Matter of Heinchon Dairy v. Village of Pawling Planning Board — Planning Board Cannot Reverse Its Own SEQRA Finding Without Explanation
The Appellate Division, Second Department affirms the annulment of a planning board’s denial of a mixed-use development application, holding that the board’s conclusory determinations—issued only eight months after it issued a SEQRA negative declaration supporting the project—were arbitrary and capricious because the board offered no factual findings or reasoning to explain the reversal.