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Historic Review Board

Regular Meeting

Fort Mill, SC · November 29, 2022

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Minutes

MINUTES TOWN OF FORT MILL HISTORIC REVIEW BOARD SPECIAL MEETING November 29th, 2022 112 Confederate Street 4:30 PM Present: Chairman Louis Roman, Scott Couchenour David Booth, Elizabeth Leventis, Jessica Scarlett, Planning Director Penelope Karagounis, Senior Planner Alex Moore Absent: Vice Chairwoman Megan Brinton, Nikki Todaro Guests: Brian Rollar, Shaw Kuester, Chris Wolfe, Douglas Roman CALL TO ORDER Chairman Louis Roman called the meeting to order at 4:30 PM. APPROVAL OF MINUTES Chairman Louis Roman entertained a motion to approve the minutes from the November 8th, 2022, Historic Review Board (HRB) meeting. Scott Couchenour made a motion to approve the minutes. David Booth seconded the motion. The minutes were then approved by a vote of 5-0. OLD BUSINESS 1. Request to modify an approved Certificate of Appropriateness (COA) Senior Planner Moore provided an overview of a request to modify an approved Certificate of Appropriateness (COA) at 219-221 Main Street. He stated that at the previous HRB meeting on November 8th, this request included the following information: This COA as approved on September 14th, 2021, required that the demising wall between 219 and 221 Main Street to remain unpainted. As noted at the November 8th meeting, during the exterior refurbishment of 219 and 221 Main Street, the demising wall was painted. After hearing the facts of the case at the November 8th meeting, the HRB ultimately determined the following: 1. Kuester Real Estate shall provide written documentation from the roofing contractor, or manufacturer of the TPO roof, as to the method of its application to the brick on the demising wall and what it would take for the application of the TPO roof to be removed from this brick, and what damages to the brick would be expected due to this potential removal. 2. Kuester Real Estate shall provide written documentation from the painting contractor, or the manufacturer of the paint, regarding what could be done to remove the paint from the brick of the demising wall, and what damages to the brick would be expected due to this potential removal. 3. This documentation will be reviewed by the HRB. Should this documentation be provided prior to the scheduled December 13th, 2022, meeting, the HRB would entertain convening for a special meeting to review the written documentation and render a decision on whether the certificate of appropriateness as issued on September 21st, 2022, will be modified to allow the paint and/or TPO roof to remain on the demising wall. Otherwise, the HRB will consider this information at its regularly scheduled meeting on December 13th, 2022. Moore then indicated that information from both the painting and roof contractors was included within the HRB packet. The first letter is from Charlotte Paint Company, the painting contractor. Charlotte Paint indicates that the paint can be removed from the demising wall. However, Charlotte Paint also states that removing the paint will be risky in that damage to the underlying brick and mortar may result. The second letter is from Johnson’s Roofing Service. This contractor indicates that the TPO wall flashings can be removed. However, this contractor also indicates that this process could have negative effects on the underlying brick. Chairman Roman then recognized Shaw Kuester the applicant and property owner and provided him with an opportunity to address the HRB. Mr. Kuester noted again that it was not the intent of Kuester Real Estate to cover any portion of this demising wall as much time, effort, and expense had gone into this project. They were in fact not aware that the demising wall had been covered. Once the town informed them of this they went back and talked with the roofer and the painter. Mr. Kuester then stated that they now want to do what they need to so that the demising wall issue is resolved. At the same time, he indicated that they do not want to damage the building as a result of correcting this mistake. Mr. Kuester then noted that it is imperative that the building be waterproof. It was his understanding that this was the reason the roofing contractor added the TPO to the demising wall. As to the painting of the demising wall, Mr. Kuester stated similarly that he wanted the situation corrected but also did not want to damage the brick of the demising wall. He noted that this portion of the building was constructed in 1898. He then indicated that the situation may be better left as it is. However, he then stated that they would do what they needed to do per the board’s decision. Chairman Roman then asked Mr. Kuester if there was a miscommunication on the part of the contractors. Mr. Kuester responded that he believed that the contractors simply thought the entirety of the demising wall was to be painted because the rear of the building was being painted green. Chairman Roman stated that the adjacent property owner at 217 Main Street was also surprised that his wall was painted and covered with the TPO roofing during this process. Mr. Kuester agreed and noted that they had spoken to the property owner of 217 Main Street. David Booth then asked Mr. Kuester if there was any documentation provided for work done above and beyond the approved plan. Brian Rollar responded that there was no change order, but rather it was just a miss. Mr. Booth then asked Mr. Rollar why he was not on-site supervising the project. Mr. Rollar indicated that he has been on-site pretty much every week at least two times a week. He stated that the did not realize that this wall was not to be painted. He also noted that he did not instruct anyone to paint the wall as the question was never raised. Mr. Booth then asked if a field verification was done by the architect of the existing condition and then also after the TPO was installed with the understanding that there was variation in the plan and what was installed. Mr. Rollar responded that there were multiple conversations and that the architect was asked to come out and look at the demising wall after the installation. He then stated that there was a varying opinion between the architect and the general contractor on where the line started and stopped regarding covering of the demising wall. Nonetheless, he noted that he and Mr. Kuester were in attendance to work with the HRB on the issue. Mr. Rollar then stated that by coming back to the HRB and perhaps taking a less invasive approach on the demising wall than sandblasting, e.g., silt blasting, the structural integrity of the wall may still be affected. Mr. Booth stated that what he read in the report indicated that the painting and roofing contractors did indicate that removal of paint and roofing from the demising wall may damage the brick. However, there was no specific indication from the contractors on the exact method or alternative solution that might be used. Rather, the painting and roofing contractors only stated within their respective reports that the brick might be damaged. Mr. Rollar responded that what they did in this instance was to get the opinions from these contractors per the November 8th HRB meeting and then looked at those opinions and then spoke with Stuart Simon, of the general contractor Simon & Watson Construction as well as the project architect. From this it was determined that they would then present the information to the HRB and open up the discussion again based on the opinions from the painting and roofing contractors. Mr. Rollar stated that within these conversations that this team had, chemical removal was not entertained while silt blasting was looked at as an option. He then noted that while silt blasting was less abrasive than sand blasting, it was still abrasive. Mr. Rollar then stated that if the HRB had a continued desire to have the paint removed from the demising wall they might look at doing the silt blasting on a small area of the wall to see how it affected the brick. However, Mr. Rollar then stated that the demising wall had a good deal of variation because it was an older wall. Thus, there could be some spots that work out well and other sections that do not. Jessica Scarlett then asked Mr. Rollar if the contractors who presented the information for this meeting were those who performed work on this project. Mr. Rollar responded that yes, these contractors were the respective painting and roofing contractors for this project, working under the license of Simon and Watson Construction. Ms. Scarlett then asked if either of them have experience working with silt blasting on historical structures. Mr. Rollar stated that he did not know the answer to this question but that he could find out. Chairman Roman stated that this would be important information to obtain. He then noted that he was at a loss as to why this information was not provided for this meeting. He then asked Senior Planner Moore what the timeline was for the approval on the 219 & 221 Main Street project. Senior Planner Moore responded that this project was originally approved in September 2021. Chairman Roman then noted that the Town of Fort Mill had been part of the State of South Carolina certified local government (CLG) program for over a decade. Thus, he stated that while the HRB did not want to be overbearing, it was important to expect that things within the historic district be done a certain way. The town has expended a lot of resources to make sure that the HRB should be doing what it’s supposed to be doing. Chairman Roman then commended Kuester for their tremendous work in the community. However, he personally believed that there must be a point and time when something happens it must impact other things. He noted that this instance of a project not being fully constructed to plan could possibly impact the Bailey Bill. Thus, the HRB would have to figure out what they are to do with this. While the current discussion involving the demising wall involves only a small portion of the overall project, Chairman Roman noted that if the current applicant is allowed to retain what was not built per the approved plan, then it may very well set a bad precedent of future projects coming forward and requesting that the HRB forgive them as well. Chairman Roman then stated that HRB certainly wanted qualified contractors to address the very sensitive demising wall and what the result of paint and TPO removal from the brick and mortar would in fact be. He questioned why the applicant did not bring in qualified contractors to discuss this issue. Mr. Rollar responded that these contractors may in fact be very qualified, but that he will have to do further investigation on this and that he could just not say with certainty at this time. Scott Couchenour then noted that in fact there were two painted walls, one being the demising wall on the 219 & 221 Main Street project, and the other being the demising wall between 219 and 217 Main Street which was also painted and covered with painting and TPO roofing. Mr. Couchenour wanted to be sure that the owner of 217 Main Street was thus kept in the loop about what was going on. Mr. Kuester concurred with this sentiment. Chairman Roman then asked Senior Planner Moore if staff had a recommendation for the board on the matter at hand. Mr. Moore responded that staff did not make a recommendation but that the applicant provide the information as requested on November 8th at the previous HRB meeting. Chairman Roman then asked Senior Planner Moore to provide information on how a decision on the covering of the demising wall could potentially impact the status of the Bailey Bill as related to this project. First, Planning Director Penelope Karagounis noted that a certificate of appropriateness, the Bailey Bill, and the façade improvement grant were each part of the project at 219 & 221 Main Street. Mr. Moore then briefly explained the Bailey Bill and how it is related to this project. He noted that this project was granted preliminary Bailey Bill approval in September 2021. This meant that the project must be completed by September 2023 in order to receive final Bailey Bill approval from the HRB. And, he noted, if that portion of the demising wall were granted approval to remain covered with paint and the TPO roof, it would be indicated within the final approval proceedings that this area was not constructed to plan. Chairman Roman then asked Senior Planner Moore if the HRB had any influence on the façade improvement grant. Mr. Moore stated that the façade improvement grant for 219 & 221 Main Street was currently being processed. He noted that the applicant had installed the wood clad windows and that the town had inspected the property and found it to be in conformance with what was approved. Chairman Roman asked if there were any other questions from the HRB. Elizabeth Leventis stated that she had no questions but indicated that it was too early to consider granting an amendment to the previously approved certificate of appropriateness without exploring all options available for remediating the situation with the demising wall. This would include the applicant gleaning the opinions of specialists with experience with this type of brick and bringing the results back to the HRB. She stated that this would take more time, but allow the HRB to properly explore the options before approving yes or no. Planning Director Karagounis then stated that the next scheduled HRB meeting would be Tuesday December 13th. Chairman Roman stated that he didn’t know if the applicant would be able to obtain all of the information needed due to the holiday season. Mr. Kuester said that they would do their best to address the HRB requests. He indicated that Charlotte Paint was a large company. Regarding the roof, he stated that he wanted to be more careful with because the original roof was in horrible condition and as the letter from Johnson’s Roofing Services indicated, they can remove the TPO, but at that point the integrity of the building is going to be at stake. Mr. Kuester noted that much of the work that they undertook on the building refurbishment involved water damage. Thus, roof integrity would be critical moving forward. With this, Mr. Kuester requested forbearance on the demising wall issue regarding the TPO flashing. He asked the HRB to allow them to keep the TPO as is since the roof was in such bad shape to begin with. Planning Director Karagounis then asked the HRB to keep in mind that any motion made could be split up, with the result that part of the request could be approved and part of the request could be continued. Mr. Couchenour stated that he would like to see that regarding the demising wall, he would like to see the demising wall for 217 Main Street be broken out separately since there was a different property owner involved for that particular property. Senior Planner Moore stated that the demising wall at 217 Main Street was not being considered under the current request and was not on the agenda. He indicated that it was his understanding that Kuester was dealing with the owner of 217 Main Street on their own, apart from the current HRB proceedings. Mr. Kuester then stated that they have a good relationship with the owner of 217 Main Street and that he had told the proprietor there that whatever he wanted Kuester to do that they would do it. Mr. Couchenour then stated that as far as the TPO was concerned, he could make a motion to allow that to remain since it was his understanding that it would be very difficult to remove without causing considerable damage. Conversely, he started that he would also be fine if the HRB decided to request additional information on its removal. Generally, he indicated that he believed it may be the right thing to do to leave the TPO> Mr. Booth stated that he also believed it may be the right thing to do, however he also stated that it was a failure on the part of the architect to bring it to the attention of HRB knowing full well what the condition of the brick was. He indicated that a conversation should have been had which considered the delicate nature of the historic brick on the demising wall. This was a failure of the architect to understand the two conditions of the brick and roofing coming together. None of this was presented to HRB or indicated on the plan. Thus, he stated that before the HRB granted approval on the TPO, they needed to review and make sure everything was understood. Chairman Roman agreed and noted that he personally had experience on Main Street with the property he owned. Here he was considering touching up the TPO membrane. With this, he brought in someone to look at the structural integrity of the wall in the attic and determine if something else needed to be done before applying the roofing membrane. This was done prior to him considering applying for a certificate of appropriateness for any work to be done. Thus, Chairman Roman noted that it was hard for him to understand why such details were not undertaken at 219 & 221 Main Street. Chairman Roman then stated that he personally did not believe that the board had enough information to obtain any motions at this time. However, he would of course allow the board to make any decision they deemed appropriate. Mr. Couchenour then stated that he would likely make a motion to defer, however he indicated that he believed the board needed some direction on what information they should ask to be presented at the next meeting. Senior Planner Moore then stated that to Mr. Couchenour’s earlier point regarding 217 Main Street, the HRB could consider this at the next HRB meeting. Chairman Roman concurred with this idea. Mr. Couchenour agreed, but also noted that with that, all of the needed direction on what the applicant needed to do should be included as well. Chairman Roman then asked Mr. Kuester if it was clear on what needed to be done. Mr. Kuester then stated that yes, but it was a frustrating situation because they did not want this to happen. He noted that he understood the position of the HRB. Chairman Roman then noted that while the demising wall issue was a small part of the overall project, but that the HRB had a process which they were very sensitive to. Thus, it was this process that the applicant was receiving feedback on in conjunction with the issues that were created on site. Mr. Kuester then stated that he appreciated the HRB showing up tonight and being in attendance for an extra meeting. Mr. Couchenour then asked if the TPO information requested would be provided by the architect and the roofing contractor and the manufacturer. Mr. Booth stated that it would be the architect, roofing contractor, and the manufacturer. Mr. Couchenour then asked who would be responsible for providing the information on the paint. Mr. Rollar stated that he would be defining the types of paint removal available and what that means and what kind of experience the contractor has in this method. Chairman Roman asked Mr. Rollar to also include information on any chemical processes which may be available. Mr. Couchenour then asked if they needed a brick mason to be involved in providing information as well. Ms. Scarlett then stated that she thought it would be reasonable that if the painting contractor did not have previous experience with this type of situation that there should be an effort made to find a company that does have the experience necessary to provide an opinion on how best to handle this situation. Mr. Couchenour then stated that from his experience Charlotte Paint was a very reputable company and that it was his opinion that they could provide the information needed. Mr. Kuester stated that he would find out. Chairman Roman then recognized Douglas Roman who attended the meeting. Mr. Roman stated that if the wall is old and it is not waterproof, and you seal it with paint or some other covering this can damage the wall. So, if you paint the wall, then you must do it with a natural paint which means it has the chemistry of the walls that allows breathability. And as far as old walls are concerned, it is the mortar which is the static of the wall. This can be grouted out and re-plastered with lime, sand, and water. It is very important that the wall is breathing. If it is sealed on one side, it must breathe from the other side. Chairman Roman then indicated that Douglas Roman is his brother and that he owns a professional painting company in Germany. Mr. Couchenour thanked Chairman Roman for allowing Mr. Roman to speak. Mr. Couchenour then indicated he was going to make a motion and noted that he was open to all friendly amendments. Mr. Couchenour moved that for item number one, the TPO roofing membrane, that information be received from the manufacturer, the architect, and the contractor of the options to have the demising wall reflect the approved plan from September 14th, 2021. Mr. Booth added that there should also be included any precedent that the contractor or architect has in removing this material, or if the manufacturer has precedent in removing this material, from brick and mortar of this type. Mr. Couchenour then moved that for item number two, which involved the removal of the paint, that more detailed information be received from the architect, the painting contractor, on the options available to have the demising wall reflect the approved plan from September 14th, 2021. This would include any precedent that the contractor or architect has in removing such paint, or if the paint manufacturer has precedent in removing this paint, from brick or mortar of this type. This would include silt blasting, chemical removal, or other options that they have. Such options would include the least invasive industry methods available. Additionally, this portion of the motion requires that information be received from a masonry company qualified to repair the underlying historical brick after removal of the paint. Thirdly, Mr. Couchenour moved that the same information as noted above for the TPO roofing membrane and paint, be provided for the demising wall at 217 Main Street. Additionally, the owner of 217 Main Street shall be involved and be present at the respective HRB meeting to ensure the board that he is agreeable to this process. A decision on the demising wall by the HRB will be deferred until such time the applicant has this required information. Ms. Leventis seconded the motion. There being no further discussion, Chairman Roman asked all those in favor of the motion to signify by saying aye. The motion carried by a vote of 5-0. Chairman Roman then noted that the HRB appreciated the diligence of Mr. Kuester in handling this situation. Additionally, Chairman Roman indicated that they certainly did not want to in any way discourage this type of development within the town’s historic district on Main Street and that they were very appreciative of the efforts that Kuester Real Estate had undertaken there. There being no other business, Chairman Roman adjourned the meeting at 5:14 PM. Respectfully submitted, Alex J. Moore, AICP Senior Planner December 6th, 2022

Agenda

HISTORIC REVIEW BOARD SPECIAL MEETING 112 Confederate Street November 29th, 2022 4:30 PM AGENDA CALL TO ORDER APPROVAL OF MINUTES 1. HRB Meeting: November 8th, 2022 [Pages 2 - 7] OLD BUSINESS 1. Request to modify a Certificate of Appropriateness (COA) [Pages 8 - 45] Applicant Name: Kuester Commercial Owner Name: 219-221 Main Street, LLC Property Address: 219-221 Main Street Purpose: The applicant has requested to modify a previously approved COA Property information: Town of Fort Mill Historic Preservation District LC, Local Commercial Zoning District ADJOURN The following press was notified of the meeting by email or fax in accordance with the Freedom of Information Act: The Herald, CN2, WRHI, WSOC, and WBTV. The agenda was also posted at the entrance to Town Hall the required length of time and on the Town website. The Town of Fort Mill is committed to assuring accessibility with reasonable accommodation, of Town services and facilities for all individuals, in compliance with federal law. Please contact the Town Manager’s Office at 803-547-2116 if you need assistance. 1 MINUTES TOWN OF FORT MILL HISTORIC REVIEW BOARD November 8th, 2022 112 Confederate Street 4:30 PM Present: Vice chairwoman Megan Brinton, David Booth, Scott Couchenour, Niki Todaro, Planning Director Penelope Karagounis, Senior Planner Alex Moore Absent: Elizabeth Leventis, Louis Roman, Jessica Scarlett Guests: Shaw Kuester, Karli Phillips, Mark Kurowski CALL TO ORDER Vice chairwoman Megan Brinton called the meeting to order at 4:34 PM. APPROVAL OF MINUTES Vice chairwoman Megan Brinton entertained a motion to approve the minutes from the October 11th, 2022, Historic Review Board (HRB) meeting. Scott Couchenour made a motion to approve the minutes. David Booth seconded the motion. The minutes were then approved by a vote of 4-0. NEW BUSINESS 1. Request to modify an approved Certificate of Appropriateness (COA) Senior Planner Moore provided an overview of a request to modify an approved Certificate of Appropriateness (COA) at 219-221 Main Street. This COA was originally approved by the Town of Fort Mill Historic Review Board on September 14th, 2021. Moore stated that the approval included those items on pages five and six of the HRB packet, but that particular focus would now be on that portion of the COA dealing with the demising wall between 219 and 221 Main Street. Moore indicated that the HRB had included a condition as part of their approval of the COA in September 2021 that this demising wall was to be left unpainted. Thus, the following language was included within the approval notification subsequently sent to the applicant: “The original brick of the demising wall between 219 and 221 Main Street shall remain unpainted. This demising wall is illustrated within the attached color rendering.” Moore continued as he stated that at some point during the exterior refurbishment of 219 and 221 Main Street, the demising wall was painted. He shared recent pictures of the building which indicated this condition. As a result, Kuester Real Estate is specifically requesting that the HRB allow for a modification to the approved COA which 2 would remove the condition that the demising wall be left unpainted and thus allow the brick to remain painted as shown. Moore then concluded his initial presentation by asking HRB members if they had any questions regarding the request. David Booth clarified that on the originally approved COA in September 2021, HRB made it a condition of the approval that the demising wall was to be left unpainted, and yet now Kuester is asking for amendment to allow for the demising wall to remain painted because Kuester painted this demising wall when it should not have been painted to begin with. Senior Planner Moore concurred with this statement. Vice chairwoman Megan Brinton then asked exactly what was painted. Shaw Kuester, President of Kuester Real Estate Services, then interjected that the portion of the demising wall that was now “painted white” was in fact was covered by a white roof membrane. David Booth then asked why the roof membrane was installed at this location. Mr. Kuester responded that he believed that that the architect determined to place the roof membrane over this section of the demising wall. Planning Staff then asked Mr. Kuester to provide the HRB with his presentation on the demising wall issue. Mr. Kuester first noted that it was not the intention of his company to have the unpainted portion of the demising wall covered with paint and roofing material. Rather, he gave all the information from the HRB approval to his construction company, Simon & Watson Construction, Inc., along with his architect, Red Clay Design. Mr. Kuester then stated that Kuester Real Estate did not know that the demising wall had been covered until they were contacted by the Town of Fort Mill. He indicated that at that point he discussed with the Planning Department about what to do. Ultimately his goal is to request forgiveness from the HRB and to find the best solution to address the paint and roofing material without damaging a project that his company has put millions of dollars into. Mr. Kuester stated that due to the delicate, historic nature of these buildings that his preferred solution would be to keep the condition as is with the paint and roofing membrane allowed to remain. Vice chairwoman Brinton then stated that this situation is indeed a dilemma because the letter of approval subsequent to the September 2021 HRB meeting, along with the minutes from that meeting, indicated very clearly that the unpainted portion of the demising wall was to remain as is. Mr. Kuester agreed but noted again that his intention was not for the demising wall to be covered with paint and roofing material. He stated that Kuester Real Estate hired contractors to complete this portion of the project but that they did not do it correctly. He agreed that it was a problematic situation. Mr. Kuester then stated that if the HRB wanted his company to try and remove the materials they could. But, at this juncture he did not know what the method for removing the materials would be. He then deferred to the HRB for their thoughts on removing the materials. 3 David Booth speculated that the roofer may have put the membrane material on the demising wall so that the roof would have a single seam rather than having flashing along the top to conceal the membrane material and to provide for a tight seal. But he then noted that this was unfortunately a poor decision based on what the understanding of the COA approval should have been. Mr. Booth then stated that the HRB was now in the position of perhaps setting an undesirable precedent. On the other hand, Mr. Booth noted, if the roofing membrane is now removed from the building, the result may have the undesirable result of opening the building to the weather elements. He stated that he was of the mind to try to cut down the roofing membrane and put flashing on it to restore the brick, but conversely, he did not want to damage the building. Mr. Booth then stated that now, in the future others may come forward on other projects with a similar situation with the idea that the developer at 219 & 221 Main Street did it, so why can’t we do the same? Then there is the constant influx of project developers asking for forgiveness. Mr. Booth then stated that at the same time, we need to understand that these buildings are historic, and they need to be protected long term. He then asked Mr. Kuester what the contractor and architect of record are suggesting to be done to rectify the situation. Mr. Kuester replied that he had spoken with the architect and that he was told by him that the brick was not intended to be painted. The architect will be okay with whatever is decided regarding the paint. The error was in fact with the contractor and not the architect. Vice chairwoman Brinton noted that the letter from Kuester Real Estate seemed to indicate that the problem was in the design documents. Mr. Kuester replied that it was not necessarily the design documents because they looked at them and it was determined that the problem was with the contractor. Mr. Booth asked if we have those approved design documents from the town to review with the elevations. Mr. Kuester indicated that he did have them, and these documents indicated that the demising wall was to remain unpainted. Mr. Booth then asked what the architectural cross section indicate because it is on the architect to make sure that the plans are followed. Senior Planner Moore stated that this cross section was included within the HRB packet for review and noted the location within the on-screen agenda presentation. He noted the plan which states “Restore existing brick. Patch and repair cracks and other damage areas with brick to match. See specs and finish plans for additional information.” Mr. Booth then asked Mr. Kuester if his contractor had provided him with a change order request to make the change. Mr. Kuester stated that the contractor did the work on the demising wall on their own with no approved change order. Mr. Booth noted that it is on the contractor to review the approved drawings and they assume responsibility for following the documents. 4 Mr. Kuester concurred with this statement. Vice chairwoman Brinton then stated that she spoke with the South Carolina State Historic Preservation Office (SHPO) to get some direction on this issue. The SHPO representative indicated to her that there was no clear answer on what to do as a remedy for this situation because of the strong need for the building not to become damaged due to attempts at removing these materials from the demising wall. Ms. Brinton also indicated that she agreed with Mr. Booth on the danger of creating an undesirable precedent of making it easy for downtown developers to come to the HRB and ask forgiveness for project mistakes. She stated that she would have a hard time allowing for such an amendment when it would be clearly in opposition to the Secretary of Interior’s guidelines. Mr. Kuester asked Ms. Brinton if she was now stating that she wished for them to remove the paint from the wall. Ms. Brinton responded that she was unsure due to the potential ramifications of doing so. Mr. Booth then pointed out that there were two problems, first, the paint on the demising wall, and second, the roofing material as well. Mr. Kuester then stated that the rendering being used for discussion was done early on. However, he indicated he would investigate the reasoning for placing the membrane roofing on the demising wall as well as the paint. The work, though, was left under the purview of the project manager and architect. He stated he would be happy to bring the architect to a future meeting. Mr. Booth then stated that his recommendation would be to have some type of investigation to determine what the condition of the TPO roof is on the demising wall and get a better understanding of what is underneath it and what the result would be of removing it. Mr. Couchenour stated that there could be mastic behind the membrane roof. Mr. Booth concurred with this and indicated that if that was the case, the brick would be destroyed in trying to remove the membrane roof. Thus, his recommendation would be to have an analysis done resulting in understanding what would need to be done to remove the membrane roof. He stated that he was not as concerned about the paint as it might be a little easier to remove than the TPO with potential mastic beneath it. Mr. Couchenour then asked if there would be a preference to try and remove the paint from the demising wall from the “Local Dish” building (217 Main Street) as well. He noted that the existing bricks on this building were in very poor condition. Mr. Mark Kurowski, owner of 217 Main Street stated that he, like Mr. Kuester and the HRB, wants what is best for the historic buildings, but that he wanted to maintain the integrity of the structures as well as their historic value. There was some discussion about testing portions of the buildings to determine the best method of removing the materials placed on the demising wall. Mr. Kurowski indicated that he would be open to testing on his building but that his intention would be to repair the existing brick on his demising wall. 5 Senior Planner Moore then asked what type of testing they had in mind since sandblasting the brick would not be recommended. Mr. Booth stated that the contractor should probably coordinate this and find out what is recommended for the removal of the membrane roof in instances such as this one. The result would be that a determination would be made on whether the membrane roof, and its supporting material, could be removed without damaging the demising wall. Mr. Couchenour then stated that the same method could be used by the painting contractor. Discussion then took place about how similar situations in the Town of Fort Mill not within the historic district are handled. Planning Director Karagounis indicated that it would be up to the town’s building official to decide on this, but that it was unlikely that similar, aesthetic related mistakes were so critical from the town’s perspective outside of the historic district There was then discussion about the timing of a decision to be made by the HRB as related to the internal deadlines that Kuester Real Estate had established with the future tenants of this building. Mr. Kuester indicated that he intended to work quickly upon the rendering of a decision by the HRB. Thus, he did not immediately see any conflicts here. Planning Director Karagounis then clarified that the HRB would want this case to come back to them for review and approval based on the analysis as previously discussed. She indicated that the HRB could have a special meeting prior to the December meeting if necessary. Mr. Kuester stated that his group would most likely need until the December meeting to gather all the information needed. Vice chairwoman Brinton entertained a motion. Mr. Booth made a motion consisting of the following three points: 1) Kuester Real Estate shall provide written documentation from the roofing contractor, or manufacturer of the TPO roof, as to the method of its application to the brick on the demising wall and what it would take for the application of the TPO roof to be removed from this brick, and what damages to the brick would be expected due to this potential removal. 2) Kuester Real Estate shall provide written documentation from the painting contractor, or the manufacturer of the paint, regarding what could be done to remove the paint from the brick of the demising wall, and what damages to the brick would be expected due to this potential removal. 3) This documentation will be reviewed by the HRB. Should this documentation be provided prior to the scheduled December 13th, 2022, meeting, the HRB would entertain convening for a special meeting to review the written documentation and render a decision on whether the certificate of appropriateness as issued on September 21st, 2022, will be modified to allow the paint and/or TPO roof to remain on the demising wall. Otherwise, the HRB will consider this information at its regularly scheduled meeting on December 13th, 2022. Scott Couchenour seconded the motion. This motion passed by a vote of 4-0. 6 There being no other business, Vice chairwoman Brinton adjourned the meeting at 5:10 PM. Respectfully submitted, Alex J. Moore, AICP Senior Planner November 15th, 2022 7 HISTORIC REVIEW BOARD APPLICANT Kuester Commercial Subject Property: 219 & 221 Main Street Tax Map # 020-02-01-008 & 020-02-01-009 Zoning District: Local Commercial, LC/Historic District Zoning Case: 2021-0660 REQUEST The Planning Department received a request from Kuester Commercial to amend a previously approved Certificate of Appropriateness (COA) for 219 & 221 Main Street. At their regularly scheduled meeting on November 8th, 2022, the HRB heard this request. After having heard this request, HRB voted to require that Kuester Real Estate provide them with additional information prior to rendering a final decision on the COA modification. BACKGROUND INFORMATION On September 14th, 2021, the Town of Fort Mill Historic Review Board (HRB) granted a COA for exterior improvements at 219 & 221 Main Street which included the following items: (1) Proposed improvements to the façade and roof at 219 Main Street: Refurbish and repaint the existing brick; Replace upper story windows with clad, wood windows; Removal of full aluminum storefront and metal siding; Replacement of full aluminum storefront and metal siding with materials matching the historic façade; An additional door will be placed along the right façade; A new thermoplastic polyoefin roof (TPO) will be added to the building. (2) Proposed improvements to the rear elevation at 219 Main Street: Refurbish and repaint the existing brick; Installation of new, clad, wood windows; Addition of an outdoor patio/deck; Addition of handrailing as required. (3) Proposed improvements to the façade and roof at 221 Main Street: Refurbish and repaint the existing brick; replace upper story windows with clad, wood windows; Restoration of existing metal panels and steel windows on the storefront; Restoration/reinstallation of awning hood and new awning; A new thermoplastic polyoefin roof (TPO) will be added to the building. (4) Proposed improvements to the rear elevation at 221 Main Street: Refurbish and repaint the existing brick; Installation of new, clad, wood windows; Addition of handrailing as required. Additionally, as part of this approval, the HRB made the following points conditional to the approved items above: • Glass shall not be incorporated into the design of any handrailing at the rear of 219 or 221 Main Street. 8 • All handrailing used within this project shall be modeled after, but not necessarily an exact replica of, the handrailing currently in existence at the rear of the Spratt Building (215 Main Street) and the Local Dish building (217 Main Street). • The original brick of the demising wall between 219 and 221 Main Street shall remain unpainted. This demising wall is illustrated within the attached, color rendering. Thus, based on the highlighted condition above, the original brick comprising the demising wall between 219 and 221 Main Street was not to be painted. Rather, it was to remain unpainted. Recently, however it came to the attention of the HRB and town staff that this demising wall has been painted in violation of the approved COA in September 2021. Subsequently, town staff contacted Kuester and informed them that there were two options at this juncture for remedying the situation: (1) Remove the paint from the demising wall so that it matches what was approved; or (2) Appear before the Town of Fort Mill HRB to request a modification to the September 2021 COA. An approval of a modification is the only way the paint may remain on the demising wall as is. Otherwise, it will have to be removed by the property owner. On November 8th, 2022, Kuester appeared before the HRB to formally request the COA modification. At that meeting, and after having heard the above information presented by town staff and by Kuester, the HRB voted to require the following: 1) Kuester Real Estate shall provide written documentation from the roofing contractor, or manufacturer of the TPO roof, as to the method of its application to the brick on the demising wall and what it would take for the application of the TPO roof to be removed from this brick, and what damages to the brick would be expected due to this potential removal. 2) Kuester Real Estate shall provide written documentation from the painting contractor, or the manufacturer of the paint, regarding what could be done to remove the paint from the brick of the demising wall, and what damages to the brick would be expected due to this potential removal. 3) This documentation will be reviewed by the HRB. Should this documentation be provided prior to the scheduled December 13th, 2022, meeting, the HRB would entertain convening for a special meeting to review the written documentation and render a decision on whether the certificate of appropriateness as issued on September 21st, 2022, will be modified to allow the paint and/or TPO roof to remain on the demising wall. Otherwise, the HRB will consider this information at its regularly scheduled meeting on December 13th, 2022. Based on the above conditions as affirmed by HRB, Kuester submitted additional information to town staff regarding the feasibility of removing the paint and portions of the TPO roof from the brick demising wall. This information is attached along with the original HRB approval information from 2021. The original approval information provides additional background material such as photographs and schematics. Kuester’s request remains to modify the COA as granted in September 2021. ATTACHMENTS 1. Original Certificate of Appropriateness (COA) notice of action letter along with application & materials from the September 2021 HRB meeting 2. Request from Kuester Real Estate to modify the approved COA along with pictures of the existing condition of the demising wall in question 3. Notice of action letter sent to applicant subsequent to the November 8th, 2022, HRB meeting 9 4. Report from painting contractor on feasibility of removing paint from brick demising wall and report from roofing contractor on feasibility of removing TPO wall flashings from brick demising wall 10 Exhibit 1 Original COA Approval Notification & Application 2021 11 October 7th, 2021 Mr. Sean Gorman sean@kuestercre.com RE: 219 & 221 Main Street Certificate of Appropriateness for exterior improvements Zoning Case 2021-0660 Mr. Gorman, On Tuesday September 14th, 2021, the Town of Fort Mill Historic Review Board (HRB) met to consider your application for a Certificate of Appropriateness (COA) for proposed exterior improvements at 219 & 221 Main Street which included: (1) Proposed improvements to the façade and roof at 219 Main Street: Refurbish and repaint the existing brick; Replace upper story windows with clad, wood windows; Removal of full aluminum storefront and metal siding; Replacement of full aluminum storefront and metal siding with materials matching the historic façade; An additional door will be placed along the right façade; A new thermoplastic polyoefin roof (TPO) will be added to the building. (2) Proposed improvements to the rear elevation at 219 Main Street: Refurbish and repaint the existing brick; Installation of new, clad, wood windows; Addition of an outdoor patio/deck; Addition of handrailing as required. (3) Proposed improvements to the façade and roof at 221 Main Street: Refurbish and repaint the existing brick; replace upper story windows with clad, wood windows; Restoration of existing metal panels and steel windows on the storefront; Restoration/reinstallation of awning hood and new awning; A new thermoplastic polyoefin roof (TPO) will be added to the building. (4) Proposed improvements to the rear elevation at 221 Main Street: Refurbish and repaint the existing brick; Installation of new, clad, wood windows; Addition of handrailing as required. As detailed in the minutes of this meeting, the HRB approved the COA for the above, exterior improvements. This approval is based upon on the above project description, the attached drawings as submitted, along with the following conditions set by the HRB: • Glass shall not be incorporated into the design of any handrailing at the rear of 219 or 221 Main Street. • All handrailing used within this project shall be modeled after, but not necessarily an exact replica of, the handrailing currently in existence at the rear of the Spratt Building (215 Main Street) and the Local Dish building (217 Main Street). • The original brick of the demising wall between 219 and 221 Main Street shall remain unpainted. This demising wall is illustrated within the attached, color rendering. 12 Additionally, to proceed with the façade improvement grant application for these exterior improvements, we will need you to submit three (3) detailed cost estimates/bids for the proposed enhancements. The façade improvement grant application is attached. Please note that approval by the HRB for this COA does not preclude the requirement for obtaining the necessary building permits from the Town of Fort Mill. Additionally, a Town of Fort Mill business license will need to be obtained by any contractor performing work on this project. For questions about building permits and business licenses, please contact Parrish Dunn, Town of Fort Mill Development Coordinator, at 803-835-2337. If you have any questions or comments about the contents of this letter, please contact me at (803) 835- 1162, or via email at amoore@fortmillsc.gov. We look forward to continued collaboration with Kuester Sincerely, Alex J. Moore, AICP Senior Planner Attachments Ecc: shaw@kuestercre.com developmentcenter@fortmillsc.gov 13 14 15 H I S T OR I C R E V I E W B OA R D APPLICANT Kuester Commercial Subject Property: 219 & 221 Main Street Tax Map # 020-02-01-008 & 020-02-01-009 Zoning District: Local Commercial, LC/Historic District Zoning Case: 2021-0660 REQUEST The Planning Department has received an application for a Certificate of Appropriateness (COA) from Kuester Commercial. The purpose of this COA request is to refurbish the exterior of the buildings located at 219 & 221 Main Street. SITE DESCRIPTION AND GENERAL CONSTRUCTION PLAN These properties are located within the downtown historic district, and both are listed on the National Register of Historic Places (NRHP). The buildings were constructed in circa 1900. The front façade of the building at 219 Main Street consists of the original brick, now painted, and augmented with aluminum awning windows, an aluminum storefront, and metal siding. The rear elevation of this structure currently consists of original brick, an awning over the rear door, infill wood sections surrounding the rear windows, along with a concrete loading deck. The front façade of the building at 221 Main Street also consists of the original brick, now painted, and augmented with metal storefront panels, and an awning. The second story windows were covered/enclosed in past years. The applicant proposes the front façade upgrade at 219 Main Street to include refurbished brick. Upper story windows will be replaced with clad, wood windows. The full aluminum storefront and metal siding will be removed and replaced with materials which match the historic, 1920 photo as included within this application. These windows will be clad, wood. A primary, recessed door will be added. An additional door will be installed along the right façade. The existing awning hood on the front façade of 219 Main Street will be restored and reinstalled with a new, retractable awning. The rear elevation refurbishment at 219 Main Street will include restoration of the existing brick, removing the infill sections and replacing them with clad wood windows. A new rooftop deck and stairs will be added. Additionally, a new, TPO roof will be installed. 16 The refurbishment of the front façade of the adjacent building at 221 Main Street will also include restoration of the existing brick. The covered, upper story openings will be replaced with clad, wood windows. The existing metal panels and steel windows on the storefront will also be restored. The existing awning hood on the front façade of 221 Main Street will be restored and reinstalled with a new, retractable awning. The rear elevation refurbishment at 221 Main Street will include restoration of the existing brick, installation of new clad, wood windows, and the installation of a new TPO roof. HISTORIC DISTRICT DESIGN GUIDELINES REVIEW When considering an application for a COA for alteration, repair, or restoration, the HRB shall use the Secretary of Interior’s Standards for Rehabilitation as guidelines in making its decisions. These guidelines are to serve as the basis for determining the approval, approval with modification, or denial of a COA. These guidelines are listed below. The staff findings follow each guideline and are in bold and underlined. 1) Every reasonable effort shall be made to provide a compatible use for a property which requires minimal alteration of the building, structure, or site and its environment, or to use a property for its original intended purpose. This is an adaptive reuse project. As such, significant historic characteristics of the exterior will be retained and refurbished while accommodating a new function. 2) The distinguishing original qualities or character of a building, structure, or site and its environment shall not be destroyed. The removal or alteration of any historic material or distinctive architectural features should be avoided when possible. The original qualities and character of this building are not being destroyed but rather enhanced. Historical materials will be retained as appropriate. 3) All buildings, structures, and sites shall be recognized as products of their own time. Alterations that have no historical basis and which seek to create an earlier appearance shall be discouraged. The proposed work to be done consists principally of enhancements to the original architectural features of the building rather than alterations. 4) Changes which have taken place in the course of time are evidence of the history development of a building, structure, or site and its environment. These changes may have acquired significance in their own right, and this significance shall be recognized and respected. This building is an example of an early 20th century vernacular storefront. Subsequent changes to the front and rear building elevations are not reflective of that era and have not obtained significance in their own right. 5) Distinctive stylistic features or examples of skilled craftsmanship which characterize a building, structure or site shall be treated with sensitivity. It is anticipated that distinctive features of this building will be treated with sensitivity. The plans as submitted by the applicant indicate a desire to maintain significant, original features found on both the front and rear elevations. 6) Deteriorated architectural features shall be repaired rather than replaced wherever possible. In the event replacement is necessary, the new material should match the material being replaced in composition, design, color, texture, and other visible qualities. Repair or replacement of missing architectural features 17 should be based on accurate duplications of features, substantiated by history, physical, or pictorial evidence rather than on conjectural designs or the availability of different architectural elements from other buildings. The applicant has indicated that the deteriorated brick on the exterior of both buildings will be restored. 7) The surface cleaning of structures shall be undertaken with the gentlest means possible. Sandblasting and other cleaning methods that will damage the historic building material shall not be undertaken. It is not anticipated that sandblasting will not be used for this project. All surface cleaning must be done in a manner that is conducive to preservation. 8) Every reasonable effort should be made to protect and preserve archaeological resources affected by, or adjacent to the property. There are no known archaeological resources that will be affected by this project. 9) Contemporary design for alterations and additions to existing properties shall not be discouraged when such alterations and additions do not destroy significant historical, architectural, or cultural materials, and such design is compatible with the size, scale, color, material, and character of the property, neighborhood, or environment. Contemporary design is not being used as this is an adaptive reuse project. The work will include refurbishment and enhancement of original architectural features. 10) Wherever possible, new additions or alterations to structures shall be done in such a manner that if such additions or alterations were to be removed in the future, the essential form and integrity of the structure would be unimpaired. The elements within this exterior refurbishment project are not anticipated to be removed in the future. STAFF RECOMMENDATION Planning Staff recommends that the HRB grant APPROVAL for a Certificate of Appropriateness for the proposed exterior refurbishment project at 219 and 221 Main Street. 18 Page 1 of 2 Date Received: _08/24/2021___ Historic Review Board Date: _09/14/21__ Application for a Certificate of Appropriateness Town of Fort Mill, South Carolina Owner/ Applicant Information: Submission Checklist Applicant Name: Kuester Commercial � pleted application* Mailing Address: 127 Ben Casey Drive Suite 103 � wings and specifications of proposed improvements* Telephone Number: _8_0_3 _-5_7_8 _-7_78_ 8 _ _______ C2rsite plan showing location of Property Information: proposed improvements* Address: 219 and 221 Main Street �Application fee ($125 residential / $250 non-residential)* Current Zoning: Commercial/ Residential Additional materials may be required Current Use of Property: ----------- Commercial *Required with submission Work Summary: Please check all areas that apply to the proposed improvements 0 DEMOLITION □ NEW STRUCTURE 0 EMERGENCY REPAIR 0 GRAPHICS/SIGNAGE 0 MAINTENANCE REHABILITATION ADDmONS TO EXISTING SITE WORK 0 Foundations D Room addition D Fence or wall GZ} Masonry D Garage 0 Site lighting GI Siding Ill Porch or deck D Street furniture 0 Roof D Greenhouse D Special features I!) Gutters/downspouts O Dormer D Parking D Chimney 0 Skylight D Walks, patios G:j Doors/entrances D Chimney 0 Other Q Windows D Other D Porch D Cornice/frieze O Ornamentation (II Awning/canopy G Storefront [J Color/painting D Other APPLICATION CONTINUED ON NEXT PAGE P.O. BOX 159 • 200 TOM HALL STREET • FORT MILL, SC 29715 TELEPHONE (803) 547-2034 • FAX (803) 547-2126 19 Page 2 of 2 Date Received: _08/24/2021___ Historic Review Board Date: _09/14/21__ Explanation of Work: Please use the area below to provide a detailed explanation of the proposed work. When explaining the work, please provide information on the design, materials, colors, as well as installation/construction procedures. For example, when applying for a wall sign please provide detail on the design of the sign, what materials will be used, what colors will be used, and how will the sign will be affixed to the wall. Please attach continuation sheets as needed. Acknowledgement of Requirements: The applicant acknowledges that the information provided is complete and that any exterior modification, except for ordinary maintenance or repair (not involving change in design, material, color, or outer appearance), shall not commence until the Historic Review Board approves the specific modification through a Certificate of Appropriateness. Additional permitting may be required prior to beginning work, including zoning review, stormwater/engineering review, building permitting, and business licensing. Please note, incomplete submissi will not be accepted. P.O. BOX 159 • 200 TOM HALL STREET • FORT MILL, SC 29715 TELEPHONE (803) 547-2034 • FAX (803) 547-2126 20 21 22 23 24 25 26 September 2021&ACADE  219 & 221 Main St. 27 September 2021 &ACADE 219 Main St.  28 September 2021 2EARº%LEVATION 219 Main St.  29 September 2021 2EAR%LEVATION 219 Main St.         30 September 2021 FrontFacade 221 Main St. 31 • September 2021 Rear %LEVATIONs 219 & 221 Main St. 32 September 2021 Rear%LEVATION 221 Main St. 33 Exhibit 2 Request from Kuester Real Estate for COA Modification & Pictures of Existing Demising Wall 34 35 36 37 38 Exhibit 3 Notice of Action Letter for November 8th HRB Meeting 39 November 15th, 2022 Mr. Shaw Kuester, President Kuester Real Estate Services shaw@kuestercre.com RE: 219 & 221 Main Street Certificate of Appropriateness for exterior improvements Zoning Case 2021-0660 Mr. Kuester, On Tuesday November 8th, 2022, the Town of Fort Mill Historic Review Board (HRB) met to consider your request to modify a previously approved certificate of appropriateness (COA) for 219 & 221 Main Street. Specifically, you requested that paint and roofing materials, which were not to be applied to the demising wall between 219 and 221 Main Street, be allowed to remain. The HRB had previously determined on September 21st, 2021, that the brick of this demising wall was to be left unpainted/uncovered. As detailed in the minutes of the November 8th, 2022, meeting, the HRB made the following determination on this modification request: 1) Kuester Real Estate shall provide written documentation from the roofing contractor, or manufacturer of the TPO roof, as to the method of its application to the brick on the demising wall and what would be entailed for the TPO roof to be removed from this brick, and what damages to the brick would be expected due to this potential removal. 2) Kuester Real Estate shall provide written documentation from the painting contractor, or the manufacturer of the paint, regarding what would be entailed to remove the paint from the brick of the demising wall, and what damages to the brick would be expected due to this potential removal. 3) This requested documentation shall be reviewed by the HRB. Should this documentation be provided prior to the scheduled December 13th, 2022, meeting, the HRB would entertain convening a special meeting to review the written documentation and render a decision on whether the certificate of appropriateness as issued on September 21st, 2021, can be modified to allow the paint and/or TPO roof to remain on the demising wall. Otherwise, the HRB will consider this information at its regularly scheduled meeting on December 13th, 2022. If you have any questions or comments about the contents of this letter, please contact me at (803) 835- 1162, or via email at amoore@fortmillsc.gov. We look forward to continued collaboration with Kuester Real Estate on this project. 40 Sincerely, Alex J. Moore, AICP Senior Planner Ecc: karli@kuestercre.com pkaragounis@fortmillsc.gov 41 Exhibit 4 Report from Painting Contractor & Roofing Contractor 42 Stuart, I have spoken with my contact about the coating removal on main street Fort Mill. He feels confident that he can do it but like anything, there’s some risks. Not only does it remove the coating or contamination being targeted, it also profiles and scars the underlying substrate in the process. This could cause a physical disorientation with the brick. I am concerned that attempting to remove such a small area will damage the surface and also discolor any other coating on other parts of the building itself. The brick itself doesn’t concern me as much as the mortar. With this building being old I am afraid that the mortar would weaken and cause bricks to become lose. Thank, ATTENTION: Please call the division number found in our email signature below: 704-827-1391 Lucas Allen Project Manager Charlotte Paint Co., LLC a PO Box 765, 1604 Lane Rd, Mt Holly, NC 28120 w charlottepaint.com d 704-827-1391 43 Johnson's Roofing Service, Inc. PO Box 607 Fort Mill, SC 29716 Phone: (803) 802-6502 Fax: (803) 802-6627 TO: Simon and Watson 11/16/2022 15050 Choate Cir Charlotte, NC 28273 Attn: Stuart Simon Re: Fully Adhered TPO Wall Flashings 219/221 Main Street Project With this letter, JRS is providing information pertaining to the fully adhered TPO wall flashings at the above referenced project. We acknowledge the 11/15/22 letter from the Ft Mill Historic Review Board; it indicates their potential desire to avoid seeing the white flashings completely extending up the parapet walls. JRS is still convinced that fully adhering the new TPO over the entire wall was the most appropriate way to ensure a watertight building. The brick was in very poor condition. The condition of the brick would have led to leaks behind the new roof flashings if they did not extend up the entire wall; moreover, the brick would have needed tuck pointing and then sealed with a coating. Extending the TPO up the wall in its entirety is a much better solution to prevent water infiltration compared to the tuck pointing and coating method. Furthermore, it gives the owner a complete warranty. The TPO can be removed from the wall if it best suits your needs. However, it comes with negative effects. There would be yellow residue on the old brick from the adhesive used to adhere the TPO wall flashings. That residue would have to be pressure washed away and that process could potentially damage the old brick and the mortar even more. Furthermore, JRS would have to terminate the wall flashings at the new height by using a termination bar and counter flashing. We are concerned the brick is potentially too deteriorated to hold a fastener for these products to ensure a quality process. Again, the brick would have to be reconditioned to prevent leaks if it was not covered with the roofing membrane. In summary, JRS will follow your direction as it pertains to how the TPO wall flashings are to be constructed. We are, however, very convinced that what we have already done is the best overall solution to keeping water outside of the building. Please take strong consideration to leaving the TPO wall flashing in their present condition. Best Regards, Drew Brashear 44 Johnson's Roofing Service, Inc. PO Box 607 Fort Mill, SC 29716 Phone: (803) 802-6502 Fax: (803) 802-6627 45

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