HomeMy WebLinkAboutNV-09-0000 - Supplemental - 0059 Kirby Roadr
, r-40
southburlinto
PLANNING & ZONING
November 25, 2009
Richard Lucia
Lucia's Wrecker Service
59 Kirby Road
South Burlington, VT 05403
Re: Zoning Violation
Dear Mr. Lucia:
This is in response to your letter of October 7, 2009. 1 have been provided
information that you recently have towed vehicles to your home. Even though the
towed vehicle is attached to or on the tow truck, this is a new activity which
constitutes a zoning violation.
As a reminder, in your letter of 2/6/2002 you state that "at no time have I ever
towed vehicles to my home or deposited any vehicles on my home property" and
"I will NOT tow vehicles to my home..." The towing of vehicles to your home
constitutes an unlawful enlargement or extension of your nonconforming
business use, and therefore, constitutes a zoning violation.
Therefore, please cease the practice of towing vehicles to your home for any
reason. If I learn that you have towed a vehicle to your home, I will have no
choice but to issue you a Notice of Violation.
Sincerely,
aymond J. Belair
Administrative Officer
Cc: Amanda S.E. Lafferty, Esq.
575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburi.com
October 19'h, 2009
To whom it may concern:
In response to the letter written from Dick Lucia Senior, dated October 7th, 2009. He said
nothing has changed in the last 35 years. This information is incorrect. His place of
business has moved several times. The last place of business was at the end of Airport
Parkway. The government purchased the land and then moved his 24/7 towing business
to his home. Mr. Lucia states there is one wrecker a 2007 freightliner. However, there has
been different wreckers, but only one at a time over the past years. There has been a
number of wreckers in the past.
1. Was a F.250 or an F350 Tow truck (like a Pick up Truck)
2. He had a Gas Engine Flat Bed
3. Then there was a bigger Diesel Engine Flatbed
4. A new 2007 Freight Liner 175 Horse Powered to a 350 Horse Powered Diesel Engine
Flatbed
Mr. Lucia states in his letter dated February 6, 2002 that he has never towed a vehicle to
his house. I have seen him tow vehicles to his house over the past several years through
he has left the car attached to his tow truck over night he has not deposited it on his
property. Mr. Lucia said there has been no complaints in regards to his truck/business this
is not true. Tom Juffrey a neighbor who lived across the street complained for years as
well as myself.
Every time he buys a new tow -truck he upgrades, and has hired help. This is expanding a
business. What about residents who will buy the new houses across the street from Mr.
Lucia, where Tom Juf Tay used to live? How long will it be before they complain about
the noise of the truck engine, and the "beep beep" when he backs up on throughout the
night? Blowing the air horn for no reason and letting the truck idle for long periods of
time through out the day as well. He is in violation of the Public Nuisance Ordinance
section (3) and (4). Which gives me the right to peaceful coexist in my home and lets me
sleep nights. To resolve this issue just have Mr. Lucia park his trucks some other place
than 59 Kirby Road.
Sincerely,
Post-i Fax Noe 7671
#9es�To
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7DateV
Co./Dept.
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Fax #
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WARD & BABB
ATTORNEYS -AT -LAW
A Trade Name for a Professional Corporation
EUGENE J. WARD, III
GUY L. BABB
ALLAN W. RUGGLES (VT, NY, CA)
WILLIAM B. TOWLE (VT, NM)
]AN M. DEGALAN (OH Only)
REGISTERED LAW CLERK:
TRACY E. ERICKSON
November 12, 2009
Ray Belair
City of South Burlington Zoning Administrator
575 Dorset Street
So. Burlington, VT 05403
Re: Lucia's Wrecker Service operated at 59 Kirby Rd., So. Burlington
Dear Mr. Belair:
CLOSING COORDINATOR:
DEBRA DENNY
LEGAL ASSISTANTS:
JANA M. MCQUEENEY
TIFFANY R. PEZZIMENTI
PARALEGALS:
JO RICHER
CATHERINE M. COLT
I am writing in response to your letter to me dated September 30, 2009 regarding Lucia's
Wrecker Service and the frustration and distress the Menards go through daily by having to live
with a 350 horsepower diesel flatbed wrecker parked 10 feet from their bedroom window which
is used in connection with Mr. Lucia's 24 hour seven day per week wrecker service.
The Menards also provided you with a letter dated October 19, 2009 which addresses certain
inaccuracies and misstatements in Mr. Lucia's letter to you dated February 6, 2002 upon which
you based your decision that no home occupation permit was needed. Their letter also conveys
their frustration at suffering through years of sleepless nights so that Mr. Lucia, or his employee,
not be inconvenienced by having to drive to another location to pick up the wrecker to answer
calls. The Menards are not asking that Mr. Lucia move his business, just his truck.
With respect to some specific points, in his 2002 letter Mr. Lucia states that he has received no
complaints from his neighbors about noise and the use of his driveway. However, as stated in the
Menards letter, the Menards, as well as their former neighbor across the street, Tom Juffrey, have
been complaining for years about the noise from the wrecker. In fact, in Mr. Lucia's most recent
letter to you dated October 7, 2009, he now admits that "Mr. Menard has had an issue with this
since 1 moved into this residence 32 years ago". Would your decision have been the same had
you been informed of the correct facts in 2002?
Also, contrary to Mr. Lucia's 2002 letter, in the past several years he has towed vehicles to his
house. (See Menard letter). This constitutes an expanded or enlargement of use. Previously,
Mr. Lucia operated his wrecker service at independent locations in So. Burlington and could
deposit vehicles at those locations. Since he no longer has an independent location to drop off
vehicles he apparently tows vehicles to his home at 59 Kirby Rd when necessary. This is
3068 WILLISTON ROAD, SOUTH BURLINGTON, VERMONT 05403-6044 O Telephone (802) 863-0307 O Facsimile (802) 863-4587
30 MAPLEVILLE DEPOT ROAD, ST. ALBANS, VERMONT 05478 O Telephone (802) 524-5718 O Facsimile (802) 524-5718
REPLY TO: SOUTH BURLINGTON OFFICE
contrary to his statement in 2002 that "I will not tow vehicles to my home" and again is an
expanded use. He also has an "on call" guy. On call being 24/7. This is an expansion of use
since he now has an employee assisting him with his 24 hour emergency towing service.
Finally, as pointed out in my clients' letter, the truck has gone from a pick up truck with a hook
on the back to a 350 horsepower diesel flatbed with the business advertising in the yellow pages
as a 24 hour wrecker service. This constitutes an expanded use and arguably, the size of the
truck coupled with the fact that he tows vehicles to his home, now qualifies his residence as a
motor freight terminal under Article 2 of the Zoning Regs.
Notwithstanding the above, as pointed out in the Menards' letter, the use of the truck constitutes
a public nuisance according to the City Noise Ordinance. Further, although your decision may be
that the wrecker service is a pre-existing non conforming use of the property, 1 believe that the
superior court would consider that issue to be a non factor in granting the Menards an injunction
preventing Mr. Lucia from parking his truck in any location which disturbs the Menards' right to
peaceful enjoyment of their property, especially since Mr. Lucia doesn't need to park the truck on
his premises in order to operate his business. In weighing the equities, I believe the court would
easily find in the Menards' favor. However, I was hoping not to go that route, since the solution
seems equally within the jurisdiction of the City of South Burlington, that is, require Mr. Lucia to
move his truck to a location where it doesn't disturb the Menards.
I look forward to your response.
i
7Sin
]an W. Ruggles,
cc. The Menards
Sincerely,
Allan W. Ruggles
3069 WILLISTON ROAD, SOUTH BURLINGTON, VERMONT 05403-6044 O Telephone (802) 863-0307 O Facsimile (802) 863-4587
30 MAPLEVILLE DEPOT ROAD, ST. ALBANS, VERMONT 05478 O Telephone (802) 524-5718 O Facsimile (802) 524-5718
REPLY TO: SOUTH BURLINGTON OFFICE
February 6, 2002 ))
CITY OF SOUTH BURLIN� l ON
575 Dorest Street
South Burlington, VT_ 05403
Dear Mr. Balier,
In regards to the letter I received on January 25't, let me give you a brief history of my business.
In 1964, 1 started as a mechanic working in my father's Texaco service station on Williston Road
in South Burlington. In 1972, 1 took over my father's business and in 1973 we changed the name
to "Lucia's Chevron". In that same year, I bought a tow truck and 1 parked it in my driveway at
1412 Airport Drive at the end of each day. In 1978, we again changed our affiliate and our name
to "Lucia's Sunoco", and it was'this year that I moved my family to our new home at 59 Kirby
Drive in South Burlington_ In the years to follow, we've closed the service station and I opted to
work as a self-employed mechanic renting space from Williston Road Citgo, Avis Rent -a -Car, and
a garage rental on Airport Parkway. I continued to use my tow truck as a wrecker service during
those years_
Although for the past 28 years I have operated a business as a mechanicitowing service in
various areas of South Burlington, my towing service has always been "Lucia's Wrecker Service"
and I have been widely used amoung the residents of the city and surrounding areas. From my
business' locations on Williston Road & Airport Parkway my towing service has always been
mobile. During these many years, I parked my tow truck in the driveway of my home about 80%
of the time when I was not at work. The South Burlington Police and Vermont State Police called
my home on a regular basis requesting my services for accidents and abandoned vehicles during
off business hours. However, at no time have I ever towed vehicles to my home or deposited any
vehicles on my home property_ Customers never came to my house to pay towing or mechanic
bills.
During the 22 years at 59 Kirby Road, I've received no complaints of noise or unsightly traffic
from our neighbors about the use of my nve�wayior`due-Fo iiie o1f6usmess— hours my low rfi uc
has come and gone for service requests. We are good friends with the people aroundus, an(
within reason we intend to keep it that way,
In the Fall of this past year, I retired my business as a mechanic hoping to continue my towing
service as my sole source of income. My tow truck would continue to be parked in my driveway
and I would continue to receive calls at home or on my cellphone for tow truck requests. I will
NOT tow vehicles to my_home or deposit them on my home property, and arrangements for
payment with customers would continue to be made on the phone or at the location where I
would tow their vehicles.
615'
I'll be 6O years old this year, and given the circumstances of my past, I would hope you'd
understand the reasons why I've parked my tow truck at home. I look forward to your decision.
Please feel free to call me at 864-1853 if you require more information or additional explanations.
Thank You
01
Richard Lucia
Lucia's Wrecker Service
1
OCT-9-2009 11:04A FROPI:CITY OF SOUTH BURLIN 8028464101 TO:96602552 P.1
October 7, 2009
i^tichard J. Lucia S(.
59 Kirby Road
South Burlington, VT 05403
-3ouin uunington Planning & zoning
Attn: Raymond J. Belair
575 Dorset Street
swn turlington, v 1054u3
Dear Mr. Belair,
1 am responding to your letter that was sent to me on October 2, 2009. In reference to a complaint
indicating that I have extended my wrecker business, nothing has changed in the last 35 years. Here
are the tuii details of my towing business that you requested:
A There :s one wrecker a 2007 Frelghtliner
8, Hours of operation the same as the past ``on can'
C. I do have an "on call guy"
D. I have an office in my home that I use for billing, faxing etc.
Like 1 said nothing has changed in the past 35 years and it is time to put this complaint to rest. Mr.
Menard has had an issue with this since i moved in to this residence 32 years ago. I keep to myself
and i respect my neighbors. 1 would greatly appreciate It if you could have someone come over and
personalty see my residence and take a took at my tow truck and than take a look Mr. Menards
residence with his salvage yard located In his backyard. The bottom tine is I just want to be able to do
what i have done for the past 35 years.
it you new anyining Turmer trom me please teal tree to contact me.
Sincerely,
hard J. Lucia Sr.
Post -IV Fax Note 7671
Dale O c
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OF SOUTH BURLINGTON
i
PUBLIC NUISANCE ORDINANCE
The Council of the City of South Burlington hereby ordains:
Section 1. Authority.
This ordinance is enacted pursuant to the authority granted to the City to promote
the public health, safety, welfare, and convenience contained in 24 V.S:A. §2291, and
§104 of the South Burlington City Charter. This ordinance shall be a civil ordinance
within the meaning of 24 V.S.A. Chapter 59.
Section 2. fne 1 Definig2us As used in this ordinance:
"City" shall mean the City of South Burlington and/or its duly authorized agents
or employees.
"Person" shall mean any natural person, corporation, municipality, the state of
Vermont, or any department, agency or subdivision of the state, and any partnership,
unincorporated association or other legal entity.
"Public place" shall mean a place where a governmental entity has title to or
which the public or a substantial group of persons has access, including but not limited to
any street, highway, parking lot, plaza, transportation structure, facility or vehicle, school,
place of amusement, park, playground or sidewalk or to the doorways and entrances to
buildings or dwellings, or grounds enclosing them thereupon
Section 3. Purpose.
It is the purpose of this ordinance to preserve the public health, safety, and
welfare by prohibiting. general nuisance behavior which is unreasonable or unsuitable for
a particular time and place, and which, consequently, is detrimental to the peace and good
order of the community. It is the goal of this ordinance to allow all persons of South
Burlington to peacefully coexist in a manner which is mutually respectful of the interests
and rights of each other. Typically, nuisance behavior disrupts the pubkc peace and
affects the quality of life within the community.
Section 4. Excessive Noise.
A. Purpose. The purpose of this section is to preserve the public health, safety, and
welfare by prohibiting excessive and disturbing noise and to prevent noise which is
prolonged or unsuitable for the time and place and which is detrimental to the peace
and good order of the community. It is the goal of this section to allow all persons of
our city to peacefully coexist in a manner which is mutually respectful of the interests
and rights of others.
OCT-9-20 9 11:04A FROM: CITY OF ._, IIJTH EURLIN Oa23+--.4101 TU:9F,r,02552 P. 1
October 7, 2009
Richard J. Lucia Sr.
59 Kirby Road
South Burlington, VT 05403
South Burlington Planning $ Zoning
Attn: Raymond J. Belair
575 Dorset Street
South Burlington, VT 05403
Dear Mr. Belair,
I am responding to your letter that was sent to me on October 2, 2009_ In reference to a complaint
indicating that I have extended my wrecker business, nothing has changed in the last 35 years. Hero
are the full details of my towing business that you requested:
A. There is one wrecker a 2007 Freightliner
B, Hours of operation the same as the past `on call"
C. I do have an "on call guy"
U. I have an office in my home that I use for billing, faxing etc.
Like I said nothing has changed in the past 35 years and it is time to put this complaint to rest. Mr.
Menard has had an issue with this since I moved In to this residence 32 years ago. I keep to myself
and I respect my neighbors. I would greatly appreciate It if you could have someone come over and
personally see my residence and take a look at my tow truck and than take a look Mr. Menards
residence with his salvage yard located in his backyard. The bottom line is I just want to be able to do
what I have done for the past 35 years.
If you need anything further from me please feel free to contact me.
Sincerely,
Richard J. Lucia Sr,
Post-W Fax Note 7671
D81e o
pa age
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southburlington
CY
PLANNING & ZONING
October 2, 2009
Mr. Richard Lucia
59 Kirby Road
South Burlington, VT 05403
Re: Towing Business
Dear Mr. Lucia:
It has come to my attention that you may have extended or enlarged your
nonconforming towing business use at 59 Kirby Road. Please be advised that
the extension or enlargement of a nonconforming use may not be permitted
under the City of South Burlington Land Development Regulations.
Please put in writing to me a detailed description of the towing business,
including a description of all non-residential activities, the equipment or vehicles
that you use and the dates that you added the equipment or vehicles to the
business, the hours of operation, how large an area in your home or on your
property that you use for the business activities, the number of employees, and
any changes to your business activities and operations since February 2002.
If you have questions, please feel free to contact me.
Sincerely,
R,
Administrative Officer
575 Dorset Street South Burlington, VT 05403 tel 802.846,4106 fax 802.846.4101 www.sburl.com
I
T
FIRA,
southburlington
PLANNING & ZONING
September 30, 2009
Allan W. Ruggles, Esq.
Ward and Babb
3069 Williston Road
South Burlington, VT 05403
Re: Lucia's Wrecker Service — 59 Kirby Road
Dear Mr. Ruggles:
Thank you for your letter of Sept 23, 2009. Based on a letter from Mr. Lucia
describing the history of his towing business, I issued a written determination in
February 2002 that the use of his residence at 59 Kirby Road for his wrecker
service was a nonconforming use. You state in your letter dated September 22,
2009, that you dispute this determination, but you do not provide any basis for
this statement. Unless it is demonstrated that any of the material facts in Mr.
Lucia's letter, dated February 6, 2002, are incorrect or otherwise misrepresented,
or that Mr. Lucia has enlarged or extended the nonconforming use without
needed approvals, I am not aware of any provision in the Land Development
Regulations that requires that Mr. Lucia obtain a permit.
1
Administrative Officer
575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburl.com
1
E
EUGENE J. WARD, III
GUY L. BABB
ALLAN W. RUGGLES (VT, NY, CA)
WILLIAM B. TOWLE (VT, NM)
IAN M. DEGALAN (OH Only)
REGISTERED LAW CLERK:
TRACY E. ERICKSON
September 22, 2009
WARD & BABB
ATTORNEYS -AT -LAW
A Trade Name for a Professional Corporation
Ray Belair
City of South Burlington Zoning Administrator
575 Dorset Street
So. Burlington, VT 05403
Re: Lucia's Wrecker Service operated at 59 Kirby Rd., So. Burlington
Dear Mr. Belair:
CLOSING COORDINATOR:
DEBRA DENNY
LEGAL ASSISTANTS:
JANA M. MCQUEENEY
TIFFANY R. PEZZIMENTI
PARALEGALS:
JO RICHER
CATHERINE M. COLT
I have been retained by Paul and Linda Menard, neighbors of Mr. Lucia's at 57 Kirby Rd. in So.
Burlington, in order to notify you and complain of the public nuisance noise issues resulting from
Mr. Lucia's operation of a 24 hour wrecker service from his home at 59 Kirby Rd. which appears
to be an unauthorized home occupation.
In connection with his business, Mr. Lucia parks his flatbed wrecker in his driveway in this
residential neighborhood where the houses are situated fairly close together. In fact, the
Menard's bedroom windows are located about ten feet from where Mr. Lucia's flatbed is parked.
As such, they are constantly being disturbed and awoken at all hours of the night by the sound of
the ignition and idling of the heavy duty truck engine. Additionally, the noxious exhaust fumes
from the truck permeate into their bedroom and lingers there long after the truck leaves the
driveway.
These are not occasional disturbances. Mr. Lucia advertises his business in the yellow pages as a
24 hour emergency towing service and based upon the number of times the Menards are awoken
in the middle of the night, he receives many calls.
It is my clients' understanding that formerly Mr. Lucia's towing service was ancillary to other
businesses he operated at different locations in South Burlington and that he would throughout
the years park his tow truck at his home after business hours and would respond to service calls
from the State Police or So Burlington Police. However, this is a far cry from operating a 24
hour flatbed wrecker service from his home driveway without a permit to operate a "home
business". I also dispute that it is a pre existing use.
Further, the engine noise and exhaust from the wrecker violates A.3, A.4 and A.5 of the City of
3069 WILLISTON ROAD, SOUTH BURLINGTON, VERMONT 05403-6044 4 Telephone (802) 863-0307 O Facsimile (802) 863-4587
30 MAPLEVILLE DEPOT ROAD, ST. ALBANS, VERMONT 05478 O Telephone (802) 524-5718 O Facsimile (802) 524-5718
REPLY TO: SOUTH BURLINGTON OFFICE
E
South Burlington performance standards. The noise from the engine also violates Section 4
paragraph d. of the Public Nuisance Ordinance and other provisions of the ordinance.
My clients have complained to Mr. Lucia and asked him on many occasions to move the truck
but to no avail. My clients do not wish to prevent Mr. Lucia from earning a living. However, he
doesn't need to park his flatbed tow truck in his driveway, which again is about ten feet from my
clients bedroom window, or in front of his house in order to conduct his business. It is simply
more convenient for him to do so. On the hand, my client's cannot pickup and move their home
to get away from the constant early morning wake up calls and obnoxious exhaust from Mr.
Lucia's heavy duty flatbed which is adversely effecting their health and welfare.
I will be contacting you to follow up on this letter and to discuss resolution of these issues.
Sinc
lIan W R gles
cc: Paul Menard
3069 WILLISTON ROAD, SOUTH BURLINGTON, VERMONT 05403-6044 O Telephone (802) 863-0307 O Facsimile (802) 863-4587
30 MAPLEVILLE DEPOT ROAD, ST. ALBANS, VERMONT 05478 O Telephone (802) 524-5718 O Facsimile (802) 524-5718
REPLY TO: SOUTH BURLINGTON OFFICE
DEPARTMENT OF PLANNING & ZONING
575 DORSET STREET
SOUTH BURLINGTON, VERMONT 05403
(802) 846-4106
FAX (802) 846-4101
January z5, zooz
i.: . -chard i.ucia
59 Kirby Road
South Burlington, Vermont 05403
Re: Home Occupation
Bear Mr. Lucia:
I;: has co me .o my attention that you have begun. :perating a Ytoni-, bzt_ xt :ss.
consisting of a towing service from your home at 59 Kirby Read. 'Pleas* `,e advised
th.;a to operate a:-iy home business, you must obtain a Cev if :-a€e of'
Occupancy/Compliance (C.O.).
Please put in writing to me a detailed description of the business and what activity
will take place in the home, how large an area in the home will be used, number of
employees, whether the towing vehicle will be parked on the property, etc.
Once I have reviewed the description of your business, I will make a determination of
whether your home business qualifies as a Home Occupation under the South
Burlington Zoning Regulations. If it qualifies, I will issue you a C.O. upon payment
of a $io fee.
If you have questions, please feel free to contact me.
Sincerely;
f-
�mnJ
aydd J.
«tB///elair
Administrative Officer
Td
February 6, 2002
CITY OF SOUTH BURLINGTON
575 Dorest Street
South Burlington, VT. 05403
Dear Mr. Balier,
In regards to the letter I received on January 25tt, let me give you a brief history of my business.
!n 1994, 1 started as a mechanic working in my father's Texaco ser pica station on Williston Road
in South Burlington. In 1972, 1 took over my fathers business and in 1973 we changed the name
to "Lucia's Chevron". In that same year, I bought a tow truck and I parked it in my driveway at
1412 Airport Drive at the end of each day. In 1978, we again changed our affiliate and our name
to "'_ cia s Sunoco", and it was thr;; year that I r-,.ved my fai lily to our new home at 59 Kirby
Drive ;r, '')c`h i;urlingto:r. In tiia years o fol;ow, we've closed the service station and I opted ;o
work as self-employed mechanic: renting spJ ,ce m.—r Willi:?i:,i Road Citgo, Avis Rent -a -Car, and
s garage rer: ai on Airport Parkway. I continu:;d to use my tow truck as rreckcr service during
thos ye�lrs.
Although for the past 28 years I have operated a business as a mechanic/towing service in
,rir:.: are-f?s of South Burlington, my towing service has always been "Lucia's Wrecker Service"
an,? : ! av4- bec.n widely used arnoung the residents of the city and surrounding areas. From- rr).,
iJL� louFtons on `_Ivilliston Road & Airport Parkway my ta,viri service has always been
mobile. During thebe many years, I parked my tow truck in ill driveway of my home about 80%
u tiro tint. when i was riot at work. The South Burlington Pc;;, ano Vermont State Police called
my h:Jn-:e on a regular basis requesting my services for accider:'_s and a:.,:andoned vehicle, during
of tn.iC n hculs. ;:--Plever, at no time have ` r: ar towel vYrrcle., to -ny home or der(-s•*ed ar-y
iroperty. Customers never, came tc my House to p_iy 'owing or
bill
During the 22 years at 59 Kirby Road, I've received no complaints of noise or unsightly traffic
from our neighbors about the use of my driveway or due to the off business hours my tow truck
has come and gone for service requests. We are good friends with the people around us, and
within reason we intend to keep it that way.
In the Fall of this past year, I retired my business as a mechanic hoping to continue my towing
service as my sole source of income. My tow truck would continue to be parked in my driveway
and I would continue to receive calls at home or on my cellphone for tow truck requests. I will
NOT tow vehicles to my home or deposit them on my home property, and arrangements for
payment with customers would continue to be made on the phone or at the location where I
would tow their vehicles.
G�5
I'll be Q6 years old this year, and given the circumstances of my past, I would hope you'd
understand the reasons why I've parked my tow truck at home. I look forward to your decision.
Please feel free to call me at 864-1853 if you require more information or additional explanations.
Thank You,
Richard Lucia
Lucia's Wrecker Service
OUCH gUG LIMGTpa
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1
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aNf04 row; �pw0N
CITY OF SOUTH BURLINGTO_
F(-_ )Tuaty 12, 2002
DEPARTMENT OF PLANNING & ZONING
575 DORSET STREET
SOUTH BURLINGTON, VERMONT 05403
(802) 846-4106
FAX (802) 846-4101
riai. Lucia
eck:er Service
S9 i�irby i<oad
Soi3f-:, B,Ar"-";:gton, Vermont 03403
Re:
Dear N".r: Luc..ia:
Thank you for your letter of February 6, 2002. Based on your history of using your
residetxc,_ for the wrecker service, I conclude that your use is pre-existing and does not
require approval. If you discontinue this use for more than six (6) months, you will
lose the right to continue the use.
Thank you for your prompt response.
Sincere l
Raymond J. Belair
Administrative Officer
Td