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January 25, 2018 I Volume 12 I Issue 2 Zoning Bulletin <br />the court found that such an interpretation of the term "campsite," <br />including attendant recreational activities such as live music, was "con- <br />sistent with the record evidence." Here, the court determined that there <br />was "substantial evidence that the Property was used for recreational <br />activities and as a campsite prior to the adoption of the zoning <br />ordinance." Such evidence included: an affidavit of a former Frost <br />Ridge employee as to recreational activities on the Property in the <br />1960s, including live music; the testimony of several neighbors that <br />there was a "history of live music on the Property," including "live, <br />amplified bands played every summer weekend during the 1970s and <br />1980s," <br />See also: Toys R Us v. Silva, 89 N.Y.2d 411, 654 N.Y.S.2d 100, 676 <br />N.E.2d 862 (1996). <br />Variance —Church challenges <br />District of Columbia's grant of an <br />area variance to synagogue <br />Church contends three -prong test for area <br />variance is not met by synagogue <br />Citation: St. Mary's Episcopal Church v. District of Columbia Zon- <br />ing Commission, 2017 WL 6044242 (D. C. 2017) <br />DISTRICT OF COLUMBIA (12/7/17)—This case addressed the is- <br />sue of whether sufficient evidence supported a zoning commission's <br />findings that a synagogue was affected by "exceptional condition" and <br />"practical difficulties" such that an area variance was warranted. <br />The Background/Facts: Hillel at the George Washington University <br />("Hillel") is a synagogue that has the mission of providing for the needs <br />of Jewish students at George Washington University ("GW") in the <br />District of Columbia. In 2014, Hillel sought to demolish its existing <br />campus religious structure and to construct a new four-story building. <br />Hillel asserted that it needed such a new facility to meet institutional <br />and religious needs. Hillel's proposed new facility would contain: a <br />basement with a sanctuary, dining hall, and two kosher kitchens — <br />separating meat and dairy; a second floor dedicated to staff offices, a <br />student lounge, gathering space, a study area, and a library; and a third <br />and fourth floor to be leased to GW. <br />Hillel's existing campus structure (to be demolished and replaced) <br />was located on a narrow, rectangular corner lot with a total area of <br />4,575 square feet. The lot was located in a "high height and medium <br />8 © 201 8 Thomson Reuters <br />