Freedom—May 11, 2025—A document contained in Wabanaki Campground’s application to the N.H. Consumer Protection and Antitrust Bureau to convert to cooperative ownership has renewed questions about the “hutnick” site plan application under consideration by Freedom’s Planning Board.

Appendix M of the application to the Bureau, which is part of the N.H. Department of Justice, is stated to be an approved, “platted of record” subdivision plan from 2000, to which an amendment is “pending approval” by Freedom.

Appendix M is actually a draft condominium conversion plan that was created by Land Tech in 2022 but never approved by any entity. It is not related to the Freedom proceedings, which involve building expansions, not a subdivision amendment.

Wabanaki principal Mark Salvati applied to the Consumer Bureau in January 2024 pursuant to RSA 356-A-5 for approval to sell shares in 77 “units” of the 11-acre campground to the public. A majority of campers last year signaled their intent to buy shares by signing a non-binding reservation agreement and making a deposit.

The Consumer Bureau acknowledged the Appendix M discrepancy but said it has not discussed it with the applicant. In an email to Ossipee Lake Alliance, Salvati said Appendix M should have referenced the campground subdivision plan that DES approved in 2001.

The 2001 DES plan was part of a settlement of environmental violations at the site. An approved town subdivision plan from that time has not been found. Salvati said he hopes to have the DES plan amended and approved, but has not decided on the timing or process for doing so.

Concern that Wabanaki’s site plan application might be used as a de facto subdivision plan began shortly after the start of Planning Board hearings on making “improvements to an existing campground” more than a year ago.

While the focus of the hearings was expanding five structures called “hutnicks,” longtime Freedom resident Susan Hoople told the board she was concerned that the application showed a high level of detail for campground features that were unrelated to the “hutnicks.”

She said approving the application might be construed as approving everything in it, not just the “hutnick” expansions. Bryan Berlind of Wabanaki agent Horizons Engineering said the document would not be used that way and the discussion ended.

But Planning Board member Anne Cunningham raised the question again this January. She pointed out that Horizons was making unrelated changes to the campground’s features each time it changed the “hutnick” designs.

The unrelated changes included adjusting campsite lot lines, adding and moving RVs, trailers and decks, and repeatedly renumbering the campsites. Cunningham said if the board approved the application it would be approving more than just the “hutnicks.”

The board agreed and instructed Horizons to submit a “stripped down” application based on a January 2024 version of the plan, and show only the “hutnicks.” Horizons has not completed the task and the application has been continued several times, most recently last month.

Meanwhile, a 22-page independent professional analysis of the site plan application concluded that it is “a subdivision plan in all but name.”

The report, by TND Engineering on behalf of residential abutters and Ossipee Lake Alliance, pointed to the application’s “depiction of the lines and labeling of units” for “closed parcels,” and the campground’s sales materials promoting the opportunity to “own a little piece of paradise” by purchasing “lots” and “units” of the property.

“Whether paradise or not, whether for sale or lease, or rent, this is all very clearly a subdivision proposal as defined by the town and the State,” the report concluded, adding that it should be withdrawn or denied by the board and a subdivision plan submitted.

The report took particular aim at Horizons Engineering’s January 30 letter to the Planning Board asking it to focus on the “hutnicks” despite all of the extraneous material in the five-sheet submission.

“The submitted plans depict fundamental noncompliance with town and State regulations that the applicant seeks to remove from the Board’s attention, namely the zoning ordinance, the site plan review regulations, and State statutes,” the report stated.

The Planning Board acknowledged receipt of the report in February but has not publicly discussed it or asked the applicant to respond.

Salvati declined to comment on the report, telling Ossipee Lake Alliance last week that the Planning Board “will give it the weight it deserves.”

Salvati said that his application to the state is still being edited and discussed with the Attorney General’s office.

“This process is new to myself and the Town of Freedom, so if mistakes were made, they will certainly be corrected prior to any approval,” he said.