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PICKERING WHARF TIF LEGAL OPINION 1999 � Q oc�I kl � 'qui owl 5 1 n CITY OF SALEM - MASSACHUSETTS WILLIAM J.LUNDREGAN Legal Department JOHN D.KEENAN City SolicitorAssistant City Solicitor 81 Washington Street - - 93 Washington Street Bo Washington Street Tel:978-741-3888 Salem, Massachusetts 01970 Tel;978-741-4453 Fax:978-741-8110 Fax:978-740-0072 February 3 , 1999 i - Mayor Stanley J. Usovicz, Jr. Salem City Hall 93 Washington Street Salem, MA 01970 RE : Pickering Wharf Hotel TIF Dear Mayor Usovicz : Please find enclosed my opinion relative to the status of the Pickering Wharf Hotel TIF. If you have any questions with reference to this matter, please do not hesitate to call me . Very truly yours W/LLIAMJ. LUNDREGAN CITY SOLICITOR WJL/amc Enclosure Memo to: Stanley J. Usovicz, Jr. , Mayor From: William J. Lundregan, City Solicitor Dated: February 2, 1999 RE: Pickering Wharf Hotel TIF You have asked me to review the Application for Certified Project,. Designation - Tax increment Financing Plan (TIF Application)' submitted by the City and Pickering Wharf Realty Trust. and to answer the following question: where the City Council Resolutions authorizing the TIF application specifically designate one of three subject parcels as the parcel to which the TIF is to apply, but where the applicants originally intended that the TIF apply to all three parcels, is there anything in the official record which permits us to argue to the state that the Resolutions should be deemed to apply to all three parcels, rather than the one specifically designated by the Council? In seeking an answer to this question, I have thoroughly reviewed the documents that were provided to me, to wit: 1 . the Application for Certified Project Designation - Tax increment Financing Plan (TIF Application) ; 2 . the Memorandum of Understanding executed by J. Hilary Rocket, Trustee, for the Pickering Wharf Realty Trust, and by Stanley J. Usovicz, Jr. , Mayor, for the City of Salem; 3 . a letter dated January 14, 1999 to George Mazareas, Director of Economic Assistance Coordinating Council, written by someone whose name and signature have been removed from my copy; 4 . a letter dated November 20, 1998 to Mayor Usovicz from J. Hilary Rockett, Jr. ; and 1 5. the original deed of the subject property from the Trustees of the Pickering Wharf Nominee Trust to J. Hilary Rockett, Trustee of Pickering Wharf Realty Trust . This deed is dated June 6, 1996 and recorded at the Essex South District Registry of Deeds in Book 13598, Page 532 . I have also reviewed the applicable law, specifically: G.L. c. 40, Sec. 59, the statute which authorized TIF financing, and the supporting regulations at 760 C.M.R. 22. 01, et seq. After an extensive review of the foregoing materials, it is my opinion that there is no valid way to argue that the TIF authorized by the City Council can be construed to extend to the other, neighboring parcels. I see no alternative but to return to the City Council with a corrective resolution, if the presently- designated parcel is not intended to be the site where the hotel is to be built. Permit me to call your attention to the following matters : 1 . The subject lots are designated as Lots 408, 446 and 447 on the assessor' s map. The lots correspond to parcel 1 (lots 446 and 408) and parcel 2 (lot 447) which were conveyed to the Pickering Wharf Realty Trust by the deed hereinbefore referenced. The said deed also conveyed twenty-six condominium units comprising the Pickering Wharf Condominium. According to the November 20, 1998 letter from Rockett to Usovicz, all of this property was intended to be the beneficiary of the T. I .F. plan. 2 . The Memorandum of Understanding did not designate the property to be the beneficiary of T. I . F. financing with any greater specificity than "Pickering Wharf. " Rockett's letter to Usovicz agrees with this; however, where Rockett seems to think that the absence of any greater designation adds weight to his argument that therefore the T . I . F. plan applies to all of his property, I 2 am of the opposite opinion: that the absence of any designation deprives this document of any value as a guide to determining which properties were supposed to be involved. 3 . Within the T.I . F. Application is a letter dated June 15, 1998 from Mayor Usovicz to Sean Calnan, Director, Massachusetts Office of Business Development . This letter - evidently meant as an introduction to the T. I . F. Application - states that, " (t) he proposed location of the hotel is at the corner of Congress and Derby Streets . " There is a lot at the corner of Congress and Derby Streets, but it is Lot 445 . Although this lot is also owned by Rockett, it is not one of the three lots under discussion. Looking at the map, one might be able to argue for an expansive understanding of the phrase "corner of Congress and Derby Streets" that would include the abutting Lot 446; however, by no stretch could that phrase be applied to Lot 447 or 408, neither of which are anywhere near Derby Street . 4 . Also within the T. I . F. within the section entitled "Applicant 1-folmatlon, " is a dcsignati on of th( nama o-id ' address cf--thc proposed project . This is given as "Pickering Wharf Hotel, Corner of Congress Street & Derby Street, Salem, MA 01970 . " The "Introduction and History of Project Development" which appears in the body of the Application, itself, also identifies the project locus as "the corner of Derby and Congress Streets . " 5 . In Section I (C) of the Application, the "tax parcel" is identified as "Map 34, Lot 446. " There immediately follows the following "legal description of TIF Zone": The following condominium unit in the Pickering Wharf Condominium (the "Condominium") in Salem in the County of Essex and Commonwealth of Massachusetts, created by and described in the Master Deed of Pickering Wharf Condominium dated August 3, 1979 recorded with Essex South Registry of Deeds in Book 6624, Page 141, as amended by a First Amendment to Master Deed dated November 3 l 9, 1979, recorded with Essex South Registry of Deeds in Book 6653, Page 99, by a Second Amendment to Master Deed dated December 28, 1979, recorded with Essex South Registry of Deeds in Book 6667, Page 39, and as further amended by a Third Amendment to Master Deed dated April 4, 1980, recorded with Essex South Registry of Deeds in Book- 6692 Page 336 (said master deed as so amended is hereinafter referred to as the "Master Deed") : Biildina 21j-t EercentaaQ In rest Derby A 10 . 8775 Together with the undivided percentage interests in the common areas and facilities of the Condominium described in the Master Deed as set forth for the unit above . . . . There is simply no way to interpret this designation as being anything other than what is manifestly is: a very carefully drawn, particularized designation of a single unit of the condominium as the intended beneficiary of the T.I.F. financing! 6. Three (3) City Council Resolutions are included within the T. I. F. Application. The first, dated March 9, 1995, is merely a general authorization for the City to employ T. I . F. financing as an economic development tool . The second Resolution, dated June 11, 1998, is the Resolution which specifically approved the T. Z . F. Application on behalf of the Pickering Wharf Realty Trust. This Resolution recites that, "the proposed certified project is located at the corner of Congress and Derby Streets, " and gives the legal description as follows: The following condominium unit in the Pickering Wharf Condominium (the "Condominium") in Salem in the County of Essex and Commonwealth of Massachusetts, created by and described in the Master Deed of Pickering Wharf Condominium dated August 3, 1979 recorded with Essex South Registry of Deeds in Book 6624, Page 141, as amended by a First Amendment to Master Deed dated November 9, 1979, recorded with Essex South Registry of Deeds in Book 6653, 4 Page 99, by a Second Amendment to Master Deed dated December 28, 1979, recorded with Essex South Registry of Deeds in Book 6667, Ill _-A -.. F...-..6__ ____J_J L... _ 1L-4. .n�. n - -- Faye Jl, GIIU GS 1411.1101 GIIICIIUCU U`l 0. 11111U 1UG 11 d1llCll GJ Cl Deed dated April 9 , 1980, recorded with Essex South Registry of Deeds in Book 6692, Page 336 (said master deed as so amended is hereinafter referred to as the `Master Deed") : Building Unit Percentage Interest Derby A 10 . 8775 said unit A, Derby Building being a part of the total Master Deed described above. Together with the undivided percentage interests in the common • ..4__ areas ' ail' -a Ci ',ties o t -'e"'Condominium- -described l-n the- ii&o�c,. Deed as set forth for the unit above . . . . (Emphasis added. ) Once more, there is no way, in good faith, to interpret this designation as being anything other than what is manifestly is : a very carefully drawn, particularized designation of a single unit of the condominium as the intended beneficiary of the T.I .F. financing! The third resolution, also dated June 11, 1998, authorized the City to enter into a T. I . F. Financing Agreement. Once again, this Resolution designates the "area to be designated as a Tax Increment Financing Zone" in the identical language used in the Second Resolution. Thus, there is simply no basis, in any of the Resolutions which passed the City Council, for arguing that the Resolutions authorized T. I . F. financing on all of the Rockett Pickering Wharf property! 5 7 . The Tax Increment Financing Agreement between the City of Salem and the Pickering Wharf Realty Trust contains no further property designations . 8 . The letter- dated January 14, 1999 to George Mazareas, Director of Economic Assistance Coordinating Council, contains the statement that, " (t) he City voted to approve a TIF to allow Pickering Wharf Realty Trust to development (sic.) a hotel with 70-140 rooms at Pickering Wharf. " Unfortunately, as we have seen, the City did no such thing. No such language appears in any of the votes of the City Council . 9. The letter dated November 20, 1998 from Rockett to Usovicz contains the following statement : " (t) here was never any mention of tax parcels or legal descriptions in the motion of the City Council, nor was there even any discussion of it . " I do not know whether there was any mention of tax parcels of legal descriptions in the motions that were presented to the Council, as I do not have those before me; however, as we have already seen, there certainly was mention of these matters in the two resolutions that the Council passed authorizing the T . I . F. application ! 10. The law governing T. I . F. applications is clear that they must be specific to designated parcels of property. G. L. c. 40, Sec. 59 provides, in pertinent part, that: . . . any city or town by vote of its town meeting, town council, or city council with the approval of the mayor where required by law, on its own behalf or in conjunction with one or more cities or towns, and pursuant to regulations issued by the secretary of the executive office of communities and development, may adopt and prosecute a tax increment financing hereinafter referred to as TIF plan, and do any and all things necessary thereto; provided, however, that the TIF plan . . . . 6 I (iii) authorizes tax increment exemptions from property taxes, in accordance with the Provisions of clause fife;-first of section five of chapter fifty-nine, for a specified term not to exceed twenty years, for any parcel of real property which is located in the TIF zone and for which an agreement has been executed with the owner thereof ` in accordance with the provisions of paragraph (v) . . . . (v) includes executed agreements between such city or town and each owner of a parcel of real property which is located in such TIF zone; provided, however, that each such agreement shall include: (1) all material representations of the parties which served as the basis for the descriptions contained in the TIF-ratan in accordance with the provisions of paragraph (ii) ; (2) detailed �....1 ta��o.^. ..� t11� t3, 3nc-eme-t maximum percentage of the cost of public improvements that can be recovered through betterments or special assessments regarding such parcel of real property pursuant to paragraphs (iii) and (iv) ; (3) a detailed recitation of all other benefits and responsibilities inuring to and assumed by the parties to such agreement; and (4 ) a provision that such agreement shall be binding upon subsequent owners of such parcel of real property (vii) is certified as an approved TIF plan by the economic assistance coordinating council established by section three B of chapter twenty-three A pursuant to regulations adopted by said council; provided, however, that the economic assistance coordinating council shall find, based on the information submitted in support of the TIF plan by the city or town and such additional investigation as the economic assistance coordinating council shall make, and incorporate in its minutes, that the plan is consistent with the requirements of this section and will further the public purpose of encouraging increased industrial and commercial activity in the commonwealth; provided, further, that a city or town may at any time revoke its designation of a TIE zone and, as a consequence of such revocation, shall immediately cease the execution of any additional agreements pursuant to paragraph (v) ; provided, further, such revocation shall not affect agreements relative to property tax exemptions and limitations on betterments and special assessments pursuant to said paragraph (v) which were executed prior thereto; and provided, further, that the board, agency or officer of the city or town authorized pursuant to paragraph (vi) to execute agreements shall forward to the board of assessors a copy of each 7 i such agreement, together with a list of the parcels included therein. (Emphasis added. ) Similar provisions appear in 760 C.M.R. 22 . 00, et seq. ; see especially Sec. 22 . 03 (2) , 22. 05, 22 . 07 . To conclude : the law is clear: T. I. F. Applications must be approved by the City Council and must specifically identify the parcel (s) to which they are to apply. The T . I . F. Application approved by the City Council did specifically identify, in clear and unambiguous fashion, a single parcel as the intended recipient of the T. I . F. financing. There is simply no "wriggle room" in any of the official documents to argue - after the fact - =hat the T . I . F. plan approved by the City Council was intended to apply to all of the Rockett property on Pickering Wharf. If such was the intent of the Council, and the applicants, then they should have manifested that intent in the Resolutions . At this time, I fear that I see no alternative but to return to the Council with a corrective resolution, and (hopefully) prevail upon a majority of the members to pass it . I hope that the foregoing has been of assistance. If you have any further comments or questions regarding this matter, please do not hesitate to contact me. 8 Coca 4, / At-AA4 6 ck— <y vh.vwV- un, .,