53-59 Mason Street 09.16.2024 Letter to Salem ZBA-Opposition to Special Permit Application ID ZBA-24-32
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September 16, 2024
VIA ELECTRONIC MAIL: dlaroe@salem.com
Mr. Daniel Laroe, Staff Planner
City of Salem Zoning Board of Appeals
Salem City Hall
93 Washington Street
Salem, MA 01970
Re: Application ID: ZBA-24-32; 53-59 Mason Street
Opposition to Special Permit Application for Change of Nonconforming Use
Dear Mr. Laroe:
Please be advised that this firm represents DSF Salem Flint LLC, the owner of a residential
apartment building consisting of one hundred thirty (130) units, located at 72 Flint Street, Salem,
Massachusetts, commonly known as the Halstead Salem Station Apartments (the “Halstead
Apartments”). On behalf of my client and the residents of the Halstead Apartments, please include
this correspondence in the record of the above-referenced application (Application ID: ZBA-24-
32) (the “Application”) for a special permit to change a nonconforming use at the property located
at 53-59 Mason Street, in Salem (the “Property”), which I understand is to be heard by the Zoning
Board of Appeals (the “Board”) on September 18, 2024. For the reasons outlined below, my client
opposes the Application and respectfully requests that the Board deny the Application with
prejudice.
The Property consists of approximately 2.1 acres of land and is improved by an
approximately 20,000 square foot building that is currently used in part for the indoor storage of
boats, automobiles, and recreational vehicles.1 The Property is located within the North River
1 The Application seeks to “change about 20,000 SF of the building from its current nonconforming
use for storage for boats and cars, to another nonconforming use of a warehouse, storage,
packaging and distribution . . . anywhere within the entire building.” As noted below, in 2022, the
Board granted a special permit to allow 14,000 square feet of the building to be used for the “year-
round and seasonal indoor storage of classic automobiles, recreational vehicles and boats.” Query
whether this nonconforming use of the Property has been expanded unlawfully from 14,000 SF to
20,000 SF without first obtaining the requite special permit from the Board.
Counselors at Law
Tanya D. Trevisan
(617) 404-8747 – Direct
ttrevisan@msullc.com
Admitted in: MA
Mr. Daniel Laroe, Staff Planner
September 16, 2024
Page 2 of 4
Canal Corridor Neighborhood Mixed Use District (NRCC), which expressly prohibits “[s]torage,
warehousing and wholesale distribution facilities except as an accessory use.” See Section 8 of
the City of Salem Zoning Ordinance (the “Zoning Ordinance”) and Section 7.1 of the “Table of
Uses, NRCC District,” contained therein.
Section 8.4.1 of the Zoning Ordinance provides that the purpose of the NRCC is:
. . . to fulfill the goals and objectives contained within the
Neighborhood Master Plan for the North River Canal Corridor (the
NRCC Plan). The NRCC Plan encourages the best use for the North
River Canal Corridor physically, economically, environmentally,
and socially while promoting the best interests of the residents of the
city. The goals of the NRCC Plan, as stated in the North River Canal
Corridor Vision Statement, February 2003, are as follows:
1. Create appropriate development while preserving our historic
neighborhood character;
2. Address transportation issues for existing and new
developments;
3. Enhance the public realm in keeping with our unique
neighborhood character.
Further, Section 8.4.2 provides that, in order to achieve the above-referenced goals of the NRCC
Plan, all developments are required to comply with the enumerated standards outlined therein,
including but not limited to the following:
1. All development shall be in compliance with the NRCC Plan.
2. All development shall be designed to complement and harmonize with
adjacent land uses (existing and proposed) with respect to architecture, scale,
landscaping and screening. Building materials of brick, stone, and wood are
encouraged. Pre-cast concrete or prefab aluminum or metal panels are highly
discouraged.
3. Ground floor spaces should have active pedestrian friendly uses.
4. Buildings should be located in a way to create a presence on the main
corridor's street edges.
5. Buildings shall face the main corridor and have an entrance on the main
corridor.
Mr. Daniel Laroe, Staff Planner
September 16, 2024
Page 3 of 4
6. Streets and roadways must include sidewalks and landscaping to provide an
attractive connection for pedestrian use, and to complement adjacent
parkland.
7. Uses are designed to generate pedestrian traffic.
8. All retail uses should support the adjacent neighborhoods.
9. All development shall be designed to facilitate, accommodate, and
encourage use by pedestrians and non-motorized forms of transportation
as much as, if not more so than, use by motorized vehicles.
(Emphasis added.) Additionally, Section 3.0 of the Zoning Ordinance, Table of Principal and
Accessory Use Regulations, provides that the principal use of the Property as a wholesale,
warehouse or distribution facility is not an allowed use in the NRCC Zoning District.
Section 3.3.2 of the Zoning Ordinance provides that the Board may award a special permit
to change a nonconforming use “only if it determines that such change or extension shall not be
substantially more detrimental than the existing nonconforming use to the neighborhood.” On
March 28, 2022, the Board granted a special permit allowing approximately 14,000 square feet of
the building on the Property to be used for indoor, year-round and seasonal storage of boats,
automobiles, and recreational vehicles (the “2022 Board Decision”).
The Application at issue here proposes to change the existing nonconforming use of the
Property to a warehouse, storage, packaging, and distribution center–a use that would not only
create a greater nonconformity but also seeks to utilize the entirety of the building (which measures
approximately 20,000 square feet) for such purposes. Were the Board to grant this Application, it
would negate the exact purpose of what the NRCC Zoning District is intended to protect against.
The proposed use of the Property is not a pedestrian-friendly use in this heavily residential area
and would discourage pedestrian traffic.
The Halstead Apartments immediately abut the Property; and there is a two-family
residence located at 61 Mason Street, which also abuts the Property. Contrary to claims contained
in the “Statement of Grounds for Zoning Relief for 53-59 Mason Street LLC” (the “Statement of
Grounds”), which is included with the proponent’s Application materials, the proposed change in
the nonconforming use of the Property not only would violate the purpose and intent of the NRCC
Plan, but it would be detrimental to the residents of the Hallstead Apartments and the surrounding
residential neighborhood, as well. Because of the close proximity of residential neighbors to the
Property, the Property is not an appropriate site for the proposed change in nonconforming use.
The Statement for Grounds indicates that there would be “one to two” large trucks” and
“several panel vans and small trucks” travelling to and from the Property on a daily basis. All of
the trucking traffic would come onto the Property from Commercial Street and would drive past
the Halstead Apartments to reach the loading docks, which would face the Halstead Apartments.
Mr. Daniel Laroe, Staff Planner
September 16, 2024
Page 4 of 4
Please find enclosed herewith an image obtained from Google Maps
(https://www.google.com/maps) which offers some perspective as to the proximity of the proposed
trucking traffic and loading docks to the Halstead Apartments. The proposed use would create a
great amount of truck traffic, and the loading and unloading of the trucks would create significant
noise and disturbance for the residents of the Halstead Apartments and other neighbors. Further,
truck exhaust and emissions would compromise the air quality for these nearby residents.
It is worth noting that this Application is not the proponent’s first foray in utilizing the
Property for this type of proposed use. Starting in 2020 and continuing for approximately eighteen
(18) months, the Property was unlawfully utilized to store and repair 18-wheeled trucks and school
buses without first obtaining from the Board the requisite special permit for such use. Residents
from the Halstead Apartments filed complaints with the City regarding the noise and traffic from
the trucks and busses all hours of the day and night and the bright lights emanating from the
Property at night. The owners of the Property were issued notices of violation of the Zoning
Ordinance for this unlawful use of the Property. Thereafter, the owners of the Property petitioned
the Board for a special permit to use the Property for year-round and seasonal indoor storage of
classic automobiles, recreational vehicles and boats, which the Board granted in 2022.
Because of its close proximity to residential neighbors, the Property is not an appropriate
location for the proposed warehouse, storage, packaging, and distribution facility. Moreover, this
proposed change in nonconforming use would violate the express purpose and intent of the NRCC
Plan as outlined in Section 8.4 of the Zoning Ordinance. Based on all of the foregoing, the Board
cannot find that the applicant meets the criteria necessary to grant a special permit for a change
from the current nonconforming use to a warehouse, storage, packaging, and distribution facility,
as such change in use would be substantially more detrimental to the neighborhood than the
existing nonconforming use.
For these reasons, on behalf of my client, I respectfully request that the Board deny the
Application with prejudice. Please note that I plan to attend the virtual hearing of the Board on
September 18, 2024, to discuss my client’s concerns and to answer any questions that the Board
may have regarding this opposition to the Application.
Thank you for your time and kind consideration of this matter.
Sincerely,
MIRRIONE, SHAUGHNESSY
& UITTI, LLC
Tanya D. Trevisan
Tanya D. Trevisan, Esq.
Encl.