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18 CROMBIE STREET - BUILDING INSPECTION 18 CROMBIE STREET i i No. 153L-2 HASTINGS, MN LOS ANGELES-CHICAGO-LOGAN.OH MCGREGOR.TX-LOCUST GROVE.GA U.S.A. �d •� ins//� �o� �' ���p s� �roa� . �- � o , . Certificate No: 304-05 Building Permit No.: 304-05 Commonwealth of Massachusetts City of Salem Building Electrical Mechanical Permits This is to Certify that the RESIDENCE located at Dwelling Type 0018 CROMBIE STREET in the CITY OF SALEM - - -- - - -------------- -- -- - - - ------ Address Town/City Name r IS HEREBY GRANTED A TEMPORARY CERTIFICATE OF OCCUPANCY 30 DAY TEMPORARY This permit is granted in conformity with the Statutes and ordinances relating thereto, and expires _ Tuesday Jan 24,2006 unless sooner suspended or revoked. Expiration Date Issued On:Thu Dec 21,2006 -------- -- --------------- -- -- --- GeoTMS®2006 Des Lauriers Municipal Solutions,Inc. - `y�yuu��.=,� �� �S1yM0 ��� •• . 0 o y �rs�s: :.�'' � � x u 0018 CROMBIE STREET 304-05 GIS#: _J4029--, - COMMONWEALTH OF MASSACHUSETTS Map: �6 CITY OF SALEM Block: Lot: — -- - -- -[0452_ — --- -- Permit#CategoryREPAIR REPLACE BUILDING PERMIT Permit# '304-OS Project# JS-2005-0319 Est. Cost: IS20.000.00 Fee i$185.00 Const Class: PERMISSION IS HEREBY GRANTED TO: :Use Group: ! Contractor: License: — -- -- Lot Size(sq. ft.) 11800 JOHN GOFF Architect- 9251 Zoning: B5 Owner: HABITAT FOR HUMMANITY oa Units Gained:_ Applicant: JOHN GOFF Units Lost: I Dig Safe#: -- ---AT: 0018 CROMBIE STREET ISSUED ON 17-Sep-3004 AMENDED ON: EXPIRES ON: I7-Mar-2005 S TO PERFORM THE FOLLOWING WORK: 304-05 HOUSE RESTORATION TJS POST THIS CARD SO IT IS VISIBLE FROM THE STREET Gas Plumbing. : _ - - Buildin ' Electric Underground: ! ground: Underground: Excavation: ix Servicer=a-L"—'i6 M ler. L�" Poolings: Rough J 6-O� Rough: P, O(( �3 Rou h Foundation: Final: Final: Final: Rough Frame: a IF Lpe Fireplace/Chimney: !/ D iO D.P.W. Fire Health Insulation: Meter: Oil: D House p Smoke: Final:.._,_.- Treasury: Water: Alarm: 'Sewer: Spriukl-:rs: y THIS PERMIT MAY BE REVOKED BY THE CITY OF SALEM UPON O"LAT�IO OOF ITS RULES RULES AND REGULATIONS. sf - Signature: r Fee Type: Receipt No: Date Paid: Check No: Amount: BUILDING REC-2005-000353 17-Scp-04 825 5185.00 i I GcoT.\ISCg,2004 Des I.auriers Municipal Solutions.Inc. ��OMDIT�� CITY OF SALEM MASSACHUSETTS go" -� �'tG„ PUBLIC PROPERTY DEPARTMENT =' 120 WASHINGTON STREET, 3RD FLOOR - ��`', yb c SALEM, MA 01 970 TEL. (978)745-9595 EXT. 380 - FAX (978) 740-9846 STANLEY J. USOVICZ, JR. MAYOR April 2, 2003 Holyoke Square Inc. Holyoke Square ATTN: Jean Dennis Salem, Ma. 01970 RE: 18 Crombie Street Dear Owners: The building at 18 Crombie Street has been vacant and unused for several years. The State Building Code 780, CMR requires the owner of a building to keep that building safe and secure. To date, I think your company has met that requirement. The reason I am writing, is to make your company aware of emergency regulations that were adopted by the B.B.R.S. back on April 10, 2001 after the Worcester fire. The new requirements require the owner of a vacant building to provide a monitored intruder alarm to alert owners and Fire Department of the presence of an intruder. I have enclosed a copy of the building code regulations. Thank you in advance for your anticipated cooperation in this matter. If you have any questions, please contact me. Sin ely, Thomas St. Pierre Acting Building Commissioner cc: Mayors Office Tom Phillbin Electrical Department Fire Prevention BY EMERGENCY ACTIONS OF THE BOARD OF BUILDING REGULATIONS AND STANDARDS -VOTED AT THE DECEMBER 12, 2000 MONTHLY MEETING OF THE BBRS AND FURTHER REVISED AT THE APRIL 10,2001 MEETING OF THE BBRS Amend 780 CMR Chapter 1. & 121 by adding two new subsections: (1) 121.7 and (2) 121.8. 780 CMR 121.7 Standards for making buildings safe or secure: Any owner of a building who has been notified that said building shall be made safe or secure under 780 CMR 121.2, shall: (1) Remove all materials determined by the head of the fire department or building official to be dangerous in case of fine. (2) Secure all floors accessible from grade utilizing one of the following methods so long as such method is approved by the head of the fire department and local building official in writing: (a) Secure all window and door openings in accordance with the U.S. Fire Administration,National Arson Prevention Initiative Board Up Procedures,continuously until sucli time as the building is reoccupied, or; (b) Provide 24 hour watchman services, continuously until such time as the building is reoccupied,or; (c) Provide a monitored intruder alarm system at the perimeter of all floors accessible from grade, continuously until such time as the building is reoccupied. Said owner, as the case may be, shall notify the building official that the approved method chosen to secure the building has been incorporated. Said owner shall allow the building official to enter the building for an inspection to ascertain that the building is secured and made safe. Said owner shall allow the head of the fire department to enter the building. The building official shall be supplied with records of maintenance and operation if the provisions in clause 2(b)or 2 (c)are used. (3) Maintain any existing fire alarms or sprinkler systems unless written permission is obtained from the head of the fire department in accordance with M.G.L.c. 148, § 27A to shut off or disconnect said alarms or systems. (4) Maintain utilities unless written permission is obtained from the building official to disconnect said utilities. Permission to disconnect utilities shall not be granted if it will result in inadequate heat to prevent freezing of an automatic sprinkler system or inadequate utilities to maintain any other protection systems. (5) The requirements of 780 CMR 121.7 (1) - (4) do not prevent a building official from ordering or taking expeditious,temporary security measures in emergency situations pending the completion of the requirements of 780 CMR 121.7 (1)- (4). For the purposes of 780 CMR 121.7(5), an "emergency situation" shall be defined as: an unexpected incident,which by its very nature may present a threat to public safety personnel who may be required to affect a rescue effort or conduct fire extinguishment operations. Upon refusal or neglect of said owner to comply with such notice, any building official acting under the authority of 780 CMR 121.3 or 121.5,shall cause to be secured all window and door openings accessible from grade in accordance with the U.S. Fire Administration National Arson Prevention Initiative Board up Procedures or other equivalent procedure approved by the head of the fire department, continuously until such time as the building is reoccupied. Any building which has been made to conform to the provisions of this regulation during vacancy may be reoccupied under its last permitted use and occupancy classification, provided that any systems which were disconnected or shut down during the period of vacancy are restored to fully functional condition and subject to 780 CMR 111.2 and MGL Chapter 40A. The local building official shall be notified in writing prior to re- occupancy. If said building is changed in use or occupancy or otherwise renovated or altered it shall be subject to the applicable provisions of 780 CMR 34. 780 CMR 121.8: Marking or identifying certain buildings that are especially unsafe in the case of fire. Any building official who determines that a building is especially unsafe in case of fire undei 780 CMR 121.2, shall notify the head of the fire department about the existence of said building. The building official,in cooperation with the head of the fire department, shall cause said building to be marked in accordance with the marking requirements established by the Board of Fire Prevention Regulations in 527 CMR 10.00. Cttp of *aYem, 41ag5atbu5etV5 ` Public Propertp Department r � jguilbing Department one 6alem green (978) 745-9595 &1. 360 Peter Strout Director of Public Property Inspector of Buildings Zoning Enforcement Officer June 8, 2001 Crombie St. Neighborhood Assoc. RE: 18 Crombie Street To Whom it May Concern: This office has performed a number of survey inspections on the above referenced property and found that the building is not condemable at this juncture according to the criteria setforth by the Massachusetts Building Code CMR 780, Chapter 1. Sincerel Peter Strout Building Commissioner LUNDREGAN LAW OFFICES WILLIAM J.LUNDREGAN THE KINSMAN BUILDING TELEPHONE(978)741.3888 JANET.LUNDREGAN 81 WASHINGTON STREET FACSIMILE(978)741-8110 SALEM,MASSACHUSETTS 01970 Email:wjl@lundmganlaw.wm January 17, 2001 c-� s � C— MS. Deborah E. Burkinshaw — City Clerk 00 r r City Hall " D M" Salem,MA 01970a c.n > RE: Abandoned Building on Crombie Street Dear Ms. Burkinshaw: As you know, I represent Holyoke Mutual Insurance Company. Holyoke has received a request to attend a meeting of the City Council Committee on Government Services on Thursday, January 18, 2001, at 6:00 p.m. I regret to inform you that we are unable to attend the Committee meeting. This matter is presently before the Appeals Court for the Commonwealth of Massachusetts, and I believe it would be inappropriate for Holyoke or myself to make comments while this matter is in litigation. You may inform the Committee that we are in the process of ongoing discussions with the Legal Department of the City of Salem. If any member of the Committee should have any..questions, please do not hesitate to contact me. Veryly your ; ---` WlL IAM J. LUNDREGiIN WIL/cr CITY OF SALEM - MASSACHUSETTS WILLIAM J. LUNDREGAN Legal Department JOHN D. KEENAN City Solicitor Assistant City Solicitor 91 Washington Street 93 Washington Street 15 Church Street Tel:978.741-3888 Salem, Massachusetts 01970 Tel:976-744-8500 Fax:978-741-8110 Fax:978-744-0111 October 28, 1998 Building Inspector's Office Kevin Goggin One Salem Green Salem, MA 01970 RE: HOLYOKE MUTUAL FIRE INS. CO., INC. v. SALEM REDVELOPMENT AUTHORITY AC No. 98-P-1671 Dear Kevin: As recently discussed, the above captioned matter which pertains to 18 Crombie Street has been scheduled for Appeals Mediation on November 17th. Prior to that, I would like to have the premises reinspected and a determination made of its "dangerousness" pursuant to Mass. Gen. L. c 143. What, if anything, needs to be done to make this property safe? Is it in such a state of disrepair at this time that it is appropriate to order demolition of the premises? Holyoke has agreed to such an inspection. Please coordinate directly with Jean Davis (740-2205) at that office at your earliest convenience. The results from the inspection will be necessary to proceed on an informed basis. Thank you for your attention to this matter. Do not hesitate to contact me with any questions. Ve st regards, Jo D. Keenan, As i tant City Solicitor JD jm.salem cc. Webb F. Primason, Esq. �. CITY OF SALEM - MASSACHUSETTS /ot 0"L WILLIAM J.LUNDREGAN Legal Department JOHN D. KEENAN City SolicitorAssistant City Solicitor 81 Washington Street 93 Washington Street 15 Church Street Tel:978-741-3888 Salem, Massachusetts 01970 Tel:978-744-8500 Fax:978-741-8110 Fax:978-744-0111 October 16, 1998 RE; Holyoke v, City ofSalem /SRA 18 Crombie Street Dear Mayor Usovicz: This matter has made its way to the appeals court. A mediation will soon be scheduled to see if there is any way to resolve this matter short of a full-blown hearing before the Appeals Court. Briefly, you may recall this case essentially boiled down to Holyoke purchasing the property and wanting to tear down 18 Crombie to landbank for future use and in the short-term use for extra parking. The SRA opposed the demolition and former Building Inspector Munroe made the determination that is was not an "unsafe" building needing to be torn down. I do not believe it has been reinspected in since other than the outside porch, which was recently torn down. Judge vanGestel in his decision upheld the power of the SRA to oppose the demolition and the discretion of the building inspector to make the determination of"safe." Although we "won"the court decision, I must agree with Judge vanGestel's comments (footnote 4 attached), that nobody, neither the citizens of Salem nor Holyoke, have gained much from this seemingly endless legal odyssey. At this time, even if we are upheld on appeal – which I think we will be – 18 Crombie Street will decay until we have no option but to order it torn down. It is my opinion that we should attempt to bring the parties together again at this time to see if anything is possible to finally bring some closure to this matter. I would like to set up a meeting with you, Craig Wheeler, Peter Strout, Tim Clarke, President of Historic Salem, Inc., head of Historical Commission, Doug Ryder, President Holyoke and counsel Webb Premason. I-Wo that the new building mspeetor to a look at=the structure before our.I eeting? �h_It Is his opinion that thls bullding� s unsafe,._Itsho d be-d ed If ofd —we sshould discuss other options. -- Please contact me at your convenience so that we may discuss this matter. As you know, Bill Lundregan previously represented Holyoke. Obviously, he has withdrawn from the case and has had absolutely no input on this matter since that time. I do not even talk to him about it in our case discussions. Thank you for your attention to this matter. Ve b t regards, Jo n . Keenan, Ass nt City Solicitor JDK/kjm.salem ENC. I 18 it ever arises, or the hands of this Court if it is that next judge, should not be. tied by this non-disposition of the issue today. No declaratory r . judgment shall be rendered. ORDER FOR JUDGMENT'S In case number 91-2352-A judgment shall be entered for the defendant dismissing all counts of the complaint. In case number 92-0688-A judgment shall be entered for the defendants dismissing all counts of the complaint.4 Allan van Gestel Justice of the Superior Court DATED: July 30, 1997 4 The Court is well aware, and regrets, that the foregoing disposition of these two casest does little to resolve the underlying issue of the fate of the building at 18 Crombie Street ini Salem. The City seeks to preserve the building for historical purposes, but has declined to take it by eminent domain or even establish the area as an historic district under G.L. c. 40C. `t City e that it can -- unfair) y .., Y seems to hope yin the Courts view -- force Holyoke Square to do theublic's work, at Holyoke Square's P y q private expense, and repair and restore the building. Holyoke Square, which presumably bought the building with its eyes wide open, `t cannot be forced to make repairs and can, if it chooses, continue to allow the building to deteriorate until such time as the Building Inspector must do more than look the other way NF and issue a demolish or repair older under G.L. c. 143, sec. 6. Neither Holyoke Square nor N.- the citizens of Salem have gained much from this seemingly endless legal odyssey. But the Court can do no more -- and should do no more -- than decide the issues brought before it as € k the law dictates. r�: of �ttlEm, fflttssttr4usEttli Public Propertg Department Department line #alem l4reen 588-745-9595 L-xt. 388 Leo E. Tremblay Director of Public Property Inspector of Building Zoning Enforcement Officer August 10, 1995 Holyoke Square, Inc. Holyoke Square Salem, M.A 01970 RE: C18_Crombie St. , Salem, To Whom Ever It May Concern: This office has received complaints concerning the above mentioned property. On August 10, 1995, I conducted an inspection and found that the rear porch post, supporting the roof structure, is in an unsafe condition and must be repaired immediately. Please contact this office upon receipt of this letter to inform us of your course of action in this matter. Failure to do so within fifteen (15) days will result in court action being taken against you. Thank you for your anticipated cooperation regarding this matter. Sincerely, Leo E. Tremblay Building Inspector LET/jmc cc: Councillor Donahue Councillor Harvey LUNDREGAN L A W O F F I C ES THE KINSMAN BUILDING WILLIAM J. LUNDREGAN 81 WASHINGTON STREET TELEPHONE (508) 741-3888 JANE T LUNDREGAN SALEM, MASSACHUSETTS 01970 FACSIMILE (508) 745-3607 August 29, 1995 Leo E. Tremblay Director of Public Property Inspector of Building Zoning Enforcement Officer One Salem Green Salem, MA 01970 RE: 18 Crombie- Street, Salem, MA s Dear Mr. Tremblay: Please be advised that I represent Holyoke Square, Inc. , Holyoke Square, Salem, MA 01970 and they have forwarded to me your correspondence to them dated August 10, 1995. Since I have just returned from vacation and our Architect, Charles DeMarco of DeMarco/Jarek Partnership, 233 Derby Street, Salem, MA, is''currently 'on vacation—until September 5, 1995, be assured that upon Mr. DeMarco' s return we will have a meeting to discuss the appropriate course of action to be taken pursuant to your Order dated August 10, 1995, pursuant to M.G.L. Chapter 143. If you have any questions with reference to this matter, please do not hesitate to call me. Ver trul yo , W IAM J. LU DR AN WJL/amp (jA4Pe'1nw)'479 Tito of �ttlem, mttssocl�usEttsPublic Propertp Department +'Builbin9 p i9e artment (One *nlem (5reen 508-745-9595 Ext. 300 Leo E. Tremblay Director of Public Property Inspector of Building Zoning Enforcement Officer August 10, 1995 Holyoke Square, Inc. Holyoke Square Salem, MA 01970 RE: 18 Crombie St. , Salem, 1•A To Whom Ever It May Concern: This office has received complaints concerning the above mentioned property. On August 10, 1995, I conducted an inspection and found that the rear porch post, supporting the roof structure, is in an unsafe condition and must be repaired immediately. Please contact this office upon receipt of this letter to inform us of your course of action in this matter. Failure to do so within fifteen (15) days will result in court action being taken against you. Thank you for your anticipated cooperation regarding this matter. Sincerely, Leo E. Tremblay Building Inspector LET/jmc cc: Councillor Donahue Councillor Harvey POSTAGE POSTMARK 00 DATE RETURN SHOW TO WHOM,DATE AND RESTRICTED w RECEIPT ADDRESS OF DELIVERY DELIVERY - Q CERTIFIED FEE+RETURN RECEIPT W N SERVICE >w � TOTAL PoSIAGE AND FEES NOINSURANCE DON RAG RGVIGEO- w¢ Ir SENT TO. NOT FOR INTERNATIONAL MAIL OQ r— ISFE MFR RIM wa _ , O� Holyoke Square, Inc. a o Holyoke Sq'uake '. . .,, WI, a SAlem, AIA 09170 F O ru � W2 U QW PS FORM 3800 a RECEIPT FOR CERTIFIED MAIL o Up. PoNRo�,NE. 2 su seance ------------------ I I STICK POSTAGE STAMPS TO ARTICLE TO COVER FIRST CLASS POSTAGE, CERTIFIED MAIL FEE,AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES(see front). 1. If you want this receipt postmarked,stick the gummed stub to the right of the return address of the article,leaving the receipt attached,and present the article at a past office service window or hand it to your rural carrier(no extra charge). 2. If you do not want this receipt postmarked,stick the gummed stub to the right of the return address of the article,date,detach and retain the receipt,and mail the article. 3. If you want a return receipt,write the certified-mail number and your name and address on a return r, receipt card,Form 3811,and attach it to the front of the article by means of the gummed ends it space permits.Otherwise,affix to back of article.Endorse front of article RETURN RECEIPT REQUESTED adjacent to the number. 4. If you want delivery restricted to the addressee,or to an authorized agent of the addressee,endorse RESTRICTED DELIVERY on the front of the article. 1 5. Enter fees for the services requested in the appropriate spaces on the front of this receipt.If return' receipt is requested,check the applicable blocks in item 1 of Form 3811. 6. Save this receipt and present it if you make inquiry. ' SENDER: • Complete items 1 and/or 2 for additional services. I also wish to receive the • Complete items 3,and as-a o following services(for an extra fee): • Print your name and address on the reverse of this form so that we can return this card to you. 1. ❑ Addressee's Address • Attach this form to the front of the mailpiece,or on the back if space does not permit. • Write"Return Receipt Requestetl'on the trendless below the article number. 2. El Restricted Delivery • The Return Receipt Fee will provide you the signature of the person delivered to and the date of deliver . Consult postmaster for feg. 3.Article Addressed to: T.; 4a.Article Number �{ P 921 991 798 ti^A";x OYC<t S+fS3rfL,. `k:. KW_.. 46.Service Type 4 yoke. Sq NA 09170 � CERTIFIED ; 7.D Deliv Jh/ 5.Sign lure—(A(dressee) 8.A res M e's Address I (ONLY if requested and lee paid.) 6.Signature—(Agent) II I PS Form 3811,November 1990 DOMESTIC RETURN RECEIPT I !f I pUnited States Postal Service Ip Official Business PENALTY FOR PRIVATE USE,$300 Illwu�l�l��nl�ulll�unll��wlul�l�lull�nll INSPECTOR OF BUILDINGS ONE SALEM GREEN SALEM MA 01970-3724 e CITY OF SALEM - MASSACHUSETTS ROBERT A. LEDOUX Legal Department JOHN D. KEENAN City Solicitor 93 Washington Street Assistant City Solicitor 314 Essex Street Salem, Massachusetts 01970 15 Church Street assacuses 508-741-2111 508-744-8500 August 4, 1997 Leo Tremblay, Bldg. Inspector One Salem Green Salem, Massachusetts 01970 RE: Demolition of 18 Crombie Street Dear Leo: Please find attached decision I recently received from the Court on the above captioned matter. I think you will find it interesting reading. It discusses your discretion as Building Inspector to determine what buildings are a"danger." The Court upheld Inspector Munroe's decision that 18 Crombie was not a danger. The decision also reviews some definitions of danger. Especially interesting is Judge vanGestel's comments in Footnote 4 at the end of the decision. I am not sure what Holyoke will do from here, but I do not think this issue is resolved yet. Thank you for your attention to this matter. Ve best regards, Jo n . Keenan JDK/kjm Enc. COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTIONS NO. 91-2352-A and NO. 92-0688-A HOLYOKE SQUARE,INC. V. SALEM REDEVELDPMENT AUTHORITY and HOLYOKE SQUARE,INC. V. STATE BUILDING CODE APPEALS BOARD, et al. FINDINGS. RULINGS and ORDER FOR JUDGMENT These two cases, tried together before the Court without a jury, involve the future of a simple, old house at 18 Crombie Street in the heart of the historic City of Salem, Massachusetts. The plaintiff, the house's present owner, believing it to be hazardous and beyond repair, wants to proceed with its demolition. The City of Salem, acting through its Redevelopment Authority, with encouragement from its Historical 2 Commission, wants the house preserved as a part of a Crombie Street historical district. The City's Building Inspector refuses to issue an order that the house be demolished; and the State Building Code Appeals Board supports that decision. The action against the Redevelopment Authority (the "SRA") is, for the most part, in the nature of certiorari. The plaintiff ("Holyoke Square") charges that the SRA's decision was in excess of its authority, unsupported by substantial evidence, arbitrary and capricious, and otherwise contrary to law. The claim involving the State Building Code Appeals Board (the "Appeals Board") and the Salem Building Inspector (the "Inspector") is an appeal pursuant to G.L. c. 30A, sec. 14 from the decision of the Appeals Board supporting the Inspector, although it also raises certiorari issues and requests declaratory judgment relating to the supremacy of the determination of the Inspector over that of the SRA. FINDINGS OF FACT Holyoke Square, Inc. is a Massachusetts corporation doing business at Holyoke Square in Salem, Massachusetts. Holyoke Square is controlled by the Holyoke Mutual Insurance Company, a long-time, respected corporate citizen of Salem. The house at 18 Crombie Street is located at and on the northeast corner of a parking lot across Norman Street from Holyoke Mutual's principal place of business. Both the house and the parking lot are owned by Holyoke Square. 3 The Salem Redevelopment Authority is a public authority corporate and politic, organized under the General Laws of Massachusetts. Crombie Street is located within the Heritage Plaza West Urban Renewal Plan promulgated by the SRA and, thus, both the street and the house at number 18 are, for certain purposes, within the regulatory jurisdiction of the SRA. The State Building Code Appeals Board is an administrative agency within the Massachusetts Executive Office of Public Safety. The Appeals Board is empowered by law to make regulations and to conduct adjudicatory proceedings relative to the interpretation of the State Building Code and related laws. The house at 18 Crombie Street is not located in any official historic district of the City of Salem such as those provided for in G.L. c. 40C; nor is the house a designated National Historic. Register property under 16 U.S.C. sec. 470, et seq. Crombie Street itself, however, is part of a National Register designated federal historic district, and 18 Crombie Street is considered part of the Crombie Street Historic District (the "District"). The National Register designation came about as a result of a 1979 request by the SRA to the Massachusetts Historical Commission. The request was granted on September 16, 1983, five years before Holyoke Square purchased the property at 18 Crombie Street. The Crombie Street Historic District is composed of the eight remaining buildings of this downtown residential enclave. The District includes a cross-section of residential buildings from various periods of 4 - development, along with a church originally built as a theater. The boundaries of the District include the six buildings that face Crombie Street -- including number 18 -- and two buildings at the west end of Barton Square, adjacent to Crombie Street on the west. Crombie Street was laid out in 1805 by Benjamin Crombie, proprietor of the "Sign of the Ship," a tavern that stood on Essex Street, east of his new street. Between 1805 and 1815, Crombie sold four house lots behind his tavern, as well as narrow strips of frontage on the street to other landholders to the west. Only two of the houses standing today were built before Crombie sold the remaining property in 1819. The District, however, was still shown intact on the 1851 map of Salem. As the only surviving downtown residential group from the early 19th century, the houses on Crombie Street are said by the Massachusetts Historical Commission to provide important information about the character of the City of Salem at that time. All the buildings directly abut the sidewalk, suggesting high density, but placement on the lots is irregular, creating a rural atmosphere. Wood is the dominant building material, although the church and one house -- called the Bowker House -- are brick, as is the Prince House that predates Crombie's activity. _ While the architectural quality within the District is said to be variable, three buildings clustered at its north end are all considered individually noteworthy. The Crombie Street Church, built as a theater in 1828, is the architectural highlight of the District. It is described as having monumental relieving arches on its facade that define its 5 composition and suggest the Federal style, but the panelled detailing of the broad piers separating these arches, along with a pair of quadrant windows 1n the gable and wide corner pilasters, are suggested to introduce a newer Greek Revival influence. Neighboring the church stands the substantial Bowker House, built in the Federal style around 1810. It was "modernized" in 1860 by overlaid brimstone trimmings. The hybrid design of Bowker House is considered very successful, reinforcing the central importance of this house to the District. The Pierson House, facing Barton Square, is called an unusually graceful vernacular Italianate residence, typical of the residences that lined Barton Square in the mid-19th century. The house at 18 Crombie Street is a bit of an onion in a petunia patch. It is a quite small, two-story, gambrel-roofed, Georgian house, the origins of which are unknown. The house is believed to have been moved to the site in 1830 by James Bott. The end wall faces Crombie Street and contains three six-over-six windows, vertically aligned and centered on the wood-shingled wall. A narrow, simple framed doorway that crowds the right corner is believed to have been added when the house was moved to the site. A massive central chimney is readily visible from the street. A small ell with a shallow pitched roof extends to the left, set back fifteen feet from the front wall. The house at 18 Crombie Street is perhaps most historically _ useful as an example of how simple working people lived at the time. _ 6 There is little evidence that persons of note ever resided there.l That latter point, to this Court, however, is of no moment. History benefits from an understanding of how everyone existed, not just the rich or famous. No persons "of note" are identified as having greeted the Mayflower when she landed at Provincetown, or later at Plymouth, but history certainly has been well served by knowing how and where those truly native Americans lived. Holyoke Square purchased 18 Crombie Street from the Naumkeg Trust Company, the latter acting as Trustee of the Frances H. Wendt Realty Trust, on February 16, 1988. The purchase price was $169,000. At the time of Holyoke Square's purchase, immediately adjacent to 18 Crombie Street on the south was, and still is, a parking lot, bounded by Crombie Street on the west and Norman Street on the south, owned by Holyoke Square. In the midst of the parking lot, on the east side, is a facility described as an auto laundry. Across Crombie Street from the parking lot is a small strip mall including a White Hen Pantry convenience store. Very little is left in the area snaking up the Crombie Street District in light of the many past changes approved by the SRA in and around the neighborhood. Those changes have included: demolition of a building at the corner of Essex and Washington Streets, leaving a vacant lot known as Lappin Park; demolition of a cafe and a diner on Norman Street, next to a Dunkin' Donuts, and construction of multi-level 1 The SRA offered some evidence that William B. Pike resided at 18 Crombie Street from 1853 through his death in April, 1876. Mr. Pike was Collector of Ports for Salem and Beverly throughout President Buchanan's administration and is said to have been close friends of Nathaniel Hawthorne and President Pierce. . The title history from 1806, after the date of Crombie's purchase, describes subsequent owners as: a merchant, a trader, a saddler, a chaise maker, a painter, a weigher and gauger, a physician, a carpenter, a widow, and a telephone answering service operator. residential housing in their place; demolition of a gasoline service station at the corner of Crombie and Norman Streets, and subsequent construction of a small strip mall and parking lot; renovation of the old Salem Theater, on Essex Street, and demolition of the buildings next door; and demolition of the buildings on the corner of Essex and Crombie Streets, and subsequent use of the land as a parking lot. After purchasing 18 Crombie Street, Holyoke Square explored possible uses by .it for the building. Included in its ideas were use as a conference center or as office space, however, consultation with experts in the building construction business quickly led Holyoke Square to the conclusion that the repairs that would be necessary to make the building useable were economically unfeasible. One source suggested that the building had a fair market value of $154,600 but would require the expenditure of an additional $113,100 to make the necessary repairs before the building would be habitable. Other cost estimates were even higher. In September, 1990, Holyoke Square received a report from DeMarco/Jarek Partnership, architects and engineers in Salem with particular expertise in renovating and evaluating old and historic buildings. The DeMarco/Jarek report catalogued numerous deficiencies found at 18 Crombie Street. Included were: serious problems with the roof; marginal condition, at best, of the principal chimney; peeling paint and rotting conditions on the exterior walls; electrical entrance cables in poor condition and rotting service cables; collapsing brick and block foundations on the front and left sides; wooden gutters rotting, and copper gutters improperly spaced too close to all fascias; downspouts in 8 marginal condition; improperly sloped grading around the foundation; rear stairs rotting; thresholds rotting; all windows in poor condition; entry doors not square; flashing around doors and windows in poor condition; foundation walls collapsing; evidence of insect damage; unlevel floors; loosened plaster throughout; electrical outlets in poor condition and limited in number; chimney flues in need of lining; sagging floors and ceilings; all plumbing in need of replacement; insulation in poor condition; and heating, plumbing, water and eletrical systems inoperative. Holyoke Square also presented evidence by Nucci Vine Associates, structural engineers, to the effect that the building is tilting over at the rate of 1/4" to 1/2" per year. Nucci •Vine Associates opined that conditions of the foundation require reconstruction and repair to insure a safe and stable foundation structure prior to any occupancy of the house. R. Eric Rumpf, of Rumpf & Associates, who originally advised the Inspector, testified that the structure falls substantially short of satisfying the generally safe and acceptable requirements of the Massachusetts State Building Code. The Court, with counsel and their experts, took a view of the premises at the time of the trial in April, 1997. In the course of the visit, concern was expressed that the upstairs flooring might not be able to support the weight of the visitors. The observations by the Court's untrained eye confirmed, in essentially all respects, the findings in the reports and testimony of Holyoke Square's experts. 9 After concluding that demolition was its preferred alternative to attempting the extensive repairs neccessary at 18 Crombie Street, Holyoke Square, on May 28, 1991, appeared before the SRA, and a hearing was held on its application for permission to remove the building. Holyoke Square argued that it was too costly to renovate the property and that its plan was to create additional parking spaces for employees and ultimately landbank for future development. The SRA voted 4 to 1 to deny the application. Earlier, on April 12, 1991, the Salem Historical Commission voted against the demolition of 18 Crombie Street because of the Commission's belief that the property was an historically significant building within the District. The SRA's vote was premised on its consideration of the historical significance of the property, its view of the structural soundness of the building, and its general opposition to landbanking with no immediate plans for redevelopment. By letter dated August 5, 1991, Holyoke Square's architects formally notified the Inspector that "the building located at 18 Crombie Street is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area." The architects' letter concluded with a recommendation "that your department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M.G.L. Ch. 143, Sec. 6." On August 18, 1991, the Inspector and Holyoke Square's architect made an inspection of 18 Crombie Street. Shortly thereafter, on August 29, 1991, the Inspector declined to issue an order to Holyoke Square to remove the structure or make it safe. The Inspector concluded 10 that, "although this single family house has a number of problems, it has not deteriorated to the point of being a hazard to the public safety and welfare, and to order its demolition at this time would be premature." Holyoke Square appealed the Inspector's decision to the Appeals Board, and an adjudicatory hearing was held on February 11, 1992. At the hearing Holyoke Square presented the reports of its experts concerning the condition of the house. On June 3, 1992, the Appeals Board issued a decision denying Holyoke Square's appeal and affirming - the decision of the Inspector. - Since the decisions noted above, nothing has been done to the property at 18 Crombie Street by Holyoke. Square other than boarding up the windows and blocking its entrance. Thus, the deterioration that comes with time moves inexorably, albeit slowly, forward. RULINGS OF LAW The Court, in making its rulings of law, will treat the two cases in the chronological order of their filing, which mirrors their evolution in the process. The Salem Redevelopment Authority Case This case involves issues surrounding the propriety of the action by the SRA, in May of 1991, when it voted to deny Holyoke Square's 11 application for permission to demolish the building at 18 Crombie Street. The SRA is a public authority organized pursuant to G.L. c. 121B, secs. 4, 9 and 11. As such, it developed the Heritage Plaza West Urban Renewal Plan in the City of Salem for the purpose of establishing standards and controls for the redevelopment and renewal of properties within its boundaries. The house at 18 Crombie Street is wholly within the boundaries of Heritage Plaza West. The legislative purpose of G.L. c. 121B is to promote sound community growth. Boston Redevelopment Authority v. Charles River Park "C" Company, 21 Mass. App. Ct. 777,, 783 (1986). Included among the powers of the SRA within the Heritage Plaza West area is the oversight of demolition and removal of buildings and improvements. See G.L. c. 121B, sec. 46(b). - This case principally is an action in the nature of certiorari under G.L. c. 249, sec. 4. It lies only where the petitioner, here Holyoke Square, has exhausted all administrative remedies. Carney v. Springfield, 403 Mass. 604, 605 (1988). In a certiorari case a court will correct only a substantial error of law, evidenced by the record, which adversely affects the material rights of the plaintiff. Id. In doing so, the Court may only rectify those errors of law "which have resulted in manifest injustice to the plaintiff or which have adversely affected the real interests of the general public." Id. i 12 Holyoke Square argues, and the Court agrees, that the scope of judicial review in an action in the nature of certiorari is whether there was substantial evidence to support the SRA's decision, citing Boston Edison Co. v. Boston Redevelopment Authority, 374 Mass. 37, 47-54 (1977). See also Doherty v. Retirement Board of Medford, 425 Mass. 130, 135 (1997); Benevolent and Protective Order of Elks v. Planning Board of Lawrence, 403 Mass. 531, 539-543 (1988). "Substantial evidence" is such evidence"as a reasonable mind might accept as adequate to support a conclusion." Jordan Marsh Co. v. Labor Relations Commission, 316 Mass. 748, 756 (1944). Under the substantial evidence test, however, a reviewing court is not empowered to make a de novo determination of the facts, to make credibility choices, or to draw different inferences from the facts found by the agency. DoheIU v. Retirement Board of Medford, supra, 425 Mass. at 135. "When the contention is made that an agency has acted arbitrarily or capriciously, or that the agency had abused its discretion, . . . , the aggrieved party making the contention is fundamentally charging that the agency's decision for one reason or another is unreasonable." Cella, Administrative Law and Practice, 40 M.P.S. sec. 1574. Although it is a close issue, this Court cannot, and does not, find that as a matter of law there was insufficient evidence in May of 1991 to support the SRA's decision or that it was abitrary or capricious in its conclusion to 13 deny the application to demolish the property at 18 Crombie Street.2 Although not part of a c. 40C historic district, it cannot be said that there wasn't ample evidence of historical interest in the property. Further, the Inspector had not then, nor has he now, found the property to be so dangerous as to order it demolished or repaired. Additionally, Holyoke Square's lack of a plan for the site, other than expanding a parking lot and landbanking, cannot be overlooked. Holyoke Square also poses the possibility that the SRA's action has the effect of an administrative taking of the 18 Crombie Street property because it prevents the preferred use thereof by its owner. The Supreme Judicial Court spoke on this subject just days ago. Its decision in Daddario v. Cape Cod Commission, 425 Mass. 411 (1997) provides the answer to why there is no administrative taking here. It said that [t]his court has repeatedly recognized that government regulations "may deprive an owner of a beneficial property use -- even the most beneficial such use -- without rendering the regulation an unconstitutional taking." . . . "Land use planning is not an all-or-nothing proposition. A government entity is not required to permit a landowner to develop property to [the] full extent he might desire or be charged with an unconstitutional taking of the property." . . . That an alternative, permissable use might be less profitable is not determinative. Id. at 416-417 2 Holyoke Square contends, among other things, and the then Chair of the SRA seems to have conceded, that in voting to deny the application, the SRA applied a different standard of reasonableness to Holyoke Square's request because it was a corporation rather than an individual. The Chair admitted that the SRA felt that it would have a right to expect Holyoke Square to expend more money on restoration of the house than it would expect of an individual owner. This attitude by the SRA is to be condemned. All citizens, rich and poor, corporate or individual, come before the government with equal standing and are entitled by our Constitutions, State and Federal, to equal treatment. This Court will tolerate nothing less. Having stated its position, however, the Court still finds sufficient evidence to support the SRA's decision and concludes that its determination was not unduly affected by its improper assumption that it could expect more from a corporation than an individual. 14 The Case against the Building Inspector and the State Building Code Appeals Board The challenge to the decision of the State Building Code Appeals Board is governed by G.L. c. 30A, sec. 14. The Court is required to give due weight to the expertise, technical competence and specialized knowledge of the agency, as well as the discretionary authority conferred upon it. G.L. c. 30A, sec. 14(7). Similar to the law applicable to the certiorari claim, the Court may not make a de novo determination of the facts or draw different inferences than the agency. Vaspourakan. Ltd. v. Alcoholic Beverages Control Commission, 401 Mass. 347, 351 (1987) Nor may it substitute its judgment for that of the board. Southern Worcester Regional School District v. Labor Relations Commission, 386 Mass. 414, 420-421 (1982). "In the absence of clear error, the interpretation an administrative body gives to its own rule is entitled to deference." Purity Supreme. Inc. v. Attorney General, 380 Mass. 762, 782 (1980). In challenging the Appeals Board's decision, Holyoke Square has the burden of demonstrating the invalidity of the Appeals Board's ruling, Faith Assembly of God v. State Building Code Commission, 11 Mass. App. Ct. 333, 335 (1981), and the Court must apply all rational presumptions in favor of the validity of the administrative action. Long v. Commissioner of Public Safety, 26 Mass. App. Ct. 61, 65 (1988). The Appeals Board's decision is subject to reversal only if it is based on an error of law, is unsupported by substantial evidence, or is abitrary or capricious, an abuse of discretion, or otherwise not in 15 accordance with law. Cella, Administrative Law and Practice, 40 M.P.S. sec. 1567. Holyoke Square contends that the Appeals Board, and the Inspector, both committed legal error when they concluded that the building at 18 Crombie Street had to be in imminent danger of collapse, and it was not, although all parties had acknowledged the building's deteriorating condition. Holyoke Square points out, correctly, that the statute, G.L. c. 143, sec. 6, does not require that a building be in an "imminent" danger of collapse before the local Building Inspector should issue a demolition or repair order.3 See, "., Ribeiro v. Town of Granby, 395 Mass. 608, 612 (1985). The pertinent language of G.L. c. 143, sec. 6 reads: The local inspector, immediately upon being informed by report or otherwise that a building . . . in that city or town is dangerous to life or limb or that any building in that city or town is unused, uninhabited or abandoned, and open to the weather, shall inspect the same; and he shall forthwith in writing notify the owner, . . . , to remove it or make it safe if it appears to him to be dangerous, or to make it secure if it is unused, uninhabited or abandoned or open to the weather. . . . (Emphasis added). This case is unusual in that the owner, Holyoke Square, is seeking to have the Inspector directed to order it to demolish its own building. The more usual course is for an owner to resist and appeal from such an order. No cases suggesting when the Inspector must order a building to be demolished have been brought to the attention of the Court, or found 3 The fact that 18 Crombie Street was not in imminent danger of collapse in August of 1991 is borne out by the fact that it is still standing as of the date of these findings and rulings in July of 1997, despite no preservative action by its owner in the meantime. 16 by it. Nor do there seem to be any appellate decisions on the meaning of when a building is "dangerous" as that word is used in G.L. c. 143, sec. 6. Webster's Third New International Dictionary defines "dangerous" as "exposing to danger:. involving risk: demanding caution or care as extremely unsafe: HAZARDOUS, PERILOUS." The Oxford English Dictionary posits: "Fraught with danger or risk; causing or occasioning danger; perilous, hazardous, risky, unsafe." A vessel is considered dangerous or unseaworthy when it is unfit for its intended purpose. Ferrara v. A & V Fishing. Inc., 887 F. Supp. 26 (D. Mass. 1995). On the other hand, a fire-eating act in a hotel was found not "abnormally dangerous," Thomalen v. Marriott Coro., 880 F. Supp. 74 (D. Mass. 1995), while a shopping cart with a broken wheel in a supermarket was. Cronin v. W.A. Foodliner, 55 Mass. App. Dec. 158 (1974). The point is that what is "dangerous" has varied meanings in different contexts. Certainly, 18 Crombie Street today, at least in its interior, is unfit for its intended purpose, and it undoubtedly was in August of 1991. Its exterior also is desperately in need of corrective work. The Court cannot, however, say that it is now, or was then, "dangerous" to the public in general, as opposed to occupants of the building. This is not because the Court has no view on the subject, but rather because it is the determination by the Inspector, not the Court, that is under review. The Court, on the evidence presented, including its own view of the property in 1997, cannot rule that the Inspector abused his important discretion in concluding, with his special expertise, that 18 Crombie 17 Street was not dangerous "to the well-being of pedestrians in the area," to use the words chosen by Holyoke Square's architects, in 1991. See, e.g., n. 3 supra. The matter before the Inspector was not, after all, whether to issue a certificate of occupancy. Nor can the Court conclude that the Appeals Board was wrong in affirming the Inspector's conclusion. There was "substantial evidence," as that phrase is employed in the appellate decisions, to support the declination to issue a demolish or repair order. Insofar as Holyoke Square seeks relief under the certiorari statute, its claim fails because certorari is only available to correct errors of law that are not otherwise reviewable. See Carney v. Springfield,ield, supra, 403 Mass. at 605. Holyoke Square's c. 30A appeal was the appropriate course to follow. See, e.g., She Enterprises. Inc. v. State Building Code Appeals Board, 20 Mass. App. Ct. 271, 272 (1985). Certiorari does not lie here. Holyoke Square also seeks a declaratory judgment to the. effect that a demolish or repair order by the Inspector cannot be overruled or countermanded by the SRA. This may well be the law in the context of an order under G.L. c. 143, sec. 6. The Court's previous statement notwithstanding however, the issue on which the declaration is sought has not been shown to be the subject of a dispute between the SRA and the Inspector. Certainly, no such controversy is presently before the Court. See G.L. c. 231A, sec. 1. "Declaratory judgment, . . . , 'is a vehicle for resolving actual, not hypothetical, controversies."' Boston Herald, Inc. v. Superior Court Department of the Trial Court, 421 Mass. 502, 504 (1995). Thus, the hands of the next judge to hear this issue, when and if 18 it ever arises, or the hands of this Court if it is that next judge, should not be tied by this non-disposition of the issue today. No declaratory judgment shall be rendered. ORDERFORJUDGMENFS In case number 91-2352-A judgment shall be entered for the defendant dismissing all counts of the complaint. In case number 92-0688-A judgment shall be entered for the defendants dismissing all counts of the complaint.4 Allan van Gestel Justice of the Superior Court DATED: July 30, 1997 4 The Court is well aware, and regrets, that the foregoing disposition of these two cases does little to resolve the underlying issue of the fate of the building at 18 Crombie Street in Salem. The City seeks to preserve the building for historical purposes, but has declined to take it by eminent domain or even establish the area as an historic district under G.L. c. 40C. The City seems to hope that it can -- unfairly in the Court's view -- force Holyoke Square to do the public's work, at Holyoke Square's private expense, and repair and restore the building. Holyoke Square, which presumably bought the building with its eyes wide open, cannot be forced to make repairs and can, if it chooses, continue to allow the building to deteriorate until such time as the Building Inspector must do more than look the other way and issue a demolish or repair order under G.L. c. 143, sec. 6. Neither Holyoke Square nor the citizens of Salem have gained much from this seemingly endless legal odyssey. But the Court can do no more -- and should do no more -- than decide the issues brought before it as the law dictates. COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION No. 91-2352B ...............................•--HOLYOKE_SQUARE, _INC......--......._...................,Plaintiff`') U. SAL EMREDEVELOPMENT_AUTHORITY Defendants) JUDGMENT ON ALL COUNTS This action came on for (trial) (:bmidno before the court, van Gestel, , J. presiding, and the issues having been duly (tried) (bmd) and findings having been duly rendered, Itis ODDEaED and ADJUDGED: ( t4t,zW ggt{Qxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx7meEamrxafxEhe YMNK"NxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxXkuxmmzc�Q+.cxxxxxxxxxxxxxxxxxxic x4yMXIVMI;gtxtbwm ttmxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxXANAIMAWMuk$xxxxxxxxxxxxxxx jSttiBtk�yxD �t>�k�l�xtk7s$ou4km�ctf8�) (that the plaintiff Holyoke Square, Inc. take nothing, that the action be dismissed on the merits, and that the defendant Salem Redevelopment Authorityrecover of the plaintiff Holyoke Square, Inc. its Ags costs-of action.) Dated at Peabody Massachusetts, this 30th day of July 19 97., Wstant Clerk V l COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION No. 92-688B HOLYOKESQUARE, INC. ...... . ........ .- ..... ............................,Plaintiffs) U. STATE BUILDING CODE APPEALS BOARD, ET AL .Defendant(s) . ........................... ... . ...... ..... .- ......... - .............. JUDGMENT ON ALL COUNTS This action came on for (trial) i7hXKKKg) before the court, van Gestel J. presiding, and the issues having been duly (tried)xQh'md) and findings having been duly rendered, It is ORDERm and AD1DDcm: MWUWPUKdffxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxicxxxxxxxnvwmmfxtlw dbl xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx4g]SWcgfc$xxxxxxxxxxxxxxxxxxx *M�mmmxdi@g�w4wxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx3gnhg4ww� �c$xxxxxxxxxxxxx a�j�t44�de'tR14j��u?ccxlFn4xEt�taxgfc�Stf�I74ix� (that the plaintiff Holyoke Square, Inc. take nothing, that the action be dismissed on the merits, and that the defendants State Bldg. Code Appeals Bd. , recover of the et al plaintiff Holyoke Square, Inc. their Acis costs of action.) Dated at Peabody Massachusetts, this 30th day of July 1997 . r..A.L'216-s. -r ............... . .......... As ' ni Clerk MRCP Form 32 7.74-5000 D F� Py�'TER 5 DAYS RETURN TO JAMES DENNIS LEARY, ESQ. '-- CLERK OF COURTS ESSEX COUNTY5 til jc 'b" J.S.00SiAGE 3FEDERAL STREET SALEM,, MASSACHUSETTS 01970 APR-5'96 0 .3 2 AS osaeis� �. _ . . ._ . _ 4 S l COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. SUPERIOR COURT CIVIL ACTION NO. 91-2352A CIVIL ACTION NO. 92-688 HOLYOKE SQUARE, INC. Plaintiff V. THE SALEM REDEVELOPMENT AU'T'HORITY, ET AL ) Defendants ) MOTION FOR CONTINUANCE Now comes the Defendant, City of Salem, by its attorney, Leonard F. Femino, and moves that this Honorable Court continue the assigned trial date from Monday, April 1, 1996 and states the following: Counsel for the Defendant has resigned his position as Assistant City. Solicitor effective April 1, 1996 after more than ten years. A new Assistant City Solicitor begins working for the Defendant on April 1, 1996 and will require some time to become familiar with this matter. ASSENTED TO: William J. egan nard F. Femino 81 Washington Street Assistant City Solicitor Suite 37 One School Street Salem, MA 01970 Beverly, MA 01915 (508) 741-3888 (508) 921-1990 For the Plaintiff 'ftrereb For the Defendants •documynt tva thatatruedopyoftheabove as served u appearing pro se and)the atttorney of rn (each ecord for each ! ;her) P rty d on c n Y mail LUNDREGAN LAW O F F I C ES THE KINSMAN BUILDING WILLIAM J. LUNDREGAN 81 WASHINGTON STREET TELEPHONE (508) 741-3888 JANE T. LUNDREGAN SALEM, MASSACHUSETTS 01970 FACSIMILE (508) 745-3607 March 4, 1996 Mr. Leo Tremblay Building Inspector City Hall One Salem Green Salem, MA 01970 RE: 18 Crombie Street Dear Mr. Tremblay: On November 14, 1995, I wrote to you pursuant to the enclosed correspondence. May I please have a reply. 4W rryy trul you , W LIAM J. LUNDR AN WJL:ej Enclosure 'ti LUNDREGAN L A W OF F I C ES THE KINSMAN BUILDING WILLIAM J. LUNDREGAN 81 WASHINGTON STREET TELEPHONE(508) 741-3888 JANET LUNDREGAN SALEM, MASSACHUSETTS 01970 FACSIMILE(508) 745-3607 November 14 , 1995 Mr. Leo Tremblay Building Inspector City Hall One Salem Green Salem, MA 01970 RE: 18 Crombie Street Dear Mr. Tremblay: I am writing to you again pursuant to M.G.L. Ch. 143, Sec. 6 in order to apprise you of the fact that the building located at 18 Crombie Street is in a state of disrepair and poses a serious hazard to the well-being of pedestrians in the area. On October 13, 1995, Robert R. Rumpf Associates inspected the said building at the invitation of its current Owner, the Holyoke Mutual Square, Inc. A copy of his report is annexed hereto for your information. It is our opinion that 18 Crombie Street is in danger of collapsing and that, therefore, it poses a health and safety hazard to persons within its vicinity. Indeed, were it not for the addition of the porch and corner rooms (which are themselves now failing) it is probable that the main frame would already have toppled. Clearly, this property should be condemned and demolished. It is our request that your Department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M.G.L. Ch. 143, Sec. 6. If you have any questions with reference to this matter, please do not hesitate to call me. Very truly yours, WILLIAM J. LUNDREGAN WJL/amp cc: Holyoke, Square, Inc. f LUNDREGAN L A W OFFICES THE KINSMAN BUILDING WILLIAM J. LUNDREGAN 81 WASHINGTON STREET TELEPHONE(508) 741-3888 JANET LUNDREGAN SALEM, MASSACHUSETTS 01970 FACSIMILE 15081 745-3607 November 14, 1995 Mr. Leo Tremblay Building Inspector City HallQ QJ One Salem Green /'//� Salem, MA 01970 RE: 18 Crombie Street '� Dear Mr. Tremblay: I am writing to you again pursuant to M.G.L. Ch. 143, Sec. 6 in order to apprise you of the fact that the building located at 18 Crombie Street is in a state of disrepair and poses a serious hazard to the well-being of pedestrians in the area. On October 13, 1995, Robert R. Rumpf Associates inspected the said building at the invitation of its current Owner, the Holyoke Mutual Square, Inc. A copy of his report is annexed hereto for your information. It is our opinion that 18 Crombie Street is in danger of collapsing and that, therefore, it poses a health and safety hazard to persons . within its vicinity. Indeed, were it not for the addition of the Y porch and corner rooms (which are themselves now failing) it is probable that the main frame would already have toppled. Clearly, this property should be condemned and demolished. It is our request that your Department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M.G.L. Ch. 143, Sec. 6. If you have any questions with reference to this matter, please do not hesitate to call me. Ver truly y rs, WIIAM J. LUND GAN WJL/amp cc: Holyoke Square, Inc. f 9100942 ROBERT M. RUMPF & ASSOCIATES Re: Frame Condition CONSULTING ENGINEERS Report(amended& revised) 101 DERBY STREET Residence-unoccupied SALEM. MASS. 01970 18 Crombie Street 508-745-6596 FAX 508.745-6596 Salem,MA 01970 10-31-95 October 31, 1995 Mr. William J. Lundregan, Esq. 81 Washington Street Salem, MA 01970 Dear Mr. Lundegran: Enclosed herewith please find our current reports pertaining to the present structural condition of the subject building above-referenced. Also, we have included the computations prepared to determine the carrying - or liveload - capacity of the second and third floors. Evident in these reports, and the corresponding computations, is the fact that structure falls substantially short of satisfying the generally safe and acceptable requirements of the Massachusetts State Building Code. Please advise if you have any further questions regarding this matter. r r Res ct lull ted;, . REric Rumpf ., Robert M. Rumpf& Associates ✓` #100942 � '. ROBERT M. RUMaF & ASSOCIATES e: ;game Condition 'A CONSULTING ENGINEERS deport(amended& revised) 101 DERBY STREET Residence-unoccupied SALEM. MASS.01970 18 Crombie Street ��. •� •�� sosaas-ssss FAX sos-las-ssss Salem,MA 01970 \ \�J 9-22-95 September 22, 1995 Mr. William J. Lundregan, Esq. 81 Washington Street Salem, MA 01970 REPORT This is a report on our inspection of the referenced building. In general, we have determined that it is structurally unsafe and does not meet Massachusetts Building Code requirements. The substructure is in poor condition; part of the foundation has deteriorated to the point that it endangers the structural integrity of the building above it. The superstructure is inadequate; we have determined through observation and analysis of the purlin floor framing capacity that is was dangerously underdesigned. If you require additional information, please advise. Respectfully subm' ed, flu, Robert M. Rumpf, P.E. Robert M. Rumpf& Associates l _ #1009gb++'�• ROBED i. fRuMFF & ASSOCIATES �� SN OF M• �� Re: Frame Condition j- C: 3uLTING ENGINEERS Report(amended& revised) s AN .�+. DERBY STREET Residence-unoccupiedOR --ALEM, MASS.01970 18 Crombie,Street �� srRuciid:rt� 508-7,5-6596 FAX 508-745-6596 Salem,NIA 01970 : N433749 + i :10- IALE� nV1 October 22, 1995 Mr. William J. Lundregan, Esq. 81 Washington Street Salem, MA 01970 REPORT General- My site visit was conducted on October 13, 1995; a portion of the first floor ceiling was removed to expose the second floor framing for inspection. Field Investigation- I observerd that the second floor joists were partially hewn, five inch diameter logs spanning over nine feet. r Conclusion - Similar to the third floor framing(investigated by other members of this firm), the second floor framing is inadequate to support residential loading. The roughly planed log framing has insufficient strength in bending to support the loads as required by the Massachusetts Building Code and, therefore, is unsafe. Respectfully submitted, Andrew W. Way, P.E. Robert M. Rumpf& Associates x. y-,:: door CapacltY Study 'A Of 4 s 4 ROBERT M. RUMPF Pa ASSOCIATES ROBERT / C 8 s +' CONSULTING ENGINEERS fo m U ✓t2'E�' $ M. ., S PF 101 DERBY STREET - 63 SALEM.MASS.01 970 - al ern, M 4pf oo.. 6663�� W 500-745-6590 FAX 500-745-0590OR ��S TEP \per 2nd Floor t"rarer Assvme �w_ 1, O'k. 6 24 -- w /04 w . D.89x�o2 = 0, 07/ h (� Load capacefy requlrcd by code : ps � D-L.• plastcr : �OpsF CjeckFlaminc' _ /p ,L L ,L ZOpsF, 40 „ 60 PSFlc)or ca acct S 4/ o below - 3r4 Floor dram �egulrCrnPn`t _ /4, 2 I span 3x 4 oto ! Q " avrra P oc ,455-4,11'"e S = 3X4g, 0 in 3 ml,ax wr¢j w 0, 027 hIF 17pst^ F(o___T capac_i tT /5 72 16 below req v ire mer, i \�/ V �j �` LUNDREGAN LAW O F F I C ES THE KINSMAN BUILDING WILLIAM J. LUNDREGAN 81 WASHINGTON STREET TELEPHONE (508) 741-3888 JANE T. LUNDREGAN SALEM. MASSACHUSETTS 01970 FACSIMILE(508) 745-3607 September 11, 1995 - Mr. Leo F. Tremblay, Building Inspector Public Property Department City of Salem One Salem Green Salem, MA 01970 RE: 18 Crombie St. , Salem, M.P. Dear Mr. Tremblay: I have had occasion to discuss this matter with Mr. Douglas Ryder, the President of Holyoke Square, Inc. and with their architect, Mr. Charles Demarco of Demarco/Jarek Partnership. We agree with your position that the rear porch post, supporting the roof structure, is in an unsafe condition. It has been our position for the past two years that the building is unsafe and should be condemned. Pursuant to MGL c. 143 S 6, we are fully prepared forthwith to remove the porch posts and the attendant roof structure. Pursuant to your conversation with me in your office on August 17, 1995, wherein you indicated that your letter of August 10, 1995 is to be considered an order to remove or make safe, we are fully prepared to go forward and remove the structure. If you wish us to apply for a demolition permit, we will do so. If you have any questions with reference to this matter, please do not hesitate to call me. a ruly yo s, M J. LUND AN WJL:ej s - � CITY OF SALEM - MASSACHUSETTS KEVIN T. DALY Legal Department LEONARD F. FEMINO City Solicitor 93 Washington Street Assistant City Solicitor 508-745-0500 Salem,Massachusetts 01970 508-921-1990 March 18, 1992 Mr. William Munroe t r ' tan c' r Building Inspector City of Salem a1 r, C)o One Salem Green Salem, MA 01970 RE: Holyoke Square Inc. v r� Dear Bill: Enclosed herewith please find Discovery filed in the above-mentioned matter. Would you kindly have someone in your office prepare responses and collect the documents requested for my review. Please call with your questions or comments. Very ruly yours, Leonar F. Femino LFF/gsw Enclosure cc: William Luster, City Planner e -� CITY OF SALEM - MASSACHUSETTS KEVIN T. DALY Legal Department LEONARD F.FEMINO City Solicitor 93 Washington Street Assistant City Solicitor 508-745-0500 Salem, Massachusetts 01970 508-921-1990 March 18, 1992 7_r s Mr. William Munroe c , Building Inspector city o cc - f Salem One Salem Green .. Salem, MA 01970 RE: Holyoke Square Inc. n Y � c Dear Bill: Enclosed herewith please find Discovery filed in the above-mentioned matter. Would you kindly have someone in your office prepare responses and collect the documents requested for my review. Please call with your questions or comments. Very ruly yours, Leonar F, Femino LFF/gsw Enclosure cc: William Luster, City Planner 7456596 �\/ STRUCTURAL REPORT `zH of A,, 18 CROMB I E STREET sr�� ROBERT M. RUMPF 8C ASSOCIATES SALEH, MAS.SACUSETTS ROBERT_', �f ]March 18, 1991 M' 0IFMV CONSULTING ENGINEERS V No. Da 101 DERBY STREET ,p SALEM. MASS.01970 Q�.e "�5 TEP STRUCTURAL REVIEW OF EXISTING RESIDENTIAL BUILDING Submitted to: Salem Planning Department One Salem Green Salem, Massachusetts 01970 INTRODUCTION This report is confined to the present structural condition of the above-referenced buildiLS; Saner41 dea_riptionc of repairs and construction are listed with associated approximate costs. Observations ,and recommendations are drawn from the following: * site visit and visual inspection of the existing building interior. * review of the OVERVIEW STUDY prepared by Demarco/Jarek Partnership, Architects and Planners, dated September 1990. * prior experience with similar building types and typical construction procedures for structural rehabili- tation. While we generally agree with the Demarco/Jarek report, we have addressed only the structural aspects of the building: foundation, framing, and related components. Remedies to structural problems are discussed later; included in our repair estimate is a line item which covers the cost of cutting and patching required for the structural improvements only. Anticipated renovation costs which are not warranted by the structural condition of the referenced building are considered - and presented - by others. EXISTING CONDITIONS We find that the condition of the superstructure of the original building and the addition is acceptable to good with the exception of the sills and various aspects of the first floor framing (as discussed in the Architects' report) . 745 6596 STRUCTURAL REPORT 18 CROMBIE STREET o ROBERT.' s ROBERT M. RUMPF & ASSOCIATES SALEM, MASSACUSETTS N1. I CONSULTING ENGINEERS March 18, 1991 3 N�b632� 101 DERBY STREET SALEM. MASS. 01 970 �pf o-�S TE The condition of the back porch is such that it should be be torn down entirely. The original building has a very severe lean to one side which we partly attribute to the way it was built and added to, but mostly to problems with the foundation. The condition of the foundation is fair to poor and likely to further deteriorate due to disintegration of its brick masonry components. In addition, severe settlement at two corners and at the Chimney supports has occurred while lateral movement of some of the walle is evident (consistent with the description in the Architect-i' report) , RECOMMENDATIONS Pursuant to the above description of observed structural problems, we recommend the following corrective measures: * Shore superstructure and replace building sills entirely. budget $ 6, 280. 00 * Jack-up the superstructure where required to level position to properly facilitate resting sills on a new foundation. Some improvement in the presently excessive leaning of the building may result from this operation. budget S 4, 860. 00 * Provide miscellaneous first floor framing reinforcing, connections, and supports. Repair chimney foundation. budget S 970. 00 7456596 STRUCTURAL REPORT kA OF a4rr,2 ?. 18 CROMBIE STREET ROBERT-; . s ROBERT M. RUMPF & AssociAres SALEM, MASSACUSETTS V M. r RUMPF. r CONSULTING ENGINEERS March 18, 1991 No.�6yD32 0 � r 101 DERBY STREET QeP CPS r SALEM. MASS.019'10 f�aS/ONAI t�4` K Remove porch completely and replace rear access with new stairs from exterior grade to first floor. budget $ 710. 00 * Remove existing concrete floor and replace with a new reinforced slab on vapor barrier with construction points on suitable, compacted gravel base. Install sump pit with pump to prevent damage from possible future flooding conditiane, budget S 3, 230. 00 * Remove the existing foundation and excavate t�Ap parlmater to allow installation of new cast- in-place concrete foundation walls and footings; dampproof foundation exterior. Include code- required vents or windows. budget $ 7, 130. 00 * Provide improved interior access to basement: install new stairs and rails. Provide new exterior bulkhead, bulkhead stairs, and weatherproof doors for exterior access. budget $ 1, 670. 00 * Remove all unused piping, wiring, conduits, miscellaneous obstructions, etc. , in basement. Clean and treat areas exposed to moisture or adjacent rot. budget $ 480. 00 746,6696 ' STRUCTURAL REPORT ?�E�tH OF 0441 C 18 CROXBIE STREET c ROBERT , ROBERT M. RuMRE & ASSOCIATES SALEM, N SSACUSETTS � 'A i March 18, 1991 0IN 32 UMP \ CONSULTING ENGINEERS � O 101 DERBY STREET pP ti V OF /STEP `+`��•' SALEM. MASS.01970 J s�ONAI E /f k Cut and patch as necessary for disturbed areas, caused by these specified structural improvements, to match original or adjacent exposed construction: interior and exterior. budget $ 960. 00 Also, although not absolutely required structurally, we recommand that the addition be torn down in its entirety and properly rebuilt. In doing so, this structure would contribute to the stability of the original building while following an improved architectural design. CONCLUSION The above-listed observations and subsequently devised recommendations are rendered to show the reasonable minimum requirements to adequately rehabilitate the structure and allow architectural and related utility improvements to follow. While the superstructure needs work as specified to be restored to level and near-plumb condition, the general intent of the Engineer is to require a new, structurally sound foundation and in doing so, achieve the additional benefit of a clean, dry, and usable basement. 745-6596 STRUCTURAL REPORT 18 CROMBIE STREET ROBERT M. RUMPF & ASSOCIATES SALEM, MASSACUSETTS CONSULTING ENGINEERS March 18, 1991 10 1 DERBY STREET SALEM. MASS.01970 Mr. William Luster Salem Planning Department One Salem Green Salem, Massachusetts 01970 Dear Mr. Luster: Enclosed herewith please find our report on the structural condition of the above-referenced building per your request, lawme report outlines the remedial construction necessary to prevent further deterioration of the structure and assure greater safety to its occupants. If you require additional information relevant to this matter - or our services in another project - please advise. Respectfully submitted, Robert M. Rumpf, P. E. COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION NO. -----------------------------------) HOLYOKE SQUARE, INC. , Plaintiff ) VS. ) THE STATE BUILDING CODE APPEALS ) BOARD, THE SALEM REDEVELOPMENT AUTHORITY, and WILLIAM MUNROE, ) ,, as he is the Building Inspector =, of the City of Salem, ) ` o c- Defendants PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF ? � U DOCUMENTS BY DEFENDANT, WILLIAM MUNROE -- �, r� Pursuant to Mass. R. Civ. P. 34 the Defendant is heredy' required to produce copies of the following documents at the officer of Plaintiffs' Counsel within forty-five (45) days of receipt hereof. NOTE: Notwithstanding their use of "all, " "any and all" and/or other, all-inclusive designations, the following Requests shall be deemed to exclude from their scope materials privileged by the attorney-client privilege, the attorney work-product privilege, and the privilege afforded to materials compiled by or at the behest of Counsel in anticipation of litigation. A. Any and all correspondence, memoranda, notes, records, reports, studies, and/or other documents of any kind and nature whatsoever, by whomever authored, for whatever purpose(s) , to whomever addressed, and by whomever received, excepting herefrom only matter privileged by the 1 3 . Please state whether or not you received a letter dated August 5, 1991, written by the DeMarko/Jarek Partnership. Professional Architects, concerning the building located at 18 Crombie Street, Salem, Massachusetts. For your reference, a copy of said letter is annexed hereto as Exhibit A. 4 . If the answer to no. 3 is in the affirmative, please state the following information: (a) The date on which you received the said letter; and (b) Whether or not you reviewed the contents of said letter prior to making any inspection of the said building in August of 1991. 5. Please state whether or not you made an inspection of the said Crombie Street building on or about August 18 , 1991 . 6. If the answer to no. 5 is in the affirmative, please identify and describe in full and complete detail each and every finding made by you as a result of said inspection which contradicts or otherwise differs with any findings or statements made by the DeMarko/Jarek Partnership in their aforesaid letter of August 5, 1991. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by DeMarko/Jarek with which you differ; (b) Your own specific finding which differs from that made by DeMarko/Jarek; and 2 (c) The reasons, in full and complete detail, why you believe DeMarko/Jarek is in error on the contested point. 7 . Please state whether or not you have previously seen a copy of a Structural Report on the said Crombie Street building dated March 18, 1991, authored by Robert M. Rumpf, Professional Engineer. For your reference, a copy of said Report is annexed hereto as Exhibit B. 8. If the answer to no. 7 is in the affirmative, please state the following information: (a) The date on which you received the said Report; and (b) Whether or not you reviewed the contents of said letter prior to making any inspection of the said building in August of 1991. 9. Please identify and describe in full and complete detail each and every finding made by you as a result of your own inspection of the subject Crombie Street building which contradicts or otherwise differs with any findings or statements made in the said Rumpf Report. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by the Rumpf Report with which you differ; (b) _ Your own specific finding which differs from that made by Rumpf; and (c) The reasons, in full and complete detail, why you believe Rumpf is in error on the contested point. 3 10. Please state whether or not you have previously seen the Estimate of Repair Work written by the DeMarko/Jarek Partnership, Professional Architects, concerning the building located at 18 Crombie Street, Salem, Massachusetts, a copy of which is annexed hereto as Exhibit C. 11. If the answer to no. 10 is in the affirmative, please state the following information: (a) The date on which you received the said Estimate; and (b) Whether or not you reviewed the contents of said Estimate prior to making any inspection of the said building in August of 1991. 12 . Whether or not you have previously reviewed the said Estimate of Repair Work, please identify and describe in full and complete detail each and every finding made by you as a result of said inspection which contradicts or otherwise differs with any findings or statements made by the DeMarko/Jarek Partnership in their aforesaid Estimate. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by DeMarko/Jarek with which you differ; (b) Your own specific finding which differs from that made by DeMarko/Jarek; and (c) The reasons, in full and complete detail, why you believe DeMarko/Jarek is in error on the contested point. 4 13 . Please state whether or not you have previously seen the Estimate of Repair Work written by Jeffrey R. Martel, of Martel Designer-Craftsman, Inc. , concerning the building located at 18 Crombie Street, Salem, Massachusetts, a copy of which is annexed hereto as Exhibit D. 14 . If the answer to no. 10 is in the affirmative, please state the following information: (a) The date on which you received the said Estimate; and (b) Whether or not you reviewed the contents of said Estimate prior to making any inspection of the said building in August of 1991. 15. Whether or not you have previously reviewed the said Estimate of Repair Work, please identify and describe in full and complete detail each and every finding made by you as a result of said inspection which contradicts or otherwise differs with any findings or statements made by Martel in his aforesaid Estimate. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by Martel with which you differ; (b) Your own specific finding which differs from that made by Martel; and (c) The reasons, in full and complete detail, why you believe Martel is in error on the contested point. 5 16. Please set forth in full and complete detail a statement of any and all facts known to you that support your professional opinion that the subject Crombie Street building does not qualify for condemnation and/or does not pose a safety hazard to persons and property in the vicinity thereof. 17 . Based upon your aforesaid inspection of the subject Crombie Street property, and the findings that you made as a result thereof, does the said building presently qualify for an occupancy permit? 18 . If the answer to no. 17 is in the negative, please set forth in full and complete detail an itemization, with respective estimated costs, of the work that needs to be performed upon the subject property in order to qualify said property for an occupancy permit. 19. Please set forth an itemization of all removal and/or demolition projects permitted within the "Crombie Street National Historic Register District" from January, 1970 to date hereof. In answering this interrogatory, with respect to each such project, please identify: (a) The date on which the project was approved; (b) The building(s) and use(es) which was/were removed and/or destroyed, and the alleged historic significance thereof; and (c) The building(s) and use(S) which succeeded that/those which was/were removed and/or destroyed. 6 20. Please set forth an itemization of all removal and/or demolition projects permitted within the "Heritage Plaza West Urban Renewal Plan" from January, 1970 to date hereof. In answering this interrogatory, with respect to each such project, please identify: (a) The date on which the project was approved; (b) The building(s) and use(es) which was/were removed and/or destroyed, and the alleged historic significance thereof; and (c) The building(s) and use(s) which succeeded that/those which was/were removed and/or destroyed. 21. Please itemize and summarize all of the evidence which you submitted to The State Building Code Appeals Board at the Board' s hearing on or about February 11, 1992 . 22 . Please identify, by name, address, occupation of profession, and business or professional address, each person known or believed to have knowledge of facts relevant to this case. 23 . Please identify, by name, address, occupation of profession, and business or professional address, each witness whom this Defendant intends to call to testify at the trial of this case. 24 . Please identify, by name, address , occupation of profession, and business or professional address, each expert witness whom this Defendant intends to call to testify at the trial of this case; and with respect to each such expert, please state: 7 (a) the subject matter on which the expert is expected to testify; (b) the substance of the facts and opinions to which the expert is expected to testify; and (c) a summary of the grounds for each expected opinion. HOLYOKE SQUARE, INC. , By Its Att rney 7i ,Lundrega Esq. 8 ashington Str S ite 37 Salem, MA 01970 (508) 741-3888 8 Pr COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION NO. amu :------ 7-77--) HOLYOKE SQUARE, .INC: , PlaintiffF. ) - 67fPf M vs.,Fix i" Al ) COMPLAINT THE STATE BUILDING:`CODEJ PEALS ) BOARD, THE BALEMREDEVELOPMENT AUTHORITY, :and`WILLIAM *UNROE, as he is the Building Inspector ) of the City of Salem, -. Defendants ------- Parties T r` � A. rr, 1. Plaintiff, ` HOLYOKE SQUARE, INC. , is a Massaeusets Corporation doing business within this Commonwealth and having a usual place ofbusiness at Holyoke Square, Salem, Essex County, Massachusetts. 2. Defendant, THE STATE BUILDING CODE APPEALS BOARD, is an administrative agency within the Commonwealth of Massachusetts Executive Office of Public Safety, organized pursuant to }M.G.L. Ch. 143, Sec. 100, empowered to make regulations or to conduct adjudicatory proceedings relative to the interpretation and enforcement of the State Building Code, and having a usual place of business at one Ashburton Place, Room 1301, Boston, Suffolk County, Massachusetts. 3 . Defendant SALEM REDEVELOPMENT AUTfioRITY, is a public authority corporate and politic, organized under the Massachusetts General Laws, with the ability to sue and be 1 f sued, and having a usual place of business at One Essex Green, Salem, Essex County, Massachusetts. 4. The Defendant, WILLIAM MUNROE, is the BUILDING INSPECTOR of the City of Salem,` with an office at One Salem ; - , Green, .Salemi,EssexrCountp,,fV sachusetts. x �!'Faot$ ` 5. Plaintiff is the owner of the real estate knownand numbered as 18 1;.Crombiee: Street, Salem, Essex ==county, Massachusetts: 6. On or about July � 3, 1990 the Plaintiff commissioned the DeMarko/Jarek.'iPartnership, Professional Architects; :to inspect the said Crombie Street property in order ' to determine whether the building thereon was reasonably safe for use and occupancy; and the said Architects did inspect the said property, as requested, on or about the said date. 7. By letter dated August 5, 1991 the Plaintiff's architects formally notified the Defendant BUILDING INSPECTOR that, "the building located at 18 Crombie Street is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area. " The said letter concluded with a recommendation, "that your department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M.G.L. Ch. 143; Sec. 6. " S. On or about August 18, 1991 the Defendant BUILDING INSPECTOR made an inspection of the said Crombie Street property. 2 9. By decision dated August 29 , 1991 the Defendant BUILDING INSPECTOR failed, neglected and refused to issue an order to the Owner to remove the structure or make it safe. 10. The Plaintiff is in agreement with its architects hat the.;., said Crombie Street building is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area. 11. The Plaintiff is informed, and does believe, that repair of the said building is economically unfeasible. 12. The Plaintiff is ready and willing to remove the present, unsafe building. 13. However, the said property is located within the jurisdiction of the Defendant REDEVELOPMENT AUTHORITY, and said AUTHORITY has refused to authorize the removal of the said building. 14. The Defendant BUILDING INSPECTOR is the chief administrative and enforcement officer of the Building Code within the City of Salem and the Defendant REDEVELOPMENT AUTHORITY is without authority to over-rule a decision of the BUILDING INSPECTOR regarding enforcement of the Building Code. 15. Accordingly, on or about October 4 , 1991 the Plaintiff timely appealed the said Decision of the Defendant BUILDING INSPECTOR to the Defendant STATE BUILDING CODE APPEALS BOARD. 16. On or about February 11, 1992 an adjudicatory hearing was held before the Defendant APPEALS BOARD on the 3 Plaintiff's said appeal. 17. Then and there, the Defendant APPEALS BOARD issued a decision DENYING the Plaintiff's Appeal and AFFIRMING the aforementioned Decision of the Defendant BUILDING INSPECTOR. Count One: Appeal Under Administrative Procedures Act 18. Plaintiff incorporates by reference and here re- alleges paragraphs 1 through 17, supra . 19. This is an Appeal of the Defendant APPEALS BOARD's decision, and is brought pursuant to M.G.L. Ch. 30A, Sec. 14 . 20. The said decision exceeded the authority of the Defendant APPEALS BOARD, was based upon error of law, was made upon unlawful procedure, was unsupported by substantial evidence, was contrary to the evidence presented, and was arbitrary, capricious, an abuse of discretion and otherwise not in accordance with law. WHEREFORE, the Plaintiff prays that this Court will: (a) Grant this appeal; (b) Review the said decision of the Defendant APPEALS BOARD; (c) Reverse the said decision of the Defendant APPEALS BOARD; (d) Order the Defendant APPEALS BOARD to instruct the Defendant BUILDING INSPECTOR to issue an order to the Plaintiff to remove the subject building or make it safe, pursuant to M.G.L. Ch. 143 , Sec. 6; and (e) Award the Plaintiff such other and further relief as may be appropriate. 4 I` Count Two: Certiorari 21. Plaintiff incorporates by reference and here re- alleges paragraphs 1 through 17, supra. 22 . This is a Complaint for Certiorari, seeking judicial review„ of the Defendant APPEALS BOARD's decision, and is brought pursuant to M.G.L. Ch. 249, Sec. 4. 23. The said decision exceeded the authority of the Defendant APPEALS BOARD, was based upon error of law, was made upon unlawful procedure, was unsupported by substantial evidence, was contrary to the evidence presented, and was arbitrary, capricious, an abuse of discretion and otherwise not in accordance with law. WHEREFORE, the Plaintiff prays that this Court will: (a) Grant certiorari; (b) Review the said decision of the Defendant APPEALS BOARD; (c) Reverse the said decision of the Defendant APPEALS BOARD; (d) Order the Defendant APPEALS BOARD to instruct the Defendant BUILDING INSPECTOR to issue an order to the Plaintiff to remove the subject building or make it safe, pursuant to M.G.L. Ch. 143 , Sec. 6; and (e) Award the Plaintiff such other and further relief as may be appropriate. 5 Count Three: Enforcement of the Building Code 24. Plaintiff incorporates by reference and here re- alleges paragraphs 1 through 17 , supra. 25. This is a Complaint in equity seeking judicial enforcement of the Building Code, and is brought pursuant to M.G.L. Ch. 143 , Sec. 57. 26. The Plaintiff is a party aggrieved by the failure of the Defendant BUILDING INSPECTOR and the Defendant APPEALS BOARD to enforce the applicable provisions of the Building Code. 27. The said failure to enforce the Building Code exceeded the authority of the Defendants, was based upon error of law, was made upon unlawful procedure, was unsupported by substantial evidence, was contrary to the evidence presented, and was arbitrary, capricious, an abuse of discretion and otherwise not in accordance with law. 28. As a direct and proximate result of the said unlawful acts or refusals to act, the Plaintiff is exposed to potential liability to any person or persons who may be injured if and when the subject property collapses. 29 . The Plaintiff is without an adequate remedy in law. WHEREFORE, the Plaintiff prays that this Court will issue an Order to the Defendant BUILDING INSPECTOR directing him to enforce the Building Code and issue an order to the Plaintiff to remove the subject building or make it safe, pursuant to M.G.L. Ch. 143 , Sec. 6; and award the Plaintiff such other and further relief as may be appropriate. 6 Count Four: Declaratory Judgment 30. Plaintiff incorporates by reference and here re- alleges paragraphs 1 through 17, supra. 31. This is an action for declaratory relief and is brought pursuant to M.G.L. Ch. 231A. All persons interested herein have been made parties hereto and duly served with process. 32. The Plaintiff avers that the Defendant REDEVELOPMENT AUTHORITY is without authority to over-rule a decision of the BUILDING INSPECTOR regarding enforcement of the Building Code. 33. The Plaintiff avers that in the event this Court awards Plaintiff the relief requested under Counts One, Two and/or Three hereof, with the result that the Defendant BUILDING INSPECTOR issues a "remove or make safe" order pursuant to M.G.L. Ch. 143 , Sec. 6, the Defendant REDEVELOPMENT AUTHORITY will be without authority to countermand or otherwise interfere with the execution of such order. 34 . A genuine dispute regarding the matters set forth in paragraphs 32 and 33 , supra, exists between the Plaintiff and the Defendant REDEVELOPMENT AUTHORITY. WHEREFORE, the Plaintiff prays that this Court will issue a Judgment declaring, that the Defendant REDEVELOPMENT AUTHORITY is without authority to countermand or otherwise interfere with the execution b n y the Plaintiff of a remove or make safe" order issued pursuant to M.G.L. Ch. 143 , Sec. 6, 7 1 and awarding the Plaintiff such other and further relief as may be appropriate. HOLYOKE SQUARE, Pic. , By I s At orne , WilLundrega , Esq. ' 81 ashington Str, t Mite 37 Salem, MA 01970 (508) 741-3888 8 , . y it I II��Itl l: :1 T Cvtp of *aleM9 jjaggaCt Ug !i Public Propertp Department �, QCT O Arj 9� �3uilbinq ,Department One :oalem Oreen CI T'11 Or S;_ LE?i„1ASS. 745-9595 (Ext. 380 William H. Munroe Director of Public Property Inspector of Buildings Zoning Enforcement Officer August 29, 1991 Charles A. DeMarco, A.I.A. DeMarco and Jarek Partnersnip Pickering Wharf 223 Derby Street Salem, MA 01970 RE: 18 Crombie St. , Salem Dear Mr. DeMarco: In response to your request and accompanied by David Harris, Assistant Building Inspector, Attorney William Lundregan and you, I made an inspection of the above referenced property on August 18, 1991 to determine the structural stability of the building located on the site. Considering the fact that the structure is about one hundred sixty ( 160) years old I found it to be in reasonably good condition. The frame of the structure was in extremely good condition with the exception of a couple of areas of the sill plate which showed some water damage and carpenter ant infestation. I was surprised to find the foundation wall was red brick rather than stone indicating the foundation may be much newer than the house. The foundation has some areas that are in need of repair but there was no sign of there being stress enough to cause failure. The electrical, heating and plumbing should be upgraded to meet the needs of todays appliances. It is my opinion that, although this single family house has a number of problems, it has not deteriorated to the point of being a hazard to the public safety and welfare, and to order it demolished at this time would be premature. Sincerely, C41 MSoe Inspector of Buildings WHM:bms cc: William Lundregan, Esq. COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION NO. ttir�t y• H LYOICErSQUARE, IN , Pl if . ?g•'' w i r'\'it ' �y •tsJ�,G.^� vs t THE `'STATE BUILDING CODE APPEALS : ) f BOARD] THE SALEM REDEVELOPMENT p AUTHORITY, and WILLIAM,MUNROE, asahe`is the pector;' "of ,the City of „',,x.. ; ,Defendants • •�;; CffitTIFICATB OF SERVICE I, WILLIAM J.. LUNDREGAN, ''hereby certify that I served ' copies of: 1. Plaintiff's First Interrogatories to Defendant, William Munroe; 2. Plaintiff's First Request for Production of Documents by Defendant William Munroe; and 3. Certificate of Service by enclosincjr- thesame with . the Summons and Complaint for Sheriff's service upon all of the named Defendants. Signed under penalty of perjury. W liam J un regan, Esq 81 Wash' ton Street Suite 37 Salem, MA 01970 (508) 741-3888 r COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION NO. -----------------------------------) HOLYOKE SQUARE, INC. , Plaintiff ) VS. ) THE STATE BUILDING CODE APPEALS ) BOARD, THE SALEM REDEVELOPMENT -- AUTHORITY, and WILLIAM MUNROE, as he is the Building Inspector Mfr,, co x of the City of Salem, -- Defendants c u 4 m -----------------------------------) PLAINTIFF'S FIRST INTERROGATORIES TO 4 r' DEFENDANT, WILLIAM MUNROE Pursuant to Mass. R.Civ.P. 33, the Defendant, WILLIAM MUNROE, Building Inspector of the City of Salem, is hereby required to answer the following interrogatories within the time provided by rule. NOTE: Notwithstanding their use of "all, " "any and all" and/or other, all-inclusive designations, the following Interrogatories shall be deemed to exclude from their scope materials privileged by the attorney-client privilege, the attorney work-product privilege, and the privilege afforded to materials compiled by or at the behest of Counsel in anticipation of litigation. 1. Please state your name, address, occupation and business address. 2. Please state the name, address, occupation and business address of each and every person consulted for information used answering these interrogatories. 1 3 . Please state whether or not you received a letter dated August 5, 1991, written by the DeMarko/Jarek Partnership. Professional Architects, concerning the building located at 18 Crombie Street, Salem, Massachusetts. For your reference, a copy of said letter is annexed hereto as Exhibit A. 4. If the answer to no. 3 is in the affirmative, please state the following information: (a) The date on which you received the said letter; and (b) Whether or not you reviewed the contents of said letter prior to making any inspection of the said building in August of 1991. 5. Please state whether or not you made an inspection of the said Crombie Street building on or about August 18, 1991. 6. If the answer to no. 5 is in the affirmative, please identify and describe in full and complete detail each and every finding made by you as a result of said inspection which contradicts or otherwise differs with any findings or statements made by the DeMarko/Jarek Partnership in their aforesaid letter of August 5, 1991. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by DeMarko/Jarek with which you differ; (b) Your own specific finding which differs from that made by DeMarko/Jarek; and 2 10. Please state whether or not you have previously seen the Estimate of Repair Work written by the DeMarko/Jarek Partnership, Professional Architects, concerning the building located at 18 Crombie Street, Salem, Massachusetts, a copy of which is annexed hereto as Exhibit C. 11. If the answer to no. 10 is in the affirmative, please state the following information: (a) The date on which you received the said Estimate; and (b) Whether or not you reviewed the contents of said Estimate prior to making any inspection of the said building in August of 1991. 12 . Whether or not you have previously reviewed the said Estimate of Repair Work, please identify and describe in full and complete detail each and every finding made by you as a result of said inspection which contradicts or otherwise differs with any findings or statements made by the DeMarko/Jarek Partnership in their aforesaid Estimate. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by DeMarko/Jarek with which you differ; (b) Your own specific finding which differs from that made by DeMarko/Jarek; and (c) The reasons, in full and complete detail, why you believe DeMarko/Jarek is in error on the contested point. 4 13 . Please state whether or not you have previously seen the Estimate of Repair Work written by Jeffrey R. Martel, of Martel Designer-Craftsman, Inc. , concerning the building located at 18 Crombie Street, Salem, Massachusetts, a copy of which is annexed hereto as Exhibit D. 14. If the answer to no. 10 is in the affirmative, please state the following information: (a) The date on which you received the said Estimate; and (b) Whether or not you reviewed the contents of said Estimate prior to making any inspection of the said building in August of 1991. 15. Whether or not you have previously reviewed the said Estimate of Repair Work, please identify and describe in full and complete detail each and every finding made by you as a result of said inspection which contradicts or otherwise differs with any findings or statements made by Martel in his aforesaid Estimate. In answering this interrogatory, with respect to each such dispute, please identify: (a) The specific finding or statement made by Martel with which you differ; (b) Your own specific finding which differs from that made by Martel; and (c) The reasons, in full and complete detail, why you believe Martel is in error on the contested point. 5 16. Please set forth in full and complete detail a statement of any and all facts known to you that support your professional opinion that the subject Crombie Street building does not qualify for condemnation and/or does not pose a safety hazard to persons and property in the vicinity thereof. 17. Based upon your aforesaid inspection of the subject Crombie Street property, and the findings that you made as a result thereof, does the said building presently qualify for an occupancy permit? 18. If the answer to no. 17 is in the negative, please set forth in full and complete detail an itemization, with respective estimated costs, of the work that needs to be performed upon the subject property in order to qualify said property for an occupancy permit. 19. Please set forth an itemization of all removal and/or demolition projects permitted within the "Crombie Street National Historic Register District" from January, 1970 to date hereof. In answering this interrogatory, with respect to each such project, please identify: (a) The date on which the project was approved; (b) The building(s) and use(es) which was/were removed and/or destroyed, and the alleged historic significance thereof • and (c) The building(s) and use(s) which succeeded that/those which was/were removed and/or destroyed. 6 20. Please set forth an itemization of all removal and/or demolition projects permitted within the "Heritage Plaza West Urban Renewal Plan from January, 1970 to date hereof. In answering this interrogatory, with respect to each such project, please identify: (a) The date on which the project was approved; (b) The building(s) and use(es) which was/were removed and/or destroyed, and the alleged historic significance thereof; and (c) The building(s) and use(s) which succeeded that/those which was/were removed and/or destroyed. 21. Please itemize and summarize all of the evidence which you submitted to The State Building Code Appeals Board at the Board's hearing on or about February 11, 1992. 22 . Please identify, by name, address, occupation of profession, and business or professional address, each person known or believed to have knowledge of facts relevant to this case. 23 . Please identify, by name, address, occupation of profession, and business or professional address, each witness whom this Defendant intends to call to testify at the trial of this case. 24 . Please identify, by name, address, occupation of profession, and business or professional address, each expert witness whom this Defendant intends to call to testify at the trial of this case; and with respect to each such expert, please state: 7 I (a) the subject matter on which the expert is expected to testify; (b) the substance of the facts and opinions to which the expert is expected to testify; and (c) a summary of the grounds for each expected opinion. HOLYOKE SQUARE, INC. , By Its Att rney fas8 Lundreg Esq. hington Str37 Salem, MA 01970 (508) 741-3888 8 i tt;6596 STRUCTURAL REPORT tH OF 18 CROMBIE STREET . c ROBERT M. RUMPF & ASSOCIATES SALEM, MASSACUSETTS ��? ROBERF o CONSULTING ENGINEERS March 181991 M.U R M N 101 DERBY STREET NO. 6 SALEM. MASS.01970 P "/$TEP @V S�aNAt a� STRUCTURAL REVIEV OF EXISTING RESIDENTIAL BUILDING Submitted to: Salem Planning Department One Salem Green Salem, Massachusetts 01970 INTRODUCTION This report is confined to the present structural condition of the above-referenced buildingj igenarKl descriptions of repairs and construction are listed with associated approximate costs. Observations and recommendations are drawn from the following: * site visit and visual inspection of the existing building interior. * review of the OVERVIEW STUDY prepared by Demarco/Jarek Partnership, Architects and Planners, dated September 1990. * prior experience with similar building types and typical construction procedures for structural rehabili- tation. While we generally agree with the Demarco/Jarek report, we have addressed only the structural aspects of the building: foundation, framing, and related components. Remedies to structural problems are discussed later; included in our repair estimate is a line item which covers the cost of cutting and patching required for the structural improvements only. Anticipated renovation costs which are not warranted by the structural condition of the referenced building are considered - and presented - by others. EXISTING CONDITIONS We find that the condition of the superstructure of the original building and the addition is acceptable to good with the exception of the sills and various aspects of the first floor framing (as discussed in the Architects' report) . T4Z 6596 STRUCTURAL REPORT ���`��A OF ef"s� 18 CROMBIE STREET o ROBERT : , ROBERT M. RUMPF & ASSOCIATES SALEM, MASSACUSETTS i M. •n - CONSULTING ENGINEERS March 18, 1991 s RU PE N%4632 101 DERBY STREET 4 P427 SALEM. MAS5.01970 I � ' The condition of the back porch is such that it should be be torn down entirely. The original building has a very severe lean to one side which we partly attribute to the way it was built and added to, but mostly to problems with the foundation. The condition of the foundation is fair to poor and likely to further deteriorate due to disintegration of its brick masonry components, In addition, severa settlement at two corners and at the chimney supports _ has occurred while lateral movement of some of the walls is evident (consistent with the description in the Archltaote` report) , RECOMMENDATIONS Pursuant to the above description of observed structural problems, we recommend the following corrective measures: * Shore superstructure and replace building sills entirely. budget $ 6, 280. 00 * Jack-up the superstructure where required to level position to properly facilitate resting sills on a new foundation. Some improvement in the presently excessive leaning of the building may result from this operation. budget $ 4, 860. 00 * Provide miscellaneous first floor framing reinforcing, connections, and supports. Repair chimney foundation. budget $ 970. 00 746�6596 �H OF MAS \V / STRUCTURAL REPORT ! �c� V 18 CROMBIE STREET �0 ROBERTI - � ROBERT M. RUMPF 8C ASSOCIATES SALEM, MASSACUSETTS RUMPF_ a CONSULTING ENGINEERS March 18, 1991 No. 692 P 4' op 4i W 101 DERBY STREET Off. G✓S T£P `rW SALEM. MASS.01 970 Fay/ONAI i * Remove porch completely and replace rear access with new stairs from exterior grade to first floor. budget $ 710. 00 Remove existing concrete floor and replace with a new reinforced slab on vapor barrier with construction ,joints on suitable, compacted gravel base. Install sump pit with pump to prevent damage from possible future flooding conditions, budget $ 3, 230. 00 * Remove the existing foundation and excavate the perimeter to allow installation of new cast- in-place concrete foundation walls and footings; dampproof foundation exterior. Include code- required vents or windows. budget $ 7, 130. 00 * Provide improved interior access to basement: install new stairs and rails. Provide new exterior bulkhead, bulkhead stairs, and weatherproof doors for exterior access. budget $ 1, 670. 00 * Remove all unused piping, wiring, conduits, miscellaneous obstructions, etc. , in basement. Clean and treat areas exposed to moisture or adjacent rot. budget $ 480. 00 =.til '1456596 STRUCTURAL REPORT ?���`SH OF MA:�c 18 CROMBIE STREET C ROSERy ROBERT M. RUMPF ESC ASSOCIATES SALEM, MASSACUSETTS M. CONSULTING ENGINEERS March 18, 1991 080 Ru PF '^ IN 32 32 O 101 DERBY STREET 49 SALEM. MASS.01970 �f S T� 4�P '3/ NAL fa * Cut and patch as necessary for disturbed areas, caused by these specified structural improvements, to match original or adjacent exposed construction: interior and exterior. budget $ 960. 00 Also, although not absolutely required structurally, we rauammaDd that the addition be torn down in its entirety and properly rebuilt. In doing so, this structure would contribute to the stability of the original building while following an improved architectural design. CONCLUSION The above-listed observations and subsequently devised recommendations are rendered to show the reasonable minimum requirements to adequately rehabilitate the structure and allow architectural and related utility improvements to follow. While the superstructure needs work as specified to be restored to level and near-plumb condition, the general intent of the Engineer is to require a new, structurally sound foundation and in doing so, achieve the additional benefit of a clean, dry, and usable basement. IL 7145-6596 STRUCTURAL REPORT 18 CROMBIE STREET ROBERT M. RUMPF & ASSOCIATES SALEM, HASSACUSETTS CONSULTING ENGINEERS March 18, 1991 101 DERBY STREET SALEM. MASS.01970 Mr. William Luster Salem Planning Department One Salem Green Salem, Massachusetts 01970 Dear Mr. Luster: Enclosed herewith please find our report on the structural condition of the above-referenced building per your request. C�Ama report outlines the remedial construction necessary to prevent further deterioration of the structure and assure greater safety to its occupants. If you require additional information relevant to this matter - or our services in another project - please advise. Respectfully submitted, Robert M. Rumpf, P. h`. 13 r 1. IT Y 0. � ' .:.S3•dale �oard 7 `".7u� and J&nwzarda William F. Weld AZZa CAOC L� .s�e%Gurlon A" - G fjo� FOR STATE USE ONLY 0.2f08 � Fee Rcc'd: (617) 7^_7-3200 Check No. Rcc'd UJ': STATE IIUILDING CODE APPLY S BOARD AI'1'GL APPLICATION FORA DATE: DOCKET NUMBER: The undersigned hereby appeal to the Static hoard or Ilaildim- Remilations and Standards from the decision of the: I4uilding Official from the Ciq/KtX%X of: Salem, Massachusetts Board of Appeals from the Cityfl own of: Other Municipal Arenev/Official entitled: State A-ency/Official entitled: OTHER: Dated: October 4 , t9 91 , having been a;,,,!rieved by such (Check Appropriate Space) X lntcrpretation _ Order Requirement Direction X Failure to Act Other - Explain Subject: (Suhmit a hrief statement of reasons and principal points upon which the application, appeal or petition is haled) Al,i, APPROPRIATE SECTIONS OF THE CODE MUST RE LISTED The Owner of the building at 18 Crombie Street , Salem, MA requested the Buil ing nspec or on August > the to M.G .L. Ch. 143 Sec . 6 (See attached letter ) . The P6lding , InsRectvr irgsprected the building on AuySt3gj1$ 18 , 14691 and , nn+ , ecu an nr a pursuant to M.G.L. Ch. I4 i , Sec . (( See attache letter ) . State hrief1v desired relief: The decision of the Building Inspector should be overruled and the owner should be ordered o remove or ma e structure safe pursuant to M.G.L. Ch. 143 , Sec. b. APPELLANT: Holyoke Square , Inc. ADDRESS FOR SERVICE: Holyoke Square, Inc . , c/o William J. Lundregan, Esq . 81 Washington Street , Salem, MA 0197 ( 508) 741-3888 l'elephoneNo. ADDRESS OF PROPERTY INVOLVED: 18 Crombie Street , Salem, MA 01970 APPELLANT'S CONNECTION TO PROPERTY IN'VOLVED: Owner APPLAPLC-1/90 1 �� 1oo�rre���ty72lU�(,Gf,(IL �����LC7b6GP.� (9.x6Ca,6 VeB (/) ce. 0/✓ UMJ Jale,�I` t � / O L•c,� __ ��,e ✓UfJ(L7C1 r� `�CIGUf!ng %���pp �.l LO/�LQQ/KQb William F. Weld ��o-,�zfm��acr� ���� � Ce lJt[tx� Governor one aXYd/t(IG'A&n :l" - Kentaro Tsutsumi � �^. ✓u� *� 021,08 Chairman (617) 727-32(X) SERVICE NOTICE Charles J. Dinezio DOCKET NUN113ER: Administrator I, William J. Lundregan as Attorney for the Appellant/Petitioner Holyoke Square, Inc. in an appeal riled with the State Building; Code Appeals Board on October 4 , 1991 HEREBY SWEAR L'NDGR THE PAINS AND PF.NAI:FIFS OF I'ERJURI• THAT IN ACCORDANCE o1ITH I'llE PROCEDUItES ADOPTED BY THE SPATE' BOARD OF BUILDING REGULATIONS AND STANDARDS AND SECTION 121.2.1 OF TI1F. SPATE BUILDING CODE, 1 SERVED OR CAUSEDTO BE SERVED, A COPT' OF THIS APPEAL AI'1'LICA•IION ON THE FOLLOWING PERSON(S) IN THE FOLLOWING MANNER: NAME AND ADDRESS OF PERSON'/nGFNC�' Si•;RVBD NIM,1101) OF SERVICE, DATE OF SERVICE William Munroe Bng Inspector Last and Usual October 4 , 1991 uildi City of Salem One Salem Green Salem, MA TT70 Sign : AI'I GLLANT/PErlTIOi' On the 4th Dai, of October 19 91 , PERSONALLY APPEARED BEFORENtETIIEAISOVENAMED William J . Lundregan , Esq . (TYpe or Print the Name of the Appellant) AND ACKNOWLEDGED AND SWORE TILE ABOVE STATE GNTS TO BE TRUE. NOTARY PUBLIC Anne M. Poor 11/2/95 SERVNO'fE.1/90 COMMISSION EXPIRES V 1fL EPT [� DeMarco • )arek Partnership T �' CIO %1 r f91 Ole CITY GFc ``10';ASS. Architects & Planners 5 August 1991 William Munroe Euildinq Inspector City Hall One Salem Green Salem, MA 01970 RE: 18 Crombie Street Dear Mr. Munroe: We are writing to you pursuant to M.G.L. Ch. 143, Sec. 6 in order to apprise you of the fact that the building located at 18 Crombie Street is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area. On July 3, 1990, we inspected the said building at the invitation of its current Owner, the Holuoke Mutual Fire Insurance Company. A copy of our report is annexed hereto for your information. In summary form, our firms findings include the following : Roof The roof appears to be 18+ years old. The lower rear portion was incorrectly flashed to the abutting wall of the house. The lower left gabel roof valleys should have been ( but were not ) lined with metal. The absence of an adequate attic ventilation system requires the installation of a continuous soffit and ridge vent sustem, in order to reduce excessive attic humidity. There is evidence of a pre-existing ice damming problem. The rear plumbing vent has been installed on the outside wall and does not meet the building code. Chimneu One ( 1 ) of the two (2) chimneus is in marginal condition, at best. All of its flashings have deteriorated. The chimney cap is in need of rebuilding and- all the flues need to be lined. Exterior Walls The exterior-warlfs. fascias, soffits and trim are all wood and are in marginal condition. The cedar shingle sidinq is in marginal condition and is r„ppinq and splitting on most sides of the building. Paint has been peeling from all wood surfaces. The fascias, soffits and all of the corner boards are in rotted condition. The electrical entrance cables are in poor condition. Pickering Wharf 0 223 Derby Street 0 Salem, Massachusetts 01970 • 508/744-4141 Mr. William Munroe S August 1991 Pane 2 and the service cables entering the house are rotting. Most significantly, the brick and block: foundations on the front and left sides of the building are collapsing. Drainage The gutters are in poor condition. The wooden gutters are rotten and the copper gutters should be (but are not ) spaced away from all fascias. The downspouts are in marginal condition. Grading around the foundation does not slope awau, thus causing water to pond. Grounds The rear wooden stairs are rotting. The rear brick patio is in marqinal condition, of major concern is the wood porch structure including, but not limited to, the roof, rafters, corner post, and porch decking. Floor joists and decking have been severely damaged by wood rot and wood boring insects. Doors_and_Windows All of the windows are in poor condition. Their thresholds are rotting. The entry doors are not square. All flashing around windows and door heads are in poor condition. The window sashes are loose in their casings. The entire bulkhead is unsafe. Easement The brick walls are in poor condition, and the right and rear foundation walls are collapsing. On the front and right sides, the sills are in poor condition, evidencing rot and insect damage. The right side floor joists have been damaged bw wood borinq insects. The brick support posts are in poor condition and are deterioratinq_. Kitchen The general structure of the kitchen is t not squared and ��e floor is not level . Electrical circuits are very limited. The walls, ceiling, floor and electrical outlets are all in marninal condition. Mr. William Munroe 5 August 1991 Page 3 Ha llways_and_Entries The rear stairwell is marginal. The plaster finish in the front stairwell has loosened. Liv_ing_Room_(Front) The ceiling sags, due to settling of the foundation. The hardwood floor similarly is not level . Electrical outlets are in marginal to poor condition, and are limited. The windows are .marginal due to excessive peeling of paint. The doors are marginal and are not square. The fireplace is marginal and in need of flue lining. Rining_Room The walls, ceiling and floor are all marginal . The ceiling sags and the structure has settled to the left. Outlets and fixtures are limited and in poor condition. The fireplace is marginal and in need of a flue lining. Closed_In_Porch (Rear_Right ) The floor and the ceiling sag. The outlets and fixtures are inoperative and limited. Sedroom___Second Floor Front The walls and ceiling are in marginal condition. The plaster is cracking and the ceiling is sagging. The floor is marginal and is not level. There are no electrical outlets, fixtures or switches. The door is not square. The fireplace is marginal and the flue needs to be lined. Bedroom_=_Sec2nd_Floor_Rear The walls and the ceiling are in marginal condition. The plaster is cracking. The doors and windows are in marginal condition. The fireplace is in poor conditions the hearth needs rebuilding and the flue needs lining. Bedroom_=_Third_Floor_Front Same comments'as,'Sie-cond Floor Rear .Bedroom. Mr. William Munroe 5 August 1991, Page 4 Bathrooms The bathrooms are located on the second and third floors; neither one of them is operative. Attic The insulation and ventilation systems are in poor condition. The chimneys and flues are in marginal condition. The left chimney is in need of repair, and there is evidence of leaking at the chimney flashings. The roof is in need of soffit and ridge venting. Utilities The heating, plumbing, water and electrical systems are currently inoperative. It is our opinion that the foundations at 18 Crombie Street are in danger of collapsing and that, therefore, it poses a health and safety hazard to persons within its vicinity. Indeed, were it not for the addition of the porch and corner rooms (which are them- selves now failing) it is probable that the main frame would already have toppled. Clearly, this property is a candidate for condemnation. It is our recommendation that your Department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M. G.L. Ch. 143, Sec. 6. If you have any questions or concerns, please contact us. Very truly yours, DeMarco/Jacek Par rship Charles A. DeMarco, A. I . A. onald F. a ek A. I.A. CAD:pl Enclosure x cc: William Lundregan, Esq. Douglas Ruder, Pres. I IT'f 0 :. .5.� V♦'illiam F. Weld aa FFcckcc'd- 7STATE USE ONLY O'�� y-_ 02f08_ (617) '?7.32pp -- S'lA'rE BUILDING CODE APDL%Is 1sOAl2U APPEAL APPLICATION FORA? DOCKET NUAIIIER: DATE: The undersigned herclry al/11e;,1s of the- to the Stile Ilnard of Ilnildin� Ita"ulations and Standards from the decision Iluildin; Official from the Cilt, of: Salem, Massachusetts lioard of Appeals from the Cityflown of. _ Other MuniciPal Agency/OITTcial entitled: Smte A,-enn'/OfTicial entitled: OTIIER: Dated: October 4 , ly 91 X h:rvin� been a;;�,rieved by such Interpretation Order (Check Appropriate Space)R Failure to Act Requirement Direction Other - E•>:piain Subject: (Submit a brief statement of reasons and principal points upon which thea tlicalion v Petition is based) ALL, APPROPRIATE SEC"LIONS OF TIIE CODE MUST 1iE LISTED The Owner of PI PP I or the building at 18 Crombie the Buil Ing nsppec or on ugus Street , Salem, MA requested ur uant to M. G.L. Ch. 143 Sec . 6 kee lding, InsectQr inspected the buildinttached letter) . The „he ' t' on AuQu 9 attache letter t to M.G.L. Ch, I4 t id , l69 and State briefly desired relief: The decision of the Blll.lCh. See overruled and the owner shout g Inspector should be e or ere o remove or ma e structure safe pursuant to M.G. . ec . APPELLANT.- Holyoke Square, Inc. ADDRESS FORSERvICE: Holyoke Square, Inc. , c/o William J. Lundregan , Esq. 81 Washington Street , Salem, MA O1 7 ADDRL•SS OF PROPERTI' 7elephoneNo. (508 ) 741-3888 INVOLVED: APPELLANT'S18 Crombie Street , Salem, MA 01970 CONNECTION PROPERn, INVOLVE[): Owner A PPLA PLC-1/90 ( // jQ G�G!'P. �✓ U�X�G J O William F. Weld ,.,&"ao( j&& (VAe Governor one SAxk--YCon• A" _ G '3n0' Kentaro Tsutsumi 6&&n, ✓&AJ-a� 020108 Chairman (617) 727-33(X) SERVICE NOTICE Charles J. Dinezio DOCKET NUN113ER: Administrator I, William J. Lundregan as Attorney for the Appellant/Petitioner Holyoke Square , Inc. in an appeal riled with the State Building Code Appeals Board on October 4 , 1991 IIEREM' SWEAR UNDER THE PAINS AND I'ENAI;I'IIiS OI' I'F:R.IUIiI'Tl1A'I' IN ACCORDANCE MITII THE PROCEDURES ADOPTED IIY THE STATE BOARD OF BUILDING REGULATIONS AND STANDARDS AND SI?C'I'ION 121.2.1 OFTHE STATEBUILDING, CODE- 1 SERVED OR CAUSED TO 111' SERVED, A COPY OF •(•Ills APPEAL APPLICATION ON THE FOLLOWING I'ERSON(S) IN 771E FOLLOWING MANNER: NAME. AND ADDRESS OF PERSON/AGENCY ShaiVED Nil."1,1101) OF SERVICE DATE OF SERVICE, WillidinTTg InMunroe Builspector Last and Usual October 4 , 1991 City of Salem One Salem Green Salem, MA 01970 s� ig 1 : art et t.v nrenno On the 4th Day or October 19 91 PERSONALLY APPFi1RED BEFORE NtETiiEABOVENAMED William J . Lundregan, Esq . (Type or Print the Name of the Appellant) AND ACKNOWLEDGED AND SWORE TILE ABOVE STAT(' ENTS TO BE TRUE. NOTARY PUBLIC Anne M. Poor 11/2/95 SERVNO'TE.1/90 COMMISSION EXPIRES l IIL C 'iEi T C] DeMarco • Jarek Partnership 007 tf Q• fF� CITY o Architects v"``'h & Planners 5 August 1991 William Munroe Building Inspector City Hall One Salem Green Salem, MA 01970 RE: IS Crombie Street Dear Mr. Munroe: We writing to you pursuant to M.G.L. Ch. 143, Sec. 6 in order to apprise you of the fact that the building located at 18 Crombie Street is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area. On July 3, 1990, we inspected the said building at the invitation : of its current Owner, the Holuoke Mutual Fire Insurance Company. A copy of our report is annexed hereto for your information. In summaru form, our firms findings include the following: Roof The roof appears to be 18+ years old. The lower rear portion was incorrectly flashed to the abutting wall of the house. The lower left gabel roof valleys should have been ( but were not ) lined with metal . The absence of an adequate attic ventilation system requires the installation of a continuous soffit and ridoe vent sustem, in =order to reduce excessive attic humidity. There is evidence of a pre-existing ice damming problem. The rear plumbing vent has been installed on the outside wall and does not meet the building code. Chimneu One ( 1 ) of the two (2) chimneus is in marginal condition, at best. All of its flashings have deteriorated. The chimney cap is in need of rebuilding and- all the flues need to be lined. Exterior Walls The exterior-waifs, fascias, soffits and trim are all wood and are in marginal condition. The cedar shingle siding is in marginal condition and is cuppino and splittina on most sides of the building. Paint has been peeling from all wood surfaces. The fascias, soffits and all of the corner boards are in rotted condition. The electrical entrance cables are in poor condition.. Pickering Wharf 0 223 Derby Street • Salem, Massachusetts 01970 • 508/744-4141 Mr. William Munroe 5 August 1991 Pace 2 and the service cables entering the house are rotting. Most significantly, the brick and block foundations on the front and left sides of the building are collapsing. Drainage The autters are in poor condition. The wooden gutters are rotten and the copper gutters should be (but are not ) spaced away from all fascias. The downspouts are in marginal condition. Grading around the foundation does not slope away, thus causinq water to pond. Grounds The rear wooden stairs are rotting. The rear brick patio is in marginal condition. Of major concern is the woodporch structure includinq, but not limited to, the roof, rafters, corner post, and porch decking. Floor joists and decking have been severely damaged by wood rot and wood boring insects. Doors_and_Windows All of the windows are in poor condition. Their thresholds are rotting. The entry doors are not square. All flashing around windows and door heads are in poor condition. The window sashes are loose in their casings. The entire bulkhead is unsafe. Easement The brick walls are in poor condition, and the right and rear foundation walls are collapsing. On the front and right sides. the sills are in poor condition, evidencing rot and insect damage. The right, side floor joists have been damaged bu wood boring insects. The brick support posts are in poor condition and are deteriorating. Kitchen The general structure of the kitchen is not squared and the floor is not level . Electrical circuits are veru limited. The walls. ceiling. floor and electrical outlets are all in marginal condition. M Mr. William Munroe 5 August 1991 Page 3 Hallwags_and-Entries The rear stairwell is marginal. The plaster finish in the front stairwell has loosened. Living_Room_(FrontJ The ceiling sags, due to settling of the foundation. The hardwood floor similarly is not level . Electrical outlets are in marginal to poor condition, and are limited. The windows are ,marginal due to excessive peeling of paint. The doors are marginal and are not square. The fireplace is marginal and in need of flue lining. Pining-Room The walls, ceiling and floor are all marginal . The ceiling sags and the structure has settled to the left. Outlets and fixtures are limited and in poor condition. The fireplace is marginal and in need of a flue lining. Closed_in-Porch_(Rear_Right) The floor and the ceiling sag. The outlets and fixtures are inoperative and limited. Bedroom - Second Floor Front ---------------------------- The walls and ceiling are in marqinal condition. The plaster is cracking and the ceiling is sagging. The floor is marginal and i not level . There are no electrical outlets, fixtures or switches. The door is not square. The fireplace is marginal and the flue needs to be lined. Pedroom___Seccnd_Floor Rear The walls and the ceiling are in marginal condition. The plaster is cracking. The doors and windows are in marginal condition. The fireplace is in poor condition; the hearth needs rebuilding and the flue needs linina. . _P•edroom___Third_Floor_Front Same comments'as,Second Floor Rear .Bedroom. Mr. William Munroe 5 August 1991, Page 4 Eathrooms The bathrooms are located on the second and third floors; neither one of them is operative, Attic The insulation and ventilation systems are in poor condition. The chimneys and flues are in marginal condition. The left chimney is in need of repair, and there is evidence of leaking at the chimney flashings. T4ie roof is in need of soffit and ridge venting. Utilities The heating, plumbing, water and electrical systems are currently inoperative. It is our opinion that the foundations at 18 Crombie Street are in danger of collapsing and that, therefore, it poses a health and safety hazard to persons within its vicinity. Indeed, were it not for the addition of the porch and corner rooms (which are them- selves now failing) it is probable that the main frame would already have toppled. Clearly, this property is a candidate for condemnation. It is our recommendation that your Department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M. G.L. Ch. 143, Sec. 6. If you have any questions or concerns, please contact us. Very truly yours, DeMarco/Jarek Par rship Charles A. DeMarco, A. I . A. Ponald F. a ek A. I.A. CAD:pl Enclosure cc: William Lundr6gan, Esq. Douglas Ruder, Pres. Salem Redevelopment 44-6900 Authority ONE SALEM GREEN, SALEM, MASSACHUSETTS 01970 TELEPHONE 744.4580 February 10, 1992 State Board of Building Regulations and Standards McCormack State Office Building One Ashburton Place - Room 1301 Boston, MA 02108 RE: Holyoke Square Inc. 18 Crombie Street Dear Sirs/Madams : I am writing concerning the appeal of Holyoke Square, Inc. , which requests that the State Board of Building Regulations and Standards reverse a decision of William Munroe, Salem' s Inspector of Buildings, for the dwelling at 18 Crombie Street. Holyoke has gone through various local processes in attempt to demolish the building in question. In November, 1990, the Salem Historical Commission denied Holyoke 's request to waive the Demolition Delay Ordinance. In April, 1991, the Salem Historical Commission' s final recommendation was in opposition to the granting of a demolition permit. In May, 1991, the Salem Redevelopment Authority (SRA) denied Holyoke ' s request for demolition of 18 Crombie Street. An appeal of the SRA' s decision by Holyoke is currently pending in Superior Court. Prior to the SRA' s decision, the City of Salem contracted Robert M. Rumpf & Associates to provide an independent structural condition report of the property. The report recommended that only the back porch of the building be torn down and provided reasonable minimal requirements to adequately rehabilitate the structure. The report concluded that the building was not a hazard to public safety and welfare. It is my opinion that Holyoke is not appealing the decision of Salem' s Inspector of Buildings out of concern for public safety and welfare, but is attempting to use the State Building Code appeals process as a means of fulfilling their own independent objectives . I urge you to uphold the fi ings of Mr. Munroe and to deny the appeal of Holyoke Square, I Wcerytrator Salem Istorical Commission ONE SALEM GREEN,SALEM, MASSACHUSETTS 01970 (6171745-9595. EXT. 311 February 10, 1992 State Board of Building Regulations and Standards McCormack State Office Building One Ashburton Place - Room 1301 Boston, MA 02108 Dear Sirs/Madams : The Salem Historical Commission is writing with regard to the appeal by Holyoke Square, Inc. for 18 Crombie Street in Salem, MA. The appellant requests that a decision of the Inspector of Buildings for the City of Salem be overruled and that the owner should be ordered to remove or make the structure safe pursuant to M.G.L. Ch. 143, Sec . 6 . In September, 1990, Holyoke Square, Inc. requested a waiver of the Demolition Delay Ordinance from the Salem Historical Commission in order to demolish 18 Crombie Street. The purpose of the proposed demolition was to create a parking lot and to "landbank" the site for future use. To facilitate our decision, members of the Salem Historical Commission, including a licensed architect, an architectural designer, an historian and a contractor specializing in the restoration of historic properties, inspected 18 Crombie Street. The Commission found that building was in relatively sound condition with no significant deflection in the floors, walls or ceilings . The Commission found that the house was not racked as much as the estimate of DeMarco-Jarek Partnership, Holyoke' s architect, and the Commission found that there was no evidence that the house in continuing to rack. The Commission also found that the gradual settling and modest racking of a house of this age is not a condition to prove the structure to be unsafe. Ceiling beams of the house show no evidence of bug or water damage except for one small area. The house framing was in excellent condition. The brick foundation showed no major cracks, settlement or fissures and there was no evidence that any corner is slipping. The foundations may be out of plumb one or two inches, which is not surprising for the age of the house, but they did not appear to be unsound. There was one small area of sill rot. There was evidence that the house was moved to this location and, therefore, the foundations may be newer than the rest of the house. There was no musty smell to the house, indicating that there has been no sepage of water into the basement. 18 Crombie Street is one of seven properties located within the Crombie Street National Register District (which is the only surviving downtown residential district from the early 19th century) . Based on these findings, the Commission voted not to waive the Demolition Delay Ordinance. The Commission' s final recommendation was in opposition to the granting of a demolition permit for this historically significant building. In May, 1991 , the Salem Redevelopment Authority, within whose jurisdiction 18 Crombie Street resides, voted to deny Holyoke' s request for demolition. Holyoke has since filed an appeal of this decision with Superior Court. The City of Salem proudly contains a myriad of historic homes - many of which are in greater disrepair than 18 Crombie Street. To allow the demolition of this property, as being a hazard to the public safety and welfare, would be to suggest that several hundred homes in Salem should be leveled. The Salem Historical Commission is in complete agreement with Salem' s Inspector of Buildings ' letter of August 29 , 1991 to Charles DeMarco. We sincerely hope that the State Board of Building Regulations and Standards will deny the appeal of Holyoke Square, Inc . Thank you for your consideration. Sincerely, IrH�SALE HISTOR C L COMMISSION John H. Carr, Jr. Vice Chairman VtV *aiem' *Va55agU5ettg -Public Vroperty Di apartment uilbing department One *aiem Orem 745-9595 Ext. 380 William H. Munroe Director of Public Property Inspector of Buildings Zoning Enforcement Officer August 29, 1991 Charles A. DeMarco, A.I.A. DeMarco and Jarek Partnersnip Pickering Wharf 223 Derby Street Salem, MA 01970 RE: 18 Crombie St. , Salem Dear Mr. DeMarco: In response to your request and accompanied by David Harris, Assistant Building Inspector, Attorney William Lundregan and you, I made an inspection of the above referenced property on August 18, 1991 to determine the structural stability of the building located on the site. Considering the fact that the structure is about one hundred sixty ( 160) years old I found it to be in reasonably good condition. The frame of the structure was in extremely good condition with the exception of a couple of areas of the sill plate which showed some water damage and carpenter ant infestation. I was surprised to find the foundation wall was red brick rather than stone indicating the foundation may be much newer than the house. The foundation has some areas that are in need of repair but there was no sign of there being stress enough to cause failure. The electrical, heating and plumbing should be upgraded to meet the needs of todays appliances. It is my opinion that, although this single family house has a number of problems, it has not deteriorated to the point of being a hazard to the public safety and welfare, and to order it demolished at this time would be premature. Sincerely, 411m Munroe Inspector of Buildings WHM:bms cc: William Lundregan, Esq. Cusmr " .:. Salem Hist®ricai ®m�nissa®n ONE SALEM GREEN,SALEM, MASSACHUSETTS 01970 (617) 745-9595,EXT.311 April 12, 1991 FINAL RECOMMENDATION REGARDING DEMOLITION PERMIT William Munroe Director of Public Property City of Salem One Salem Green Salem, MA 01970 RE : 18 Crombie Street Dear Mr . Munroe : As per Part II , Chapter 2 , Article XV, Divison 2, Section 2-394 (demolition Delay ) of the Code of Ordinances , the Salem Historical Commission hereby submits this written recommendation regarding the demolition of 18 Crombie Street . The Salem Historical Commission is opposed to the granting of a demolition permit for 18 Crombie Street due to the property being a historically significant building within the Crombie Street National Register District . Sincerely, Annie C . Harris Chairman cc : Holyoke Square, Inc . -�'U|LU F//T �- 2 ��^�[n����� �������JQ� ONE SAL EHGREEN.SALEM. MASSACHUSETTS ole70 .o1n7^5-06ys, EXT 311 PRELIMINARY RECOMMENDATION REGARDING DEMOLITION 288MI? RE. 18 Crombie Street On Wednesday, November 7 , 1990 / the Salem Historical Commission unanimously voted in opposition to the granting of a permit for demolition for 18 Crombie Street as proposed by Holyoke Square Inc . through its representative William J. Luodregan/ Esq. As per Part II , Chapter 2 , Article X\/, Division 2, Section 2-394 (Demolition Delay ) of the Code of Ordinances, no permit for demolition shall be issued until a more thorough investigation is undertaken and a final written recommendation regarding the granting of the permit for demolition is provided by the Commission to the Director of Public Property and to the property owner . Such investigation and recommendation shall be completed within 180 days of the original submission (October lS/ 1090 ) to the Historical Commission. I attest that this is an accurate record of the vote taken, not amended or modified in any way to this date . November 12 / 1990 Ja 8, Guy Cl��k o� the C��miasiou Tr^ C/ Miss Building Inspector City Clerk J8isCom8/Deoial7 � 1 S � 1 7/j /{� 1l .1 a��: : Jir'�:id9'LvJI v.J 9lJrJ7JRZ.Z�6.� ONE SAL EPA GREEN SALEM. PAASSACH'JSE77S 312-10 c 1 71 445-9595. E<T. -!! I PRELIMINARY RECOMMENDATION REGARDING DEMOLITION PERMIT RE: 18 Crombie Street On Wednesday, November 7, 1990, the Salem Historical Commission unanimously voted in opposition to the granting of a permit for demolition for 18 Crombie Street as proposed by Holyoke Square Inc . through its representative William J. Lundregan, Esq. As per Part II , Chapter 2, Article XV, Division 2 , Section 2-394 (Demolition Delay ) of the Code of Ordinances , no permit for demolition shall be issued until a more thorough investigation is undertaken and a final written recommendation regarding the granting of the permit for demolition is provided by the Commission to the Director of Public Property and to the property owner. Such investigation and recommendation shall be completed within 180 days of the original submission (October 15, 1990 ) to the Historical Commission. I attest that this is an accurate record of the vote taken, not amended or modified in any way to this date . November 12, 1990 Jan A. Guy C14/k of the C mission cc : Building Inspector City Clerk JHisCom8/Denial7 dale �oard o��ud/di �� daliaxa and A"Wa lW4 William F. Weld ./l' oxmaaE Jule l� 'e ✓clog Governor one Awwo&n gLe; _ G /J07 02f08 Kentaro Tsutsumi ✓�oa�a�e, ��aaaadEu�a Chairman (617) 727-3200 Charles J. Dinezio Administrator n r? December 6, 1991 — William Munroe rn One Salem Green = , Salem, MA 01970 Docket Number: 91-116 _ Property Address: 18 Crombie Street, Salem, MA Hearing Date: December 19, 1991 Hearing Time: 9:30 AM The Appeal for the subject property has been scheduled to be heard on the hearing date and time indicated above. The hearing will take place in the State Board of Building Regulations and Standards (BBRS) Conference Room (Room 1301) at the McCormack State Office Building, One Ashburton Place, Boston Massachusetts 02108. The State Building Code Appeals Board requires your presence or that of you representative at its hearing relative to the above mentioned case. Please brine with you a copy of the record, including any documents, plans, sketches, drawings, etc., that will help to give the Appeals Board grounds to adjudicate this appeal. Sincerely; THE STATE BOARD OF BUILDING REGULATIONS AND STANDARDS Kathy McNeil Administrative Secretary 0�e T6oWvrrroouu�a C o��ac�tuaell6 A � /[J /, William 4('. Weld �:/()[�(Q.�9f.6 � and �� i o,yeaaE Jtale Governor ,� >I xerCo�c lace - 9a6,m mol Kentaro Tsutsumi "adm6eff4 02f08 Chairman (617) 727.3200 Charles J. Uinezio Administrator c January 27 , 1992 r'• William H Munroe Inspector of Buildings One Salem Green-2nd Floor Salem MA 01970 Docket Number: 91-116 Property Address: 18 Crombie Street, Salem Hearing Date: February 11, 1992 Hearing Time: 9: 30 AM The Appeal for the subject property has been scheduled to be heardon the hearing date and time indicated above. The hearing will takeplace in the State Board of Building Regulations and Standards(BBRS) Conference Room (Room 1301) at the McCormack State OfficeBuilding, One Ashburton Place, Boston Massachusetts 02108. The State Building Code Appeals Board requires your presence or thatof your _representitive at its hearing relative to the abovementioned case. Please bring with you a copy of the record, including any documents,plans, sketches, drawings, etc. , that will help to give the AppealsBoard grounds to adjudicate this appeal. Sincerely; THE STATE BUILDING CODE APPEALS BOARD Kathy McNeil Administrative Secretary I j^ DeMarco • Jarek tt ' Partnership Architects --{®� & Planners c August 1991 William Monroe Building inspector City Fail One Salem Green Salem, MA 01970 RE: IS Crombin ctr eat Dear Mr. Munroe: ;e are writing to you pursuant to M. G. L. _h. 143. Sec, 6 in order to apprise you of the fart that the jyildin❑ located at IS Crombie Street is in a state of disreoair and if ,.c:t corrected will pose a hazard to the well-being of pedestrians in the .area. On July 3, 1990, we inspected the said building at the invitation of its current Owner. the Holuoke Mutual Fire insurance vomgam_. A copy of our report is annexed hereto for your information. In summary form, our firms findings include the following : Roof The roar appears to be le+ years old. The lower rear portion was incorrectly flashed to the abutting wall of the house. The lower left gabel roof valleys should have been ( but were not ) lined with metal . The absence of an adequate attic ventilation system requires the installation of a continuous soffit and ridge vent system, in order to reduce excessive attic humldltu. There is evidence of a pre-existing ice damming problem. The rear plumbing vent has been installed on the outside wall and does not meet the building code. Chimney One ( 1 ) of the two ( ) chimneys is in marginal condition, at best. All of its flashings have deteriorated. The chimney cap is in need of rebuilding and all the flues need to be lined. Uteriar Walls -------------- The exterior walls, fascias, soffits and trim are all wood and are in marginal condition. The cedar shingle siding is in marginal condition and is cupping and splitting on most sides of the building. Paint has been peeling from all wood surfaces. The fascias, soffits and all of the corner boards are in rotted condition. The electrical entrance cables are in poor condition. Pickering Wharf • 223 Derby Street 0 Salem, Massachusetts 01970 • 508/744-4141 KIMLING DEQ F Mr. William Munroe 5 August 1941 ;IZ3 I � ;i 39 .. ? Page K=n ID - MY C z G ASS. and the service cables entering the house are rottina, Most significantly, the brick: and block foundations on _he front and left sides of the building are collapsing. Dra age The Gutters are in poor condition. The wooden gutters are rotten and the copper gutters should be ! but are not ) spaced away from, all fascias. The downspouts are in marginal condition. Grading around the foundation doe=_ not slope _.way, thus causing water to pond. Grounds The rear wooden stairs are rotting. The rear brick patio is in marginal condition. Of major concern is the wood porch structure including, but not limited to, the roof , rafters, corner post, and porch decking. Floor joists and decking have been severely damaged by wood rot and wood boring insects. Doors and Windows All of the windows are in poor condition. Their thresholds are rotting. The entru doors are not square. All fla.shina around windows and door heads are in poor condition. The window sashes are loose in their casinos. The entire bulkhead is unsafe. Easement The brick walls are in poor condition, and the right and rear foundation walls are collapsing. On the front and right sides, the sills are in poor condition, evidencina rot and insect damage. The right side floor joists have been damaged by wood boring insects. The brick: support posts are in poor condition and are deteriorating. Kitchen The general structure of the kitchen is not squared and the floor is not level . Electrical circuits are very limited. The walls. ceiling, floor and electrical outlets are all in marginal condition. Mr. William Munroe �) 5 August 1991 Page C!T'i hiallwaus and Entries -------------------- The rear stairwell is marginal . The plaster finish in the front stairwell has loosened. Living-Room-(Front ) The ceiling sags, due to settling of the foundation. The hardwood floor similarly is not level . Electrical outlets are in marginal to poor condition, and are limited. The windows are marainal due to excessive peeling of paint. The doors are marginal and are not square. The fireplace is marainal and in need of flue lining. P-in in Rgom The walls, ceiling and floor are all marginal . The ceiling sags and the structure has settled to the left. Outlets and fixtures are limited and in poor condition. The fireplace is marginal and in need of a flue lining. Closed-In_Porch_ ( Rear_Right ) The floor and the ceiling_ sag_ . The outlets and fixtures are inoperative and limited. Bedroom - Second Floor Front _ _Qojr_ rn± The walls and ceiling are in marginal condition. The plaster is cracking and the ceiling is sagging. The floor is marginal and is not level. There are no electrical outlets, fixtures or switches. The door is not square. The fireplace is marainal and the flue needs to be lined. Bedroom - Second Floor Rear --------------------------- The walls and the ceiling are in marainal condition. The plaster is cracking. The doors and windows are in marginal condition. The fireplace is in poor condition ; the hearth needs rebuilding and the flue needs lining. Bedroom - Third Floor Front --------------------------- Same comments as Second Floor Rear Bedroom. 6UILDI:"G r PT Mr. 'W41liam Munroe August 1991 Page 4 05. CII ( Ci :, Bathrooms The bathrooms are located on the second and third floors: neither one of =hem is operative. Attic The insulation and ventilation systems are in poor condition. The chimneys and flues are in marginal condition. The left chimney is in need of repair, and there is evidence of leaking at the chimney flashino=_.. The roof is in need of soffit and ridge ventinq. Utilities The heating, plumbing, water and electrical systems are currently inoperative. It is our opinion that the foundations at IS Crombie Street are in danger of collapsing and that, therefore, it poses a health and safety hazard to persons within its vicinity. Indeed, were it not for the addition of the porch and corner rooms (which are them— selves now failing) it is probable that the main frame would already have toppled. Clearly, this property is a candidate for condemnation. It is our recommendation that your Department conduct an immediate inspection of its own, and then issue an order to the Iwner to remove the structure or make it safe, pursuant to M. G. L. Ch. 143, Sec. S. If you have any questions or concerns, please contact us. Veru truly yours, DeMarco/Jarek Par . rship Charles A. DeMarco, A. I .A. Ponald F. a Ek A. I.A. CAD:pl Enclosure cc: William Lundregan, Esq. Douglas Ryder, Pres. SUrtUFnC; DEPT 0 DeMarco • )arek Partnership OCT �' 00 RECqVOD Ift rg' C • Architects QTYFSALEM,M4SS. & Planners 5 August 1991 William Munroe Building Inspector City Hall One Salem Green Salem, MA 01970 RE: 18 Crombie Street Dear Mr. Munroe: We are writing to you pursuant to M_G.L. Ch. 143, Sec. b in order to apprise you of the fact that the building located at 18 Crombie Street is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area. On July 3, 1990, we inspected the said building at the invitation of its current Owner, the Holyoke Mutual Fire Insurance Compan . A copy of our report is annexed hereto for your information. in summary form, our firms findings include the following : Roof The roof appears to be 18+ years old. The lower rear portion was incorrectly flashed to the abutting wall of the house. The lower left gabel roof ,.alleys should have been (but were rot ) lined with metal. The absence of an adequate attic ventilation system requires the installation of a continuous soffit and ridge vent system, in order to reduce excessive attic humidity. There is evidence of a pre-existing ice damming problem. The rear plumbing_ vent has been installed on the outside wall and does not meet the building code. Liiim ey One ( 1 ) of the two (2) chimneys is in marginal condition, at best. All of its flashings have deteriorated. The chimney cap is in need of rebuilding and. all the flues reed to be lined. E''t ort or Wails .N The exterior-wSTS, fascias, soffits and trim are all wood and are in odor s.marginal condition. The cedar shingle siding is in marginal condition and is cupping and spitting on most sides of the building. Paint has been peeling from all wood surfaces._ __. The fascias, soffits and all of the corner boards are 'in rotted condition. The electrical entrance cables are in poor condition. Pickering Wharf 0 223 Derby Street 0 Salem, Massachusetts 01970 • 508/744-4141 Mr. William Munroe 5 August 1991 Page 2 and the service cables entering the house are rotting. Most significantly, the brick and block foundations on the 'front and left sides of the building are collapsing. Drainage The gutters are in poor condition. The wooden gutters are rotten and the copper gutters should be (but are not) spaced away from all fascias. The downspouts are in marginal condition. Grading around the foundation does not slope away, thus causing water to pond. Grounds The rear wooden stairs are rotting. The rear brick patio is in marginal condition. Of major concern is the wood porch structure including, but not limited to, the roof, rafters, corner post, and porch decking. Floor joists and decking have been severely damaged by wood 'rot and wood boring insects. Doors_and_W_ndows All of the windows are in poor condition. Their thresholds are rotting. The entry doors are not square. All flashing_ around windows and door heads are in poor condition— The window sashes are loose in their casings. The entire bulkhead is unsafe. Rasement The brick walls are in poor condition,, and the right and rear foundation walls are collapsing. On the front and right sides, the sills are in poor condition, evidencing rot and insect damage. . The right, side floor joists have been damaged by wood boring inserts. The brick support posts are in poor condition and are deteriorating. Kitchen The general structure of the kitchen is not squared and the floor is not level . Electrical circuits- aro veru limited. The waii5, ceiling, floor and electrical outlets are a!! in marginal condition. ,. Mr. William Munroe 5 August 1991 Page 3 . Ha 11wagE_2nd_Entries The rear stairwell is marginal. The plaster finish in the front stairwell has loosened. Li v_ing_Rogm_(Front ) The ceiling sags, due to settling of the foundation. The hardwood floor similarlu is not level . Electrical outlets are in marginal to poor condition, and are limited. The windows are marginal due to excessive peeling of paint. The doors are marginal and are not square. The fireplace is marainal and in need of flue lining. Pining-Room The walls, ceiling and floor are all marginal . The ceiling sags and the structure has settled to the left. Outlets and fixtures are limited and in poor condition. The fireplace is marginal and in need of a flue lining. Closed_In_Porch_(Rear_Riaht) The floor and the ceilina spa. The outlets and fixtures are inoperative and limited. Sedroom___Second_Floor-Front The wails and ceilingg are in marginal condition. The Plaster i= _-cracking and the cell _- g ina is sagging. The floor is marainal and i not level. There are no electrical outlets, fixtures or switches. The door is not square. The fireplace is marninal and the flue needs to be lined. Bedroom ---cecond_Floor_Rear The walls and the ceiling are in marainal condition. The plaster is cracking. The doors and windows are in marginal condition. The fireplace is in poor condition; the hearth needs rebuilding and the flue needs lining. . Eedroar:, -_Tt,ird_ laor_Front Same commen' s as;Sscond Floor Rear .Bedroom. Mr. William Munroe 5 August 1991, Page 4 Bathrooms The bathrooms are located on the second and third floors; neither one of them is operative. Attic The insulation and ventilation systems are in poor condition. The chimneys and flues are in marginal condition. The left chimney is in need of repair, and there is evidence of leaking at the chimney flashings. Ttie roof is in need of soffit and ridge venting. Utilities The heating, plumbing, water and electrical systems are currently inoperative. It is our opinion that the foundations at IS Crombie Street are in danger of collapsing and that, therefore, it poses a health and safety hazard to persons within its vicinity. Indeed, were it not for the addition of the porch and corner rooms (which are them- selves now failing) it is probable that the main frame would already have toppled. Clearly, this property is a candidate for condemnation. It is our recommendation that your Department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M.6.". Ch. 1141, Sec. 6. If _you have any questions or concerns, please contact us. Very truly yours, DeMarco/Jacek Par rship Charles A. DeMarco, A. I . A. ponaldA. I.A. CAD.pl ` . Enclosure x cc, William Lundr6gan, Esq. Douglas Ruder, Pres. A44 U&axd/ pol�a A u�, andAxelz,� William F. Weld `/�et�oa�mao� J�a(.e rjrire ✓p W"Mu q Governor rtw A&Ww6n gtc; _ Room -180-1 Kentaro Tsutsumi �caCo�g ✓ff�ella 021,08 Chairman (617) 727-3200 Charles J. Dinezio Administrator STATE BUILDING CODE APPEALS POARD June 3, 1992 William J. Lundregan, Esq. 81 Washington St. Salem, MA 01970 RE: Docket: #91-116 Property Address: 18 Crombie Street Salem, MA 01970 We are pleased to enclose a copy of the decision relative to the above-mentioned case wherein certain variances from the State Building Code had been requested. Sincerely, STATE BUI ING CODE APPE�B ARD Thomas M. Riley Clerk cc: State Building Code Appeals Board �>�te Ur om�m,4�tll�eca,� �.�ac,ltu,6e�`b rf . late oBocrad `7 Auaz�nyeadati AaanJd,�AndaxtZ William F. Weld ✓rCCIOo�maa� /&& tv*,e Aa- ","� Governor tvvw &A 'ce _ Room x,30-/ Kentaro Tsutsumi G . ✓��+ 02108 Chairman (617) 727-3200 Charles J. Dinezio Administrator STATE BUILDING CODE APPEALS BOARD Docket #91-116 Date: June 3, 1992 In accordance with MGL c143, Section 100 and the Commonwealth of Massachusetts State Building Code, this Appeals Board has found the following: The appellant, Holyoke Square, Inc., on October 4, 1991, appealed to this Appeals Board the decision of the Building Official, City of Salem, dated August 29, 1991. Although a public hearing was originally scheduled for December 19, 1991, the appellant requested postponement and the public hearing was ultimately held on February 11, 1992, in Boston before members of the State Board of Building Regulations and Standards who acted as the State Building Code Appeals Board and in such capacity, a majority of the said Appeals Board found in its opinion the enforcement of the Massachusetts State Building Code would not do manifest injustice to the appellant and the relief requested would conflict with the general objectives of the State Building Code and any of its enabling legislation. There were present at the said hearing: William J. Lundregan, Holyoke Square, Inc., 81 Washington St., Salem, MA 01970 David Harris, Building Inspector, Salem Bldg. Dept., 1 Salem Green, Salem, MA 01970 Leonard F. Femino, Asst. City Solicitor, One School St., Salem, MA 01915 Jane A. Guy, Salem Planning Dept., One Salem Green, Salem, MA 01970 Charles DeMarco, Holyoke Square, Inc., 223 Derby St., Salem, MA 01970 STATE BUILDING CODE APPEALS BOARD Docket #91-116 DateGune 3, 1992 The appellant testified that Holyoke Square, Inc., acquired the property at interest with the intention of utilizing same for commercial purposes but sometime after purchase determined that renovations to the property would be cost prohibitive, in part due to the structural condition of the building. The appellant testified it is the contention of Holyoke Square,Inc.,supported by consultants'evaluations,that the building should be viewed as an unsafe structure and consequently, in accordance with MGL c143 s6, the Building Official should order that the building be demolished (Nucci Vine Associates "Building Monitoring Report",dated 2/10/'92 and the"Overview Study"of DeMarco/Jarek Partnership,dated September 9, 1990 are the consultants' reports offered in support of the contention that the building is unsafe). The City of Salem testified that the building at interest did have certain structural problems related to age, construction and decay,but did not view such condition as warranting an"unsafe building"call per MGL c143 s6,and offered as additional proof of this position,the report of Robert M. Rumpf&Associates -"Structural Report, 18 Crombie SL, Salem, MA", dated 3/18/91. It came to light during testimony that the appellant and the City of Salem are currently in Essex Superior Court regarding the same property but on matters tied to City by-laws affecting properties within Salem's "redevelopment area"-the appellant noted however that he was before the State Building Code Appeals Board simply on the "unsafe building" issue as addressed in MGL c143 s6. Having heard all testimony and noting.that both the appellant's consultants and the City's consultant and__.._..._____.__ Building Department do not view the building as in danger of imminent collapse (although all parties recognize the building's deteriorating condition), the Board unanimously voted to uphold the decision of the City of Salem Building Department and does not find sufficient reason to require the immediate condemnation and demolition of said building. SO ORDERED STATE BUILDING CODE APPEALS BOARD Docket #91-116 DateJune 3, 1992 The following Board Members were present and voted in the above manner: Lcr�Chairman, � William P. Kramer L John B rover ��-t� James allisey -zsvv C/A true copy attest, dated / ! terkk Thomas M. Riley Any person aggrieved by a decision of the State Building Code Appeals Board may appeal to a court of competent jurisdiction in conformance with Chapter 30A, Section 14 of the General Laws. e T CITY OF SALEM - MASSACHUSETTS KEVIN Dor Legal Department City Solicitor icittor LEONARD F. FEMINO 508-745-0500 93 Washington Street Assistant City Solicitor Salem, Massachusetts 01970 508-921-1990 June 30, 1992 William Luster, City Planner City of Salem One Salem Green Salem, MA 01970 Dear Bill: Enclosed herewith please find a copy of the decision from the State Building Code Appeals Board regarding 18 Crombee Street for your files. g yours, ooaid F. Femino LFF/gsw Enclosure cc: David Harris, Assistant Building Inspector I ,.CONDIT.{,A.�c AfOLNINE DD?P Salem Historical Commission ONE SALEM GREEN,SALEM, MASSACHUSETTS 01970 (617)745-9595,EXT.311 February 10, 1992 State Board of Building Regulations and Standards McCormack State Office Building One Ashburton Place - Room 1301 Boston, MA 02108 Dear Sirs/Madams : The Salem Historical Commission is writing with regard to the appeal by Holyoke Square, Inc. for 18 Crombie Street in Salem, MA. The appellant requests that a decision of the Inspector of Buildings for the City of Salem be overruled and that the owner should be ordered to remove or make the structure safe pursuant to M.G.L. Ch. 143, Sec . 6 . In September, 1990, Holyoke Square, Inc. requested a waiver of the Demolition Delay Ordinance from the Salem Historical Commission in order to demolish 18 Crombie Street. The purpose of the proposed demolition was to create a parking lot and to "landbank" the site for future use. To facilitate our decision, members of the Salem Historical Commission, including a licensed architect, an architectural designer, an historian and a contractor specializing in the restoration of historic properties, inspected 18 Crombie Street. The Commission found that building was in relatively sound condition with no significant deflection in the floors, walls or ceilings . The Commission found that the house was not racked as much as the estimate of DeMarco-Jarek Partnership, Holyoke 's architect, and the Commission found that there was no evidence that the house in continuing to rack. The Commission also found that the gradual settling and modest racking of a house of this age is not a condition to prove the structure .to be unsafe. Ceiling beams of the house show no evidence of bug or water damage except for one small area. The house framing was in excellent condition. The brick foundation showed no major cracks, settlement or fissures and there was no evidence that any corner is slipping. The foundations may be out of plumb one or two inches, which is not surprising for the age of the house, but they did not appear to be unsound. There was one small area of sill rot. There was evidence that the house was moved to this location and, therefore, the foundations may be newer than the rest of the house. There was no musty smell to the house, indicating that there has been no sepage of water into the basement. 18 Crombie Street is one of seven properties located within the Crombie Street National Register District (which is the only surviving downtown residential district from the early 19th century) . Based on these findings, the Commission voted not to waive the Demolition Delay Ordinance. The Commission' s final recommendation was in opposition to the granting of a demolition permit for this historically significant building. In May, 1991, the Salem Redevelopment Authority, within whose jurisdiction 18 Crombie Street resides, voted to deny Holyoke' s request for demolition. Holyoke has since filed an appeal of this decision with Superior Court. The City of Salem proudly contains a myriad of historic homes - many of which are in greater disrepair than 18 Crombie Street. To allow the demolition of this property, as being a hazard to the public safety and welfare, would be to suggest that several hundred homes in Salem should be leveled. The Salem Historical Commission is in g complete agreement with P i Salem' s Inspector of Buildings ' letter of August 29 1991 to P g g Charles DeMarco. We sincerely hope that the State Board of Building Regulations and Standards will deny the appeal of Holyoke Square, Inc. Thank you for your consideration. Sincerely, HE SALE HISTORIC L COMMISSION John H. Carr, Jr. Vice Chairman d CITY OF SALEM - MASSACHUSETTS KEVINT. DALY,' City Solicitor i , Legal Department,. . LEONARD F.FEMINO 508-745-0500 93 Washington Street Assistant City Solicitor Salem, Massachusetts 01970 508-921-1990 June 30, 1992 William Luster, City Planner City of Salem One Salem Green Salem, MA 01970 Dear Bill: Enclosed herewith please find a copy of the decision from the State Building Code Appeals Board regarding 18 Cromhee Street for your files. Very tr yours, onard F. Femino LFF/gsw Enclosure cc: David Harris, Assistant Building Inspector �' C�xecu/i�le � iCe t�✓ ul�calalety .Male -Toard of Auld Ala"ona aced Anda William F. Weld J&& C)ffw _0&a ntr Governor CCW Q&"f0&ft 0)" _ Room -/,To/ Kentaro Tsutsumi �t)o6lon, /�aaaac�u�aet7a 0,2fON Chairman (617) 727-3200 Charles J. Dinezio Administrator STATE BUILDING CODE APPEALS BOARD Docl:A #91-116 Date: June 3, 1992 In accordance with MGL c143, Section 100 and the Commonwealth of Massachusetts State Building Code, this Appeals Board has found the following: The appellant, Holyoke Square, Inc., on October 4, 1991,appealed to this Appeals Board the decision of the Building Official, City of Salem, dated August 29, 1991. Although a public hearing was originally scheduled for December 19, 1991, the appellant requested postponement and the public hearing was ultimately held on February 11, 1992, in Boston before members of the State Board of Building Regulations and Standards who acted as the State Building Code Appeals Board and in such capacity, a majority of the said Appeals Board found in its opinion the enforcement of the Massachusetts State Building Code would not do manifest injustice to the appellant and the relief requested would conflict with the general objectives of the State Building Code and any of its enabling legislation. There were present at the said hearing: William J. Lundregan, Holyoke Square, Inc., 81 Washington St., Salem, MA 01970 David Harris, Building Inspector, Salem Bldg. Dept., 1 Salem Green, Salem, MA 01970 Leonard F. Femino, Asst. City Solicitor, One School St., Salem, MA 01915 Jane A. Guy, Salem Planning Dept., One Salem Green, Salem, MA 01970 Charles DeMarco, Holyoke Square, Inc., 223 Derby St., Salem, MA 01970 STATE BUILDING CODE APPEALS BOARD Docket #91416 Datejune 3, 1992 The appellant testified that Holyoke Square, Inc., acquired the property at interest with the intention of utilizing same for commercial purposes but sometime after purchase determined that renovations to the property would be cost prohibitive, in part due to the structural condition of the building. The appellant testified it is the contention of Holyoke Square, Inc.,supported by consultants'evaluations,that the building should be viewed as an unsafe structure and consequently, in accordance with MGL c143 s6, the Buildin, Official shoold order that the building be demolished (Nucci Vine Associates "Building Monito!in! Report",dated 2/10/92 and the "Overview Study"of DeMarco/Jarek Partnership,dated September 9, 1990 are the consultants' reports offered in support of the contention that the building is unsafe). The City of Salem testified that the building at interest did have certain structural problems related to age, construction and decay,but did not view such condition as warranting an "unsafe building"call per MGL c143 s6, and offered as additional proof of this position,the report of Robert M. Rumpf&Associates - "Structural Report, 18 Crombie St., Salem, MA", dated 3/18/91. It came to light during testimony that the appellant and the City of Salem are currently in Essex Superior Court regarding the same property but on matters tied to City by-laws affecting properties within Salem's "redevelopment area"-the appellant noted however that he was before the State Building Code Appeals Board simply on the "unsafe building" issue as addressed in MGL c143 s6. Having heard all testimony and noting that both the appellant's consultants and the City's consultant and Building Department do not view the building as in danger of imminent collapse (although all parties recognize the building's deteriorating condition), the Board unanimously voted to uphold the decision of the City of Salem Building Department and does not find sufficient reason to require the immediate condemnation and demolition of said building. SO ORDERED STATE BUILDING CODE APPEALS BOARD Docket #91-116 Datejune 3, 1992 The following Board Members were present and voted in the above manner: Chairman, William P. Kramer "` John E. rover �yizt— James allisey -sem-1 ("tu'C- A true copy attest, dated I t Thomas M. Any person aggrieved by a decision of the State Building Code Appeals Board may appeal to a court of competent jurisdiction in conformance with Chapter 30A, Section 14 of the General laws. a _ J" :lJoard of Aw"wyp �li /tea and J&ndo William F. Weld /[�C(�a�rnadE JCa& CAV 'OAA" t�v Governor C." ,QU G _ Room /,10- Kentaro Tsutsumi ✓� . 1&aad&4e0 0,2708 Chairman (617) 727-3200 Charles J. Dinezio n ' Administrator r� January 27, 1992 William H Munroe Inspector of Buildings One Salem Green-2nd Floor Salem MA 01970 Docket Number: 91-116 Property Address: 18 Crombie Street, Salem Hearing Date: February 11, 1992 Hearing Time: 9: 30 AM The Appeal for the subject property has been scheduled to be heardon the hearing date and time indicated above. The hearing will takeplace in the State Board of Building Regulations and Standards(BBRS) Conference Room (Room 1301) at the McCormack State OfficeBuilding, One Ashburton Place, Boston Massachusetts 02108. The State Building Code Appeals Board requires your presence or thatof your representitive at its hearing relative to the abovementioned case. Please bring with you a copy of the record, including any documents,plans, sketches, drawings, etc. , that will help to give the AppealsBoard grounds to adjudicate this appeal. Sincerely; THE STATE BUILDING CODE APPEALS BOARD Kathy McNeil Administrative Secretary Salem Redevelopment 44-6900 Authority ONE SALEM GREEN, SALEM, MASSACHUSETTS 01970 TELEPHONE 744 -4580 February 10, 1992 State Board of Building Regulations and Standards McCormack State Office Building One Ashburton Place - Room 1301 Boston, MA 02108 RE : Holyoke Square Inc. 18 Crombie Street Dear Sirs/Madams : I am writing concerning the appeal of Holyoke Square, Inc . , which requests that the State Board of Building Regulations and Standards reverse a decision of William Munroe, Salem' s Inspector of Buildings, for the dwelling at 18 Crombie Street. Holyoke has gone through various local processes in attempt to demolish the building in question. In November, 1990, the Salem Historical Commission denied Holyoke' s request to waive the Demolition Delay Ordinance. In April, 1991, the Salem Historical Commission' s final recommendation was in opposition to the granting of a demolition permit. In May, 1991, the Salem Redevelopment Authority (SRA) denied Holyoke' s request for demolition of 18 Crombie Street. An appeal of the SRA's decision by Holyoke is currently pending in Superior Court. Prior to the SRA' s decision, the City of Salem contracted Robert M. Rumpf & Associates to provide an independent structural condition report of the property. The report recommended that only the back porch of the building be torn down and provided reasonable minimal requirements to adequately rehabilitate the structure. The report concluded that the building was not a hazard to public safety and welfare. It is my opinion that Holyoke is not appealing the decision of Salem' s Inspector of Buildings out of concern for public safety and welfare, but is attempting to use the State Building Code appeals process as a means of fulfilling their own independent objectives . I urge you to uphold the fi ings of Mr. Munroe and to deny the appeal of Holyoke Square, I S cer y i ster Proje t Administrator p A �xecuGirie ��cCe a��u�c �� s ' .Mate Aoala o/ and, ftwarda William F. Weld /N�oa�maa�C /tate CAW .GiY wa�ty Governor One ,Qu&"& t 9LCc - Room /.30-f Kentaro Tsutsumi �ddac�lEi�aetta 0,21,08 Chairman (617) 727-3200 Charles J. Dinezio Administrator n � December 6, 1991 47 r William Munroe r'n x- One Salem Green :n ca =>_ -- ; .., �Jn Salem, MA 01970 M. t Docket Number: 91-116 Property Address: 18 Crombie Street, Salem, MA Hearing Date: December 19, 1991 Hearing Time: 9:30 AM 0/1 C " •o ate- The Appeal for the subject property has been scheduled to be heard on the hearing date and time indicated above. The hearing will take place in the State Board of Building Regulations and Standards (BBRS) Conference Room (Room 1301) at the McCormack State Office Building, One Ashburton Place, Boston Massachusetts 02108. The State Building Code Appeals Board requires your presence or that of you representative at its hearing relative to the above mentioned case. Please bring with you a copy of the record, including any documents, plans, sketches, drawings. etc., that will help to give the Appeals Board grounds to adjudicate this appeal. Sincerely; THE STATE BOARD OF BUILDING REGULATIONS AND STANDARDS Kathy Mc eil Administrative Secretary C 57 y '°� �X 0/g J94 Wf1�77CC1`4Fo y 0E- SAL L( ,l•,nss•� William F. Weld /m � � ' FOR STATE USE ONLY ne JOah ,/ //�acueae�a O'ems Fee Recd: ✓Navaaa� (617) 727-3200 Check No. Recd B},: STATE MILUING CODE APPEALS BOARD APPEAL APPLICATION FORM DATE: DOCKET NUMBER: The undersigned herehy appeals to the Statc hoard or Iloildimg Regulations and Standards from the decision of the: Building Official from the Cityrl6,Mvlr oF. Salem, Massachusetts Board or Appeals from the Cityrrown of: _ Other Municipal APency/Oficial entitled: State Agency/Oficial entitled: OTHER: Dated: October 4 , 19 91 , having heen aggrieved by such (Check Appropriate Space) % Interpretation _ Order Requirement Direction X Failure to Act Other - Explain Subject: (Suhmit a hrief statement of reasons and principal points upon which the application, appeal or petition is hased) ALA, APPROPRIATE SECTIONS OF THE CODE MUST BE LISTED The Owner- of the building at 18 Crombie Street , Salem, MA requested the Buil ing Inspec or on ugus o ins pursuant to M.G.L. Ch. 143 Sec . 6 ( See attached letter ) . The Bpilding, Insppecty iRs ected the buildincr on Au4giutI t 18 , 1 91 and a, � not , c¢n an n pursuant to M.G.L. Ch. I4� , Sec . (( See attached letter) T State hrielly desired relief: The decision of the Building Inspector should be overruled and the owner should be ordered o remove or make structure safe pursuant to M.G.L. Ch . 143, Sec. b . APPELLANT: Holyoke Square , Inc . ADDRESS FOR SEM CE: Holyoke Square, Inc. , c/o William J. Lundregan , Esq . , 81 Washington Street , Salem, MA 0197 T'elephoneNo. ( 508 ) 741-3888 ADDRESS OF PROPERTY INVOLVED: 18 Crombie Street;Salem,'MN 01970-7 APPELLANT'S CONNECTION TO PROPERTY INVOLVED: Owner APPLAPLC-f/90 T ✓fze U� o�mirir,�yr�e�re�:u� a��i2'GaQdG�,/tcc6eC�Q Q @ //V�XCG pa#1 to- --- �- �.ZP.CdLII?,,,e �/�ff.� 6L ✓ J s , .date ✓iJuard 2)aal,n{je Aiya4weo mrd A.Wrda William F. Weld ��`e(�owmgac ,sate CAW a - -Owan_�Governor Cne J4/ Iu,, " _ Ao /jo / Kentaro Tsutsumi 021,08 Chairman (617) 727-320) SERVICE NOTICE Charles J. Dinezio DOCKET NUMBER: Administrator 1, William J. Lundregan as Attorney for the Appellant/Petitioner __Holyoke Square , Inc. in an appeal filed with the State Building Code Appeals Board on October 4 , 1991 IIEREBY SMEAR UNDER THE PAINS AND PENAIXIES OF PERJURY TIIAT IN ACCORDANCE WITH THE PROCEDURES ADOPTED BY 'I'IIE STATE BOARD OF BUILDING REGULATIONS AND STANDARDS AND SECTION 121.2.1 OF"I HE STATE BUILDING CODE, I SERVED OR CAUSED TO BE SERVED, A COPT' OF THIS APPEAL APPLICATION ON TUE FOLLOWING PERSON(S) IN THE FOLLOWING MANNER: NAME AND ADDRESS OF PERSON/AGENCY SERVED C.1GTIIOD 011' SE'RVICIi DATE OF SERVICE Wil Builldiniam gInsMunroepector Last and Usual October 4 , 1991 City of Salem One Salem Green Salem, MA U1770 �Siignoll /r LLANT/1`EnT1;0 On the 4th Day of October 19 91 , PERSONALLY APPEARED 13EFORENIET11EABOVE NAMED William J . Lundregan , Esq. (7 ype or 11rinI the Name of the Appella nQ AND ACKNOWLEDGED AND S)5'ORE 'I'lIE ABOVE STA TC� TO BE TRUE. NOTARY PUBLIC Anne M. Poor 11/2/95 SERVNOTE.I/90 COMMISSION EXPIRES �II�LDiric DEPT tp o ver , asgaC Uge tg Public Propertp Department , OCT � CI 00 AH 91 �rn„gwN Nuilbing Department RECEIVED One *alem Oreen CITY OF SALEM,MASS. 745-9595 P!xt. 380 William H. Munroe Director of Public Property Inspector of Buildings Zoning Enforcement Officer August 29, 1991 Charles A. DeMarco, A.I.A. DeMarco and Jarek Partnership Pickering Wharf 223 Derby Street Salem, MA 01970 RE: 18 Crombie St. , Salem Dear Mr. DeMarco: In response to your request and accompanied by David Harris, Assistant Building Inspector, Attorney William Lundregan and you, I made an inspection of the above referenced property on August 18, 1991 to determine the structural stability of the building located on the site. Considering the fact that the structure is about one hundred sixty (160) years old I found it to be in reasonably good condition. The frame of the structure was in extremely good condition with the exception of a couple of areas of the sill plate which showed some water damage and carpenter ant infestation. I was surprised to find the foundation wall was red brick rather than stone indicating the foundation may be much newer than the house. The foundation has some areas that are in need of repair but there was no sign of there being stress enough to cause failure. The electrical, heating and plumbing should be upgraded to meet the needs of todays appliances. It is my opinion that, although this single family house has a number of problems, it has not deteriorated to the point of being a hazard to the public safety and welfare, and to order it demolished at this time would be premature. Sincerely, >_ iam Munroe Inspector of Buildings WHM:bms cc: William Lundregan, Esq. F-J= DeMarco • Jarek PL'I!_i?I"! DEPT Partnership AUC �L 39 orf `of Architects log & Planners RECEf`dF0 CITY OF S . r :MASS. 5 August 1991 William Munroe Building Inspector Citu Hall One Salem Green Salem, MA 01970 RE: IS Crombie Street Dear Mr. Munroe: We are writing to you pursuant to M. G.L. Ch, 143, Sec. b in order to apprise you of the fact that the building located at IS Crombie Street is in a state of disrepair and if not corrected will pose a hazard to the well-being of pedestrians in the area. On July 3, 1990, we inspected the said building at the invitation of its current Owner, the Holyoke Mutual Fire Insurance Company. A copy of our report is annexed hereto for your information. In summary form, our firms findings include the following: Roof The roof appears to be IS+ years old. The lower rear portion was incorrectly flashed to the abutting wall of the house. The lower left gabel roof valleys should have been (but were not) lined with metal . The absence of an adequate attic ventilation system requires the installation of a continuous soffit and ridge vent system, in order to reduce excessive attic humidity. There is evidence of a pre-existing ice damming problem. The rear plumbing vent has been installed on the outside wall and does not meet the building code. Chimney One ( 1 ) of the two (2) chimneys is in marginal condition, at best. All of its flashings have deteriorated. The chimney cap is in need of rebuilding and all the flues need to be lined. Exterior Walls -------------- The exterior walls, fascias, soffits and trim are all wood and are in marginal condition. The cedar shingle siding is in marginal condition and is cupping and splitting on most sides of the building. Paint has been peeling from all wood surfaces. The fascias, soffits and all of the corner boards are in rotted condition. The electrical entrance cables are in poor condition, Pickering Wharf 0 223 Derby Street • Salem, Massachusetts 01970 • 508/744-4141 E,DILDI,4r DEPT Mr. William Munroe a i (� 5 August 1991 AN 1 ? 9 aq 39 AH I Page 2 R Ec-LrVEo CITY OF SALEM,MASS. and the service cables entering the house are rotting. Most significantly, the brick and block foundations on the front and left sides of the building are collapsing. Drainage The gutters are in poor condition. The wooden gutters are rotten and the copper gutters should be (but are not ) spaced away from all fascias. The downspouts are in marginal condition. Grading around the foundation does not slope away, thus causing water to pond. Grounds The rear wooden stairs are rotting. The rear brick patio is in marginal condition. Of major concern is the wood porch structure including, but not limited to, the roof, rafters, corner post, and porch decking. Floor joists and decking have been severely damaged by wood rot and wood boring insects. Doors and Windows All of of the windows are in poor condition. Their thresholds are rotting. The entry doors are not square. All flashing around windows and door heads are in poor condition. The window sashes are loose in their casings. The entire bulkhead is unsafe. Basement The brick walls are in poor condition, and the right and rear foundation walls are collapsing. On the front and right sides, the sills are in poor condition, evidencing rot and 'insect damage. The right side floor joists have been damaged by wood boring insects. The brick support posts are in poor condition and are deteriorating. Kitchen The general structure of the kitchen is not squared and the floor is not level . Electrical circuits are very limited. The walls, ceiling, floor and electrical outlets are all in marginal condition. Fir. William Munroe 5 August 1991 An I Z {�7 AH, Page 3 R E CE M_'J i CITY OF 5:,1--1: MIASS, Hallways-and_Entries The rear stairwell is marginal. The plaster finish in the front stairwell has loosened. Living_Room_(Front ) The ceiling sags, due to settling of the foundation. The hardwood floor similarly is not level . Electrical outlets are in marginal to poor condition, and are limited. The windows are marginal due to excessive peeling of paint. The doors are marginal and are not square. The fireplace is marginal and in need of flue lining. Dining_Room The walls, ceiling and floor are all marginal. The ceiling sags and the structure has settled to the left. Outlets and fixtures are limited and in poor condition. The fireplace is marginal and in need of a flue lining. Closed-In_Porch_(Rear Right ) The floor and the ceiling sag. The outlets and fixtures are inoperative and limited. Bedroom - Second Floor Front ---------------------------- The walls and ceiling are in marginal condition. The plaster is cracking and the ceiling is sagging. The floor is marginal and is not level. There are no electrical outlets, fixtures or switches. The door is not square. The fireplace is marginal and the flue needs to be lined. Bedroom - Second Floor Rear --------------------------- The walls and the ceiling are in marginal condition. The plaster is cracking. The doors and windows are in marginal condition. The fireplace is in poor condition; the hearth needs rebuilding and the flue needs lining. Bedroom - Third Floor Front --------------------------- Same comments as Second Floor Rear Bedroom. BIJILDING DEPT Mr. William Munroe 5 August 1491 AUG 12 9 39 Rei °91 Page 4 RECEIVED CITY OF SALEM,HASS. Bathrooms The bathrooms are located on the second and third floors; neither one of them is operative. Attic The insulation and ventilation systems are in poor condition. The chimneys and flues are in marginal condition. The left chimney is in need of repair, and there is evidence of leaking at the chimney flashings. The roof is in need of soffit and ridge venting, Utilities The heating, plumbing, water and electrical systems are currently inoperative. It is our opinion that the foundations at 18 Crombie Street are in danger of collapsing and that, therefore, it poses a health and safety hazard to persons within its vicinity. Indeed, were it not for the addition of the porch and corner rooms (which are them- selves now failing) it is probable that the main frame would already have toppled. Clearly, this property is a candidate for condemnation. It is our recommendation that your Department conduct an immediate inspection of its own, and then issue an order to the Owner to remove the structure or make it safe, pursuant to M.G.L. Ch. 143, Sec. b. If you have any questions or concerns, please contact us. Very truly yours, DeMarco/JZZ: p Charles A. DeMarco, A. I.A. Ponald F. a ek A. I.A. CAD-pl Enclosure cc: William Lundregan, Esq. Douglas Ryder, Pres. u.; Cttp of ebairm, Aaggacbagettg ' w pi Public Propertp Department �3uilbing Department One abalem green 745-9595 Cxt. 360 William H. Munroe Director of Public Property Inspector of Buildings Zoning Enforcement Officer August 29, 1991 Charles A. DeMarco, A.I.A. DeMarco and Jarek Partnersnip Pickering Wharf 223 Derby Street Salem, MA 01970 RE: 18 Crombie St. , Salem Dear Mr. DeMarco: In response to your request and accompanied by David Harris, Assistant Building Inspector, Attorney William Lundregan and you, I made an inspection of the above referenced property on August 18, 1991 to determine the structural stability of the building located on the site. Considering the fact that the structure is about one hundred sixty ( 160) years old I found it to be in reasonably good condition. The frame of the structure was in extremely good condition with the exception of a couple of areas of the sill plate which showed some water damage and carpenter ant infestation. I was surprised to find the foundation wall was red brick rather than stone indicating the -foundation may be much newer than the house. The foundation has some areas that are in need of repair but there was no sign of there being stress enough to cause failure. The electrical, heating and plumbing should be upgraded to meet the needs of todays appliances. It is my opinion that, although this single family house has a number of problems, it has not deteriorated to the point of being a hazard to the public safety and welfare, and to order it demolished at this time would be premature. Sincerely, i iam Munroe Inspector of Buildings WHM:bms cc: William Lundregan, Esq. a BUILDING DEPT NOV 13 12 23 FM '90 1 y.,u.r. RECEIVED �. . gYOFSALEM,MASS. r 1I C 4"a ONE SALEM GREE`!.SALEM, MASSACHUSETTS 01970 t6171 745-9595. EXT. 311 PRELIMINARY RECOMMENDATION REGARDING DEMOLITION PERMIT RE : 18 Crombie Street On Wednesday, November 7 , 1990, the Salem Historical Commission unanimously voted—in—opposition to the granting of a permit for demolition for .18..Crombie_Street as proposed by Holyoke Square Inc . through its representative William J. Lundregan, Esq. As per Part II , Chapter 2 , Article XV, Division 2, Section 2-394 (Demolition Delay ) of the Code of Ordinances , no permit for demolition shall be issued until a more thorough investigation is undertaken and a final written recommendation regarding the granting of the permit for demolition is provided by the Commission to the Director of Public Property and to the property owner. Such investigation and recommendation shall be completed within 180 days of the original submission (October 15, 1990 ) to the Historical Commission. I attest that this is an accurate record of the vote taken, not amended or modified in any way to this date . November 12, 1990 Jan A. Guy Clk of the C mission cc : Building Inspector City Clerk JHisCom8/Denial7 A r .CONDIT. c 2 i S 9fGIMINE D- Salem Historical Commission ONE SALEM GREEN,SALEM, MASSACHUSETTS 01970 (617)745-9595,EXT.311 April 12 , 1991 FINAL RECOMMENDATION REGARDING DEMOLITION PERMIT William Munroe Director of Public Property City of Salem One Salem Green Salem, MA 01970 RE : 18 Crombie Street Dear Mr . Munroe : As per Part II , Chapter 2, Article XV, Divison 2, Section 2-394 (demolition Delay) of the Code of Ordinances, the Salem Historical Commission hereby submits this written recommendation regarding the demolition of 18 Crombie Street . The Salem Historical Commission is opposed to the granting of a demolition permit for 18 Crombie Street due to the property being a historically significant building within the Crombie Street National Register District . Sincerely, Annie C . Harris Chairman cc : Holyoke Square, Inc . Cite of *alem, 41am5arbuattz Aubtit 3prapertp Mepartment �3uitaing Mepartment One*alem Oreen (978) 745-9595 ext. 380 Peter Strout Director of Public Property Inspector of Buildings Zoning Enforcement Officer ; March 14, 2001 Holyoke Insurance 39 Norman Street Salem, Ma. 01970 RE: 18 Crombie Street Dear Facility's Manager: I conducted an inspection of 18 Crombie Street this morning at the request of a'eighbor. The second floor windows have been broken out. Section 103 of the Massachusetts State Building Code requires the property owner to "maintain a safe, operable and sanitary condition of its property". You are therefore to fix or secure the second floor windows at 18 Crombie Street. Failure to comply with these orders within fifteen (15) days will result in legal action being taken against you in Salem District Court. Thank you for your anticipated cooperation in this matter. Sincerely, 2 Frank DiPaolo Local Building Inspector cc: David Pelletier Com, ��, � d a , � 2 c� a« � �� � � U � q �v i Salem #1015 St arms, MA Salem #928 em, MA Salem #396 , MA Salem #183 ly, MA Salem #902 A Salem #824 ly, MA Salem #583 St MA . - Salem #582 MA Salem #981 St: rly, MA Salem #018 v Salem #1006 MA Salem #546 ad, MA Salem#1970 HIC f Cite of 6alem, Aa!6garbUattg Public i3ropertp Department WuitDing Department C�iO (One fpalem Oreen (978) 745-9595 text. 380 Peter Strout Director of Public Property Inspector of Buildings Zoning Enforcement Officer APRIL 24,2001 HOLYOKE INSURANCE CO 39 NORMAN STREET SALEM,MA 01970 RE: 18 CROMBIE STREET DEAR FACILITIES MANAGER: THIS IS A FOLLOW UP ON THE LETTER THAT WAS SENT OUT MARCH 14,2001. AS OF TODAY,NOTHING HAS BEEN DONE AND NO ONE HAS CONTACTED THIS OFFICE. SECTION 103 OF THE MASS STATE BUILDING CODE REQUIRES THE PROPERTY OWNER TO MAINTAIN A SAFE,OPERABLE AND SANITARY CONDITION OF ITS PROPERTY. A PERIOD OF FIVE(5)WEEKS HAS GONE SINCE MY LETTER WAS SENT TO YOU, WITH NO RESPONSE YOU GIVE ME CHOICE BUT TO FINE YOU FIFTY(50)DOLLARS. IF YOU DO NOT MAKE A GENUINE EFFORT WITHIN SEVEN(7)DAYS,ANOTHER FIFTY(50)DOLLAR FINE SHALL FOLLOW. THANK YOU FOR YOUR ANTICIPATED COOPRERATION IN THIS MATTER. SINCERERLY, FRANK R. DIPAOLO LOCAL BUILDING INSPECTOR -