Full opinion text
MEMORANDUM OPINION SMALKIN, District Judge. This action is before the Court on the defendants’ motion for summary judgment and the plaintiffs cross-motion for partial summary judgment with respect to liability. Neither side requested a jury trial. The issues have been fully briefed, and no oral hearing is necessary. Local Rule 105.6. Factual Background The plaintiff, Bryant Woods Inn, Inc., is a corporation that operates two group homes in Columbia, Maryland. The homes provide housing and other services in a non-institutional setting to elderly people with disabilities, most of whom suffer from Alzheimer’s disease or related forms of dementia. The homes are owned by Richard Colandrea, who is the sole shareholder and president of Bryant Woods Inn, Inc. The corporation pays rent to Mr. Colandrea for the use of his properties as group homes. The home at issue in this litigation, Bryant Woods Inn I, is located at 10461 Waterfowl Terrace and has been owned by the Colandrea family for over twenty years. In 1989, the Colandreas began using Bryant Woods Inn I as a group home for up to eight elderly people with disabilities. Between 1989 and 1994, the home operated as Group Senior Assisted Housing under a program supervised by Maryland’s Office on Aging. In 1994, Bryant Woods Inn I was licensed by the Maryland Department of Health and Mental Hygiene as a “domiciliary care” home. In 1992, Mr. Colandrea asked both the Office of Aging and the Department of Health and Mental Hygiene to approve the home as a home for up to fifteen residents. Both state agencies denied his request, because Mr. Colandrea had not secured zoning authority from Howard County to house more than eight elderly or disabled people. Section 110.C.4 of the Howard County Zoning Regulations permits the following uses as a matter of right, as uses accessory to a principal residential use: “The housing by a resident family of: a. Not more than four non-transient roomers or boarders; or b. Not more than eight mentally and/or physically disabled persons or persons 62 years of age or older, provided the use is registered, licensed or certified by the State of Maryland; or c. A combination of a or b above, provided that the total number of persons housed in addition to the resident family does not exceed eight.” Consequently, to the extent that the Colan-dreas were a “resident family” at the Waterfowl property, they did not require special zoning approval to provide homes for up to eight elderly disabled people. Richard Co-landrea’s plans to house fifteen people at Bryant Woods Inn I in addition to family members and staff, however, could hot be realized without zoning authority from Howard County. Columbia is a New Town Zoning District under the Howard County Zoning Regulations, and is subject to a different zoning scheme from the remainder of Howard County. H.C.Z.R. § 125.A.1. In particular, the special exception procedure which ordinarily permits Howard County property owners to apply for changes in the zoning status of their properties is not available to residents of Columbia. Before October, 1993, no effective mechanism existed whereby individual property owners could request changes in the zoning regulations applicable to their properties. In 1993, however, Howard County provided that Columbia residents could request exceptions from the zoning regulations by applying for an amendment to their neighborhood’s Final Development Plan (FDP). H.C.Z.R. § 125.D.2. Section 125.-D.2.c. of the Howard County Zoning Regulations vests the authority to approve FDP amendments in the Howard County Planning Board and sets forth the criteria governing the Planning Board’s decisions: “The Planning Board shall approve, approve with modifications or deny the proposed amendments to the Final Development Plan, stating the reasons for its action. The Planning Board shall approve the request only if it finds that: (1) The use is consistent with the land use designation of the property ... and compatible with existing or proposed development in the vicinity. (2) The use will not adversely affect vicinal properties.” As soon as the new provisions took effect, Richard Colandrea prepared and submitted to the Howard County Planning Board a petition for an FDP amendment. Colandrea described his proposed amendment as follows: “Allow for the housing of disabled persons provided the use is licensed or certified by the state of Maryland. The housing of disabled persons shall not be considered a business use; shall not change the use classification of the property or the structure from that of residential and shall require no other community association approval.” (Colandrea’s December 6, 1993 application for a plan amendment, Exh. 4 to Dfts.’ Mot. Summ.J.) Because the State of Maryland would allow Colandrea to provide homes for fifteen elderly people with disabilities if zoning approval were granted, the effect of Co-landrea’s petition would be to increase the number of residents of Bryant Woods Inn I to 15, excluding members of the Colandrea family. Mr. Colandrea’s application for an FDP amendment was one of the first received by the Planning Board pursuant to the new regulations. Under the new procedure, the Howard County Department of Planning and Zoning was responsible for processing Colan-drea’s petition and for making an initial recommendation to the Planning Board. It is undisputed that when the Department of Planning and Zoning received the Colandrea petition it wrote to Mr. Colandrea, explaining that his proposed amendment to provide for the housing of disabled persons was not defined in the Howard County Regulations, and did not “clearly define your proposed use.” (January 12,1994 letter from Gina Tirinnanzi to Richard Colandrea, Dfts.’ Exh. 5 to Mot. Summ.J.) In addition, the Department advised Mr. Colandrea that it lacked authority to waive local covenant requirements, and that Mr. Colandrea’s petition should therefore “contain language for land use only.” (Ibid.) Finally, the Department asked Mr. Colandrea to supply additional information about the number of employees, parking requirements and availability, and lot coverage. (Ibid.) Recognizing that he had insufficient information to prepare a comprehensive staff report, Richard Blood, the staff member assigned to handle the Colandrea petition, asked Joseph Rutter, the Director of the DPZ, whether or not to go ahead with the hearing as scheduled. (Blood Depo. at 262-263, Pltf.’s Exh. 43 to Mot.Summ. J.). Mean-. while, Mr. Colandrea’s neighbors had requested a postponement of the hearing on the basis that the sign on the property giving notice of the hearing was not sufficiently conspicuous. (Rutter Depo. at 365, Dfts.’ Exh. 22 to Opp.) Mr. Rutter took the position that “if the residents find the sign enough to know that it’s in their opinion not properly posted, well, they found it, that’s the intent of the sign, to make notification.” (Ibid.) Mr. Rutter therefore determined that Mr. Colandrea “should have his opportunity to go to the Planning Board and make his case, and not have delays at the request of the residents because of a technicality in posting.” (Id. at 366). Mr. Colandrea did not ask for a postponement of the hearing. Richard Blood explained at his deposition that Mr. Rutter ordered him to go ahead and “notify the residents [that the hearing] was going to be the 17th and do the best I could on the staff report and if it had to be negative for lack of information, that is how it would have to be.” (Blood Depo. at 264r-265, Exh. 43 to Pltf.’s Mot.Summ.J.). Blood accordingly prepared the staff report, recommending to the Board that Colan-drea’s petition be denied. On February 10, 1994, when the staff report had been finalized and approved, the Department received Mr. Colandrea’s response to its requests for further information. (Pltf.’s Exh. 53 to Mot. Summ.J.). Mr. Colandrea proposed that his property should “be used for a Group Care Facility,” described in detail the number of employees and prospective residents, and set forth the parking needs of the expanded use. Blood did not revise the packets of information which had been prepared for review by the members of the Planning Board to take account of the new submission. The public hearing before the Planning Board took place on February 17, 1994. As was customary, the proceedings began with a presentation by Richard Blood, the member of the Howard County Department of Planning and Zoning who had been responsible for processing the Colandrea petition. Blood stated that because the Colandrea petition was so indefinite, the Department had relied on regulations and other land use criteria applicable to Group Care Facilities under the Howard County Zoning Regulations. Using the Group Care Facility criteria, Blood concluded that Bryant Woods Inn I had inadequate parking, and that there was a risk that off-street loading and storage areas might be incompatible with the residential character of the neighborhood. Blood also explained to the Board that Mr. Colandrea’s amendments to his original petition had been received after the staff report had been finalized. The Board heard argument from Mr. Co-landrea’s attorney and testimony from a number of witnesses. Mr. Colandrea’s attorney specified the proposed use of the property, explaining that the land use impact of the group home would be minimal. In addition, Mr. Colandrea’s attorney advised the Board that the Fair Housing Act might require the County to “accommodate some of [its] zoning regulations in order to guarantee housing opportunities for the disabled.” (Hearing Transcript at 13, Dfts.’ Exh. 2 to Mot. Summ.J.). Mr. Colandrea testified in favor of the amendment, as did Edward Leavy, an owner of three group homes in Montgomery County. Diane Perry of Howard County’s Office on Aging and Stephanie Lyons of the County Alzheimer’s Association answered questions about the land use impact of assisted living facilities and about the needs of individuals suffering from Alzheimer’s disease. A neighbor and an attorney testified in opposition to the amendment on behalf of the Waterfowl Neighborhood Association, the Columbia Association and the Wilde Lake Community Association, arguing that the Planning Board lacked the power to grant that portion of the original Colandrea petition which asked that the proposed use be exempted from local covenants. Another neighbor, Lawrence Schoen, testified in opposition to the petition on his own behalf, expressing concerns about parking, traffic and construction. Mr. Schoen stated that “there isn’t really an interference from the people living in the house, it’s these ancillary activities like parking and construction that are creating the problem.” (Id. at 48). At the conclusion of the hearing, the Board voted unanimously to deny the petition. In a written Decision and Order issued on March 31, 1994, the Board stated that “[t]he open-ended nature of the Petitioner’s requested amendment makes it impossible for this Board to conclude that the criteria of Section 125.D.2.C. of the Zoning Regulations have been met.” (March 31, 1994 Decision and Order in Planning Board Case No. 293 at 4, Exh. 11 to Dfts.’ Mot.Summ.J.) The Board observed that the amendment Mr. Colandrea had submitted specifically limited neither the number of residents who might live in Bryant Woods Inn I nor the level of their need for assistance with daily living. With respect to parking, the Board made the following findings: “Petitioner proposes a parking plan which accommodates between four and six vehicles on the site. However, the plan does not allow for easy circulation of the accommodated vehicles and would likely result in fewer cars actually using on-site parking, thus forcing overflow parking onto the street. This would have a particularly adverse effect on vicinal properties since the subject property, although somewhat rectangular, is ‘pie-shaped’ with a particularly narrow area of road frontage available for on-street parking. Based on the personal observation of one of the Board members during two site visits and the testimony of Petitioner’s neighbors, even the existing use generates parking congestion on the street. This situation would be exacerbated by Petitioner’s proposed expansion.” (Id. at 4-5). The Board determined that “the proposed use is a group care facility as that term is defined in Section 125.A.7.b. of the Zoning Regulations,” and that the parking criteria applicable to group care facilities should therefore be met. Using these criteria, the Board found Bryant Woods Inn I’s parking facilities to be inadequate. (Id. at 5.) The Board held that its denial of the Co-landrea petition did not “limit housing opportunities for the disabled in contravention of the Fair Housing Act.” (March 31, 1994 Decision and Order in Planning Board Case No. 293 at 6, Exh. 11 to Dfts.’ Mot.Summ.J.) The Board pointed out that § 125.A.7.C. and § 110.C.4 of Howard County’s Zoning Regulations permitted Mr. Colandrea to house eight elderly people with disabilities, although only four boarders per home are ordinarily permitted. In connection with Mr. Colandrea’s desire to increase the number of residents from eight to fifteen, the Board stated that “eight residents is a reasonable break point for requiring additional scrutiny of the specific impacts which Petitioner’s proposed intensification of a home occupation or business use of residential property will have on vicinal properties.” The Board stated that even if the denial of the petition had a disparate impact upon disabled people, it was nonetheless consistent with the Fair Housing Act because it was based on “the Board’s non-diseriminatory, legitimate interest in prohibiting an over-intensification of use of residential property which will exacerbate an already congested traffic and parking situation on Petitioner’s street and/or require on-site parking that would be out of character and scale with the residential community.” (Id. at 7.) Finally, the Board observed that community members had no objection to the existing use of Bryant Woods Inn I for elderly residents, and that the community’s concerns “centered around parking and traffic congestion and Petitioner’s operation of an in-home business in violation of the community association covenants, as distinct from unsubstantiated fears about having disabled neighbors.” (Id. at 8.) Mr. Colandrea filed a Motion for Reconsideration, both suggesting alternative language for his amendment which might alleviate the Board’s concerns with respect to specificity, and arguing that the Board’s determinations with respect to parking were irrational. In addition, Mr. Colandrea offered to undertake that no resident would park a car at Bryant Woods Inn I. The Planning Board considered the motion at a meeting held on June 23, 1994 and voted to deny it. The Board issued its formal denial in a written opinion of August 18, 1994, stating that “Petitioner’s proposal to eliminate resident parking, while removing the “worst case scenario’ for parking, will still not significantly alleviate the increase in parking demand that his proposed expansion will place on an already congested site.” (Board’s August 18, 1994 Order in Planning Board Case No. 293 at 2, Pltf.’s Exh. 67 to Mot.Summ.J.) Mr. Colandrea did not appeal to the Howard County Board of Appeals. Instead, on March 2, 1995, Bryant Woods Inn, Inc., initiated the present action by filing a complaint in the United States District Court for the District of Maryland. The complaint alleges causes of action against Howard County and against the Planning Board under the Fair Housing Act, 42 U.S.C. §§ 3601 et seq., and under the Fourteenth Amendment to the United States Constitution, cognizable under 42 U.S.C. § 1983. The plaintiff seeks a judgment declaring that Howard County acted in an illegally discriminatory manner, an injunction against Howard County’s continued refusal to permit Mr. Colandrea to house up to fifteen people with disabilities in Bryant Woods Inn I, an injunction against future similar action by Howard County, compensatory and punitive damages, attorneys’ fees and costs. After some discovery, both sides filed motions for summary judgment. Although neither Bryant Woods Inn, Inc., nor Howard County raised issues relating to the justiciability of the motions for summary judgment, this Court had serious doubts about its jurisdiction over the case, particularly in light of the plaintiffs failure to appeal the decision against it to the Howard County Board of Appeals. By a letter ruling dated November 16, 1995, the Court informed counsel that it questioned “whether the decision under attack by the plaintiff has the requisite degree of finality to satisfy traditional prudential requirements for federal court review of challenged state administrative actions, which can involve such often interrelated issues as ripeness, comity, exhaustion and the like.” The Court asked the parties to brief issues relating to justiciability, including exhaustion, finality and ripeness, and comity principles. A Jurisdiction Bryant Woods Inn, Inc., filed its complaint in the present case after the Planning Board had denied Mr. Colandrea’s petition. Mr. Colandrea did not pursue an appeal to the Howard County Board of Appeals. The plaintiff therefore initiated its federal action without exhausting state administrative remedies and without receiving a decision from the highest decision-maker in the County with authority to hear the case. Whether administrative remedies must be exhausted before federal statutory remedies may be pursued depends upon the intention of Congress in fashioning the federal cause of action. See McCarthy v. Madigan, 503 U.S. 140, 144, 112 S.Ct. 1081, 1086, 117 L.Ed.2d 291 (1992). A plaintiff may seek relief under the Fair Housing Act either by filing a complaint with the Department of Housing and Urban Development, by initiating a civil action on its own behalf, or by seeking the assistance of the Department of Justice in an enforcement proceeding. 42 U.S.C. §§ 8610-3614. These remedies are not mutually exclusive. Section 3613, which sets forth the procedures governing private civil actions, does not explicitly state whether or not administrative remedies must be pursued before a complaint may be filed. “[Wjhere Congress has not clearly required exhaustion, sound judicial discretion governs.” McCarthy, 503 U.S. at 144, 112 S.Ct. at 1086. Several of the criteria set forth by the Supreme Court to constrain the exercise of this discretion suggest that exhaustion should be required in the present case: “Exhaustion concerns apply with particular force when the action under review involves exercise of the agency’s discretionary power or when the agency proceedings in question allow the agency to apply its special expertise ... The exhaustion doctrine also acknowledges the commonsense notion of dispute resolution that an agency ought to have an opportunity to correct its own mistakes with respect to the programs it administers before it is haled into federal court.” McCarthy, 503 U.S. at 145, 112 S.Ct. at 1086 (citations omitted). Furthermore, none of the three factors set forth in McCarthy as “circumstances in which the interests of the individual weigh heavily against requiring administrative exhaustion” is present in this case. 503 U.S. at 146, 112 S.Ct. at 1087. An appeal to the Board of Appeals would not prejudice the plaintiff’s subsequent assertion of a federal action. 503 U.S. at 147, 112 S.Ct. at 1087-88. There is no indication that the Board of Appeals would be biased, or would have predetermined the issue against the plaintiff. 503 U.S. at 148, 112 S.Ct. at 1088. Moreover, contrary to the plaintiffs contentions in its Memorandum on Justiciability, the Board of Appeals has the institutional competence, and indeed the obligation, to review Fair Housing Act issues and to grant appropriate relief. See generally Insurance Commissioner v. Equitable Life Assurance Soc., 339 Md. 596, 615-624, 664 A.2d 862, 872-876 (1995) (holding that administrative agencies in Maryland have the power to decide constitutional issues); Halle Companies v. Crofton Civic Ass’n, 339 Md. 131, 661 A.2d 682 (1995) (discussing generally the powers of Boards of Appeals). General principles therefore appear to favor exhaustion in this case. Nevertheless, this Court has found no reported case in which a federal court has denied a plaintiff relief under the Fair Housing Act for failure to exhaust state administrative remedies. Furthermore, the appeal from the decision of the Planning Board to the Howard County Board of Appeals is apparently not a crucial part of the County’s Final Development Plan (FDP) amendment process. There is no provision in the regulations governing FDP amendments that specifically gives a right of appeal from an FDP decision by the Planning Board to the Board of Appeals. Rather, the right to appeal must be inferred from Section 125 D.2 of the Howard County Zoning Regulations, 16.900(j)(2)(iii) and 16.301(b) of the Howard County Code, and The Howard Research & Development Corp. v. Concerned Citizens for the Columbia Concept, 297 Md. 357, 466 A.2d 31 (1983). Furthermore, the appeal to the Board of Appeals in the present case is not de novo, as it would be in the analogous special exception procedure, see Halle Companies, 339 Md. at 143, 661 A.2d at 688, but on the record. § 501(c) of the Howard County Code; § 2.210(b). Under these circumstances, mindful of the Supreme Court’s warning that “federal courts are vested with a ‘virtually unflagging obligation’ to exercise the jurisdiction given them,” this Court holds that the plaintiffs failure to exhaust administrative remedies does not deprive it of jurisdiction over the Fair Housing Act and § 1983 claims. McCarthy, 503 U.S. at 146, 112 S.Ct. at 1087 (quoting Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 817-818, 96 S.Ct. 1236, 1246-1247, 47 L.Ed.2d 483 (1976)). The plaintiffs failure to pursue an appeal to the Board of Appeals also raises issues relating to finality and ripeness, particularly since the plaintiff contends in this action, inter alia, that in denying the Colan-drea petition Howard County failed to make a reasonable accommodation for the disabled. See generally U.S. v. Village of Palatine, 37 F.3d 1230, 1234 (7th Cir.1994) (where plaintiff argued “that the Village failed to make a reasonable accommodation under the Act, the Village must be afforded an opportunity to make such an accommodation pursuant to its own lawful procedures”); Oxford House, Inc. v. City of Virginia Beach, 825 F.Supp. 1251, 1259-1264 (E.D.Va.1993) (discussing ripeness of reasonable accommodations claim). See also Williamson Planning Comm’n v. Hamilton Bank, 473 U.S. 172, 105 S.Ct. 3108, 87 L.Ed.2d 126 (1985). The plaintiff has filed a federal action against Howard County charging that the County failed to make reasonable accommodations for people with disabilities, without allowing the County’s highest agency decision-maker to consider what action should be taken. Nevertheless, as the plaintiff points out in its Memorandum on Justiciability, the Planning Board’s unappealed decision to deny Mr. Co-landrea’s petition is final in the sense that it now constitutes the local law of Howard County and prohibits Mr. Colandrea from housing more than eight elderly or disabled residents at Bryant Woods Inn I. For justi-ciability purposes, therefore, the plaintiffs Fair Housing Act claims are both ripe and final. Lastly, the nature of the dispute in the present case raises questions about the proper relationship between the federal court and state judicial and administrative bodies. As the Fourth Circuit has recently explained, “state and local zoning and land use law is particularly the province of .the State and ... federal courts should be wary of intervening in the area in the ordinary case ... [Cjases involving questions of state and local land use and zoning law are a classic example of situations in which ‘the “exercise of federal review of the question in a case and in similar cases would be disruptive of state efforts to establish a coherent policy with respect to a matter of substantial public concern.” ’ We can conceive of few matters of public concern more substantial than zoning and land use laws.” Pomponio v. Fauquier County Board of Supervisors, 21 F.3d 1319, 1327 (4th Cir.), cert. denied, — U.S. -, 115 S.Ct. 192, 130 L.Ed.2d 125 (1994) (applying Burford abstention in zoning case). As will become clear, the present case does involve disputed issues of local land use law, such as the applicability of certain parking regulations to Bryant Woods Inn I. Unlike those cases in which the Fourth Circuit has urged federal courts not to “leave their indelible print on local and state land use and zoning law by ..., in effect, sitting as a zoning board of appeals,” however, this case involves neither a state claim in federal disguise, nor a facially merit-less federal cause of action. Pomponio, 21 F.3d at 1327. See also Sylvia Development Corp. v. Calvert County, 48 F.3d 810, 828-829 (4th Cir.1995). Rather, the plaintiff has asserted causes of action arising under the Fair Housing Act, which provides direct federal relief for those aggrieved by discriminatory land use decisions of state and local governments. Accordingly, although the present case is on the margin of federal judicial power, this Court must conclude under the cited precedent that it has jurisdiction to decide the parties’ cross-motions for summary judgment. B. Summary Judgment Standards Summary judgment may be entered in a civil ease if “the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits ... show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Fed.R.Civ.P. 56(e). The party opposing the motion must “do more than simply show that there is some metaphysical doubt as to the material facts.” Matsushita Elec. Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 586, 106 S.Ct. 1348, 1356, 89 L.Ed.2d 538 (1985). Rather, “the quality and quantity of the evidence offered to create a question of fact must be adequate to support a jury verdict” in favor of the non-moving party. Thompson Everett, Inc. v. National Cable Advertising, L.P., 57 F.3d 1317, 1323 (4th Cir.1995). In considering a motion for summary judgment, a court must consider the facts and draw its inferences in the light most favorable to the party opposing the motion. See Tuck v. Henkel Corp., 973 F.2d 371, 374 (4th Cir.1992), cert. denied, 507 U.S. 918, 113 S.Ct. 1276, 122 L.Ed.2d 671 (1993). Nonetheless, such inferences “must, in every case, fall within the range of reasonable probability and not be so tenuous as to amount to speculation or conjecture.” Thompson Everett, 57 F.3d at 1323. If materially different inferences may rationally be drawn from the undisputed facts, then summary judgment is inappropriate. C. The Fair Housing Act As amended in 1988, the Fair Housing Act (FHA) protects people with disabilities against discrimination in housing. 42 U.S.C. §§ 3601 et. seq. A cause of action under the FHA against a local government may arise under any one of three theories. A plaintiff may allege that the local government’s decision was based on intentional discrimination against the disabled. See, e.g., Bangerter v. Orem City Corp., 46 F.3d 1491 (10th Cir.1995). A facially neutral regulation, practice or policy may violate the Act if it has a disparate impact upon people with disabilities. See Smith v. Town of Clarkston, 682 F.2d 1055, 1065 (4th Cir.1982). Lastly, a local government’s failure to make a reasonable accommodation for people with disabilities may give rise to a cause of action under the FHA. 42 U.S.C. § 3604(f)(3)(B). The plaintiff in the present case alleges that “Defendants have violated the FHA[ ] under all three theories.” (Pltf.’s Mot.Summ.J. at 26). I. Intentional Discrimination The Fair Housing Act prohibits intentional discrimination against people with disabilities. 42 U.S.C. § 3604 provides that “it shall be unlawful ... [t]o discriminate in the sale or rental, or to otherwise make unavailable or deny, a dwelling to any buyer or renter because of a handicap of [a person with disabilities] ...” See also Bangerter v. Orem City Corp., 46 F.3d 1491, 1500-1501 (10th Cir.1995); Potomac Group Home v. Montgomery County, 823 F.Supp. 1285, 1295 (D.Md.1.993). An actionable intent to discriminate need not be motivated by dislike for, or animosity against, people with disabilities; the legislative history of the Fair Housing Act shows that Congress intended equally to prohibit discrimination resulting from “false and over-protective assumptions about the needs of handicapped people, as well as unfounded fears of difficulties about the problems that their tenancies may pose.” H.R. No. 100-711, U.S.C.C.A.N. 2185 (1988). Nevertheless, a plaintiff alleging intentional discrimination has the burden of showing that a decision to deny housing opportunities was motivated, at least in part, by unjustified consideration of the disabled status of individuals who would be affected by the decision. In this regard, government officials are generally held to act with discriminatory intent, regardless of their personal views, when they implement the discriminatory desires of others. See, e.g., Dailey v. City of Lawton, 425 F.2d 1037, 1039 (10th Cir.1970) (holding, in § 1983 racial discrimination action, that “it is enough for the complaining parties to show that the local officials are effectuating the discriminatory designs of private individuals”); Oxford House-C v. City of St. Louis, 843 F.Supp. 1556, 1576 (E.D.Mo.1994); Potomac Group Home, 823 F.Supp. at 1297-1298; United States v. Borough of Audubon, 797 F.Supp. 353, 361 (D.N.J.), aff’d, 968 F.2d 14 (3d Cir.1992). In deciding whether Bryant Woods Inn, Ine.,’s evidence of intentional discrimination can withstand Howard County’s motion for summary judgment, this Court must take particular care to draw every legitimate inference in favor of the plaintiff. As the Fourth Circuit has recognized, “municipal officials acting in their official capacities seldom, if ever, announce on the record that they are pursuing a particular course of action because of their desire to discriminate.” Smith v. Town of Clarkston, 682 F.2d 1055, 1064 (4th Cir.1982). Furthermore, courts have acknowledged that government officials may conceal discriminatory intent by claiming that they relied upon objective, neutral criteria such as parking regulations. See, e.g., Potomac Group Home, 823 F.Supp. at 1290-1292; Support Ministries for Persons with AIDS, Inc. v. Village of Waterford, 808 F.Supp. 120, 131 (N.D.N.Y.1992). Nevertheless, a plaintiff alleging a cause of action based on intentional discrimination must produce at least some evidence, either direct or circumstantial, of discrimination. As the parties agree in their cross-motions for summary judgment, the facts giving rise to the present case are not in dispute. Rather, the question before this Court is whether, from the undisputed facts, a fact-finder could reasonably draw an inference that the County’s actions were motivated by factors which related to the disabled status of the prospective residents of Bryant Woods Inn I. In answering this question, the Court must bear in mind that “inferences must, in every ease, fall within the range of reasonable probability and not be so tenuous as to amount to speculation or conjecture.” Thompson Everett, Inc. v. National Cable Advertising, 57 F.3d 1317, 1323 (4th Cir.1995). Bryant Woods Inn, Inc., contends that “[t]he record reveals a consistent, three year pattern of conduct whereby Howard County officials repeatedly responded to community pressure to prevent a few more disabled, elderly citizens from living in an affluent Columbia neighborhood.” (Pltf.’s Mot. Summ.J. at 29). Indeed, the plaintiff asserts that the record contains “compelling evidence of discriminatory intent” on the part of the Planning Board. According to the plaintiff, the record contains four types of evidence that the Department of Planning and Zoning acted with a discriminatory intent when it denied the Colandrea petition: 1) the neighbors opposed the petition as “a threat to safety and property values” and the County officials took the community opposition into account in making their decision (id. at 29-31); 2) the Department of Planning and Zoning “grossly departed from its normal procedures” in handling the Colandrea petition (id. at 31-33); 3) the individual members of the Planning Board “were motivated by stereotypes about people with disabilities” (id. at 33-34); and 4) the Planning Board offered “shifting and irrational justifications” for its decision to deny the Colandrea petition (id. at 34-37). a. The County’s Response to Political Pressure Bryant Woods Inn, Inc., alleges that the Planning Board intentionally discriminated against people with disabilities by responding to the community’s opposition to Mr. Colan-drea’s proposed expansion. It is undisputed that the Howard County officials who received communications from Mr. Colandrea’s neighbors viewed the petition as “controversial” and “politically sensitive.” (Paul Farragut Depo. at 23-24, Pltf.’s Exh. 27; Richard Blood Depo. at 135-136, Pltf.’s Exh. 43). Nevertheless, it is amply clear from the record that the Planning Board considered legitimate land use criteria in arriving at its decision. (Pltf.’s Exhs. 66, 67; Dfts.’ Exhs. 2, 11). There is a factual dispute about the degree to which political pressure determined the procedure followed by the Department of Planning and Zoning and affected the Planning Board’s ultimate decision on the Colandrea petition. Viewing all the evidence in the light most favorable to the plaintiff, this Court assumes both that the Department of Planning and Zoning deviated from its usual procedures and that it was predisposed to deny the Colandrea petition because a contrary decision would have been difficult politically. In Sylvia Development Corp. v. Calvert County, 48 F.3d 810 (4th Cir.1995), the Fourth Circuit considered the legal effect of a local zoning board’s response to local political pressures: “The record in this case reveals that the public opposition to the Blue Dolphin project, as well as the sympathy to this opposition expressed by certain commissioners, centered around legitimate land use issues such as the concern over further growth in Calvert County, the consequences of increased residential density, and the preservation of the community’s aesthetic character — issues that are at the heart of countless local zoning disputes in every corner of the county. It is not pernicious per se for a zoning authority to be influenced by political pressure in the community. ‘Such give-and-take between government officials and an engaged citizenry is what democracy is about.’ ” Sylvia Development, 48 F.3d at 829 (quoting Gardner v. Baltimore Mayor & City Council, 969 F.2d 63, 72 (4th Cir.1992)). If, however, a zoning board’s response to political pressure amounts to the implementation of local residents’ discriminatory impulses, then the board’s actions may give rise to a cause of action for intentional discrimination. See Dailey, 425 F.2d at 1039. To sustain its claim of intentional discrimination, therefore, the plaintiff must present some evidence that community opposition to the expansion of Bryant Woods Inn I was based, at least in part, upon the fact that the residents of the Colandrea group home are people with disabilities. The record reveals that community opposition to Mr. Colandrea’s activities at Bryant Woods Inn I began in late 1992, when Mr. Colandrea proposed constructing a two-story addition to the house to accommodate additional residents, and it continued thereafter. Mr. Colandrea’s neighbors objected to the physical expansion of the house as inconsistent with the character of the neighborhood, which is generally composed of smaller homes. See, e.g., December 28, 1992 letter from Rex Dalrymple to Vernon Gray, Pltf.’s Exh. 28 (“Richard Colandrea has applied to expand both [his Waterfowl Terrace] properties by almost an additional 50% to over 5,000 sq. ft. in size, far larger than any other homes in the area”); July 15, 1993 letter from William Voss to Charles Ecker, Pltf.’s Exh. 41 (“Our street is made up of three and four bedroom homes and one 75% bigger with more bedrooms is just not compatible with our neighborhood”). The neighbors complained of existing traffic and parking problems at Bryant Woods Inn I, and anticipated increased difficulties with traffic and parking. See, e.g., December 9, 1992 letter from John Baker to Bernice Kish, Pltf.’s Exh. 26 (“The traffic in and out of this home is on the edge of becoming a problem and adding additional people to the residence will only make this minor annoyance a real problem for the neighborhood.”); January 1,1994 letter from Rex Dalrymple to William Manning, Pltf.’s Exh. 44 (“Approval of the application would create additional parking problems for residents on Waterfowl Terrace, which already has a severe parking problem.”) The letters express anxiety about neighborhood safety. See, e.g., December 28, 1992 letter from Rex Dalrymple to Vernon Gray, Pltf.’s Exh. 26 (“If vehicles are parked along the street, on both sides of the street, that leaves only 14 ft down the center for emergency vehicles to travel ... ”). Members of the local community were also concerned about possible resale of the enlarged Colandrea home, and about the effect of the larger property upon their property values and tax assessments. See, e.g., December 28, 1993 letter from Paul Imre to Joseph Rutter, Pltf.’s Exh. 44 (“If this exemption is allowed to pass zoning it will severely impact the resale value of the existing homes in the Bryant Woods Neighborhood. Many of us are elderly homeowners and it could pose a hardship for us.”). In addition to the numerous land use concerns about Mr. Colandrea’s proposed expansion of Bryant Woods Inn I, the residents of Wilde Lake expressed hostility and resentment against Mr. Colandrea personally. One particular complaint was Mr. Colandrea’s refusal to even attempt to comply with local covenants, or to respond informally to neighbors’ concerns about his activities at the Waterfowl properties. The neighbors made Howard County officials aware that “Richard Colandrea has consistently refused to apply for a business license even though the operation of both homes [on Waterfowl Terrace] certainly is a business.” (December 28,1992 letter from Rex Dalrymple to Vernon Gray, Chairman of Howard County Zoning Board, Pltf.’s Exh. 26.) They petitioned the Wilde Lake Board for enforcement of the covenants. (Pltf.’s Exh. 28). Ultimately, because Mr. Colandrea refused to submit an “In-Home Business Application” to the Wilde Lake Architectural Committee for either of the Waterfowl Terrace homes, the Columbia Association and the Wilde Lake Community Association, Inc., sued Mr. Colandrea in the Circuit Court for Howard County for violating the restrictive covenants applicable to the properties. Mr. Colandrea’s petition for an amendment to the Final Development Plan was not calculated to assuage the neighbors’ concerns about his apparent disregard for local covenants. Mr. Colandrea’s proposed amendment read as follows: “Allow for the housing of disabled persons provided the use is licensed or certified by the state of Maryland. The housing of disabled persons shall not be considered a business use;, shall not change the use classification of the property or the structure from that of residential and shall require no other community association approval.” (Colandrea’s December 6, 1993 application for a plan amendment, Exh. 4 to Dfts.’ Mot. Summ.J.). Consequently, part of the local opposition to the petition was based on neighbors’ view that the amendment was an attempt by Mr. Colandrea to avoid the covenant restrictions. See, e.g., January 3, 1994 letter from John Baker to Joseph Rutter, Pltf.’s Exh. 44 (“In my opinion, the only reason Mr. Colandrea wishes to have this property rezoned is to circumvent the local process of obtaining approval for modifications [or] expansions to the property and getting approval for running a business in a single family dwelling.”); January 1, 1994 letter from Rex Dalrymple to William Manning, ibid. Another source of friction between Mr. Colandrea and his neighbors was Mr. Colan-drea’s other business activities allegedly carried on in Waterfowl Terrace. See December, 1992 letter from Dr. Robert S. Beale, Jr. to Bernice Kish, Pltf.’s Exh. 26 (“For the past several years, the Colandrea family has operated several commercial ventures on our street. Those activities which seem to include a junk hauling business and a rooming house have caused concern in my household and those of my neighbors.”); December 18, 1992 letter from Dr. Robert Beale to Bernice Kish, ibid, (“the junk-hauling business is bad enough with trash-laden trucks remaining for days at a time in front of my house”). Lawrence Schoen, another neighbor, took twenty photographs of Mr. Colandrea’s vehicles and trash cans during the first month of 1993. He sent the photographs to Janet Mason, Chair of the Wilde Lake Village Board, with copies to Mr. Colandrea and to nine community association and local government representatives. In a cover letter, Mr. Schoen describes the content of the photographs as follows: “They show his several vehicles used to carry construction materials and/or debris parked in various places on or around two of the three the [sic] Colandrea family properties in my neighborhood ... One of them shows his truck blocking the sidewalk. Others show overflow trash and automobile parking resulting from his businesses. He has what appears to be a commercial garage filled with materials for his businesses which faces Columbia open space. As you know, this was a period of intense attention on Mr. Colandrea’s activities and his failure to keep his commercial vehicles out of the area is a measure of his disdain for the laws and rules that the rest of us live by.” (Ibid.) Mr. Schoen’s anxiety about Mr. Co-landrea’s pursuit of business ventures extended to the proposed expanded use of Bryant Woods Inns I and II as assisted living facilities. Mr. Schoen stated that “[i]t is my understanding that Mr. Colandrea has attempted to purchase still more homes in the neighborhood over the years. He seems to be interested in expanding all of the properties owned by the family ...” (Ibid.) The letters written by Mr. Colandrea’s neighbors are emotional and express numerous objections to Mr. Colandrea’s activities on Waterfowl Terrace. Some include statements which can be construed as offensive or discriminatory with respect to certain groups of people. Dr. Beale argues in his December 8, 1992 letter to Bernice Kish, for example, that “the nursing employees could be people whom I would not generally expect to be in my neighborhood” and that “[T]he relatives of the customers or employees of these ventures could be people whom I would not like to inform even of the existence of Waterfowl Terrace.” (Pltf.’s 26). Many express a high degree of animosity against Mr. Colandrea and distrust of his motives. See January 11, 1993 letter from Christine Crable to Charles Ecker, Pltf.’s Exh 28 (“[w]e must not allow ‘greed’ masqueraded as unselfish sharing to creep into our community and destroy our true objective”); January 1, 1994 letter from Rex Dalrymple to William Manning, Pltf.’s Exh. 44 (ascribing to Colandrea the intent to “circumvent those Wilde Lake Covenants, with which he apparently does not agree, in order to place his property to a higher density use which would provide substantially higher economic benefits to him personally”); January 3, 1994 letter from John Baker to Joseph Rutter, ibid, (charging that Colan-drea’s request for expansion “is based purely on personal greed, not on what is best for the neighborhood or the elderly residents of his business”). Conspicuous by their absence, however, are statements that either explicitly or implicitly suggest that the neighbors were opposed to Mr. Colandrea’s use of the Waterfowl Terrace properties because his client base was composed of elderly and disabled people. Of the numerous letters contained in the record, only one expresses any opposition to the expansion of Bryant Woods Inn I on a ground that relates to the presence of elderly or disabled residents. In her letter to Charles Ecker of January 11,1993, Christine Crable asks him to consider “the mental and physical affects [sic] of living in the midst of a greater than normal population of illness and old age.” (Pltf.’s Exh, 28). While this snippet from one rather odd letter does provide evidence that one Columbia resident had concerns based on the disabled status of the proposed residents of Bryant Woods Inn I, such evidence is plainly too slender a reed upon which to rest a triable issue of fact with respect to whether or not Howard County’s denial of the Colandrea petition effectuated the discriminatory designs of the local community. “One swallow does not make a summer.” Aristotle, Nichomachean Ethics, Book 1, Ch. 7 (c. 325 B.C.). Neither does a single discriminatory statement contained in one of the numerous letters in the record create a triable issue of fact with respect to the intentional discrimination claim against the County. See generally O’Connor v. Consolidated Coin Caterers Corp., 56 F.3d 542, 548-550 (4th Cir.1995); Birkbeck v. Marvel Lighting Corp., 30 F.3d 507, 511-512 (4th Cir.1994). This Court has carefully considered the entire record before it. Counsel for the plaintiff has meticulously tilled the record for any material which might give rise to an intentional discrimination claim. Because of the unusual level of general local opposition to the expansion of Bryant Woods Inn I, there was, perhaps, sufficient grist for the plaintiffs mill to keep counsel from the briar patch of Rule 11. Nevertheless, on the basis of the undisputed facts, no rational trier of fact could infer that the disabled status of the fifteen people who would live in Bryant Woods Inn I was a motivating factor in the Howard County Planning Board’s denial of Mr. Colandrea’s petition. Apart from Ms. Crable’s isolated statement, the plaintiff has not produced any evidence, direct or circumstantial, that the community opposition to Mr. Colandrea’s expansion of Bryant Woods Inn I was motivated by considerations relating to the elderly or disabled status of the group home’s residents. On the contrary, the record evidence shows that the community opposition to Colandrea’s petition was based primarily upon legitimate land use concerns, including parking, traffic and safety. As Lawrence Schoen testified at the hearing before the Planning Board, “there isn’t really an interference from the people living in the house, it’s these ancillary activities like parking and construction that are creating the problem.” (Hearing transcript at 48, Dfts.’ Exh. 2 to Mot.Summ.J.). To the extent that the community’s opposition to the Bryant Woods Inn I expansion was sharpr ened by emotional or irrational concerns, those concerns involved animosity against Mr. Colandrea personally, which arose out of anger at Mr. Colandrea’s perceived indifference to local concerns and the residential character of the community, and fear that he would expand his other properties in the neighborhood. Indeed, it is clear that Mr. Colandrea’s neighbors would have opposed any expanded use of his properties which would have threatened the character of the community, regardless of whether or not the expanded use would make homes available to people with disabilities. Personal animosity, based on other-than prohibited motives, does not violate one’s right to be free from proscribed discrimination. See Williams v. Cerberonics, Inc., 871 F.2d 452 (4th Cir.1989). It is well-established that if the evidence produced by the non-moving party in response to a summary judgment motion “is merely colorable ... or is not significantly probative ... summary judgment may be granted.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249-250, 106 S.Ct. 2505, 2510-2511, 91 L.Ed.2d 202 (1986) (citations omitted). The plaintiff has not produced evidence from which a finder of fact could rationally conclude by the appropriate proof burden that the Planning Board’s denial of the Colandrea petition was motivated by Columbia residents’ intentional discrimination against people with disabilities. Absent evidence of discrimination against the disabled on the part of its constituents, a county’s response to political pressure does not give rise to an intentional discrimination claim under the Fair Housing Act. To the extent that the plaintiffs intentional discrimination claim under the Fair Housing Act is based upon the theory that the Planning Board implemented its constituents’ discriminatory impulses, therefore, the defendants are entitled to summary judgment on that claim. b. Intentional Discrimination by the Planning Board Bryant Woods Inn, Inc,, contends that certain statements of members of the Planning Board reveal that they “based their decision on precisely the kinds of stereotypes and unfounded assumptions about the ‘impact’ of people with disabilities that are forbidden by the FHAA.” (Pltf.’s Mot.Summ.J. at 38). The plaintiff offers three facts as evidence for this claim: (1) the use of the word “mainstream” by Board Member Cathy Hartman; (2) the Board’s use of the word “institution” to describe Bryant Woods Inn I, as expanded (Id. at 33-34); and (3) Dr. Dale Schumacher’s questions about the residents’ medical needs. Cathy Hartman’s deposition contains the following colloquy: “Q. ... Why does having fifteen people as opposed to eight people make it more of a business? ... A. I think when you start getting into the higher numbers, it’s not what you would view as — I think mainstreaming eight people into a residential neighborhood is certainly much more acceptable and easier to accommodate than it would be for fifteen Q. When you use the word “mainstreaming,” what do you mean? A. People that want to participate in community affairs and be a part of the neighborhood.” (Hartman Depo. at 44, Pltf.’s Exh. 54). According to the plaintiff, “[t]he view that people are outside the ‘mainstream’ of society because they are elderly and have Alzheimer’s disease is self-evidently discriminatory.” (Pltf’s Mot.Summ.J.) The plaintiff therefore takes the position that Ms. Hartman’s use of the word mainstreaming is evidence of invidious discrimination, “precisely the kind of remark[] which can occur at less guarded moments during a deposition and help reveal a person’s actual underlying motives.” (Pltf.’s Reply at 28). This Court is puzzled by the plaintiffs assertion that the word mainstreaming is “self-evidently discriminatory.” The plaintiff objects to the underlying assumption that “people are outside the ‘mainstream’ of society because they are elderly and have Alzheimer’s disease.” This point of view is not discriminatory. Rather, it acknowledges the distressing fact that people with Alzheimer’s disease, like many other people with disabilities, have historically been excluded from opportunities available to those who are not disabled. It is not discriminatory to recognize and acknowledge the existence of persistent and unjustified exclusion of the disabled from many aspects of “mainstream” society. On the contrary, sound public policy for people with disabilities must take account of the nature of this exclusion and the lack of a rational basis for it. The amicus memorandum filed in this Court by the Assisted Living Facilities Association of America, Inc., and the Assisted Living Legal Defense and Education Fund explains that until the middle of this century “the official policy of the United States was to segregate people with disabilities from ‘normal’ society.” (Amicus Memo, at 7). More recently, segregation and stigmatization of the disabled have been replaced by efforts to give equal opportunity and consideration to people who have disabilities, a policy described as “normalization”. (Amicus Memo, at 9). According to amici, “the concept of ‘normalization’ — the idea that people with disabilities do better when they live as part of society rather than separate from it— has influenced national policy on disabilities for the past thirty years.” (Id. at 10). “Normalization,” therefore, is aimed at breaking down the barriers which still prevent people with disabilities from being treated as equals in society and is not itself discriminatory. Ms. Hartman explained that she used the word mainstreaming to describe the accommodation of “people that want to participate in community affairs and be a part of the neighborhood.” Ms; Hartman’s point of view fairly describes the process of normalization, viewed by amici, at least, as the goal toward which the FHA is aimed. It is not evidence of discrimination. Bryant Woods Inn, Inc., also argues that “the Board consistently expressed the view that a fifteen person group home is an ‘institution.’ ” (Pltf.’s Mot.Summ.J. at 34.) According to the plaintiff, “[s]uch attitudes stereotypically view seniors as institutional wards in total disregard for the family-like atmosphere that characterizes the Waterfowl home and other groups.” (Ibid.) As one of two identified examples of the offensive use of the word institution, the plaintiff cites to the following colloquy in the deposition of Theodore Mariani, a member of the Planning Board, during which Mr. Mariani was questioned about why Howard County classified homes with eight residents as residential, but not homes with fifteen residents: “A. I think what we are saying is when you go above eight [residents] you are getting a different kind of setting than a, quote, familial setting. Q. What type of setting are you getting between nine to fifteen? ... A. When you get larger than eight, I think it begins to take on more of an institutional type setting. Q. And what are the characteristics of the institutional type setting? A. Larger staff numbers, larger dining facilities, starting to get almost like a commercial kitchen operation. A whole series of things begin to change.” (Mariam Depo. at 190-191, Exh. 4 to Pltf.’s Reply.) Far from stereotyping “seniors as institutional wards,” Mr. Mariam quite obviously sought to distinguish comfortable, familial housing for seniors from larger group housing in which the intimate atmosphere of a family has been lost. It is not discriminatory to consider the possibility that an eight person group home might promote the goals of normalization more effectively than a home for fifteen people. Advocates for the disabled agree that the most desirable characteristic of assisted living is its familial nature. See Dr. Deborah Louis Depo. at 28, Pltf.’s Exh. 5 to Mot.Summ.J. (“the model [for group homes] being a family model where someone already in residence in the community decides that they will become a facility and take four to six or however many seniors into their home and basically sort of operate it like a family”); Amicus Memo, at 10 (“In housing, normalization means living in a normal size home in a residential neighborhood.”). Sensitivity to the fact that a familial atmosphere may disappear if too many people live in a home is simply not invidious discrimination. Compare Horizon House v. Township of Upper Southampton, 804 F.Supp. 683, 694-695 (E.D.Pa.1992) (holding that it is discriminatory to use quotas to promote numerically even integration throughout different communities). Lastly, Bryant Woods Inn, Inc., argues that Dr. Dale Schumacher’s “persistent and intrusive questions” about the elderly residents’ medical needs “similarly reflect common stereotypes which may not be used to limit housing opportunities for seniors.” (Pltf.’s Mot.SummJ. at 33-34). During the Planning Board hearing, Dr. Schumacher did ask Mr. Colandrea to explain what land use impact might arise from the provision of medical services to the residents of Bryant Woods Inn I. See Dfts.’ Exh. 2 at 20-23. As Dr. Schumacher later explained in his deposition, the medical needs of different residents might lead to differences in the expected number of visits from health care workers, in the need for delivery of medical supplies, and in the likelihood of medical emergencies. Under these circumstances, Dr. Schumacher’s interest in the medical profile of the residents of Bryant Woods Inn I is not a manifestation of stereotyping, but is a clear attempt to develop the factual basis for a rational assessment of the land use impact of the proposed use. The plaintiff has not produced one scintilla of evidence that the individual members of the Planning Board based their decisions on discriminatory impulses. Plucking isolated words such as mainstream and institution from the record, and describing them as “self-evidently discriminatory” or “common stereotypes” does not amount to the production of evidence of discrimination. Consequently, to the extent that the plaintiffs cause of action for intentional discrimination is based upon alleged discrimination by individual members of the Planning Board, it is meritless. c. “Shifting and irrational justifications” Lastly, Bryant Woods Inn, Inc., argues that “the County’s inability to advance a consistent, plausible justification for its conduct is itself evidence of discriminatory intent.” (Pltf.’s Mot.Summ.J. at 34). According to the plaintiff, the “only land-use justification cited by Board members, both at the hearing and in their formal decision, was parking.” (Id. at 35). It is the plaintiffs position that the Board’s concerns about parking were implausible and irrational. This Court will assume, for the purposes of assessing the summary judgment motion against the plaintiff, that concerns about parking were the only legitimate concerns articulated by the Planning Board in making its initial decision. The Planning Board made the following determinations with respect to parking: “Petitioner proposes a parking plan which accommodates between four and six vehicles on the site. However, the plan does not allow for easy circulation of the accommodated vehicles and would likely result in fewer ears actually using on-site parking, thus forcing overflow parking onto the street. This would have a particularly adverse effect on vicinal properties since the subject property, although somewhat rectangular, is ‘pie-shaped’ with a particularly narrow area of road frontage available for on-street parking. Based on the personal observation of one of the Board members during two site visits and the testimony of Petitioner’s neighbors, even the existing use generates parking congestion on the street. This situation would be exacerbated by Petitioner’s proposed expansion.” (Transcript of hearing at 4-5, Dfts.’ Exh. 2 to Mot.Summ.J.). The plaintiff objects to the Planning Board’s finding that parking at Bryant Woods Inn I was inadequate for the following reasons: “Although the Board learned that none of the residents drive [sic], its Decision was premised upon fifteen residents with cars. Moreover, while the Board heard evidence that the home has five off-street and at least two on-street parking spaces (which is almost enough to meet even the unreasonable standard that Defendants imposed), it ignored that evidence. The Board also ignored evidence that visitors were rare. On the other hand, the Board credited complaints about parking raised by neighbors at the hearing