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HomeMy WebLinkAbout06-07-24 Public Comment - A. Sweeney - Attn City Commissioners, regarding the budgetFrom:Alison Sweeney To:Bozeman Public Comment Subject:[EXTERNAL]Attn City Commissioners, regarding the budget Date:Friday, June 7, 2024 11:27:39 AM Attachments:BBC_Neighborhood_Friendly_UDC_Final_v2_Reduced.pdf Condon Poster Sheet1.pdf CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good morning Mayor, Deputy Mayor, and Commissioners, On behalf of the Better Bozeman Coalition I want to thank all of you for being willing to keepan open dialogue regarding our recommendations for a neighborhood friendly unified development code. I'm attaching our group's report (compiled through hundreds of hours of volunteer time) withresearch based solutions we'd like to see the city implement as part of a UDC rewrite so that it may be part of the public record. I'm sending this to you now so that you may examine the recommendations in the chapter ondemolition and Historic Preservation in Bozeman ahead of your work on the 2 year budget. We ask that you fully resource (allocate money) Historic Preservation in Bozeman, includingthe following: Fund a new historic properties survey, Implement the landmark program, Implement the heritage tree program, Consider promoting our Historic Preservation Officer to full time. We appreciate Commissioner Madgic and Deputy Mayor Morrison meeting with us to begindiscussing the report. And we look forward to scheduling conversations with the rest of you as well. Also, please attend an upcoming presentation, Q&A, and book signing with ProfessorPatrick Condon on June 19th. 4:30pm at the Bozeman Senior Center. We are interested in continuing an informed conversation on how we manage growth in Bozeman. Werecognize the state government has taken away a lot of tools, but we still have choices going forward. I'll be sending this invitation to several City Staff Departments and Advisory Boardsas well. I know your citizens would feel acknowledged by your attendance. It will need to be properly noticed of course. Thank you very much, Alison B. SweeneyBernadette's Handmade Jewelry Bozeman MT406-404-5740 alison-bernadettes.com A Neighborhood Friendly Unified Development Code Recommendations Compiled by The Better Bozeman Coalition May 31, 2024 2 Background and Intent After the City released its first draft of the revised Unified Development Code (UDC) in the fall of 2023 using the services of Austin Texas based consultants Code Studio, residents from across Bozeman gathered to voice their opposition through many hours of oral public comment in front of the Community Development Advisory Board. This outcry was coupled with hundreds of written public comments against the draft submitted to the City online. The City wisely paused the update until the New Year. This pause created time for the City and groups such as the Better Bozeman Coalition to come to a better understanding of the issues related to the proposed zoning changes and how they would impact the future of Bozeman. The challenge is clear: How can we best meet the growth needs of Bozeman with affordable and diverse housing options while at the same time providing solutions that are equitable to both newcomers as well as the current residents who have made Bozeman the desirable and economically successful city that it is. In our research, we have found that there is a pervasive narrative across the state and the country, that the best way to address the affordable housing shortage is to change zoning and building codes to allow for the redevelopment of existing neighborhoods in order to spur the creation of what pro-build advocates are calling “Missing Middle Housing”. “Missing Middle Housing “is a range of house-scale buildings with multiple units—compatible in scale and form with detached single-family homes—located in a walkable neighborhood.” - https://missingmiddlehousing.com The Better Bozeman Coalition does not dispute that racism played a significant role in the proliferation of single-family zoning, nor the fact that historically, the creation of suburbs was in part subsidized “white flight” from city centers and included the targeted construction of freeways through black and working-class neighborhoods. Remarkably, the current upzoning movement playing out across the country is a continuation of these same policies. The current movement gives developers and real estate interests access to valuable land currently occupied by economically diverse, working-class populations so that the land can be put to some other “highest and best use”. This redevelopment leads to the displacement of vulnerable populations and gentrification that is exclusionary in its very nature due to the high cost of the redeveloped properties. Moreover, our research has revealed the reality that increasing density alone does not produce affordability, but that there are other policies that do, which we recommend the City of Bozeman adopt. Based on the expert observations of long-serving urban planners and peer-reviewed studies, upzoning is actually counterproductive to the pursuit of affordable housing creation and the goal of maintaining diverse neighborhoods. In addition, our research and recommendations in this report cover zone edge transitions, increased height allowances, solar access, floor area ratio regulations, demolition, historic preservation, deconstruction, affordable housing and the location of fraternities and sororities. 3 The creators of this document respectfully submit the recommendations contained herin to the City of Bozeman with the intent that city staff, consultants, and elected officials will use it as a resource when making changes to the first draft of the UDC update. The suggestions we make in this document are researched and designed to preserve the character of our existing neighborhoods, protect existing affordable housing, set the stage for future affordable housing creation, enable us to meet our climate goals, and limit the damage to Bozeman’s urban forest. This document is not intended to take the place of renewed public engagement surrounding the UDC update that includes Bozeman homeowners and renters, stakeholders that were not sufficiently consulted or involved in the UDC rewrite process for the creation of the first draft. The Better Bozeman Coalition urges the City to come up with a re-engagement plan that includes direct mailers to residents and property owners whose zoning and building codes will be changed by the UDC update. We believe that the engagement survey completed early this year preferentially reached computer savvy residents who were already engaged with the UDC review process and left out most other residents of Bozeman. These mailers should include clear, understandable language about zoning and code changes and a schedule of events where residents and property owners can participate in shaping the next UDC draft. We believe that Bozeman is a unique place in the Greater Yellowstone Ecosystem with a charm and character embodied in its built environment which is as important to protect as the natural environmental amenities that surround it. Our waterways, mountains, wildlife, and native plants provide outdoor recreation opportunities that everyone cherishes. These natural amenities are also what make it possible to live here through the ecosystem services they provide. Additionally, the character of our existing neighborhoods, business districts, urban trails, wetlands, and forest resources provide a quality of life that everyone who chooses to live here also cherishes. 4 Acknowledgements These individuals contributed to the content of this document on a volunteer basis out of a love-for, and pride-in our city, as well as a sense of civic duty. Better outcomes are realized when residents are involved in shaping the way we grow. Lead Author Alison Sweeney Contributing Authors Kathy Powell Mary Lou Osman Michelle Osman Ken Silvestri Brian Close Ron Brey Lorre Jay Larry Johnson Rick Kerin Susie Drukman Tim Marcinko Robert Rydel Brandon Spitzer Dan Carty We thank additional contributors who wish to remain anonymous 5 Table of Contents Background and Intent ................................................................................................................. 2 Acknowledgements ...................................................................................................................... 4 1. The Truth About Density and Affordability ................................................................................... 6 2. The Trouble With Upzoning ...................................................................................................... 9 3. Zone Edge Transitions .............................................................................................................. 13 4. Increased Height Allowances .................................................................................................... 19 5. Solar Access ............................................................................................................................ 28 6. Floor Area Ratio (FAR) regulations ........................................................................................... 30 7. Demolition and Historic Preservation ....................................................................................... 36 8. Deconstruction Ordinance ....................................................................................................... 42 9. Affordable Housing ................................................................................................................ 43 10. Locating Fraternities and Sororities ........................................................................................ 48 11. Conclusion ............................................................................................................................ 49 6 1. The Truth About Density and Affordability Density on its own does not produce affordability in the housing market; either for sale or for rent. Density can allow for more people to live in walkable neighborhoods, helping the City achieve climate goals laid out in the 2020 Bozeman Climate Plan. However, if the additional density is to be reached through redevelopment of existing neighborhoods, on already expensive urban land, affordability must be sacrificed. The high cost of land, labor, and lumber precludes an affordable outcome from redevelopment. Additionally, the redevelopment of existing housing poses the threat of a net-loss of affordable housing. By tearing down an existing affordable home or multifamily dwelling to replace it with more units, we gain density, but end up with fewer units of housing financially accessible to our local workforce. Bozeman is in a national, perhaps even a global real estate market. As long as there is a demand for high end housing in Bozeman that is what will be built. Even though there is also a demand for housing that is financially accessible to our full time residents who work here, the free market will give us development that is financially out of reach for those we need to house here for the city to function. Developers are allowed to build what will bring them the most profit. High-end housing will drive up prices, making the production of affordable housing even more difficult. In his February 2023 article in The Tyee, Patrick Condon, Professor at the University of British Columbia, Master of Urban Design, says the following: “My preferred approach is this: Don’t just “up-zone” for new density hoping that new supply will lead to affordability (it won’t), but insist that up-zoning for new density be contingent on affordability… Any social benefit demand applied by the city, in this case adding less expensive housing, will affect the project “proforma” and put downward pressure on the price developers can pay for land… Is this practical? Yes. We are already doing this. The Downtown-Eastside/Oppenheimer plan has proven that you can zone for affordability, in this case mandating it over 50 per cent of units, and still have projects get built.” Since the state legislature bans the widely used tool of inclusionary zoning, Bozeman will need to investigate alternatives such as the affordable housing overlay zoning described in professor Condon’s recent book Sick City. It is being used successfully in Cambridge Massachusetts now. The pursuit of density through redevelopment also puts our urban forests at risk. With no protections in city code to ensure that established trees are allowed to age in place, we will lose existing trees to new construction. It isn’t necessary. With an urban tree protection ordinance the City can adopt code to regulate tree removal on public and private property. Our older, more established trees have a built- in resilience that new plantings do not. With our changing climate a young tree has less chance of reaching maturity than an established tree has of surviving unpredictable weather patterns. (See for example, “The Importance of Old Trees”, University of Michigan Institute for Global Change Biology) Furthermore, dense urban environments are the most stressful environments for trees to survive in. By reducing open space that exists in our established neighborhoods we increase the stress even on 7 established members of our urban forest ecosystem. Replacing trees with buildings will increase the urban heat island effect, increasing the use of air conditioning, making our climate goals that much more difficult to attain. Urban air quality will suffer, water quality will suffer, and the health impacts on our community will be negative. The removal of trees will happen gradually through redevelopment, so the effects will be cumulative rather than immediate, making it harder to recognize and prevent. Recommendations • The BBC recommends that the City of Bozeman adopt zoning and building codes to dis- incentivize tear down and redevelopment of existing neighborhoods, while allowing for sensitive infill that requires affordability in at least some of the units. Overlay zoning tools are a legal possibility to achieving this end. Floor Area Ratio (FAR) and demolition regulations are other options discussed in a later section of this document. • Work with individual Neighborhood Associations and HOA’s to develop zoning that works with the existing environment, housing, and residents. Adopt a policy of withintrification, where the current residents instead of outside developers drive the changes. How an existing neighborhood adds density without displacement will look different in different neighborhoods. • Allow increased density and mixed use in new greenfield development. As new land is annexed into the city limits, allow for smaller lot sizes, better walkability in design, and more multi-family construction in mixed use developments that allow for neighborhood scale commercial in walkable proximity to residential dwellings. The draft UDC achieves this. • Develop an urban tree protection ordinance in partnership with local groups like the Bozeman Tree Coalition, and professional ecologists, so that new housing and trees can coexist. This is possible if the City Commission adopts findings according to the 2023 Montana Code Annotated 76-3-511 that the health of our urban forest is necessary to maintain public health. • Adopt an affordable housing preservation policy as prioritized by the City Commission at the January 26th 2024 priority setting work session. Incorporate tactics described in the December 2023 American Planning Associations publication on preserving Naturally Occurring Affordable Housing, or NOAH. 8 Redevelopment at the corner of 8th and Alderson resulted in 5 units replacing an existing single-family home as well as most of the trees that were on the property. The real estate listing for the new units range in price from $900,000 to $1.4 million. We’ve gained units, but lost affordability. 9 2. The Trouble With Upzoning Upzoning is when the development potential on a piece of urban land is increased. Upzoning can be in the form of increased height allowances, decreased minimum lot sizes, reduced setbacks, removal of Floor Area Ratio (FAR) regulations, and/or an increase in the number of separate dwelling units allowed on a parcel (increasing density). The following image, used by Professor Patrick Condon, demonstrates the affect upzoning has on the price of urban land. At a teleconference in February 2021 Professor Condon shares the observed reality of upzoning to increase housing supply in Vancouver. “We have incrementally quadrupled the density of Vancouver, but we haven’t seen any decrease in per square foot costs. That evidence is indisputable. We can conclude there is a problem beyond restrictive zoning. … No amount of opening zoning or allowing for development will cause prices to go down. We’ve seen no evidence of that at all.” The value of urban land is determined by the demand for it, and the development potential awarded to it through zoning and building codes. If development potential is increased in high demand areas through opening up zoning constraints, the price of that land will increase before any of the newly allowed density can be built and occupied. Because of this, upzoning cannot result in affordable housing creation in a high demand real estate market. 10 In their 2019 analysis titled, “Housing, urban growth and inequalities: The limits to deregulation and upzoning in reducing economic and spatial inequality,” Andrés Rodríguez-Pose of the London School of Economics (LSE) and Michael Storper, make the following findings. “Upzoning is far from the progressive policy tool it has been sold to be. It mainly leads to building high-end housing in desirable locations.” Richard Florida in his May 2019 article for Bloomberg, Building More is no Match for Inequality, states the following. “And upzoning ends up fueling, not relieving, economic and spatial inequality.” Many cities use upzoning as a way to target the redevelopment of a neighborhood that isn’t producing sufficient tax revenue. Raising the tax-assessed value of urban land puts more money in city coffers to provide city services. The problem is that this redevelopment almost always results in displacement through gentrification. At the BBC we accept the following definition for gentrification from the Oxford Languages Dictionary: “The process whereby the character of a poor urban area is changed by wealthier people moving in, improving housing, and attracting new businesses, typically displacing current inhabitants in the process.” Above: a parcel containing an existing affordable home on the left (rented when purchased by a developer) is redeveloped to take advantage of additional density allowed by zoning, resulting in the displacement of the renter, the removal of multiple mature trees, and a change in neighborhood character pictured on the right. The new housing is unattainable to the same demographic of the displaced renter. Gentrification. Land Use Policy, in their April 2021 edition, published a report by Jenna Davis, titled, How do Upzonings Impact Neighborhood Demographic Change? Examining the link between land use policy and gentrification in New York City. This report gives us statistical data that proves upzoning has led to gentrification and displacement. 11 “…this paper examines upzoning activity in New York City as a case study into how upzonings interact with neighborhood change, using the non-Hispanic white population as a proxy for gentrification… this paper finds that upzonings are positively and significantly associated with the odds of a neighborhood becoming whiter.” Recommendations • The BBC recommends that rather than upzoning, the city should examine removing barriers in the building code to subdividing existing structures into multiple units as a way to increase density without redevelopment. This could include waving impact fees and/or grandfathering in noncompliant duplexes. Allow a density bonus tied to subdividing an existing structure (for example, for structures built before the year 2000) rather than demolishing and rebuilding. This should be coupled with minimum Floor Area Ratios so that new units give us dignified housing. • Create an Additional Dwelling Unit (ADU) incentive package that reduces the cost to produce granny flats. This needs to be tied to a short-term rental ban. If the city is giving financial incentives, the new unit should not be built as a speculative investment, but as housing. • Streamline the Planned Development Zone (PDZ) process in order to facilitate increased density tied to affordability in a neighborhood sensitive context. This aligns with a suggestion made at the City Commission’s priority setting meeting in January of 2024. A young couple bought the single-family home pictured above and during a remodel added a basement apartment to help pay their mortgage. The BBC recommends the City examine barriers in code to doing more of this. This can benefit the elderly looking for a live-in caretaker, or adult children who want to move home, but can’t find a place to rent that they can afford. It will also allow landlords to divide existing properties to increase the number of rental units on the market. 12 The small ADU shown in the photo on the left, added above an existing garage adds density in a neighborhood sensitive way. 13 3. Zone Edge Transitions Since upzoning and redevelopment cannot bring affordable housing to Bozeman, the BBC suggests that stronger zone edge transition (ZET) regulations be adopted in order to minimize the impacts of new development on existing neighborhoods. This will make for better design in new neighborhoods as well. The City’s current ZET’s are inadequate to protect existing neighborhoods from the impacts of new development. • The current ZET’s compromise the location of existing National Historic Register listed buildings and existing Historic Districts. • They eliminate the potential for future passive solar design or active solar energy generation. • They put current installed solar energy generation systems at risk due to shading. • No transition measures need be taken if new development is located across even a narrow neighborhood street. This leads to new construction overwhelming existing residential neighborhoods leading to a flurry of sell offs and displacement of current residents. • No transition is currently required between R-4 and any lower density residential district. R-4 has a current height allowance of 40 to 50 ft (depending on roof pitch). • Current ZET code doesn’t require sufficient building design features that protect the privacy of existing residents. Following is a diagram showing some of the current Zone Edge Transition regulations in Bozeman. The image above shows a 3 story existing home next to a transition, however many existing homes are only one story, making the transition even more inadequate. 14 The proposed zone edge transitions are even worse. In the first draft of the UDC rewrite, no transition measures are required when a zone changes across even a narrow neighborhood street. With the increased building height allowances in the proposed code, the problems this is already creating will be exacerbated. We are not learning from our mistakes. Growth Policy Reference page 25: R 1.1 Be reflective: use past experience to inform future decisions. The new draft includes no protections proposed for active solar energy generation systems. The ability to redevelop existing buildings to use passive solar design is still ignored. With the increased building heights proposed in the new code even more properties surrounding new development will be negatively impacted. Studies show an increased wintertime heat load on buildings permanently shaded, and some residents are already experiencing shading to their property sufficient to prevent their producing home grown food. The lack of ZET’s in the proposed UDC are actually setting us back in terms of achieving our climate goals. In a December 2021 publication of Building and Environment, researchers presented in their article, Evaluating the Impact of Shading from Surrounding Buildings on Heating/Cooling Energy Demands of Different Community Forms, the following: “Additionally, climate is a major factor that affects shading, apart from the index parameters and building layouts. Anna P [12] used EnergyPlus to study the degree of shading in two cities with different climate and realistic single-family residential building. The results showed that the energy demand decreases by 42% in summer in Miami and increases 22% in winter in Minneapolis. Further research using a hypothetical nine-building block that contained a three-story commercial reference building [13] in eight cities in the U.S. indicated that the building's energy consumption can increase by 60.4% than that without shading.” Our growth policy does call for long-term community benefit from policies that prioritize sustainability. Growth Policy Reference page 26: R 2.9 Long- Term and Lasting Impact: Create long-term gains to the community with solutions that are replicable and sustainable, creating benefit for present and future generations. Growth Policy Reference page 38: EPO-3.9 Integrate climate change considerations into development standards 15 Building design regulations in the proposed UDC’s zone edge transitions are not adequate to protect the privacy of existing residential neighbors who find themselves adjacent to taller, denser buildings resulting in a drastic reduction in quality of life in established neighborhoods. Buildings that step back are much more interesting architecturally. If solid-wall balcony enclosures are required, they provide privacy to both new and existing residents while enjoying their outdoor open space. If a landscape barrier is going to be used or required as a privacy measure in ZET’s they need to specify evergreen trees. As you can see in this image to the right, deciduous trees provide privacy for only a small portion of the year in our climate. Require the use of letterbox windows (on the left in the image above) on facades that directly overlook adjacent residential neighborhoods and those across an alleyway. More conventional windows (on the right in the image above) are better suited to facades in new construction that are across a street from established neighborhoods. 16 Despite a height allowance of 65 ft in the new R-B zone, (95ft if a project is using the deep incentives awarded in chapter 38.380) planners did not see fit to require any transition measures between R-B, and R-A, even between adjacent lots! Here’s what that looks like in practice: The entire Historic Preservation Advisory Board voted unanimously against the transition requirements in the new draft code during their September 2023 meeting. The NCOD Policy Direction report issued in 2019 by Bendon Adams and Orion Planning & Design suggested, “Incorporate additional site design standards within the existing zone edge transition requirements” on page 49.
 Another idea was to “Create a B-3 transitional zone (B-3T) for areas located beyond the core downtown district.
This could be an overlay district or separate zone district (B-3T) that would apply to properties located between Babcock and the existing B-3 boundary to the south, and Mendenhall and the existing B-3 boundary to the north. The intent of the existing B-3 zone would remain in place, with massing, scale, site design and other dimensional requirements adjusted to better align with a transitioning commercial, mixed use to residential, mixed-use neighborhood. Neighborhood sensitive zone edge transitions are actually the key to successfully increasing density in the urban environment. They are the primary method of reducing the impacts of new development on existing neighborhoods. The BBC wants Bozeman to do density well. Growth policy reference page 34: DCD-2.9 Evaluate increasing the number of stories allowed in centers of employment and activity while also directing height transitions down to adjacent neighborhoods. Recommendations • Require zone edge transition (ZET) regulations to apply across neighborhood streets that measure 60 feet across (from curb to curb) or less. • Require solar access measures be taken to avoid new construction blocking existing or future active solar energy generation systems and the potential for future passive solar design in adjacent redevelopment projects. See a later chapter on Solar Access. 17 • Use step-backs above the 2nd story, not the 3rd when a transition occurs on a lot line or across an alley, rather than a street. • When a zone that includes no setbacks from the lot line (in other words allows 100% lot coverage with no set backs) borders an existing residential lot, require a step back in new construction after 1 story, and require that wall to be solid with no windows and a high fire rating. • Have elevations drawn illustrating real neighborhood homes adjacent to new construction, and across a 35-foot street from new construction, in order to fully understand what new proposed ZET’s will actually look like in practice. • Require building design features, such as what materials may be used, on the first 3 stories, when a ZET borders a designated historic district or historic property in order to maintain the integrity of location for historic resources. These features should apply across a narrow street as well as adjacent lots. • Require noise mitigation measures for mechanical systems equipment in new construction located adjacent to residential lots. • Require building design features that protect the privacy of existing adjacent neighborhood residents. 1. Evergreen landscape barrier requirements 2. Window sizing and placement on walls of new construction that face existing residential neighborhoods above the second floor 3. Require solid balcony walls or screening to protect both new and existing residents privacy in new construction above the second floor. 18 4. Allow fire lanes to be placed in the transition area to further minimize impacts on existing neighborhoods. Fire lanes act as a natural set back between zones. • Use the Municipal Resource Services Center manual titled Protecting Existing Neighborhoods from the Impacts of New Development, as a guide to create neighborhood friendly zone edge transition regulations. • Since the winter sun in Bozeman dips to only 22.5 degrees above the horizon, when a taller denser building is located to the south of an existing neighborhood, the angle determining the allowable building envelope for new construction may need to be even less than 45 degrees as measured from the base of an existing home. • Zones should be adjusted to transition across a street in the instance that denser, taller, development is allowed to the south of residential neighborhoods. 19 4. Increased Height Allowances Illustrations of the new zoning districts provided by Code Studio used an isometric perspective, which is deceptive in communicating the actual difference in mass and scale between two buildings. This makes it easier to underestimate the impact of new height allowances proposed in the first draft of the UDC rewrite. Bozeman’s residential neighborhoods are not built out to their current height allowances. Since the redevelopment of our existing neighborhoods cannot bring us affordable housing, the BBC questions the need to increase height allowances in all zones. When compared to many other cities, our existing height allowances are actually quite liberal. Portland only allows 30 ft. total building height in R zones. The intent of imposing height restrictions is to recognize the aesthetic value height has in creating neighborhood character. When housing blends well with surrounding other structures, regardless of their use, new infill can avoid obstructing important landmarks, and allow natural elements to be enjoyed by everyone; view sheds, airflow, sunlight etc. If significant density is added to Bozeman in the form of tall buildings, only those economically privileged enough will be able to enjoy those things that all Bozeman residents once had access to. Height restrictions also play a significant role in increasing or disciplining land value through awarded development potential. In a 2014 Strong Towns article titled, “A Case For Height Restrictions”, Charles Marohn makes this argument: “Today our cities are starved for growth. At the same time, there are scores of people wanting to do small projects – incremental development – that are stifled by the artificially high cost of land. How can I say “artificially”? You have a one-story strip mall, a vacant lot and a sixteen-story tower next to each other. What is the value of the vacant lot? Let’s say the local code allows that vacant lot to be developed as a one-story strip mall, but nothing higher. If the strip mall is worth $500,000, then the vacant lot is going to be somewhere around $75,000. Okay, but what if the development code allows that vacant lot to be developed as a sixteen-story tower? If the tower is worth $20,000,000, then that vacant lot is going to fetch a much higher price, maybe as much $2.5 million.” The numbers might be a little different in Bozeman, but the principal holds true. In order to portray how the additional height allowances in the proposed UDC will actually be perceived from ground level by residents, the BBC has had architectural massings done by a professional. These follow for residential zones R-A, R-B, R-C, commercial zones B-3 and B-2M, and mixed-use zone NEHMU. Each image shows the developable height allowed under the new UDC next to an existing home in each zone. 20 15.0' Max 1 Additional Story @15' for Affordable Housing IncentivesUnknown How to Apply with 25ft Max Top Plate Height Requirement 45.0' Draft Unified Development Code Zone R-A - Proposed Maximum Allowable Building Height Comparison to Typical Home 420 North 10th Bozeman, Montana 0' 0"12"1"2" 15'30'60' Scale: 1" = 30' *Current Zone R-1* 5' Lot Line Setback Exhibit 1 5.0' Max Above Ground Current Code: 28' to 40' Max (Dependent on Roof Pitch) 15.0' 25.0' Max Top Plate 21 15.0' Max 2 Additional Stories @15' Each for AffordableHousing Incentives 90.0' 30.0' Draft Unified Development Code Zone R-B - Proposed Maximum Allowable Building Height Comparison to Typical Home 620 North Tracy Bozeman, Montana 0' 0"12"1"2" 15'30'60' Scale: 1" = 30' *Current Zone R-4* 5' Lot Line Setback Exhibit 2 5.0' Max Above Ground Current Code: 40' to 50' Max (Dependent on Roof Pitch) 22 15.0' Max 2 Additional Stories @15'Each for Affordable Housing Incentives 105.0' 30.0' Draft Unified Development Code Zone R-C - Proposed Maximum Allowable Building Height Comparison to Typical Home 427 North 6th Bozeman, Montana 0' 0"12"1"2" 15'30'60' Scale: 1" = 30' *Current Zone R-5* 5' Lot Line Setback Exhibit 3 5.0' Max Above Ground Current Code: 50' to 60' Max (Dependent on Roof Pitch) 23 15.0' Max Upper Story 18.0' MaxGround Story 2 Additional Stories @15' Each for AffordableHousing Incentives 108.0' 30.0' Draft Unified Development Code Zone NEHMU - Proposed Maximum Allowable Building Height Comparison to Typical Home 701 North Wallace Bozeman, Montana 0' 0"12"1"2" 15'30'60' Scale: 1" = 30' *Current Zone NEHMU* 5' Lot Line Setback (0' Mixed Use and Townhouses) Exhibit 4 5.0' Max Above Ground Current Code: 50' Max 24 15.0' Max Upper Story 18.0' MaxGround Story 4 Additional Stories @15'Each for Affordable Housing Incentives 153.0' 60.0' Draft Unified Development Code Zone B-2M - Proposed Maximum Allowable Building Height Comparison to Typical Home 610 West Lamme Bozeman, Montana 0' 0"12"1"2" 15'30'60' Scale: 1" = 30' *Current Zone B-2M* 0' Lot Line Setback (By Proposed Only) Exhibit 5 5.0' Max Above Ground Current Code: 5 Stories or 60' Max (Whichever is Less) 25 Draft Unified Development Code Zone B-3 - Proposed Maximum Allowable Building Height Comparison to Typical Home 24 West Lamme Bozeman, Montana 0' 0"12"1"2" 15'30'60' Scale: 1" = 30' *Current Zone B-3* 18.0' MaxGround Story 15.0' Max Upper Story 5.0' Max Above Ground 4 Additional Stories @15' Each for AffordableHousing Incentives 168.0' 60.0' Current Height Allowance 70' Max Outside of Core Area 55' Max Inside Core Area 0' Lot Line Setback (By Both Standards) Exhibit 6 26 With land prices already quite high in Bozeman, and additional development potential likely to increase that price even further, the BBC questions the wisdom of increasing height allowances when we have room to add density under the current height allowances. We have a lot of room to grow without putting unnecessary inflationary pressure on land value. Our existing height limits will allow for missing middle housing to be built. If we increase height allowances we will actually skip the generational phase of development known as the missing middle, instead incentivizing high-density luxury condos that dwarf neighborhoods. Growth Policy reference page 29: N-1.11 Enable a gradual and predictable increase in density in developed areas over time. Growth Policy reference page 30: N-3.8 Promote the development of "Missing Middle" housing (side by side or stacked duplex, triplex, live-work, cottage housing, group living, rowhouses/townhouses, etc.) as one of the most critical components of affordable housing. For context, here is a table of the different types of housing allowed under our current code For clarity, very little of Bozeman is actually zoned R-1. And in the areas that are zoned R-1, a variety of housing types are actually allowed. Many of the areas zoned R-2 and R-3 have single-family homes in them, giving the impression that single-family zoning has constrained development. In the central and historic neighborhoods, single-family homes predominate because there was a demand for it, even though the construction of what is now referred to as the “missing middle” was always allowed. 27 Recommendations • Leave existing height allowances in place to prevent raising the price of urban land even more. • Existing height allowances should also be left in place because even though they do present a risk to residential and commercial solar energy generation, increasing height allowances would put systems at an even higher risk of being shaded by new development. • Adjust zones to more accurately reflect what is already on the ground. For example the home in Exhibit 3 at 427 N. 6th Ave should not be in R-C. Adjusting zoning will prevent tear-down, and a loss of existing affordable housing (currently rented) by reducing the profit potential from redevelopment. • Introduce a wall plate height as suggested in the first draft of the UDC, but 25 feet is too generous. This will disrupt neighborhood character in many areas of the city, consider 15ft. • Adopt code that in some way relates height allowance in redevelopment projects to the existing neighborhood homes adjacent to the redeveloped property. This will promote sensitive infill with equitable access to natural amenities such as view sheds, airflow, and sunlight. • Increase allowed density in certain neighborhoods where appropriate (and in cooperation with neighborhoods) tied to an affordable housing overlay district in order to allow smaller local developers to build “missing middle housing.” This type of construction is more likely to employ local labor, rather than the imported labor of the large metropolitan out-of-state developers. It’s not that we can’t build the “missing middle” because of code; lots of diverse housing types are allowed in most zones in Bozeman (cottage housing is allowed everywhere!) but the artificially high price of land prevents them. As witnessed in Vancouver, affordable housing overlays can discipline land prices by affecting the pro-forma financial analysis of projects that are allowed to be built. The exact same premise is put forth in the Strong Towns article referenced on page 18. 28 5. Solar Access For years the City of Bozeman has been loosening regulations around installing solar energy generation on both residential and commercial property. It’s working! This has resulted in an incredible number of net-metered customers within the city limits. The BBC’s recent inquiry of NorthWestern Energy shows that there are 2217 grid-tied net-metering customers in Bozeman with an installed production capacity of almost 20 Megawatts! There are numerous other systems producing solar thermal energy, which usually offsets natural gas usage, which further reduces the carbon footprint of our buildings. Bozeman has an ambitious goal of using 100% clean electricity by 2030. That is only 6 years away. Residential and commercial solar electric generation on privately owned buildings is contributing significantly to this goal. While the draft UDC furthers the cause, making the installation of renewable energy generation even easier, it overlooks the need to now protect it. Much of this private investment is at risk because of increased redevelopment pressure in our community. The increased height allowances, and lack of zone edge transitions, in the proposed Unified Development Code rewrite puts these resources at such an increased risk of shading that it’s time to protect active solar energy generation, and the ability to redevelop existing parcels of land in the city using passive solar design. Growth Policy reference page 25: R-2.1 Co-Benefits: Provide solutions that address problems across multiple sectors, creating maximum benefit. A significant amount solar electricity generating capacity has been installed by private owners in Bozeman. Because it is tied to an existing electrical grid it now becomes a contributing public resource. Protecting it provides maximum benefit across both public and private sectors. Growth Policy reference page 26: R-2.7 Adaptive Capacity: Include flexible and adaptable measures that consider future unknowns of changing climate, economic, and social conditions. As global average temperatures rise, Bozeman will see an increase in electricity demand for air conditioning during the summer months. This will potentially be exacerbated by the increased heat island effect and degradation of our urban forest through increased densification. Therefore electricity generated at the time of this increased demand will be even more valuable than it is today. 29 Protecting installed solar energy generation will also give the local industry professionals who consult, install, and service these systems continued job security, contributing to a resilient local economy. Recommendations • Develop a complete solar access law for inclusion in the UDC update working with City Staff, the Sustainability Advisory Board, and partner groups in the community including industry professionals from Montana Renewable Energy Association (MREA), the Montana Environmental Information Center (MEIC), and MSU’s Sustainability department. 30 6. Floor Area Ratio (FAR) regulations Our current UDC contains Floor Area Ratio (FAR) regulations that determine the bulk of the building that can be constructed on a lot within the city limits. The current regulations are shown in the table below. In the bottom row of this table we see two numbers separated by a colon. The first number is the FAR, the second (always 1) represents the total lot size. So essentially this number is a fraction, or ratio. Most cities write FAR using just the first number. For example the allowed FAR in zone R-1 is 0.5. Multiply this number by the square footage of your lot and you get the allowed square footage for you home. Bozeman has average lot sizes of about 6,000 sq. ft. So your calculation would look like this: 0.5 x 6000 = 3000 sq. ft. You can build a 3000 square foot home on that lot. 31 Different people define a McMansion differently, but some cities are now using stricter FAR regulations to prevent the demolition of modest, older, more affordable homes by owners who like the location but not the home on the lot. More affordable homes are snapped up and redeveloped into ultra-modern luxury McMansions leading to the gentrification of once working class neighborhoods. Our current FAR regulations are not strict enough to prevent this from occurring, so what may have been a more affordable home for someone, is allowed to be redeveloped for a new more affluent homeowner. For example in the current zone R-2 the floor area ratio is 0.75. 0.75 x 6000 = 4500 sq. ft. That is a big home; some might say a McMansion. The FAR regulations in our current code are not tied to the number of dwelling units, so you can tear down a small home and build a McMansion, even in a zone that would let you build a duplex, multiple townhouses, rowhouses, or cottage housing. Large modern McMansion dwarfs an older home The first draft of the UDC rewrite contains no Floor Area Ratio (FAR) regulations whatsoever. Instead there is a 10,000 sq. ft. maximum building size. You are allowed to cover 40% of your lot. So in the new R-A zone someone could build a 3 story, 10,000 sq. ft. home. There is no guarantee that the new structure will contain multiple units. Some people say you could never build a house that big because of other constraints, like the 40% lot coverage. Let’s examine this for a minute. Most lots in Bozeman are around 6,000 sq. ft. but many are larger. A 7,000 or even 9,000 sq ft lot is not unheard of. 40% of 7000 is 2800 sq ft So that’s the allowed footprint of your house. You can build a basement, and 3 stories above ground. So that’s 4 floors at 2800 sq ft which easily accommodates a 10,000 sq ft building. Some cities are implementing strict FAR regulations with additional square footage allowed only if additional units are produced. This at least gives us density, though as we know from experience small does not necessarily 32 equal affordable in our current market when there are a handful of studio and one-bedroom apartments for sale at $600,000 to $700,000. Here’s an example of what Portland decided to do with its FAR regulations after successive previous code revisions led to increasingly larger building envelopes with no requirement for multiple units: 33 And this is the code that was implemented to address this problem: Portland Zoning Code Amendment 33.110.210 Floor Area Ratios “FAR limits are being added to the R7, R5 and R2.5 zones. Over the last few years, new houses in these zones have grown in size to the point where new development sometimes overwhelms existing houses on the block. With the potential for additional dwelling units (up to four units per lot in some cases), there could be pressure to continue to increase the size of buildings. FAR is an effective tool for regulating the overall bulk of a building while providing reasonable flexibility in site layout, housing style, and design. “Buildings with more floors will have smaller footprints, which increase outdoor area and yard space, but more floors can increase shadowing and reduce privacy on adjacent lots. Buildings that are single level can have larger footprints that reduce yard space, however this configuration can improve privacy for adjacent lots. “The proposed FARs were calculated with consideration of building coverage limits to encourage smaller building footprints and larger outdoor areas. The proposed FARs also encourage compatibility with adjacent existing houses. FAR limits are not proposed for the lowest density zones (RF, R20, R10), because these areas are characterized by larger and more variable lot sizes. Consequently, new development in these areas has not generally overwhelmed adjacent lots. In addition, the additional housing types allowed in R7-R2.5 will not be allowed in RF-R10, which lessens pressure for building 34 larger structures.” (See page 32 in the report, “Residential Infill Project, An Update to Portland’s Single-Family Zoning Rules.” The American Planning Association (APA) has a name for smaller, older, more affordable homes; NOAH or Naturally Occurring Affordable Housing. If we can prevent the loss of NOAH through strict floor area ratio regulations we will help maintain access to our central and historic neighborhoods for people who will be priced out through redevelopment. The following is from the APA’s December 2023 issue: “However, many other NOAH units are vulnerable to loss through redevelopment. Over the past decades, individuals and custom homebuilders have often purchased older single-family homes simply for the value of their lots and their desirable locations. The NOAH structure is then demolished and replaced with a much larger and more expensive home that is not affordable to existing residents of the neighborhood. In addition to individual home replacement, some larger housing builders have acquired multiple adjacent NOAH properties, demolished those homes, merged the lots, and constructed a larger number of attached townhomes, apartments, or condominiums on the combined properties.” This nearly perfectly describes what we’ve witnessed occurring in Bozeman for years. We will end up with a less economically and culturally diverse center of town. The small, relatively affordable house on the left was demolished and replaced with a high-end duplex A strict FAR regulation may have been able to preserve this NOAH on the left, while allowing the homeowner to build an addition to turn it into a duplex or add an ADU. Instead our current regulations allowed it to be redeveloped into high-end duplexes, where each unit sold for $1.8 million. This could be part of the City Commission’s commitment to create an affordable housing preservation plan. A priority set in January of 2024. 35 Recommendations • Adopt strict FAR regulations to prevent the redevelopment of NOAH into luxury homes. For example, a FAR of 0.4 could prevent the redevelopment of NOAH. • Award additional FAR tied only to additional units, as long as the original structure is maintained. If the original structure is demolished to make way for new multi-unit housing with greater FAR allowances, all of the new units must be deed restricted for affordability. This is discussed more in a later affordable housing overlay section. We know smaller is not necessarily more affordable, so in order to prevent speculative land redevelopment additional density through redevelopment would need to be tied to affordability. • Do not consolidate the current R-1 zone with other zones. Consolidation is unnecessary since R- 1 already allows a diversity of housing types. Portland and other cities still have several residential zones reserved for single-family homes. Moreover, only 41 % of Bozeman’s housing stock is single-family homes compared to 70% statewide, and 60% nationally. Bozeman is currently leading the state in a diversity of housing types. • In order to preserve NOAH, do not upzone current R-2 neighborhoods. Only award increased density in conjunction with an affordable housing overlay zone, described in more detail later in this report. 36 7. Demolition and Historic Preservation Many residents in Bozeman feel that the Neighborhood Conservation Overlay District (NCOD) is the reason we have such well-preserved historic character in our central neighborhoods, and that this is an asset to the community. This sentiment is well documented in the 2019 NCOD Policy Direction Report by Bendon Adams and Orion Planning & Design. Here are some quotes that came from the engagement with the community. “The NCOD preserves Bozeman’s sense of place and character so it doesn’t become “Everywhere, USA.”” “The NCOD and especially the historic neighborhoods need to be preserved and not overwhelmed by new, large scale, unattractive development.” “Revisions to the regulations may be helpful to address noncontributing buildings, however, the survey of historic resources within the City should be updated to ensure the continued preservation of historic resources that may not have been considered historic at the time of the previous survey.” Bozeman residents consider the preservation of older neighborhoods within the NCOD and our Historic Districts essential to the continued charm and economic success of our city. But Historic Preservation has taken on new meaning in the last decade or so, as it has been increasingly recognized as a way to preserve and lift up the stories of overlooked populations across this country including LGBTQ and BIPOC communities. The elevation and celebration of these histories, coupled with the dramatic increase in redevelopment and infill from unsympathetic developers have led to a general feeling that the NCOD isn’t protecting our neighborhoods and Historic Districts the way it was originally intended to. The true history of our town is only now beginning to be told, thanks to community organizations like The Extreme History Project. The City’s Belonging in Bozeman Plan, adopted in December 2023 records a history of Bozeman’s overlooked communities for the first time in official documents. The tangible reminders of this history include historic African American neighborhoods and a red-light district that would be jeopardized through the incentivized redevelopment promoted by the City’s first draft UDC update. Also at risk are the many post-war veteran, immigrant, and working-class neighborhoods that are eligible and worthy of protection through reinvigorated historic preservation policies. The Better Bozeman Coalition believes that it is irresponsible and risky to incentivize redevelopment of these neighborhoods before the Historic Preservation Program is reworked and strengthened including expanded surveying of our historic resources beyond the existing Neighborhood Conservation Overlay District (NCOD). Historic Preservation in Bozeman is poised to see a new injection of interest, and momentum since the city hired Community Planning Collaborative out of Jacksonville Florida to help rework the NCOD and guide us through the creation of a Local Landmark Program. The City Commission also set strengthening Historic Preservation as one of its priorities for the next two years. Additionally, we have a 37 progressive Historic Preservation Officer who wants to implement people centered Historic Preservation in addition to place centered Historic Preservation. People centered preservation includes overlooked communities and advocates for the preservation of the tangible links to their past in our city. The homes belonging to members of Bozeman’s historic African American community may not be the most incredible examples of certain schools of architecture. But they are important to preserve because once we lose them, we can never get them back, and it’s much easier to lose their stories if all the physical reminders of their trials and triumphs are removed. This is an example of vernacular architecture “having acquired significance” because of the people associated with it. The role of Historic Preservation Policy in any great city is to manage the changes occurring over time, not to prevent change. It’s not healthy to freeze things in time, but old buildings and neighborhoods give our community a soul, and maintain the proximity of the past. Acknowledging and preserving our past prepares and informs us going forward. Historic Preservation is also the most sustainable way to grow a city. Often building and neighborhood design was particularly well suited to its environment because people didn’t have access to cheap fossil fuel energy the way they do today. While insulation must be updated, solar orientation, the handling of snow load, and the placement of deciduous trees were fundamental considerations for building in an environmentally responsive context. Eves on homes were designed to allow sunlight into rooms in winter, while preventing it in summer, etc. In many cases old buildings are well adapted to their location. Adaptive reuse of historic structures also prevents tons of quality building materials from ending up in our landfills. Historic structures are our inheritance in terms of embodied energy, the energy consumed by all of the processes associated with the production of a building. We should not squander it. See the next section for a deconstruction ordinance to address this in situations where a historic structure really must come down. Reduce-Reuse-Recycle should apply to our buildings too. In many ways the mixed use zoning in the new draft UDC is a wonderful gift to Historic Preservation. Currently, if historic homes are to be adapted for a different use they need to be in a zone like B-2M, B-3, NEHMU, or R-5. The development potential in these zoning districts allows such a large building envelope that it puts the physical structures at risk because redevelopment would be so much more profitable. Our current code does not protect even nationally listed historic buildings from demolition. Bozeman’s Sweet Pea Study Club 38 Owning a home in the NCOD is not for everyone. It comes with a responsibility of custodianship. You are the owner of a historic resource, not just the land underneath it. In a way, the NCOD and underlying zoning function as covenants to regulate what an owner can and can’t do with a property. This agreement needs to be strengthened going forward to prevent the loss of tangible history. Strict FAR regulations will also help protect historic resources from demolition. The small home above on the left was originally owned by Oswald and Ada Smith. According to a 2016 survey, it was listed as eligible for the National Register of Historic Places. It’s one of 13 properties that were surveyed at the request of the Historic Preservation Advisory Board in order to create a National Historic District honoring our African American population in early Bozeman. Oswald Smith was a janitor for the Ellen Theater for over 40 years! He died in 1968. The Samuel Lewis house at 209 S. Tracy, shown on the left, is an example of a small historic home that could well be adapted to house offices or some other commercial use. Unfortunately, it is currently zoned B-3 and the profit potential from redevelopment in B-3 puts the structure itself at risk. In the first draft of the UDC rewrite, neighborhood scale business is allowed in lower density zones like R-A. This is a great way to reduce the incentive to tear down a historic structure, but instead adapt it for an appropriate neighborhood friendly commercial use. Samuel Lewis was a local African American barber and business owner and his half-sister, Edmonia Lewis, was a world-renowned sculptor. 39 Oswald and Ada Smith’s home (arguably an example of NOAH that we should be trying to protect) is an example of a loss that the NCOD was designed to protect against. The new building doesn’t compliment neighborhood character, because it doesn’t comply with the design guidelines for the NCOD, just one example being the suggested use of horizontal lap siding. This redevelopment also raises the price of the property, putting it out of reach of working class Bozeman residents, as well as raising the property taxes of everyone around it. Also notice the loss of so many mature trees through the redevelopment process. The deterioration of Historic Preservation in Bozeman can be traced back to ordinance 1927, adopted in May of 2016, which led to the following changes: • Removed the review of demolition applications within the NCOD from the purview of the Historic Preservation Advisory Board (HPAB) as well as other powers that this body previously used to enforce the NCOD guidelines. • Under ordinance 1927 the NCOD guidelines became voluntary rather than required. • The Historic Preservation officer became a member of staff of the City of Bozeman appointed by the City Commission, rather than being hired by and acting as staff to the HPAB. This change served to politicize the role. Ordinance 1920 adopted in January of 2017 further undercut Historic Preservation in Bozeman. For several years Bozeman didn’t even have a Historic Preservation Officer. During this time any priority to maintain neighborhood character was further sacrificed to new development in the downtown B-3 zone. Today we are living with a Historic Preservation Program that is struggling to be effective at saving even the historic resources within the NCOD. We do have strong codes to prevent the demolition of historically significant resources, but we need the will to enforce them. For example, the existing Bozeman Municipal Code (BMC) chapter 38.340.090 requires a Certificate of Appropriateness (COA) be issued in order to demolish a historic building. One of the criteria for obtaining a COA for demolition, is described in item C.2. of that section. The developer must prove the following: "38.340.090.C.2 Whether the structure has no viable economic life remaining. ‘No viable economic life remaining’ means the costs of repair and/or rehabilitation to bring the structure to a habitable condition as established by the applicable technical codes in article 10.02, exceed the costs of demolition and redevelopment to minimum standards with a building of the same type and scale." Furthermore, in order to establish this criteria, multiple bids must come to the same conclusion as described in (BMC) 38.220.090.A.1.j: “If demolition of a historic structure, as defined in article 7 of this chapter, is proposed a structural analysis and cost estimates indicating the costs of repair and/or rehabilitation to bring the structure to a habitable condition as established by the applicable technical codes in Article 10.02, versus the costs of demolition and redevelopment. Analysis must include cost estimates from more than one general contractor for the work. The cost comparison is between the cost to rehabilitate the structure to a condition which meets the building code standard for occupancy and demolition and construction of a new structure of the same type and scale to building code standards.” 40 This code has not been strictly applied to many of the demolitions within the NCOD in recent years. This erodes the public’s trust in our local government. Residents begin to believe that officials and staff are “in the pockets” of the developers who are profiting from their luxury developments in our historic neighborhoods. Residents can’t understand why historic homes and other beloved structures are allowed to be demolished if this is not the case. The Historic Preservation Advisory Board stopped the demolition of the Armory Building twice when they had judiciary powers, and we would not have the beautiful adaptive reuse building we do now if it weren’t for their actions. Bozeman’s current two-year stay of demolition is a mere annoyance for anyone intending to demolish historic properties within NCOD. Often, they simply wait the two years and then proceed with the demolition. Required maintenance is also being ignored as buildings are blatantly left to the destruction of the weather, prior to an application or re-application of a Certificate of Appropriateness for Demolition. Many cities deny demolition of historic structures outright. Some allow for the demolition of historic properties only in cases where a property owner establishes proof of economic hardship or the property poses a safety threat after a fire or other type of natural disaster. Many cities in Montana have Preservation Commissions, rather than advisory boards, and these bodies are empowered with the authority to deny demolition of historic buildings. In a February 22nd, 2024 edition of the Missoula Current, a City Preservation Commission’s denial of a demolition of a privately owned building on the site of Fort Missoula is described. “In a process that played out akin to a trial, the majority of council agreed that the developer, Tres Birds, failed to demonstrate that its application didn't receive a fair review and that the Historic Preservation Commission (HPC) acted in bias when denying the permit. The vote to uphold the HPC's denial of the permit passed on a 7-4 vote.“I do not feel that the (developer) has proven error on behalf of the HPC,” said council member Mike Nugent.” Missoula City Council deferred to the Historic Preservation Commission on a demolition ruling. Recommendations • Enact a moratorium on demolitions until a new historic properties inventory survey can be completed that includes surveys of post war, mid-century neighborhoods outside the NCOD. If this is not possible, direct staff to strictly enforce the existing code around determining “viable economic life left” in a structure. • Allocate proper resources to a Historic Preservation Program including the updated survey and promoting our Historic Preservation Officer to a full time position with full time pay. • Enact a local Landmark Program with an expanded definition of sites worthy of protection to include “acquired significance” through cultural association to overlooked communities, events associated with the civil rights movement, and the women’s movement, and Bozeman’s early history of agriculture. 41 • Consider adjusting the NCOD boundary to include more mid-century neighborhoods. Do this in coordination with neighborhoods including but not limited to those represented on the Inter- Neighborhood Council. • Once a completed historic properties inventory survey has been finalized reinstate the review of demolition to the Historic Preservation Advisory Board, elevating them to a proper Historic Preservation Commission. Restoring demolition review to the board was recommended as a short-term goal on page 12 of the 2019 Final NCOD Policy Direction Report. • Adopt a deconstruction ordinance for demolition city-wide, explained further in the next section. • Change zoning in historic neighborhoods to align with historic preservation goals. Downzone the sections of Bon Ton, Cooper Park, and South Tracy Historic Districts that are currently zoned B-3 and R-4 to less dense zones to protect the historic character of these neighborhoods. This change was recommended in the 2019 NCOD report. • Downzone the properties surveyed as part of the future African American neighborhood historic district to protect them from redevelopment. • Create and adopt an incentive program for restoration efforts within an expanded NCOD. • Create and adopt an incentive program for property owners who want to internally subdivide an existing historic structure to add more dwelling units. • Codify NCOD design guidelines so they are not optional. • Put a sizable fine in place for anyone who neglects maintenance and anyone who demolishes a building found to have viable economic life left, within the NCOD. Unlawful demolitions should require reconstruction. • Implement and resource the Heritage Tree Program in cooperation with the Historic Preservation Advisory Board. • Have the current Historic Preservation consultants, Community Planning Collaborative, work with Code Studio to implement downzoning, zone edge transition regulations, and mixed-use zoning to protect historic resources. • Work to actively promote the formation of a Historic Preservation non-profit in the community to help fund restoration work. • Use Historic Preservation policy tools to protect NOAH. 42 8. Deconstruction Ordinance Older buildings were often constructed using quality materials that can be reused or recycled if the building is dismantled properly. “Every year the US demolishes 1 billion square feet of existing buildings to replace them with new ones.” [Rogers Merlino, K. (2018). Building Reuse; Sustainability, Preservation, and the Value of Design. University of Washington Press] “This burdens our municipal landfill unnecessarily.” The sustainable solution is to feed these materials into a circular economy through recycling or reuse. The BBC recommends that the city’s code be amended to incorporate a requirement that for buildings over 50 years old, a contract with a certified deconstruction contractor be a required part of any application for demolition. Other cities have implemented this type of requirement as part of both Historic Preservation and Climate Action Plans. Recommendations • Adopt a deconstruction clause in the Bozeman Municipal Code for buildings 50 years or older. • Work with the Historic Preservation Advisory Board, and the Sustainability Advisory Board to create language based on other City’s success. San Antonio is currently using best practices. • Identify possible contractors willing to be certified in deconstruction. • Identify possible repositories for the salvaged materials. Pacific Steel and Recycling, the ReStore etc. so that they can be put back into use for affordable housing. 43 9. Affordable Housing Bozeman is in a national, perhaps even a global real estate market. As long as there is a demand for luxury housing in Bozeman that is what developers will build. Even though there is also a demand for housing that is financially accessible to our full time residents who work here, the free market will give us luxury development. And it will drive up prices, making the production of affordable housing more difficult. It is the right of developers to build whatever will bring them the most profit in compliance with city zoning and building codes. The problem it poses for us, is that we don’t end up getting the housing we need to function as a city. We need service workers, but also importantly we need people to plow our streets, fix our roofs, staff our hospitals, our police and fire departments, our schools, our mechanic shops, and our grocery stores. Housing is no longer accessible to purchase for these essential workers in our community, and affording rent is becoming more burdensome. Housing as an investment allows homes to sit empty, because they are a place for people to park their money and build wealth. These are not people who live and work in our community. According to the most recent census data there are 15 million vacant homes in the United States. According to a website interpreting census data called USA FACTS: “These vacant homes, which include rentals, represent 10.5% of the country’s total housing inventory.” This is in stark contrast to a 2023 report issued by the National Alliance to End Homelessness finding that: “Homelessness has been on the rise since 2017, experiencing an overall increase of 6 percent. In 2022, counts of individuals (421,392 people) and chronically homeless individuals (127,768) reached record highs in the history of data collection. Unsheltered rates are also trending upward, impacting most racial, ethnic, and gender subgroups.” At the BBC we do not support upzoning in Bozeman’s UDC rewrite that encourages the redevelopment of our existing neighborhoods. As articulated in the first two chapters of this report, redevelopment of already expensive urban land cannot bring us affordable housing. We agree that we need to build “the missing middle” entry-level housing. We do not agree that the increased height allowances, and other upzoning tactics in the proposed UDC rewrite applied to existing neighborhoods, will get us that. On the contrary, as articulated in chapter 2 of this report, the increased height allowances proposed will actually incentivize that we skip that phase of development all together, going from single family homes and one story neighborhood commercial to high-density high-rise development at luxury prices. At the Better Bozeman Coalition the affordable housing policies, and those addressing homelessness that we support are predicated on the three P’s as outlined by the 2019 article titled, “3 Ps’ Is Best Solution For Housing Affordability And Homelessness Crises” in News by Housing is a Human Right. 44 “To that end, it’s crucial to protect tenants, preserve existing affordable housing, and produce new affordable housing. We protect tenants by preventing gentrification and homelessness by making rents affordable and discouraging evictions through strong tenant protections such as rent control and just cause eviction. We preserve existing affordable housing by not allowing developers to demolish it to build luxury housing. We produce new affordable housing for middle and working class residents, the poor, and unhoused individuals through adaptive reuse, pre-fab and modular housing, and other cost-effective construction methods.” The state legislature has removed many of the tools used successfully in other places to protect tenants. But the BBC supports the City Commission priority, set in January 2024, to provide tenants a right to council. At a minimum we need to do this. Moreover, we support continued exploration into ways, allowed under state law, that might be used to improve tenant protections. The Historic Preservation measures and those recommended by the American Planning Association, described in earlier chapters around protection of NOAH, are paramount to implement as soon as possible in Bozeman’s high-demand real estate market. This will not only preserve housing stock that currently sells below the median home price in Bozeman, it will also preserve a large portion of the older homes in the core neighborhoods that are currently rented out to local tenants. If we don’t preserve existing affordable housing, we risk displacing working class tenants from the center of town for a generation or more. At the BBC, we believe part of the charm of our central and historic neighborhoods is the economic diversity among residents that can be found there. The third tenant of the 3 P’s is the hardest; Produce affordable housing. But it’s actually so simple on the face of it. The free market can’t give us affordable housing, so we turn to innovative approaches that are being used successfully elsewhere. Affordable Housing Overlay The first of three approaches the BBC would like to see the City of Bozeman take, has to do with zoning in the UDC rewrite. Overlay districts are a zoning tool allowed to municipalities in Montana. The BBC suggests a strategic downzoning of neighborhoods to mostly match what is already built out on the ground. This is to prevent speculative redevelopment and gentrification. Overlay an affordable housing district that awards a density bonus (increased number of dwelling units allowed on a given parcel) if the new units are deed restricted for affordability at 60% AMI (Area Median Income) for rental and 100% AMI for sale. How is this different than the deep incentives in the affordable housing ordinance? An affordable housing overlay district doesn’t award extra height or less parking, it ties increased density to affordability. This has the affect of disciplining the pro-forma financial analysis of projects as described in chapter 1 of this report, which in turn disciplines the land value. This tool is described in detail in Professor Patrick Condon’s book Sick City published in 2021. An affordable housing overlay district is being used successfully in Cambridge Massachusetts and Vancouver BC. 45 A Cooperative Housing Model Across the country communities are coming together to fund housing themselves. Several of these cooperative models are described in a recent New York Times article titled, Priced Out of Housing, Communities Take Development Into Their Own Hands. “Much of the approach stems from efforts by the federal and local governments to make it easier for small investors to put money into real estate developments. Federal rules once barred small investors — those whose net worth is less than $1 million or who make less than $200,000 a year in income — from participating in development projects; that changed in 2015. At the same time, a few states enacted laws allowing small investors to put their money into local developments.” These developments are typically mixed use, having small-scale commercial and some short-term rental units subsidize the housing units that are affordable, income-based rentals, for local workers. Investors can include up to 1000 community members. This differs from Bozeman’s current Community Housing Impact Fund, because investors would be putting money into a specific project, not a general fund. The role of the City of Bozeman in a scheme like this would be to streamline the Planned Development Zone process to allow for speedy approval of affordable housing applications and maybe one or two departures from code that doesn’t threaten surrounding areas. It’s important not to compromise design standards or zone edge transition requirements because this leads to stereotypical resentment in communities of affordable housing projects as being ugly or overwhelming to established neighborhoods. This is in line with Goal 2 of the Belonging in Bozeman plan’s Housing Goals and Recommendations. “Goal 2. Reduce displacement of residents who work and go to school in Bozeman but cannot afford to live in Bozeman. 2. Convene local partners to explore the potential for co-operative housing models.” Local partners could include financial institutions like NorthFork Financial, First Interstate Bank, or local credit unions. For example, Stockman Bank in Missoula financed the construction of the Hogan apartment complex with over 50 local investors contributing. According to the website, “We anticipate rents at The Hogan to be about half of typical independent senior living facilities in Montana, and less than a third of a typical assisted living facility. “ https://www.thehoganmt.com Municipally Owned Housing In a May 16th Bozeman Daily Chronicle article it was announce that, “Montana to get $38.7 million from federal housing voucher program.” Conspicuously absent from the roster of housing authorities awarded the new federal funding was Bozeman. Because Bozeman is the only major city in Montana that doesn’t have a housing authority or any publicly owned housing whatsoever. Public housing is recognized the world over as an essential tool to keep housing affordable to the people you want and need in your community. Paris suffers from such high desirability that 25% of its residents live in municipally owned housing according to a recent New York Times article, How does Paris stay Paris? By Pouring Billions into Public Housing. Not just housing, but small scale neighborhood 46 commercial is subsidized in Paris because they recognize that in order to keep their little wine and cheese shops, and their bakeries, and fresh vegetable vendors in every neighborhood, they have to make it happen on purpose. Small business can’t compete with the global chains. And if a community wants to keep it’s unique flavor, it needs to make it happen. Public housing has failed in the past because it’s been subject to the whims of continually decreasing federal funding. But Montgomery County Maryland has been using a different model for decades that relies on revenue bonds, available only to municipalities, that are paid back over time by the rents from mixed income affordable housing projects, where higher earning renters subsidize lower income renters. But it needs to be administered by a housing authority because they have a unique ability to function as a bank. The model is described in a New York Times article titled, This is Public Housing, Just Don’t Call it That. The Housing Opportunities Commission in Montgomery County Maryland has been using this model successfully for decades. Recommendations • Continue to support local non-profits in the important housing work they are doing. • Act on the City Commission’s priority to adopt a regional unhoused policy. • Form a local housing authority to make use of creative models for municipally owned mixed- income affordable housing schemes using city owned land. • Explore every possible avenue to protect renters allowed under Montana law. • Continue to advocate in Helena for the right to implement a luxury sales tax, and even a vacancy tax in order to fund the creation of affordable housing. • Lobby Helena to overturn HB 259 to restore the right to use inclusionary zoning • Implement strategies to preserve NOAH. An affordable housing preservation policy is already one of the Commission priorities set in January 2024. • Explore tenants right to purchase, or first right of refusal laws that would be possible to implement in City code. This is necessary to protect mobile home park tenants as well as some historic multi-family homes that are currently rented to local working residents. • Lobby Helena for the right to enact rent control and eviction protections. • Implement strict FAR regulations so the existing housing stock, often occupied by renters, would be preserved rather than torn down for redevelopment into luxury condos. • Explore opportunities to use the materials gleaned from a deconstruction ordinance to make tiny homes for transitional housing on city owned land. • Zone new land for manufactured housing. • Work with individual neighborhoods to develop a neighborhood plan for where and what type of increased density would be appropriate. 47 • Adopt the provisions in the first draft of the UDC for greenfield development only (where it might have a chance of producing affordable housing) so that new more dense neighborhoods can be created promoting walkability and neighborhood scale commercial development. 48 10. Locating Fraternities and Sororities There is a concern by many neighbors and neighborhoods as to where new or relocating fraternity and sorority houses can locate in Bozeman. In 2017 the UDC listed Fraternity and Sorority Houses as a unique “Separate Residential Use’. They could locate in R-3, R-4, office and commercial zoning districts but were not allowed in R-1 or R-2. The requirements for parking, lot size, and open space for fraternity and sorority houses were the same requirements as for Group Living. Unbeknownst to neighbors and neighborhoods, the city removed Fraternity and Sorority Houses as a Separate Use and grouped them into Group Living allowing them in any residential zoning district. When a single-family home on Garfield was rented to 4-5 men, the neighbors were ok with that until they learned it was really a 50 member fraternity. How was that possible when the UDC rules they knew said that could not happen? This was hugely disruptive. Many neighbors felt unsafe as large parties and big gatherings happened. Police were called when the parties ran late into the night. Discussions with the fraternity about concerns did not help. So, the neighbors filed a lawsuit that proper notice of this change was not given and the court ordered the city to go back to what the code was in 2017. Although the current and proposed UDC rewrite still list the changed language of 2018, neighbors were told by city Planning that the actual code being applied is the one from 2017. Recommendations • Revert back to the 2017 UDC code with reference to the location of fraternities and sororities. • List Fraternity and Sorority Houses as a “Separate Use” and a subset under Group Living. The City of Billings and Missoula both do this in their municipal codes. • Allow new or relocating fraternity and sorority houses in high density mixed use zoning districts with adequate parking mandated to support large gatherings. • Follow the same requirements as Group Living for parking, lot size, open space, on-site occupancy and duration of occupancy. • Address the need for a required minimum size for indoor meeting/ gathering/ event rooms. Fraternities and Sororities at MSU have 30-90 members. Most single-family houses are not designed to hold 50 people for a gathering. Any new or relocating fraternity or sorority house needs to be required to have a minimum inside meeting/gathering/event room to hold at least 50 members. There are meeting room calculators on line. Chi Omega sorority meeting room=1,059 sq ft Delta Gamma sorority meeting room =992 sq ft • Define Fraternity/ Sorority house. As an example, the Billings Muni code uses the following definition: “Fraternity/sorority house: A dwelling or dwelling unit occupied by and maintained exclusively for fraternity or sorority members, their guests or visitors and affiliated with and acknowledged as a fraternity/sorority house by an academic or professional college or university or other recognized institution of higher learning.” 49 12. Conclusion At the Better Bozeman Coalition, our mission is… To preserve the unique character of Bozeman’s neighborhoods while working with the city on housing affordability, availability and natural resource sustainability. We acknowledge Bozeman’s neighborhoods, whether new or old, are the heart of this city. They are places of community for all those who live in them. We believe that we can meet the challenges of growth without destroying the things that make our City beautiful, unique, and desirable. We hope to welcome future residents to live and work in a City that honors our past history and is safe, accessible, healthy, beautiful, equitable, affordable, and sustainable for generations to come. These recommendations represent the ideas and values of a group of concerned residents who want to protect our existing and future neighborhoods from gentrification, and exploitation by unsympathetic developers who increasingly want to cash in on the charm of our community. We celebrate the economically diverse neighborhoods we have, and encourage policies that prevent displacement of those who live and work here. We have something great here, let’s work together to keep it that way. This report is not intended to take the place of proper community engagement on behalf of the City surrounding further amendments to our Unified Development Code. Every resident and property owner in Bozeman deserves to weigh in on zoning changes and historic preservation in their neighborhoods. Better outcomes result when residents participate. Patrick Condon University of British Columbia Professor of Urban Design, author of : Sick City , Broken City , and Seven Rules for Sustainable Communities will be visiting Bozeman to share lessons learned about increasing land prices and decreasing housing affordability. join us June 19th 4:30 pm Bozeman Senior Center 807 N. Tracy Ave for an in-depth presentation followed by a book signing