S. Gately-Wilson v. Upper Mount Bethel Twp. ZHB

CourtCommonwealth Court of Pennsylvania
DecidedMay 1, 2025
Docket872 C.D. 2024
StatusUnpublished

This text of S. Gately-Wilson v. Upper Mount Bethel Twp. ZHB (S. Gately-Wilson v. Upper Mount Bethel Twp. ZHB) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
S. Gately-Wilson v. Upper Mount Bethel Twp. ZHB, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Sarah Gately-Wilson, : Appellant : : v. : : Upper Mount Bethel Township Zoning : Hearing Board, John Ross, and Ruth : No. 872 C.D. 2024 Ross : Argued: April 8, 2025

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: May 1, 2025

Before this Court is an appeal by Sarah Gately-Wilson (Objector) from an order of the Court of Common Pleas of Northampton County (Common Pleas) that affirmed an order of the Upper Mount Bethel Township (Township) Zoning Hearing Board (Board). The Board granted a variance to John Ross and Ruth Ross (Applicants) for primary driveway access to their property (Property) from an alley rather than a public road. Upon review, we conclude the record lacks substantial evidence in support of the Board’s decision,1 and we reverse Common Pleas’ order and remand to Common Pleas.

1 Because Common Pleas took no additional evidence on appeal from the Board’s decision, this Court’s review is limited to determining whether the Board committed an error of law or manifestly abused its discretion; such an abuse of discretion occurs only where the Board’s findings are not supported by substantial evidence. 1825 Rt. 309 Allentown, LLC v. Zoning Hearing Bd. of S. Whitehall Twp., 309 A.3d 187, 190 n.2 (Pa. Cmwlth. 2024) (citing Artisan Constr. Grp., LLC v. Zoning Hearing Bd. of Upper Pottsgrove Twp., 275 A.3d 80, 84 n.5 (Pa. Cmwlth. 2022)). I. Background Applicants purchased the Property in 2018. Reproduced Record (RR) at 64a. The Property contains roughly 31 acres of farmland and no structures. Id. at 66a. In 2017, Applicants’ predecessors in title placed the Property under the burden of an agricultural easement (Agricultural Easement) in favor of Northampton County Farmland Preservation (Farmland Preservation). Id. at 72a, 109a & 119a. The terms of the Agricultural Easement allow construction of a residence and related structures on the Property, limited to a maximum area of two acres. Id. at 67a, 74a, 121a-22a, 128a & 134a. The Property has about 300 feet of road frontage on Sagen Drive, a public road in the Township. RR at 82a-83a. After purchasing the Property, Applicants obtained a change of address for the Property from 210 Sagen Drive to 978 Sunrise Boulevard. Id. at 108a-09a. However, the Property has no frontage on Sunrise Boulevard. Id. at 68a. Applicants’ sole access to the Property from Sunrise Boulevard is via a private alley over which their chain of title burdens the Property with a right-of-way in favor of Objector and others. Id. at 68a & 152a-53a. Objector uses the alley as a farm road to access her farmland at 934 Sunrise Boulevard. Id. at 161a.2 In 2021, Applicants sought and obtained various permits from the Township and approval from Farmland Preservation for a residential dwelling and a pole barn to be constructed on a portion of the Property abutting the private alley. RR at 49a. Objector appealed from the grant of the Township permits, asserting that

2 This evidence suggests that, in common parlance, the road in question might be better described as a farm road than an alley. See RR at 161a (describing the alley as “a gravel farm road that is under constant maintenance just to be passable for . . . private vehicles and tractors and. . . trucks . . .”). We use the term “alley” here because it is a defined term in the Township’s zoning ordinance that applies to the road in question, as set forth in the discussion section below.

2 the Township’s zoning ordinance forbids the use of an alley as the sole or primary access to a property’s primary structure. Id. at 10a & 177a; TWP. OF UPPER MOUNT BETHEL, PA., CODE OF ORDINANCES, art. IV, ch. 350 (Zoning Ordinance), § 350-26B & C (2004). After a hearing, the Board issued a decision sustaining Objector’s appeal. RR at 97a & 233a-73a. Applicants did not appeal the Board’s decision. In 2022, Applicants applied for and were granted a driveway permit to construct a driveway adjoining Sagen Drive. RR at 48a, 57a, 93a-94a, 103a-05a & 157a-58a. However, Applicants did not seek approval from Farmland Preservation for an alternate location of their residence and pole barn along Sagen Drive. Id. at 149a; see also id. at 123a-24a. Instead, in 2023, they filed an application for a variance from the Township’s ordinance to allow them to construct the residence and pole barn on the previously chosen spot, where their sole driveway access would be from the alley, as that part of the Property has no frontage on a public road. Id. at 10a, 59a-60a, 67a, 110a & 262a. The Board held a hearing on the variance application. See RR at 21a- 213a. The entirety of the record evidence that can possibly be construed as relating to any potential hardship to Applicants from denial of the variance consists of testimony by Ruth Ross that Applicants “didn’t want to break up” the portion of the farmland along Sagen Drive, id. at 99a, and a supplemental letter from Maria Bentzoni on behalf of Farmland Preservation (Bentzoni) indicating that Applicants’ chosen construction location was “the most efficient area” on the Property. Id. at 130a. However, on cross-examination, Bentzoni explained that by describing the location as “efficient,” she might have been “overstepping” and was referring to the possibility that the contours of the land along Sagen Drive might create problems

3 with “percing” for placement of Applicants’ septic system.3 Id. at 145a-46a. Moreover, Farmland Preservation had already approved the location without the additional review that prompted the letter, stating as the only consideration that “the location and the area of disturbance [would] be within the two acre size which is within the threshold established . . . .”4 Id. at 129a-30a. Notably, Bentzoni acknowledged that Farmland Preservation requires any construction on property subject to a preservation easement to comply with zoning restrictions and that she was not aware that Applicants’ chosen location for constructing their house would not comply with the Zoning Ordinance’s road frontage requirement, nor that a driveway permit had been issued for access from Sagen Drive. Id. at 147a-48a, 150a & 218a. In addition, Bentzoni acknowledged on cross-examination that she could not offer any reason why a location along Sagen Drive would not be approved by Farmland Preservation’s board: Q If [Applicants] came to you with a driveway permit and a septic permit . . . and asked you for the two acre exemption, curtilage, for a residential structure off of

3 A percolation or “perc” test measures soil drainage rate to determine suitability for placement of a private septic system. See 25 Pa. Code § 71.62. Drainage requirements for septic systems are subject to specific calculations and are regulated by the Pennsylvania Department of Environmental Protection and local agencies – not Farmland Preservation; hence Bentzoni’s acknowledgment that she was overstepping by speculating about percolation issues. See 25 Pa. Code § 73.15. 4 The letter also observed that, in discussions with the prior owner of the Property, Farmland Preservation had previous concerns about potential “difficulty” obtaining sufficient sight distance to allow driveway placement on Sagen Drive. RR at 130a. However, any such professed concern is negated by the undisputed fact that the Township issued a driveway permit to Applicants for a driveway on Sagen Drive. In any event, sight distance requirements for driveway placement on Township roads are regulated by the Township – again, not by Farmland Preservation. See Zoning Ordinance, § 291-13D(2). The record is bare of any indication of authority on the part of Farmland Preservation to involve itself in determining whether a proposed driveway location has sufficient sight distance.

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Bluebook (online)
S. Gately-Wilson v. Upper Mount Bethel Twp. ZHB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/s-gately-wilson-v-upper-mount-bethel-twp-zhb-pacommwct-2025.