13 BURKE STREET - BUILDING JACKET 3 ��� 1l� S�re�-�
geN111T�
�,�tnlweoo�
ELIZABETH M. RENNARD CITY OF SALEM
JERALD A. PARISELLA
City Solicitor KIMBERLEY L. DRISCOLL, MAYOR Assistant City Solicitor
93 Washington Street One School Street
Salem, MA 01970 Beverly, MA 01915
Tel: 978.619.5631 LEGAL DEPARTMENT Tel:978.921.1990
Fax: 978.744.1279 93 WASHINGTON STREET Fax:978.921.4553
Email: brennard@salem.com SALEM, MASSACHUSETTS 01970 Email:jap@alexandedemino.com
TO: Thomas St. Pierre Q
FROM: John P. Bosse, Esq. and Jerald A. Parisella, Esq
RE: Lot Split by Municipal Boundary
DATE: November 8, 2007
FACTS
You have requested an opinion from the solicitor's office regarding what zoning
relief is available to the owner of real property which straddles the line dividing Salem
and Peabody. This opinion is based on these facts as presented to the solicitor's office.
The property is located at 13 Burke Street in Salem but also has a portion of it located in
Peabody. The property in Salem is in the R-I zoning district, which allows only single-
family residences, while the portion of the Peabody lot is zoned for two-family use. The
owner wishes to convert the home to a two-family dwelling and is seeking zoning relief
in Salem.
ISSUE
Whether the Salem ZBA may grant the real property owner a variance from
single-family use to two-family use for the portion of the property located in Salem.
ANALYSIS
Permitted Use
The City of Salem's Zoning Ordinance provides that detached single-family
dwellings are a permitted use within single-family residential districts. Salem Zoning
Ordinance Art. V, Sec. 5-2. Conversely, Sec. 5-2 of the Salem Zoning Ordinance does
not provide for two-family use within a single-family residential district. Additionally,
Art. V, Sec. 5-3 of the Salem Zoning Ordinance does not provide for two-family use
within a single-family residential district by special permit.
"Unlike prior nonconforming uses, which originated as legal uses of property,
uses within a variance only become legal with the permission of the permit granting
authority." Mendoza v. Licensing Board of Fall River, 444 Mass. 188, 207 (2005).
"Variances allowing nonconforming uses should be unusual because they are individual
waiver of local legislation." Id. at 207. In a footnote, Mendoza states:
"Although all variances are unusual forms of relief from zoning requirements, use
variances should be particularly extraordinary because they inherently undermine
the local zoning ordinance's division of uses. See M. Bobrowski, Massachusetts
Land Use and Planning Law § 8.04, at 261 (2d ed. 2002) ("Use variances...are
greatly disfavored"). General Laws c. 40A, § 10, bars zoning variances for
nonconforming uses unless specifically authorized by the local zoning ordinance."
Id. at 208, n. 23.
In the case at hand, the Salem Zoning Ordinance does not authorize two-family
use within a single-family residential district. If the Salem ZBA ("ZBA") were to grant
the petition for a use variance, the ZBA would be waiving the permitted uses under a
single-family residential district. As a result, the ZBA should deny the property owner's
request for a use variance.
Split Municipal Lot
In Beale v. Planning Bd. of Rockland,the plaintiff("Beale") sought approval
from the planning board of Rockland for a definitive subdivision plan that would extend
an existing road in the town of Rockland into the town of Hingham to provide access for
a proposed retail shopping center in Hingham. 423 Mass. 690, 691 (1996). The land in
Rockland for the access road was located within an "Industrial Park I-2" district, and the
Rockland zoning by-law did not allow retail sales generally in the I-2 district. Id. at 691-
692. The planning board of Rockland in denying Beale's application for approval of the
subdivision, concluded that"as to the land in Rockland, retail shopping center use would
violate the use requirements of the applicable zoning district under the Rockland zoning
by-law." Id. at 691. Beale appealed to the Land Court, where a judge upheld the
decision of the planning board. Id. at 691.
On direct appellate review from the judgment of the Land Court,the Supreme
Judicial Court stated that"The judge correctly interpreted the Rockland zoning by-law as
prohibiting retail uses in the I-2 zone, based upon the absence of such uses from the list
of permitted uses in the zone and the express allowance of such uses in Rockland's
business zoning districts." Id. at 693. In the present case, the Salem Zoning Ordinance
prohibits two-family use within a single-family residence zone, based upon the absence
of such use from the list of permitted uses in the zone and the express allowance of such
use in Salem's two-family zoning district. Salem Zoning Ordinance Section 5-2.
2
A
"Use of land in one zoning district for an access road to another zoning district is
prohibited where the road would provide access to uses that would themselves be barred
if they have been located in the first zoning district." Beale, 423 Mass. at 694 (1996).
While the case at hand does not involve the use of an access road, it does concern the use
of land located within a single-family district in Salem for proposed two-family use. The
land in Salem should not be allowed for two-family use, despite the fact that the portion
of the land in Peabody allows for such use. For the ZBA to allow for two-family use
within a single-family zoning district would run contrary to the holding that"a
municipality ought to be accorded the right to carry out the policies underlying its zoning
ordinance or by-law with respect to the actual uses made of land within its borders." Id.
at 694, quoting Burlington Sand & Gravel, Inc. v. Harvard, 26 Mass.App.Ct. 436, 439
(1988).
As the Court held in Beale, the potential indirect impact of a board's decision
upon the use of the land does not prevent a municipality from enforcing its own zoning
by-law with respect to the land within its boundaries. "Where a parcel of land lies in two
municipalities, each may apply its zoning laws to the portion that lies within its
boundaries." Beale, 423 Mass. at 698 (1996). Similar to the Supreme Judicial Court's
reasoning in Beale, the impact of the ZBA's decision upon the use of the land in Peabody
does not prevent the ZBA from enforcing its own zoning ordinance with respect to the
land in Salem.
See also Town of Brookline v. Co-Ray Realty Co., 326 Mass. 206 (1950). In this
case the developer proposed to build an apartment (permitted in Boston) and use the
Brookline land for access (apartment not permitted in the Brookline district). The project
was denied because the use was not permitted in Brookline.
Substantial Hardship
Restricting the property owner to single-family use does not prevent all use of the
property in question resulting in a substantial hardship. By contrast, the property owner
can continue to use the property for single-family use, which is permissible under the
Salem Zoning Ordinance. Cf. Beale, 423 Mass. at 699-700 (1996).
CONCLUSION
The Salem ZBA should deny the property owner's petition for a use variance in
order to convert a single-family dwelling into a two-family dwelling for the following
reasons:
1. Two-family use is not permitted within a single-family residential district,
and allowing such nonconforming use would be a waiver of local
legislation. Mendoza v. Licensing Board of Fall River, 444 Mass. 188,
207 (2005).
3
2. The Salem ZBA has the right to enforce its own zoning ordinance with
respect to the land in Salem. Beale v. Planning Bd. of Rockland, 423
Mass. 690, 698 (1996).
3. The property owner will not incur a substantial hardship with respect to
the use of his land, as he may continue to use such land for a single-family
dwelling. Cf. Beale v. Planning Bd. of Rockland, 423 Mass. 699-700
(1996).
4