Historical Significance or Value
The house at 17 Jubilee Avenue has historical value for its association with wealthy Auckland builder and entrepreneur Alexander Richardson Watson who was closely associated with New Zealand’s late-nineteenth kauri timber industry and whose Torpedo Bay residential development illustrates Devonport’s development as a popular nineteenth-century seaside suburb of Auckland. The place also has historical significance as one of the assets of the estate inherited by his son, Devonport-born philanthropist A.R.D. Watson one of whose many bequests enabled the further development and beautification of Devonport’s esplanade where a civic memorial marks his beneficence.
Aesthetic Significance or Value:
The house at 17 Jubilee Avenue has aesthetic value for its visually appealing external appearance, and its setting within a well-established seaside neighbourhood. The residence is one of a pair of elegant villas (15 and 17) of virtually identical design within a row of well-maintained Victorian-era timber houses. Notable visual features of the residence include the formal entrance steps with square pillars and orbs; three brick chimney stacks (two symmetrically placed); the return verandah with paired posts; bay windows; and the configuration of the building on the site.
Architectural Significance or Value:
The house with its associated outbuilding has architectural significance as an example of a suburban, upper-middle class, late-Victorian villa residence of timber construction. It has value as one of a diverse collection of substantial rental houses erected and possibly designed by prominent nineteenth-century Auckland builder / contractor Alexander Richardson Watson. It has value as a well-designed house constructed in kauri timber and reflects joinery materials widely available at the time. Although the tower has been removed from the west elevation, the building otherwise largely retains its overall exterior form. It also retains most of its original layout, board and batten ceilings, timber dados, the original kitchen mantelpiece and stove alcove, and vertical timber linings of wide, dressed kauri boards in the rear service area.
Social Significance or Value:
The house at 17 Jubilee Avenue has social value as a reflection of a superior rental residence built in a sought-after seaside suburb for the intended purpose of accommodating tenants of high social standing. Early tenancies were held by Auckland merchant and agent John Boyd Gilfillan; and also by respected public servants - an Inspector in Charge of the Agricultural Department; and a Registrar of Pensions. The residence operated for a short period in the early twentieth century as a lodging house catering for those in semi-professional occupations including a sharebroker, a dentist, an accountant and a tea taster. The layout of the residence incorporating a rear hall and significant elements of the original service area reflects the domestic arrangements of a moderately well-off, turn of the century household.
(a) The extent to which the place reflects important or representative aspects of New Zealand history:
The house at 17 Jubilee Avenue reflects the turn of the century consolidation of seaside residential suburbs that emerged during the economic boom of the late 1870s and 1880s within commuting distance of the central business districts of the colony’s major cities, to cater for an emerging urban middle class.
(b) The association of the place with events, persons, or ideas of importance in New Zealand history:
The place has a close association with Alexander Richardson Watson, a leading Auckland builder / contractor and reputedly one of Auckland’s wealthiest citizens, who was a founding shareholder and a director of the Auckland Timber Company and a local advisor to its successor the Melbourne-based Kauri Timber Company. The place also has an association with his son Alexander Richardson Dickey Watson a notable public benefactor who made numerous public bequests in Auckland, including funding for much of the sea wall along Devonport’s King Edward Parade.
(g) The technical accomplishment or value, or design of the place:
The place has value as an externally well-preserved suburban villa that contributes to an understanding of the diversity of late-Victorian residential design. The place illustrates the incorporation of elements of an earlier mid-nineteenth century colonial Georgian or Regency style, as evident in the formality and simplicity of the design; the hipped roof; and the return verandah supported by paired posts. The architectural value of the place is enhanced by the survival of formal entrance steps which enhance the overall elegance of the place and its significance in the streetscape.
(k) The extent to which the place forms part of a wider historical and cultural complex or historical and cultural landscape:
The place forms part of the historical and cultural landscape of Devonport, a maritime suburb noted for its well-preserved nineteenth- and early twentieth-century buildings. The houses at 5, 15 and 17 Jubilee Avenue and 60 King Edward Parade are believed to be four of a number of residential buildings identified in the mid-1970s for their architectural interest and as representative of the former Borough’s earlier character. The houses at 15 and 17 Jubilee Avenue are located approximately 500 metres to the east of the Watson Memorial, erected by the former Devonport Borough Council to commemorate the generosity of A.R.D. Watson whose fortune was partly derived from a property portfolio that included the villas at 15 and 17 Jubilee Avenue.
Summary of Significance or Values
This place was assessed against, and found it to qualify under the following criteria: a, b, g and k.
It is considered that this place qualifies as a Category 2 historic place.
Early history of the site:
The northern shores of the Waitemata Harbour are of significance to several iwi, having been explored and occupied since early human arrival in New Zealand. According to oral tradition, the Arawa canoe under the navigator chief Tama Te Kapua investigated the Waitemata. The canoe deposited a ritual obsidian core brought from Hawaiki on Te Mata (Boat Rock), an island to the west of Chelsea Bay, giving rise to the name of the Waitemata Harbour. The Tainui canoe also landed at Te Hau Kapua (Torpedo Bay) in present-day Devonport before travelling to its eventual heartland in the Waikato.
According to oral tradition there were people already living at Te Hau Kapua at the time of the visit of the Tainui canoe. Physical evidence of very early settlement has been found on the foreshore where adzes were manufactured on stone working floors. Recorded horticultural features in the Maunga Uika (North Head), Takarunga (Mt Victoria) and Takararo (Mt Cambria) vicinity and evidence of terraces, pits and midden indicate that Maori occupied the volcanic cones in later times. The beach at Te Hau Kapua was the site of a late-eighteenth-century battle when a Nga Puhi, Te Kawerau and Te Parawhau alliance raided the Ngati Paoa pa, Takapuna, now known as North Head.
Following Ngapuhi incursions in the 1820s, much of the North Shore was depopulated, assisting its purchase by the British Crown after formal colonisation in 1840. A small Maori settlement at Te Hau Kapua remained until 1863.
Early colonial land division:
Devonport, originally known as Flagstaff, emerged as a colonial settlement with its use a British naval station in the 1840s. Crown land in the area was subdivided into suburban farms in 1850 and went on sale in 1851 and 1853. Located a short distance across the harbour from the colonial capital, Auckland, the land was particularly sought after by investors and speculators.
The site on which the house at 17 Jubilee Avenue was constructed lay within suburban farm Allotment 13A at North Head, a purchase made by James Hammond in 1854 adjoining Allotment 13 bought in 1851. Hammond, one of three elected wardens of the Hundred of Pupuke in 1854 and an inaugural member of the Flagstaff District Highway Board in 1867, had established a brickworks in Stanley Bay by 1845. He later personally advanced funds for the completion of one of the North Shore wharves.
Although Devonport was subject to speculation and land subdivision in the 1860s, large-scale development emerged primarily during the economic boom of the 1870s and 1880s. With the establishment of good quality ferry services to and from Auckland, Devonport became a well-established residential suburb and significant seaside resort.
Parts of Allotments 13 and 13A, purchased in 1874 by Hammond’s children Edward Hammond and Sarah Burgess, were bought in 1882 by Alexander Richardson Watson (1828-1911) a leading Auckland building contractor.
By 1884, during an Auckland real estate boom that largely targeted speculative investors, Watson created a 30-lot residential subdivision extending from Torpedo Bay to North Head Road (Takarunga Road). A private road to Watson’s residence in spacious grounds at North Head provided frontage for many of the new lots. The thoroughfare was known as Artillery Road by 1886, reflecting military fortifications constructed nearby during the Russian scare, and was later renamed Jubilee Avenue in 1897.
Lot sales in Watson’s subdivision were slow due to the economic depression of the late 1880s and early 1890s. Although Watson retired as a contractor in 1888, he continued to erect buildings for himself. In 1894, as the Auckland economy began to recover, he built the first of three rental houses in place south of Artillery Road by 1897. During the year ending February 1896 Watson also erected a single-storey villa, now known as 14 Takarunga Road.
The locality afforded views of the harbour and Devonport Domain’s cricket ground, and was near the Flagstaff commercial centre. Cheltenham Road at the west end of the Avenue was an important route for commuters from the developing seaside suburb of Cheltenham; and an important link for city excursionists visiting Cheltenham’s Rangitoto Bathing Beach.
Construction of residence at 17 Jubilee Avenue (circa 1897-9):
The single-storey timber villa at 17 Jubilee Avenue was Watson’s fifth rental property constructed within the subdivision. The design closely resembled the house at 14 Takarunga Road in place by February 1896, and was later adapted for 15 Jubilee Avenue erected in 1900-1.
The exact date of construction of 17 Jubilee Avenue is unknown, but occurred between February 1897 and before the end of 1899. A photograph of Torpedo Bay (1896-9) shows foundations under construction and timber stacked on the site.
The house was one of three Watson-built rental residences overlooking Torpedo Bay to incorporate a cupola, each of a different design. As at 14 Takarunga Road a cupola topped a tower lending an exotic appearance, inviting comparison with the architecturally eclectic Orientalism that emerged in English seaside resorts in the 1860s; or the pavilions of Midway at the World’s Columbian Exposition in Chicago, an attraction visited by Watson in 1893 during a trip to Britain.
The front entrance of the elegant villa was approached by plastered steps with wing walls decorated by orbs on squat piers. The seven-roomed dwelling almost L-shape in plan had a return verandah on three elevations, and three bay windows. Apart from the tower, the design loosely reflected colonial Georgian influences. Two brick chimneys topped by glazed-clay chimney pots served back-to-back fireplaces in the front rooms. A third chimney - located towards the rear of the hipped, slate roof - served the kitchen.
Internally, the front door opened into a wide central hallway. The most prestigious spaces located at the front of the house included the parlour off the east side of the hall. Immediately behind was a dining room with two doors, one opening into a rear hall adjoining the kitchen and service area. At the end of the central hall were the bathroom, and the back door. A 1906 plan shows the property bounded by picket fences, and a stone wall extending back from an outbuilding which accommodated a lavatory, a washhouse and a wood / coal store.
Although the identity of the architect and builder is not known, Watson - evidently a former draughtsman for William Henry Playfair (1789-1857), architect of the Scottish National Gallery (1851-7) - may have been the designer.
At the time of his death in 1911, Alexander Watson was one of Auckland’s wealthiest citizens. Born in Peebles, Scotland, the son of joiner / wheelwright Thomas Watson (1794-1884) and Isabella (nee Richardson), Alexander was an engineering apprentice before moving to Edinburgh. He emigrated to Australia in 1851 where he undertook significant building contracts including banks, government buildings, and one of the first lighthouses on the Victorian coast. He accrued substantial capital and moved to New Zealand in 1864 where sizeable Auckland contracts undertaken included the Thames, Waitemata and Albert hotels; the Albert Brewery; and possibly the four-storey Auckland Timber Company Building (ATC). Watson was a founding shareholder and a director of the latter company and, after the formation of the Kauri Timber Company (KTC) in 1888, was a member of the local Board formed to assist the Melbourne-based directors. Watson personally gifted kauri timber to a value of £700 for fittings in the new United Presbyterian Church in Peebles, Scotland, in 1890.
Twentieth century and beyond:
The first tenant of the Jubilee Avenue villa was Auckland kauri gum merchant and manufacturers’ agent John Boyd Gilfillan (1858-1927). Gilfillan, a son of notable early Auckland businessman and politician John Anderson Gilfillan (1821-75), experienced financial difficulties during the late nineteenth-century depression. However his business established in 1888 and which represented firms including the English cornflour producers Brown and Polson, continued into the 1920s. The Jubilee Avenue address off Cheltenham Road and overlooking King Edward Parade, two streets known for their large and handsome residences, suited Gilfillan’s social standing as a member of Auckland’s mercantile community.
Gilfillan’s tenancy ended in circa 1905 and was followed by those of surveyor John William Davis (circa 1906-8); and James Duncan, Inspector in Charge of the Agricultural Department (circa 1910). By 1911 the residence was a boarding house whose lodgers included a sharebroker, a dentist, and a tea taster.
Following Watson’s death in 1911 and that of his wife Matilda (nee Dickey) a year later, the couple’s only child Alexander Richardson Dickey Watson (1878-1917) came into a considerable inheritance that included the Torpedo Bay subdivision and rental properties. A.R.D. Watson had business interests in Sydney where he lived the greater part of each year. Reputed to be an excellent mathematician, Watson was one of few qualified actuaries in New Zealand. He was a noted public benefactor both before and after his death, having given over the Watson family home on North Head to the Auckland Hospital Board for use as a convalescent home for soldiers wounded in the First World War (1914-18).
Following A.R.D. Watson’s premature death in 1917, half of his sizeable estate was shared among nine bodies, being orphanages and the Salvation Army (Auckland and Sydney), Dr Barnado’s Homes, the St John’s Ambulance Association (Auckland), the Sydney Picture Gallery, Auckland City Art Gallery, Auckland City Council and Devonport Borough Council. The latter bequest was to be used ‘in or towards extending or completing or permanently improving the esplanade along the beach or foreshore...’. The first section of the King Edward Parade had been built to commemorate the dual events of ‘Peace in South Africa’ following the South African - or Second Boer War; and the coronation of Edward VII. Subsequent improvements were to include a new bathing beach (1928), a focal point for a memorial unveiled in 1936 recognising Watson’s bequest which by that time had yielded £4,000 for seafront improvements. The Watson Memorial was one of several memorials erected along the esplanade in the early-to-mid-1900s that contributed to beautification of the seaside suburb.
A 1916 survey plan re-subdivided the unsold portion of the Torpedo Bay estate into 26 sites. Following the First World War (1914-18) senior public servant Thomas Weight (Registrar of Pensions) tenanted 17 Jubilee Avenue more latterly a lodging house favoured by minor public servants. Weight was succeeded in 1922 by a journalist. The house was sold in 1924 along with adjoining Lot 23.
New owners accountant Frank Snoad (d.1945) and his wife Lucy were the occupiers until completion of a new residence on the rear site in circa 1929. The property was then rented to groups of largely working-class tenants who seldom stayed long. Following the death in 1943 of tenant Steven Bryne, a shipping clerk, the rear rooms were occupied by Bryne’s widow and daughter for the following two decades.
Health inspector Percival Wallwork bought in 1951, regularising tenancies for his daughter Alice Hitchmough and her husband; and the Brynes. The tower - by this time containing a lavatory at ground floor level - was demolished, and (along with an enclosed part of the verandah) accommodated a bathroom. These facilities and kitchen in an adjoining room served the front tenancy. Alterations to better accommodate the rear tenancy may have included conversion of the original bathroom and part of the back hall into a bedroom, with the original pantry and scullery becoming a bathroom. The front fireplaces were redeveloped with modern tile surrounds. Joinery was removed, although four-panel doors, the hall dados, and board and batten ceilings survived. The residence reverted to a family home when the Hitchmoughs purchased in 1966.
The property changed hands in 1998. Skirtings and cornice mouldings were remade - patterned on original joinery which survived in at least one room; and the 1950s fire surrounds were removed. The mid twentieth-century bathroom, kitchen and an adjoining room became an open-plan kitchen, dining and living area. The original bathroom was reinstated. The original room of the domestic help became a second bathroom. Skylights were installed in the former kitchen and scullery / pantry area - used a sitting room since the 1960s.
The house at 17 Jubilee Avenue is located in Devonport, a maritime suburb of the north shore of Auckland. Devonport, noted for its well-preserved nineteenth- and early twentieth-century buildings, lies on the northern shoreline of the Waitemata Harbour, across from the inner eastern suburbs and the central business district (CBD) of Auckland. The house occupies a site in Jubilee Avenue, a no exit street overlooking King Edward Parade on the Torpedo Bay foreshore.
Properties located towards the southeast end of the street back onto North Head - Takapuna (Record No. 7005, Category 1 historic place), a former nineteenth- and twentieth-century military fortification alternatively known as Fort Cautley. A considerable distance to the northeast, adjoining Cheltenham Beach in the Vauxhall Road / Tamaki Naval Base vicinity is O Peretu (Record No. 7231, wahi tapu area) an area of ancient historic, cultural and spiritual significance - one of few remaining icons identified, of Ngati Paoa pre-fleet heritage and of a presumed extinct people Tini o Maruiwi. Along the Torpedo Bay foreshore of the inner harbour are a number of archaeological sites including nineteenth-century shipyards and a timber mill. Some 500 metres to the west of the Jubilee Avenue property, is Holy Trinity Church (Anglican) (Record No. 504, Category 2 historic place) constructed in 1881 in Church Street. On the esplanade at the south end of Church Street is the Watson Memorial (Record No. 4517, Category 2 historic place), constructed by Devonport Borough Council in 1936 in remembrance of A.R.D. Watson, a major public benefactor.
Approximately a kilometre to the west of Jubilee Avenue is Devonport’s main commercial thoroughfare, Victoria Road, its southern gateway marked by the Esplanade Hotel (Record No. 4481, Category 1 historic place). The hotel is one of a number of commercial buildings of late nineteenth-and early twentieth-century date in the main street. Also at the southern end of Victoria Road are a number of commemorative monuments including the First World War Memorial (Record No. 4515, Category 2 historic place); the Alison Clock (Record No. 4513, Category 2 historic place); and the Coronation Sea Wall (Record No. 4516, Category 2 historic place). Within wider Devonport are a number of nineteenth- and early twentieth-century residential buildings.
Several residences in east King Edward Parade and the western portion of Jubilee Avenue date from the late nineteenth and early twentieth century. Notable examples are two-storey houses at 5 Jubilee Avenue and 60 King Edward Parade; and the pair of elegant single-storey villas of virtually identical design at 15 and 17 Jubilee Avenue. These are believed to be four of a number of nineteenth- and early twentieth-century residential buildings identified in wider Devonport in 1974 for their architectural interest and as representative of the former Borough’s earlier character.
The site lies on sloping ground that descends southward towards Jubilee Avenue. The irregularly-shaped property is approximately rectangular in plan. A tall retaining wall of bricks laid with cement mortar extends along a substantial part of the rear boundary and is shown on the 1947 land survey creating the current site, but is absent from earlier survey plans (1919 and 1906). Within the northeast corner of the property is an outbuilding constructed in association with the original house.
The main residence lies extremely close to the rear boundary, and is separated from the retaining wall by a narrow concrete path. The striking visual character of the house as viewed from the street is enhanced by its location within the elevated, rear portion of the site and is reinforced by lawns and the straight path that commences mid-way along the front boundary. The centrally-located front door sheltered by the verandah is accessed via a handsome set of plastered steps. A surviving part of the original design, the steps reinforce the formality of the house which owes more to the classical tradition than many late-Victorian villas. A minor path approximately parallel to the west boundary connects to the west end of the front verandah and appears to be a twentieth-century introduction. A pair of concrete strips adjoining the east boundary provides vehicle access to an informal parking space near or within the open south end of the outbuilding.
The externally well-preserved residence retains its original footprint. The building has a hipped roof and a prominent return verandah along three sides which is supported by posts - largely in pairs. The centrally located front entrance with narrow side-lights is flanked by a symmetrical pair of factory bay windows. These elements and a small wing off the east side towards the rear of the building loosely reference colonial Georgian and later Regency influences of the 1860s which enjoyed a revival towards the end of the nineteenth century. Reflecting the elevated seaside location originally enjoying views of the harbour and North Head, the design incorporates airy verandahs on the east, south and west elevations.
The house is of timber construction and retains its original, almost L-shaped footprint. Three brick chimney stacks are located on the hipped slate roof of centre gutter design. The two front chimneys have pronounced string courses and chamfering and are topped by clay chimney pots, a surviving original feature. The rear chimney serves a modern wood burner that occupies the fireplace of the sitting room (original kitchen). The verandahs are roofed with corrugated metal. The externally well-preserved building is clad with horizontal, rusticated weatherboards.
The single-storey structure is believed to stand on brick piles and low foundation walls. The verandah no longer has its timber balustrade and the upper portions of the posts show few indications of the original fretwork. The façade has a pair of factory bay windows that contain sash windows and which incorporate decorative timber brackets and applied columns with rudimentary capitals. A third bay window of identical design is located on the east (side) elevation, sheltered by the verandah return. The south-facing front door has narrow side lights and a rectangular fanlight. An external door in the south (front) elevation of the former kitchen wing on the east side of the house opens into a library / guest room.
A small addition on the west elevation occupying the location of the former viewing tower does not disturb the building’s overall original form. French doors, bi-fold window openings, a small verandah addition towards the rear (west elevation) are recent alterations and do not detract from the visual appearance of the house as viewed from Jubilee Avenue.
Internally, the residence retains the L-shaped layout. A generously-sized central hall (orientated southwest-northeast) extends from the front to the back door. Towards the rear a side hall branches off to the east. The front portion of the house accommodates three bedrooms and a living room; while the rear portion contains an open-plan kitchen, dining and living area; a library / guest room; and two bathrooms.
The central hall and passage retain timber-panelled dados (the dado-rails have been replaced). The hall arch has been reinstated, based on the design of the arch in an adjoining residence. The upper right fanlight on the front door case is hinged for ventilation. The glass in the front door, the associated fan and side lights; and that of the back door and fanlight, dates from the 1950s. The original board and batten timber ceilings, ceiling roses, and four-panel doors survive throughout the house. Many of the cornice mouldings, architraves and skirting boards have been reproduced and reinstated by the current owners, using surviving joinery as a pattern.
The four rooms opening off the front hall retain their overall original form -although French doors connecting the middle bedroom and the west verandah are a more recent introduction. Fire places have been removed from the four front rooms, but the chimneybreasts and original hearths remain. The formal sitting room (original dining room) in which a fireplace has recently been reinstated is lit by the east-facing bay window, but no connects into the rear passage adjoining the original kitchen. The open plan kitchen, dining and family room occupies the northwest portion of the house, replacing the 1950s bathroom, kitchen and another room - an alteration that necessitated the removal of a partition wall. A further sash window has been introduced into the north elevation; and French doors and bi-fold windows within the north end of the west elevation.
The original bathroom and service area of the house is little altered, although the use of some rooms has changed. The original bathroom; an adjoining second bathroom (originally room for the domestic help); and a library / sitting room (original kitchen, pantry and scullery) have vertical timber linings of wide, dressed kauri boards. Skylights have been introduced into the north side of the library / sitting room roof. Two narrow windows - which originally lit a scullery and a pantry - rooms incorporated into the former kitchen in the 1950s - have recently been revealed following the removal of modern wall linings. A brick-lined alcove originally occupied by the kitchen stove now houses a wood burner. The fire surround with its timber mantel is an original surviving feature.
The outbuilding erected in association with the house circa 1897-9 has a gable roof sheathed in corrugated metal. It has the external appearance of a timber-framed, weatherboard structure; and may have an earth floor.
The east wall is brick and incorporates the upper portion of a chimney that originally would have served a copper as part of a former a washhouse. The west elevation is clad with horizontal, rusticated weatherboards and has two doors and a small-paned sash window. A substantial portion of the north wall is now open. A large opening in the south elevation reflects modification of the structure at an unknown date for possible use as a garage.
An internal partition wall that would originally have divided the interior into two or three spaces - a lavatory (south end); and a washhouse and wood shed - has been removed. The space above the beams is largely open up to the roof.
1897 - 1899
Construction of villa with tower, and outbuilding
Tower converted to bathroom
Demolished - Other
Formalising two flats including conversion of a bedroom to kitchen; possible conversion of pantry / scullery to bathroom; modernisation of fireplaces and joinery including skirting
Removal of verandah balustrades
Reconversion to single dwelling; original kitchen / pantry / scullery converted to sitting room
Bathroom removed from west verandah and incorporated with 1950s kitchen into open plan kitchen / dining / living area involving introduction of further external openings
West verandah extended north over concrete deck
Rear room converted to second bathroom; installation of skylights in former kitchen area
Conversion of outbuilding to garage?
House: Brick foundations; timber frame and cladding; slate roof
Outbuilding: Brick foundations (?) and east wall; timber frame and cladding (north, west and south walls); corrugated metal roof
28th March 2012
Report Written By
Cyclopedia of New Zealand, 1902
Cyclopedia Company, Industrial, descriptive, historical, biographical facts, figures, illustrations, Wellington, N.Z, 1897-1908, Vol.2, Christchurch, 1902
Sydney Musgrove (ed), The Hundred of Devonport: A Centennial History, Devonport, 1986.
Jeremy Salmond, Old New Zealand Houses 1800-1940, Auckland, 1986, Reed Methuen
Young, Amanda, ‘Early Domestic Buildings in Devonport’, Research report MA in Anthropology, University of Auckland,  (copy held by NZHPT Auckland)
Salmond Architects 1989
Salmond Architects, ‘Devonport Historic Register’, Auckland, 1989
Verran, David, The North Shore: An Illustrated History, Auckland, 2010
A fully referenced report is available from the Northern Region office of NZHPT.
Please note that entry on the New Zealand Heritage List/Rarangi Korero identifies only the heritage values of the property concerned, and should not be construed as advice on the state of the property, or as a comment of its soundness or safety, including in regard to earthquake risk, safety in the event of fire, or insanitary conditions.