In Angus v. Miller, 5 Mass. App. Ct. 470, 363 N.E.2d 1349 (1977), decided under the law in force prior to the enactment of St. 1975, c. 808, the Appeals Court found that nonconforming structures could not be "rebuilt" absent damage or destruction by catastrophe. In Angus, the Appeals Court found the applicable bylaw did not authorize the razing of existing nonconforming buildings and construction of a new nonconforming commercial building. That bylaw authorized a nonconforming structure to be "rebuilt if damaged or destroyed, enlarged, or changed to a specific new use." The petitioner asserted the project constituted an enlargement under the bylaw. The Appeals Court refused to read "enlarged" to include the demolition of existing nonconforming buildings and the construction of new nonconforming buildings. Such a project would properly be considered a rebuilding rather than an enlargement, and the bylaw stated that a structure could be rebuilt only if "damaged or destroyed," implying by casualty. Angus, 5 Mass. App. Ct. at 472-473.