HomeMy WebLinkAbout04-08-19 Public Comment - L. Kirk (with Save Bozeman) - NCOD ReviewFrom:lisakirk@enviromininc.com
To:Agenda; info@savebozeman.org; BPAGmembers@googlegroups.com
Subject:NCOD Review
Date:Monday, April 08, 2019 12:57:34 PM
Attachments:8 April 2019 Save Bozeman.docx
524 Professional Drive
Bozeman MT 59718
406-581-8261
8 April 2019
Bozeman City Commission
Bozeman Department of Community Development
City of Bozeman
121 N. Rouse Street
Bozeman MT 59715
Public Comment: NCOD and Historic Preservation Review and Recommendations
Honorable Commissioners and City Staff,
Save Bozeman very much appreciates City Commission support of the NCOD review. BendonAdams
has done an excellent job of summarizing the feedback provided on multiple occasions by Bozeman
citizens, who strongly support the protection of our inlying and historic downtown neighborhoods.
Together with many in the community, we support retention of our NCOD, creation of guidelines for
preservation of neighborhood character and historic resources, and efforts to better define and
strengthen historic preservation overall. We strongly support the completion of an architectural survey
of historical resources as a basis for any adjustment of the NCOD boundaries.
Of particular merit are the recommendations to improve zoning and reduce conflict along boundaries,
or zone edge transitions, between the B3 and adjacent historic districts. As you may recall, conflicts
created by the 2015 Subchapter 4B language have generated much public concern. We commend
BendonAdams for their insightful analysis of this increasingly significant problem in downtown
Bozeman. We especially appreciate their recommendation to adjust the B-3 boundary near historic
districts to encourage better transitions, using streets as boundaries. This will reduce the potential for
highrise infill construction to loom over historic neighborhoods, thereby reducing the quality and value
of adjacent historic structures.
Save Bozeman asks that NCOD policy be revised to reduce, rather than exacerbate, the “looming”
conflict between current UDC guidance for zone edge transitions at the B3-historic interface and our
existing NCOD standards for certificates of appropriateness under the NCOD, as described at
38.340.050, which require conformance with the Secretary of Interior (SOI) Standards for Treatment of
Historic Properties. Our NCOD specifies that “Contemporary, non-period and innovative design of new
structures should not destroy significant historical, cultural or architectural structures or their
components and such design should be compatible with the foregoing elements of the structure and
surrounding structures.” We should strengthen these requirements to be consistent with SOI guidance
(p. 161, 162), which recommends “placing new construction far enough away from historic buildings…
[such that] it is minimally visible and will not negatively affect the buildings character, the site, or
setting, [and] ensuring that the new construction is secondary to the historic building and does not
detract from its significance.” Specifically, the guidelines also advise against “construction that results
in the diminution or loss of the historic character of the building, [including] constructing a new
building…on an adjacent site that is much larger than the historic building or…not compatible in scale or
design with the character of the historic building and the site.”
We ask that the City Commission ensure Bozeman’s compliance with the SOI guidelines as decisions are
made regarding changes to the NCOD. This is particularly important in light of the current Draft
Downtown Bozeman Improvement Plan recommendations for transition zones, which emphasize
economic opportunity over historic preservation and neighborhood community character (see figure
illustrating current code requirements on page 102 of the DBIP draft). Surely, such a transition zone is
inconsistent with the SOI guidance and has potential to promote future conflict along the B3-residential
interface.
Sincerely,
Lisa Bithell Kirk, Ph.D., P.Geo.
Director, Save Bozeman
524 Professional Drive
Bozeman MT 59718
Lab +1-406-581-8261
Cell +1-406-224-5154
www.enviromininc.com