Spahn v. Philadelphia Zoning Bd. of Adjustment

17 Pa. D. & C.5th 121
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedSeptember 8, 2010
Docketno. 01970
StatusPublished

This text of 17 Pa. D. & C.5th 121 (Spahn v. Philadelphia Zoning Bd. of Adjustment) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spahn v. Philadelphia Zoning Bd. of Adjustment, 17 Pa. D. & C.5th 121 (Pa. Super. Ct. 2010).

Opinion

OPINION AND ORDER

FOX, J.,

— Gary Spahn (Spahn) has appealed a decision of the Philadelphia Zoning Board of Adjustment (ZBA) which granted dimensional variances for the construction of two single-family dwellings at property located 756-760 S. Chadwick St. (property). The owners of the property, Chadwick Street Properties, L.P. (Chadwick) have intervened.

[123]*123FACTUAL AND PROCEDURAL SUMMARY

Chadwick applied to the Department of Licenses and Inspections (L&I) for a zoning and use registration to allow for the relocation of lot lines to create two lots from three and to erect two new single-family dwellings on the property. The application was refused for the following reasons:

- Proposed building height 41 ’2” exceeded maximum allowed 35 feet
- Proposed four stories exceeded maximum allowed of three
- Proposed lot sizes were less than required
- Proposed open area was 216 ft.; 324 ft required.
- Proposed side yard less than the required 5 feet

An appeal was filed to the ZBA. In addition to the variance requested, Chadwick requested a certificate to allow curb cuts for parking purposes. The Zoning Board Examiner discovered errors in the refusal and issued a corrected refusal. The revised refusal changed the zoning designation from R-10 to R-10A. This change increased the disparity between proposed plan and the dimensional minimums required under the Zoning Code.

Apublic hearing was held on August 26,2009. Counsel for Chadwick and its architect appeared before the ZBA. Spahn appeared and testified in opposition to the variance request. All were given ample opportunity to testify. The ZBA received letters from city council President Anna C. Verna and the South of South Neighborhood Association. [124]*124Both indicated that the opinions of the neighbors were mixed and therefore neither took a position on the application. ThePhiladelphiaPlanning Commission voiced no objection to the requested variances and the requested parking certificate. The board granted the variances and the parking certificate. Spahn filed this timely appeal. The court received the certified record from the ZBA and its findings and conclusions. Briefs were submitted and the court heard oral argument.

DISCUSSION

The ZBA found that Chadwick met its burden and established that a literal enforcement of the provisions of the Zoning Code would result in an undue hardship. The ZBA concluded an unnecessary hardship would result in that the small size of the existing lots made it impractical to construct dwellings without the requested variances. Further the ZBA found that the shape and size of the lots were unique. Finally, the ZBA found that the record, as a whole, established that Chadwick met all the requirements for the approval of the variances and the issuance of the Parking Certificate.

The standard of review is deferential to the ZBA. Where no further evidence is gathered, the court limits its scope of review to, “whether the board committed a manifest abuse of discretion or an error of law.” Valley View Civic Ass’n. v. Zoning Bd. of Adjustment, 501 Pa. 550, 554, 462 A.2d 637, 639 (1983). The board commits an abuse of discretion if its decision is not based upon “relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id at 555, 462 A.2d at 640. When the reviewing court considers no further evidence, [125]*125“questions of credibility and evidentiary weight are solely the province of the zoning hearing board.” Whitpain Township Bd. of Supervisors v. Whitpain Township Zoning Hearing Bd., 550 A.2d 1355 (1988). Thus, it is the ZBA who establishes whether relevant evidence exists to meet all the necessary factors. The reviewing court does not alter the board’s conclusion unless it is not supported by substantial evidence. View Civic Ass’n. at 559, 462 A.2d at 642.

The ZBA may grant a variance if there is no conflict with the public interest and if the circumstances of the area are such that a “literal enforcement of the provisions of this [code] would result in unnecessary hardship.” Philadelphia Zoning Code § 14-1801(1). The burden is on the party seeking the variance. A variance is granted only if the reasons are “substantial, serious and compelling.” Valley View Civic Ass’n. at 555, 462 A.2d at 640. The three key requirements set forth by § 14-1802(1) of the code are: “1) unique hardship to the property; 2) no adverse effect on the public health, safety or general welfare; and 3) the variance is the minimum necessary to afford relief.” E. Torresdale Civic Ass’n v. Zoning Bd. of Adjustment at 324, 639 A.2d 446, 447 (1994).

Hardship is proven by showing that “(1) the physical features of the property are such that it cannot be used for the permitted purpose; or (2) that the property can be conformed for a permitted use only at a prohibitive expense; or (3) that the property has no value for any purpose permitted by the zoning ordinance.” Hertzberg v. Zoning Bd. of Pittsburgh, 554 Pa. 249, 257, 721 A.2d 43, 47 (1998) (citing Allegheny W. Civic Council v. Zoning Bd. of Pittsburgh, 547 Pa. 163, 167, 689 A.2d 225. 227 [126]*126(1997). The party seeking the variance must also prove that the hardship is “unique or peculiar to the property as distinguished from a hardship arising from the impact of zoning regulations on an entire district.” Valley View Civic Ass’n. at 555, 462 A.2d at 640. When deciding whether to grant a variance, all evidentiary factors as a whole must be taken into consideration, including “relationship to adj acent structures, as well as the surrounding neighborhood.” W. Cent. Germantown Neighbors v. Zoning Bd. of Adjustment, 827 A.2d 1283, 1288 (Pa. Commw. Ct. 2003).

Mr. Spahn resides at 745 S. 17th St. and shares an alley to the rear of his property with the Chadwick property (the three lots). He argued that the proposed plan has substantially less open space than the 30 percent required in a R-10A zoned area. The additional bulk and the fourth floor will interfere with the peaceful enjoyment of his property. He contends that the properties on this block of Chadwick street are virtually the same size and therefore the hardship is not unique and this is a matter that should not be addressed by the issuance of a variance but by rezoning the district. Hill District Project Area Committee, Inc. v. ZBA City of Pittsburgh, 638 A.2d 278 (Pa. Cmwlth).

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Related

Hertzberg v. Zoning Board of Adjustment
721 A.2d 43 (Supreme Court of Pennsylvania, 1998)
Whitpain Township Board of Supervisors v. Whitpain Township Zoning Hearing Board
550 A.2d 1355 (Commonwealth Court of Pennsylvania, 1988)
Hill District Project Area Committee, Inc. v. Zoning Board of Adjustment
638 A.2d 278 (Commonwealth Court of Pennsylvania, 1994)
East Torresdale Civic Ass'n v. Zoning Board of Adjustment
639 A.2d 446 (Supreme Court of Pennsylvania, 1994)
Valley View Civic Ass'n v. Zoning Board of Adjustment
462 A.2d 637 (Supreme Court of Pennsylvania, 1983)
Allegheny West Civic Council, Inc. v. Zoning Board of Adjustment
689 A.2d 225 (Supreme Court of Pennsylvania, 1997)
West Central Germantown Neighbors v. Zoning Board of Adjustment
827 A.2d 1283 (Commonwealth Court of Pennsylvania, 2003)

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Bluebook (online)
17 Pa. D. & C.5th 121, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spahn-v-philadelphia-zoning-bd-of-adjustment-pactcomplphilad-2010.