further d~fine the easement (as ref~d to in tho deed) because "physical monum~mts when denominated in a deed shall pr~ail over those shown on a survey." Id. The deed manifests an intention to grant a right 0fpassage along the sontherly shoreline wherever located so long as it meets the general direcfiona! sweep of the deed language to effectuate the purpose for which the easement was created. Lewis v. Yotm~. 92 lq.¥.2d 443,453-454, 682 N.Y..q.2d 657, 663 (1998). Thus, this Court finds that the Association has a valid and existing easement over and across the subject premises owned by tho def~,nt as described in the 1989 deed and the defendant is enjoined from interfering with the Association's use and possession of the easement. The second cause of action is for a prescriptive easement across the private roadway on the defen~,nt's p,openy ~,nn{ng from the western temfinus of Basin Rolui in a general northwesterly direction to the Association's deeded easement ama and to the jetty which pro~rudes into Southold Bay. The defemrlant ml~fl~ that because the members of the Paradise Point Corporation and subsequent owns, rs of the defimdant's p~perty we~ all officers of the Associatio~ no such prescriptive easement could have been created. The defender, however, cites no support whatsoever for her con~tlon that these individ-.h who wore two hats (as all officer in the Association ~nd as an owner of the proper~y) effectively precluded the · Association' s p~'~scriptive easemellt righIs as created by those officers of the Association who were not also-owners of the det'e~a~t's propeat-y. Indeed, def~a~t's argummat would necessarily ~esult in a b~.ach of fidneinry du~ to the Association by those officers in the Association msi~t.l.in~ dual and inconsistent roles. Therefore, the Cou~t fin& defe~d..t's enntemien unten.hle. In order to establish a prescriptive ensemcnt, the proponent of the casement must prove by cles~ and convincing evidence that the'use has been adverse, opm and notorious, continuous and ~mlnterrupted for the prescriptive period. ~ 251 A.D.2d 449, 674 N.Y.S.2d 409, 410 (2d Dept. 1998). The stamtorypcriod is fifteen years for a use that COrnm~ll~ prior to 1963 and ten yeas for a use th.t COmm~Eed i~l~r~'d~. City of Tonaw~nfia v. ,~-lticott Creek ~ea'~own=s Association. tnc..,et at.. 86 A.D.2d 118, 121,449 N.Y.S.2d 116, 119 (4th Dept. 1982). Where the easement bas been shown to be open, notorious, continuous and ondisputed, it is presumed that tho usc was hostile, mad thc burc~ shi~s to thc opponent to show that the use was permi,~ive. ~ 251 A.D.2d at 449, 674 N.Y.S.2d at 410. It~ however, the opponent of the easement establiehes tlmt the relationship. between the user and landowner is one of cooperation and ndghhorly soeornr~odation, the presumption is lost and the proponent of the easement must show that the use was under el,ir~ of right and advers~ to the interests ofthe landowner. McNeill v. Shutts. Sr. et al.. 258 A.D.2d 695, 696, 685 N.Y.S.2d 318 (4th Dept. 1999). Thc Court credit~ the testimony of the Association' s wimesses and that of the defendant's 4 fact witnesses such as John Sinning. All of the fact witnesses testified to their use es well au their parents' (many of whom were officers in the Aasodation) and children's use of this private roadway. They used this roadway for recr~tion, to reach the jetty snd watcr~vay where many had boats or to swim, for approximately forty years all together, from the inc~pfibn of the Association until the defendant erred a fence in 2002. In particular, thc tealimony of RobOt Scalia (hereinat~er refon-ed to as "Scalia") demousirated that the Association has met its burden of proving the cieme~ts of a prescriptive easement. Sc,Ils testified that he became an officer in the Association in the 1970's until 191/3, and that he was a member before and after that time frame. He stated that the Association maint~in~A the ~n~i~ roadway in dispute from the end of Basin Road by snow plowing it and m,ld~ any re'pairs. Moreover, he and many others testified tha~ the Association an'anged and paid3 ~or the Canal to be dredged every one to three years, ~aa that such dr~§ activ/ty-ti~i~ed the roadway in issue to move the cranes and/or ia'acks to the area to be dredged which was at the end of this mad. The tracks would use the road to ~meve the spoils as well. This occtured at least ten to twelve times since 19~I alone, mad stm'ted in the early 1950's. At no time dung Scalia's memhemh/p in the Assodation did he or anyone ehe to his knowledge ever ask for permission to use the road. Indeed, all of the witnesses testified that no penulasion was ever sought from the owner(s) of the property. In fact, Scalia believed, as did all of the Association' s fact witnesses, that the private roadway in question was "our read," that he and all the homeowners had a "right of passage over it." Bven those witnesses who had acquired an interest in the ownership of the property in issue had never request~l permission to use the road for recreational or d.,-~ging aciivities au officers of the Aasociation prior to acqui~5 their owncmhip intcre~ Furth~ore, after acqu~hag an interest in the property, those witnesses who wore two hats did not receive any requests for permission to use the road and never verbally commllllicated ally permissiOn to others to use the roadwayprior to 2000, long after the statutory period h~a been fnl611ed. i~tance, the defend~mt's witness, John Sirmlng (hengn~fl~r refen'ed to as "Sinning"), testified th.t he was an officer in the Association from 1981 to 1993. He obtained an interest in the properly (with Bd Boyd, through the creation of Paradise of Southolfl. Inc.) in 191/5, Prior to 191/5, as an officer in the Association, Si~.i~g was Evolved in the dredging process, and he never ~equested permission to use the roadway in isane from anyone. Ai~ he became a part owner, he would give permission to hlmselLf acting on beh~l¢ of the Association, to use the roadway but it-appea~ thai he never commanicalcd that pem~ission to anyone else. While Sim~i~5 did testify that he hadreceived requests for pra-,i~sion to dredge af~ 1993, no apcdfic infonusfion was elicited and it zem~i~ ~mclear who hsd made th~ requests and whe~l they we~'e made. Therefore, the testimony thst the Association used the roadway for decades for various ~Thcre is evidonce that the Paradise Point Corporation may have shared in the costs of dredging at some time dining the 19fi0'~. 4While it remaln~ unclear whether the Association i~ asserting ause of the roadway ptior t° 1963, and thus,must show fifleon years to satisfy the statutory period, both p~riofls have been satisfied bythe testimony at trial. aa purposes without ever obtMn~g portaL, sion rem~n~ unmbutted. Forth~more, the Association's witnesses estsblished ~h~* for many years the Associ~on (and thc Paradise Point Corporation at some point in the !960's) paid a private serenity fizm to patrol the entire ar~a, inoluding this roadway, In addition, the Assodafion paid for the installation of a light on the tun-around portion of this roadway, and installed and mnint=i~ed "private property" sig~s at the be~aai~g of this private roadway ~om at least 1988. Based upon the teslimony at trial, the Association hsn established by clear and convincing evidence that the Association, through its officers and members, has used this roadway for its benefit for well beyond the necessary ten or fifteen years, that the use was open, notorious, and continuous (at least seasonAllyifnot constantly). Therefore, a preaam?tion arises that the use was adveme ;md the burden ~i~/s to the defendant to establish that the use was pm'mid,ye. RiwLmere Aoartments. Inc. V. Stoneleiv. h Park'wav. Inc.. et al.. 275 A.D.2d 701, 702, 713 N.Y.S.2d 356, 357 (2d Dspt. 2000). The defendant argues that the use was with permission ~om the inception due to the fact that the officers of the Pazadise Point Corporation and the subsequent vm'ious owners of the pmpen'y in issue were all members and officers of the Association. Therefore, the clef;red,mt contends, the Assodatien does not reap the benefit of the preaumplion and instead must show sfTirl31a~VC facts to b~r. abllsh that thc tlSC was tlllder a cl~4m of right and advemc'to the imerests of the landowners, lqot all of the officers of the Aasoclmlon, however, were in the Corpoxaiion and not all of the officers in the Association held an inten~t in the property burdened by the easement in question. ~ defendant lass failed to d~:nonstrate that because some officers of the Association during the many decades over which this easement evolved wore two bats, one as an officer of the Association and one as an owner of the property, that they somehow deahvyed the ability of the other officers of the Association during these years to creat~ mad assert pzescriptive easement d~hts on bob,I/' of the Association in thi~ roadway; especially in the abse~e of any proo£that p=,,,,ission was communicated to these non-owners/officers of the Association. What is clear from the testimony of'all the fact witnesses is thst fl'om generation to Muua'ation, no one thoughi that they n~eded permission to use th~ roadway for any reason- They believed they bad a clear fight to it, and no permission was ever communicated to these ofiqc~-owne:s of the property; The only time that.belief seemed to e.h;m~e was. when the vdlness obtained an ll~qrer ~Omrntlllioatezt pu, uxL~aion tO ally other offiOe~: o£th~ Associatioll o: index1, to anyolle that used that roadw3y. ~Tor did any owner at anytime lxyto stop those officers and rnemherS of the Assodation from using the roadway. In addition, the Association shouldered the burden and expense of maintaining the roadway for decades. It pairt for snow removal, security, lighting, and used it innumerous times through its members and officers for recreation and to facilitate the dredging of the waterway. The fact that the Association ~h~red the coats'of this roadway until approldmately 1970 and after that exclusively maintained it, establishes that its use was not merely a neighborly 6 accommodation on the par~ of th~ d~fena~t's predecessors in titl~ with thc result that the pre~rmpti, on of adversity r~r~i~ ~ 142 AJD.2d 552, ~63, $31 N.Y.S.2d 99 (2d Dept. 1988). Therefore, th{~ Court fi~d~ that the ~socia~io~l h~ sllccecc~d in proving that it has an existing ~ascm~t over this roadway to be ufi]i~.ed by it through its membc~s for tho purpose for which th~ Association was crc~d~ thc usc and enjoyment of thc Paradisc Point Community? Fim~lly, the Court also fin& ttmt the Association has proven its case on its third cause of action to det~,~,,ine the pm'ties fights to the j ~y. The Association has established its ownership of the j~cy by the deed in evidence dated 1989 in which the then owners of the jetty clearly ~ntended to and did convey their title to the j ~tty to the Associatin~ The above consfitut~ the decision and judgment of this Com't. Dated: October 27, 2004 FINAL DISPO,~I'fION ENTER J.S.C. .NON-FINAL:DIsPOm'rtON their boats, or for any otJaer reereatiousl use. 5The defendant cites to City of Tonawmada v. Ellinott Creek Homeowners Association Inc., et d., 86 A.D.2d 118, 449 N.Y.S.2d i 16 (4th Dept. 1982) for the proposition that the Association may not assert prescriptive easement figh*~ on behalf of its membem for their personal use. That case, however, does not stand for such a proposition and is inapposite as in that case the Court found that as the Homeowners Association appeared "only in its reprcsonta~ve capacity and neither own[ed] nor cl~m[ed] a fight to .any interest in the property on its own babal~ it m~y not asscll a defense or countercblm basect on... proscriptive easement." In this case, the Association is not asserting prescriptive easement rights as some sort of a legal representative of its members which it has no legal ability to do; thc Association itself~ as a separate legal entity, is asserting a right to a prescfipQve ease~nent, on its own beh=l¢ Thus, the Association will own thc ~ght to the easement, not the/ndividual members in their personal capacity. A~ apract/cal matter, however, thc Assoc/ation has no independent existence. It is active through its members and only exists, as it appears from its "Constitution," to support it members usc and enjoyment of the Paradise Point Community. Having such an cascment fight, 'therefore, can only be utqli~xl bymembors of the Association for the same purpose - the members' use and enjoyment whether it is to dredge the Basin and Canal for the members' use of 7 Paradise Point A~sn., Inc. v Zupa (2005 NYSlipOp 08092) Page 1 of 2 Paradise Point Assn., Inc. v Zupa 2005 NYSlipOp 08092 October 31, 2005 Appellate Division, Second Depm'tment Published by New York State Law Reportin~ Bureau pursuant to Judiciary Law § 431. Paradise Point Association, Inc., Respondent, ¥ Mary S. Zupa, Appellant. --[* ] In an action, inter alia, pursuant to KPAPL article 15, to determine claims to certain real property, the defendant appeals from (1) a jud~nent of the Supreme Court, Suffolk County (Catterson, J.), dated October 27, 2004, which, after a nonjury trial, declared that the plaintiffpossesses an easement over her property as described in a certain deed and enjoined her from interfering with the plaintiffs "use and possession" of the easement, declared that the plaintiff has a prescriptive easement over a private roadway on her property and enjoined her from interfering with the use of the easement, and determined that she is barred from "all claim to an estate or interest in" a certain jetty protruding from her property into Southold Bay and enjoined her from interfering with the plaintiffs possession of that jetty, and (2) a money judgment of the same court dated November 5, 2004, which is in favor of the plaintiff and against her in the principal sum of $6,936, representing an award of costs and disbursements in the action/ Ordered that judgement is modified, on the law, by deleting from the first decretal paragraph thereof the words "and possession"; as so modified, the judgment is affmned; and it is further, [*2] Ordered that the money judgment is affirmed; and it is further, Ordered that one bill of costs is awarded to the respondent. http:ltwww.courtS.state.ny.ustreporter/3dseries/2005/2005_OSO92.hWn 8/24/2006 Paradise Point Assn., Inc. v Zupa_~(2005 NYSlipOp 08092) . Page 2 of 2 With respect to the cause of action for an easement over the defendanfs property as described in a 1989 deed, the Supreme Court declared that the Paradise Point Association, Inc. (hereinafter PPA), had a valid and existing deeded easement over the de£endanfs property and enjoined the defendant from interfering with the PPA's use and possession of that easement. It is well settled that easement rights derive from use and enjoyment (see Di Leo v 2~ec~to Holding Corp., 304 NY 505, 511 [1952]). The easement owner gains no right to possess or occupy the land (id.; see Trustees of Town of Southampton v ~ressup, 162 NY 122 [1900]). Here, the deed was clear that the PPA only gained a limited use and enjoyment of the servient land. Therefore, the court erred in enjo~niug the defendant from interfering with the PPA~s possession of the deeded easement. The Supreme Court correctly declared that the PPA had a prescriptive easement over the dirt roadway on the defendant's property mad therefore properly enjoined her from interfering with its use of the road (see Di Leo v_Pec~to Holding Co~., supra at $12; Frumkin ¥ Chemtop, 251 AD2d 449 [1998]). The defendant's'rems~n~ng contentions are without merit. Ad,ms, J.P., Luciano, Skelos and Lifson, J~., concur. http ://www. courts.state.ny.us/reponer/3dseries/2005/2005_OSO92.htm 8/24/2006 Paradise Point Association, Inc. v Zupa ' Page I of 2 Paradise Point Association, Inc. v Zupa Motion No: 2004-09780 +1 Slip Opinion No: 2006 NYSiipOp 60325 Decided on January 6, 2006 Appellate DiVision, Second Depaament, Motion Decision Published by New York State Law Reportin~ Bureau pursuant to Judiciary Law §431. This motion is uncorrected and subject to revision before publication in the Official Reports. Supreme Court of the State of New York Appellate Division: Second Judicial Department M34460 C/si THOMAS A. ADAMS, J.P. DANIEL F. LUCIANO PETER B. SKELOS ROBERT A. LIFSON, JJ. 2004-09780, 2004-10034 Paradise Point Association, Inc., respondent, v Mary S. Zupa, appellant. (Index No. 22401/02) DECISION & ORDER ON MOTION 10/12/2006 Motion by the appellant for leave to reargue appeals from two judgments of the Supreme Court, Suffolk County, dated October 27, 2004, and November 5, 2004, respectively, which were determined by decision and order of this court dated October 31, 2005, or, for leave to appeal to the Court of Appeals from the decision and order of this court. Upon the papers filed in support of the motion and the papers filed in opposition thereto, it is http://www.nycourts.gov/reporter/motions/2006/2006_60325.htm Paradis5 Point :4,ssociation, Inc. v Zupa 'Page 2 of 2 ORDERED that the motion is denied, with $100 costs. ADAMS, J.P., LUCIA_NO, SKELOS and LIFSON, JJ., concur. ENTER: James Edward P~lzer Clerk of the Court http://www.ny¢ourts.gov/reporter/motions/2006/2006_60325.htm 10/12/2006 tatt Court o! ~tpptais At a session of t~e Court, i. ld ~ppeals ttdl i# the City of ninth on t~e .............................................. May 2006 2-!0 Mo. No. 248 Paradise Point Association, Inc., Respondent, V. Mary S. Zupa, Appellant. A motion for leave to appeal to the Court of Appeals in the above cause having heretofore been made upon the part of the appellant herein and papers having been submitted thereon and due deliberation having been thereupon had, it is ORDERED, that the said motion be and the same hereby is denied with one hundred dollars costs and necessary reproduction disbursements. Stuart M. Cohen Clerk of the Court '~ -'.' · :'," ,~b 1 ~: 24 ! ~317278262 INDEY' NO. 22401-02 PRESENT: HON. MARY M. WERNER JI. JSTIOE OF THE SUPREME COURT PARADISE POINT ASSO~IA-TION, INC., PA~';E 02 ORIGINAL MOTION DATE: 1/5/06 MARY S, ZUPA, - against - Plaintiff(s), Defendant(s), MOTION NO. 005, MG McNULTY-SPIESS, P.C. Attorneys for Plaintiff 214 Roanoke Avenue Post Office Box 757 Riverhead, New York 11901 WICKHAM. BRESSLER, GORDON & GEASA, P.C. Attorneys for Defendant By: Eric Bressler, Esq. 13015 Main Road Post Office Box 1424 Maffltuck, New York 11952 VICTOR j. ZUPA, ESQ. Attorney for Defendant 4565 Paradise Point Road Southold, New York 11971 Upon the following papers read on Supporting Papers 1.5 and this motion: Order to Show Cause and Exhibits A-F; Answering Affidavits and Supporting Papers 6- 8; decision of the court dated February 9, 2006; and upon proceedings held March 9. 2006 and June 8, 2006; ~t is ORDERED that the motion (seq. #005) of plaintiff Paradise Point Association, Inc., brought on by order fo show cause dated December 13, 2005, for an order holding defendant Mary S. Zupa in contempt of court for willful disobedience of the judgment dated October 27, 2004-, rendered after a bench tdal (Catterson, j.), which was affirmed as modttied by the Decision and Order of the AppelJate Division: Second Judicial Department dated October ,2000, which was further clarified by the Court on March 9, 2006, is granted; it is . March ORDERED that upon and for reasons stated on the record of proceedings held 9, 2006 and' June 8, 2006, the Court finds that the defendant Mary S. Z. upa J8 guilty of civil and criminal contempt in having wilfully disobeyed the March 9, 2006 order of the Court; it is ~/1~I20B~ ld:2~ 1~31727B262 MONULTY SPIESS PC PA~ 03 ORDERED. AND ADJUDGED that defendant Mary S. Zupa. is sentenced to ten (10) days incarceration .in the Suffolk County Correctional Facility, Riverhead, New York; it.is ORDERED AND ADJUDGED that this sentence shall be imposed forthwith and the decision shall be deemed an order and/or warrant of commitment pursuant to and in accordance'with'Judiciary Law § 772.The Sheriff of any county of'the State of New York wherein defendant Mary S. Zupa, may be found, be and he or she is hereby directed to forthwith arrest said Mary S. Zupa without process and to commit her to the custody of the Sheriff of the County of Suffolk who shall incarcerate her for ten (10) days in the Suffolk County Correctional Facility located in Riverhead, New York; it is ORDERED AND ADJUDGED that the execution of this Order is stayed pursuant to and in accordance with Judiciary Law § 772 for a period of twenty-one (21) days after personal service of a copy of this Order upon defendant, granting defendant leave and the opportunity to purge herself of the contempt by removing on or before June 25, 2006 the entire fence and signs as directed by the Court on Mamh 9, 2006 and acknowledged by defendant on.the record of the proceedings held June 8, 2006; and in the event defendant, Mary S. Zupal fails to purge herself of the contempt by the time period set forth herein in this Order, than she shall appear before this Court on June 26, at 9:30 a.m. (lAS Part 32, Arthur Cromarty Criminal Court Complex, 210 Center Drive, Rivethead); and in that event the stay of the execution of the sentence imposed shall be vacated and warrant of COmmitment shall issue forthwith; It is further ORDERED that counsel for plaintiff shall forthwith serve a copy of this Order upon defendant, Mary S. Zupa, pursuant to CPLR 306(4 ), 308(2) o'r 308(4), and upon counsel for defendant, pursuant to CPLR 2103(b) (1) or (3) or CPLR 2103 (b) (2), by ovemight delivery with no signature required and thereafter file the affidavit(s) of service with the Clerk of the Court, within five (5) days of the date of said service and also notify the Court by written communication of same with a copy of the affidavit of service; and tt is further ORDERED that the law firm of Mcnulty-Spiess, P,C. shall immediately notif~ the Court by facsimile transmission to (631) 852-2156 of the compliance of the defendant with said Orders of the Court. A person, who is guilty of wilful disobedience of a court's lawful mandate, may be punished for civil and criminal contempt (see Judiciary Law § 750[A][3][4]; 753[A]). Civil contempt seeks to vindicate the dghts of a private party to litigation and any penalty for such contempt is designed to compensate the injured party or to cosine compliance with'the court's mandate (see, Matter of Deer, of Envtl. Protection of the City of Nc.;.: York v. Decartment of Envti. Conservation of the State of New Yort~,, 70 N.Y.2d 233,519 N.Y.S.2d 539 [1987]; Matter of McCormack v. Axalrort. 59 N.Y.2d 574, 466 NYS2d 279 Pa~adise Point Assec. t~i~, v, 7,,nc Index No. 22401-02 [1983]). Conversely, criminat contempt is imposed to preserve the power and integrity of the judicial process and to compel respect for ~ lawful orders, id. The penalty imposed for criminal contempt is punitive in 'nature, as Its objective is to deter disobedience of judicial mandates, id. Both civil and criminal contempt require'a finding that a lawful order expressing an unequivocal mandate was in effect; that it is reasonably certain that the order was disobeyed; and that the party charged had knowledge of that order (see Matter of McCormack v Axelmd, supra). The Mamh 9, 2006 order of the Court is very clear, specific and set forth in unambiguous terms. Thus, a prima facle case of criminal contempt has bean established thereby shifting the burden to defendant to establish good cause for her defiant noncompliance with this Court's Order. The Court finds that defendant has failed to establish such good cause. To this Court, this is a clear message of her continued defiance and refusal to acknowledge the Orders of this Court. Here, there is clear and convincing evidence that the Court's O~der has been violated and disobeyed and that the acts of omission in response to ~he Orders of the Court were and are wilful, intentional and a deliberate attempt to question and defy the authority of'this Court, as well as, to ignore the mandates of the Court and calculated to interfere with the due administration and judicial procass of justice (see Judiciary Law § 750[A][3][4]). Further, plaintiffs calculated disobedience of the lawful mandate of the Court has impaired and impeded the lawful rights of plaintiff (see Judiciary Law 0 753[A][8]), Accordingly, plaintiff's motion is granted to the extent noted herein. This constitutes the Order and Judgment; this Co.u..y~..._ · MARY~VERNEP~, J.~.C. % Paradise Point A~sO=. Inc, v, ?*m. Index NO, 22401.02 Paradise Point Association, Inc. v.Z~pa Page Paradise Point Association, Inc. v Zupa Motion No: 2006-05752 Slip Opinion No: 2006 NYSIipOp 70895 Decided on June 23, 2006 Appellate Division, Second Department, Motion Decision Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. This motion is uncorrected and is not subject to publication in the Official Reports. Supreme Court of the State of New York Appellate Division: Second Judicial Depax~uaent M41364 S/si THOMAS A. ADAMS, J.P. DANIEL F. LUCIANO PETER B. SKELOS ROBERT A. LIFSON, JJ. 2006-05752 Paradise Point Association, Inc., respondent, v Mary Zupa, appellant. (Index No. 22401-02) DECISION & ORDER ON MOTION Motion by Mary Zupa, inter alia, for leave to appeal to this court from an order of the Supreme Court, Suffolk County, dated June 8, 2006, and to stay enforcement of the order dated June 8, 2006, pending hearing and determination of the appeal. Upon the papers filed in support of the motion and the papers filed in opposition thereto, it is http://www.nycourts.gov/reporter/motions/2006/2006_70895.htm 9/28/2006 Paradise P~int Association, Inc. vZupa Page 2 o~2 ORDERED that the branch of the motion which is for leave to appeal to this court bom the order dated June 8, 2006, is denied as unnecessary as the order is appealable as of right (see CPLR 5701 [a][2][v]); and it is further, ORDERED that the motion is otherwise deaied. ADAMS, J.P., LUCIA_NO, SKELOS and LIFSON, JJ., concur. ENTER: James Edward Pclzer Clerk of the Court http://www.nycourts.gov/reporter/mofions/2006/2006_70895.hma 9/28/2006 4 Order of Fox Cohalan, J., Entered Octobe£ 4, 2005, Appealed From [Pages 4- 7] IND~XNo. BUPREM~ COURT- STATE OFNEWYORK I.A~S. PAKT 24 - SUFFO~ COTONTY PRESENT: Hon. PETEK FOX COI~LLAlq' Sustic¢ ofth~ Sup~ Co~t MOTION DATE ~=: CA.L. DATE 5-4~05 Mot. S~q. # OOg ~ ~',:~::~;-,x~' Zupa v [Paradise Point, et al. ~flex No. 04-22180 Page lqo. 2 that the cross-motion (~04) for ~,,mm,~ judgm,mt by dmfcndaut State of ,, ~he complaint is gnmtefl; and it is fmth~r O~D~F.~ that the cross-motion by ddend~ Pm~dise P~ ~o~ ~c. for lca~ ~~ ~ ~ B~ to.ted ~ ~ T~ of~o~ol& ~ 365 B~ad ~ 199~. P]~;,,~ ;~ ~ym~d a p~it to ~d a ~ at ~ ~ of lot five w~ ab~ ~e B~ ~e ~c~ ~ f~m~bnl~h~J Pl~i~Z~a~o~a~~lot~2002 ~ch ~ ~h~ ~ ~ c~t for ~ ~o~ ~d ~ ~ ~e B~: Dd~ ~o~~ cl.i~, o~p of~ B~ ~ ~.of C~g~ ~a ~o ct~m~ ~t ~ ~.po~ess~ of ~e ~ ~cc ~ ~ w~ ~ ~ for a~,,-;m~ ~ ye~. Ia contrast, plalnti~, allege that as upland ownera, they have gee title to a portiua of the B~ri~ w~i~h.lies in front ofthe~ i~zui,~7 at 3fiS'Bash~ Road. They the c~,nrm grantor, the.Paradise Point Corpmafioa, is prior in lime to ths;~ in addition, plainl'if~ C. lnlm ~ the A~ooil~Oll'S ~m.~' ~'~ld//l~lfOes the ~Ut.Lr~ ~ of j,,a?~t in th~ favor, for a dcclarati_~.tl~t~hey.. . ...~. .. .,,_~m~ioint..~.~ ov~c~s ~oporfimmt~ ,ha,~ o£the be£T ofttm Basin'aml for injuncfivo rolief bming othem from · intm-f~g with tl~ir rJparln~ fights. The Association mss-moves for leave tO "~-d the ~nsw~ ,~a the sram of N~w York cros~mOVe~ fo~ ~"'""'F jud~a~nt as ~,,,in,t.. it. .... · · ':': .... ' ' ' ~ The Boani of Town Truste~, by l~er ~cl Octobcr 27, 2000. infonvefl plal;,~ h'r. of tho resolution o~ Oc~hcr 25, 2000 ~ranling ptai.~i~' p~mit '~o imtall two sin~-pil~ dolphin, to stabilizelt~.,~,~ and dock with ~ l~y Onlcr date& An~st 2, 2004 (Lou2hllu, ~.),' foe Court upheldtt~ d~m'mina~n ofth~ Zoning Board of App~ls a~i diamiss~d th~ A_.-ticle ?1~ Petificm brought by p~t;~,~. Mary Zupa, con6~rn.~$ th. Boanl's fin~dng ~t Zupa v'?axadise ?oil, ~t al. Iud=z: No..~22 ~ 80 "Page Ne. 3 ~e d~f~e of statute ofH~im~ ~d a co~t~ol~ ~ ~to~ · ' · · ~ ~,~..~no ~2d253,.264, 32g ~28 894 [1972], ~d 52 ~d 8~ [1973]; ~r~a~ ~~: Page. No. 4 ~~t 473,601 ixlYg2d 129 [1993]). A~ has be~ ~fly s~'~ ~m '~o~e" h ~~o~ ~p & ~a~ Co., 226 ~ 38~ 45~ 1919 ~ LR~ g30 [1919]). In tl~ oa,~:, plai~i~ff~ ~ not cnQtlcd to ~xchlsivc ownm~hip of a ~i~ollional~ ar~a of Basin ~d~ ~o~ced~ ~oc ~t ~e ~t ~so~aQ~S~e ~ ~blc. ~an~g, 2~ ~2d 1113, 635 ~d 9~ [!~. ~, p~i~' ~n for ~ fi.S.C. F~IA1, DISPOSITION, ~ ~Zupa v Z~ning Bal. of App~ls of Town Of SoUthold '[t 2006 op Decided on July 11, 2006 Appellate Division, Second Department Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. This opinion is uncorrected and subject to revision before publication in the Official Reports. Decided on July 11, 2006 SUPREME COURT OF TIlE STATE OF NEW YORK APPELLATE DMSION: SECOND JUDICIAL DEPART1VIENT HOWARD MII,LER, J.P. THOMAS A. ADAMS GLOKIA GOLDSTEIN JOSEPH COVELLO, JJ. 2005-05234 DECISION & ORDER · [*l]In the Matter of Mary S. Zupa, appellant, V Zoning Board of Appeals of Tow~ of Southold, et al., respondents. (Index No. 19605/04) Wickham, Bressler, Gordon & Geasa, P.C., Mattituck, N.Y. (Eric J. Bressler of counsel), for appellant. Smith, FinkelStein, Lundberg, Islet & Yakaboski, LLP, Riverhead, N.Y. (Frank A. Islet of counsel), for respondent Zoning Board of Appe~s of Town of Southold. Esseks, Hefter & Angel, Riverhead, N.Y. (Stephen K. Angel and Anthony C. Pasta of counsel), for respondent Paradise Point Association, Inc, 7/17/2006 h'Ccp :t/ww~ .courts.smte.ny.us/reporter/~ dsenes/2006/2006_05648.htm ~;:?::' In a proceeding pursuant to CPLR artmle 78 to rev,ew a deterrnmat,on of :respondent Zoning Board of Appeals of the Town of Southold dated Au .grist 2, 20~! inter alia, granted the petitioners' application for an area variance to permit construction of a single-family home on the condition that no building permit be issued until a nonconforming marina use is discontinued or a variance is granted permitting the marina use in conjunction with the residential use, the petitioner appeals from a judgment of the Supreme Court, Suffolk County (Loughlin, J.), entered May 26, 2005, which denied the petition, con.firmed the det,mfination, and dismissed the proceeding. ORDERED that the judgment is affirmed, with one bill of costs. When reviewing a determinati°n ora zoning board, a court is limited to detema, ining whether the zoning board's action is illegal, arbitrary, or an abuse of discretion (see Matter ofIfrah v Utschig, 98 NY2d 304, 308). The determination ora zoning board regarding the continuation of a preexisting nonconforming use must be sustained if it is rational and is not illegal or an abuse of [*2]discretion, even if the reviewing court would have reached a different result (see Matter of P.M.S. Assets v Zoning Bd. of Appeals of Vil. of Pleasantville, 98 NY2d 683,685). Moreover, a zoning board may impose conditions when granting a variance, as long as the conditions are reasonable and are directly related to the real estate involved, without regard to the person who owns or occupies it, and to the underlying purpose of the zoning code (see Matter of St. Onge v Donovan, 71 N'Y2d 507, 515; Matter of Finger v Levenson, 163 AD2d 477). Based on our review of the record, the determination of the respondent Zoning Board of Appeals of the Town of Southold was rational and was not illegal or an abuse of discretior~ and the condition imposed was reasonable and directly ' related to the use of the land and the underlying purpose of the zoning code. Accordingly, the Supreme Court properly denied the petition, confn'med the determination, and dismissed the proceeding. We do not pass on the issue of the legality of a certain nonconforming marina, the subject of which is being litigated in an action entitled Zupa v Paradise Point Assn., pending in the Supreme Court, Suffolk County, under Index No. 25843/02. MILLEK, J.P., ADAMS, GOLDSTEIN and COVELLO, JJ., concur. ENTER: http:llwww.courts.state.ny.us/rcportcr/3dsefics/2006/2006_O564g.hma 7/17/2006 s:EdWard P¢Izcr · of thC Court http:/Iwww.courts,sta~e.ny.uslreportcr/3dseries/2006/2006_O564g.h~m 7It 7/2006 -- Uiee-Presiclent Arkie Foster Dickerso~ Town Hall /560S1~ Route 25 P.O. Box 1179 Southold, New York 11971-09§9 Telephone (6Sl) 765-1892 Fax (661) 765-6641 2005 BOARD OF TOWN TRUSTEES TOWN OF SOUTI-IOLD Walker Assoc., Inc. St. 1969 POINT ASSOC., INC. RD., SOUTHOLD I-1-16.10 Walker:. own Trustees took the following action during its regular meeting held on 1, 2005 regarding the above matter: Inter-Science Research Assoc., Inc. on behalf of PARADISE POINT INC. applied to the Southold Town Trustees for a permit.under the provisions of the Southold Town Code, the Wetland Ordinance of the Town of application dated April 22, 2005 and, application was referred to the Southold Town Conservation Advisory for their findings and recommendations, and, Public Hearings were held by the Town Trustees with respect to said on May 18, 2005, July 20, 2005, and August 24, 2005, at which time all persons were given an opportunity to be heard, and, the Board members have personally viewed and are familiar with the question and the surrounding area, and, .the Board has considered all the testimony and documentation submitted this application, and, the structure complies with the standards set forth in Chapter 97 of the Code, the Board has determined that the project as proposed will not affect the safety and general welfare of the people of the town, BE IT, , that the Board of Trustees approve the application of PARADISE POINT INC. to reconstruct'the existing docking facility 10' to the northwest consisting 15' fixed catwalk, a 4'X 12' ramp, and a 6'X 76' floating dock with three consisting of one (1) 3'X 20' float and two (2) new 3'X 40' floats, with the the two docks to the west are removed, and all as depicted on the survey ~ Howard W. Young last dated December 22, 2005. and complete project will expire two years from the date the permit Fees must be paid, if applicable, and permit issued within six months o[the are required at a fee of $50.00 per inspection. (See attached schedule.) Jr. Board of Trustees /~8/2oo6~w~. o~:2o FAX {COPY} MEMORA.NDUM SUPKEM~ COUKT, SLrFFOLK COUNTY. Applicmion of. MA_KY S. ZUPA and VICTOi~ .L ZUPA, Pedtion For a Judgment lhn'~mnt to CPLR Ardcle 78 THE BOARD OF TKUSTEES OF ~ TOWN OF SOUTHOLD and PAKADISE POINT ASSOCIATION, INC., WI~, BRESSLEP,4 GORDON & OEASA, P.C. Attorneys for Petitioners 13015 Main Rnad, PO Box 1424 M~ttitlmk, ~ 11952 LA.S. PAKT 9 By: Burke, Dated: ~ // , 2006 IndexNo. 06-2080 Mot. Seq.# 001-CDISPSUBJ RemmDa~: 3~-06 Adjoumed: 6-7-06 · SMITH, FINKEL'STEIN, LUNDBERG, IS.qLER & YAKABOSKI, LLP Attnmeys for ~o~t Bo~ 456 ~ng Av~, PO Box 38~ ~v~h~, ~ 11901 . ESSEKS, HEFTER & ANGEL Attorneys for P, cspondent Paradise Point Assn., Inc. 10g Eust Main Sweet, PO Box 279 P, iverhead, NY 1 !901 In thiu Article 78 proceeding petifionem seek a judlpmmt unnulll,ng and revar~ing detu.,-.inutions by respondmut Bo~d of Trusmes of tim Town of Southold granfi'aE respondent Paradise Point Association, Inc. a wetlands pe, ,,,it for the r~novation and reoOnstmotion of their dock. The p~ition is diumiuscd. This proceeding hnu its genesis in a long term and contentious, dispute between petitioners and respondent Psradise Point Aasooiafion~ Inc. (Paraddse Point), involving access to, and the use of, docking f~ilities on a body ofwater known as th~ "Basin" in Southold, N~v York. ' P~dtioner Mal~ S. Zupa is the owner of a 1.7 dore parcel of real property bordcriug on both Southold Bay and th~ Basin. Respondent Paradise Point, a group comtxised of neighboring landowners, ga.~ a~cess to their boats dooked or moored in the BaSin ~.hrollg~'1 an el~-~ll[lel~.t ii, ross Ms, Zupa's parcel which ~ont~ on the Basin. Kespondent Paradise Point mulntain, three doe. ks in the Basin, the largest of which extends approwlmately 100 fe~t into the Basin. Two smaller [~OOl 10/15/2D0~ ~ 04:2! I~A,,~ ~ ,' ~)002 COPY 7:.upa v Board of Trustees 3.nd~x No..06-2080 Page No. 2 docks are siUmted to the west of tho largest dock. In April o£2005, respondent Paradise Point applied to respondent Board for the wetlands. permit necessary to repair and/or replace its existing docks. Although the initial proposal providexl for the replacement u,~ repair of the docks in their ag size and' location, Paradise Point a~ced~d to respond~lt Board's request that altea-~ativ~ design propossls for the docks be submitted to lmeommodate both th~ concerns of the Board and c~taln n~arby landowners, 'including the petitioners h~e. in, regarding the size and placement of the docks. Following a number ofpublic hearings on the application, the Board by resolution, dated S~ptamber 21, 2005, approv~ respond-hr Paradise Point's spplioation for a wetla p~rmit to rsp~ir their existing dockqn§ feciligr with the following changes, and subjea m nmw plans showing the following: I. Existing 6' x 100' floaling dock to be moved 10' to the North west. 2. The sase dock will be shortened to the end of the.third seaward finger fina~ to approximately 76'; in order to follow the Code requirasent of dock extending no more than one third across a my. The finger at the end of the existing doc& to the west will be removed. 3. The fingers on the dock, lanekvard to seaward, will be permitted at 3' x 20', 3' x 40' and 3' X 40'. 4. The two docks to lhe w~st will be remov.d. lnummeh as the Paradise Point dock plan will require additional approvals l¥om oth~r agencies such as the New York State Departmeat of Envir0nmental Conservation and the Army Corps ofRn~oine~rs b~fore it my be implemented, respond{mt Paradise Point also appliexl for p~,,iusion from the respon&.,mt Board to perform emergency repairs on the presemt dook while awaiting the other aganci,s' review of the new dock p]anu By determination, dated November 16, 2005, respondent Board approved emergemy work by Paradise Point to preserve the existing docks during that Fall and Winter season. The emergency work was restricted to: a. resetting four piles to stabilize the dook over the winter; h. re-bolting two float ends; c. tightening all eye boils;. d. bolting two existing stringers; e. installlng two sets of eye bolts; mad f. re-nailing son~ 25 loose boards. In January, 2006, petitioners commanced the instam Artiole 71t proceeding challenging the respondent Board's determinations of September 21, 2005 and November 15, 2005 as arbilrary mad oaprioious, affected by an error of law anr~ a abuse of discretion, im particular, petitioners maintain that the Board's determinatiom violate, both the procedural mad substantive requirements of Chapter 97 [now Chapter 275] of the Southold Tom Code. 10/18/200~ WI~D ~4:21 ~AX . ~ , ~003 Zupa v Board of Trustees lnct~ No. 06-20110 ?age 1%. 3 With respect to petitioners' claims regarding the Board's determination, dated November 15, 2005, granting permi.nsion for emergency repairs to the existing docks, responden: Paradise Poinl allages'that the aforementioned repairs have long since boom.completed. This assertion is not clnallenged by the petitioners. Petitioners didaot seek a prelirnlnswy injl~Oll or Other~Vine presea've the stares q tm to prevent the repairs from .going forward during the pendency.o£this · proceedln~ The petitioners failed to even address the mootness claim in their r~ly a~rms~ion in support of the p~diion, and therefore, the Court is no/presented with any arguments raising the applicability of exceptions to the mootness doctrine. Petitioners' clslmnxagarding the Board~s determination, dated November 15, 2005, are consequently dismissed, as academic (see, Downes v Town of Southampton Zoning .Board of Appeals, 15 AD3d 398, 790 NYS2d 469 [2005] and the eases cited therein). Petitioners'. clulmu regarding the Board's determlnutiou, ttu*.d S~b~ 21, 2005, ~g ~ w~unSu pem~ ~ reg~d to ~ rmov~on md reeo~on of ira de~ ~ssed. ~ a proceeding p~,snl to CP~ ~cle 78 a ~ ~y not ~b~m~ for ~l of~ body it ~s E~e dec,ion m~H~ ~ a ~g ~ ~poned e~ee ~d ~ not =bi~ or ~ able of ~or~on. ~ d~in~on of~bk e~d~e, it ~ be ~ed (H~ood v Board of ~te~ of the Ink.or.d ~ge of ~ou~ton, 176 ~2d 291~ 574 ~S2d 217 [1991] app ~ 80'~2d 756, '588 ~82d 824). The application which is the subject of this Article 78 proceeding was made Chapter 275 [formerly Chatner 97] of the Southo]d To'wn Code entitie, d~ "Wetlands and Shoreline". Section 275-11[o][23 of the Town Code Section provide~, inpertiaent pan, Town policy that "all doclm shall be designed constructed and 10oared so as'to redue~ a dook's potential adverse impacts to navigation, public s~ety, waterway congestion, access to public trust lands attd water, ,nS natural resources and habitats." Section 275-11 [c][2] of the Town Code requires tha~ pre-existing nonpermitted and/or nonconformin5 Irixuctures cannot be replaced in kind without full review ~nd approval by the Board of Trnstees. Section 275-12 of the Town Code sets forth the applicable st,re,lards to be considered.by respondent Board in whether to granI an application :for a wetls~d~ permit for a dock (Code of the Town of Southold §275-12). Under ih{~ section of. the Code, the Board may issue a wetlands permit only if it determines lhat a proposal will not sub.ntanfia]ly: [~_] fi~.dvera~ly af~ot the w~tlallds of the Towll; [B] Cause damage from erosion, turbidity or siltation; [C] Cause saltwater intrusion into the fresh water resowoes of the Town; ID] Adversely affect tis]l, shellfish or other beneficial urganinmn~ aquatic wildlife and vegetation or the natural habitat thereof; [t3] lmerease the d~nEer o:fflood and storm-tide damage; IF] Adversely affect navigation o~ tidal waters or the tidal flow of the tidal waters of the Town; [G] Change the course of any channel or the natural movement or ilo~v of any waters; [H] Weaken or und~mine the lateral support of other lands in the vicinity; [I] Otherwise adversely affect the health, safety and general welfare of the people of the Town; and [iii Adversely affect the aesthetic vatue of the wetland and adjaeem areas. COPY Zupa ~ Board o£Trusmcs. Index 1~o. 06-20g0 Page No. 4 Upon a review of the record, ~Im Court concludes that th= Board's d~u:~.,iuation was m~te in full compUance with both the procedural md substantive requirean=nts of Ch~ter 275 of thc Town Code. Contrary to petitioners' conmntinns thc appropriate dommmnts wcrc submitted by respondent Paradise Point on'irs application, the required notice of the public hem4ng was given and tt~ public h~aring was s~tually conducted and continued on several dams thereafter. Thc record also re. fleets that respondent Board heard testhnony from anumber of witnesses ~nd considered wr/tmn subm~.sions both in support .~a in opposition to the application. Petitioners, in particul~r,v~rc afforded thc opportunity to ~ddress the Board and r~.i~c sub~-~.sious in support of their objections. Tim Boreal considered tlm plans and reports prepared by respondaut Paradise Point's expert ss web ss thc retort oftl~ Town's Cormervation AdvisorY Counoil which recommended approval of tim proposal.s%tbj~ot to cumin conditions ~dopted bythe Bo~l. In reviewing thc application th= Board. requ~st~.d respondent Par.,~.c Point to offer.various altmnstives to its orJ~..1 proposal in order to allow th~ existing dock ~o bett~r conform with thc' regulations for n~wly consmmted docks. As a result the proposal.~or respondent Psmdise Point's reconstnmmd doom whioh wss ult~r~.tely ap~ov~ by respondent Board provides for s single, ~.t~er dock to be constrtmted in a configuration which is less inU'usivc upon petitioners' property, in particular, and th= Basin~ in gcnc~l. Momover~ two of the three pm-existing docks am criminated in thc proposal approved by th= Board, Under th~sc circ-m~tancas,, thc Board's d=term~nation to grant respondent Paradise Point's applioation £or a w~ands'permit was suppormd by thc substantial cviH~.-cc~ had a rational basis and was not arbitrary ~nd capricious, F~=ally, the Court declines to 'con~id~r those arguments msdc.by petition=rs herein which arc simply a reh~.~ing of cl~im~ raised by the petitioners i~ otlmr plenary artions, and CPLR article 78 proceedings. Ofpartic~l~r not= is the p~tioners' c~.im .that respondent Board failed to c~ter~i-e *~,* respondent Paradise Point's ~m is not a legal n0noonfo..,'m~g use · ss suez a du~r,,i~n'don would not bc within th~ purvi~v of the respondent Board's'authority on an aPPlication for a w~lands p=,~it. In any event, as has already been pointed out ~oy the A.ppcliam Division, second D~p~u [men~, the legality otthe Paradise Point mm-bm, is already tl~ subject of Iiti~ation in an action, entitied-Zutm v l~aradi~e .Point .,4_s~a, p~ding in this Court under Index No. 02-25843 (Zu~a ~ Zoning ~oard qf At~la~als ~d~the Tow~ oJ~$auti~aid, 31 AD3.d 570, S. 17 iXTYS2d 672 [2006'J). . . ~ Accordingly, thc p~tion is dc~nicd and th~ procc~-g is Submit judgment. . . ' ~'//~" ~PPEALS BOARD MEMBERS Ruth D. Oliva, Chairwoman Gerard P. Goehringer James Dinizio, Jr. Michael A. Simon Leslie Kanes Weisman ae ~ http://southoldtown.northfork.net ZONING BOARD OF APPEALS TOWN OF SOUTHOLD Tel. (631) 765-1809 · Fax (631) 765-9064 Southold Town Hall 53095 Main Road · P.O. Box 1179 Southold, NY 11971-0959 Town Annex/First Floor, North Fork Bank 54375 Main Road (at Youngs Avenue) Southold, NY ! 1971 FINDINGS, DELIBERATIONS, AND DETERMINATION MEETING DATE: SEPTEMBER 14, 2006 RECEIVED 8EP 1 9 2006 outl[old Town Clerlt ZBA File # 5914 - BOARD OF TOWN TRUSTEES, TOWN OF SOUTHOI n. Request for Town-Wide Interpretation of Zoning Code Section 280-141 (formerly 100-241) regarding the following question: Where a legal nonconforming, preexisting dock/marina use is issued a wetlands permit that requires docks to be relocated in the same general area and reduced both in size and number, would compliance with those conditions cause the docks/marina to lose their legal nonconforming status under Section 100-241 ? SEQRA DETERMINATION: The Zoning Board of Appeals has visited the property under consideration in this application and determines that this review falls under the Type II category of the State's List of Actions, without further steps. DATE OF PUBLIC HEARINg: The Zoning Board of Appeals held a public hearing on this application on July 27, 2006, at which time written and oral evidence were presented. Based upon all testimony, documentation and other evidence, the Zoning Board finds the following facts to be true and relevant: BACKGROUND: The Zoning Board of Appeals received an application from the Board of Trustees pursuant to former Town Code Section 100-271(D) [now Section 280-146(D)] for an interpretation of Section 100-241 (now Section 280-121). The application states: "THE TRUSTEES' ISSUANCE OF PERMITS FOR DOCKS DOES NOT REQUIRE BUILDING PERMITS AND, AS A RESULT, THERE IS NO MECHANISM FOR THE BUILDING INSPECTOR TO ACT AND THUS NO APPEAL RIGHT TO THE ZBA, THUS, AN APPLICANT HAS NO PROCEDURE TO OBTAIN THE ANSWER TO THE QUESTION BELOW THAT THE TRUSTEES BELIEVE WILL RECUR FROM TIME TO TIME: WHERE A LEGAL NONCONFORMING, PRE-EXISTING DOCK/MARINA USE IS ISSUED A WETLANDS PERMIT THAT REQUIRES DOCKS TO BE RELOCATED IN THE SAME GENERAL AREA AND REDUCED BOTH IN SiZE AND NUMBER, WOULD COMPLIANCE WITH THOSE CONDITIONS CAUSE THE DOCKS/MARINA TO LOSE THEIR LEGAL NONCONFORMING STATUS UNDER SECTION 100-241." Page 2 - September 14, 2~.-~ Appeal No. 5914 - Interpretation (Town Trustees) Southold Town Zoning Board of Appeals The issues giving rise to this request from the Board of Trustees are set forth in the letter to the Beard of Trustees dated May 12, 2006 from the attorneys for the Paradise Point Association. The Zoning Board of Appeals held a public hearing on July 27, 2006 at which time written and oral evidence were presented. Based upon all testimony, documentation, and other evidence, the Zoning Board makes the following determination. JURISDICTION Of ZONING BOARD Section 280-146D authorizes the Zoning Board to, among other things, "determine the meaning of any provision in this chapter'' "on request of any Town officer, board or agency." FINDINGS OF FA CT/DETERMINA TION 1. The Town Trustees have requested the Zoning Board's interpretation of the non- conforming use provisions of the Code because they have issued a permit to a non- conforming boat basin that would require a reconfiguration of the existing docks rather than allow an in kind repair/replacement. The Trustees regard the reconfiguretion as more desirable since it brings the docks into greater conformity with Trustee requirements. The change was instituted at the Trustees' request and was not sought by the applicant. 2. Section 97-28 of the Town Code sets forth the Standards for Issuance of Permits by the Town Trustees as follows: "The Trustees may adopt a resolution directing the issuance of a permit to perform operations applied for only if it determines that such operations will not substantially: A. Adversely affec~ the wetlands of the Town. B. Cause damage from erosion, turbidity, or siltation. C. Cause saltwater intrusion into the fresh water resources of the Town. D. Adversely aff~ct fish, shellfish or other beneficial marine organisms, aquatic wildlife and vegetation or the natural habitat thereof. E. Increase the danger of flood and storm-tide damage. F. Adversely affect navigation on tidal waters or the tidal flow of tidal waters of the Town. G. Change the course of any channel or the natural movement or flow of any waters. H. Weaken or undermine the lateral support of other lands in the vicinity. I. Otherwise adversely affect the health, safety, and general welfare of the people of the Town. J. Adversely affect the aesthetic value of the wetland and adjacent areas." ' P~'l~e ~ - September 14, 2~...J Appeal No. 5914 - Interpretation (Town Trustees) Southold Town Zoning Beard of Appeals 3. Section 280-121A of the Town Code provides in pertinent part: "Except as provided hereinafter, nonconforming use of buildings or open land existing on the effective date of this chapter or authorized by a building permit issued prior thereto, regardless of change of title, possession or occupancy or right thereof, may be continued indefinitely, except that such building or use: A. Shall not be enlarged, altered, extended, reconstructed or restored or placed on a different portion of the lot or [6arcel of land occupied by such use on the effective date of this chapter, nor shall any external evidence of such use be increased by any means whatsoever." 4. With respect to the issue before the Board, the non-conforming "use" at issue is the non-commercial boat basin on Town owned land controlled by the Trustees under the Andros Patent. 5. The re-alignment of the basin's docks as required by the Trustees does not constitute a change that would be prohibited under Section 280-121A. The use is not being "enlarged, altered, extended, reconstructed or restored or placed on a different portion of the lot or pamel of land occupied by such use"; particularly since the re-alignment was at the request of an independent board with full jurisdiction over the subject matter. DETERMINATION: Weisman, it was On motion offered by ChairWoman Oliva, seconded by Member RESOLVED, that the re-alignment of the basin's docks as required by the Trustees does not constitute a change that would be prohibited under Section 280-121A. Vote of the Board: Ayes: Members Oliva (Chairwoman), Goehringer and Weisman. (Members Dinizio and Simon were a)~'e~t.) This Resolution was duly adopted (3-0). Ruth D. Oliva 9//.~'-/06 Approved for Filing Patrick M. O'Connell Thomas A. Osbom David M Kaufman Mary Kate Mullen Angelina Daily Office Administrator ATTORNEYS AT LAW COURTHOUSE CORPORATE CENTER 320 Catleton Avenue, Suite 6800 Central Islip, New York 11722 (~31) 342~070 (631)462-1060 Fax: (631) 342.8350 2 Coraci Boulevard, Suite 6 26 Coufl Street, Suite 1601 Shidey, New York 11967 Brooklyn, New York 11242 Mr. James Dinizio Cb~i..'than, Board of Appeals PO Box 1179 Southold, New York 11971-0959 Re: ZBS #8010 - Dear Mr. Dinizio: April 25, 2007 Of Counsel Patrick Henry Justice, N.Y.S Supreme Court (Ret.) Appeal Application (Mary Zupa) Thank you for your letter of 9 April concerning the captioned matter. It is our desire to adjourn the application until the various questions of law and fact pending in Supreme Court be resolved. Accordingly, our application for relief will be submitted at a later time. '% truly yours. PH:fm (~~'e~ ~~ cc: Anthony C. Pasca Esseks, Hefter & Angel, LLP 108 East Main Street PO Box 279 Riverhead, New York 11901-0279 Office Location: Town Annex/First Floor, No~th Fork Bank 54375 Main Road (at Youngs Avenue) Southold, NY 11971 http://southoldtown.northfork.net BOARD OF APPEALS TOWN OF SOUTHOLD Tel. (631) 765-1809 Fax (631) 765-9064 April 9, 2007 Mailine Address: 53095 Main Road P.O. Box 1179 Southold, NY 11971-0959 Patrick Henry, Esq. 320 Carleton Avenue, Suite 6800 Central Islip, NY 11722 Re: ZBA # 6010 - Appeal Application (Mary Zupa) Dear Mr. Henry: This will confirm that the following action was taken at the Zoning Board Meeting held on March 29, 2007 by the Zoning Board of Appeals concerning the above Appeal Application: BOARD RESOLUTION: After receiving testimony, and it appearing that by ZBA determination #5266 adopted August 2, 2004, this Board granted the applicant an area variance to construct a home as set forth therein, conditioned upon, among other things, that no building permit be issued until the nonconforming marina use is removed or a variance is granted to permit its continued use in conjunction with a residential use; and it further appearing that the applicant is agreeable to apply for such variance, Now, therefore, upon motion offered by Chairman Dinizio, seconded by Member Weisman, this hearing is adjourned to April 26, 2007, so that the applicant can file an amended appeal to include the request for the variance described in ZBA Determination # 5266, which application shall specifically show the portions of the property affected by the marina use as well as the areas of the property that are affected by easements that the Paradise Point Association has over the subject property, as previously determined by the Courts. Please feel free to call our Administrative Secretary, Linda Kowalski, if there are questions concerning the filing of the amended application forms. Thank you. .~ery truly you~__~_ ·/ /~a~aD~nizio,Jr. /-- / SMITH, I?INKELSTEIN, LUNDBERG, ISLER AND YAKABOSKI, LLP March 30, 2007 APR James Dinizio Chairman of the Zoning Board of Appeals 53095 Main Road P.O. Box 1179 Southold, New York 11971 Re: Zupa v. Zoning Board of Appeals - Index No. 06-29166 Dear Mr. Chairman: Enclosed please find the reply papers submitted on behalf of the Zupas with respect to the Zoning Board's interpretation rendered to the Trustees. I will keep you advised. FAI/cd Enclosure cc: Kieran Corcoran, Esq. - w/end. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK ~,~,~.p,~6 % %%%-/ ....................................................................... X Index ~u.. u -29166 Application of MARY S. ZUPA and VICTOR J. ZUPA, Petitioners, REPLY AFFIRMATION For a Judgment Pursuant to CPLR Article 78 -against- ZONING BOARD OF APPEALS OF THE TOWN OF SOUTHOLD, THE BOARD OF TRUSTEES OF THE TOWN OF SOUTHOLD and PARADISE POINT ASSOCIATION. INC., Respondents. ERIC J. BRESSLER, an attorney duly admitted to practice in the courts of the State of New York, affirms to the truth of the following under penalties of perjury: 1. I am a member of Wickham, Bressler, Gordon & Geasa, P.C., attorneys for petitioners and make this affirmation in support of the petition and in reply to the answers of respondents. I have knowledge of the facts stated herein. 2. The Determination at issue is not rational, is unlawful, is unsupported by substantial evidence, is arbitrary and capricious, is in excess of jurisdiction, and is an abuse of discretion for eight reasons. Each of these reasons is explained below. 3. First, although the request to the Zoning Board of Appeals was couched as a request for a town-wide interpretation, it plainly was not so. Rather, the request dealt with a single project and was highly fact dependent. The size, location, and configurations of the proposed project were concededly relevant and determinative of the issues. Under such circumstances a town-wide interpretation could not issue and the Zoning Board of Appeals lacked jurisdiction. The record reflects that the Zoning Board of Appeals member Dinizio, who was curiously absent upon the vote of this matter, expressed such a view (R-130, all references are to the Return). The only appropriate means to handle such an application would have been for the true applicant, the Associatiom to make an application for relief with a request to a specific property or project. 4. Second, as a request for a town-wide interpretation, the Request was fatally deficient in that it did not identify any vagueness or ambiguity in Town Code Section 100-241. As a result, necessarily, the Determination does not constitute an interpretation of a Town Code section on a town-wide basis. The Determination is nothing mom that a grant of relief to a disguised applicant who got the Trustees to do their bidding for them. 5. Third, the underlying premise of the Determination was that the Trustees required the Association to move their docks. This is simply untrue and not supported in any way by the return. The Association sought to reconstruct their non-conforming docks in exactly the same location - a purely voluntary act on their part. The Trustees denied the application but permitted alternative relief which the Association was and is free to accept or decline. The Determination somehow impermissibly changed a permissive grant into a mandatory requirement, ignoring the facts of the application. 6. Fourth, the Determination irrationally found that the docks and marina use existed solely with respect to the Basin, the land under which is owned by the Trustees. This finding is directly contradictory to the Zoning Board of Appeal's earlier determination (Exhibit F to petition) that the docks and marina existed on Mary Zupa's property and operated to bar her from a building permit until the docks/marina were either removed or legalized by variance. Based upon the earlier determination it is obvious that removal and reconstruction of the docks/marina in a new location falls squarely within Section 100-241. There is no way to reconcile the treatment of the docks/marina in such a disparate manner in the two determinations. The result of this disparate treatment is to bar Mary Zupa from building by virtue of the earlier determination and to permit the docks/marina to exist in perpetuity in the future. 7. Curiously, the Zoning Board of Appeals seemed to recognize its inherent inconsistency in its position when member Goehringer stated at the hearing that: "We need to differentiate between a marina and never call this a marina. It never should have been called a marina, it should never be called a marina. It is a private boat docking area in a private boat basin; and that's it." (R-108) Apparently the docks/marina are now just a community dock when it comes to granting relief to the Association to permit reconstruction, but they are a full blown marina use encumbering the upland when it comes to denying Mary Zupa an opportunity to build a home on concededly residential property. 8. Fifth, the Determination entirely avoids the issue as to how reconstruction and movement of the docks and the use thereof to a new location on the upland and within the Basin does not constitute movement to a new location within the meaning of Section 280-121 (100- 241). To state the conclusion does not explain the reasoning, if any, or justify the result. The Town Code Section 280-121 (120-241 ) makes it clear that non-conforming buildings and uses d~ not by their terms necessarily extend to entire parcels of land, and, in fact, prohibits movement from one position to another within a parcel. It is plain that the original docks/marina were in a specific location different from the proposed new location. Thus, a movement necessarily wouk occur upon reconstruction. 9. Sixth, the Town Code plainly provides for elimination of non-conforming uses (Section 100-10). The Determination totally ignores this requirement and essentially permits th~ continumlon of a noO-co~forrning use nd infinitum by mean,~ of rer~ti.t[ve movements and/or 10. Seventh: tl~ Determinatio~ ignored th~ :tact that the legality of the docks/mm'i~aa was and i.s cun~nltly sub j!~ljce before thc Supreme Court, Suffolk County. Rathez, the Zoning Board of Appeals aimply sidz-stepped the issue arid awarded relief'as tribe issue didn't exist, l 1. Finally, the issue of the involuniarincss of the proposed move a~d Ieconstmction was h~properly raised procedurally as well as suk.stanfively unsupported (as Set forth above). At no time was any. Jntcrpretetlon requested as to Town Code Section 100-246 adv~ed~ed o1' sought by alaplication. Thus, its consideration was not permissible, 12. In sunmmy, the Zoning Board of Appeals in its zeal to approve for the Association retching it .requested, total}y ignored the law and i'Bcts j. rl granting l'eltef, The Dctermination should be annulled. WHEREFORF_~ it is rcN~'v'tfully reqtlesled gaat th~ Deic~mlnation be mmulled because the Determinaiion at issue is not rational, is unlawfiii, is tmsupl~orted by substantial evidcnce, is arbitrary and capricious, is in excess ofjurisdJclion, and is an abu.~: of discrefioll, and for such other and farther relief'as tb~ Court may deelI~ just and proper, Dated: Mm-~h 27, 2007 M~atit uek. N~w Yo~k ~ J. Bresa LEGAL NOTICE SOUTHOLD TOWN ZONING BOARD OF APPEALS THURSDAY, MARCH 29, 2007 PUBLIC I~ARINGS NOTICE IS HEREBy GIVEN, pur- suant to Section 267 of the Town Law and Chapter 280 (Zoning), Code of the Town of Southold, the following public hearings will be held by the SOUTH- OLD TOWN ZONING BOARD OF APPEALS at the Town Ha0, 53095 Main Road, PO. Box 1179, Southold, New York 11971 ~959, on IIIURSDAY, M~RCH 29, 2007: 9:40 A.M. LYNNE CARDACI /t6012. Request Iora Variance under Section 280 124, based on the B0ilding Inspector's Sanuary 9, 2007 Notice of f~isapproval concerning an applieatinn r a building permit for'a proposed addition to the existing dwelling at less than 40 feet from the front lot gne, at 80 Jerinck Lane (at Oaklawn Avenue), Southold; CTM 70-3-16. 9:50 A.M. STEPHEN and CLARA WONG g6014. Request for a Vari- ance under Section 280-15, based on the Building Inspector's January 25, 2007 Notice of DisapprovaI concern- thg an appbeation Iora building permit to locate an accessory garage in a front yard rather than a rear yard. Location of Property: 1780 East Gillette Drive and (west) Gillette Drive, East Marion; CTM 38-3-23.1. 10:00 A.M. PAUL R. CADMUS #6016. Request for a Variance under Section 280-124, based on the Building Inspector's January 26, 2007 Notice of Disapproval concerning an application for a building permit to build a covered porch addition at less than 40 feet from the front lot line, at 7005 Main Road, East Marion; CTM 31-1-3. 10:10 A.M. LEE and MARIE BE- NINATI #6017. Request for Variances under Section 280-15 and 280-38C- 1, based on the Building Inspector's January 4, 2007 Notice of Disapproval, amended February 22, 2007 concerning an application for a building permit for (a) in a yard other than the required rear yard, (b) set back less than 25 feet from the property line, (c) height ex~ ceedthg the code limitation of 22 feet to the top of the ridge, and (d) dormer exceeding 40% of the roof width. Lo- cation of Property: 3070 Peconic Lane and C.R. 48 (Middle Road or North Road), Pecouic; CTM 74-3 15. 10:30 A.M. NANCY BORIS g6007. Request for a Variance under Section 280-124, based on the Building Inspec- tor's October 24, 2006 Notice of Disap- proval concerning an application for a building permit for an addition to the dwelling at less than 35 feet from the front yard lot line and with lot coverage exceeding the code limitation of 20%. Location: 335 Pierce Drive and private right-of-way, Cutchogue; CTM 136-1-8. 10:40 A.M. THOMAS RYZUK 06009. Request for a Variance under Section 280-124, based on the Building Inspector's January 19, 2007 Notice of Disapproval concerning a proposed new dwelling, after demolition of the exist- ing structure. The dwelling is proposed at less than 15 feet on a single side yard and less than a total of 35 feet combined side yard setbacks, at 790 North Sea Drive, Southold; CTM 54-5-14. 10:50 A.M. PERICLES NOTIAS g6005. Request for a Variance under Section 100-30A.3 (280-18), based on the Building Inspector's March 30, 2005 Notice of Disapproval conceruing an as- built dwelling (re£ B.E File Re£ 29700- Z) exceeding the code limitation of 2-1/2 stories at 675 Summit Drive, Mattituck; 11:00 A.M. $OSEPH GULMI and SUSAN BRAVER #5994. Request for a Variance under Zoning Code Sec- lion 28~105, based on the Building Inspector's December I1, 2006 Notice of Disapproval, and request for relief from Condition under ZBA No. 5340 concerning the setback location of an as-built pool (re£ B.R 891932-Z), at less than 30 feet from the front lot line. Lo- cation: 250 Pine Tree Court, Cutchogue; 1:25 EM. JOHN and PATRICE KEITF g6008. Request for Varianc- es under Sections 280-15, 280-116B, and 280-124, based on the Building Inspector's January 11, 2007 Notice of Disapproval concerning an application for a building permit for as-built shed, of a screen porch, and new addition to dwelling. The reasons stated in the disapproval are: (a) decking construc- tion is shown with a zero setback from the bulkhead, (b) the as-built screened porch is less than 75 feet from the bulk- head; (c) the rear yard setback is pro- loft: posed at less than 50 feet; (d) the as- built accessory shed does not meet the required 5 ft. minimum setback under ZBA No. 3229. (Note: Variance relief is not requested for the trellis structure.) Location of Property: 280 Basin Road, Southold; CTM 81-1-19. 1:50 EM. ROBERT SEELEY #5912. Request for a Variance under Section 280-116 (100-239.4A based on the Building Inspector's April 12, 2006 Notice of Disapproval concerning a proposed accessory swinmting pool structure in a location at less than 100 feet from the top of the bluff adjacent to the Long Island Sound, at 1250 Sound Drive, Greenport; Rockcove Estates Lot 4; CTM 33-3-19.4. 2:05 PM. EDWARD FERGUS #5941. Request for a Variance under Section 280-18 (100-30 A.3) based on the Building Inspector's May 31, 2006 Notice ol Disapproval concerning an ap- l~lication for a building permit to build a s~ngle-family dwelling in a Iocation less than the code-required 50 feet from the rear lot line, at 1854 North Bayview Road, Southold; CTM 70-12-39.3. 2:20 EM. MARY ZUPA This is an Appeal for an Interpretation or other action, based on the Building Department's December 21, 2006 turn ora building permit application for construction of a single-family dwelling, at 580 Basin Road, Southold; C'rM 81- 1-16.7. The Board of Appeals will hear all persons, or theh- representatives, desir- ing to be heard at each hearing, andior desiring to submit written statements before the conclusion of each hear- lng. Each hearing will not start carter than designated above, l~ifes are avail- able for review during regular busi- ness hours and prior to the day of the hearing. If you have questions, please do not hesitate to contact our office at (631) 765-1809, or by emaih Linda. Kowalski@Town.So ut hold.ny, us. Dated: March 7, 2007. ZONING BOARD OF APPEALS JAMES DINIZIO, JR., CHAIRMAN By Linda Kowalski 54375 Main Road (Office Location) 53095 Main Road (Mailing Address) PO. Box 1179 Southold, Ny 11971-0959 8276 1T 3/15 LEGAL NOTICE SOUTHOLD TOWN ZONING BOARD OF APPEALS THURSDAY, MARCH 29, 2007 PUBLIC HEARING NOTICE IS HEREBY GIVEN, pursuant to Section 267 of the Town Law and Chapter 280 (Zoning), Code of the Town of Southold, the following public hearing will be held by the SOUTHOLD TOWN ZONING BOARD OF APPEALS at the Town Hall, 53095 Main Road, P.O. Box 1179, Southold, New York 11971-0959, on THURSDAY, MARCH 29~ 2007: 2:20 P.M. MARY ZUPA #6010. This is an Appeal for an Interpretation or other action, based on the Building Department's December 21, 2006 return of a building permit application to construct a single-family dwelling at 580 Basin Road, Southold; CTM 81- 1-16.7. The Board of Appeals will hear all persons, or their representatives, desiring to be heard at each hearing, and/or desiring to submit written statements before the conclusion of each hearing. Each hearing will not start earlier than designated above. Files are available for review during regular business hours and prior to the day of the hearing if you have questions, please do not hesitate to contact our office at (631) 765-1809, or by email: Linda. Kowalski@Town.Southold.ny.us. Dated: March 6, 2007° ZONING BOARD OF APPEALS JAMES DINIZIO, JR., CHAIRMAN By Linda Kowalski 54375 Main Road (Office Location) 53095 Main Road (Mailing Address) P.O. Box 1179 Southold, NY 11971-0959 · ZONINO BOARD OF APFEAI.8 TOWN O~ 80UTHOLD: NEW' YORK In thc Matter of thc Application of (lq ~"ae of Applicaats) CTIvl Parcel #1000- AFFIDA%TF OF MAILINGS COUNTY OF SUffOLK) STATE OF NEW YORK) Onthe /5 dayof~0, rc~ ,%C~..Q, Ipersoo~llyma~ledatheUnited Siaes Po~ Office in ..... N~w Yo~, by CER~.~D M~, 1~ RECENT ~Q~S 1~, a m~e ~- of ih6 a~ed M~ Notice in pm~d ~nvelo~s add~ ~ cmcnt o~cm sh.o~ on ~ c~em ~s~s~nt m~ vefifi~ from ~c offic~ r~s oR fie ~ me ~ Assessms, or ( ) ~un~ R~ P~e~, Offim . for ~'eQ~ pm~ny M~ich abu~ ~d is ~mss a ~bltc or phvBte s~ or v~hicular ~t~[~zy of r~ord. s~o~ding ~he applimt% pro~,. .. Sworn to befog me this '~ day of/1,w,~4--. ,200 7 [~:)TARY PUBLIC, State of New YoI~ No. 52-4622371 -- - -- \ ~ualified in Suffolk ~ tN~tary eubli~) \7,,,. ~ ~:.~--.~ ~ PLEBE list, on ~c ba~ offs Affi~t or on a she~ of pa~r ~e iol humors ne~ to ~c LEGAL NOTICE SOUTHOLD TOWN ZONING BOARD OF APPEALS THURSDAY, MARCH 29, 2007 PUBLIC HEARING NOTICE IS HEREBY GIVEN, pursuant to Section 267 of the Town Law and Chapter 280 (Zoning), Code of the Town of Southold, the following public hearing will be held by the SOUTHOLD TOWN ZONING BOARD OF APPEALS at the Town Hall, 53095 Main Road, P.O. Box 1179, Southold, New York 11971-0959, on THURSDAY~ MARCH 29~ 2007: 2:20 P.M. MARY ZUPA #6010. This is an Appeal for an Interpretation or other action, based on the Building Department's December 21, 2006 return of a building permit application to construct a single-family dwelling at 580 Basin Road, Southold; CTM 81- 1-16.7. The Board of Appeals will hear all persons, or their representatives, desiring to be heard at each hearing, and/or desiring to submit written statements before the conclusion of each hearing. Each hearing will not start earlier than designated above. Files are available for review during regular business hours and prior to the day of the hearing If you have questions, please do not hesitate to contact our office at (631) 765-1809, or by emall: Linda. Kowalski~Town.Southold.ny.us. Dated: March 6, 2007. ZONING BOARD OF APPEALS JAMES DINIZlO, JR., CHAIRMAN By Llnda Kowalski 54375 Main Road (Office Location) 53095 Main Road (Mailing Address) P.O. Box 1179 Southold, NY 11971-0959 ~ward Boyd P.O. Box 1468 Southold, NY 11971 I000-81-1-8 Donna Mortimer 3985 Paradise Point Road Southold, NY 11971 1000-851-1-7 Stephen Koyler 24 Gramercy Park South New York, NY 10003 1000-81-I-9&10 Ronald Hermance 327 McKinley Place Ridgewood, NJ 07450 1000-81-1-16.8 Basin Road Realty Trust 35 Tremont Street Maynard, MA 01754 1000-81-I-17 Stephen Pen'icone 1205 Tuthill Rd. Ext. Southold, NY 11971 1000-81-1-16.12 Victor J & Mary S Zupa 4565 Paradise Point Road Southold, NY 11971 1000-81-1-13.1 Town of Southold PO Box 1179 Southold, NY 11971 1000-81-1-16.10 ZONING BOARD OF APPEALS TOWN OF SOUTHOLD: NEW YORK In the Matter of the Application of Regarding Posting of Sign upon pphoant s Land Identified as 1000- COUNTY OF SUFFOLK) STATE OF NEW YORK) AFFIDAVIT OF SIGN POSTING /ff. x/.: [ Iq O [ _, New York, being duly sworn, depose and say that: Onthe o2.vvz -~day of fi~/]/LC./-/ ,,:2,~?, Ipersonally placed theTown's official Poster, with the date of hearing and nature of my application noted thereon, securely upon my property, located ten (10) feet or closer from the street or right-of-way (driveway entrance) - facing the street or facing each street or right-of-way entrance;* and tlmt / I hereby confirm that the Poster has remained in place for seven days prior to tlc/at date of the subject hearing date, wh/ch hear/ng date was shown to be .fi~/bP,_Cff o~, O..o',v 7 . ! Sworn to before me th/s day ofl~cffc-~ ,200 ~1 Commissk:m Exl)kes Aixfl 16, 200~ *near the entrance or driveway entrm~ce of my properly, as the area most visible to passersby. ~ : ¢ HE~IRH~ F~X HO. : G31-B7B-B951 Mar. ~ 2B87 10:41AM P2 Total Postage & Faa* J (~ ~r~. ~f sent ro Edward Boyd ~;o~:~:-~u?" P.O. Box 1468 o,,OBo~No. Southold, NY 11971 03/13/2d)07 J RI[18Effil]~I N3 07~50 Return Receipt Fe~ J~ ~' ~ ~..'~1 iaiHere (Endorsemen~ Required Total Pos~ge P - ~ *~.~ 03/13/~7 Ron~d ~s~, ~ 327 McKi~ey Place ~o'~o. R~dgewood, NJ 07450 sobg~oLD N~ 11971 Certified Fee Stephen Perricone 1205 Tuthill Rd. Ext. o,~,oso,,o Southold, NY 11971 03113/2007 (Endorsement Required) Total Postage & Faa. ~0.39 $1.85 Sa., ro Town of Southol [~¢~;~m:~=' P.O. Box 1179 uthold, NY 11971 m Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delive~ Fee Basin Road RealW T~t 35 Tremont Street Mayn~d, ~ 01754 Postage Ceriified Fee Return Receipt Fee (Endorsement Required) Restricted Deliveny Fee (Endorsement Required) ~s~.~ ro Stephen Koyler ~/~:;4,~:~o.." 24 Gramercy Park South ~_~o~j?:.... New York, NY 10003 · Complete items 1, 2, and 3. Also complete it~rn 4 if Restricted Delivery Is desired. · Print your name and address on the reverse so that wa can retum the card to you. · Attach this card to the beck of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~ address diffem~a from item 1 ? if YES, enter dalivery address below: r'l Addre~eee [] No Tow~of Southold p. Lh. Box 1179 Southold, NY 11971 3. Service Type q~Ll~erflfled Malt [] Express Mall [ t-I Registered [] Return Receipt for Merchand}se I [] Insured Mall [] C.O'D. ~] 4. Restricted Delivery? (Extra Fee) [] Yes 2. Article Number rr~.eoa~s~t~0 7001 2510 0004 1873 2962 PS Form 3811, February 2004 Domestic Return Receipt · Complate Rems 1, 2, and 3. Alan complete item 4 If Restricted Delivery is desired. [] Agent · Print your name and address on the reverse [] Addressee so th at we can return the cad to you. by(Printed Name) · Attach this card to the back of the mailplece, or on the front if space permits. Bhasih Road Realty Trust 35 Tremont Street ': Maynard, MA 01754 s. Mall [] Express Mall p'Reglstef~::[ D Return Recalpt for Merchandise ri ~ r'l ,nsurad Mall []C.O.D. ~.~.~o~7~001 2510 0004 1873 2979 PS Form 381 1..February 200~.':-., ', Domestic Return Receipt 102S~o-02-M-1S40, · Complete items 1, 2, and 3. Also complete Rem 4 If Restricted Delivery Is desired. · Print your name and address on the reverse so that we can retum the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. Is daliva3 If YES, enter dallvep Stephen Perricone 1205 Tuthill Rd. Ext. Southold, NY 11971 2. ~1 Mall [] ~ Malt md [] Return Receipt for Merchandise [] Insured Mall [] C.O.D. []Yes PS Form ;5~'1 'l, February 2004 uom~o h~e~Jrn ~lp[ ,02595-O2-M-1540 F'R[~ : C HE~IPP40 INC fax NO. : 631-8'78-8951 I0,39 0901 Return Receipt Fee /q,ig~j/~ '" ~Here m ~.~ &~-~7~,~-' 3985 P~adise Point Road ~ [o/~;.~.%.; Southold, NY 11971 Certified Retu n Receipt ~ !~-.~.;~- Victor 3. & Mary S. Zupa , .~.~v~--a~:- 4565 paradise Point Road ' t~r~.'; ?_o:i'_. Southold, NY 11971 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. · Print your name and address on the reveme so that we can return the card to you. · Attach this card to the back of the mfdlpiane, or on the front if space permits. 1. ArticleAddmssed to: Edward Boyd P.O. Box 1468 · Southold, NY 11971 -I~.R~(}PrI~--' Name)~ C. Date of Delivery ~y~ ~;~? [] Y~ ~ In~ M~I 0 C.O.D. 4. Restricted Delivery? ~ Fee) 0 Ye~ 2. Article Number 7001 2510 0004 1873 3037 PS Form 3811, February 2004 Domestic Return Rsceipt -- 1. Article AcldreSs~ to: ' Ronald Hermance 327 McKinley Place , Ridgewo .og, NJ 07450 ~1 ~'~ Number 7 0 01 . PS Form 3811, February 2004 [~f,.Ceratled Mall [] E~ Mall [~1 R~l~te~:l [] Return Receipt for Memhandlse FI InaJ'KI Mall [] 0.0.0. 4. ReMga~m:l De#vee~ ~dm Fee) OYe~ 2510 0004 1873 3020 ¥ D.a6~J-; Return Receipt · Complete items 1, 2, and 3. Also complete item 4 if RestrlctedDelivery is desired. · Print youLname and address on the reverse so that we can return the ca~l to you. · Attach this cand to the back of the maiipisoe, ~or on the front if space permits. 1.~l~tJcle Addressed to: ~onna Mortimer 3i985 Paradise Point Road Southold, NY 11971 2. Article Number V,.,o;o, Vom s~,v~ ~b~O 7001 ! PS Form 3811, February 2004 Signature D Agent X [] Addressee Ptfntsd Name) [ C. Date of Delivery 9 I ~ed Mall [] Express Mall I ~ Registered [] Return Receipt fo~ Melcha~ldiSe l [] Insured Mall i-I C.O.D. . ~ 4. Restricted Dalive~? (Extra Fes) [] yes 2510 0004 1873 3006 Domestic Return Receipt NOTICE OF HEARING The following application will be heard by the Southold Town Board of Appeals at Town Hall, 53095 Main Road, Southold: NAME: ZUPA, M. #6010 MAP #: 81-1-16.7 APPEAL: Interpretation or Other Action REQUEST: Building Permit/Construction DATE: THURSDAY, MAR. 29, 2:20 PM If you are interested in this project, you may review the file(s) prior to the hearing during normal business days between 8 AM and 3 PM. ZONING BOARD-TOWN OF SOUTHOLD 765-1809 ZONING BOARD OF APPEAL~="' MAILING ADDRESS and PLACE OF HEARINGS: 53095 Main Road, Town Hall Building, P.O. Box 1179 Southold, NY 11971-0959 (631) 765-1809 Fax 765-9064 LOCATION OF ZBA OFFICE: Town Hall Annex at North Fork Bank Building, 1st Floor 54375 Main Road and Youngs Avenue, Southold website: http://southtown.northfork.net March 6, 2007 Re: Town Code Chapter 55 - Public Notices for Thursday, March 29, 2007 hearing Dear Sir or Madam: Please find enclosed a copy of the Legal Notice describing your recent application. The Notice will be published in the next issue of the Times Review newspaper. 1) Before March ~14th: Please send the enclosed Legal Notice, with both a Cover Letter including your telephone number and a copy of your Survey or Site Plan (filed with this application) which shows the new construction area or other request, by CERTIFIED MAIL, RETURN RECEIPT REQUESTED, to al.~l owners of property (tax map with property numbers enclosed), vacant or improved, which abuts and any property which is across from any public or private street. Use the current owner name and addresses shown on the assessment rolls maintained by the Town Assessors' Office located at Southold Town Hall, or Real Property Office at the County Center, Riverhead. If you know of another address for a neighbor, you may want to send the notice to that address as well. if any letter is returned to you undeliverable, you are requested to make other attempts to obtain a mailin.q address or to deliver the letter to the current owner, to the best of your ability, and to confirm how arran.qements were made in either a written statement, or durin.q the hearinq, providinq the returned letter to us; AND not later th~n March 15th: please either mail or deliver to our office your Affidavit of Mailin.q (form enclosed) with parcel numbers, names and addresses noted, and furnish it to our office with the white receipts postmarked by the Post Office. When the green signature cards are returned to you by the Post Office, please mail or deliver them to us before the scheduled hearing. If any signature card is not returned, please advise the Board during the hearing and provide the card (when available). These will be kept in the permanent record as proof of all Notices. 2) Not Later March 19th: please make arrangements to place the enclosed Poster on a signboard such as cardboard, plywood or other material, posting it at your property for seven (7) days (or more) until the hearing is held. Securely place the sign on your property facing the street, no more than 10 feet from the front property line bordering the street. If you border more than one street or roadway, an extra sign is available for the additional front yard. Please deliver your Affidavit of Postinq during the meeting. If you are not able to meet the deadlines stated in this letter, please contact us promptly. Thank you for your cooperation. Very truly yours, Zoning Appeals Board and Staff Encls. COURTHOUSE CORPORATE CENTER 320 Carleton Avenue, Suite 6800 Central Islip, New York 11722 PHONE: (631) 232-0363 FAX: (631) 8350 1 8 2007 January 16, 2007 Mr. James Dinizio, Chair Southold Zoning Board of Appeals 53095 Main Road P.O. Box 1179 Soutbold, New York 11971-0959 Re; Appeal of Mary S. Zupa 580 Basin Road (SCTM 1000.81.1.16.7) Dear Mr. Dinizio: PH:ad Please be advised that I have been retained to represent Mary Zupa in her appeal in the captioned matter. Accordingly, it is requested that I be given the opportunity to address the Board when the matter is next scheduled. Notification of the date and time would be most appreciated. FROM : RPM TECHNOLOGY FAX NO. : 516 567 8841 ID, o ~r~t ~ oP I. 27 2807 09:05AM P1 Zop~ H~v~~ MY Sup~b~? $OoT~ouO SAViNGs BANK Sotlthol~ N,Y; 1!97! ~ 2~i 200? l~ to emlorS~ the aPPlic~on ~ Mm'Y ~fora buil~ pem~t ~ ~a single- ~ami!Y d~?ling at 580 B~ Road, Southold. I am a neigh°r and welcom~ tl~ idea ~a a house wiil be con.~uctCd on the proposed ~e. C~airma~, ~t ~ CEO Wlavr $0 C~:NvFt~g'f RO~,D · P~.~tU~, b,~J 076~2~1475 *~1 ~967A900 Office Location: Town Annex/First Floor, North Fork Bank 54375 Main Road (at Youngs Avenue) Southold, NY 11971 http://southoldtown.northfork.net BOARD OF APPEALS TOWN OF SOUTI-IOLD Tel. (631) 765-1809 Fax (631) 765-9064 Mailing Address: 53095 Main Road P.O. Box 1179 Southold, NY 11971-0959 March 12, 2007 Mark Terry, Senior Environmental Planner LWRP Coordinator Plarming Board Office Town of Southold Town Hall Annex Southold, NY 11971 Re: ZBA File Ref. No. 6010 (Zupa) Dear Mark: We have rcccived an application for a reversal of the Building Department's rejection of an application to construct a home at the Zupa premises at 580 Basin Road, SouthoId. Copies of the LWRP form and area map are also attached for your use and reference. May we ask for your assistance in an evaluation and recommendations for this proposal. Thap, k you. Very truly yours, JAIvIES DINIZIO, JR. By:_ COURTHOUSE CORPORATE CENTER 320 Carleton Avenue, Suite 6800 Central Islip, New York 11722 January 16, 2007 PHONE: (631} 232-0363 FAX: (631) 8350 JAN 1 it 2007 Mr. James Dinizio, Chair Southold Zoning Board of Appeals 53095 Main Road P.O. Box 1179 Southold, New York 11971-0959 Re: Appeal of Mary S. Zupa 580 Basin Road (SCTM 1000.81.1.16.7) Dear Mr. Dinizio: PH:ad Please be advised that I have been retained to represent Mary Zupa in her appeal in the captioned matter. Accordingly, it is requested that I be given the opportunity to address the Board when the matter is next scheduled. Notification of the date and time would be most appreciated. January 26, 2007 Linda: Attached are 7 copies of the ZBA appeal papers already filed, and an original and 7 copies of the LWRP. Mary/_~and I appreciate your help. Vic SOUTHo/~ 2.8A(c) Real Property Tax Service Age~y T~IN ~ SOUTNOLD