`
`
`
`
`
`Docket No. 20-CV-08566
`
`
`
`
`
`
`COMPLAINT
`AND PETITION
`
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`DAVID EISENBACH, GEORGE H. EISENBACH,
`JOANNE EISENBACH, JENNIFER YOUNG, DANA
`CARINI, ROSEMARIE ORSHAKOSKI, MICHAEL
`ORSHAKOSKI, JONATHAN D. CHAMPLIN, ANNE
`CHAMPLIN, RAYMOND H. CHAMPLIN, KENNETH
`LEVINE, CATHERINE POLERA, JULIEN DAVIES
`HOPE ROGERS, PHIL WEISS, CYNTHIA KING, JO
`MANGO, and LAURALEE HOLMBO,
`
` Plaintiffs/Petitioners,
`
` -against-
`
`VILLAGE
`NELSONVILLE,
`OF
`VILLAGE
`ZONING
`BOARD
`OF
`OF NELSONVILLE
`APPEALS, VILLAGE OF NELSONVILLE PLANNING
`BOARD, WILLIAM BUJARSKI, as Building Inspector
`of
`the Village
`of Nelsonville, HOMELAND
`TOWERS, LLC, NEW YORK SMSA LIMITED
`PARTNERSHIP d/b/a VERIZON WIRELESS, and
`NEW CINGULAR WIRELESS PCD LLC d/b/a AT&T,
`
` Defendants/Respondents.
`
`
`Statement of the case
`
`1.
`
`This lawsuit challenges the legal sufficiency of the Consent Order1, which
`
`represents a collection of defective land use decisions. As a contractual remedy, the
`
`Consent Order’s authority derives from the statutes it implements; specifically, the TCA,2
`
`
`1 Reference is made to a certain Stipulation of Settlement and Consent Order, dated January 29, 2020
`(the “Consent Order”), which is attached as Exhibit “A”, entered in the action styled: New York SMSA
`Limited Partnership d/b/a Verizon Wireless and Homeland Towers v. The Village of Nelsonville, et
`al., Docket No. 18-cv-5932 (Briccetti, J.) (the “DJ Action”).
`2 47 U.S.C. § 151, et seq. (“Communications Act” or “TCA”)
`
`
`
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 2 of 33
`
`
`
`NEPA,3 SEQRA, and ESA.4 As a judicial act, endorsing the Consent Order bypassed
`
`indispensable environmental review that should have first been implemented. This
`
`action implicates the Court’s approval of the Consent Order as violating federal and state
`
`laws, and thus failing to promote the objectives envisioned by the TCA, NEPA, SEQRA,
`
`and the ESA.
`
`2.
`
`3.
`
`Now, this Court must vacate, annul, and set aside the Consent Order.
`
`In the DJ Action, the Providers5 sought to enforce alleged TCA violations
`
`relating to the Village constructively denying its applications for site plan approval and
`
`a variance to construct a one-hundred ten-foot (110’) monopine tower and ancillary
`
`wireless telecommunications equipment in the Village of Nelsonville.
`
`4.
`
`The Providers mainly targeted the Village’s delays, flawed environmental
`
`significance review of the project under SEQRA, and its failure to make a significance
`
`determination before denying their applications. The Providers also asserted claims for
`
`direct violations of TCA § 704. The Village caved to the hefty thud of the Providers’
`
`claims in the DJ Action, which resulted in the de facto approval of the Providers’
`
`applications. These were previously met with heavy public opposition.
`
`5.
`
`This “sue and settle” gambit paid off for the Providers, but prevented
`
`interested members of the public from a meaningful opportunity to participate in the
`
`SEQRA process. In its role as parens patriae, the Village failed in adequately
`
`representing the interests of its citizens, who now bring this action.
`
`
`3 The federal policies embodied by National Environmental Policy Act (“NEPA”) are implemented at
`the state level in this case by the New York State Environmental Quality Review Act, which is
`promulgated under 6 NYCRR Part 617, et seq. (“SEQRA”).
`4 16 U.S.C. § 1531, et seq. (the “ESA”).
`5 Collective reference is made to Homeland, Verizon, and AT&T (the “Providers”).
`
`2
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 3 of 33
`
`
`
`6.
`
`Plaintiffs also seek to vacate, annul, and set aside the building permit
`
`issued to Homeland on June 15, 2020 to construct a 95-foot tall monopine tower to
`
`distribute wireless telecommunications services, for ancillary equipment, and site work
`
`including construction of retention walls and a roadway (the “Building Permit”).
`
`7.
`
`At its essence, this case is about balancing the implementation of
`
`environmental significance review with the TCA’s mandate of promoting the swift
`
`development of wireless telecommunications infrastructure.
`
`8.
`
`The Communications Act does not entirely preempt NEPA and SEQRA by
`
`virtue of the Supremacy Clause of the U.S. Constitution. But a balance must be struck
`
`between preserving federal interests in developing wireless technology infrastructure
`
`and implementing mandatory environmental review.
`
`Jurisdiction and venue
`
`9.
`
`The declaratory and injunctive relief Plaintiffs seek are authorized by 28
`
`U.S.C. §§ 2201 and 2202 and FRCP6 57.
`
`10.
`
`This Court has subject matter jurisdiction pursuant to 28 U.S.C §§ 1331
`
`and 1343.
`
`11.
`
`Venue in the Southern District of New York is proper under 28 U.S.C. §
`
`1391(b)(2) as Plaintiffs’ claims arose in the Ninth Judicial District.
`
`12.
`
`Jurisdiction over Plaintiffs’ state law claims is proper pursuant to 28 U.S.C.
`
`§ 1367.
`
`13.
`
`The Court has pendent jurisdiction over Plaintiffs’ claims arising under
`
`CPLR7 § 7803(3).
`
`6 Fed. R. Civ. P. (“FRCP”).
`7 New York Civ. Prac. L. & R. (“CPLR”).
`
`
`
`3
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 4 of 33
`
`
`
`14.
`
`Pursuant to CPLR § 271 this hybrid special proceeding is timely because it
`
`is within four months of the Building Permit being issued on June 15, 2020.
`
`15. No prior application for similar relief has been sought from this Court or
`
`any other court of competent jurisdiction.
`
`The parties and their legal standing
`
`16.
`
`Plaintiffs/petitioners David Eisenbach, George H. Eisenbach, and Joanne
`
`Eisenbach are individuals who own and/or reside on real property known as 34 Billy’s
`
`Way, Cold Spring, New York 10516 (the “Eisenbach Property”).
`
`17.
`
`Plaintiffs/petitioners Jennifer Young and Catherine Polera are individuals
`
`who own and/or reside on real property known as 449 Lane Gate Road, Cold Spring, New
`
`York 10516 (the “Young Property”).
`
`18.
`
`Plaintiffs/petitioners Dana Carini and Julien Davies are individuals who
`
`own and/or reside on real property known as 75 Moffat Road, Cold Spring, New York
`
`10516 (the “Carini Property”).
`
`19.
`
`Plaintiff/petitioners Rosemarie Orshakoski and Michael Orshakoski are
`
`individuals who own and/or reside on real property known as 115 Moffat Road, Cold
`
`Spring, New York 10516, (the “Orshakoski Property”).
`
`20.
`
`Plaintiff/petitioner Jonathan D. Champlin, Anne Champlin, and Raymond
`
`H. Champlin are individuals who own and/or reside on real property known as 9
`
`Rockledge Road, Nelsonville, New York 10516 (the “Champlin Property”).
`
`21.
`
`Plaintiff/petitioner Kenneth Levine is an individual who owns and/or
`
`resides on real property known as 103 Healy Road, Nelsonville, New York 10516 (the
`
`“Levine Property”).
`
`4
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 5 of 33
`
`
`
`22.
`
`Plaintiff/petitioner Hope Rogers is an individual who owns and/or resides
`
`on real property known as 160 Moffat Road, Cold Spring, New York 10516 (the “Rogers
`
`Property”).
`
`23.
`
`Plaintiffs/petitioners Phil Weiss and Cynthia King are individuals who own
`
`and/or reside on real property known as 752 East Mountain Road South, Cold Spring,
`
`New York 10516 (the “Weiss Property”).
`
`24.
`
`Plaintiff/petitioner Jo Mango is an individual who owns and/or resides on
`
`real property known as 392 Main Street, Nelsonville, New York 10516 (the “Mango
`
`Property”).
`
`25.
`
`Plaintiff/petitioner Lauralee Holmbo is an individual who owns and/or
`
`resides on real property known as 6 Parsonage Street, Cold Spring, New York 10516 (the
`
`“Holmbo Property”).
`
`26.
`
`The Champlin Property is within very close proximity (i.e. less than five
`
`hundred (500) feet) to the Project, thus intensifying its adverse physical and
`
`environmental impacts--both qualitatively and quantitatively--from the general public
`
`and community
`
`27.
`
`The Eisenbach Property, Young Property, Carini Property, Orshakoski
`
`Property, Champlin Property, Levine Property, Rogers Property, and Weiss Property are
`
`within close proximity (i.e. less than one thousand five hundred (1,500) feet) to the
`
`Project, which still magnifies its adverse environmental impacts to a greater degree than
`
`the general public and community.
`
`5
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 6 of 33
`
`
`
`28.
`
`The Mango Property and Holmbo Property are close enough to the Project
`
`that its adverse impacts will still yield an impact and permanent harm different that
`
`those cast on general public and community.
`
`29.
`
`Each of the individual properties identified in Paragraphs 16-25, above, are
`
`in such close proximity to the Project and the Premises to generate adverse
`
`environmental impacts that are unique and fundamentally different from the public at
`
`large including:
`
`(a)
`
`(b)
`
`(c)
`
`(d)
`
`(e)
`
`(f)
`
`negative visual impacts (e.g., Project bulk and scale from
`building elements, and increased light and visual pollution);
`
`physical disturbances to natural habitats due to Project site
`disturbances, grading, and an increase in impervious
`surface coverage on the Premises;
`
`stormwater
`increased
`sedimentation;
`
`runoff
`
`causing erosion and
`
`destruction and elimination of native wildlife habitats such
`as birds, bats, mammals, and native plant species;
`
`displacement of rare and protected species of plants and
`animals including Indian Bats and Northern Long-eared
`Bats; and
`
`displacement of native animals that once frequented the
`Premises and surrounding properties of plaintiffs.
`
`
`
`
`
`
`
`
`
`
`
`30.
`
`The Project’s individual and cumulative environmental impacts will
`
`uniquely and particularly impact Plaintiffs due to their proximity, alone, to the Project.
`
`31.
`
`The failure to consider private rights of way and limited means of access to
`
`the Premises over private roads or ways could also seriously compromise access to the
`
`Project and the Premises.
`
`6
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 7 of 33
`
`
`
`32.
`
`Plaintiffs will otherwise be directly and uniquely impacted by the Project
`
`and its adverse physical and environmental impacts.
`
`33. Upon information and belief, the Village is a municipal corporation
`
`organized and existing under New York State laws with its principal office located at
`
`Village Hall, 258 Main Street, Nelsonville, New York 10516.
`
`34.
`
`The Village, as a municipality, its departments, bureaus and officers
`
`thereof, is empowered and responsible to perform and exercise all powers, duties,
`
`privileges and immunities granted to it by the United States Constitution, New York
`
`State Constitution and other applicable provisions of law.
`
`35. Upon information and belief, the Planning Board was and is a duly
`
`constituted board created by the Village pursuant to Article 2 of New York’s Village Law
`
`and the Village’s Charter, Local Laws, Ordinances, and Resolutions.
`
`36. Upon information and belief, the ZBA was and is a duly constituted board
`
`created by the Village pursuant to Article 2 of New York’s Village Law and the Village’s
`
`Charter, Local Laws, Ordinances, and Resolutions.
`
`37. Homeland is a domestic limited liability company having an office located
`
`at 9 Harmony Street, 2nd Floor, Danbury, Connecticut 06810.
`
`38.
`
`Verizon is a limited partnership authorized to do business in the State of
`
`New York having an office located at One Verizon Way, Basking Ridge, New Jersey
`
`07920.
`
`39.
`
`AT&T is a domestic corporation authorized to do business in the State of
`
`New York.
`
`7
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 8 of 33
`
`
`
`40. Defendants8 are each a “person” subject to suit and are being sued for
`
`declaratory relief, injunctive relief, or seeking judicial review of a final agency action(s)
`
`discharged in their capacity as a Village official or a duly constituted board.
`
`A. The Communications Act
`
`Statutory background
`
`41.
`
`In 1996, Congress amended the Communications Act of 1934 to establish
`
`“a pro-competitive, de-regulatory national policy framework designed to accelerate
`
`rapidly private sector deployment of advanced telecommunications and information
`
`technologies and services to all Americans by opening all markets to competition.”9 These
`
`amendments were designed to dismantle legal, operational, and financial barriers to
`
`telecommunications markets that had previously stifled competition in the past.
`
`42.
`
`TCA § 253(a) embodies this preemptive mandate in providing that
`
`“[n]o State or local statute or regulation, or other State or local legal requirement, may
`
`prohibit or have the effect of prohibiting the ability of any entity to provide any interstate
`
`or intrastate telecommunications service.”10
`
`43.
`
`The Supremacy Clause of the U.S. Constitution empowers Congress to
`
`preempt state or local laws or regulations under certain specified conditions.11 And
`
`
`8 Defendants/respondents the Village of Nelsonville (“Village”), Village of Nelsonville Zoning Board of
`Appeals (“ZBA”), Village of Nelsonville Planning Board (“Planning Board”), William Bujarski, as
`Building Inspector of the Village of Nelsonville (the “Building Inspector”) (collectively, the “Village”),
`Homeland Towers, LLC (“Homeland”), New York SMSA Limited Partnership d/b/a Verizon Wireless
`(“Verizon”), and New Cingular Wireless PCD LLC d/b/a AT&T (“AT&T”) (collectively, the
`“Defendants”).
`9 S. Conf. Rep. No. 104-230, 104th Cong., 2d Sess. 1 (1996).
`10 47 U.S.C. § 253(a).
`11 See, e.g., Louisiana PSC, 476 U.S. at 368
`
`8
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 9 of 33
`
`
`
`preemption of state law or regulation occurs “when there is outright or actual conflict
`
`between federal and state law.”12
`
`44. However, TCA § 332(c)(7) entitled “preservation of local zoning authority”
`
`delegates state and local authority over zoning and land use decisions for personal
`
`wireless service facilities albeit with specific limitations on that authority. For example,
`
`state or local governments may not discriminate against providers of functionally
`
`equivalent services and must act on applications within reasonable periods of time.13
`
`45.
`
`Allegations that a state or local government has acted inconsistently with
`
`TCA § 332(c)(7), et seq. are justiciable controversies that may be litigated.
`
`B. NEPA and SEQRA
`
`46. NEPA is “our basic national charter for protection of the environment.”14
`
`The statute was conceived with the purpose of prioritizing comprehensive environmental
`
`analysis to ensure that federal agencies carefully examine the environmental significance
`
`and range of potential impacts from their decisions before they are undertaken. NEPA
`
`also ensures that the public is made aware of the range of environmental effects and
`
`impacts attending land use applications and agency decision-making.
`
`47.
`
`To license new wireless communications facilities, the FCC requires that
`
`project proponents identify all actions that may have a significant environmental effect
`
`for which environmental assessments must be prepared, and this includes:
`
`(i)
`
`Facilities that: (i) may affect listed threatened or endangered
`species or designated critical habitats; or (ii) are likely to
`jeopardize
`the continued existence of any proposed
`endangered or threatened species or likely to result in the
`destruction or adverse modification of proposed critical
`
`
`12 Louisiana PSC, 476 U.S. at 368, citing, Free v. Bland, 369 U.S. 663 (1962).
`13 See 47 U.S.C. § 332(c)(7)(B) for a full list of enumerated limitations.
`14 40 C.F.R. § 1500.1(a).
`
`9
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 10 of 33
`
`(ii)
`
`habitats, as determined by the Secretary of the Interior
`pursuant to the Endangered Species Act of 1973 (“ESA”); and
`
`Facilities that may affect districts, sites, buildings, structures
`or objects, significant in American history, architecture,
`archeology, engineering or culture, that are listed, or are
`eligible for listing, in the National Register of Historic
`Places.15
`
`
`
`
`
`48.
`
`In New York, NEPA’s charter and purpose is mechanized through SEQRA.
`
`49.
`
`Every land use decision requires that the reviewing agency examine the
`
`proposed action’s impact on the environment by implementing the stages of the SEQRA
`
`review process.16
`
`50.
`
`SEQRA’s implementing regulations require that “[n]o agency involved in
`
`an action may undertake, fund or approve the action until it has complied with the
`
`provisions of SEQRA.17 In determining the environmental significance of land use
`
`decisions, the reviewing agency is charged with classifying the types of actions
`
`comprising a land use and the potential to yield an adverse environmental impact.
`
`51.
`
` Type I or Unlisted actions under SEQRA are more likely to have significant
`
`adverse environmental impacts.18 By contrast, Type II actions involve activities that
`
`have been found by New York State as having no significant environmental impacts.
`
`These actions are statutorily exempt from SEQRA review.19 Type II actions do not
`
`require preparation of an EAF, a negative or positive declaration of environmental
`
`
`15 47 C.F.R. § 1.1307(a)(3) and (4); 16 U.S.C. § 470f., which is also referred to as Section 106 of the
`National Historic Preservation Act (“NHPA”).
`16 22 N.Y.C.R.R. Part 617.
`17 6 NYCRR 617.3(a).
`18 6 NYCRR § 617.4.
`19 6 NYCRR § 617.5(a).
`
`10
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 11 of 33
`
`
`
`significance, or an EIS. SEQRA regulations enumerate certain actions as Type II, which
`
`are categorically excluded from SEQRA review.20
`
`52. Here, leaving aside how the Project could have or should have be typed
`
`under SEQRA, the Village avoided this mandatory review process altogether.21
`
`Factual background
`
`53.
`
`The Providers develop and operate telecommunications infrastructure to
`
`provide mobile telephone and other wireless communication services nationwide by the
`
`grant of licenses from the Federal Communications Commission.
`
`54.
`
`Through the adoption of federal mandates, regulations, and as promulgated
`
`through acts of Congress, the proliferation of telecommunications facilities--in particular,
`
`wireless communications--is a widely-recognized demand throughout the United States.
`
`To that end, telecommunications companies including the Providers closely study and
`
`deploy resources to ensure consistency and wireless communication services and to avoid
`
`interruptions and gaps in wireless service coverage.
`
`55.
`
`Telecommunications companies regularly analyze and perform studies
`
`assessing the above referenced infrastructure and wireless communication needs
`
`throughout New York State. In particular, the Providers recently identified natural
`
`topographical features throughout the Village of Nelsonville making it prone to wireless
`
`transmission and reliability problems for to personal wireless service coverage and
`
`emergency service providers.
`
`56.
`
`To this end, the Providers sought to locate and install a wireless service
`
`generating facility on a certain 9.63-acre tract of real property known as 15 Rockledge
`
`20 6 NYCRR 617.5(c).
`21 Complaint, ¶¶ 141-143.
`
`
`
`11
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 12 of 33
`
`
`
`Road, Nelsonville, New York 10516 (the “Premises”). Originally, they sought permission
`
`to construct this antenna and ancillary equipment by means of a special use permit as
`
`required by Code § 188-67, et seq. In addition, because the Premises is landlocked, the
`
`Providers requested interpretive relief from the ZBA to determine the need for a variance
`
`from New York State Village Law § 7-736, which requires that a property be accessible
`
`by a street recognized on a duly filed and recorded plat. Additionally, the Providers
`
`required site plan approval from the Planning Board. The Providers made these three
`
`applications to the Village as detailed below (collectively, the “Applications”).
`
`A. Planning and Zoning Board Proceedings
`
`57. On July 20, 2017, the Providers filed applications for special use permit, an
`
`application for variance with the ZBA, and a site plan application with the Planning
`
`Board in connection with the Project. Subsequently, the Providers supplemented the
`
`Applications with a host of correspondence and submissions detailing physical and
`
`engineering data supporting the Project, area analyses assessing deficiencies in the need
`
`for enhanced wireless services, and a long form environmental assessment form.
`
`58.
`
`The Building Inspector then referred the Project to the ZBA for review of
`
`its special use permit application for relief from Village Law § 7-736. If approved by the
`
`ZBA, the Planning Board would have then considered the Project’s site plan application.
`
`59.
`
`In the ensuing year, the Providers made numerous submissions to the ZBA
`
`and Planning Board supplying additional engineering data, radiofrequency studies,
`
`consulting reports and analyses, and correspondence supporting the Project. In response,
`
`the Village engaged engineers and site planning professionals to analyze the Project’s
`
`numerous components to provide feedback and guidance to the Village in its review.
`
`12
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 13 of 33
`
`
`
`60.
`
`The Village’s professional consultants made findings including that gaps in
`
`wireless coverage existed in the process of reviewing Project submissions.
`
`61. On or about October 18, 2017, counsel for the Providers supplied
`
`correspondence from New York State’s Historic Preservation Office “(SHPO”) to the ZBA
`
`and Planning Board identifying that the Project, in its then-form, would not adversely
`
`affect those districts, sites, buildings, structures, or objects either listed or eligible for
`
`listing on the National Register of Historic Places.
`
`62.
`
`In October, 2017, the Planning Board began questioning the need for
`
`alternative site proposals from that of the Premises. The Providers, in turn, identified a
`
`lack of feasible alternatives to the Project including four nearby church steeples of
`
`significantly less height and a 120-foot tall facility located at 2 Secor Street, which was
`
`owned by the Village. Ultimately, these alternatives failed due to engineering
`
`insufficiency and heavy public opposition.
`
`63. On November 15, 2017, the ZBA and Planning Board commenced their joint
`
`public hearings on the Applications.
`
`64.
`
`From November 15, 2017 through April 4, 2018, both boards held
`
`protracted public hearings, during which time Project opponents raised a plethora of
`
`objections. Chief among these objections was the Premises being landlocked. Access was
`
`proposed over a private right of way. For decades, the strip of private property known as
`
`“Rockledge Road” was used exclusively and uninterrupted as access to various landlocked
`
`parcels including the Premises for personal use. Certain Project opponents argued that
`
`the Providers (specifically, Homeland) proposed a use entirely outside of the scope of the
`
`right-of-way through their building permit application.
`
`13
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 14 of 33
`
`
`
`65. Major Project objections also included disputes over demonstrating
`
`significant gaps in wireless coverage and actual need to provide such communication
`
`services by constructing a tower.
`
`66. Opponents also cited the Project’s negative aesthetic and environmental
`
`impacts on the Cold Spring Rural Cemetery, which had recently been listed as a property
`
`of historic significance.
`
`67. Many homeowners living in close proximity to the Project including
`
`Plaintiffs spoke out against its adverse aesthetic and environmental impacts that would
`
`be foisted upon them especially given their proximity to it.
`
`B. Deciding the Applications
`
`68. On May 30, 2018, the ZBA and Planning Board convened a joint meeting to
`
`decide the Applications. At this meeting, the ZBA extensively discussed the progress of
`
`the Applications and alternative concepts to a one-hundred and ten (110) foot monopine
`
`antenna. Ultimately, Project alternatives were abandoned.
`
`69.
`
`The boards discussed that granting the Applications required two
`
`conditions, the first being that telecommunications facility be made available for public
`
`safety purposes and the second that tree preservation and screening be prioritized.
`
`70.
`
`The boards discussed the viability of potential alternative locations for the
`
`Project and the lack of a viable alternative to the Project being sited on the Premises.
`
`71.
`
`The ZBA Chairman then discussed in detailed architectural and historical
`
`basis for conserving the cultural and strict aesthetic characteristics surrounding the
`
`Premises including the Cold Spring Cemetery. He then concluded that deciding the fate
`
`of such wireless telecommunications facilities in the village of Nelsonville was best suited
`
`14
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 15 of 33
`
`
`
`to local boards rather than “a Federal District Court judge” dictating their future.22 The
`
`ZBA Chairman then voted in favor of the Providers’ special use permit application.
`
`72.
`
`ZBA Member Clements then followed by articulating her concerns to
`
`preserve viewsheds and visual impacts she believed exceeded the Code, and subsequently
`
`voting against the application. Two additional “no” votes followed and then a final vote
`
`in favor of the special use permit application.
`
`73.
`
`The ZBA denied the Providers’ special use permit application by a 3-2 vote.
`
`74. When prompted by Homeland’s attorney, the ZBA’s attorney then indicated
`
`that the related applications before the ZBA for relief from Village Law § 7-736 and for
`
`site plan approval were constructively denied.
`
`75. On June 12, 2018, the ZBA published notice of its decisions.
`
`C. The DJ Action.
`
`76. On June 29, 2018, the Providers commenced litigation against the Village
`
`alleging a host of federal and state claims. In particular, the Providers asserted the
`
`following ten causes of action against the Village:
`
`Count
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`Nature of relief sought
`ZBA determinations not in writing:
`47 U.S.C. § 332(c)(7)(B)(iii)
`Village’s actions violated FCC “Shot Clock Order”:
`47 U.S.C. § 332(c)(7)(B)(ii)
`Effective denial of applications:
`47 U.S.C. § 332(c)(7)(B)(iii)
`Effective prohibition:
`47 U.S.C. § 332(c)(7)(B)(i)(II)
`Prohibition of services, bar to entry,
`and unreasonable discrimination: 47 U.S.C. § 253
`Excessive fees
`
`
`22 Reference is made to Page 70, Lines 2-324 of the transcript of proceedings from a joint meeting of
`the ZBA and Planning Board held on May 30, 2018 and accompanying transcript that is available at:
`https://static.wixstatic.com/ugd/b667a0_176ee59251a9446d8e17f92ee1487ab8.pdf.
`
`15
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 16 of 33
`
`7
`8
`9
`
`10
`
`Judicial review (CPLR Article 78)
`Violation of Freedom of Information Law
`New York Constitutional claims alleging
`violation of 5th Amendment and Taking
`Violation of
`Open Meetings Law by illegal executive session
`
`
`
`
`
`77. On July 30, 2020, the Village appeared in the DJ Action by filing an answer
`
`with broad and qualified denials and raising stock affirmative defenses. The Village did
`
`not interpose any counterclaims.
`
`78. On January 29, 2020, the DJ Action was then settled by executing the
`
`Consent Order, which reduced the height of the monopine tower from 110 feet to 95 feet.23
`
`Additionally, the Consent Order outlined physical, environmental, and aesthetic
`
`parameters to mitigate the Project’s imposing nature, chief among them:
`
`(a)
`
`
`(b)
`
`
`
`surrounding the telecommunications facility on the premises with 8-
`foot-high cedar privacy fencing;
`
`implementing security and lighting systems designed to minimize or
`eliminate light pollution;
`
`(d)
`
`(c) minimizing or eliminating the Project’s noise pollution;
`
`reserving certain Project elements for the Building Inspector’s
`“reasonable approval” at the “building permit stage”24 such as
`monopine tower color, retaining wall design and appearance,
`retaining wall fencing, level spreader sizing and stone riprap at pipe
`outlets, and layout and geometry of the site access driveway;
`
`
`(e)
`
`
`(f)
`
`
`
`simulation of a pine tree to the greatest extent commercially
`reasonable for the monopine tower with high density branches in
`needles running from the top down to approximately 40 feet above
`finished grade consistent with attached drawings; and
`
`installation of vegetative screening and camouflaged netting and
`fencing.
`
`
`23 A true and correct copy of the Consent Order is attached as Exhibit “B”.
`24 Neither of these phrases are defined in the Consent Order.
`
`16
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 17 of 33
`
`
`
`(the “Consent Order Site Modifications”); (Consent Order, ¶ 2).
`
`
`79. Upon successfully completing the Consent Order Site Modifications, the
`
`Building Inspector was required to issue a certificate of compliance within fifteen (15)
`
`days. (Consent Order, ¶ 4).
`
`80.
`
`The Providers were also required to establish a $30,000 fund “to be held
`
`and distributed by the Village to nearby property owners to install landscaping” and the
`
`Providers “have no responsibility to maintain any such landscaping.” (Consent Order, ¶
`
`6). No further specificity was provided on how this parameter would be implemented.
`
`81. Oddly, the Consent Order also recites that “the Village makes no
`
`representation whatsoever whether the ability or authority to construct or maintain the
`
`proposed improvements in Exhibit A are within the rights Plaintiffs claim under the
`
`‘Existing Rockledge Road Access Easement’ (Liber 667, pg. 615) referenced therein.”25
`
`(Consent Order, ¶ 8)
`
`82.
`
`Perhaps the most controversial recitation is that “this Consent Order shall
`
`be deemed a Type II action under the New York State Environmental Quality Review
`
`Act, as it is the action of a court. 6 N.Y.C.R.R. § 617.5(c)(46).” (Consent Order, ¶ 13).
`
`
`
`D. Project changes and building permit review
`
`83.
`
`Since the ZBA denied the Providers’ special use permit application and
`
`constructively denied the balance of the sought-after relief nearly two years and six
`
`
`25 This reference is believed to harken back to significant neighbor opposition to the Applications
`addressing whether the Homeland, as successor-in-interest to the Premises, is actually possessed of a
`right, title, or interest to the right of way providing access to the otherwise landlocked Premises. This
`issue is concurrently being litigated by interested parties in State Court (i.e. Supreme Court of the
`State of New York, Putnam County).
`
`17
`
`
`
`Case 7:20-cv-08566 Document 1 Filed 10/14/20 Page 18 of 33
`
`
`
`months ago, the Project has undergone significant changes beyond the Consent Order
`
`Site Modifications.
`
`84.
`
`Shortly after adopting the Consent Order, the Providers filed an application
`
`for building permit for the Project with the Village’s Building Department.
`
`85.
`
`By a rejection letter, dated March 26, 2020, the Building Inspector cited
`
`substantial changes to the Project including:
`
`(a)
`
`(b)
`
`(c)
`
`Significantly less detailed plans than the original set supplied
`to the Court in the DJ Action (i.e. fewer drawings, details, and
`Code compliance tables);
`
`Realignment of the access drive to and on the Premises
`requiring potential removal of additional trees;
`
`Lack of compliance with NYS Fire Code including omission of
`the required “turnaround” and omission of emergency access
`key box;
`
`(d)
`
`Omission of two required parking spaces required by Code;
`
`(e)
`
`(f)
`
`(g)
`
`Drive profile reflecting gradient of 14.89% exceeding NYS
`Fire Code maximum of 10%;
`
`Omission of drawings reflecting nature, appearance, and
`positioning of communications tower pole; and
`
`Omission of retaining wall design reflecting appearance and
`structural composition.
`
`
`
`
`
`
`
`
`
`
`
`
`
`86.
`
`By letter, dated May 28, 2020, Homeland responded to the Building
`
`Inspector’s deficiency letter including access drive realignment:
`
`“the access drive has been realigned in consideration to minimizing
`impacts to the subject property both during and after completion of
`construction. The minor realignment of t



