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5 COLUMBUS SQUARE - ZBA (002) 5 Columbus Square (R-1 ) William & Louise Pelletier � "a\1 ` UIf of " cWp ' ���iZI55ttC lISPttg CIT' , "CE DECISION ON THE PETITION OF WILLIAM & LOUISE PELLETIER REQUESTING THE BUILDING INSPECTOR HAVE THE BOAT CRADLES REMOVED FROM THE TIDAL FLATS IN FRONT OF 5 COLUMBUS SQUARE (R-1 ) A hearing-on this petition was held on September 19, 1984 with the following Board Members present: James Hacker, Chairman; Messrs. , Gauthier, Luzinski, Strout, and Associate Member Bencal. Notice of the hearing was sent to abutters and others .and notices of the hearing were properly published in the Salem Evening News in accordance with Massachusetts General Laws Chapter 40A. The Petitioner is requesting the Board of Appeal have the Building Inspector order the removal of the boat cradles from the tidal flats in front of 5 Columbus Sq. (R-1 ) . Mr. Peter Haywood is the owner of the boat cradles. After careful consideration and thoughtful deliberation, the Board of Appeal, by a vote of four to one, Mr. Gauthier voting present, voted to uphold the Building Inspectors decision. This decision is based on the following terms and conditions: 1 . No more than sixty (60) boat cradles are to be floated at one time; 2. They are to be floated in the position shown in a photograph displayed by Mr. Haywood showing the relative position and egress for small crafts to the shore. Said photograph was taken approximately 1950. James B. Hacker, Chairman A COPY OF THIS DECISION HAS BEEN FILED WITH THE PLANNING BOARD AND 'CITY CLERK APPEAL FP.O'A THIS DECISIDF7. 'F ANY, SHALL BE %:ADE PO'SUANT TO SECTION 17 OF THE MASS. GENERAL LA71S, C-APT_R SDE. AND SHALL EE F:LEO 6!THIN 20 DAPS AFTER THE DATE OF FILING OF THIS D'cCiS!CY I:4 THE C'ICE CP THE CITY CLERK. P j i T TD WAS_ GENT IU L:a'C. C11A.PTER EDE, '•:CT:j;; 71. THE VARIANCE OR SPECIAL PERMIT CRA:I"E:) Hcf:E::;. EHG.LL P: -­i EFFECT UNTIL A CE:PY OF THECLCIEI;(I, EC ?;iG THE CERT• _ ,. I-) NO A?PEAL HAS L-_EN FILED, FlCkil,i\ CF 1HC '17y .u_c: ir4:: ,. DA.. HAS- ELb- .T_ D E OR THS' IF 'JA! i' APPE;_ F. E F!.E. -n' IT H S LEEN C n "! c.D OR a-;;TED IS RECL-F:? IN THE S H ESSEX OF CccS A4.D INDEXED UFEcd THE NA -E OF THE OV.'NER OF RECORD OR IS RECORDED AND NO1ED ON THE OWNER'S CERTIFICATE OF TITLE. BOARD OF APPEAL COMMONWEALTH OF •MASSACHUSETTS ESSEX, SS. CITY OF SALEM BOARD OF APPEALS WILLIAM PELLETIER and LOUISE PELLETIER, , . Plaintiffs, -vs- MEMORANDUM IN SUPPORT OF WINTER ISLAND YACHT YARD RICHARD T. MCINTOSH, Building Inspector and Zoning Enforcement Officer, Salem, Massachusetts, and PETER S. HAYWOOD d/b/a WINTER ISLAND YACHT YARD, Defendants. STATEMENT OF FACTS Since 1926, a boat yard has been operating on the property on which the Winter Island Yacht Yard now operates . The boat yard is a nonconforming use under G. L. c. 40A, S. 6, and the Salem -Zoning Ordance , Section VIIC. The Salem Zoning Ordinance defines a waterfront boat yard as an open area where boats may be stored and repaired. The plaintiffs purchased a home next to the Yacht Yard in 1964. The defendant, Peter S. Haywood, purchased the Yacht Yard in November, 1979. Almost all boats today are fiberglass. At about the beginning of 1984, the plaintiffs complained to the Zoning Enforcement Office of the City of Salem, Richard T. McIntosh, that the defendant was violating his nonconforming use by fiberglassinq boats on the property and storing boat cradles on the property. On April 20, 1984, Mr. McIntosh responded that the nonconforming use of the property as a boat yard may be continued, and that the fiberglassing of boats and storage of boat cradles were part of the nonconforming use (see appended letter) . I. THE DEFENDANT HAS NOT EXCEEDED ITS VALID NONCONFORMING USE. The plaintiffs and the defendant here agree that the defendant has had a valid nonconforming use as a boat yard, but the plaintiffs contend !, that the defendant has "exceeded the scope" of that use. The court in Powers v. Building Inspector of Barnstable, 363 Mass. , 648, 653, 296 N. E. 2d 491, 495 (1973) , set out a three-pronged test of whether a defendant has exceeded a nonconforming use. Finally, in Bridgewater v. Chuckran, 351 Mass. 20, we said, at 23: "Recent cases have emphasized three tests for determining whether current use of property fits within the exemption granted to nonconforming uses. (1) Whether the use reflects the "nature and purpose" of the use prevailing when the zoning by-law took effect . . . . . . (citations omitted) . (2) Whether there is a difference in the quality or character, as well as the degree, of use . . . (citations omitted) . (3) Whether the current use is ' different in kind in its effect on the neighborhood. ' (citation omitted) . In the case at hand, there has been no change in the quality or character of the use of the Winter Island Yacht Yard. Since 1926 , the defendant, Haywood, and his predecessors have been in the business of building, repairing and storing boats . The defendant, Haywood, is still in the business of building, repairing and storing boats, and the plaintiffs complain of no other activities. Because the defendant' s use is nonconforming does not mean it is static. Implicit in the use of the land for a boat yard business is the necessity of keeping pace with technology; if the defendant was allowed to repair wooden boats only, the defendant would be out of businesss since wooden boats are rare today. The character of the use does not change solely by reason of an advance in technology. Vdayland V. Lee, 325 Mass. 637, 91 N. E. 2d 835 (1967) (where printing had been allowed under the nonconforming use, the employment of an automatic printing press did not exceed the use) ; Berliner v. Feldman, 363 Mass. 767, 298, N. E. 2d 153 (1973) (an inn, operating under a nonconforming use, which installed insulation, heat, modern plumbing, did not exceed the use) . The fact that improved and more efficient instrumentalities are utilized in pursuit of the use does not exclude it from the category of an "existing use, " provided these are ordinarily and reasonably adapted to make that use available to the owner, and the original- nature and purpose of the under- taking remain unchanged. " Wayland v. Lee, 325 Mass. 637, 643, quoting from De Felice V. Zoning Bd. of Appeals of East Haven , 130 Conn. 156, 162. And, again, because the defendant's use is nonconforming does not mean it is static. Implicit in the nature of the use of the land for a boat yard business is that the proprietor will try to expand the volume of business. Cases are legion which state that intensification of nonconforming use does not exceed the use. Board of Selectmen of Blackstone v. Tellestone, 4 Mass. App. Ct. 311, 348, N.E. 2d 110 (1976) (it was error for lower court to limit the nonconforming uses to' which the property has always been put -- storage and repair of vehicles and a handyman' s business -- even though the business had grown) ; Building Commission of Medford v. McGrath, 312 mass. 461, 45 N. E. 2d 265 (1942) (more horses being kept at a riding school) ; McAlleer et al v. Board of Appeals of Barnstable, 361 Mass. 317, 280 N.E. 2d 166 (1972) (hotel being used year round rather than seasonally) ; Cochran et al. v. Roemer et al. , 287 Mass . 500, 192 N. E. 58 (1933) (fuel company business greater in volume and conducted by different methods) ; Sullivan v. Board of Appeals of Harwich, 15 Mass . App. Ct. 286, 445 N. E. 2d 174 (1983) ; Building Inspector of Seekonk v. Amaral et al. , 9 Mass. App. Ct. 869, 401 N.E. 2d 158 (1980) (defendant's junk yard was not limited to four or five cars , the highest number allowed at the time of the creation of the nonconforming use) ; Jahnigen v. Staley, 225 A. 2d 277 (Md. 1967) (number of boats on defendant's wharf increasing greatly, volume of cars on defendant' s lot increasing from a few to thirty or forty did not exceed nonconforming use) . The defendant' s business activities do not exceed the nonconforming use. The plaintiffs complain of the following acts on the defendant's property: 1. storage of boat cradles ruined view from plaintiffs ' property; 2. storage of boat cradles block plaintiffs' marine access to their property; 3. repairing fiberglass boats; 4. building fiberglass boats; 5. stones falling from defendant' s retaining wall onto plaintiffs' property; 6. filling of land. 1. The plaintiffs have no right to a view from their home. Under Massachusetts law, "an easement of light and air can be acquired only by express grant, by covenant, or by implication where the light or air is actually and absolutely necessary. " Novello v. Capringo, 276 Mass. 193, 196, 176 N.E. 809, 809-810 (1931) . See also G.L. C. 187 , s . 1. 2. The plaintiffs state not that the boat cradles complained of are on the plaintiffs' property, but only that these cradles are on the tidal flats in front of the plaintiffs ' home. In Massachusetts , owners of land on seashore have title, subject to public right of navigation , fishing and fowling,. to low water mark or where tide ebbs more than th t distance to one hundred( rods from the high water mark. Op. Atty. Gen. , Jan. 11, 1963, p. 103; Opinion of the Justices to Senate, 383 Mass. 895, 424 N.E. 2d 1092 (1981) . Where the cradles are on lots vaned by the defendant, the plaintiffs must show that they use marine navigation to . get to their home, and in the big ocean how exactly their marine navigation is impeded by the defendants ' cradles, i.e. why they cannot go around the cradles. "In nuisance actions against private defendants it is (also) relevant, although not decisive, to compare the cost to the defendant of an injunctive remedy with the damage to the plaintiff. " Triangle Center, Inc. v. Department of Public Works, 386 Mass. 858, 864, 438 N.E. 2d 798 , 802 (1982) . The test is similar to that stated in the Restatement, 2d Torts, s . 826 and 829A. Section 826 states : An intentional invasion of another' s interest in the use and enjoyment of the land is unreasonable if (a) the gravity of the harm outweighs the utility of the actor' s conduct, or (b) the harm caused by the conduct is serious and the financial burden of compensating for this and similar harm to other would not make the continuation of the conduct not feasible. Section 829A states : An intentional invasion of another' s interest in the use and enjoyment of land is unreasonable if the harm resulting from the invasion is severe and greater than the other should be required to bear without compensation. r r t iI� t 1 fl q I Here, the plaintiffs complain that the defendant is repairing and i I libuilding fiberglass boats. See Francisco v. Department of Institutions i l and Agencies, 13 N.J. Misc. 663, 180 A. 843 (1935) (occasional unpleasant 11 ' jiodor not nuisance) . The defendant is in a business which has great ; social utility. If the defendant was not permitted to fiberglass boats Z' I ion his property, he would be out of business. )The defendant, Haywood, j I '!would lose his means of livelihood. The injury to the plaintiffs because Ilof the repair and occasional construction of fiberglass boats is slight; I � the injury the defendant would sustain in not being permitted to repair I', I and construct fiberglass boats is grave indeed. See Triangle Center, Inc. I� Iv. Department of Public Works, supra; Restatement, 2d Torts, s . 826. Ij 3. The defendant will gladly remove any stones from its retaining j '!wall which may have fallen onto plaintiffs' property. I I� jl i i �I I II I I` I II : Ii I; I� i I Ij �I F I I I i I i it COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. EOARD OF APPEALS WILLIAM PELLETIER, ET AL, Plaintiffs, -vs- RICHARD T. MCINTOSH., ET AL, Defendants. MEMORANDUM IN SUPPORT OF WINTER IS-LAND YACHT YARD LAW OFFICES OF ROBERT W.WELCH + AND WILLIAM J. LUNDREGAN K 221 ESSEX STREET SALEM,MA COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. - CITY OF SALEM BOARD OF APPEALS WILLIAM PELLETIER and LOUISE PELLETIER, Plaintiffs, - -vs- MEMORANDUM IN SUPPORT OF WINTER ISLAND YACHT YARD RICHARD T. McINTOSH, Building Inspector and Zoning Enforcement Officer, Salem, Massachusetts, and PETER S. HAYV700D d/b/a WINTER I ISLAND YACHT YARD, Defendants. STATEMENT OF FACTS Since 1926, a boat yard has been operating on the property on which the Winter Island Yacht Yard now operate s. •The boat yard is a nonconforming use under G.L. c. 40A, s. 6, and the Salem Zoning Ordance, Section VIIC. The Salem Zoning Ordinance defines a waterfront boat yard as an open area where boats may be stored and repaired. The plaintiffs purchased a home next to the Yacht Yard in 1964. The defendant, Peter S. Haywood, purchased the Yacht Yard in November, 1979. Almost all boats today are fiberglass. At about the beginning of 1984, the plaintiffs complained to the Zoning Enforcement Office of the City of Salem, Richard T. McIntosh, that the defendant was violating his nonconforming use by fiberglassing boats on the property and storing boat cradles on the property. On April 20, 1984, Mr. McIntosh responded that the nonconforming use of the - property as a boat yard may be continued, and that the fiberglassing of boats and storage of boat cradles were part of the nonconforming use (see appended letter) . I. THE DEFENDANT HAS NOT EXCEEDED ITS VALID NONCONFORMING USE, _ The plaintiffs and the defendant here agree that the defendant has had a valid nonconforming use as a boat yard, but the plaintiffs contend that the defendant has "exceeded the ,scope" of that use. f i The court in Powers v. Building Inspector of Barnstable, 363 Mass. 648, 653, 296 N.E. 2d. 491, 495 (.1973) , set out a three-pronged test of whether a defendant has exceeded a nonconforming use. Finally, in Bridgewater v. Chuckran, 351 Mass. 20, we said, at 23: "Recent cases have emphasized three tests for determining whether current use of property fits within the exemption granted to nonconforming uses. (1) Whether the use reflects the "nature and purpose" of the use prevailing when the zoning by-law took effect . . . . . . (citations omitted) . (2) Whether there is a difference in the quality or character, as well as the degree, of use (citations omitted) . (3) Whether the current use is ' different in kind in its effect on the neighborhood. ' (citation omitted) . In the case at hand, there has been no change in the quality or character of the use of the Winter Island Yacht Yard. Since 1926, the defendant, Haywood, and his predecessors have been in the business of building, repairing and storing boats. The defendant, Haywood, is still in the business of building, repairing and storing boats, and the plaintiffs complain of no other activities. Because the defendant's use is nonconforming does not mean it is static. Implicit in the use of the land for a boat yard business is the necessity of keeping pace with technology; if the defendant was allowed to repair wooden boats only, the defendant would be out of businesss since wooden boats are rare today. The character of the use does not change solely by reason of an advance in technology. Wayland v. Lee, 325 Mass. 637, 91 N.E. 2d 835 (1967) (where printing had been allowed under the nonconforming use, the employment of an automatic printing press did not exceed the use) ; Berliner v. Feldman, 363 Mass. 767, 298, N.E. 2d 153 (1973) (an inn, operating under a nonconforming use, which installed insulation, heat, modern plumbing, did not exceed the use) . The fact that improved and more efficient instrumentalities are utilized in pursuit of the use does not exclude it from the category of an "existing use, " provided these are ordinarily and reasonably adapted to make that use available to the owner, ,and the original nature and purpose of the under- taking remain unchanged. " Wayland v. Lee, 325 Mass. 637, 643, quoting from De Felice v. Zoning Bd. of Appeals of East Haven, 130 Conn. 156, 162. And, again, because the defendant's use is nonconforming does not mean it is static. Implicit in the nature of the use of the land for a boat yard business is that the proprietor will try to expand the volume of business. Cases are legion which state that intensification of nonconforming use does not exceed the use. Board of Selectmen of Blackstone v. Tellestone, 4 Mass. App. Ct. 311, 348, N.E. 2d 110 (1976) (it was error for lower court to limit the nonconforming uses, to which the property has always been put -- storage and repair of vehicles and a handyman' s business -- even though the business had grown) ; Building Commission of Medford v. McGrath, 31'2 Mass. 461, 45 N.E. 2d 265 (1942) (more horses being kept at a riding school) ; McAlleer et al v. Board of Appeals of Barnstable, 361 Mass. 317, 280 N.E. 2d 166 (1972) (hotel being used year round rather than seasonally) ; Cochran et al. v. Roemer et al., 287 Mass. 500, 192 N.E. 58 (1933) '(fuel company business greater in volume and conducted by different methods) ; Sullivan v. Board of Appeals of Harwich, 15 Mass. f 1 , App. Ct. 286, 445 N.E. 2d 174 (1983)_; Building Inspector of Seekonk v. Amaral et al. , 9 Mass. App. Ct. 869, 401 N.E. 2d 156 (1980) (defendant's junk yard was not limited to four or five cars, the highest number allowed at the time of the creation of the nonconforming use) ; Sahnigen v. Staley, 225 A. 2d 277 (Md. 1967) (number of boats on defendant's wharf increasing greatly, volume of cars on defendant's lot increasing . from a few to thirty or forty did not exceed nonconforming use) . The defendant' s business activities do not exceed the nonconforming use. Theplaintiffscomplain of the following acts on the defendant's property: 1. storage of boat cradles ruined view from plaintiffs ' property; 2. storage of boat cradles block plaintiffs' marine access to their property; - 3. repairing fiberglass boats; 4, building fiberglass boats; 5. stones falling from defendant's retaining wall onto plaintiffs' property; 6. filling of land. 1. The plaintiffs have no right to a view from their home. Under Massachusetts law, "an easement of light and air can be acquired only by express grant, by covenant, or by implication where the light or air is actually and absolutely necessary." Novello v. Capringo, 276 Mass. 193, 196, 176 N.E. 809, 809-810 (1931) . See also G.L. c. 187, s . 1. 2. The plaintiffs state not that the boat cradles complained of are on the plaintiffs' property, but only that these cradles are on the tidal flats in front of the plaintiffs' home. in Massachusetts, owners I f of land on seashore have title, subject to public right of navigation, fishing and fowling,. to low water mark or_,where tide ebbs more than that distance to one hundred rods from the high water mark. Op. Atty. Gen. , Jan. 11, 1963, p. 103; Opinion of the Justices to Senate, 383 Mass. 895, 424 N.E. 2d 1092 (1981) . Where the cradles are on lots owned by the defendant, the plaintiffs must show that they use marine navigation to get to their home, and in the big ocean how exactly their marine navigation is impeded by the defendants' cradles, i.e. why they cannot go around the cradles. "In nuisance actions against private defendants it is (also) relevant, although not decisive, to compare the cost to the defendant of an injunctive remedy with the damage to the plaintiff. " Triangle Center, Inc. v. Department of Public Works, 386 Mass. 858, 864, 438 N.B. 2d 798 , 802 (1982) . The test is similar to that stated in the Restatement, 2d Torts, s. 826 and 829A. Section 826 states : An intentional invasion of another's interest in the use and enjoyment of the land is unreasonable if (a) the gravity of the harm outweighs the utility of the actor's conduct, or (b) the harm caused by the conduct is serious and the financial burden of compensating for this and similar harm to. other would not make the continuation of the conduct not feasible. Section 829A states : - An intentional invasion of another's interest in the use and enjoyment of land .is unreasonable if the harm resulting from the invasion is severe and greater than the other should be required to bear without compensation. a Here, the plaintiffs complain that the defendant is repairing and building fiberglass boats. See Francisco v. Department of Institutions and Agencies, 13 N.J. Misc. 663, 180 A. 843 (1935) (occasional unpleasant odor not nuisance) . The defendant is in a business which has great social utility. If the defendant was not permitted to fiberglass boats on his property, he would be out of business. The defendant, Haywood, would lose his means of livelihood. The injury to the plaintiffs because of the repair and occasional construction of fiberglass boats is slight; the injury the defendant would sustain in not being permitted to repair and construct fiberglass boats is grave indeed. see Triangle Center, Inc. v. Department of Public Works, supra; Restatement, 2d Torts, s . 826. 3. The defendant will gladly remove any stones from its retaining wall which may have fallen onto plaintiffs' property. t a COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. BOARD OF APPEALS WILLIAM PELLETIER, ET AL, { Plaintiffs , i -vs- RICHARD T. MCINTOSH., ET AL, Defendants.. i MEMORANDUM IN SUPPORT OF WINTER ISLAND YACHT YARD i 1 LAW OFFICES OF ROBERT W.WELCH AND WILLIAM J. LUNDREGAN 221 ESSEX STREET SALEM,MA I Board of Appeal City of Salem Salem, MA 01970 Re: The undersigned hereby waives the time requirement, which the Board has to act on the above referenced petition under Massachusetts General Laws, Chapter 40A, Section 15. FAA J 1 WILLIAM J. LUNOREGAN ATTORNEY AT LAW 221 ESSEX STREET SALEM. MASSACHUSETTS 01970 744.0637 RESIDENCE 631-7323 � d