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Home My WebLink About20200239 Cioni Porch Correspondance SNYDER, KILEY, TOOHEY, CORBETT & COX, LLP HARRY D.SNYDER ATTORNEYS AT LAW MICI-IAELJ.TOOi-IEY PLEASE REPLY TO: KATHLEEN A.CORBETT P.O. BOX 4367 JAMES G.SNYDER SARATOGA SPRINGS, N.Y. 12866 Stachia Wagner JAMES S.Cox STREET ADDRESS: 160 WEST AVENUE Paralegal JOHN B.CANNIE TELEPHONE(518)X84-1X00 FACSIMILE(518)584-1503 July 1, 2020 Zoning Board of Appeals Attn: Keith Kaplan, Chairman City Hall - 474 Broadway Saratoga Springs, New York 12866-2296 Also via email to: Susan.bardenasaratoLTa-sprinas.org and Jennifer.merriman(u)saratoga-springs.com Re: Cioni - 138 Washington Street- Area Variance for Porch Dear Board Members, As you are aware,this office has been retained by Tricia Cioni with respect to the above referenced application for an area variance. At the last meeting, members of the Board requested that my client consider reducing the size of the porch in order to bring the property closer to conformance with the setback requirements within the UR-3 zone. For the following reasons, reducing the size of the porch would be impracticable, and come at significant increase expense to my client. First,the intention of my client is to utilize as much of the pre-existing porch as is possible and simply re-secure the porch to the main house and secure the footings under the porch. Any change in the size or shape of the porch will prevent her from doing that. Specifically, if the seven foot width of the porch is reduced by any more than a few inches, the roof will not be able to be utilized and my client will have to pay for a completely new roof on this portion of the structure. As will be explained in more detail below, any change to the width or length of the porch will result in the need to relocate windows,doors, and/or the concrete steps at the property. Second, changing the dimensions of the porch will cause my client to have to remodel other parts of the property at significant cost and expense. If the porch was shortened on the 15 foot length, the concrete steps onto the porch from the side walk would have to be demolished and relocated in order to shorten it on the south side. Additionally, the windows that look from the main house onto the porch would have to be removed, as any shortening of the porch on the south side would quickly come into contact with those windows. Further, any shortening of the porch from the north side would result in having to move the location of the door from the main building onto the porch, as there is currently just a enough space between the north side of the porch and the location of the door to allow a door to open fully. Any shortening on the north side would prevent the door from being able to open fully in its current location. If the porch were to be shortened on the 7 foot width, the concrete steps would have to be removed and modified,as they are currently very close to the corner of the porch and shortening it would make the entry onto the porch look off center from the current location of the stairs. Photos of the stairs and the windows from the house onto the porch are submitted here as Exhibit"A". Third, a reduction in size of the porch will affect what has been the historic use and utilization of the porch. As the Board is aware,this is a small lot and therefore does not have enough space for any outdoor storage sheds. This porch has been used not only for the benefit of the unit which it serves as an entrance and exit, but also for the benefit of the occupants of the other unit at the property as a place to store property maintenance items like rakes, shovels and brooms. Additionally,this porch has been used as storage for personal items of the occupants of the unit to which it is attached, such as bicycles and the like, since there is no garage or shed. Further, because the kitchen in the unit is only large enough for a small two-person table,the porch is often used for entertaining and larger dining events when the occupants have guests to the property. As is common in Saratoga Springs, porches are places where guests are entertained, and residents enjoy the sights and sounds of our City during the evening. A reduction in the size of the porch will affect these uses. Finally,the concerns raised by the Board as to the size of the porch mostly focused on bringing the porch farther away from the sidewalk on Beekman Street in order to avoid any potentially adverse impacts from snow falling off the porch and onto the sidewalk. With respect to the concern I would first like to point out to the Board that there was nothing contained in the documents produced by the City Building and Planning Department under FOIL that indicated there had ever been a complaint or notice of violation for property maintenance at the property. My client has consistently maintained the property and will continue to do so in the future. Additionally, as noted in my presentation on June 8, 2020, many of the similarly situated corner lots in the neighborhood have rooflines that are right on top of the sidewalk, so this type of zero setback is consistent in the neighborhood for this type of property. Further,the west side of Beekman Street generally has many properties which have a zero setback and could result in snow ending up on the street, even in more heavily trafficked areas like the Beekman Street Art District.A photo of 79—83 Beekman Street is submitted herewith as Exhibit"B"as an example. As can be seen, any changes to the dimensions of the porch will also affect other parts of the building and will increase the scope and cost of the rebuild project of this porch. It is worth noting that this is properly termed a rebuild and not a"new"porch, as the porch has been in existence for quite some time, at a minimum since 1977. Further and the only reason my client is appearing before the Board on this application is a result of an unfortunate car crash into the porch by a third party,wholly unrelated to my client's use and utilization of the porch. Finally,the size and location of the porch in relation to the lot line on Beekman is consistent with other properties in the neighborhood. On behalf of the Applicant,we request the Board to grant the area variances as requested in the Application. I will be appearing at the meeting on behalf of the applicant on July 6, 2020 and will be happy to answer any and all questions the Board may have at that time. Thank you for your time and attention to this matter. Very truly yours, J;o In :. ann`i q. ,ZJBC/jk Enc. EXIHIll ht ET "A" ,,,,,, ,;,„, , _....„: ,,,:,,,,,„„,,,:,„„...,,.., , -,•_,.. — .,,,,,„-.it.,,,''',''4,:enlri'f",..,')',.;,ViiM1.11 ,,,, , y ,1•70',', ,,.:):,,tA,' i.., '. ' . . ''.,,:;,..10,:',11LL:2... . ,,,,,,, , „..',.;-'.:-.---...;,-,:''`'''- '''''..,41$.,".''.,,,,,,':',0‘: 1 '.., ' l'I'Cl. ,,' t ,'i, rtI.('''''I,' ''''. '41 ,.,. . ..... ' "'i T,,'"i" '' t.. • " , ' 1 ''''''''' • "''.i ''. ':',""." ,"t . '',t''.1 ,1 1 . , ' ', ..„ I.'I. ; ' ,I •.' I-- I j I j , . . --- . 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