Glastonbury Affd. Hous. Dev. v. Town Coun., No. Cv94 0543581 (Sep. 4, 1996)

1996 Conn. Super. Ct. 5433-QQ
CourtConnecticut Superior Court
DecidedSeptember 4, 1996
DocketNo. CV94 0543581
StatusUnpublished

This text of 1996 Conn. Super. Ct. 5433-QQ (Glastonbury Affd. Hous. Dev. v. Town Coun., No. Cv94 0543581 (Sep. 4, 1996)) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Glastonbury Affd. Hous. Dev. v. Town Coun., No. Cv94 0543581 (Sep. 4, 1996), 1996 Conn. Super. Ct. 5433-QQ (Colo. Ct. App. 1996).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.]MEMORANDUM OF DECISION On May 27, 1994, the Glastonbury Housing Development, Inc. (GLAHD), filed an application for a zone change with the defendant, Town Council (Council), the zoning authority of the Town of Glastonbury. The legal owner of the property sought to be developed by GLAHD is the Carolyn L. Liebler Trust, Carolyn M. Bogue and Francis L. Liebler, Trustees. The property subject to the proposed zone change application consists of several parcels which total 26.43 acres, although the owners hold title to an additional 17 plus acres to the south of the subject premises which they intend to deed to the Town as open space. Some portions of the affected parcels are zoned as a "Planned Business and Development Zone," some as "Planned Industrial Zone," and some as "Flood Zone." GLAHD desires to change the bulk of the property to "Flood Zone" and the remaining 8.2 acres to "Residence A."

The application states that the reason for the requested change is to allow for development of an affordable housing proposal as a Planned Area Development (PAD) pursuant to § 4.12.3(c) of the Building Zone Regulations of the Town (Building Regulations). (ROR, Item I.I: Application for Zone Change, sub-item 1(a): Cover Letter.) GLAHD informed the Council that it planned to develop the subject property as "affordable housing" in accordance with § 8-30g of the General Statutes.

The Council held three public hearings on the zone change application and, on October 11, 1994, denied the application. The ten reasons the Council gave for its denial are as follows:

1. Use of the subject property for residential purposes CT Page 5433-RR is incompatible with surrounding industrial and commercial land uses and zoning[,] including an oil storage facility, three auto repair shops, and a truck rental operation. Additionally, there are no Residence A lands abutting the subject property.

2. The close proximity of the oil storage facility poses a potential safety hazard for future residents, with particular concern for residential development on the most westerly portion of the site.

3. Residential use of this property continues the pattern [sic] and would expand the imbalance of concentrating affordable housing within the Town Center (i.e., northwest quadrant of the Town).

4. The property as it exists today is predominantly within a flood hazard area. Although there is evidence that the area is capable of being removed from flood hazard, that capability has not been approved or implemented as of this date.

5. The change of 5.6 acres of Commercial and Industrial zoned land to Residence A would deprive the Town of one of the last undeveloped commercial parcels in that area of the Town Center.

6. There would be potential liability to the Town, if[,] being aware of flood and fire hazards to persons or property, it should approve this proposed residential development.

7. The proposal represents a destruction of an encroachment on the Flood Plain and the loss of productive farmland and would establish a dangerous precedent.

8. There would be a real flood hazard and danger to residents, the building and property.

9. In the event of a leak, spill[,] ignition and/or fire at the adjoining oil storage facility, future residents would be placed in a high[-]risk situation, jeopardizing their health and safety.

10. In view of the above factors, there is a real danger to health, safety and welfare of the future children and residents who would reside on this property.

(Return of Record (ROR), Item III.C: Minutes of October 11, 1994 CT Page 5433-SS meeting, pp. 14-15; Motion to Complete Record, dated June 26, 1996, Item 4, pp. 2-3.)

GLAHD filed this appeal alleging that the Council's denial of its application was illegal, arbitrary, an abuse of discretion and in violation of General Statutes § 8-30g.

A. THE STATUTORY SCHEME AND STANDING TO APPEAL

General Statutes § 8-30g, the Affordable Housing Land Use Appeals Act (Act), modifies the procedure of judicial review of certain land use appeals to the Superior Court. The land use appeals affected by § 8-30g are those in which the development proposed includes a certain percentage of "affordable housing" as defined by the Act.

An affordable housing development is defined as a "proposed housing development (A) which is assisted housing or (B) in which not less than twenty percent of the dwelling units will be conveyed by deeds containing covenants or restrictions which shall require that such dwelling units be sold or rented at, or below, prices which will preserve the units as affordable housing, as defined in section 8-39a, for persons and families whose income is less than or equal to eighty percent of the area median income, for at least twenty years after the initial occupation of the proposed development. . . ." General Statutes § 8-30g(a)(1).

An affordable housing application is defined as "any application made to a commission in connection with an affordable housing development by a person who proposes to develop such affordable housing. . . ." General Statutes § 8-30g(a)(2). The Act permits an appeal by "[a]ny person whose affordable housing application is denied or is approved with restrictions which have a substantial adverse impact on the viability of the affordable housing development or the degree of affordability of the affordable housing dwelling units. . . ." General Statutes § 8-30g(b).

The defendant Council argues that this appeal is not properly within the appeal procedure set forth in § 8-30g because it claims GLAHD is not "a person who proposes to develop affordable housing" within the meaning of 8-30g(b). The Council claims that GLAHD failed to give "meaningful assurance" that the property would be used to build affordable housing. This argument CT Page 5433-TT challenges GLAHD's standing to pursue this appeal.

"The issue of standing implicates the court's subject matter jurisdiction." Appeal from Probate of Bencivenga, 30 Conn. App. 334,337, 620 A.2d 195 (1993), aff'd, 228 Conn. 439, 636, A.2d 832 (1994). Standing focuses on the party seeking to be heard and not on the issues that party wants to have decided. Zoning Boardof Appeals v. Planning Zoning Commission, 27 Conn. App. 297,300, 605 A.2d 885 (1992). The focus is on whether one is a proper party to request adjudication of the issues, rather than on the substantive rights of the aggrieved parties. Nye v. Marcus,198 Conn. 138, 141, 502 A.2d 869 (1985).

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Bluebook (online)
1996 Conn. Super. Ct. 5433-QQ, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glastonbury-affd-hous-dev-v-town-coun-no-cv94-0543581-sep-4-1996-connsuperct-1996.