lot under contract has the engineering complete and is in the municipal permit process 150 all ofwhich takes timeenvironmentally compelling reason to prohibit using the existing site until the new sit ID: 890306
Download Pdf The PPT/PDF document "rejected an additional site which the bu..." is the property of its rightful owner. Permission is granted to download and print the materials on this web site for personal, non-commercial use only, and to display it on your personal computer provided you do not modify the materials and that you retain all copyright notices contained in the materials. By downloading content from our website, you accept the terms of this agreement.
1 rejected an additional site which the bu
rejected an additional site which the business had under contract. lot under contract, has the engineering complete, and is in the municipal permit process – all ofwhich takes time.environmentally compelling reason to prohibit using the existing site until the new site is ready andmoving the tanks back to their historic site closer to the river is in neither the business's nor theState's best interest.move the tanks. William B. Towle, Esq.Ward Law, PC3069 Williston RoadSouth Burlington, VT 05403Phone 802/863-0307 ext. 18Fax 802/863-4587www.wardlawvt.com http://www.linkedin.com/in/willtowle Please note my new email address: WARNING: FRAUD ALERT.attempting to initiate fraudulent wire requests or change wire instructions.does not email wire instructions or wire instruction changes.this office requesting that you wire or transfer funds or change wire instructions, please immediatelycall our office at a previously known/verified telephone number other than the number contained inthe email.DO NOT INITIATE A WIRE TRANSFER BASED ON EMAILED INSTRUCTIONS ALONE. CONFIDENTIALITY NOTICE: This electronic email transmission may contain attorney/client privilegeand confidential information intended only for the individual or entity named above. Anydissemination, use, distribution, copying or disclosure of this communication by any other person orentity is strictly prohibited. Should you receive this transmission in error, please notify the sender and return the originaltransmission to towle@wardandbabb.com . WBNoEncrypt From:Will TowleTo:NRB - Comments Subject:J.M. Rowley Corporation Proposed AO Public CommentDate:Wednesday, Octob
2 er 31, 2018 3:34:41 PMNRB Comments: This
er 31, 2018 3:34:41 PMNRB Comments: This office represents J.M. Rowley Corporation. My client objects to each alleged violation, and without waiver on any other issue, I writepredominantly to address a core issue regarding the allegations within Count III. III. Failure to obtain an Act 250 Permit Amendment pursuant to Act 250 Rule 34(A) [Fuel StorageArea construction] historical and pre-existing use of this parcel. operation.and the West Milton Road.buildings (as the crow flies) up an access road in the upland wooded section of the lot. and business activity for probably at least a hundred years.tanks over for almost 40 years near the barn/Quonset hut.violation and is a pre-existing use.However, this is not in either business's or the State's interest. across the Milton Road from the parcel) after Irene and Sandy caused the fuel distribution businessto move the tanks in approximately 2014 to a higher portion of the parcel, but still near the barn/oldfarm part of the parcel. This was done, at the business's expense, solely to avoid the risk of having aflood event wash the tanks down river. significant adverse impact with respect to any of the Act 250 criteria. Act 250 Rules 2(C)(7), Code ofVt. Rules 12 004 060-3.250 application, we do not believe this is “commencement of development” under the law. 10 V.S.A.§ 6081.(a).limitation. aggressively looking for an alternative site.engineering, getting the municipal permitting, and construction.denied previous attempts to permit the existing use on the existing site, and the town of Milton als