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VARIANCE REQUEST
ZONING BOARD OF ADJUSTMENT
October 22, 2019
CASE: ZBA-944
PETITIONER: Kurt R. Huff and Catherine A. Oliverio, property owners
REQUEST: Variance from the 25’ front yard setback requirement per Section 51.6-2(3) of the New Hanover
County Zoning Ordinance.
LOCATION: 210 Windy Hills Drive
PID: R07908-005-025-000
ZONING: R-15, Residential District
ACREAGE: 0.43 Acres
PETITIONER’S REQUEST:
Kurt Huff and Catherine Oliverio, property owners, are requesting a variance from the 25’ front yard setback
requirement for R-15 per Section 51.6-2 of the New Hanover County Zoning Ordinance. The property is located
at 210 Windy Hills Drive, Wilmington, NC.
BACKGROUND AND ORDINANCE CONSIDERATIONS:
In July 2018, the property owner’s agents submitted an application to construct a single-family residence on the
site. The submitted site plan showed the front staircase encroaching approximately 9.7’ into the required front
yard setback. After proceeding through the review process, the application did receive zoning approval by staff
with no indication that a revision or alteration to the plans was needed, although the zoning conditions document
stated the structure was subject to a front yard setback of 25’.
On or about July 20, 2019, staff was notified that the front staircase appeared to encroach into the required front
yard setback as observed during a routine building inspection during the construction process. At this time, staff
advised the building contractor that despite the approval of the site plan, the structure would have to be brought
into compliance with the applicable provisions within the zoning ordinance. As a result of the inadvertent staff
approval of the site plan, county staff allowed construction to proceed and the building contractor and
homeowner were advised of options to bring the structure into compliance with the front yard setback
requirement. The applicant elected to continue construction of the home as designed and to pursue a variance
to the front yard setback requirement in an attempt to bring the structure into compliance, and a Certificate of
Occupancy was obtained on September 20, 2019.
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Submitted site plan showing encroachment of staircase into 25' front yard setback.
The County’s Zoning Ordinance does not have a specific allowance for features such as decks, staircases, or
porches to encroach into any required yard area; and these features are considered to be part of the main
structure per the definition of Structure and/or Building:
Structure and/or Building-Anything constructed or erected within a fixed location on the ground, or
attached to something having a fixed location on the ground. The terms building and/or structure shall
be construed to include porches, decks, carports, garages, sheds, roof extensions, overhangs extending
more than 2’, and any other projections directly attached to the structure and/or building. (12/17/2012)
As such, a home and any deck, staircase, or porch serving the structure would have to adhere to the yard
requirements or relaxed yard requirements based on an approved variance.
New Hanover County’s zoning and subdivision regulations allow for subdivisions to utilize Performance or
Conventional requirements. Under Conventional requirements, lots that are created must adhere to the
dimensional requirements for the zoning district. For example, lots created under Conventional requirements in
the R-15 zoning district must meet the dimensional requirements of Section 51.6-2:
Section 51.6: R-15 Residential District
51.6-1: The R-15 Residential District is established as a district in which the principal use of land is for
residential purposes and to insure that residential development not having access to public water and
Staircase
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dependent upon septic tanks for sewage disposal will occur at sufficiently low densities to insure a healthful
environment.
51.6-2: Conventional Residential Regulations
Dimensional Requirements:
(1) Minimum lot area 15,000 sq.ft. Duplex 25,000 sq.ft.
(2) Minimum lot width 80 feet
(3) Minimum front yard 25 feet
(4) Minimum side yard 10 feet
(5) Minimum rear yard 20 feet
(6) Maximum height 35 feet
Setbacks for structures on Conventional Residential lots are dictated by the yard requirements of the zoning
district of the property, per the definitions of Setback Line and Yard in the Zoning Ordinance:
Setback Line - The line on the front, rear, and sides of a lot, which delineates the area upon which a
structure may be built and maintained. (23-28)
Yard - A required open space unoccupied and unobstructed by a structure or portion of a structure
provided, however, that fences, walls, poles, posts, and other customary yard accessories, ornaments and
furniture may be permitted in any yard subject to height limitations and requirements limiting obstruction
of visibility. (1/5/81) Private driveways or easements serving three or fewer lots pursuant to Section 65
may also be permitted in any yard. (3/8/93) HVAC units elevated to comply with flood plain regulations
may be permitted in any side yard provided the supporting structure is at least (5) feet from the adjoining
property line. (8/18/03) (23-42)
Yard, Front - A yard extending between side lot lines across the front of a lot adjoining a public or private
street. The depth of the required front yard shall be measured at right angles to a straight line
joining the foremost points of the side lot lines, and in such a manner that the yard established
shall provide minimum depth parallel to the front lot line. (7/6/92) (23-43)
The deed and record plat for the subject property, which was recorded in 2002, depict the lot as being Lot 2 of
the Avalon Oaks Subdivision, which county records indicate is a conventional subdivision and thus must adhere to
the yard requirements for R-15 in Section 51.6-2.
The applicant contends that the variance is necessary as the plans were duly submitted and approved by the
county, and that all necessary inspections were conducted. In addition, the applicant contends the stairs are
necessary in their location to provide access to the structure, which is required to be elevated due to its’ location
in the VE Special Flood Hazard Area.
In summary, the petitioner is requesting a variance of approximately 15’ from the 25’ front yard requirement of
Section 51.6-2(3). If approved, the variance would allow the entry staircase to remain in its current position with
a 9.7’ encroachment into the front yard setback.
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BOARD OF ADJUSTMENT POWER AND DUTY:
The Board of Adjustment has the authority to authorize variances from the terms of the Zoning Ordinance where,
due to special conditions, a literal enforcement of the regulations would result in unnecessary hardship. In
granting any variance, the Board may prescribe appropriate conditions and safeguards in conformity with the
Zoning Ordinance. A concurring vote of four-fifths (4/5) of the voting members of the Board shall be necessary to
grant a variance. A variance shall not be granted by the Board unless and until the following findings are made:
1. Unnecessary hardship would result from the strict application of the ordinance. It shall not be necessary
to demonstrate that, in the absence of the variance, no reasonable use can be made of the property.
2. The hardship results from conditions that are peculiar to the property, such as location, size, or
topography. Hardships resulting from personal circumstances, as well as hardships resulting from
conditions that are common to the neighborhood or the general public, may not be the basis for granting
a variance.
3. The hardship did not result from actions taken by the applicant or the property owner. The act of
purchasing property with knowledge that circumstances exist that may justify the granting of a variance
shall not be regarded as a self-created hardship.
4. The requested variance is consistent with the spirit, purpose, and intent of the ordinance, such that public
safety is secured, and substantial justice is achieved.
ACTION NEEDED (Choose one):
1. Motion to approve the variance request based on the findings of fact (with or without conditions)
2. Motion to table the item in order to receive additional information or documentation (Specify).
3. Motion to deny the variance request based on specific negative findings in any of the 4 categories
above.