This letter was submitted to the Town of New Shoreham on Block Island prior to the Town granting permission for Deepwater Wind to erect a met tower on town land under the Special Temporary Provisions (Section 112) of the Town's zoning. Under Section 112, permits may be granted only for a use or purpose that cannot be accomplished by compliance with provisions of the ordinance. Attorney Hagopian argues that Deepwater's proposal does not meet the "exigent circumstance requirements" including risks to public health and safety or any other emergency or urgent necessity that warrants invoking this provision.