Loading...
HomeMy WebLinkAbout20220202 Stewarts 31- 33 Marion Avenue additional information THEE LAW OFFICES OF Libby Coreno, Esq. M. E L I ZA E E T H C O R E N O,ESQ.P.C. libby@corenolaw.com December 2, 2022 Mr. Gage Simpson, Chair Zoning Board of Appeals City of Saratoga Springs 474 Broadway Saratoga Springs,New York 12866 Re: Stewart's Shops Marion Avenue—Area Variance Relief Dear Chairman Simpson: As you may recall, I represent Stewart's Shops ("Stewart's")regarding its proposed renovation of the location at Marion Avenue which includes a request for area variance relief from the Zoning Board of Appeal ("ZBA"). During our last appearance before the ZBA on September 26, 2022, Stewart's was directed to address three primary issues concerning the project, to wit: (1) whether the application should include area variance relief from the Section 6.3.3 of the former Zoning Code related to the distance of gas pumps from an abutting residential district; (2) whether the application should make a request for relief from the limitation of parking in the rear setback pursuant to Section 6.2.7 Design Requirements, part D of the former Zoning Code; and (3) the terms of the License Agreement between Stewart's and National Grid for use of the access road between Stewart's parcel and the City of Saratoga Springs' parcel. First, the gas pumps located on the Marion site have been permitted by the City before 1976 as evidenced by the Special Use Permit issued by this Board. The 1976 Permit references the Congress Gas& Oil location in reviewing the request to construct a car wash—which request was granted on May 26, 1976 (see Letter from Patrick Cogan to the Board dated May 22, 2022). Subsequent zoning provisions have been enacted in the City regarding the placement of gas pumps which included the 2004 requirements of Section 6.6.3 providing that no gas pump shall be located within 250 feet of an abutting residential district. However, according to the zoning notes from Code Enforcement Officer Patrick Cogan's, letter dated May 22, 2022, the City zoned the surrounding parcels as UR2 sometime around 1990 which was decades after the pumps were installed. Even before 1990 though,his records indicate that the Marion site has been surrounded by residential zoning since the first inception of the restrictions in the outer district circa 1971. Therefore, Stewart's position is that(1)the gas pumps placement are pre-existing to Section 6.3.3 and therefore are"grandfathered"under the 250 feet rule; (2)the Special Use Permit contemplates the proper use of gas and car wash at the site as early as 1976 which rights have vested in favor of Stewart's; (3) a 2004 site plan approval from the City Planning Board (also referenced in Cogan letter) denotes the placement of the gas pumps and the canopy without any relief from this Board —a time which both the UR2 zoning and Section 6.6.3 were in effect; and, notwithstanding any of the foregoing legal grounds, (4) Stewart's would otherwise be entitled to request area variance relief from the Board for the slight movement (3 feet) of the gas pumps even farther away from the residential district to become more conforming. Law Office of M.Elizabeth Coreno,Esq.P.C. 63 Putnam Street, Suite 202 Saratoga Springs,New York 12866 (518)682-6901 (518)682-6902 THEE LAW OFFICES OF Libby Coreno, Esq. M. E L I ZA E E T H C O R E N O,ESQ.P.C. libby@corenolaw.com Second, as it relates to the parking in the rear setback, it is unclear whether Section 6.2.7 Design Requirements,part D was in effect at the time the 2004 site plan approval was issued by the City. The approval does not show the parking requirements on the plans;however, it is self-evident that the "macadam" referenced necessarily serves as the parking spaces on the site. Regardless, the current application places nine (9) in the rear yard setback which is permitted under the current UDO zoning and exactly 20% of the parking in the front yard setback which is also permitted under the new zoning (Section 10.2(B)(5)). Therefore, the applicant is requesting to modify its application for area variance relief from the 2004 zoning restrictions in favor of conforming with the current UDO zoning in the City. Third, I am enclosing the License Agreement with National Grid which owns SBL: 166.5-4-2, a parcel which extends from Marion Avenue,surrounding the Adirondack Trust ATM kiosk heading north along the eastern boundary of the Stewart's lands. It is this license agreement that Stewart's and the City both utilize for access to their adjacent sites. In reviewing the terms of the License Agreement, the City has previously issued approvals subject to the same License Agreement; specifically in the matter of DRC 2004.005, the Design Review Commission (DRC) issued an approval on February 5, 2004 allowing the construction of a kiosk and tank replacement which was ultimately completed in 2005 and, as previously mentioned, the Planning Board's 2004 site plan also contemplates the use of the license area. Taken together, Stewart's understands that its (and the City's) continuing reliance on the National Grid license is taken at its own risk, but the 50-year pattern and history between the parties (and predecessors) gives no cause for concern at this time. I wish to thank the Board for its time and courtesies in this matter. Respectfully submitted, . Elizabeth Coreno Cc: Zoning Board of Appeals Ryan Rubado Law Office of M.Elizabeth Coreno,Esq.P.C. 63 Putnam Street, Suite 202 Saratoga Springs,New York 12866 (518)682-6901 (518)682-6902 oGA City of Saratoga Springs Zoning KCOGAN Zoning&Building Inspector o� �! BUILDING DEPARTMENT Extension 2491 s H - z CITY HALL DUANE MILLER u - Assistant Building Inspector 474 Broadway, Suite 32 Extension 2512 Saratoga Springs, NY 12866 •NC�RPORATED�A,�• JEANNA FRITZ-THOMAS Assistant Building Inspector • BUILDING & PLUMBING Telephone (518)587-3550 Ext. 2511 Extension2541 • CODE COMPLIANCE www.saratoga-springs.org ROBERT KOCIS • ZONING Assistant Building Inspector Extension 2542 JOHN BARNEY Assistant Building&Construction Inspector Extension 2521 May 16, 2022 RICHARD TIERSCH Assistant Building&Construction Inspector Extension 2563 Zoning Board of Appeals Application 4 20220202 31 —33 Marion Avenue— Stewart's Shops Parcels 4: 166.5-4-1.1, 166.5-4-1.2, 166.5-4-1.3 RE: City Zoning Ordinance §240-1.7(D) Members of the Zoning Board of Appeals, As requested, I have examined the application submitted by Stewart's Shops for the proposed redevelopment of 31 —33 Marion Ave. Per the applicant's narrative, a portion of the adjoining parcel (166.5-4-1.1)has been "incorporated into the proposal via 1.7(D) of the City's Zoning Ordinance which extends zoning 100 feet." Correspondence received from neighbors and the Maple Ave, Marion Ave, Maple Dell Neighborhood Association has raised objections and questioned the validity of utilizing §240-1.7(D) as it applies to the property in question. The Zoning Board of Appeals (ZBA)has requested a determination and clarification of whether Section 1.7(D) can be utilized by the applicant to extend the requirements of the Tourist Related Business (TRB) zoning district 100 feet to the north into parcel 166.54-1.1,which is part of the Urban Residential—2 (UR-2) zoning district. The Zoning Map boundary between the TRB and UR-2 zoning districts is clearly coincident with the parcel boundary between parcels 4 166.5-4-1.1 and 166.5-4-1.3. §240-1.7 of the City's Zoning Ordinance reads as follows: 1.7 INTERPRETATION OF DISTRICT BOUNDARIES Where there is uncertainty as to the boundary of any district contained within this Chapter or as shown on City maps,the following rules shall apply: A. Unless shown to the contrary on a City map,the boundary lines of districts are the center lines of streets, or such lines extended,the center lines of railroad rights-of-way,the center lines of creeks and waterways. B. Where district boundaries are indicated as approximately following the City boundary line, lot lines, or projections thereof, said boundaries shall be construed to be coincident with such lines. C. If a center line or right-of-way line of a street,highway, railroad,public utility, or watercourse,which is approximately coincident with a district boundary, is moved up to a distance of 50 feet,the district line shall be automatically adjusted to be coincident with such line. Page I 1 D. Where a zoning district boundary line divides a lot or land in single ownership as existing at the time of this enactment,the district requirements on either side of the boundary may be construed,at the property owner's option, as extending into the remaining portion of the property for a distance not exceeding 100 feet. The neighborhood association suggests that Section 1.7(D) can only be used"where there is uncertainty as to the boundary of any district". In this case,there is no uncertainty as to where the boundary between the TRB and UR-2 districts is located, so the suggested implication would be that 1.7(D)cannot be used without such uncertainty. Following the logical and literal construction of Section 1.7, I find it difficult to disagree. However, after thoroughly researching the history of the language, and examining the text of every iteration of the Zoning Ordinance since 1961,my determination is that clause 1.7(D)was grouped under Section 1.7 as a result of a formatting error in 2012, and was never intended to only apply in situations "where there is uncertainty as to the boundary". The clause dealing with"Lots in two districts"was under a separate heading from 1961 —2012. Logically,placing the clause under Section 1.7 doesn't make sense. If there is uncertainty as to the exact boundary between districts,how can the requirements be construed to extend up to 100 feet? Where would the 100 feet be measured from? There is plenty of established precedent that the City has never required an applicant to demonstrate uncertainty in order to utilize the 100 foot move. Additional information can be found in my attached research notes titled"Zoning Notes— Split Zoned Lots". So if uncertainty as to the boundary location need not be established,the question remains as to whether Section 1.7(D) can be used by the applicant to incorporate 100 feet of parcel 166.5-4-1.1 into the project, construing the requirements of the TRB district 100 feet to the north of the district boundary line. To answer that question, I believe it is necessary to establish when said boundary line was drawn, and whether or not the land divided by the boundary was under single ownership "at the time of this enactment". I examined every known and published version of the Zoning Map since 1961. An outline of my findings is contained in the attached research notes titled"Marion Ave Zoning Map Notes". I intend to bolster these notes with corresponding images of the referenced map versions if necessary. My conclusion is that the boundary between the commercial zoning district(TRB, TRBD, C-3) and the residential zoning district has been in the same location,coincident with the parcel boundary between 166.5-4.1.1 and 166.5-4-1.3 since at least 1998, and in all likelihood, since 1991. Property records show that Stewarts Shops Corp acquired parcel 166.5-4-1.3 from Marion Ave Car Wash in 2003. Stewarts Shops Corp acquired parcel 166.5-4-1.1 from Congress Gas and Oil in 2004. So when the district boundary was established, it was exactly coincident with the parcel boundary,the parcels were not under single ownership,and were not owned by Stewart's Shops. The heart of the issue is whether or not a commercial use such as a car wash should be allowed to expand 100 feet into a parcel clearly zoned for residential use. In 1976,when the car wash was originally authorized on what is now parcel 166.5-4-1.3,the use required a special permit in the B-3 zoning district. Special Permits were evaluated by the Zoning Board of Appeals in 1976. A carwash use in the TRB zoning district would require Special Use Permit and Site Plan Approval,now conducted by the Planning Board. Attached is the special permit granted by the Zoning Board of Appeals in 1976,providing the original authorization for the construction of the car wash. As you can see,the following condition of approval left no doubt as to the ZBA's opinion in this matter: "The Board points out that the balance of Congress Gas &Oil property to the north is considered to be residential in character and the Board at this time disapproves further business expansion north of the subject property." Page 1 2 For the reasons stated herein, it is my determination that it would be inconsistent with the language and intent of the Zoning Ordinance to allow Stewart's Shops to extend the requirements of the TRB district 100 feet to the north into parcel 166.5-4-1.1,which is wholly within the UR-2 district. I respectfully reserve the right to amend and augment the information contained in this letter and supporting documents if necessary, or in the event of an interpretation appeal. Please let me know if any additional information is required or if clarification is requested on this or any other issue. Respectfully, Patrick D. Cogan Zoning and Building Inspector Page 1 3 LICENSE AGREEMENT THIS AGREEMENT, made the day of 2015, with an effective date of June 1, 2015 (the "Effective Date") by and between NIAGARA MOHAWK POWER CORPORATION, a transportation corporation of the State of New York, with its principal office and place of business at 300 Erie Boulevard West, Syracuse, New York 13202, hereinafter called "Licensor" and STEWART'S SHOPS CORP., with its principal office and place of business at 2907 Route 9, Malta, New York 12020, and a mailing address of P.O. Box 435, Saratoga Springs, New York 12866, hereinafter called "Licensee". WITNESSETH: SUBJECT to such terms and conditions hereinafter set forth in this Agreement, Licensor does hereby consent to Licensee, its successors and assigns, witliout covenant or warranty of any kind, express or implied, permission to use and maintain a paved access and parking area ("License Area") upon a portion of Licensor's land commonly known as the Spier Falls- Saratoga-Ballston electric transmission line (the "Right-of-Way") located near the intersection of Marion Avenue (Route 9) and Route 50, in the City of Saratoga Springs, County of Saratoga and State of New York, as described in Exhibit "A", and as shown on Exhibit °B", each attached hereto and made a part hereof. The License Area was originally the subject of an agreement dated the I" day of August, 1978 between Licensor and Congress Gas and Oil Co., Inc and a subsequent agreement dated June 3, 2005 between Licensor and Licensee. Licensor retains the right to construct, install, repair, and replace facilities within and around the License Area. LICENSE SUBORDINATE TO PRIOR RIGHTS 1. The rights described above are given and accepted subject to any and all outstanding leases, tenancies, easements, licenses or other tenures, and_or claims of title affecting Licensor's said Right-of-Way or any portions thereof; and subject also to any and all encumbrances, liens, conditions, restrictions and,`or reservations under which Licensor holds the same. TERM OF AGREEMENT, TERNIINATI.ON, ANNUAL FEE 2. A. The term ("Term") of this Agreement shall commence on June 1, 2015 and expire on May 31, 2020. B. This Agreement is revocable by Licensor and may be terminated at any time by either party upon thirty (30) days written notice to the other party. In the event of termination, Licensee shall remove any and all facilities installed or constructed hereunder and shall restore Licensor's Right-of-Way in all respects to the condition existing at the time of execution of this Agreement. C. Licensee shall pay an annual License Fee ("License Fee") in the amount of Ten Thousand and 00:100 (S 10,000.00) dollars for each year of the Term. The License fee shall be due annually and payable in advance. D. Subject to the terms and conditions set forth herein, this Agreement may be renewed for an additional five-year term ("Renewal Term") commencing June 1, 2020 and expiring May 31, 2025. Licensee shall provide notice of its intention to renew this Agreement no later than ninety days prior to the expiration of the Initial Term. E. Licensee shall pay an annual License Fee in the amount of Thirteen Thousand and 00:100 ($13,000.00) dollars for each year of the Renewal Term. The License fee shall be due annually and payable in advance. 2 INSURANCE RE UIREMENT 3. At the time of execution of this Agreement by Licensee, Licensee shall furnish to Licensor evidence that insurance policy(ies) satisfactory to Licensor, and not subject to cancellation or material change without ten (10) days prior written notice to Licensor have been issued to it, as set forth on Exhibit"C" attached hereto, which policy(ies) or equally satisfactory renewals or extensions thereof shall be maintained in force so long as Licensee exercises the rights granted herein. PRIOR NOTICE OF CONSTRUCTION AND RIGHT OF INSPECTION 4. A. Licensee shall give Licensor at least one (1) week written notice before commencing any work hereunder, whether in initial construction or subsequently. Licensor, at its election, may have an inspector present at the time or times such work is being performed. Such inspector shall have the right and authority to require modification or cessation of any or all work hereunder, when in his or her judgment, such work is contrary to the provisions of this Agreement, or is or may become a source of danger to the facilities of Licensor, and in any such event, Licensee shall promptly pay Licensor the reasonable cost and expense of such inspection. The presence or absence of Licensor's inspector shall not constitute a waiver of any provisions of this Agreement. B. In case of emergency, however, Licensee may proceed to make immediate repairs upon verbal or telephone notice to Licensor of the situation which said notice Licensee shall follow within three(3) working days thereof with a confirming letter. SPECIAL CONDITIONS 5. Entry onto Licensor's lands, protection of Licensor's facilities, payment of consideration and other relevant matters are subject to the following conditions: 3 a. Licensee shall not park in the License Area or Right- of-Way, except for any parking spaces that may exist as of the date of this Agreement. b. Licensee shall not store, repair or dispose of vehicles in the License Area or Right-of-Way. C. Licensee shall not store or dispose of oil or hazardous wastes or substances in the License Area or Right-of- Way. d. Licensee shall not install any unauthorized structure on the License Area or Right-of-Way. C. Licensee shall not prevent longitudinal vehicular travel by Licensor once Licensee's permanent facilities are installed. f. Licensee shall not change grade without consent of Licensor. g. Licensee shall not perform blasting operations of any nature. CONDUCTOR AND STRUCTURE CLEARANCE 6. The excavation, construction, operation, maintenance, repair, reconstruction and removal of Licensee's facilities in the License Area shall be accomplished without any equipment having extensions whose highest point reaches (or which is potentially capable of reaching) within fifteen (IT) feet of the lowest electric conductor on Licensor's Right-of-Way. There shall be a minimum horizontal clearance to the nearest structure of twenty-five (25') feet. All construction equipment working under or near electric conductors shall be grounded. COMPACTION OF EXCAVATION 7. Licensee shall provide not less than thirty (30") inches of cover over any underground facilities installed by Licensee pursuant hereto; such cover shall be compacted so as to be capable of withstanding AASHTO-H20 highway loading. PRESERVATION OF DRAINAGE 8. Licensee shall restore existing grades and contours so that there will not be a collecting or pooling; of runoff waters or surface waters upon the License Area or Right-of-Way resulting from the installation, construction, maintenance and operation of Licensee's facilities. LOCATION MARKERS 9. Standard marker posts (if applicable), extending a minimum of three (3') feet above ground, shall be installed by Licensee at the points of entrance and exit of any pipelines, cables or other underground facilities installed by Licensee across the License Area or Right-of-Way. SOIL RESTORATION 10. All earth or soil disturbed by the work of Licensee shall be properly backfilled and the surface thereof restored to its former condition to the extent reasonably possible by Licensee at its sole cost and expense. STANDARD CONSTRUCTION 11. The facilities constructed and installed shall be in compliance with all federal, state and local regulations concerning;the construction of such facilities. Licensee shall, at all times after construction, maintain said facilities in good repair and in a safe condition. QUALITY OF CONSTRUCTION MATERIALS 12. The quality of the material to be used in constructing the facilities on the License Area or Right-of-way shall be in compliance with all regulations relating;to the construction of such facilities. COMPLIANCE WITH APPLICABLE LAWS 13. Licensee shall, at its own cost, comply with applicable laws, ordinances, orders, rules and regulations of the United States, State of New York, or any departments, bureaus, 5 authorities or commissions created under the laws of either government, and of the municipalities in which said lands are situated as the same relates to the exercise of the rights and privileges granted hereunder, including but not limited to, all OSHA standards for work in a high voltage area, and shall obtain all required pen-nits for the operations permitted herein. NON-INTERFERENCE WITH FACILITIES 14. Licensee shall so construct and shall thereafter operate, maintain, repair, reconstruct, and/or remove its facilities so as not to injure or damage Licensor's Right-of-Way or injure, damage or interfere with Licensor's existing facilities, or facilities which may be installed in the future. LICENSOR'S PARAMOUNT RIGHTS 15. All rights granted hereunder shall be subject and subordinate to the paramount rights of Licensor now and hereafter to occupy and use all or any portion or portions of the License Area in its operations, provided however, that any such occupancies or uses shall not prevent the exercise by Licensee of the rights conferred by this Agreement. Licensor, however, shall not be responsible to Licensee for any damage to Licensee's facilities arising out of Licensor'S operations or otherwise. REIMBURSEMENT FOR MODIFICATION OF FACILITIES 16. Licensee shall promptly reimburse Licensor, upon submission of proper bills, for any and all reasonable costs and expenses of changing and/or relocating Licensor's existing or future facilities, and any and all additional costs and expenses involved in the construction of new facilities made necessary by the installation and presence of Licensee's facilities. NOTICE 17. Any notice to be given under the terms of this Agreement shall be in writing, addressed as follows: 6 To Licensor: To Licensee: Niagara Mohawk Power Corporation Stewarts Shops Corp. Attn: Real Estate Manager Attn: Rcas{��c. �a•� ,�i 1 125 Broadway P.O. Box 435 Albany, New York 12204 Saratoga Springs, New York 12866 The date of mailing shall be deemed the date of service of such notice. REIMBURSEMENT OF TAXES 18. Licensee shall reimburse Licensor for all additional taxes and assessments levied against the License Area or Right-of-Way because of Licensee's occupation and use of same. INDEMNIFICATION 19. Licensor shall not be responsible for loss, damage, or injury (including death) to property or persons, including Licensee and Licensee's employees, agents and guests, arising from or in any way connected with the exercise of the rights provided herein. Licensee agrees to indemnify, defend and hold harmless Licensor against all loss, damage, liability, cost and expenses arising from or in connection with any damage or injury to third parties (including real property, personal property and environmental damages) or persons (including injuries resulting in death), directly or indirectly arising out of, caused by, incurred during, or in any way connected with the use of the rights granted herein, or which occurs on or about the License Area, or which is caused by any act, omission, negligence or misconduct of Licensee, including its agents, employees, and guests. PAVING 20. Licensee may, at its own cost, expense and risk, install, improve or maintain an asphalt paved surface within the bounds of the License Area and Licensor shall not be held liable for any damage thereto resulting from its use of the Right-of-Way. ENTIRE AGREEMENT 21. No provision of this License shall be deemed to have been waived by Licensor unless such waiver be in writing signed by Licensor. This License contains the entire agreement between the parties and any executory agreement hereafter made shall be ineffective to change, modify or discharge it in whole or in part unless such executory agreement is in writing and signed by both parties. IN WITNESS WHEREOF, the parties hereto have hereunto subscribed their names and affixed their seals all on the day and year first above written. NIAGARA MOHAWK POWER CORPORATION By: Name: Keith P. McAfee Its: Vice President - Electric STEWART'S SHOPS CORP. By: -��Lj Name: Mi hael Co ca Its: Treasurer R STATE OF NEW YORK ss.. COUNTY OF P L,6(4N On the 2011" day of 0 J9(X4— , 20I5, before me, the undersigned, a Notary Public in and for said state, personally appeared e.�_ k-+_ C. Y-n c _ e; , personally known to me or proved to me on the basis of sati factory evidence tb be the individual(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their capacity(ies), and that by his/her/their signature(s) on the instrument, the individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument. Haliaa M.Gaiewski Notary Public,State of New York Qualified in Schenectady County No.01GA6107N5 Commission Expires April 12, '2-0 Ito STATE OF NEW YORK ss.. COUNTY OF On the _/Vl�day of G7V;k/ 2015, before me, the undersigned, a Notary Public in and for said state, personally appeared 1AChtt Coa t- personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is'are subscribed to the within instrument and acknowledged to me that hershe?they executed the same in his/her their capacity(ies), and that by his/her'their signature(s) on the instrument, the individual(s), or the person upon behalf of which the individual(s) acted, executed the 6� PAULTESM yglw� In Sa R31M��• 0�to17�ICO/7 n Oil 501 COM-+►setm Er-+rRr p 9 EXHIBIT "A" NMPC Doe. No. 147437 LICENSEE: STEWART'S SHOPS CORP. PURPOSE: Use and maintenance of existing paved area within Right-of-Way LOCATION OF PROPERTY: Routes 9 and 50, City of Saratoga Springs, County of Saratoga DEED REFERENCE: To: Niagara Mohawk Power Corporation From: The Delaware and Hudson Railroad Corporation Dated: October 13, 1960 Recorded: November 7, 1960 Book 698 at Page 168 County: Saratoga NIAP REFERENCE: Spier Falls Saratoga Ballston, Q-197, Sheet 15 NIAGARA NIOHAWK PERSONNEL TO ADVISE OF CONSTRUCTION: Mike Martuscello Manager, Overhead Lines Northeast 518-522-0332 10 I Gj AQD E DEMWAW f7f,PA ZV. 0.468 Ac2E z ED (D ot 7.1-65 AC:2ES 250 L t --JTY C- -0..50-2 C ...77 .x--s cc:zp 17c Sta--L z mx L- aoUrE 4-T IIW A'�,-LEZ%7-e E�-- j Z-F.-s -J---A ZeZ� .--.61 1-M 5 7T L�0-MfWn c! Bz-c�0 0AL CSWA- JT. 472 3- •'Ct,- ,0.1424 5R'.rr Z-5D WAT L-1)= Z.C�Eq -At SUR""OF LVM OF 7 CONGRESS GAS & OIL COMPANY, LNr- 7,MON AV2iUE'CAR WASH. INC m BE CChVEIM TO SIEWAM DMK co". f L Z. EXHIBIT "C" Insurance Requirements 1 . From the commencement of the Agreement, through final expiration or longer where specified below, Grantee shall provide and maintain, at its own expense, insurance policies, intended to be primary(with no right of contribution by any other coverage available to National Grid USA its direct and indirect parents, subsidiaries and affiliates (the"Insured Entities")),covering all Operations, Work and Services to be performed under or in connection with this Agreement, issued by reputable insurance companies with an A.M. Best Rating of at least B+, which at least meet or exceed the requirements listed herein: (a) Workers' Compensation and Employers Liability insurance as required by the State in which the work activities under this Agreement will be performed. If applicable, Coverage shall include the U-S. Longshoreman's and Harbor Workers Compensation Act, and the!ones Act. The employer's liability limit shall be at least$500,000 each per accident,per person disease, and disease by policy limit. If Grantee is exempt from having to obtain and maintain workers' compensation coverage due to their legal status as a sole proprietor or partnership, Grantee shall obtain: 1. Long tenn disability insurance covering any illness or injury incurred in connection with this Agreement that prevents Grantee from working, with benefits of at least 50%of the Grantee's monthly income on the last day before the disability begins. 3. Health Care Insurance, covering any loss occasioned by bodily injury, sickness or disease, and medial expense, with limits,coverage,deductibles, co-insurance payments, and any other cost sharing features customarily maintained by other entities of a similar size and business nature. (b) Commercial General Liability (CGL) Insurance, covering all operations to be performed by or on behalf of Grantee under or in connection with this Agreement, with minimum limits of: Bodilv Iniury(BI) -$1,000,000 per occurrence Property Damage(PD) - S 500,000 per occurrence OR Combined Single Limit -S1,000,000 per occurrence OR BI & PD per Occurrence -$l,000,000 General Aggregate& Product Aggregate -S2,000,000 each • Coverage shall include: contractual liability(with this Agreement, and any associated verbal agreements, being included under the definition of"Insured Contract"thereunder), products/ completed operations,and if applicable, explosion, collapse and underground (XC&U). • If the products-completed operations coverage is written on a claims-made basis, the retroactive date shall not precede the effective date of this Agreement and coverage shall be maintained continuously for the duration of this Agreement and for at least two years thereafter. • Additional Insured as required in Article 3 below, • The policy shall contain a separation of insureds condition. II a In the event Grantee is a governmental entity such as a Town, County, Municipality etc., and such entity's liability to a third party is limited by law, regulation,code,ordinance, by-laws or statute(collectively the"Law"), this liability insurance shall contain an endorsement that waives such Law for insurance purposes only and strictly prohibits the insurance company from using such Law as a defense in either the adjustment of any claim, or in the defense of any suit directly asserted by an Insured Entity. (c) Automobile Liability,covering all owned, non-owned and hired vehicles used in connection with all operations, wort:or services to be performed by or on behalf of Grantee under or in connection with this Agreement with minimum limits of: Bodily Iniury - $500,000 Per oecurrence; 1,000,000 nares!ate Property Damage -$500,000 per occurrence OR Combined Single Limit -51,000,000 per occurrence Additional Insured as required in Article 3 below. (d) Umbrella Liability or Excess Liability coverage, with a minimum per occurrence limit of $4,000,000. This coverage shall run concurrent to the CGL required in Article 1(b) above, shall apply excess of the required automobile, CGL and employer's liability coverage required in this Insurance Exhibit, and shall provide additional insured status as outlined in Article 3 below. (e) Watercraft Liability, if used in connection with this Agreement, with the same minimum limits of liability as outlined in requirement I(b)above,and naming the Insured Entities, including their officers and employees, as additional insured as outlined in article 3. (f) Aircraft Liability, if used in connection with this Agreement, with a limit of liability of not less than $10,000,000 combined single limit per occurrence,and naming the Insured Entities, including their officers and employees,as additional insured's as required in Article 3 below. Such coverage shall not include a per-passenger or per seat coverage limit. (g) Contractors Pollution Liability(CPL): covering any sudden and accidental pollution liability which may arise out of, under, or in connection with this Agreement, including all operations to be performed by or on behalf of Grantee, or that arise out of the Grantee's use of any owned, non-owned or hired vehicles, with a minimum liability limit of, Bodily°Iniury(BI) - $1,000,000 Per occurrence Property Damage(PD) -$ 500,000 per occurrence OR Combined Single Limit -$1,000,000 per occurrence This requirement may be satisfied by providing either this CPL policy, which would include naming the Insured Entities, including their officers and employees, as additional insured's as outlined in Article 3 below; OR by providing coverage for sudden and accidental pollution liability under the CGL and commercial automobile insurance policies required above - limited solely by the Insurance Services Organization(ISO) standard pollution exclusion,or its equivalent. In the event grantee is unable to secure and/or maintain any or all of this sudden and accidental pollution liability coverage, Grantee agrees to indemnify and hold the Insured Entities harmless 12 against any and all liability resulting from any coverage deficiency that is out of compliance with this insurance requirement. (It) Risk of Loss: Grantee shall be responsible for all risk of loss to its equipment and materials, and any other equipment and materials owned by its employees or by other third parties that may be in their care, custody and control. If this coverage is excluded from the Commercial General Liability policy, then coverage will be acceptable under Grantee's property policy. In the event that any equipment or materials (Goods)are supplied by the Insured Entities, an Insured Entities representative will provide the insurable value of the Goods to Grantee in writing, both cumulatively and on a maximum per item basis. Grantee will provide replacement cost insurance for these Goods under a blanket builder's risk policy, an equipment floater, or other equivalent coverage, while such Goods are under the care, custody and control of Grantee. Such insurance shall cover all Goods outlined in the Agreement or as noted on subsequent contract amendments. The coverage limit shall apply on either a per Iocation basis or a maximum per item basis, and shall name the Insured Entities, as a Loss Payee with respect to their insurable interest as required in Article 3 below. (i) Ilomeow•ners/Sole Proprietors Insurance: In the event that Grantee is either a homeowner or sole proprietor, the requirements in section l A and D do not apply. However, these requirements do apply to any contractors that have been hired by Grantee to perform any work activities on the premises as defined in this Agreement. In addition, if a Homeowners insurance company will not provide the additional insured status to National Grid as required in section 3, Grantee agrees to indemnify and hold harmless the Insured Entities for any liability that would have otherwise been covered had the insurance carrier recognized the additional insured status. (j) Limits: Any combination of Commercial General Liability, Automobile Liability and Umbrella Liability policy limits can be used to satisfy the limit requirements in items 1 b, c& d abode. If the terns of this agreement is longer than five (5) years, in the fifth year,and eaery five(5) years thereafter, the Commercial General Liability and Umbrella/Excess Liability insurance limits required above shall be increased by the percentage increase in the Consumer Price Index from the month the Agreement was executed to the month immediately preceding the first month of the year in which the increase is required. 2. Self-Insurance: Proof of qualification as a qualified self-insurer, if approved in advance in writing by an Insured Entities representative,will be acceptable in lieu of securing and maintaining one or more of the coverages required in this Insurance Section. Such acceptance shall become a part of this insurance provision by reference herein. For Workers' Compensation, such evidence shall consist of a copy of a current self-insured certificate for the State in which the work will be performed. In order for self insurance to be accepted, Grantee's unsecured debt must have a financial rating of at least investment grade. For purposes of this section, "Investment Grade"means (i) if Grantee has a Credit Rating from both S&P and Moody's then, a Credit Rating from S&P equal to or better than"BBB-"and a Credit Rating from Moody's equal to or better than"Baa3"; (ii) if Grantee has a Credit Rating from only one of S&P and Moody's, then a Credit Rating from S&P 13 equal to or better than"BBB-" or a Credit Rating from Moody's equal to or better than"Baa3; or (lit) if the Parties have mutually agreed in writing on an additional or alternative rating agency, then the equivalent credit rating assigned to an entity by such additional or alternative rating agency that is equal to or better than"BBB-" from S&P and/or"Baa3" from Moody's. 3. Additional Insured and Loss Payee: The intent of the Additional Insured requirement under the CGL, Auto, CPL, Umbrella/Excess, Aircraft and Watercraft policies is to include the Insured Entities, their directors, officers and employees, as Additional Insured's for liabilities associated «-ith, or arising out of, all operations, work or services to be performed by or on behalf of Grantee, including ongoing and completed operations,under this Agreement. The following language should be used ►s hen referencing the additional insured status: National Grid USA, its subsidiaries and affiliates shall be named as additional insured.. The Loss Payee language, as required in article Lit above, shall read as follows: National Grid USA its subsidiaries and affiliates shall be included as a Loss Pavee as their interest may appear_ To the extent Grantee's insurance coverage does not provide the full Additional insured coverage as required herein, Grantee agrees to indemnify and hold harmless the Insured Entities against any and all liability resulting from any deficiency in Grantee's insurance coverage that may be out of compliance with this insurance requirement. 4. Waiver of Recot ery: Grantee and its insurance carrier(s) shall waive all rights of recovery against the Insured Entities and their directors, officers and employees, for any loss or damage covered under those policies referenced in this insurance provision,or for any required coverage that may be self-insured by Grantee. To the extent Grantee's insurance carriers will not waive their right of subrogation against the Insured Entities, Grantee agrees to indemnify the Insured Entities for any subrogation activities pursued against them by Grantee's insurance carriers. However, this waiver shall not extend to the gross negligence or willful misconduct of the Insured Entities or their employees, sub-contractors or agents. 5, Contractors: In the event Grantee uses Contractors in connection with this Agreement, it is expressly agreed that Grantee shall have the sole responsibility to make certain that all Contractors are in compliance with these insurance requirements and remains in compliance throughout the course of this Agreement, and thereafter as required. Grantee shall remain liable for the performance of the Contractor, and such sub-contract relationship shall not relieve Grantee of its obligations under this agreement. Unless agreed to in writing the by the Risk Management Department of National Grid USA Service Company, any deductible or self insured retentions maintained by any Contractor, which shall be for the account of the Contractor, and shall not exceed S100,000. In addition, Contractor shall name both the Grantee and National Grid USA, (including their subsidiaries, affiliates,officers and employees), as additional insured's under the Commercial General Liability and Umbrella/Excess Liability insurance. If requested by National Grid, Granteee shall provide National Grid with an insurance certificate from its Contractor evidencing this coverage. In the event any Contractor is unable to maintain all of the same insurance coverage as required in this insurance article, Grantee agrees to indemnify and hold the Insured Entities harmless against any and all liability resulting from any deficiency in Contractor's insurance coverage that may be out of compliance with these insurance requirements. 14 6. Insurance Certification: Upon execution of this Agreement, Grantee shall promptly provide National Grid with(a) Certificate(s) of Insurance for all coverage's required herein at the follo%ving address: National Grid Attn: Risk Management Bldg. B-3 300 Erie Boulevard West Syracuse, NY 13202 Such certificates, and any renewals or extensions thereof, shall outline the amount of deductibles or self-insured retentions which shall be for the account of Grantee. Such deductibles or self- insured retentions shall not exceed S 100,000 unless agreed to in writing by the Risk Management Department of National Grid USA Service Company, whose approval shall not be unreasonably withheld,delayed or conditioned. Grantee shall provide National Grid with at least 30 days prior written notice of any cancellation or diminution of the insurance coverage required in this insurance article. 7. Insurance Obligation: If any insurance coverage is not secured, maintained or is cancelled and Grantee fails immediately to procure other insurance as specified, National Grid has the right, but not the obligation,to procure such insurance and to invoice Grantee for said coverage. 8. Incident Reports: Grantee shall furnish the Risk Management Department of National Grid USA Service Company with copies of any non-privileged accident or incident report(s)(collectively, the"Documents")sent to Grantee's insurance carriers covering accidents, incidents or events occurring as a result of the performance of all operations, work and services to be performed by or on behalf of Grantee under or in connection with this Agreement, excluding any accidents or incidents occurring on Grantee property. If any of the National Grid Companies are named in a lawsuit involving the operations and activities of Grantee associated with this Agreement, Grantee shall promptly provide copies of all insurance policies relevant to this accident or incident if requested by National Grid. However, in the event such Documents are deemed privileged and confidential (Attorney Client Privilege), Grantee shall provide the relevant facts of the accident or incident in a format that does not violate such Attorney Client Privilege, 9. Other Coverage:These requirements are in addition to any which may be required elsewhere in this Agreement. In addition, Grantee shall comply with any governmental site specific insurance requirements even if not stated herein. 10. Coverage Representation: Grantee represents that it has the required policy limits available, and shall notify National Grid USA Service Company's Risk Management Department in writing when the minimum coverage's required in this article herein have been reduced as a result of claims payments, expenses,or both. However,this obligation does not apply to any claims that would be handled solely with in Grantee's deductible or self-insured retention. 1 I. Responsibility: The complete or partial failure of the Grantee's insurance carrier to fully protect and indemnify the Insured Entities per the terms of the Agreement, including without limitation, this exhibit, or the inadequacy of the insurance shall not in any way lessen or affect the obligations of the Grantee to the Insured Entities. 12. Coverage Limitation: Nothing contained in this article is to be construed as limiting the extent of the Grantee's responsibility for payment of damages resulting from all operations, work and 15 services to be performed by or on behalf of Grantee under or in connection with this Agreement, or limiting, diminishing, or waiving Grantee's obligation to indemnify, defend, and save harmless the Insured Entities in accordance with this Agreement. 16