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HomeMy WebLinkAbout10-21-24 Public Comment - Z. Osman - Public comment for Community Development Advisory Board_ Historic Landmark Program WorksessionFrom:Zehra Osman To:Bozeman Public Comment Cc:Sarah Rosenberg; Erin George; Chris Saunders; adrienne; Jennifer Madgic; Joey Morrison; Terry Cunningham; Douglas Fischer; Emma Bode Subject:[EXTERNAL]Public comment for Community Development Advisory Board: Historic Landmark ProgramWorksession Date:Monday, October 21, 2024 11:41:10 AM 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. City Clerk’s Office: Please post in public record and please email to each of the Historic Preservation Advisory Board members and each of the Community Development Advisory Board members. Thank you! Dear Community Development Advisory Board - I am writing to you in preparation for your Monday October 21, 2024 meeting, which includes a work session on the Historic Landmark Program (HLP). I’ve lived here long enough to have attended two previous iterations, and now a new iteration, of review of the HLP and Historic Preservation Program (HPP). Still, there seems to be confusion about what historic properties are and how they enter into conversations regarding development. FOLLOW THE NHPA Since the 1966 National Historic Preservation Act (NHPA), the United States has been improving planning processes in order to consider the loss of historic properties, which include historic buildings, structures, sites (e.g. archeological), districts, and objects. The 1972 National Environmental Policy Act (NEPA) also emphasized the consideration of historic properties in planning process. These Acts came about during a time when the country was losing irreplaceable resources. Bozeman’s Historic Preservation Program (HPP), which I’ve heard began to take form shortly after these Acts were passed, has helped our City retain those resources that are important to this area’s post 1800s history, though I do need to add that our understanding, preservation, planning and education of Native American history is sorely deficient and needs a lot more attention and work. The HPP has unfortunately eroded over the years, especially over the past 20 years. Sure, Bozeman doesn’t always have to comply with the NHPA because it pertains more to federal lands and federal funding. However, these laws are excellent and we should look to them for a framework for Bozeman’s HPP. I urge Bozeman follow the NHPA as a guide and not try to recreate the wheel. For example, under Section 106 of the NHPA: 1. The area affected by a proposed undertaking (Area of Potential Effect, or APE) is inventoried for historic properties to determine the presence of archeological resources, historic buildings, historic districts, or objects (e.g. lamp posts). How else would one know what is being affected by the project? Let’s do this in Bozeman’s HPP! 2. These resources are then evaluated for eligibility to the National Register of Historic Places, which includes not only nationally significance, but also state and local significance. This is done in consultation with the State Historic Preservation Office for review. Let’s do this in Bozeman’s HPP!3. Then, the proposed undertaking’s effects on historic properties are evaluated under The Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI STDS) Under the Code of Federal Regulation 36CFR Part 68, https://www.ecfr.gov/current/title-36/chapter-I/part-68 . The goal is to avoid an “adverse effect” to these properties, as defined. These standards are stated in the regulation. Let’s not recreate the wheel and let’s follow these in Bozeman’s HPP!4. If a change to an existing historic property is proposed, then the project is considered a “rehabilitation” and the SOI STDS provide guidelines to help apply the standards. Then the https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1-preservation- rehabilitation.pdf . Here, you go to page 75, and there are guidelines that help prevent an adverse effect to a historic property. Let’s not recreate the wheel and let’s follow these in Bozeman’s HPP! Our Strategic Plan 1.2 Community Engagement states: Broaden and deepen engagement of the community in city government, innovating methods for inviting input from the community and stakeholders. I took the time to take the survey, encourage others to take the survey, and chatted with staffers about the HLP at Lunch on the Lawn this summer. The report you will see tonight has lots of statistics to show that community engagement happened. However, all the open ended comments we community members took the time to enter into the survey is represented by a brief summary. The report goes right into some recommendations. What happened to all of our community ideas? Have they all been lumped together into soundbites? THE ROLE OF TREES IN HISTORIC PROPERTIES The Historic Preservation Board has been talking about the Heritage Tree Program for some time now. The Unified Development Code (UDC) includes environmental and tree protection language but for some reason it is not enforced. If heritage trees (and existing mature trees, in general) are not prioritized as part of the HLP, HPP, and the UDC rewrite now, then when? The City’s Community Development - Historic Preservation Program webpage states: "Preservation goes beyond saving old buildings, it creates a unique sense of place, a sense of community and bridges the gap between the past and our future. Preservation is about recognizing and celebrating what our community values and ensuring it can be enjoyed by future generations.” Trees are discussed in the SOI STDS and Guidelines https://www.nps.gov/orgs/1739/upload/treatment- guidelines-2017-part1-preservation-rehabilitation.pdf. If you do a word search for “trees” in this document, you’ll see trees are considered features that are important to character of the setting: Setting (District/Neighborhood) The setting is the larger area or environment in which a historic building is located. It may be an urban, suburban, or rural neighborhood or a natural landscape in which buildings have been constructed. The relationship of buildings to each other, setbacks, fence patterns, views, driveways and walkways, and street trees and other landscaping together establish the character of a district or neighborhood (page 21) Identifying, retaining, and preserving features of the building site that are important in defining its overall historic character. Site features may include walls, fences, or steps; circulation systems, such as walks, paths or roads; vegetation, such as trees, shrubs, grass, orchards, hedges, windbreaks, or gardens; landforms, such as hills, terracing, or berms; furnishings and fixtures, such as light posts or benches; decorative elements, such as sculpture, statuary, or monuments; water features, including fountains, streams, pools, lakes, or irrigation ditches; and subsurface arche­ological resources, other cultural or religious features, or burial grounds which are also important to the site. (Page 137) Trees are supposed to be considered in projects. Trees and vegetation absolutely need to be included in our HLP and HPP and UDC. When I heard a City staff member say trees are not included in the scope of the current HLP, I was stunned. They are part of the APE (see above) and are part of the historic setting. In conclusion, Federal agencies and State Historic Preservation Offices throughout the country follow the NHPA and the SOI STDS. It’s sound, well-reviewed, and underscored by law. I urge the City of Bozeman to create a HLP and HPP that closely follows these excellent laws and guidance without recreating the wheel. I also urge the City to consider natural features such as trees as an important part of the setting, as defined by the NHPA, Section 106 of the NHPA, and the SOI STDS. Respectfully, Zehra Osman Sanders Ave 59718