Seaforth Housing v. City of Portland

Superior Court of Maine·Decided December 13, 2005·No. CUMap-05-034·Unpublished

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS DOCKET NO. AP-05-034 ,' .

SEAFORTH HOUSING, LLC -J-

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Plaintiff

VS. ORDER ON 80B APPEAL

CITY OF PORTLAND Defendant

and WATERVIEW DEVELOPMENT, LLC Party-in-interest

Before the court is Plaintiff Seaforth Housing, LLC's ("Seaforth") appeal, pursuant to M.R.Civ.P. 80B, of the City of Portland Planning Board's ("Board") approval of party-in-interest Waterview Development, LLC's ("Waterview") application for development of a condominium building.

BACKGROUND

Seaforth owns Back Bay Tower, a fifteen-story condominium building in Portland situated on Cumberland Avenue, across Mechanic Street from the Waterview development site. The Waterview development, as approved by the Board, will have twelve stories, 94 residential units, and 144,000 square feet of space. On February 28, 2005, Waterview submitted an application to the Board for final site plan and subdivision approval, which was approved by the Board after a public hearing, in a decision dated May 10, 2005. On June 8, 2005,

Seaforth filed an appeal from this decision, and on June 28, 2005, filed a motion for a stay, which was denied. The court now considers Seaforth's appeal.

On appeal, Seaforth contends that the Board erred with respect to its final site plan and subdivision approval in finding that (1)Waterview has adequate financial capacity to complete the proposed development, (2) the project minimizes, to the extent feasible, any substantial diminution in the value or utility to Back Bay Tower ( 3 ) Waterview's application satisfied traffic requirements (4) Waterview complied with the parlung space requirement and (5) the proposal would not cause significant wind impact.

In addition, Seaforth maintains in its appeal briefs that it did not receive notice of any of the proceedings before the Portland City Council. These proceedings resulted in the City Council's approval of a Contract Zone Agreement, a necessary step in \VaterviewJs process of obtaining final site plan and development approval from the Board. However, in its motion to strike certain portions of the appeal record submitted by Waterview, Seaforth also maintains that it "is only appealing the [May 101 decision on the February 28, 2005 application. Plaintiff is not seeking to challenge the Contract Zone Agreement between the City and Waterview." Plaintiff's Motion to Strike Portions of "Record" with Incorporated Memorandum of Law at 2. Thus, by Seaforth's own admission, the Contract Zone Agreement is not challenged, and any question of adequate notice with respect to hearings held on the Contract Zone is waived. Accordingly, Seaforth's claims that it did not receive notice of these hearings will not be reviewed.

DISCUSSION

I. The Board's Findings Concerfiing the Adequacy of Waterview's Proposal

The Board's site plan and subdivision approval is governed by state statute and by the provisions of the City of Portland 1,and Use Ordinance ("Ordinance"). 30-A M.R.S.A. § 4404. The court reviews the Board's decision for errors ~f law, abuse of discretion, c; findings of fact not supported by substantial evidence in the record. Sre York v. Town of Ogz~rzyuit,2001 IvlE 53, 6, 769 A.2d 172, 175.

A. Fina/tcinl Capacity

Seaforth claims that Waterview did not meet the requirements of Ordinance 5 14-525(c)(9).' Waterview had submitted to the Board a letter from Key Bank stating that it has a strong interest in proceeding with financing the project in the amount of $20,000f000. In addition, Waterview submitted a cover letter to the Planning Board describing the scale of the project and stating that the estimated construction cost is $17,000,000. These submissions appear to cover the statutory requirement under 5 14-525(c)(9). Although 5 14-525(c)(9)requires a letter from a responsible financial institution stating that it "would seriously consider findncing" the development and Key Bank's letter states that it has a "strong interest" In financing the development, these phrases indicate sirnilar levels of interest. Thus, the substance of 5 14-525(c)(9)'srequirement is met.

' Ordinance 14--525(c)(9)states: [For] all site plans . . . the applicant shall . . . provide written statements containing the following: (9) evidence of financial and technical capacity to undertake and complete the development including, but not limited to, a letter from a responsible financial institution stating that it has reviewed the planned development dnd would seriously consider financing it when approved, ii requested to do so.

Seaforth claims, however, that Waterview was also required to present evidence cf the actual costs of completing the project, for comparison against the amount the financial institution svould be willing to finance. Bruk el. Town of Georgetowrz, cited by Seaforth to support this assertion, is inapposite. See 436 A.2d 894, 897 (hie. 1981). In Bri~k,the court was considering whether a Board's denial of a proposed subdivision xvas supported by substantial evidence in the record. The Law Court upheld the Board's decision in part because it was supported by its finding that the developer had not tallied costs associated with the project in a way that satisfied the Board that the developer had adequate financial capacity to cover those costs. See id., n. 5. This opinion merely reaffirms that a planning board has broad discretion to make factual findings, and that the findings svill not be overturned by the court on appeal if they are supported by substantial evidence in the record. See id. This opinion does not add to the minlmum requirements for approval as stated in 30-A M.R.S. 5 4404(10)2and Ordinance 5 14-525(c)(9). Under these requirements, the Board xvas entitled to find, based on Waterview's presentation of the scale and total estimated cost of the project, as well as the letter of strong interest from Key Bank, that Waterview had demonstrated adequate financial capacity to complete the development. See id.

B. Dirnint~tioliIn I7alueor Utility to Neigliboving Structzlres

30-A 1LI.R.S.A. s4404(10) states:

When adopting any subdivision regulations and when reviewing a n y subdivision for approval, the municipal reviewing authority shall consider the following criteri'l and, before granting approval, mu:jt determine that:

(10) the subdivider has adequate financial and technical capacitjf to meet the requirements ot this section;

Seaforth claims that Waterview did not satisfactorily demonstrate that its development had minimized, to the extent feasible, any substantial diminution in the value or utility to neighboring structures. See Ordinance § 14-526(a)(4).3

The Board's Decision includes a detailed explanation for its finding that the LA7 v a~t.1 I. ..----:

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meet this reqiiirernent. 'IA4ithoutreprinting the

entire text of this explanation, the Board noted, significantly:

Con~mentswere received on behalf of Seaforth, w h c h asserted that the Project's height 2nd mass will cause a $1.4 million diminution of value to its property. Seaforth failed to present any documentation or rational analysis to support this statement.

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Related

Bruk v. Town of Georgetown
436 A.2d 894 (Supreme Judicial Court of Maine, 1981)
Glasser v. Town of Northport
589 A.2d 1280 (Supreme Judicial Court of Maine, 1991)
York v. Town of Ogunquit
2001 ME 53 (Supreme Judicial Court of Maine, 2001)