Statement of Grounds (2) (1) IPLAW, & TITI_X IPC
40 Salem Street
Bldg 2, Suite 16
Lynnfield, MA 01940
Tel. 781-246-2000
Fax. 781-205-0982
John N. Papantonakis, Esq. www.jplawandtitle.com
September 7,2023
City of Salem
Attn: ZBA
93 Washington Street
Salem, MA 01970
RE: STATEMENT OF GROUNDS
LOCUS: 38 Willson Street, Salem,MA 01970
OWNER: Gaetano Fodera
APPLICATION ID: ZBA-23-30
To Whom it May Concern:
This office represents the above-named applicant in connection with his application for a Special Permit.
The subject property is an existing nonconforming structure, as defined by the Salem Zoning Code. The
proposed work would extend the existing second-floor mudroom approximately ten (10) feet outward to
become flush with the existing deck, as shown on the attached Plot Plan. Said existing deck would also be
modified to be enclosed by the extension of the existing roof, which would not alter the current
dimensions of the deck.
Under Section 3.3.3 of the Salem Zoning Code, a special permit"to reconstruct, extend, alter, or change a
nonconforming structure"may be granted when "not be substantially more detrimental than the existing
nonconforming structure to the neighborhood." The proposed work would not change the use, function, or
general footprint of the existing structure, but rather expand the current use and enjoyment of the
applicant and his family. Further,the proposed work would have no impact on the factors listed in Section
9.4 of the Salem Zoning Code, such as traffic flow, neighborhood character, and environmental impacts.
In regard to neighborhood character,the proposed work would not alter the existing structure in a way
that is inconsistent with its current aesthetic and the aesthetic of the neighborhood.
On the aforementioned grounds,the applicant respectfully requests that the Zoning Board of Appeals
grants a Special Permit for the proposed work.
Very truly yours,
n N. Papant a-is, Esq.