A neighbor of the Wellspring Farm Learning Center has filed a formal complaint with the Zoning Board of Appeals, suggesting that activities at the rehabilitation center create a nuisance.

Signed by Hiller Road resident Cathy Mendoza, the complaint was also sent to Selectmen, the building inspector, the town administrator and town counsel.

The complaint, in the form of a letter dated Jan. 6, states that Wellspring Farm co-founders James and Holly Vogel have expanded their business operations beyond plans initially submitted to the ZBA.

Founded in 2000 at 42 Hiller Road, the center offers rehabilitation programs for children and adults with a range of diagnoses, including anxiety, autism and physical trauma.

According to Mendoza, there are high levels of traffic and noise caused by incoming and outgoing patients and staff.

“Upwards of thirty cars, buses, taxi cabs and other transportation services can be seen and heard coming and going from the property,” Mendoza wrote. “To say the noise level that comes with the constant exit, entry and treatment of the patients is unbearable, would be an understatement.”

When the Vogels first appeared before the ZBA for approval, Mendoza said the couple stated the operation would be small, limited to a handful of students per week.

In documents submitted along with the complaint, she highlighted one passage from the Vogels that reads: “We are open just four days per week and serve no more than five students per day. We are very specialized, exclusive and small and intent to remain with this current philosophy.”

The complaint also refers to loud patients that Mendoza says are affecting her child, who has a disability.

“Many of the patients have loud outbursts and some of the patients scream and yell obscenities,” she wrote.

This isn’t the first time that Mendoza has complained to the town.

In 2001, she filed an appeal with the ZBA that was overturned.

According to the Wellspring Farm's website, James Vogel has had a career in human services lasting 44 years. Before he co-founded the center, he served as the Massachusetts Commission for the Blind’s regional director. His wife worked in Worcester public schools where she developed curricula for children with special needs.

When reached for comment regarding the complaint, James said: “All complaints are exaggerated and untrue. Period.”

In her letter, Mendoza requested that the Vogels restrict the center’s operations to four days week, serving no more than eight students per day. She also asked that the couple stop marketing the property as an outpatient mental health facility.

The complaint also refers to an issue outside of the ZBA’s purview – the fact that the Vogel’s business and property is up for sale.

“We are concerned that they will attempt to sell to someone who will attempt to further expand this intrusive operation,” Mendoza wrote.

When asked, the couple declined to comment on the sale.

According to ZBA Chair Richard Cutler, it’s unclear whether or not the business could be transferred to a new owner following a sale.

“That’s something for the attorneys to figure out,” Cutler said.

Cutler's board met on Jan. 14, and while the letter was included in its packet of correspondence it was not discussed, he said.

He said it’s likely the board will schedule a hearing to address the complaint soon.