Utility Constructors, Inc. v. Zoning Hearing Board

28 Pa. D. & C.3d 132, 1982 Pa. Dist. & Cnty. Dec. LEXIS 130
CourtPennsylvania Court of Common Pleas, Crawford County
DecidedAugust 4, 1982
Docketno. A.D. 1981-1119
StatusPublished
Cited by1 cases

This text of 28 Pa. D. & C.3d 132 (Utility Constructors, Inc. v. Zoning Hearing Board) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Crawford County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Utility Constructors, Inc. v. Zoning Hearing Board, 28 Pa. D. & C.3d 132, 1982 Pa. Dist. & Cnty. Dec. LEXIS 130 (Pa. Super. Ct. 1982).

Opinion

THOMAS, P.J.,

The applicant, Utility Constructors, Inc., is the owner of 87 acres of undeveloped land adjoining Conneaut Lake. It hopes to develop the land into a travel trailer park. Homeowners in the vicinity do not want a travel trailer park there. The zoning hearing board denied Utility’s application for a travel trailer park and the matter is before the court on Utility’s appeal from that decision.

FACTS

Utility’s land was originally zoned as general commercial and seasonal residential. On January 18, 1980, Utility submitted a zoning amendment [134]*134application to the township requesting a change in the zoning classification to resort commercial. The purpose of the request was to permit a travel trailer park as a special exception use. After several heated hearings, court resolution of some procedural shortcomings1 and legal maneuvering, the Board of Supervisors rezoned the land to Resort Commercial on June 17, 1981 (Ordinance No. 139-1981). Allowable uses in the Resort Commercial district include travel trailer parks as a special exception use.

On September 1, 1981, Utility applied for a permit for a travel trailer park. The zoning officer denied the permit and hearings were then held before the Sadsbury Township Zoning Hearing Board.

The zoning board held a lengthy hearing on October 28, 1981, a brief hearing November 13, 1981, and a final meeting December 7, 1981, to announce its 34 findings of fact and two conclusions of law, listing the reason for denying the Application for Special Use as a Travel Trailer Park.

Section 802 of the Sadsbury Township Zoning Ordinance2 covers travel trailer parks and consists of three pages of single spaced type, spelling out in considerable detail all the requirements that must be met in erecting a travel trailer park as a special exception to satisfy the ordinance and zoning board.

We note initially, the record in this case is rather cumbersome and complex as, apparently by agreement of counsel, the initial hearing before the township supervisors held February 26, 1980, when the request for a zoning change by Utility was presented to the board, was incorporated into the zoning [135]*135board’s record with the same force and effect as if the pro and con testimony of the zoning change request to allow a travel trailer park had been repeated again 20 months later before the zoning board.3 Additionally, we note minutes of Township Planning Commission meeting held October and February, 1980, appearing as Homeowners’ Exhibits 5, 6, and 7 (14 pages). They were objected to. We have read them and reluctantly rule them admissible as part of the record in this case, noting, however, that many of the statements are non-conclusory, self-serving opinions or inquiries and are not very helpful in establishing facts. Thus, the record consists of some 130 pages of zoning board testimony, 99 pages of previous testimony before the Supervisors, 14 pages of Planning Commission minutes, two maps and some 13 other exhibits. We have laboriously read it all as well as some 33 pages of excellent briefs.

Some of the testimony at the Supervisors’ hearing consisted of statements, opinions, questions and innuendos posed by interested local citizens and, while interesting, did not generally establish proven facts or statistical trueisms useful to establish a series of facts from which could flow reasonably accurate conclusions of either fact or law.

Changes in zoning ordinances spawn citizen interest and the resultant outpouring of interest frequently results in a strained demonstration of [136]*136democracy in action. Zoning laws and changes thereto enacted by the legislative branch of a local government invite appeals to the judicial branch and, with the exception of routine criminal cases, probably generate more pages of judicial opinion than any other phase of the law.

Thus, from the volumes of decisions and interpretation of statutes have evolved some legal principles to guide litigants and courts in arriving at decisions in the zoning field. We enumerate some of those principles.

BURDEN OF PROOF

An applicant (here Utility) has the burden of initially presenting evidence to the zoning board which shows that their proposal (a travel trailer park) complies with the terms and conditions of the zoning ordinance covering the subject matter at issue (here section 802 covering travel trailer parks). This rule means that Utility must carry the burden in showing its proposal complies with the objective requirements of section 802.

The important characteristic of a special exception is that the elected representatives of the local citizenry, i.e., the township supervisors, permit an exception to the general zoning classifications if the applicant brings his proposal within the four corners of the strict rules established for the particular exception — here a travel trailer park.

Once the applicant meets his burden of showing his proposal is permissible as being in compliance with the ordinance guidelines, then it is presumed that the proposal is consistent with the promotion of the health, safety and general welfare of the area.

If the applicant meets this burden and acquires this presumption, then the persuasive burden shifts to the objectors and they assume the burden of [137]*137showing by credible evidence that the proposal is detrimental to the public health, safety and welfare of the area.

For a lengthy discussion of the above principles, see the rather complex language of Bray v. Zoning Board of Adjustment, 48 Pa. Commw. 523, 410 A.2d 909 (1980).

ADVERSE IMPACT PRINCIPLE

In order to refuse a request for a special exception by virtue of its adverse impact on the surrounding community, the zoning board must find from all of the evidence that there would be a high degree of probability that the proposed trailer park would adversely effect the health, safety and welfare of the Sadsbury Township area. See Foster Grading Co. v. Venango Twp. Zoning Board, 49 Pa. Commw. 1, 412 A.2d 647 (1980).

Most special exceptions, by their very nature, are bound to have some effect on the surrounding area and this effect was presumptively weighted and considered by the residents speaking through their elected representatives when the Supervisors permitted the zoning change. Thus, the degree of injury to the area necessary to support a denial of the proposal by the zoning board must be greater than the average anticipated effect normally flowing from such a proposal. See Kopelman v. Zoning Hearing Board, 55 Pa. 306, 423 A.2d 761 (1980).

Putting it another way, it must be assumed that when the supervisors changed the zoning ordinance to permit a travel trailer park, they considered the normally anticipated impact their decision would have on such matters as traffic flow, esthetic considerations, impact on water and sewer facilities, lake use, the impact of an increased transient popu[138]*138lation, etc.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Utility Constructors, Inc. v. Zoning Hearing Board
471 A.2d 944 (Commonwealth Court of Pennsylvania, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
28 Pa. D. & C.3d 132, 1982 Pa. Dist. & Cnty. Dec. LEXIS 130, Counsel Stack Legal Research, https://law.counselstack.com/opinion/utility-constructors-inc-v-zoning-hearing-board-pactcomplcrawfo-1982.