HomeMy WebLinkAboutBOA agenda 111218 - cancelled PLANNING & INSPECTIONS DEPARTMENT
Craig N. Benedict, AICP, Director
Current Planning
(919) 245-2575
(919) 644-3002 (FAX)
www.orangecountync.gov
131 W. Margaret Lane
Suite 201
P. O. Box 8181
Hillsborough, NC 27278
AGENDA
ORANGE COUNTY
BOARD OF ADJUSTMENT
WHITTED MEETING FACILITY
300 West Tryon Street
HILLSBOROUGH, NORTH CAROLINA
November 12, 2018
7:00 p.m.
No. Page(s) Agenda Item
1. CALL TO ORDER
2. CONSIDERATION OF ADDITIONS TO AGENDA
3. APPROVAL OF MINUTES
• August 13, 2018
4. PUBLIC CHARGE :
The Board of Adjustment pledges to the citizens of Orange County its respect.
The Board asks its citizens to conduct themselves in a respectful, courteous
manner, both with the Board and with fellow citizens. At any time should any
member of the Board or any citizen fail to observe this public charge, the
Chair will ask the offending person to leave the meeting until that
individual regains personal control. Should decorum fail to be restored, the
Chair will recess the meeting until such time that a genuine commitment to
this public charge is observed. All electronic devices such as cell phones,
pagers, and computers should please be turned off or set to silent/vibrate.
The Board of Adjustment is a quasi-judicial administrative body established
in accordance with the provisions of local regulations and State law to
perform specified functions essential to the County’s planning program.
Action(s) taken by the board are based solely on competent, substantial, and
material evidence presented during a previously scheduled and advertised
public hearing on a specific item. As detailed within Section 2.12.2 of the
1
UDO the Board chair reserves the right to exclude evidence and testimony that
is deemed: ‘incompetent, irrelevant, immaterial, or unduly repetitious’ and
therefore fails to reasonably address the issues before the Board of
Adjustment. While it should be noted there is no time limit on the
presentation of evidence, the Chair asks that the presentation of evidence be
consistent with established policies, rules of procedure, and acceptable
levels of decorum to ensure a fair and equitable hearing for all parties.
No. Page(s) Agenda Item
5. CASES:
A. A-5-18 – Public Hearing to review a Class B SUP request
submitted by Camp Chestnut Ridge and NC United Methodist
Camp & Retreat Ministries, Inc. requesting to expand the existing
Camp/Retreat Center facilities (PINs: 9843-22-1289; 9843-13-7930;
9843-05-5036; 9833-93-5222; and 9842-49-7233) along Camp
Chestnut Ridge Road, west side Chestnut Ridge Church Road,
and east of Mt. Willing Road.
6. ADJOURNMENT
IF UNABLE TO ATTEND THIS MEETING, PLEASE CALL THE PLANNING DEPARTMENT
(NUMBERS LISTED BELOW – PRESS 1 PLUS EXTENSION 2575 OR 2585). STAFF CAN THEN
DETERMINE IF A QUORUM WILL BE PRESENT FOR THE MEETING.
HILLSBOROUGH – (919) 732-8181 ; MEBANE – (919) 227-2031
CHAPEL HILL – (919) 967-9251 ; DURHAM – (919) 688-7331
2
MINUTES 1
BOARD OF ADJUSTMENT 2 August 13, 2018 3
REGULAR MEETING 4
5
MEMBERS PRESENT: Karen Barrows, Vice Chair 6
Susan Halkiotis 7
Barry Katz 8
Randy Herman 9
10 STAFF PRESENT: Michael Harvey, Current Planning Supervisor 11
James Bryan, Staff Attorney 12
13
AGENDA ITEM 1: CALL TO ORDER 14
Vice Chair Karen Barrows called the meeting to order at 7 p.m. 15
16
AGENDA ITEM 2: CONSIDERATION OF ADDITIONS TO AGENDA 17
There was none. 18
19
AGENDA ITEM 3: APPROVAL OF MINUTES – July 9, 2018 Barry mentions two sets of minutes 20
It was noted that the word “statue” needed to be replaced by “statute” in several places. 21
MOTION by Barry Katz to approve the July 9, 2018, minutes. Susan Halkiotis seconded. 22 VOTE: UNANIMOUS 23
24
AGENDA ITEM 4: PUBLIC CHARGE 25
Barry Katz read the public charge. 26
27
The Board of Adjustment pledges to the citizens of Orange County its respect. The Board asks its citizens to conduct 28
themselves in a respectful, courteous manner, both with the Board and with fellow citizens. At any time should any 29
member of the Board or any citizen fail to observe this public charge, the Chair will ask the offending person to leave the 30
meeting until that individual regains personal control. Should decorum fail to be restored, the Chair will recess the meeting 31
until such time that a genuine commitment to this public charge is observed. All electronic devices such as cell phones, 32
pagers, and computers should please be turned off or set to silent/vibrate. 33 34
The Board of Adjustment is a quasi-judicial administrative body established in accordance with the provisions of local 35
regulations and State law to perform specified functions essential to the County’s planning program. Action(s) taken by the 36
board are based solely on competent, substantial, and material evidence presented during a previously scheduled and 37
advertised public hearing on a specific item. As detailed within Section 2.12.2 of the UDO the Board chair reserves the 38
right to exclude evidence and testimony that is deemed: ‘incompetent, irrelevant, immaterial, or unduly repetitious’ and 39
therefore fails to reasonably address the issues before the Board of Adjustment. While it should be noted there is no time 40
limit on the presentation of evidence, the Chair asks that the presentation of evidence be consistent with established 41
policies, rules of procedure, and acceptable levels of decorum to ensure a fair and equitable hearing for all parties. 42 43
44 AGENDA ITEM 5: A-3-18 – PUBLIC HEARING TO CONTINUE REVIEW of an application 45
appealing the final determination of the Planning Director, as articulated in an October 13, 46
2017, letter, concerning a parcel of property located at the intersection of Morrow Mill and 47
Millikan Roads (PIN: 9729-50-7168) owned/operated by Southeast Property Group LLC (a.k.a. 48
Wild Flora Farm) care of Ms. Kara Brewer. 49
Staff Attorney James Bryan said in past cases, he has given an opening statement about what is quasi-judicial and 50
what is not to clear confusion. He explained the Board of Adjustment appeals procedure. He simplified that facts can be 51
DRAFT MINUTES 8.13.18 3
reasonably decided and rules are correctly interpreted. He noted that facts decided by this board cannot be arbitrary or 1
capricious but rather supported by competent, material, substantial evidence in the record. The rules are interpreted by 2
the law. He reviewed how the Board of Adjustment determines the facts. This board makes findings of facts if facts are 3
based on competent, material and substantial evidence that are not arbitrary or capricious and are presented in the 4
record. Competent evidence is legally fit so that it is trustworthy, and reliable and competent evidence for traffic and 5
property values must be provided by experts in those fields. James Bryan also reviewed that substantial evidence is 6
sufficient to support a specific conclusion. 7
8
James Bryan then reviewed the flow for facts and shared a diagram that explained that before the public hearing, the 9
application is submitted and the staff report is written. At the hearing, evidence is given on the record and then the 10
hearing is closed and the board deliberates. The board then takes all the evidence presented for the record at the 11
hearing and determines findings of fact based on whether it was competent, material and substantial evidence. The 12
staff attorney noted that some evidence may be uncontested and other evidence may be excluded. In cases where 13
there is evidence on both sides for a relevant standard, the board must decide based on its reasonable judgment. 14
15
James Bryan then reviewed how the board interprets a rule and presented a slide to remind everyone that if the text is 16
clear and unambiguous, its plain meaning should be enforced. If an ambiguity remains, the board must favor the 17
property owner and the free use of land. 18
19
James Bryan then established the framework for this case. Regarding jurisdiction, on Page 11 of the agenda packet, 20
there is a letter from Current Planning Supervisor Michael Harvey dated October 13, 2017, that is a final and binding 21
decision of staff, which carries the weight of law. Regarding whether the applicants have standing, the board will find on 22
Page 51 of the agenda packet the applicants’ statement of standing. James Bryan reviewed that regarding the rule, this 23
is a new statute N.C.G.S. §153A-340(b)(2a). This was passed by the General Assembly in July 2017. 24
25
Barry Katz said this is a case that predates the change in the law. He wonders how the change in the law is relevant to 26
this case. James Bryan said the parties can better speak to that. 27
28
James Bryan then reviewed that before Michael Harvey wrote his letter on October 13, 2017, he received a request. 29
James Bryan reviewed that the request was for a classification that the structure on the property is a structure for a 30
farm purpose, pursuant to N.C.G.S. §153A-340(b)(2a). He then highlighted the first sentence in a paragraph of the 31
statute that states: “A building or structure that is used for agritourism is a bona-fide farm purpose if the building or 32
structure is located on a property that is owned by a person who holds a qualifying farmer sales tax exemption 33
certificate from the Department of Revenue pursuant to G.S. 105-164.13E(a). James Bryan said he does not think 34
either parties are arguing over the last part of that statement. James Bryan said the applicant included the property 35
owner’s original request, which is one letter with four exhibits. James Bryan referred to Page 10 of the agenda packet to 36
answer how staff responded to the rule, noting that Michael Harvey laid out four sections. 37
38
Barry Katz said the deed for the property was filed with Mark Chilton on March 24, 2015. Is it relevant for him to ask 39
when the barn itself was purchased. 40
41
James Bryan said he does not know whether it is relevant but Barry Katz will have an opportunity to ask that when the 42
applicant is before the board. 43
44
James Bryan returned to Page 10 of the agenda packet, noting there were five attachments to Michael Harvey’s letter, 45
pages 12 - 50 of the agenda packet. He noted that Page 51 is what the appellant says is wrong with the staff’s 46
determination. He noted that Page 68 is the new information that is available. This is 20 pages that were submitted by 47
the applicant upon the board’s subpoena. This information includes the application to the state for a qualifying farmer 48
exemption certificate number; the Internal Revenue Service letter issuing an employer identification number; and the 49
plan of merger of Wild Flora Farm, LLC, with Southeast Property Group, LLC. 50
4
1
James Bryan said to apply the principles to the present case, a structure is a bona fide farm purpose if the structure is 2
used for agritourism and the person who owns the property where the structure is located is the same person who 3
holds a qualifying farmer sales tax exemption certificate from the Department of Revenue pursuant to G.S. 105-4
164.13E(a). He thinks there will be three conclusions the board will have to make: 5
#1 Is the structure used for agritourism? 6
#2 Who owns the property where the structure is located? 7
#3 Does that owner have a certificate from the North Carolina Department of Revenue indicating a farmer sales tax 8
exemption? 9
10
James Bryan said when reviewing Michael Harvey’s determination for an appeal, the Board of Adjustment stands in the 11
staff person’s shoes and says this is what should have been done. That decision is made today after evidence is 12
presented. 13
14
James Bryan shared a slide repositioning all of the information. He said the current evidence in the agenda packet is 15
the building permit found on Page 19 and the farm plan summary, website, correspondence regarding weddings and 16
educational workshops, social media and other pictures found on Page 26. His slide noted the facts used by staff but 17
James Bryan noted that the board may receive additional evidence this evening or may determine that some of this 18
evidence is not competent, material or substantial. The board will determine its facts. James Bryan then reviewed that 19
the board will have to decide that the structure is used for agritourism or is not used for agritourism. 20
21
Barry Katz said it has been his impression that Kara Brewer and her attorney have been arguing that the Unified 22
Development Ordinance is not germane to this and it is essentially a state issue and not a county issue. So, why are we 23
discussing this? 24
25
James Bryan answered that the General Assembly has tried to craft what they want for many years. What they drafted 26
here isn’t the clearest but don’t let the perfect be the enemy of the good. 27
28
Barry Katz said he would like to look at the statute while James Bryan answered. It was noted that the statute starts on 29
Page 92 of the agenda packet. 30
31
James Bryan read this sentence excerpted from the statute and found at the top of Page 92 in the agenda packet: 32
“Failure to maintain the requirements of this subsection for a period of three years after the date the building or 33
structure was originally classified as a bona fide purpose pursuant to this subdivision shall subject the building or 34
structure to applicable zoning and development regulation ordinances adopted by a county pursuant to subsection (a) 35
of this section in effect on the date the property no longer meets the requirements of this subsection.” 36
37
James Bryan noted that there is a time limit of three years from the date the building or structure was originally 38
classified as a bona fide farm purpose. If not the county, who makes that classification? The applicant asked the county 39
to make that classification and Michael Harvey made that classification as a bona fide farm purpose. 40
41
Barry Katz asked for confirmation that staff made that classification because the structure is a barn on a property that 42
has an agricultural tax exemption. 43
44
James Bryan said anybody can ask for a classification and staff will make that determination if that first sentence is met. 45
46
Barry Katz asked that the property owner does not have to be a farmer to gain that classification. 47
48
James Bryan answered that you have to meet the letter of the law. 49
50
5
Barry Katz checked that this barn qualifies for agritourism because it is situated on property that qualifies for an 1
agricultural tax exemption. He asked James Bryan if that is part of the argument. 2
3
James Bryan said it was imperfectly cited, so he couldn’t say. 4
5
Randy Herman added that there is a definition of agritourism later in that section. 6
7
Barry Katz said he has read the definition. 8
9
James Bryan said the second element is who owns the property. He shared a slide that lists current evidence in the 10
agenda packet including: 11
1. Building Permit (PIN) on Page 19 12
2. Orange County Land Records showing owner as SPG, LLC, on Page 42. 13
3. Deed recorded at Orange County Register of Deeds showing SPG, LLC, on Page 45. 14
4. Articles of Merger filed with NC Secretary of State showing Wild Flora Farm, LLC, as surviving entity after being 15
merged with SPG, LLC, on Page 83. 16
5. Certification of Merger filed with Orange County Register of Deeds showing merger of SPG, LLC, into Wild 17
Flora Farm, LLC, on Page 85. 18
19
James Bryan noted Michael Harvey did not have the merger information when he made his determination in October 20
2017. 21
22
Barry Katz asked how an entity would fail to maintain requirements. 23
24
James Bryan said he would presume if you no longer hold a certificate from the North Carolina Department of Revenue, 25
no longer own the property, or no longer are engaged in agritourism. 26
27
Barry Katz asked in agritourism or agriculture? 28
29
James Bryan answered agritourism because that is explicitly what the statute requires. 30
31
James Bryan reviewed some sample motions for the board’s decision, which were shown on a slide. 32
33
Barry Katz asked if the board would be hearing about continuity of ownership. 34
35
James Bryan answered that the parties can respond to that. 36
37
Current Planning Supervisor Michael Harvey reviewed that the abstract package begins on Page 3. A public hearing 38
began at the May 7, 2018, regular meeting, where the board chose to issue subpoenas, at the request of the applicant, 39
to Wild Flora Farm, LLC, and other parties for information submitted to the North Carolina Department of Revenue as 40
part of an application for a qualifying farm exemption certificate. At the board’s July 9, 2018, meeting, those responses 41
were provided to the board along with other motions by the attorney for Kara Brewer, the owner of Wild Flora Farm, 42
LLC. As James Bryan has alluded and as covered in the abstract, what precipitated this appeal was on July 12, 2017, 43
Session Law 2017-108 became effective. The excerpt of this session law is contained in Attachment 4 of the abstract 44
package and begins on Page 92. It establishes criteria for the use of structures on a bona fide farm for agritourism 45
events. Staff received a request from the attorney for Kara Brewer, Andy Petesch, on October 12, 2017, asking for the 46
determination classifying the use of the barn building and structure at Wild Flora Farm for agritourism events as a bona 47
fide farm and therefore exempting for it from county zoning regulations. Michael Harvey said Andy Petesch based this 48
request on the relevant session law. In reviewing the request provided by Andy Petesch, staff made the determination 49
that the structure qualified for bona fide farm purpose as recently amended under the North Carolina General Statutes 50
6
and as such was not subject to county zoning regulation and the owner could engage in agritourism activities, which the 1
statute indicates includes weddings. Staff provided Andy Petesch with a copy of the determination, along with LeAnn 2
Brown, attorney for the appellants. That staff determination has been appealed. 3
4
Michael Harvey reviewed that the appeal begins on Page 5. The subpoena response begins on Page 68. The request 5
to quash or modify the subpoenas begins on Page 89. The aforementioned Attachment 4 begins on Page 92. The 6
excerpt from the May and July 2018 meetings begins on Page 94. He asked that the abstract and all attachments be 7
put in the record. 8
9
MOTION by Susan Halkiotis to enter the abstract and all attachments into the record. Barry Katz seconded. 10 VOTE: UNANIMOUS 11
12
LeAnn Brown said she represents the appellants and read their names, acknowledging they are the same people who 13
have been involved in the other appeals this board has heard regarding this property. She said that this is an appeal of 14
a decision that was made October 13, 2017. She said the appeal was dated November 7, 2017, and noted it has taken 15
awhile to get before the Board of Adjustment. She said one of the first items that the board needs to deal with is the 16
item regarding standing. She said she has a certified copy of the minutes from the first time the Orange County Board 17
of Adjustment heard an appeal regarding this property, which included detailed evidentiary materials that gave evidence 18
of standing. So, in addition to what’s in the application that Michael Harvey has introduced into evidence addressing 19
standing, she is offering into evidence those minutes so that the board does not have to receive additional hours of 20
testimony about standing. She asked that the board receive that as sworn testimony. Also included in those minutes is 21
the determination that was made by this board in connection with the Special Use Permit that the use that was 22
proposed would not maintain or enhance the value of contiguous property. She noted the board has received the 23
certified copy of the minutes twice as sworn testimony in determining whether her party has standing. 24
25
Barry Katz asked for the date of the meeting minutes regarding standing. 26
27
LeAnn Brown answered October 10 and 24, 2016. And everyone still lives in the same place and is still doing the same 28
thing. LeAnn Brown explained the circumstances whereby several people she represents could not be present this 29
evening and acknowledged that she would have to ask for this public hearing to be continued if the board determined it 30
needed testimony from the individuals in order to establish standing. 31
32
LeAnn Brown said in the October 2016 minutes she is passing out, Page 19 acknowledges the board’s earlier finding 33
that those individuals she represents have standing, in addition to what’s on Page 51 of the agenda packet. She asked 34
if the board agreed to find standing. Board members informally agreed. 35
36
Andy Petesch requested to make a brief comment regarding the submission of these materials as standing. Andy 37
Petesch does not object to the certified minutes but wanted to note for the record that he objected then and objects now 38
to the finding that the individuals LeAnn Brown represents have standing. 39
40
LeAnn Brown asked if the board finds that the individuals she represents have standing so that she can proceed. Board 41
members nodded. LeAnn Brown noted for the record that all the board members nodded assent. 42
43
LeAnn Brown said in the materials filed in the appeal, there is an error alleged that she wants to address. She said 44
Southeast Property Group, LLC, which is now called Wild Flora Farm, LLC, by merger -- a merger that occurred well 45
after this tax certificate -- Southeast Property Group, LLC, applied to this board for a Special Use Permit in 2015. The 46
facts are, as is reflected in the minutes that the board has received into evidence, that Michael Harvey originally 47
determined that a Class B Special Use Permit was required for the events center that was going to be built upon the 48
property. There was no appeal taken of his determination that a Special Use Permit was required. She was not the 49
attorney for the opposing individuals at that time, but by the time the public hearing was held by the Board of 50
7
Adjustment, evidence suggests that Kara Brewer was proceeding voluntarily. Nonetheless, Kara Brewer chose to seek 1
a Special Use Permit from the Board of Adjustment. The Board of Adjustment held hearings, received evidence, 2
considered the facts, and denied the Special Use Permit on the grounds that it did not mean the facts that the board 3
must find in order to grant one. That occurred in 2015 and one of the documents before the board is the order of the 4
decision determining that in 2015. 5
6
LeAnn Brown asked the board to receive into evidence Exhibit 2, which was handed to board members a few minutes 7
earlier. 8
9
MOTION by Randy Herman to accept Exhibit 2 into evidence. Barry Katz seconded. 10 VOTE: UNANIMOUS 11
12
LeAnn Brown noted she had just passed copies of Exhibits 3, 4 and 5 to James Bryan for distribution to the board. She 13
reviewed that Exhibit 3 is the petition to deny the Special Use Permit; Exhibit 4 is the writ of certiorari granted by the 14
court, which means the court was intending to hear it; and Exhibit 5 was a dismissal with prejudice of the appeal. The 15
building involved and the land involved is the same as before the board now. She noted this is a quasi-judicial hearing 16
and the doctrines of res judicata and collateral estoppel apply in quasi-judicial hearings. She has copies of a case, 17
Mount Ulla Historical Society v. Rowan County, that talks about the doctrine of res judicata. Res judicata in a zoning 18
case is for the purpose of protecting litigates from re-litigating previously decided matters. It applies to Board of 19
Adjustment quasi-judicial decisions. If you can show that the fact and reasons obviate the reason the denial occurred, 20
then it would not apply, but otherwise it applies. In the Mount Ulla case, there was a three-year period of time between 21
the first Board of Adjustment decision and the second. It involves a radio tower and the radio tower was 1,250 feet in 22
the first application and it was changed to 1,000 feet in the second. The board determined that it was a different tower 23
because it was a different height and the court reversed that and said res judicata that the concerns expressed by the 24
board with regard to the reasons for denial and not been obviated. 25
26
LeAnn Brown said the doctrine of collateral estoppel also applies to this proceeding. She noted collateral estoppel 27
means determination of an issue in a prior judicial or administrative proceeding precludes re-litigation of that issue. It 28
bars a subsequent adjudication of a previously determined issue even if a subsequent action is based on an entirely 29
different claim. It is designed to prevent repetitive lawsuits over matters which have been decided and which have 30
remained substantially static factually and legally. And it applies to quasi-judicial opinions. There is a 2013 Court of 31
Appeals opinion called Hillsboro Partners v. the City of Fayetteville, which is again a land use matter in which this 32
doctrine was held to apply. The filings that have occurred in this case: May 18, 2015, application for a Special Use 33
Permit, as LeAnn Brown had mentioned, Michael Harvey had originally indicated to Kara Brewer, who was seeking the 34
permit through her entity that owned the property, Southeast Property Group, LLC, that she had to have a permit. Kara 35
Brewer did proceed. It was denied on November 9, 2015. The order is included in Exhibit 2. It was appealed and it was 36
dismissed with prejudice. LeAnn Brown noted she has said “with prejudice” twice because she thinks it is very 37
significant. 38
39
Barry Katz asked what that means. 40
41
LeAnn Brown answered that it means this matter was litigated, the board had a quasi-judicial hearing, it was appealed 42
by Southeast Property Group, LLC, and Kara and Chris Brewer to Superior Court. It was never heard and when it was 43
dismissed, it was dismissed with prejudice, which means it was dismissed without an opportunity to bring it back to 44
court. She said it is her contention and has been her contention that once the decision was made to dismiss that 45
petition, that’s the end of the story and whatever has happened subsequent to that with regard to this property, whether 46
or not the statute should have applied then or now is foreclosed by that. It’s foreclosed under the doctrines of res 47
judicata and collateral estoppel, LeAnn Brown said. 48
49
Barry Katz asked if Superior Court gave a reason for dismissing it with prejudice. 50
8
1
LeAnn Brown answered that she cannot speak to that because that is not her case. It would be for Andy Petesch to 2
answer. She reiterated that the dismissal with prejudice brought an end to the recourse for appealing the Orange 3
County Board of Adjustment decision to deny the Special Use Permit. She added that she believes Southeast Property 4
Group, LLC, and Kara and Chris Brewer were without recourse before the petition to Superior Court was filed because 5
when Michael Harvey first determined that she had to file for a Special Use Permit, Kara Brewer should have appealed 6
that to the Board of Adjustment. And that never occurred. 7
8
Randy Herman said the effect of all that would be that the property owner does not qualify for a Special Use Permit and 9
he does not think that the property owner is now arguing that they do but rather that the statute has changed such that 10
the property is no longer subject to our zoning entirely. 11
12
LeAnn Brown said that under the doctrine of res judicata and collateral estoppel when you have chosen the means by 13
which you proceed before a quasi-judicial body and seek a permit and then you choose not to appeal that decision that 14
you have chosen the path that you are going to take. You have set your course of action. Once you are denied the 15
Special Use Permit, you cannot appeal that and dismiss it and then come back and say, ‘You know what, I don’t think I 16
ever needed it anyway.’ And that is exactly what has happened here. 17
18
Randy Herman said the statute under which they are proceeding did not exist at the time that they initially applied so 19
they couldn’t have chosen that path at that time. 20
21
LeAnn Brown said the statute at the time that they saw the Class B Special Use Permit is the statute that this board 22
was considering when it considered the appeal in 2016 and then the statute said what it says now about nonfarm use. 23
That zoning always applies when a farm property is being used for a nonfarm use. That sentence has not been taken 24
out of the statute. And that’s the sentence I think Michael Harvey was considering when he made the decision that Kara 25
Brewer needed a Class B Special Use Permit in the first place, or that the property owner did. The statute did exist. It 26
has been amended to delete the provision that allowed a property owner to rely upon a farm number, which is what 27
Kara Brewer was relying upon, but has added the provision that talks about structures. So, yes, the statute has 28
changed but as she said, related to the Hillsboro Partners case, the doctrine of collateral estoppel will apply even if the 29
subsequent action is based on a different claim. And she thinks that’s the only thing that’s happened here is it’s a 30
different claim. The language is still the same. The building is still the same. The property is still the same. It is still the 31
same intended use. 32
33
Barry Katz said he recalls Kara Brewer voluntarily applying for the Special Use Permit. 34
35
LeAnn Brown said the minutes show that initially the county determined that she had to apply for it. The county then 36
determined that she did not necessarily need to do that. And by the time the hearing took place, Kara Brewer had 37
decided to voluntarily proceed and in the hearing she said she was voluntarily proceeding. Voluntarily or not, she chose 38
that path. And when that didn’t work out, they’ve used different avenues and that’s what collateral estoppel says you 39
can’t do. 40
41
Randy Herman asked LeAnn Brown if she has a case that says that res judicata or collateral estoppel applies when the 42
substantive law has changed between the first proceeding and the second proceeding. 43
44
LeAnn Brown said she does not have a case that talks about a change in statute between the first proceeding and the 45
second proceeding. She said she is happy to hand out the cases she mentioned. She thinks both cases she mentioned 46
are clear that the claims can change but if the facts are still the same, the facts are still the same. We are not allowed in 47
the law to have a proceeding and be unhappy with the results and then find another theory and another theory and 48
another theory she said. There have been four appeals and her party contends that res judicata and collateral estoppel 49
bring an end to this proceeding. 50
9
1
LeAnn Brown said she has other reasons for the board to rule in her party’s favor. In March 2016 there was an 2
application for a building permit and the planning supervisor determined that a building permit was not needed. The 3
Board of Adjustment heard that and remanded it back to Michael Harvey. That was appealed and that appeal is 4
pending. Then the current planning supervisor on remand determined that it was a bona fide farm and the use of the 5
barn for weddings was incidental to the farm use. That was around November 2016. Her party appealed on December 6
1, 2016, and that case was heard on March 17, 2017. There is a pattern of taking a long time for her to get before the 7
Board of Adjustment, LeAnn Brown added. The Board of Adjustment determined that the barn was an events center 8
and reversed the current planning supervisor. That’s on appeal. There was a petition for review for that filed on May 4, 9
2017. There was an NOV (Notice of Violation) that was issued that Southeast Property Group, LLC, has appealed. Her 10
party filed an appeal of the determination that it was a rural special events center, which is one of the things that 11
happened. Those appeals have never been heard. And then we have this appeal. 12
13
LeAnn Brown said her first contention to this board is that because of the doctrines of res judicata and collateral 14
estoppel that this matter is not properly before the board and the board should determine that those doctrines should 15
prohibit Kara Brewer from seeking the opinion that she sought from Michael Harvey. LeAnn Brown plans to talk about 16
why her party believes the current planning supervisor erred and why she thinks he erred in saying that the materials 17
that he had before him were sufficient to comply with the current version of N.C.G.S. §153A-340(b)(2a). The party has a 18
pending application before the court to compel further compliance with the subpoenas this board issued. She said she 19
looked at whether to postpone this hearing because that’s pending and she wanted to preserve her rights to seek 20
additional documents and so that has been filed, but in looking at the documents that the subpoenaed parties chose to 21
produce to the board that are in Exhibit 1, she thinks the evidence is clear that Orange County erred in determining that 22
the owner of the property has an exemption certificate from the North Carolina Department of Revenue. She said she 23
thinks the last time she was before this board, Randy Herman asked her if she thought this board could look behind the 24
Department of Revenue to determine whether the information that department had was adequate to issue the 25
certificate. She does not plan to get there tonight but what Orange County did was look behind the clear language on 26
the face of the certificate and connect dots to say that a certificate issued to some entity other than the owner of the 27
property was in fact a certificate for the owner of the property. The certificate is issued in the name Wild Flora Farm. It is 28
not Wild Flora Farm, LLC. Wild Flora Farm, LLC, did not exist on the date the certificate was issued. 29
30
Karen Barrows noted that LeAnn Brown had spoken for 30 minutes and asked if she could wrap up in the next 10 31
minutes. 32
33
LeAnn Brown said she could wrap up in 10 to 15 minutes and asked that the board give her at least as much time as 34
County Attorney James Bryan and Current Planning Supervisor Michael Harvey took. LeAnn Brown said she is not 35
presenting a lot of evidence but she wants to be sure her party has the proper due process for the board to hear this 36
argument in full. 37
38
LeAnn Brown read the portion of the N.C.G.S. §153A-340(b)(2a) that states that the property owner must hold the 39
qualifying certificate of a farming sales tax exemption. She noted that the sales tax exemption certificate requires an 40
income from farming of $10,000 for the previous tax year or for an average of $10,000 a year over a three-year period. 41
The certificate is dated November 22, 2017. The preceding tax year would be 2016. The profit-and-loss sheet produced 42
identifies the tax year as 2016. That document lists Wild Flora Farm without the LLC and lists Kara Brewer’s name 43
under it. The application included in the documents that were produced in answer to the subpoena has Kara Brewer as 44
the applicant doing business as Wild Flora Farm. What that means is that the person who applied was Kara Brewer and 45
she used the DBA of Wild Flora Farm. There is no evidence that she used the DBA of Wild Flora Farm as an individual 46
but that’s what her application to the Department of Revenue says. So, LeAnn Brown thinks the board should look at 47
that at face value and say the person who applied is Kara Brewer doing business as Wild Flora Farm. The entity that 48
owned the property at the time the application was made was Southeast Property Group, LLC. There is no dispute 49
about that. Wild Flora Farm, LLC, was not created until February 14, 2017. It could not have had income in 2016. The 50
10
tax identification number was not obtained until April 12, 2017. The tax ID number on the documents was partially 1
redacted. It looks similar but the document produced shows that the ID was obtained April 12, 2017. The articles of 2
merger for Wild Flora Farm, LLC, and Southeast Property Group, LLC, were not filed until February 19, 2018, on a plan 3
of merger dated February 14, 2018. Nothing in the evidence suggests that an exemption certificate obtained was 4
obtained in the name of the owner of the property, LeAnn Brown siad. There is an assumed name certificate for 5
Southeast Property Group, LLC, to do business as Wild Flora Farm but it wasn’t recorded until October 12, 2017. Here 6
is how the staff erred. Staff determined that Kara Brewer is a member/manager of the LLC and therefore a certificate in 7
her name is the same as a certificate in the name of the LLC. And then there was the merger and the names are similar 8
so if we sort of connect the dots, it must all be the same thing. LeAnn Brown said we cannot look behind what that 9
certificate says and we likewise cannot do the work for someone who is applying and say well, if you’d done it right, it 10
would say this or this. Kara Brewer is not Southeast Property Group, LLC. The fact that she is a member of it simply 11
means she is a member of it. Just as she would not want her personal liability to be subject to any lawsuit filed against 12
Southeast Property Group, LLC, her as an individual obtaining the certificate of exemption is not adequate to meet the 13
statute. Unless the certificate said Southeast Property Group, LLC, related to income it earned in 2016, it would not be 14
a certificate that meets the requirements of the statute. 15
16
LeAnn Brown said that Michael Harvey noted in his letter from which her party appealed in the thing that is an advisory 17
opinion that changes in the property ownership could subject the property to the Unified Development Ordinance. It was 18
not part of Michael Harvey’s final and binding determination but she thinks it was an interesting point. She would ask 19
the board to find that the request to the county and the grant to the county is precluded by the doctrines of res judicata 20
and collateral estoppel. And on the merits, if the board does not find the evidence that she asks it to find, LeAnn Brown 21
noted the records on the documents do not show that the owner of the property at the time the application was made to 22
the county had a tax exemption certificate. And the county cannot look beyond what the statute requires and allow 23
someone to get a certificate in someone else’s name and apply it. That is not what the statute says you can do. The 24
statute does not say you can get the certificate in your personal name and apply it to your corporate entity. 25
26
Randy Herman requested to ask a question. Karen Barrows said she would ask Andy Petesch to speak first and then 27
give the board time to ask questions. 28
29
Andy Petesch addressed the board on behalf of Kara Brewer and Wild Flora Farm, LLC, which is the successor to 30
Southeast Property Group, LLC. Starting with the res judicata and collateral estoppel argument, LeAnn Brown brought 31
up the issue of Michael Harvey having made a determination. Andy Petesch would submit that it was not an appealable 32
determination at any point. It was never in writing. It was something that was verbally conveyed and as Barry Katz 33
noted and as reflected in the minutes, it was something that Kara Brewer had volunteered to pursue. He submitted 34
copies of an excerpt from the abstract of the Special Use Permit hearing and an excerpt from the approved minutes. He 35
took both from the certified record that went to the Superior Court. He has highlighted some key passages, starting with 36
the abstract case. In staff comments, it is noted that there has been a heightened level of concern that the property 37
meets the requirements to be classified as a farm. On the next page, the second paragraph from the bottom states that 38
when staff first met with the property owner, staff indicated that the project would require a Special Use Permit. That 39
was part of a conversation and not a written determination, which would be required for an appeal. He continued to 40
read from the same paragraph that the property owner informed staff that the property was in farm status but Kara 41
Brewer thought it was prudent to go through the Special Use Permit process. The same paragraph states that the 42
property owner had the ability to have a wedding venue or a retreat on the property as it is recognized as a farm 43
according to state law. That fact has frustrated some residents. Andy Petesch then read from the next page, under the 44
first comment from staff, it states that the farm status is completely separate and irrelevant and has no bearing on the 45
this permit process or on the applicant being allowed to pursue a Special Use Permit proposing the development of the 46
land. Andy Petesch said at the beginning of that hearing, Michael Harvey gave a preface that the board’s purpose that 47
night was not to make a determination on the property’s status as a farm as defined under General Statutes. 48
49
11
Andy Petesch said what these documents plainly show is that these were two separate issues and in fact … Andy 1
Petesch then passed out copies of an email from Orange County Planner Patrick Mallett to Kara Brewer that indicates 2
that there were always two paths: the proposed barn, as a retreat center, could be permitted in that zoning district with 3
the issuance of a Class B Special Use Permit or as a bona fide farm operation as part of the agritourism activity 4
associated with the law. Those were the two possibilities. It was always presented that she could have gone on either 5
path and one did not preclude the other, Andy Petesch said. What the case law does show is that if she were granted a 6
Special Use Permit, then she could not later attack that Special Use Permit by saying she is exempt. But she never 7
accepted that benefit. She was denied that, which left the possibility of pursuing the farm exemption completely open. 8
9
Michael Harvey asked for the exhibit number for the email from Patrick Mallett to Kara Brewer. There was brief sorting 10
out of the exhibit numbers. Andy Petesch answered the abstract would be Exhibit 6, the minutes would be Exhibit 7, 11
and the email would be Exhibit 8. 12
13
Barry Katz said if Kara Brewer had been granted the Special Use Permit, she would have had no reason to say that this 14
is not a county matter but rather a state matter. 15
16
Andy Petesch said that’s interesting that you bring that up because in the case of Marsh v. Union County Board of 17
Adjustment, a gentleman wanted to operate a rodeo and applied for a Special Use Permit, which was granted with nine 18
conditions. One of those conditions was that he could only have four events a year and that he had to open a second 19
access. When his Special Use Permit was revoked for not meeting the conditions, Marsh appealed to Superior Court 20
that his property was exempt and he did not need the Special Use Permit. The court decided to uphold the Board of 21
Adjustment’s decision. Marsh did not appeal the decision of the Superior Court but continued to operate. He was issued 22
another notice of violation. He again argued that he was exempt and the court told Marsh that he had missed his 23
chance to make an appeal. Andy Petesch said that is not what is happening here because Kara Brewer did appeal and 24
the fact that it was dismissed with prejudice adds no special effect under the law. Andy Petesch said the board will not 25
find in the petition the reason that she should be allowed to operate is because she is exempt but is limited only to the 26
Special Use Permit and not statutory exemption and that is why res judicata and collateral estoppel do not apply here. 27
28
Andy Petesch said in the case of Bailey and Associates v. Wilmington County Board of Adjustment, the court 29
referenced, in reference to judicial estoppel where a party was seeking to say an application was submitted recognizing 30
property was in a wetland area and now the applicant is changing it to say not in a wetland area, the court described 31
what the Supreme Court says are three factors useful in determining whether judicial estoppel should be invoked, with 32
only the first being essential in the doctrine’s invocation. First, the party’s subsequent position must be clearly 33
inconsistent with its earlier position. Kara Brewer, consistent with staff, has held the entire time that she can seek the 34
exemption. That she would be exempt once she starts operating a bona fide farm and can do agritourism. At that time, 35
as LeAnn Brown alluded, the agritourism was related to or incidental. Now that’s changed and the General Assembly 36
has clarified that standard. Andy Petesch referred back to the court case that the second factor is whether the party has 37
succeeded in persuading an earlier court to that position so that acceptance of a subsequent position in a later 38
proceeding might pose a threat to judicial integrity. He said that gets at the case LeAnn Brown brought up earlier with 39
respect to a cell tower because the shortened cell tower proposal was not substantially different from the first proposal 40
of a slightly taller cell tower. Andy Petesch said one of the reasons why the exemption was not pursued in the beginning 41
is that the owner had not yet begun any agricultural activities on the property so staff could not have said at that time 42
that the property was exempt. There was no agriculture was going on at that time. In order for Kara Brewer to proceed 43
faster, at that point the Special Use Permit was a more streamlined process. 44
45
Barry Katz said Kara Brewer made an error in how she pursued this and now Andy Petesch is claiming she gets a do-46
over. 47
48
12
Andy Petesch said he would disagree with that characterization of it. There was never an error made. It was indicated 1
to Kara Brewer that she could have pursued either option but one was a faster option. It did not work out but that did not 2
mean that she is precluded from pursuing the other. 3
4
Barry Katz said that the board has heard that it may be, depending on what case law you’re looking at, that she is 5
precluded. And then there is this issue that the board has heard that there is an ownership discontinuity. Would Andy 6
Petesch get to that as well? 7
8
Andy Petesch said he would. He said LeAnn Brown did not present any case that is squared on the facts of this case 9
and he has shown the board several reasons why this case is distinguished from other cases. 10
11
Barry Katz said the board has not had time to look at the cases that either Andy Petesch or LeAnn Brown has 12
presented and has not made any determination at all. 13
14
Andy Petesch said the Board of Adjustment does not have the equitable powers to make such a determination. He 15
believes the power is too broad for this board and the board’s powers are more narrowly prescribed. 16
17
Barry Katz asked if Andy Petesch believes that this would be better decided by Superior Court. 18
19
Andy Petesch answered that he believes LeAnn Brown needs to raise the issue now for it to be considered in Superior 20
Court and he does not believe this board has the authority granted by the state to adjudicate res judicata and collateral 21
estoppel issues. He said he thinks it would be potentially different in a case where you have a very clear Special Use 22
Permit being submitted because that usually is included in the language of the UDO with regards to submitting a 23
substantially similar application but in this case, we’re talking about something very different from that. 24
25
Karen Barrows asked Barry Katz to hold his questions. 26
27
Andy Petesch said to address the merits of the materials that have been submitted with respect to Michael Harvey’s 28
decision, referring to the agenda packet, the application for a qualifying farmer exemption certificate on Page 70, LeAnn 29
Brown tried to indicate that it would be unreasonable for the staff to go behind the Department of Revenue but he would 30
submit that the application clearly references that if the owner is an entity, partnership or LLC, enter the tax ID number 31
on Line 1. Kara Brewer gave the identification number of the LLC and it has been partially redacted but its last three 32
numbers clearly match that of Kara Brewer and Wild Flora Farm. It is the LLC that has made the application and that is 33
further underscored on the profit-and-loss Schedule F, the 1040 form, that again the Wild Flora Farm is the proprietor 34
and the ID number. It also includes a social security number that has been redacted. A single-member LLC Wild Flora 35
Farm, LLC, sole member, also part of plan of merger on Page 74 indicated under paragraph 4 that Kara Brewer was 36
the sole member of Southeast Property Group and Wild Flora Farm. When you have a single member LLC, it is not 37
regarded differently from Kara Brewer herself for tax purposes. From a Department of Revenue standpoint, there is 38
zero difference between Kara Brewer and Wild Flora Farm, LLC, but it is clear that the certificate is issued to Wild Flora 39
Farm, LLC, and not a DBA because the federal tax ID number is listed specifically there connecting it. Whether there 40
was a typo in terms of the pen not listing LLC or whether she put her name on the wrong line, those things are 41
irrelevant or at least it is within Michael Harvey’s power and this board’s power to look at this and make a finding of fact 42
that it was indeed Wild Flora Farm, LLC, that was issued the certificate. While Southeast Property Group, LLC, was the 43
property owner of the time, in October 2017, the merger process had been started and it became effective in February 44
of 2018. The certification of merger was recorded with the Orange County Register of Deeds February 14, 2018. This is 45
a de novo review by this board that Wild Flora Farm is the owner of this property and is also the holder of the qualifying 46
farmer exemption and therefore it meets the statutory standard. As far as it being used for agritourism, Paragraph 2 (a) 47
clearly addresses wedding, meals as being agritourism activities. He requested that this board affirm Michael Harvey’s 48
determination that Wild Flora Farm, LLC, Kara Brewer, The Barn of Chapel Hill, however you want to frame it, meets 49
the statutory requirements and is therefore exempt from the UDO and other zoning regulations of Orange County. 50
13
1
Karen Barrows invited questions from the board. 2
3
Randy Herman said he has a question to ask for both attorneys and invited Andy Petesch to answer first because he 4
was already standing. Randy Herman said it relates to the fact that we have on appeal a decision of the planning staff 5
which you have said was probably not correct at the time because at the time Southeast Property Group, LLC, and Wild 6
Flora Farm, LLC, were not the same entity, but because of the merger, Andy Petesch would now submit is correct 7
because the facts have changed, so is the board supposed to be reviewing the facts as they were presented to Michael 8
Harvey at the time or reviewing the facts as they exist today. 9
10
Andy Petesch answered that with respect to the first part of that and what was the status when SPG still was a record 11
owner of the property, he would submit that this is a brand new statute that has not been interpreted in the courts and 12
so the question about whether single member LLCs with unity of ownership satisfy the statute, that is still an open 13
question. 14
15
Randy Herman said that aside. 16
17
Andy Petesch said to get to the real part of your question, the issue is what was the question presented to Michael 18
Harvey and you assess that same question with the evidence before you. Because if we were just limited to the 19
evidence he had at the time he made the decision, we could have skipped a lot of this. But now you have additional 20
evidence. And Andy Petesch added that shortly after that merger was completed, he submitted a supplement to 21
Michael Harvey so that the current planning supervisor had that information with respect to the ownership of the 22
property by Wild Flora Farm vis-a-vis the merger. 23
24
Randy Herman said to LeAnn Brown let’s assume hypothetically that the certificate was issued to Wild Flora Farm, LLC, 25
at the time that the property was owned by Southeast Property Group, LLC, but since then they have merged and are 26
the same entity. What effect does this have on the appeal if we assume that facts were incorrect at the time but they 27
are correct today? 28
29
LeAnn Brown said that she does not think the Board of Adjustment review power over a staff member is to take an 30
appeal that was filed in 2017, allow someone to do something in 2018 and say, ‘Oh, never mind. We just didn’t get to 31
you before the facts changed.’ We are deciding based on what the facts were when Michael Harvey made the decision 32
in 2017. She also reminded the board that the profit-and-loss document is from 2016 when Wild Flora Farm, LLC, did 33
not exist. So, the argument that it is really Wild Flora Farm, LLC, cannot possibly be correct. It is her position that 34
whatever has happened subsequently, Kara Brewer would have to go back through the process and do this correctly. If 35
Kara Brewer went to the Department of Revenue, applied in the property entity, showed income in that entity’s name for 36
the period that she needed it and brought that back to Orange County, perhaps there would be a different set of facts. 37
But you can’t fix this for her. She didn’t do this right. The county can’t fix it for her and I don’t think the Board of 38
Adjustment can either, LeAnn Brown said. 39
40
Barry Katz said so on September 21, 2017, Kara Brewer filed an application that included the 2016 taxes? 41
42
LeAnn Brown answered it includes a profit-and-loss statement from 2016. 43
44
Barry Katz said and what she has here identifies herself as Kara Brewer with an LLC. But in fact in 2016 she was not 45
that entity. Is that what you are arguing? 46
47
LeAnn Brown said in 2016, Wild Flora Farm, LLC, did not exist. And it wasn’t a DBA for Southeast Property Group, 48
LLC, because that assumed name was not filed until afterward. And no one is arguing that it is because that’s not its tax 49
14
ID number. So, yes, LeAnn Brown said, it’s her contention that it is impossible for an entity that does not exist to earn 1
income the year before it exists. 2
3
Susan Halkiotis said there is not a signature or a date of when this was filed. Usually there is a signature on the 4
Schedule F. 5
6
LeAnn Brown said she is looking at it just as the board is and it was attached to Kara Brewer’s application so she does 7
not know when it was filed. 8
9
Susan Halkiotis asked if it was an amended return. 10
11
Andy Petesch said he does not know the nature of the return. What was requested on the subpoena request was the 12
document submitted to the Department of Revenue with respect to the qualifying farmer exemption. This was part of the 13
exemption application. 14
15
Susan Halkiotis said just because the profit-and-loss statement is for 2016 doesn’t mean that it was filed by April 15, 16
2017. 17
18
Andy Petesch said all he could say is he does not have more information about that but what he would submit is that 19
the Department of Revenue would be able to look and see whether a filing had been made and it was that department’s 20
determination that the filing was compliant. 21
22
Andy Petesch said he would like to respond to the contention that Wild Flora Farm did not exist in 2016 and somehow 23
makes this void. He submitted North Carolina Department of Revenue Directive CD02-1 states that a single-member 24
LLC that is not classified as a corporation is a disregarded entity from its single owner. So, the fact by 2017 when Wild 25
Flora Farm, LLC, did exist and tax returns were filed, and the application was made, there is no distinction between 26
Wild Flora Farm and Kara Brewer from a state or federal tax standpoint. 27
28
Susan Halkiotis said there is a distinction for the application. For the application that was produced for the exemption 29
certificate number, there is clearly a distinction. They are asking for the farm’s income and not Kara Brewer’s income. 30
31
LeAnn Brown said she would like to object to the document, which does not relate to the farm exemption at all. The 32
document that Andy Petesch just handed the board. She wanted to object to the board receiving it, for the record. 33
34
Karen Barrows said so we shan’t. 35
36
Susan Halkiotis said she thinks Andy Petesch has said that the employer ID that ends in 804 is the same on all 37
documents. 38
39
Andy Petesch said that’s correct. 40
41
Barry Katz asked if Kara Brewer had an employer identification number in 2015. 42
43
Andy Petesch answered it was issued in 2017. Andy Petesch said the revenue is listed as farm revenue. Whether it 44
was Kara Brewer at the time, because it’s a disregarded entity, this is a question outside this board’s purview. He 45
believes the question before this board is who was the qualifying farm tax exemption certificate issued to. And the card 46
itself says Kara Brewer and Wild Flora Farm. He believes the documents make clear that the entity that the Department 47
of Revenue issued it to is Wild Flora Farm, LLC, vis-a-vis an employer identification number. 48
49
Barry Katz checked that Andy Petesch did not think that res jurisdicta and collateral estoppel apply. 50
15
1
Andy Petesch agreed that was his argument. 2
3
Randy Herman asked LeAnn Brown if hypothetically the tax exemption was clearly issued to Wild Flora Farm, LLC, and 4
it read that way and then LeAnn Brown was able to show the board that Wild Flora Farm, LLC, did not actually have 5
any income to qualify for the certificate, in that case does LeAnn Brown believe that under the statute this board could 6
disregard the certificate? 7
8
LeAnn Brown answered that is an interesting question with this brand new statute and she should note James Bryan’s 9
observation earlier was a good one that the statute, inartfully written as it is, appears to give the county the ability to 10
look at things. Otherwise, who is making the determination whether or not it is a farm activity if not the county? LeAnn 11
Brown does think the board is allowed to look at what the statutes say and the statute says the certificate has to be 12
issued to the owner of the property. We know it wasn’t. When Michael Harvey made his decision, it was not yet merged. 13
The board is also to look at 105 and 105 states that a qualifying farmer has income from farming operations for the 14
preceding tax year of $10,000 or more. And we know the entity didn’t exist. She thinks the board can look at that. If the 15
board gives the Department of Revenue the benefit of the doubt, whether or not Kara Brewer amended her return, it is 16
impossible for Wild Flora Farm, LLC, to earn income in a year in which it did not exist. She thinks that is not the entity to 17
whom the Department of Revenue issued the certificate and that is why it is written the way it is, because that entity did 18
not exist in 2016 to have generated income. In answer to the deeper question Randy Herman is asking whether the 19
board can look at whether the Department of Revenue erred in issuing a certificate, she said she does not know that 20
she knows the answer to that but the Board of Adjustment has pretty broad power to enforce the UDO. But in this case, 21
she doesn’t think the board has to worry about it because the board knows that the entity did not have income in 2016 22
so the board knows that the Department of Revenue did not issue the entity a certificate. It must be to Kara Brewer 23
individually, DBA Wild Flora Farm. 24
25
Barry Katz said starting with this process in 2015, the board was under the impression that this was a qualified farm 26
because there were forests on it and whatnot. The whole time there was the impression that this was a qualified farm, 27
but is obtaining the exemption certificate what documents it as a qualified farm? 28
29
LeAnn Brown answered no, the statute still contains the factors it had before with the exception of one of the factors 30
she relied on earlier which was the farm number. One of the positive changes in the statute, from LeAnn Brown’s 31
perspective, is that it removed the requirement of the farm number. The other factors are still there. The forestry plan is 32
still there, although you have in your evidence that the forest isn’t still there. This is a separate thing. This is something 33
that bootstraps a building on very special facts. 34
35
Susan Halkiotis said she would like to point out, especially for Randy Herman’s benefit, that beginning in 2015, the 36
board had questions all along about the determination that we were starting with a farm and this was an agritourism 37
activity. So, in fact tonight’s meeting probably is no different in character from our first meeting in 2015 in that so much 38
circuitous information was presented at the time. Susan Halkiotis acknowledged that Andy Petesch was not present at 39
that time, but even going back nearly three years ago, this board had a lot of questions and skepticism about what was 40
being presented to qualify this property as a farm. And so, how that relates to tonight is that this is déjà vu. 41
42
Barry Katz said he can recall Kara Brewer’s testimony as she characterized the farming activities at the public hearing 43
for the Special Use Permit. She had two young children who were in grade school. She would pick them up after school 44
and take them out there to transplant seedlings. That was her farm. She had these beds of flowers and she was going 45
to transplant flowers. And then came the chestnut trees when she got advice that she needed to have something that 46
looked like a farm. The chestnut trees and the bees and all that came later. 47
48
James Bryan asked to speak. He said he would like to clarify whether the board can consider new evidence. James 49
Bryan said it is clear that the board can. He referred to a handout he has given the board from the School of 50
16
Government that says in other cases the board may need to consider additional evidence to make a decision. He said 1
it’s important to remember that a board review of the board’s decision is different from Michael Harvey’s review of his 2
decision. It’s a review of his determination so it’s just a fact of whether something is or is not. Michael Harvey 3
determined that it is certified as something. Whether he had any rationale or reasoning is meaningless. He could have 4
written only that this was his final and binding determination that X. The board, however, is held to a different standard. 5
The board has to have findings of fact and conclusions for it. What’s before this board is everything that is competent, 6
material, substantial evidence. 7
8
James Bryan said regarding res judicata and collateral estoppel, there are two things to consider. One is if the board is 9
truly concerned and not persuaded by his advice, the board can continue the hearing and tell the attorneys to brief this 10
for the board. They mentioned a lot of cases and didn’t provide the cases. The board can continue this if it wants to do 11
so but James Bryan said this is a new matter; 2(a) did not exist. There are issues that have been decided. There is a 12
previous order with a finding of fact that this is a bona fide farm. So, the board cannot come back and say it’s not. But 13
that is irrelevant to this discussion. All that is relevant to the discussion is the rule. Who owns the property? Do they 14
hold a tax exemption certificate from the Department of Revenue? And is the structure used for agritourism? That’s all 15
that matters. 16
17
James Bryan said regarding this new law, one other case has gone up to the Court of Appeals, Jeffries v. Harnett 18
County. They had sort of the mirror image of this. That one was a gun range and the board had to look at it. The statute 19
mentions weddings but doesn’t mention hunting. The court decided that most hunting is not agritourism but went on to 20
say that the property owner could go on to apply for a Conditional Use Permit. James Bryan said it is not exactly on 21
point, the property owner went for the agritourism exemption first instead of the Conditional Use Permit. But the court is 22
saying, ‘You didn’t get this one. You are free to go for another permit.’ 23
24
Randy Herman asked James Bryan, regarding the issue of looking behind the certificate, if the board thinks a certificate 25
was supposed to be issued for Wild Flora Farm, LLC, and the board thinks that Wild Flora Farm, LLC, didn’t have 26
income sufficient to gain the certificate and therefore the issuance of the certificate was wrong, can we look behind it or 27
do we have to say, ‘No, the certificate was issued and that’s the end of it.”? 28
29
James Bryan answered the board is held to the exact words of the statute and to their plain meaning. What the statute 30
says is the holder of the certificate – not someone who has the attributes of someone who would qualify. He said it’s not 31
shown in the photocopy very well but the letter from the Department of Revenue, there’s an actual card for it. He said 32
he thinks it would be an absurd reading to say it is somebody who literally holds the card so you could pass it around 33
the table. But he thinks it says that. If you want to read something into it, there has to be some reason. There has to be 34
some statutory construction that you say, ‘Oh, this is probably what they meant.’ And he does not think the board has 35
heard anything about that. He doesn’t think it’s ambiguous. He thinks the plain meaning is intended. If it’s ambiguous, 36
you have to resolve it with statutory construction and if there is any ambiguity left, you have to resolve it in favor of the 37
property owner for the free use of land. The courts have been very clear for a long time. It is very settled that anything 38
done through the zoning, Chapter 153 A, Article 18 is a derogation of property rights and has to be narrowly construed 39
in favor of the property owner. So, if there’s a question, that’s where the tie to the runner goes. One side has to win and 40
it’s the free use of property. 41
42
Barry Katz asked for clarification that the board does not get to consider res judicata and collateral estoppel. 43
44
James Bryan answered res judicata would be if this was before the board again. So, if someone applies for a kennel 45
and the board denies a kennel and then the same person comes for a kennel that would be res judicata. He does not 46
see how it applies in this matter – 2(a) did not exist. 47
48
Barry Katz said James Bryan mentioned that if it’s like a tie, the privilege goes to the property owner. But the board’s 49
issue here is whether there is any real continuity. Isn’t that so? 50
17
1
James Bryan said the Board of Adjustment needs to show where in the General Statutes it states that there has to be 2
continuity. 3
4
Barry Katz said to James Bryan that Bryan had just said that the statute doesn’t mean that you can just have this card 5
and pass around this card. If Kara Brewer was the one that actually owned this property and the LLC was formed 6
sometime after, and it’s not clear that Kara Brewer is or was at that time the LLC, then how can the board give any 7
advantage to a property owner? 8
9
James Bryan said he thinks what Barry Katz is implying is that the Department of Revenue made a mistake. That the 10
certificate on its face when it says Wild Flora Farm doesn’t mean Wild Flora Farm or shouldn’t have stated Wild Flora 11
Farm. That it was either a clerical error or a mistake on their part or maybe fraud was committed on them. Whatever it 12
is, James Bryan doesn’t think the statute clearly indicates that the board can consider that. He thinks the board has to 13
read the statute as: ‘A person who holds a qualifying farmer sales tax exemption certificate from the Department of 14
Revenue.’ 15
16
Barry Katz checked that the board is also to consider whether Michael Harvey erred. 17
18
James Bryan answered no, but rather the determination was right or wrong. 19
20
Barry Katz asked whether the board is to make any judgment on whether the determination was right or wrong. 21
22
James Bryan answered yes, the board is to determine whether the structure located on the property is classified as a 23
bona fide farm purpose under the new section of statute. 24
25
Karen Barrows asked if it was time to close the public hearing. 26
27
LeAnn Brown said that she was not sure she had requested that Exhibits 3, 4 and 5 (the petition, the writ, and the 28
dismissal) be moved into evidence. 29
30
MOTION by Randy Herman to move those exhibits into evidence. Barry Katz seconded. 31
VOTE: UNANIMOUS 32
33
LeAnn Brown said she needed to put an objection in the record, in case this case goes elsewhere, to the last bit of 34
information and argument that the board received from James Bryan. The information included in evidence indicates 35
that the county attorney’s office advised Michael Harvey as to the opinion the board is now reviewing and when the 36
county attorney’s office starts making argument with regard to the case, it’s a violation of her clients’ due process rights 37
and potentially Andy Petesch’s. 38
39
Andy Petesch requested that the board make a motion to accept all the documents he handed up into evidence. There 40
were Exhibits 6-8 and a 9 that LeAnn Brown had objected to. Andy Petesch said he did not see any reason to not enter 41
it into evidence as well. 42
43
MOTION by Barry Katz to move those exhibits into evidence. Susan Halkiotis seconded. 44
VOTE: UNANIMOUS 45
46
Susan Halkiotis asked James Bryan, regarding facts, on the slide James Bryan had put up earlier, there were three 47
requirements for facts: competent, material, substantial. In order for evidence to be competent, James Bryan had 48
indicated that it needed to be trustworthy. If members of this board were to find any of this evidence not to be 49
trustworthy based on our own questions about, for instance, how that certificate was obtained, or the name on the 50
18
certificate, etc., etc., can we do that? Can we question the trustworthiness of the evidence and therefore the 1
competence of the evidence? 2
3
James Bryan said that is nuanced. The trustworthiness speaks to a piece of evidence for what it is proffered to be. For 4
instance, if you were to have an affidavit from somebody and you don’t know whether that’s their true statement, 5
whether it’s notarized and things like that speak to the trustworthiness of the affidavit. The actual substance of it, that’s 6
not the competency that they’re talking about with the rules of evidence. For instance, if you were to have a case that 7
dealt with traffic, if you had an engineer’s sealed report that it would increase traffic tenfold, then you would have a 8
competency issue with the trustworthiness of it if he wasn’t an engineer. If he gave the same report and you just didn’t 9
believe him, saying that he was only out there one day and it was a Saturday, not a Monday, that’s a very poor report 10
and I just can’t trust your conclusions, that’s different. That goes to whether there is substantial evidence of something 11
being there. 12
13
Susan Halkiotis said then she has questions about the substantial qualifications for this evidence, I guess. 14
15
Karen Barrows said I think we can still close the public hearing and still speak with James Bryan. She asked if that is 16
correct. 17
18
James Bryan answered that she was correct. 19
20
Karen Barrows called for a motion to close the public hearing. 21
22
MOTION by Randy Herman to close the public hearing. Barry Katz seconded. 23
VOTE: UNANIMOUS 24
25
Randy Herman said not having been here for any of the previous iterations of this case, as James Bryan stated there 26
are only three issues that the board has to determine: whether a tax certificate was issued, whether the person who 27
owned the property was the holder of the certificate, and whether the structure is used for agritourism. There is a pretty 28
clear definition of agritourism in the statute. And he does not think that anyone is seriously contending that it does not 29
meet that definition and no one is really questioning whether the tax certificate was issued so really the only question 30
that remains is whether the person who owns the property is the same person who holds the certificate. And then the 31
board has to look at specifically what does the certificate say and what does the application for the certificate say. And 32
it’s interesting because it is pretty clear that if you just look at the certificate it does not say LLC, it just says Wild Flora 33
Farm, which is not necessarily the same thing. But if you go back and look at the application that was submitted, it 34
clearly shows a federal employer identification number, that it is an LLC is clearly checked, but on the other hand if you 35
look under No. 3, it says the applicant’s legal name is Kara Brewer. It doesn’t say Wild Flora Farm, LLC. So, the 36
application kind of goes both ways and it isn’t clear from the application who actually is applying. And there’s evidence 37
that could support either conclusion in there, so he doesn’t know. 38
39
Barry Katz asked Randy Herman to reiterate the three items for consideration, which he did. 40
41
Barry Katz said there has been argument that the entity in 2016 was not the same entity as what’s on the document in 42
2017. That’s a problem. 43
44
Randy Herman said there are two different ways you can look at that. You can say the certificate was issued in error 45
and shouldn’t have been issued because maybe the information provided on the return was inaccurate or was 46
fraudulent or something and he doesn’t think the board can consider that kind of argument because once the certificate 47
is issued, the board has to take it at face value. But, he does think it goes toward the question of who was the intended 48
holder of the certificate; was it Kara Brewer or was it the LLC. And if the fact is that the LLC did not have any income for 49
19
the period for which the certificate was issued, then he thinks that it tends to support the conclusion that the Department 1
of Revenue did not intend to issue the certificate to the LLC but to Kara Brewer personally. 2
3
Barry Katz asked what would the consequence of that be. 4
5
Randy Herman said if the certificate was issued Kara Brewer and she is the holder of the certificate, she is not the 6
property owner and so in that case the building would not qualify under the statute. So, really the question is: Who is 7
the holder of the certificate, which was issued in two different names and one of which was maybe supposed to say 8
LLC but doesn’t say LLC and based on the application which has two names, one of which is the name of the LLC 9
without the LLC written? The board is trying to guess at what the Department of Revenue intended when it issued this. 10
11
Barry Katz said I don’t think the department thought that much about it. 12
13
Randy Herman said that’s part of the problem. And if you look at the certificate, I think it is pretty clear that all the 14
Department of Revenue did was copy what was written on the application. 15
16
Barry Katz said it seems that Kara Brewer was the owner and the LLC was formed later. 17
18
Randy Herman said Southeast Property Group, LLC, was the owner of the property at the time. It has since merged. 19
So, if the board is taking the facts as of today, the LLCs are the same thing but Kara Brewer as an individual is not. It 20
clearly indicates on the application that it is for an LLC but the name under applicant is not an LLC. 21
22
Barry Katz asked Randy Herman for his opinion on when the LLCs existed. 23
24
Randy Herman answered Southeast Property Group, LLC, existed earlier and Wild Flora Farm, LLC, was created in 25
early 2017. So, it existed at the time that the certificate was filed but maybe didn’t have the income. 26
27
Barry Katz asked Randy Herman that it is his opinion that this is the only thing to consider and not the arguments that 28
were made considering res judicata and collateral estoppel but he does not think they are correct because the issue 29
before the board is different from what was presented in the earlier case. 30
31
Barry Katz said one of the arguments before the board is that the board has made decisions in the past on this case 32
and the property owner hasn’t appealed those decisions in a timely manner. That should have ended it. 33
34
Randy Herman said the decision that was made earlier was that the property did not qualify for a Special Use Permit. 35
And they are not arguing now that they do qualify for a Special Use Permit. They are arguing that they don’t need a 36
Special Use Permit because they are exempt from zoning. 37
38
Barry Katz said we have heard this over and over again. 39
40
Randy Herman said that the board has been told, although he hasn’t looked through the documents to verify, that the 41
Board of Adjustment at some point earlier made the determination that there was bona fide farm use on the property. 42
43
Barry Katz said he does not think the board did. 44
45
Susan Halkiotis said if the board did, it was only with opposition because this has always been the point of contention 46
with this property. 47
48
Karen Barrows said she wasn’t sure the board was contesting that farm activities were going on but … 49
50
20
Susan Halkiotis said they were added later. 1
2
Karen Barrows said right, they were incidental to the barn. 3
4
Randy Herman said the question has to be at the time that Michael Harvey reviewed whether the property was exempt 5
from zoning, was the property exempt from zoning based on the laws that existed at that time. 6
7
Susan Halkiotis said the question tonight is with regard to Michael Harvey’s determination in October 2017. 8
9
Randy Herman agreed. 10
11
Susan Halkiotis said her feeling about this is Michael Harvey made a determination based on evidence that was 12
presented to him which in his role with the Planning Department he can’t question. He was looking at a certificate and 13
the new statute and he made a determination. But the appeal is based on these questions about what was presented, 14
about the validity of the certificate to begin with. If the three questions are that the board has to find positively for the 15
questions of agritourism, who owns the property, and is the owner of the property actually who the certificate is issued 16
to, she can’t say that for sure. She can’t vote or affirm in any way that those last two items are true. She can’t say that 17
the person who owns the property is the same entity to whom the certificate was issued because of the questions that 18
have been raised. So, she wouldn’t be able to find positively for all three of those questions. She is open to someone 19
arguing a different point with her. 20
21
Barry Katz agreed with Susan Halkiotis. 22
23
Karen Barrows said she thinks she is persuaded to agree with Susan Halkiotis. She had thought at the outset that this 24
was going to be clear and easy but of course it isn’t. It is ambiguous. 25
26
Barry Katz asked for someone to succinctly define the ambiguity. 27
28
Randy Herman said the ambiguity is that in order to support the determination of staff, the board would have to find that 29
the owner of the property was also the holder of the certificate. And the way that the name is reported on the certificate 30
and the way the name is reported on the application, it is not clear that the person who holds the certificate is the same 31
person who is the owner of the property. 32
33
Susan Halkiotis asked James Bryan whether the board has to make three motions, noting that on James Bryan’s slide, 34
there were motions regarding the findings of fact, conclusions, and affirming/reversing/modifying staff determination. 35
36
James Bryan recommended that the board make three separate motions. 37
38
Randy Herman said the board can make each of the findings of fact motions separately. 39
40
Susan Halkiotis checked with James Bryan that the question still comes under the substantial qualification because she 41
is figuring out how to word the findings of fact. 42
43
Randy Herman said he doesn’t think it does. He does not think that there is any question of whether the certificate is 44
valid. He does not think there is question of whether the certificate is substantial. It is what it is. But it concerns him still 45
a little bit because he thinks all the other indicators on the application indicate that it was supposed to be an application 46
for an LLC and the wrong name was put in on Line 3 and if Kara Brewer had put the name of the LLC on Line 3 then 47
there would be no question. So, basically the board is saying that she does not qualify because she made a small error 48
in her paperwork. That may be the right decision but it is concerning to him to look at it that way, he said. 49
50
21
Barry Katz said isn’t there an issue that if the LLC didn’t exist in 2016 and they have to file a financial statement for 1
2016 that the statement is not pertinent to the LLC. 2
3
Randy Herman said maybe it is and maybe it isn’t but he is not sure that it’s a determination that the board can make. 4
Even if the application was based on a totally fraudulent tax return and the parties could appear before us and prove 5
without a doubt that it was a fraudulent tax return, he thinks if the certificate was issued the board has to rely on that 6
because that’s what the statute says. So, he doesn’t think the board can say the certificate should not have been 7
issued. The only question is who was the certificate issued to and is that the same entity as the party who owns the 8
property. 9
10
Susan Halkiotis asked how the first motion should be worded. 11
12
Randy Herman suggested starting with the ones that are not controversial. 13
14
Karen Barrows suggested starting with the finding that the structure is used for agritourism. 15
16
MOTION by Randy Herman to find as fact that the property is being used for agritourism as that term is defined in the 17
statute. There was no second. 18 19
James Bryan said that is more of a conclusion. He suggested a template that includes citing the evidence or what was 20
presented. 21
22
Randy Herman said neither parties have disputed that weddings are taking place on the property. Prior minutes could 23
be relied upon. 24
25
James Bryan said pages 26 to 41 of the agenda abstract were entered into evidence. 26
27
Randy Herman said he would include pages 19-22 also, which includes the building permit. 28
29
Barry Katz said he does not think that the board has ever challenged the farm plan summary but like a business plan, 30
what actually happens is very different from what a business plan says. 31
32
Barry Katz said he would not accept this as a fact at all. It is not a fact. It is hypothetical. He said he has done too many 33
business plans to believe one. 34
35
James Bryan said this is a very good point of what is substantial evidence. The board can refer to the minutes of the 36
prior hearings, which was entered as an exhibit. He said the board does not have to be very specific. 37
38
Barry Katz said the proposal was made last year and he doesn’t remember anyone challenging it but the farm plan 39
wasn’t the focus. He noted that originally Kara Brewer said she was going to plant flowers with her children. And then 40
she moved on to this because she got better advice. 41
42
Susan Halkiotis said she agrees with Barry Katz. 43
44
Andy Petesch and LeAnn Brown conferred with James Bryan. 45
46
Karen Barrows said that the board would like to continue to make motions. 47
48
James Bryan said the attorneys had been working out how to make it easier for the board to make a motion and the 49
board could reopen the public hearing to hear evidence if that would help. 50
22
1
MOTION by Randy Herman to find as a matter of fact that the evidence presented on pages 19-22 and pages 26-41 and 2
also the evidence presented in the minutes contained in Exhibit 3 the board finds the property is being used for 3
agritourism as the term is defined in the statute. There was no second. 4
5 Barry Katz said he does not believe the farm plan summary, adding that it’s an aspirational document and not a 6
substantive document. 7
8
Randy Herman said the board has 100 pages of minutes concerning the activities that were taking place on the 9
property and the statute defines agritourism to include weddings so he doesn’t think there is any question that weddings 10
are taking place on the property. 11
12
Barry Katz said fine, weddings are taking place on the property. 13
14
Susan Halkiotis asked Randy Herman to amend the motion to not include the farm plan summary. 15
Barry Katz said he would prefer to just say Kara Brewer is holding weddings there. 16
17
Randy Herman said the board has to point to a specific piece of evidence that supports that finding and that would be 18
the previous minutes. 19
20
Karen Barrows suggested only using pages 19-22 as evidence. 21
22
Barry Katz said that would be fine. 23
24
Randy Herman said a building permit is also aspirational and not what is actually taking place. 25
26
Barry Katz agreed and said he would be fine with including pages 19-25. 27
28
Susan Halkiotis suggested the evidence include the minutes of previous meetings where it was not contested that 29
weddings are taking place on the property rather than the building permit and the plans. 30
31 MOTION by Randy Herman to find that based on the evidence previously presented in the minutes from the October 10, 32
2016, and October 24, 2016, meetings, which the board has accepted into evidence as Exhibit 3, that there is 33
agritourism activity taking place on the property as that term is defined in the statute. Barry Katz seconded. 34
DISCUSSION: Susan Halkiotis said she would vote for it but strictly on the wording, ‘agritourism as defined by the new 35
statute.’ Barry Katz added that in the board hearings the board heard testimony but the board never accepted that this 36
was a real agricultural entity that used agritourism as a way to supplement the income of a farmer. What we were 37
experiencing was an attempt to have an events center placed in an agricultural environment where the events center 38
was a business entity and it was not in fact adjunct or supplemental to an agricultural entity, Barry Katz said. Rather, it 39
was the primary purpose if not the sole purpose of citing it where it was. 40
VOTE: UNANIMOUS 41
42 MOTION by Randy Herman to find as a matter of fact that based on the deed which was included on pages 78-80 of the 43
documents and also the Articles of Merger on pages 85-86 the property is currently owned by Wild Flora Farm, LLC. 44
DISCUSSION: Susan Halkiotis said she was thinking about it. Barry Katz asked for Randy Herman to be clearer because 45
Southeast Property Group, LLC, was the purchaser. Randy Herman said the purchaser was Southeast Property Group, 46
LLC, and then Southeast Property Group, LLC, merged with Wild Flora Farm, LLC, with Wild Flora Farm, LLC, being 47
the surviving entity. So, as of today, the owner of the property is Wild Flora Farm, LLC. Susan Halkiotis noted that was 48
as of February 14, 2018. Randy Herman agreed. 49
SECONDED by Susan Halkiotis. 50
23
VOTE: UNANIMOUS 1
2
Barry Katz said he does not know how to phrase the next finding of fact, which is the most consequential. 3
4
James Bryan said if this were to be appealed to Superior Court, the court is going to look at it and the board has to tell 5
the court very explicitly here why the board decided one way or the other. The board needs to point to documents that 6
persuaded them to decide. The court will look at that and review whether that was arbitrary or capricious. 7
8
Susan Halkiotis asked Randy Herman to make the motion. 9
10 MOTION by Randy Herman moved to find as a matter of fact, based on evidence presented in the qualifying farmer 11
exemption certificate on Page 13 and also the application for that certificate which is found on pages 71-73, that Wild 12
Flora Farm, LLC, is not the holder for a qualifying farmer exemption certificate issued by the Department of Revenue. 13
Barry Katz seconded. 14
VOTE: UNANIMOUS 15
16
MOTION by Randy Herman moved to conclude as a matter of law that the structure located on the property is being used 17
for agritourism purposes as that term is defined in the statute. Susan Halkiotis seconded. 18 DISCUSSION: Barry Katz said there is an issue of continuity -- if it is being used for agritourism purposes, then the entity 19
that is running it is not the same entity that does not have the tax certificate. Randy Herman said that’s a separate 20
conclusion. 21
VOTE: UNANIMOUS 22
23
Karen Barrows said the next conclusion is with regards to who owns the property. Susan Halkiotis said she still doesn’t 24
know who owns the property. Randy Herman said the board made a finding of fact that Wild Flora Farm, LLC, owns the 25
property so he does not mind making that motion. Barry Katz said the board can agree to that. 26
27
MOTION by Randy Herman moved to conclude as a matter of law that the property is owned by Wild Flora Farm, LLC. 28
Barry Katz seconded. 29
VOTE: UNANIMOUS 30
31
Susan Halkiotis reminded the board that the last conclusion is with regards to whether the property owner holds the 32
certificate. 33
34
MOTION by Randy Herman to conclude as a matter of law that the owner of the property, Wild Flora Farm, LLC, is not a 35
holder of a qualifying farmer exemption certificate issued by the Department of Revenue. Susan Halkiotis seconded. 36 VOTE: UNANIMOUS 37
38 Susan Halkiotis asked to make a fourth conclusion that the property did not meet the statutory requirements for the 39
issuance of the decision made on October 13, 2017. 40
41 MOTION by Randy Herman to reverse the final and binding determination of staff as set forth in the letter dated October 42
13, 2017, that the property is a bona find farm purpose as set forth in the statutes. Barry Katz seconded. 43
DISCUSSION: Karen Barrows clarified with Randy Herman that the motion is that it’s not a bona fide farm or that the 44
exemption certificate was the issue. Randy Herman said he was saying that the exemption certificate was presented to 45
support the conclusion that it was a bona fide farm and because the property owner is not the same as the holder of the 46
certificate, that certificate cannot support that conclusion. 47
VOTE: UNANIMOUS 48
49
24
Barry Katz said it is still not clear to him whether there is any relevance to the argument related to res judicata and 1
collateral estoppel. Can the board make a motion to keep that issue open to be discussed at some later date at some 2
other venue. 3
4
Randy Herman said if the board has already determined that the determination of staff was in error, then that argument 5
is moot. Barry Katz said OK. 6
78 AGENDA ITEM 7: ADJOURNMENT 9
10
MOTION by Barry Katz to adjourn at 10 p.m. Susan Halkiotis seconded. 11
VOTE: UNANIMOUS 12
13
_________________________________________ 14 NAME OF CHAIR, CHAIR 15
25
ORANGE COUNTY
BOARD OF ADJUSTMENT
PUBLIC HEARING
AGENDA ITEM ABSTRACT CASE A-5-18
Meeting Date: November 12, 2018
Agenda
Item No. A-5-18
SUBJECT: CASE A-5-18: Class B Special Use Permit Proposing Expansion of an Existing
Camp/Retreat Facility Called “Camp Chestnut Ridge.”
DEPARTMENT: Planning and Inspections PUBLIC HEARING: (Y/N) Yes
ATTACHMENTS: INFORMATION CONTACT:
1. Site Assessment;
2. Application Package;
3. NIM and BOA Notification Materials;
4. Staff Comments;
5. Special Use Permit Findings of Fact; and
6. Existing and Previous
Special Use Permits.
Patrick R. Mallett, Planner II (919) 245-2577
Michael D. Harvey, Planner III (919) 245-2597
Craig Benedict, Director (919) 245-2575
UNDER SEPARATE COVER
A. Site Plan
PURPOSE: To hold a quasi-judicial public hearing, receive sworn testimony and evidence, and
take action on a Class B Special Use Permit (hereafter ‘SUP’) application proposing the
expansion/modification of an existing Camp/Retreat Center in accordance with the provisions of:
• 2.7 Special Uses;
• 5.2.2 Table of Permitted Uses;
• 5.3.2 Application of Use Standards – Special Uses; and
• 5.7.5 Standards for Recreational Facilities: Camp Retreat Center.
of the Unified Development Ordinance (hereafter ‘UDO’).
BACKGROUND: The basic facts concerning the current application are as follows:
Owner/Applicant/Operator: NC United Methodist Camp & Retreat Ministries, Inc.
Camp Chestnut Ridge
7000 Waterfield Place
Garner, NC 27529
Consultants(s): Charlie Yokley, AICP
2905 Meridian Parkway
Durham. NC 27713
26
Location: Along Camp Chestnut Ridge Road, west side Chestnut Ridge Church
Road, and east of Mt. Willing Road. The primary physical address is
1058 Equestrian Center Drive (an internal named access driveway off of
Camp Chestnut Ridge Road). Please refer to Attachment 1 for a map
and site assessment of the subject parcel.
Parcel Information: a. PIN: 9843-22-1289; 9843-13-7930; 9843-05-5036; 9833-93-
5222; and 9842-49-7233.
b. Size of parcels: +/-376 acres.
c. Zoning of parcels: Agricultural Residential (AR); Upper Eno
Protected; and Cane Creek Protected Watersheds.
d. Township: Cheeks.
e. Future Land Use Map Designation: Rural Residential and
Resource Protection Area.
f. Growth Management System Designation: Rural Designated.
g. Existing Conditions/Physical Features: Previously developed
as a Camp Retreat Center consisting of multiple structures and
activity areas supporting the camp.
The site(s) are primarily forested with areas maintained as open
fields, including several horse pastures on the southern side of
the project area. Topography across the properties composing
the project are generally has less than 15% slopes, and in a few
places approaches 30% slopes with naturally occurring steep
topography in proximity to riparian corridors sloping toward the
centerline of streams. There are no steep slopes caused by
human alteration. The overall site contains: 17 intermittent and
perennial stream features; 38 jurisdictional wetland features; and
3 jurisdictional open water features (i.e. ponds).
Forested areas are dominated by mature hardwood tree species,
including southern red oak (Quercus rubra), white oak (Quercus
alba), red maple (Acer rubrum), tulip poplar (Liriodendron
tulipifera) and dogwood species (Cornus sp.).
Approximately 60 acres are encompassed by County enforced
riparian buffers along tributaries to Seven Mile Creek. Many of
these buffers are protected against development by a previously
established Conservation Easement held by the NC Division of
Mitigation Services. Development is prohibited within these
easement areas.
h. Roads: Public access for proposed expansion would be via the
existing camp entrance at Camp Chestnut Ridge Road at the
intersection with Chestnut Ridge Church Road.
i. Water and Sewer Service: The property is not located within a
primary utility service area. Any development on the property
would be served via existing and/or new private septic and well
27
systems. Note, the applicant has submitted further details
regarding the existing Low Pressure septic system that serves
the Dining Hall and other buildings and individual systems for
building such as the camp cabins.
Surrounding Land Uses: a. NORTH: Single-family residences, farms and undeveloped
properties zoned AR.
b. SOUTH: Single-family residences, farms and undeveloped
properties zoned AR.
c. EAST : Single-family residences and undeveloped properties zoned
AR.
d. WEST: Single-family residences and undeveloped properties zoned
AR.
Proposal: As detailed within Attachment 2, the applicant proposes to expand an existing Camp
Retreat facility originally developed in 1959. This existing facility currently operates under
previously approved Class B Special Use Permits issued by the Board of Adjustment on
February 8, 1993 (for expansion of buildings and the Dining Hall Facility), and May 12, 2003
(for the development of an animal rehabilitation facilities) and a de facto SUP granted when the
Cheeks Township was originally zoned on October 1, 1984. A copy of the previous SUPs are
contained within Attachment 6.
The expansion seeks to renovate, improve or expand 26 existing buildings, cabins and/or
facility areas; and develop 10 additional facilities for camp, recreation a retreat activities. The
request would also expand the camp capacity to for campers and pastoral retreat visitors from
200 to 350 campers/visitors per week.
ORDINANCE REQUIREMENTS:
A “Retreat Center” is defined within Article 10 Definitions of the UDO as:
“A new or existing facility operated by a corporation or association of persons or churches for
social and recreational purposes. A Retreat Center may be owned by a profit or not-for-profit
Corporation.”
A “Camp” is defined within Article 10 Definitions of the UDO as:
“A recreation use which may include locations for tents, cabins, or other recreational sleeping
structures, but would not include mobile homes. A camp may be owned by a profit or not-for
profit corporation.”
Section 5.2.1 Table of Permitted Uses of the UDO combines Camp and Retreat centers into the
same land use category, which is a permitted use of property within the AR general use zoning
district subject to the issuance of a SUP.
Standards governing the development of a Camp/Retreat facility, as detailed in Section 5.7.5 of the
UDO, are as follows:
Standards for Class B Special Use Permit:
(1) Submittal Requirements In addition to the information required by Section 2.7, the
following shall be submitted as part of the application:
28
(a) A site plan prepared in accordance with Section 2.5, also showing the following
(existing or proposed):
(i) Buildings,
(ii) Campsites,
(iii) Storage areas,
(iv) Fencing and gates,
(iv) Outdoor recreation areas, and
(v) Access road(s) to the site, as well as on site roads, with an indication of
type of proposed surface.
STAFF COMMENTS: A Site Plan has been submitted with this request providing
required details.
Please note, this is the required site plan denoting compliance with the UDO as it
relates to the issuance of the SUP. A final site plan shall be required for review
and approval by the County prior to the commencement of earth disturbing
activities as required in Section 2.5: Site Plan Review of the UDO.
The applicant has also included a detailed narrative within Attachment 2
providing additional information on the nature of the operations and activities
envisioned for the property.
(b) A description of the type of facility planned, the size, capacity, and use of
proposed buildings; a signed statement from the owners or operators that there shall be
no activity allowed that will have adverse effects on adjacent property. The statement
shall also include a complete list of all recreational activities that will take place on the
site.
STAFF COMMENT: Provided within Attachment 2 as well as on the submitted site
plan.
(c) A P hasing Plan, when necessary, indicating the area to be developed in each
phase with time periods for construction of each phase. This may be indicated on the
site plan.
STAFF COMMENT: The applicant proposes 3 phases for the development. The
required information is provided on the site plan (Sheet C-6) with additional details
contained within Attachment 2.
(2) Standards of Evaluation
(a) Unless public sewer is proposed to be extended, the adequacy for the method
of sewage disposal will be determined by the lot size and oil suitability.
Appropriate letters from the Orange County Environmental Health Department, local
jurisdictions and/or the State Division of Environmental Management s hall be submitted
to indicate preliminary approval.
STAFF COMMENT: Required information is provided within Attachment 2.
Note, the applicant intends to modify, expand or install new private systems to
support the proposed new development.
(b) The site plan shall show the distances to the nearest residential structures.
STAFF COMMENT: Please refer to the attached site plan (C-1
and C-2).
29
(c) The landscape plan shall show how the facilities will be screened from the
adjacent properties.
STAFF COMMENT: Existing and planned facilities are several hundred feet from
adjacent properties. A 100 foot wide building setback and buffer will be
provided along the perimeter of the camps. Existing trees will be saved within
this buffer. More detailed landscape plans will be provided at the time of Site
Plan submittal.
(d) If private recreational facilities are proposed, the improvements must meet the site
improvement requirements in Section 7.11 of this Ordinance. The site plan for
recreational facilities shall be reviewed by the Orange County DEAPER Director.
5
STAFF COMMENT: According to the submitted application and site plan
private recreational facilities will be limited to the locations, frequency and
timeframes indicated in Attachment 2 and the site plan.
(e) Off street parking requirements shall be provided in accordance with Section 6.9 of
this Ordinance.
STAFF COMMENT: The site plan contains required information.
Existing parking, drop-off and bus spaces will meet the majority of the
planned expansion.
As part of the submittal, the applicant has also voluntarily offered the imposition of the
following conditions on the SUP, specifically:
1. In accordance with the provision(s) of Section(s) 5.2.1 Table of Permitted Uses and
5.7.4 Camp/Retreat Center, activities allowed to occur on the property shall be in
accordance with the submitted application package, Site Plan and narrative as reviewed
by the Orange County Board of Adjustment on November 12, 2018. Furthermore, these
overall Site Plans shall be updated and included as part of the Site Plan submittals for
future Phases or groupings of buildings that are submitted for development permits.
2. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and to ensure the proposed use is in harmony
with the general area as required in Section 5.3.2 (A) (2) (c) of the UDO all lighting
installed on the property shall comply with the provisions of Section 6.11 of the UDO.
Under no circumstances may lighting levels exceed 0.1 foot-candles at any property line.
No new outdoor on-site lighting will be located within 100’ of the property boundaries.
3. To promote public safety as required in Section 5.3.2(B)(2) of the UDO, to ensure viable
vehicular access as required in Section 5.3.2 (B) (3), and in accordance with the
provisions of Section 2.5 of the UDO the applicant shall submit Site Plans and with
existing/projected vehicular trip generations to NC Department of Transportation
(NCDOT) prior to the commencement of earth disturbing activity. 4. To ensure general design standards as required in Section 5.3.3 of the
UDO, Orange County Erosion Control and Stormwater Permits shall be obtained by the
Camp with the initial site plan submittal. These permits shall include an overall land
30
disturbance plan that anticipates the camp’s anticipated total land disturbance at total
build-out. This plan shall be updated an included with subsequent site plan submittals.
5. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and to ensure the proposed use is in harmony
with the general area as required in Section 5.3.2 (A) (2) (c) of the UDO, existing
vegetation within 100’ of the property boundary (excluding property frontages along public
rights-of-way ) will remain undisturbed.
6. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and to ensure the proposed use is in harmony
with the general area as required in Section 5.3.2 (A) (2) (c) of the UDO, no amplified
sound will be permitted on-site between the hours of 12:00am – 7:00am.
7. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and permitted by Orange County Environmental
Health, the existing audible Low Pressure alarm associated with the septic system will be
replaced with a SMS/MMS notification system.
8. Per Section 2.5 of the UDO, the applicant shall obtain all necessary development
permits from the County prior to the initiation of and land disturbing activity
associated with the camp, but not limited to:
i. Building Permits;
ii. Environmental Health Permits;
iii. Erosion Control and Stormwater Management Permits;
iv. Solid Waste Management Permit; and
v. Zoning Compliance Permits.
STAFF COMMENT(S):
1. The applicant has offered the above conditions of approval for this request. These
conditions address potential impact (namely light, tree preservation and outdoor noise) on
adjacent properties. 2. Attachment 4 contains Staff’s evaluation of the proposals compliance with the various
standards detailed within these sections. While no major concerns have been expressed, staff is recommending the imposition
specif ic conditions of approval offered by the applicant to ensure the project’s compliance
with the provisions of the UDO in the event the Board determines the application can be
approved. 3. As detailed within Attachment 5 staff has determined the application is consistent with
established submittal requirements and there is sufficient documentation demonstrating
compliance with established development standards.
31
4. As you are aware, staff does not make a formal recommendation on the approval of the
application or on the applicant’s compliance with the general standards detailed within
Section 5.3.2 (a) (2), specifically: (1) The use will maintain or promote the public health, safety and general
welfare, if located where proposed and developed and operated according to
the plan as submitted; (2) The use will maintain or enhance the value of contiguous property (unless
the use is a public necessity, in which case the use need not maintain or
enhance the value of contiguous property); and (3) The location and character of the use, if developed according to the
plan submitted, will be in harmony with the area in which it is to be located and
the use is in compliance with the plan for the physical development of the
County as embodied in these regulations or in the Comprehensive Plan, or
portion thereof, adopted by the Board of County Commissioners. 5. There are several goals/policies detailed within the adopted 2030 Comprehensive Plan
addressing the development of Camp/Retreat Centers in the County including: a. Land Use Goal 1: Fiscally and environmentally responsible, sustainable
growth, consistent with the provision of adequate services and facilities and
a high quality of life. b. Land Use Goal 2: Land uses that are appropriate to on-site environmental
conditions and features, and that protect natural resources, cultural
resources, and community character. c. Land Use Goal 3: A variety of land uses that are coordinated within a
program and pattern that limits sprawl, preserves community and rural
character, minimizes land use conflicts, supported by an efficient and
balanced transportation system. 6. Local residents were notified of the required Neighborhood Information Meeting (NIM) and
the public hearing consistent with the requirements of the UDO. The Camp
owners/consultants and 5 area residents attended the meeting. Please refer to Attachment
3 for additional information. 7. Review of SUP applications are carried out in a quasi-judicial format meaning that decisions
relating to the approval or denial of an application are based solely on the sworn
testimony of all parties involved with the case, both those for and against an
application, as well as the review of the competent material and substantial evidence
submitted into evidence during the Public Hearing. 8. The applicant has the burden of establishing, by the submission of competent material
and substantial evidence, the existence of facts and conditions that demonstrate the
projects compliance with the various requirements and standards detailed within the
UDO. Those opposing approval of the application shall have the burden of establishing,
also through the submission of competent material and substantial evidence, the
specif ic manner in which the proposal does not satisfy the requirements for approval
of the application.
32
9. As previously indicated, the Board of Adjustment shall render a decision only on the
sworn testimony of all parties and on the competent material and substantial evidence
submitted during the hearing relating to the approval or denial of the application. 10. Per Section 2.25.4 of the UDO, every decision of the Board of Adjustment shall be
subject to review at the request of any aggrieved party by the Superior Court by
proceedings in the nature of certiorari. Appeals have to be submitted with the Superior
Court within 30-days of the availability of notice of decision as detailed within 2.12.5 of
the UDO. 11. If approved, staff is recommending the imposition of several conditions as detailed within
Attachment 5. 12. Please note if this project is approved by the Board, this approval does not exempt the
applicant f rom securing all applicable permits authorizing land disturbing activities to
commence including, but not limited to: • An Erosion Control/Stormwater Permits; • P ermits from the Orange County Health Department approving a proposed septic
system/well for the project; • B uilding permits including review and approval of the plans by the County Fire
Marshal; • A Solid Waste Management permit; • A Zoning Compliance Permit; and/or • NCDOT Driveway permits. The approval of the SUP established is that the proposed land use is permitted to be
developed as proposed. If the applicant cannot secure required permits authorizing the
physical development of the project, as detailed herein, the SUP may expire.
33
AddressesSTATUS
ActivePreAssignedRetiredUnverified
StreamsTYPE
USGS StreamSoils Survey StreamOC Updated StreamStreams (Deleted)
EasementsLINE_CODE
Road EasementUtility EasementWater Body Buffer 80ftWater Body
Stream Buffer 80ftWater Body Buffer 65ftUSGS StreamSoils Survey StreamOC Updated StreamNWI Wetlands
ParcelsStreetsZoningWater BodyFIRM
Conservation Easements(Others)Watershed ·
0 260 520 Feet
1 inch = 1,000 feet
9833959479EDWARD JOSEPH JR MAREKAROSEMARY M MAREKA
9833810146MINKAFARM LLC
9843312285JOAN ELMORECECIL
9842373362AUDREY TOWNSEND
9843418421MICHAEL RELMORE
9843302088JIMMY JEFFERIES ELMOREFRANCES ELMORE
9833835154PERRY PCOUCHELL
9833921230LLC MINKAFARM
9833950877INEZ SHAMBLEY
9842496865KENNETHDOYLE COPPLE
9843055036RETREAT MINISTRIES INCNC UNITED METHODIST CAMP &
9842584282PETER MMAYER
9843259908TOMMY MBOYD
9842290271REBECCA PALMERWILLIAM PALMER
9843338790CHESTERH SYKES
9843338790CHESTERH SYKES
9843338790CHESTERH SYKES
9832991165EDWARD J PARKSVIVIEN I PARKS
9843319657JOANELMORE CECIL
9842485497STEPHENPAUL BACHHUBER
9842287384F STUART CARSONFRANCES W MARSHALL
9833935222RETREAT MINISTRIES INC NCUNITED METHODIST CAMP &
9842377364ASPEN DEVELOPMENTGROUP LLC
9842299098LORI ANNE SHAPIROJACK H RAMSEY
9832891832PHYLLISS KIMBALL
9833907146BRIAN D HARRYKIMBERLY K HARRY
9833737137JULIATEIXEIRA
9843308790JIMMIE JEFFRIES ELMOREFRANCES H ELMORE
9832982927MINKAFARM LLC
9842171316ANNETTEL JOHNSON
9842593770PATRICIABAGNAL
9833806144RICHARD LHOWARD
9843357605JOHN PABERNETHY INC
9843251652GRACE BROBERTS
9842481886IRVING F HOFFMANSARAH CRAIGE
9843221289RETREAT MINISTRIES INC NCUNITED METHODIST CAMP &
9843549612EAGLES NESTFOUR LLC
9843623321JOEL LROBERTS
9842081463R J HICKMANGENEVA HICKMAN
9833907846LLC MINKAFARM
9832990686GABRIELS SANCHEZ
9833807785LLC MINKAFARM
9842188731MARK DROBINSON
9842572624THOMAS ETAL STANNCARA STANN
9843424100CHURCH CHESTNUTRIDGE
9843424100CHURCHCHESTNUT RIDGE
9842188194MARION WEBBOMALLEY
9843157228JOHN C CLAYTONJOYCE P CLAYTON
9843523840HEDRICK TJR SYKES
9842179544SENGA A CARROLLMAIA J DERY
9842095625LLC MINKAFARM
9843004786LLC MINKAFARM
9843662371LOIS SBAKER
9843254957MICHAEL L CHAPMANKAREN C CHAPMAN
9843730728LLC EAGLESNEST FOUR
9843137930RETREAT MINISTRIES INC NCUNITED METHODIST CAMP &
9843137930RETREAT MINISTRIES INC NCUNITED METHODIST CAMP &
9843709133PTNS HARRISASSOCIATES LTD
B
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FloodPanel:9833J
FloodPanel:9843J
FloodPanel:9832J
FloodPanel:9842J
Upper EnoProtectedWatershed
Cane CreekProtectedWatershed
AR
BORLAND R
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MONARCHWAY
PRIVATE DRIVECAMPFIRE CIR
Site Data:PINs: 9843-22-1289; 9843-13-7930; 9843-05-5036; 9833-93-5222;9843-13-7930; and 9842-49-7233.Zoning: Agricultural Residential (AR)Acreage: 376 acresOverlay Districts: Upper Eno Protected; and Cane Creek ProtectedWatersheds
Zoning Requirements:Min. lot width: 150'Building Setbacks: 100' around perimeterMax. Height: 25’Required Buffer 30' Type B Buffer per 5.7.5(A)(2)(c)Max. Impervious 12% (1,965,427 sq. ft. based on 376 acres)
Environmental Features:Streams/Water Bodies: Yes, variable width stream buffers. 80' shownSFHA (Floodplain in): NoWetlands: YesFlood Info:Panel #: 9843JBase Flood Elevation (BFE): N/ABFE with 2’ County Freeboard: N/AFlood Depth at structure: N/A
Land Disturbance Thresholds:1) Erosion Control Application/Permit required if disturbing more than10,000 sq. ft.; and2) Stormwater Management Application/Permit required if disturbingmore than 12,000 sq. ft. (Upper Eno Protected); and 21,780 (CaneCreek Protected) for non-residential structures.
**Call OC Erosion Control a t (919) 245-2586 for more information**
Notes:1) Private Road Justifications, Recorded Declarations, RestrictiveCovenants, Bona Fide Farm status, use and building type (e.g. duplex.units) will change subdivision and development requirements.2) Wetlands data is taken from Classification of Wetlands andDeepwater Habitats of the United States. U.S. Department of theInterior, Fish and Wildlife Service and does not constitute a forma ldelineation (i.e. survey) of the property. All wetland areas areapproximate.3) Flood boundaries are subject to change based on periodicamendments to flood maps.Determination is based on current, best available, data; and4) This does not constitute a formal land survey.
Date Site Assessment Completed 12EP2018 by PRM
Data shown on this map is obtained from Orange CountyGIS and is for reference only.Exact locations and boundaries should be verified.Map prepared by Orange County Planning & Inspections.09/12/2018 - pmallett
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2
I. Introduction
Chestnut Ridge Camp and Retreat Center (the Camp) is currently served by several
independent on-site wastewater (septic) systems, throughout the property. Mitchell
Environmental was retained to complete an evaluation of existing, permitted septic
systems on the site to determine permitted sewage flowrates, and to estimate currently
utilized capacity, and available capacity, if any remains. Data evaluated for this
evaluation included sewage flowrate data provided by the Camp and copies of septic
system permit documents provided by Orange County.
II. Status of Site Improvements
Structures with associated septic system permits were verified through evaluation of
provided maps, sketches, and an on-site meeting with Rev. Nick Jeffries, Director of the
Camp. Facilities currently served by septic systems include Morris Dining Center, the
Pavilion, six camper cabins (Birch, Crane, Elm, Maple, Mebane, and Oak), one staff
residence (Falcon), one staff house, one Director’s house, one bath house, and the
former Piedmont Wildlife Center. Individual septic system drainfields that formerly
served Morris Dining Center, the Pavilion, Elm, and Oak, have been abandoned.
Wastewater produced by these facilities is now collected by gravity sewer mains that
flow to a pump station north of Morris Dining Center. This pump station sends
wastewater to a sand filter pretreatment system, and LPP (low-pressure pipe) drainfield
near the southeast corner of the property. Other structures void of plumbing exist on the
property, but none of these structures are served by septic systems.
III. Septic System Permits
Orange County provided digital copies of all septic system permits they have on file for
the Camp, as detailed in Table 1 below:
Table 1: Septic System Permit Summary
Structure Name Receiving Septic
System
Permitted
Sewage
Flowrate
(gallons per day)
Septic
Drainfield
Type
Pumped
or
Gravity
Dosed
Morris Dining Center
Sand Filter LPP
System 2,850 LPP Pumped
The Pavilion
Elm Cabin
Oak Cabin
Proposed Pastoral Retreat
Staff Residence (Falcon) Individual Septic 1,560 Conventional Pumped
Bath House Individual Septic 600 Conventional Gravity
Director’s House Individual Septic 480 Conventional Gravity
Staff House Individual Septic 360 Conventional Gravity
Mebane Cabin Shared Septic w/
Bull Run Valve
360 Conventional Gravity
Piedmont Wildlife Center 100 Conventional Gravity
Birch Cabin Individual Septic Not Specified Conventional Gravity
Crane Cabin Individual Septic Not Specified Conventional Gravity
Maple Cabin Individual Septic Not Specified Conventional Gravity
91
3
Permitted sewage design flowrates range from 100 to 2,850 gallons per day (gpd), with
a total specified sewage design flowrate for the entire property of 6,310 gpd. As
indicated in Table 1, sewage design flowrates are not specified in the septic system
permits for Birch, Crane, and Maple cabins, so permitted flows for these structures are
not included in this calculation. Septic system permits provided by Orange County are
attached to this report.
IV. Current Usage and Available Capacity
Sand Filter LPP System
Septic system use data was collected for the sand filter LPP system from May 27 to
October 19, 2017, covering a period of 145 days. Summer camps started Sunday, June
11, and ended Friday, August 25, with a total of 11 weeks of summer camp. Facility
usage outside of this period was for staff training, year-round residences, and
maintenance activities. Weekly summer camps started on either Sundays or Mondays,
but always finished on Fridays.
For the entire period of data collection, a total of 96,372 gallons of wastewater was
pumped to the sand filter LPP system, with a resultant average daily wastewater flow of
665 gpd. To assess anticipated increased flowrates during summer camp weeks,
weekly wastewater volume was calculated for every Sunday to Saturday period of record
(21 total weeks; 2 with partial data). As anticipated, wastewater flowrates were highest
during summer camp weeks, with weekly flows ranging from 3,095 to 10,170 gallons per
week. Non-summer camp weeks produced wastewater flows ranging from 0 to 5,723
gallons per week. Resultant average daily wastewater flows for summer camp weeks
ranged from 442 to 1,453 gpd. By comparison, the top 10 percent of adjusted daily
wastewater volumes during summer camp weeks ranged from 1,771 to 2,921 gpd. The
numerical average of the top 10 percent of adjusted daily wastewater volumes is 2,184
gpd, which represents the alternative sewage design flowrate for the sand filter LPP
system, per 15A NCAC 18A .1949 (c)(1). Compared to the permitted flowrate of 2,850
gpd, current usage is only 77 percent (2,184 gpd / 2,850 gpd = 0.77, or 77%) of the
available capacity of this system. Per these calculations, residual available capacity in
this system is 666 gpd.
Flow equalization (FE) technologies could be added to this system per Innovative
Wastewater System Approval No: IWWS-2004-01 (copy attached) to further increase
available capacity for new or expanded structures. FE is accomplished through the
utilization of a large pump tank that is sized to hold wastewater produced over the entire
FE period, minus equalized effluent doses that are disposed of in the existing nitrification
field. Using the highest calculated average daily wastewater volume per week (1,453
gpd), the utilization of FE with a one week cycle could theoretically reduce current usage
to only 51 percent (1,453 gpd / 2,850 gpd = 0.51, or 51%) of the available capacity of
this system. Per these calculations utilizing FE, residual available capacity in this
system could be as high as 1,397 gpd.
92
4
Table 2: Chronological Weekly and Average Daily Wastewater Production
Week #
Total Volume
for Week
(gallons)
Average Daily
Volume for
Week
(gallons)
Order of
Largest to
Smallest
Weekly
Volume
Summer
Camp Week?
1 5062 723 10 No
2 5723 818 7 No
3 5993 856 6 Yes
4 7797 1114 4 Yes
5 6308 901 5 Yes
6 5194 742 9 Yes
7 5692 813 8 Yes
8 10170 1453 1 Yes
9 8016 1145 3 Yes
10 9859 1408 2 Yes
11 4811 687 12 Yes
12 3095 442 14 Yes
13 3294 471 13 Yes
14 1652 236 18 No
15 1993 285 16 No
16 1716 245 17 No
17 892 127 20 No
18 4969 710 11 No
19 1606 229 19 No
20 0 0 21 No
21 2532 362 15
Total = 96372 gallons Daily Ave. = 665 gallons / day
**Summer camp weeks highlighted in green.**
93
5
Table 3: Weekly and Average Daily Wastewater Production in Order of Weekly Volume
Production
Order of Largest
to Smallest
Weekly Volume
Weekly Volume in
Descending Order
Average Daily
Volume in
Descending Order
Summer Camp
Week?
1 10170 1453 Yes
2 9859 1408 Yes
3 8016 1145 Yes
4 7797 1114 Yes
5 6308 901 Yes
6 5993 856 Yes
7 5723 818 No
8 5692 813 Yes
9 5194 742 Yes
10 5062 723 No
11 4969 710 No
12 4811 687 Yes
13 3294 471 Yes
14 3095 442 Yes
15 2532 362 No
16 1993 285 No
17 1716 245 No
18 1652 236 No
19 1606 229 No
20 892 127 No
21 0 0 No
**Summer camp weeks highlighted in green.**
A proposed two bedroom pastoral retreat has been proposed to connect to the sand
filter LPP system. With two bedrooms, this new structure will have a design sewage
flowrate of 240 gpd per 15A NCAC 18A .1949 (a). Accordingly, the design sewage
flowrate for the proposed pastoral retreat will reduce residual available capacity in the
sand filter LPP system, once connected.
Other Septic Systems
Usage data was not provided for other septic systems on the property; hence, we are
unable to assess available capacity in any septic system other than the sand filter LPP
system at this time. A similar pumped volume analysis could be utilized to assess
available capacity in the staff residence (Falcon), but installation of water meters would
be required for accurate assessment of all other systems due to their gravity dose
designs.
V. Summary
The sand filter LPP system currently has residual available capacity of 666 gpd, and this
available capacity could be significantly increased (possibly up to 1,397 gpd) with the
addition of FE technologies. Further, additional residual capacity may be available in
other existing septic systems on the property, but detailed analysis of these systems is
required for accurate assessment.
94
6
Exhibits
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
7
Septic System Permits
113
8
Sand Filter LPP System
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
9
Staff Residence (Falcon)
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
10
Bath House
161
162
163
164
11
Director’s House
165
166
167
168
169
170
171
172
173
12
Staff House
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
13
Mebane Cabin
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
14
Piedmont Wildlife Center
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
15
Birch, Crane, and Maple Cabins
(Assumed – Not Clearly Identified)
251
252
253
254
255
256
257
258
259
260
261
262
263
264
16
Proposed Pastoral Retreat
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285
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295
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303
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305
306
307
308
309
310
311
312
313
31
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31
5
31
6
31
7
31
8
31
9
32
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FINDINGS OF THE ORANGE COUNTY BOARD OF ADJUSTMENT
PERTAINING TO A REQUEST SUBMITTED BY
CAMP CHESTNUT RIDGE / NC METHODIST CAMP AND RETREAT MINISTRIES INC
PROPOSING EXPANSION OF A CAMP RETREAT FACILITY CALLED “CAMP CHESTNUT RIDGE”
ON A PARCELS OF PROPERTY OFF OF CAMP CHESTNUT RIDGE ROAD
(PINS 9843-22-1289; 9843-13-7930; 9843-05-5036; 9833-93-5222; and 9842-49-7233)
As required under Section 5.2 Table of Permitted Uses of the Orange County Unified Development
Ordinance (UDO), a Class B Special Use Permit is required for the development/operation of a
camp/retreat center, in accordance with the provisions of Section 2.7 of the UDO. Such permits shall
comply with general and specific standards as set forth in Section(s) 5.3.2 and 5.8.2 of the UDO.
Section 5.3.2 (A) (2) of the UDO requires written findings certifying compliance with the following:
(1) The use will maintain or promote the public health, safety and general welfare, if located
where proposed and developed and operated according to the plan as submitted;
(2) The use will maintain or enhance the value of contiguous property (unless the use is a
public necessity, in which case the use need not maintain or enhance the value of
contiguous property); and
(3) The location and character of the use, if developed according to the plan submitted, will
be in harmony with the area in which it is to be located and the use is in compliance with
the plan for the physical development of the County as embodied in these regulations or
in the Comprehensive Plan, or portion thereof, adopted by the Board of County
Commissioners;
In addition, the Board shall make findings certifying that the application is complaint with the following
specific standards:
(1) Specific standards for the submission of Special Use Permit applications as outlined
within Section(s) 2.2 and 2.7 of the UDO.
(2) Specific regulations governing the development of a Camp/Retreat Facility as set forth in
Section 5.7.5 of the UDO.
(3) Section 5.3.2 (B) relating to the method and adequacy of the provision of:
a. Sewage disposal facilities,
b. The adequacy of police, fire, and rescue squad protection, and
c. The adequacy of vehicular access to the site and traffic conditions around the site.
(4) The general findings outlined within Section 5.3.2 (A) (2).
Listed below are the findings of the Orange Planning staff regarding the application in question. The
findings have been presented by Article and requirement to assist the Board of Adjustment in its
deliberations.
Attachment 5
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REQUIREMENT UDO SUPPORTING EVIDENCE Staff BOA
APPLICATION COMPONENTS
Proper forms 2.2 Application (Attachment 2)
Yes
Fees paid 2.2.4(D) Application (Attachment 2)
Yes
Full description of use
Location
Appearance
Operational characteristics
2.7.3(B)(1) Application (Attachment 2) (Site plan) Yes
Owner Information 2.7.3(B)(2) Application (Attachment 2) (Site plan)
Yes
Information needed for Use Standards 2.7.3(B)(3) Application (Attachment 2) (Site plan)
Yes
Site Plans
(10 copies for Class B; 26 for Class A)
2.7.3(B)(4) 10 Copies of Site Plan Submitted Yes
Preliminary Subdivision Plat (if
necessary)
2.7.3(B)(5) N/A [No subdivision proposed.] N/A N/A
List of parcels within 1,000 feet 2.7.3(B)(6) Application (Attachments 2 and 3)
Yes
Elevations of all structures 2.7.3(B)(7) Application (Attachment 2)
Yes
Environmental Assessment (or EIS)
Topography
Drainage issues
Natural or Cultural resources
Mining
Hazardous Wastes
Wastewater treatment
Water usage
2.7.3(B)(8) EIS Not Required
EA provided in Application
(Attachment 2)
Yes
Method of Debris Disposal 2.7.3(B)(9) Application (Attachment 2) (Site plan)
Yes
Development Schedule 2.7.3(B)(10) Application (Attachment 2) (Site plan)
Yes
Extended Vesting Request 2.7.3(B)(11) Not requested N/A N/A
NOTIFICATION REQUIREMENTS NOTIFICATION REQUIREMENTS
Public Notice
Date
Time
Place
2.7.6(a) Application (Attachment 3) Yes
Published in Newspaper
Two successive weeks
First notice at least ten days
prior but no more than twenty-
five days prior
2.7.6(b) Staff Testimony
The legal ad was published in the News
of Orange and the Chapel Hill Herald on
October 31, 2018 and again on
November 7, 2018
Yes
Sign Posting on Property (at least 10
days prior)
2.7.6(c) Staff Testimony
posted sign on November 2, 2018
Yes
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Mailed Notice
Certified mail
All adjacent property owners
(within 1,000 feet)
Not less than fifteen days prior
2.7.6(d) NIM and BOA Materials (Attachment 3)
NIM notices mailed September 14,
2018
BOA Public Hearing Notices mailed
November 2, 2018
Yes
REQUIREMENT UDO SUPPORTING EVIDENCE Staff BOA
SPECIFIC STANDARDS
Waste Disposal
Method and adequacy of provision for
sewage disposal facilities, solid waste
and water service.
5.3.2(B)(1) Staff’s Abstract and Staff Comments
(Attachment 4)
Both Environmental Health and Solid
Waste have indicated they have no
concerns.
Yes
Safety
Method and adequacy of police, fire
and rescue squad protection.
5.3.2(B)(2) Staff’s Abstract and Staff Comments
(Attachment 4)
Fire Marshall and Sherriff’s office have
indicated that they have no concerns.
Yes
Vehicle Access
Method and adequacy of vehicle
access to the site and traffic
conditions around the site.
5.3.2(B)(3) The submitted site plan shows access
points.
NCDOT District Office has indicated
that they have no concerns
(Attachment 4).
Yes
REQUIREMENT UDO SUPPORTING EVIDENCE Staff BOA
STANDARDS FOR A CHILD CARE FACILITY 5.8.2
Site Plan
A site plan prepared in accordance
with Section 2.5 and Standards for
Camp/Retreat Facilities.
2.5; and
5.7.5(A)(1)
Application (Attachment 2) (Site plan)
Yes
Standards of Evaluation
A description of the type of facility,
the size, capacity, use of proposed
buildings, septic systems and
recreation areas including .
5.7.5 (A) (2)
(a-e)
Application (Attachment 2) (Site plan)
Yes
372
REQUIREMENT UDO SUPPORTING EVIDENCE Staff BOA
SPECIFIC STANDARDS
In accordance with Section 5.3.2 (A) (2), the Board of Adjustment shall also consider the following general
conditions before the application for a Special Use can be approved.
The use (will / will not) maintain or
promote the public health, safety and
general welfare, if located where
proposed and developed and
operated according to the plan as
submitted.
Section 5.3.2
(A) (2) (a)
Application package as contained
in Attachment 2 inclusive including,
but not limited to:
Narrative;
Environmental Assessment
(EA) Application; and
Site Plan.
Site Assessment (Attachment 1)
Staff review comments
(Attachment 4)
Based on all above findings,
Applicant’s Narrative, and Staff’s
report, the Board finds the use will
maintain or promote the public
health, safety, and general welfare
if located where proposed and
developed and operated according
to the plan as submitted.
Yes
The use (will / will not) maintain or
enhance the value of contiguous
property (unless the use is a public
necessity, in which case the use
need not maintain or enhance the
value of contiguous property).
Section 5.3.2
(A) (2) (b)
Application package as contained
in Attachment 2 inclusive including,
but not limited to:
- Narrative;
- Staff abstract;
- Review comments
(Attachment 4); and
- Appraisal evidence
submitted by applicant
Based on all above findings, and a
lack of competent/material
evidence in the record refuting the
testimony, the Board finds the use
will maintain or enhance the value
of contiguous property.
Yes
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The location and character of the
use, if developed according to the
plan submitted, (will / will not) be in
harmony with the area in which it is
to be located and the use is in
compliance with the plan for the
physical development of the County
as embodied in these regulations or
in the Comprehensive Plan, or
portion thereof, adopted by the Board
of County Commissioners.
Section 5.3.2
(A) (2) (c)
Application package as contained
in Attachment 2 inclusive including,
but not limited to:
- Narrative;
- Environmental Assessment
(EA) Application; and
- Site Plan;
- Site Assessment
(Attachment 1); and
- Staff review comments
(Attachment 4).
Based on the above findings,
Applicant’s Narrative, and Staff’s
report, the Board finds the location
and nature of the use, if developed
according to the plan submitted,
will be in harmony with the area in
which it is to be located and the
use is in compliance with the plan
for the physical development of the
County, as embodied in these
regulations and in the
Comprehensive Plan.
Yes
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Conditions of Approval:
1. In accordance with the provision(s) of Section(s) 5.2.1 Table of Permitted Uses and
5.7.4 Camp/Retreat Center, activities allowed to occur on the property shall be in
accordance with the submitted application package, Site Plan and narrative as reviewed
by the Orange County Board of Adjustment on November 12, 2018. Furthermore, these
overall Site Plans shall be updated and included as part of the Site Plan submittals for
future Phases or groupings of buildings that are submitted for development permits.
2. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and to ensure the proposed use is in harmony
with the general area as required in Section 5.3.2 (A) (2) (c) of the UDO all lighting
installed on the property shall comply with the provisions of Section 6.11 of the UDO.
Under no circumstances may lighting levels exceed 0.1 foot-candles at any property line.
No new outdoor on-site lighting will be located within 100’ of the property boundaries .
3. To promote public safety as required in Section 5.3.2(B)(2) of the UDO, to ensure viable
vehicular access as required in Section 5.3.2 (B) (3), and in accordance with the
provisions of Section 2.5 of the UDO the applicant shall submit Site Plans and with
existing/projected vehicular trip generations to NC Department of Transportation
(NCDOT) prior to the commencement of earth disturbing activity.
4. To ensure general design standards as required in Section 5.3.3 of the
UDO, Orange County Erosion Control and Stormwater Permits shall be obtained by the
Camp with the initial site plan submittal. These permits shall include an overall land
disturbance plan that anticipates the camp’s anticipated total land disturbance at total
build-out. This plan shall be updated an included with subsequent site plan submittals.
RECOMMENDATION:
Staff has reviewed the application, the site plan, and all supporting documentation and has found that the
applicant complies with the application requirements, notice requirements, submittal requirements for
camp/retreat centers, specific standards of evaluation for Camp/Retreat centers, and required regulations as
outlined within the UDO
Staff has not received any evidence indicating the project does not comply with the UDO, including the provisions
of Section 5.3.2 (A) (2) inclusive, establishing the grounds for making a negative finding on the general standards
as detailed herein. These standards include maintaining or promoting the public health, safety, and general
welfare, maintaining or enhancing the value of contiguous property, the use is in harmony with the area in which it
is to be located, and the use being in compliance with the general plan for the physical development of the
County.
The Board could make an affirmative finding on this application provided the Board of Adjustment finds in the
affirmative on the specific standards of evaluation and general standards as detailed herein, and no evidence is
entered into the record demonstrating the applicant has either:
a. Failed to meet their burden of proof that the project complies with the specific development standards for a
telecommunication facility, or
b. Fails to comply with the general standards detailed within Section 5.3.2 (A) (2) of the UDO.
In the event that the Board makes an affirmative finding, and issues the permit, staff recommends the attachment
of the following conditions:
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5. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and to ensure the proposed use is in harmony
with the general area as required in Section 5.3.2 (A) (2) (c) of the UDO, existing
vegetation within 100’ of the property boundary (excluding property frontages along
public rights-of-way ) will remain undisturbed.
6. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and to ensure the proposed use is in harmony
with the general area as required in Section 5.3.2 (A) (2) (c) of the UDO, no amplified
sound will be permitted on-site between the hours of 12:00am – 7:00am.
7. To promote the public health, safety and general welfare as required in Section
5.3.2 (A) (2) (a), to ensure adjacent property values are maintained or enhanced as
required in Section 5.3.2 (A) (2) (b), and permitted by Orange County Environmental
Health, the existing audible Low Pressure alarm associated with the septic system will be
replaced with a SMS/MMS notification system.
8. Per Section 2.5 of the UDO the applicant shall obtain all necessary and applicable
permits from the County associated with the development of the property consistent with
the approved Special Use Permit, including but not limited to:
a. Building/ Solid Waste Management Permit,
b. Environmental Health Permit,
c. Erosion Control Management Permit,
d. Stormwater Permit, and
e. Zoning Compliance Permit.
9. In accordance with the provisions of Section 2.7.12 (C) of the UDO, if any condition of
this Special Use Permit shall be held invalid or void, then this Special Use Permit shall be
void in its entirety and of no effect.
10. In accordance with the provisions of Section 2.7.12 (D) of the UDO, the Special Use
Permit will automatically expire within 12 months from the date of approval if the use has
not commenced or construction has not commenced or proceeded unless a timely
application for extension of this time limit is approved by the Board of Adjustment.
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