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Home My WebLink About01-03-25 Public Comment - N. ten Broek - The Guthrie application (#24493)From:Noah ten Broek To:Bozeman Public Comment; Terry Cunningham; Emma Bode; Douglas Fischer; Jennifer Madgic; Joey Morrison Subject:[EXTERNAL]The Guthrie application (#24493) Date:Tuesday, December 31, 2024 3:03:55 PM 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. Dear Commission and City Staff, Please find my public comment attached to the following google drive link. The document was too large for a regular upload. The Guthrie V.2 application (#24493).pdf Kind regards, Noah ten Broek Dear City Staff and Commission, Greetings! I am writing today to provide comment on the amended application (#24493), which has evolved from the previously denied application (#23354). It is imperative to address the characterization of this submission as a “new” application. The content of application (#24493) is merely a remedial effort to retroﬁt a previously deﬁcient proposal to meet adequacy. After thoroughly reviewing the Neighborhood Conservation Overlay District (NCOD) code, Bozeman’s Community Plan, and the Bozeman Guidelines for “Historic Preservation & the Neighborhood Conservation Overlay District”, it is abundantly clear that these guidelines were speciﬁcally designed to prevent developments like the Guthrie from encroaching upon our neighborhood. These documents emphasize the importance of preserving neighborhood integrity while ensuring the city adheres to its own cultural framework for guiding appropriate development within the core of our community. Although I had previously opposed the development proposal, it wasn’t until delving into these documents that I fully recognized its profound incompatibility. The Guthrie is entirely inappropriate for our neighborhood, and the preservation of our cultural character and architectural values must take precedence above all else. One of my primary concerns is that both versions of the Guthrie proposal fail to comply with the NCOD guidelines. Speciﬁcally, the design does not align with the architectural characteristics of the surrounding multifamily apartment buildings and homes. The recent revelation that the Guthrie features ﬁxed, non-operable windows for each unit, relying solely on HVAC systems, feels completely out of step with our neighborhood’s character and the fundamental needs of its human residents. HomeBase Partners should have conducted a comprehensive design study of local structures to incorporate architectural elements that align with our neighborhood's intentional design principles. Such an approach would have honored and preserved the unique character and functionality of our community-focused neighborhood. The mid-century buildings in our neighborhood, with their characteristic half-story underground design, embody the pragmatic, aesthetic, and philosophical ideals of their era, inﬂuenced by architectural pioneers like Frank Lloyd Wright. Wright’s philosophy of “organic architecture,” which emphasized harmony between human habitation and the natural environment, inspired designs that integrated buildings into the landscape rather than dominating it. The partially below-grade construction reﬂects this ethos, blending seamlessly with the environment while offering functional advantages. Originally, these designs responded to post-war economic needs by reducing heating and cooling costs through natural insulation provided by the earth. Today, these features are equally relevant for environmental reasons, as they align with modern sustainability goals. By improving energy efﬁciency, reducing reliance on artiﬁcial climate control, and lowering the carbon footprint of buildings, they address critical climate challenges. This approach also honors the recent Held v. Montana Supreme Court decision, which reafﬁrmed the necessity for the state to prioritize sustainable practices and protect the environment for future generations. By embracing these principles, we ensure that development remains climate- conscious while preserving the character and values of community. The result is a distinct architectural vernacular in our neighborhood that not only embodies the principles of mid-century modernism but also fosters a cohesive, harmonious relationship between buildings, their occupants, and the natural environment—timeless in its ingenuity and relevance. I’ve compiled photos of all the large multifamily buildings in the NCOD and near the proposed Guthrie site bordering the NCOD to provide context of the character of our neighborhood. You can view these photos using the following link. The photo’s of the respective buildings are at the bottom of this document. [https://www.google.com/maps/d/edit? mid=1tJ_2crzvLrNFjUw0DnQLJvreFbmzCeA&ll=45.67815313882773%2C-111.040689105135 34&z=14] All the large multifamily complexes within and around the NCOD share a consistent design that reﬂects the historical character of the area. A deﬁning feature of these buildings is their recessed ﬁrst story, set halfway underground, which aligns with the architectural era in which they were constructed. Additionally, these buildings incorporate more than 80% brick or feature real wood and stucco elements in their façades. It is notable that HomeBase Partners’ ﬁrst fully residential complex in B-3 zoning, Block M (34 E Lamme), considered the NCOD guidelines. Block M recessed its ﬁrst story halfway underground, utilized ~50% brick, and included signiﬁcant concrete design elements. Moreover, it showcased extensive residential façade articulation—a critical design feature that is conspicuously absent on The Guthrie’s Villard and west-facing sides, directly violating section 38.530.040. The Guthrie is proposed for a residential area, not a commercial one. For the ﬁrst time in Bozeman, HBP (HomeBase Partners) is subject to residential guidelines within the Neighborhood Conservation Overlay District (NCOD). Yet, they appear determined to force a commercial-style (B- zoning) product into a residential zone, disregarding the established guidelines and character of the neighborhood. In a private meeting, where I represented myself solely as an individual, I engaged in a discussion with Andy Holloran and Chuck Winn about the design compatibility of The Guthrie with our neighborhood. We explored how HBP might adjust the size and scale of the project to align with the gradual and predictable increase in density outlined in our Community Plan (Policy N-1.11). During this conversation, I referenced HBP’s Block M development as a relatable example for sympathetic inﬁll. Block M incorporates thoughtful design elements, including a recessed ﬁrst story and a stepped-back fourth story, which effectively reduce the visual impact of height. Its façade features signiﬁcant articulation, creating a visually engaging design that complements the architectural diversity of our Craftsman and mid-century neighborhood. This approach exempliﬁes how increased density can be introduced in a way that respects and enhances the character of the surrounding community. However, the meeting referenced in application (#24493), concerning the (31) Early Termination of a Two-Year Stay (Sec. 3 & 4), was grossly misrepresented by HBP. Their characterization of the discussion between Noah ten Broek, Chuck Winn, and Andy Holloran distorted both its purpose and content, constituting a violation of Sec. 38.200.060. Additionally, this meeting implicates the city in procedural impropriety, as it was explicitly promised by the city manager Chuck Winn to be informal in nature. However, HBP used the meeting in bad faith as an attempt to fulﬁll the conditions necessary to lift a two-year demolition stay. This misrepresentation undermines the integrity of the process and constitutes a breach of trust, calling into question the procedural fairness in handling this matter. Where the Guthrie application fails the Bozeman Community Plan The Bozeman Community Plan R-1.1: "Be reﬂective: use past experience to inform future decisions." •The Guthrie proposal fails to reﬂect on past community experiences where large-scale developments disrupted the neighborhood character and continuity of our collective identity as seen in: One11, The Ives etc.) •Whereas, developments like Block M successfully integrated density while respecting the architectural scale and character a core district, offering a clear example for how reﬂective planning and sympathetic design can inform decisions by the same developer. •The Guthrie, in contrast, does not incorporate lessons from these precedents, such as recessed stories or articulated façades, and instead introduces a commercial product into a residential zone, disregarding its historical and architectural context. N-1.11: "Enable a gradual and predictable increase in density in developed areas over time." •The Guthrie’s 4-story mass is a stark anomaly in a neighborhood deﬁned by single-story and split-level homes, along with 2-story multifamily buildings. •Its scale does not align with the gradual and predictable increase in density envisioned by the Community Plan. •The abrupt increase in height and scale is neither gradual nor predictable and disregards the established neighborhood pattern. N-4.1: "Continue to recognize and honor the unique history, neighborhoods, neighborhood character, and buildings that contribute to Bozeman’s sense of place through programs and policy led by both City and community efforts." •The Guthrie undermines this policy by proposing the demolition of a mid-century convalescent home that contributes to the neighborhood’s unique historical narrative. •The property’s architecture reﬂects mid-century design principles, including recessed ﬂoors and pitched roofs, which are essential to preserving the character of this neighborhood. •Adaptive reuse, as opposed to demolition, would better honor the history and contribute to Bozeman's sense of place. 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." •The Guthrie is located in a residential area outside any center of employment or activity. •By proposing a 4-story building with no height transition, it directly contradicts this guideline. •The proposed building’s height fails to transition down to the surrounding single-story and 2-story buildings, creating a visual and functional incongruity with the adjacent neighborhood. DCD-3.6: "Evaluate parking requirements and methods of providing parking as part of the overall transportation system for and between districts." •The Guthrie’s proposed parking arrangement is inadequate for the density it introduces. •By relying on off-site parking, it increases the burden on neighboring streets, leading to congestion and noise that disrupt the residential character and safe school operations. •This failure to integrate parking solutions exacerbates conﬂicts between residents and the proposed development, undermining neighborhood predictability. EPO-3.9: "Integrate climate change considerations into development standards." •The Guthrie’s design ignores modern climate-sensitive considerations, such as energy efﬁciency and building integration with the natural landscape. •The proposal’s disregard for the partially recessed, energy-efﬁcient designs seen in nearby buildings undermines opportunities to align with the Held v. Montana decision, which prioritizes sustainable practices to address climate change. •A better approach would include features like partially below-grade construction to reduce heating and cooling demands and minimize environmental impact, solar and electric charging stations for electric vehicles. M-2.3: "Work with School District #7 and other community partners in planning and operating safe routes to local schools." •The Guthrie creates additional trafﬁc congestion and noise along N 5th Ave, a key route for children walking to nearby schools. •The lack of collaboration by the city and the developer with School District #7 to ensure the safety of these routes fails to meet this policy. •A more community-oriented design would prioritize minimizing trafﬁc and ensuring pedestrian safety for families and children in the area. This would include and not be limited to concurrent trafﬁc safety infrastructure updates into main arterials such as 7th, Peach and Villard for both pedestrians and busses. A trafﬁc plan for safe and easy drop off of school children. A 24-hour parking district etc. Comprehensive Analysis of NCOD Provisions in Relation to The Guthrie Proposal: Sec. 38.340.010 - Intent and Purpose Section C: Restoration and Rehabilitation of Existing Structures •The Guthrie proposal fails to prioritize the restoration or rehabilitation of the existing structure, a central intent of the NCOD. •The mid-century building currently on the site possesses architectural signiﬁcance that aligns with the neighborhood’s established character. •Instead of stimulating restoration, HBP proposes demolition and replacement, disregarding the principle of preserving existing structures as a foundation for new construction. •While new construction is encouraged under this section, it must contribute to and enhance the neighborhood's aesthetic and functional character which the Guthrie fails at. •The Guthrie does not align with these expectations, as its mass, scale, and contemporary design disrupt the established architectural continuity. •The lack of harmonious integration into the neighborhood demonstrates a failure to meet the intent of Section C. Section F: Protection and Enhancement of Signiﬁcant Neighborhood Characteristics •The existing structure is an irreplaceable asset that reﬂects Bozeman’s architectural history and small agricultural-based development patterns. Its mid-century design and integration with the natural environment embody the unique characteristics of the area, which the NCOD seeks to protect. •Demolishing the structure undermines the preservation of landmarks, planning styles, and architectural character essential to Bozeman’s identity. This directly contradicts the intent of Section F, which emphasizes protecting historic assets for educational, cultural, and economic beneﬁts. Sec. 38.340.070 - Deviations from Underlying Zoning Requirements Criteria for Deviations •Historically Appropriate Modiﬁcations: The Guthrie’s proposed deviations from NCOD guidelines are not more historically appropriate than enforcing the chapter’s standards. The building’s lack of articulation, excessive scale, and contemporary materials fail to respect the historical character of adjacent properties or the broader neighborhood. •Minimal Adverse Effects: The Guthrie's design has signiﬁcant adverse effects on abutting properties. Its imposing height, ﬂat façade, and absence of traditional architectural elements diminish the visual harmony of the neighborhood. Additionally, the intensiﬁcation of use will introduce increased noise, trafﬁc, and light pollution, further impacting neighboring residences. •Public Health, Safety, and Welfare: The lack of adequate buffers, the excessive visibility of parking areas, and the building’s incongruous scale compromise the neighborhood’s cohesion and livability, thereby failing to assure the protection of public welfare. Sec. 38.340.090 - Demolition or Movement of a Historic Structure or Site A. Certiﬁcate of Appropriateness (COA) for Demolition and Subsequent Development •The Guthrie proposal’s subsequent development plan does not comply with the standards set forth in Section 38.340.050. It disregards the architectural and cultural context of the area, failing to provide a design that enhances or preserves the neighborhood's historic fabric. •Approval of the COA for demolition would contradict the purpose of the NCOD, which is to stimulate restoration and rehabilitation rather than demolition. C. Response to Criteria for Demolition or Movement of a Historic Structure or Site 1. The Property's Historic Signiﬁcance •Assessment of Importance: ◦The property has been deemed historically eligible, emphasizing its signiﬁcant cultural, architectural, and historical value. It has a direct connection to Bozeman's founding families and plays a critical role in preserving the unique mid-century architectural character of the neighborhood. ◦Architecturally, the building reﬂects mid-century design principles, including its characteristic recessed sub-grade story and pitched roof. These elements are rare and integral to the neighborhood’s historic identity, aligning with conservation efforts outlined in the Neighborhood Conservation Overlay District (NCOD). 2. No Viable Economic Life Remaining •Determination of Viability: ◦The claim of "no viable economic life remaining" has not been substantiated. Rehabilitation costs, while potentially signiﬁcant, do not inherently render the structure economically non-viable, particularly given the possibility of adaptive reuse. ◦The property could be revitalized through the use of tax credits, grants, or public- private partnerships aimed at preserving historically signiﬁcant structures. This would honor its historical status while maintaining its value and utility within the community. ◦Adaptive reuse, as demonstrated by similar projects in the area (The Sapphire, The Lark, RSVP) is a viable alternative to demolition and aligns with both the spirit and intent of Bozeman's historic preservation guidelines. Two-Year Stay Section (Sec. 38.340.090.D) The two-year stay provision is critical to ensuring that all viable alternatives to demolition, including adaptive reuse or preservation, are thoroughly explored before allowing irreversible changes to the neighborhood fabric. However, its application in this case, as presented by the applicant for The Guthrie project, reveals signiﬁcant shortcomings and potential violations of the intended purpose of this safeguard. Misrepresentation of Alternatives Explored The applicant, HomeBase Partners (HBP), has failed to adequately demonstrate good-faith efforts to explore alternatives to demolition. While the two-year stay allows time for adaptive reuse, listing the property as historic, or offering the structure for relocation, HBP’s actions to date suggest a lack of meaningful engagement with these options. Speciﬁcally: 1.Adaptive Reuse Ignored:◦Despite the mid-century convalescent home’s architectural and historical value, no detailed feasibility study for adaptive reuse has been provided. Adaptive reuse would align with NCOD guidelines and honor the building’s historical signiﬁcance while accommodating new development goals. 2.Community and Stakeholder Engagement Deﬁcient:◦HBP has not transparently or adequately sought input from neighborhood groups or preservation experts, as required by the early termination criteria. This lack of engagement undermines the integrity of the two-year stay process. 3.Historic Listing Not Pursued:◦The applicant has not made meaningful attempts to list the property for sale as a historic asset, even though its architectural signiﬁcance has been repeatedly emphasized by community members and stakeholders. Premature Push for Early Termination HBP’s attempts to use the informal meeting referenced in their application as evidence of good- faith efforts are misleading. The meeting was intended to be informal and exploratory but was instead mischaracterized by HBP as part of their compliance with the early termination criteria. This represents a bad-faith attempt to circumvent the two-year stay without fully addressing its conditions, violating both the spirit and intent of the provision. Failure to Demonstrate No Viable Economic Life HBP has not sufﬁciently proven that the existing structure has no viable economic life remaining. According to the criteria in Section 38.340.090.C, the cost of repair or rehabilitation must exceed the cost of demolition and redevelopment. However: 1.No Detailed Cost Analysis Provided:◦The applicant has not presented a transparent cost analysis comparing rehabilitation versus demolition and redevelopment in earnest detail. Without this information, it is impossible to conclude that the structure lacks economic viability. 2.Viability Through Tax Credits and Grants:◦State and federal tax credits, along with other ﬁnancial incentives, could signiﬁcantly offset rehabilitation costs, but the applicant has not explored or presented these options in good faith. Violation of Public Trust The two-year stay is intended to provide the community with conﬁdence that their concerns will be considered and addressed. HBP’s approach has instead fostered mistrust by: 1.Misrepresenting informal meetings as compliance efforts. 2.Failing to engage transparently with the public on alternatives to demolition. 3.Prioritizing demolition over adaptive reuse without adequate justiﬁcation. Improper Handling of Documentation and Submittals The applicant has not met the standards for a complete and adequate submittal, as required by the two-year stay criteria. Speciﬁcally: 1.Incomplete Application for Demolition:◦The absence of comprehensive documentation, such as historical surveys or feasibility studies, undermines the validity of their request. 2.Subsequent Development Plans:◦The proposed replacement development does not comply with NCOD standards, particularly regarding scale, design, and compatibility with the neighborhood. 1.Inﬂated Costs of Adaptive Reuse: HBP's cost analysis for adaptive reuse appears to have exaggerated the challenges of rehabilitating the existing structure. Speciﬁcally, the analysis likely overstates the expenses associated with structural retroﬁtting, bringing the building up to modern code, and addressing deferred maintenance. This approach artiﬁcially skews the ﬁgures to make adaptive reuse appear economically unfeasible. 2.Undervaluation of Reuse Beneﬁts: HBP's analysis does not adequately account for the intrinsic and long-term beneﬁts of adaptive reuse, such as: ◦Retaining the neighborhood's historical and architectural integrity. ◦Minimizing waste by reducing demolition debris. ◦Lowering carbon emissions compared to new construction, aligning with climate- conscious development goals outlined in EPO-3.9 of the Bozeman Community Plan. 3.Selective Omission of Funding Opportunities: The analysis fails to consider potential funding sources for adaptive reuse, such as federal and state tax credits for historic preservation, grants, or community partnerships, which could signiﬁcantly offset costs. 4.Misleading Comparison of New Build Costs: The estimated costs for new construction in HBP's analysis likely downplay expenses, particularly in areas such as: ◦Environmental impact mitigation. ◦Extensive site preparation. ◦Compliance with NCOD guidelines and the necessary façade articulation and design modiﬁcations. 5.Lack of Detailed Itemization: A thorough, itemized breakdown of costs for both adaptive reuse and new construction is absent, making it difﬁcult to assess the accuracy and validity of the ﬁgures provided by HBP. 6.Neighborhood Value Ignored: The cost analysis disregards the intangible cultural and social value of preserving an iconic neighborhood structure that contributes to Bozeman's sense of place. These non- monetary values are critical in adhering to the NCOD's intent and purpose, which prioritizes restoration and preservation. Sec. 38.340.130 - Safe Condition and Good Repair The provision under Sec. 38.340.130 mandates that structures within the conservation district be maintained in a safe condition and good repair. However, HomeBase Partners (HBP) has actively contributed to the deterioration of the historic convalescent home through questionable actions, undermining the intent of this section: 1.Premature Asbestos Abatement Damaging the Structure: ◦Before a demolition permit was granted, HBP contracted an asbestos abatement team to work on the building. This process, instead of preserving the structure, led to signiﬁcant interior and exterior damage. Historic features were destroyed or compromised, leaving the building visibly deteriorated and further reinforcing a misleading narrative of disrepair. ◦This action disregards the requirement to maintain the structure in good repair, as outlined in Sec. 38.340.130. It suggests a deliberate strategy to degrade the building’s condition and justify demolition. 2.Violation of Conservation Principles: ◦The intentional or negligent damage to the building during the abatement process is a clear violation of the NCOD’s principles, which prioritize restoration and preservation of historic structures. This destruction directly undermines the purpose of the NCOD and compromises the building’s historic and architectural signiﬁcance. 3.Misleading Presentation of Condition: ◦The visible damage caused by the abatement team has created a false narrative that the building is beyond repair. This misrepresentation is a direct result of HBP’s actions and should not be considered an accurate reﬂection of the building’s structural or historical viability. City records indicate that the building was inspected yearly and passed necessary inspections. ◦By failing to address maintenance and instead contributing to the building’s decline, HBP has acted in bad faith and violated the intent of this provision. 4.Failure to Preserve Architectural Integrity: ◦The asbestos abatement process should have been conducted with care to protect the building’s historic features. Instead, HBP’s actions resulted in the loss of irreplaceable elements of the structure, further detracting from its historical signiﬁcance and architectural integrity. The Guthrie’s Non-Compliance with the Bozeman Guidelines for Historic Preservation & Neighborhood Conservation Overlay District (NCOD) Policy: Compatibility with Neighborhood Context The proposed Guthrie development fundamentally violates the guiding policy for multi- household construction within the NCOD, which prioritizes the preservation of neighborhood integrity and architectural compatibility. Its current design disregards these core principles, presenting an irreparable threat to the character and cohesion of the neighborhood. 1.Retention of Existing Structures: ◦Guideline: "Retaining an existing single household building that contributes to the established character of the neighborhood in a multi-household project is encouraged." ◦Violation: The mid-century convalescent home currently on-site is a contributing structure that reﬂects the neighborhood’s architectural heritage. Its design, with recessed ﬁrst-ﬂoor construction and materials characteristic of the mid-century period, offers irreplaceable cultural and historical value. The demolition of this building disregards both the guideline and the community’s calls for adaptive reuse. ◦Argument: Retaining and rehabilitating the existing structure would maintain neighborhood continuity, satisfy the NCOD’s intent to conserve architectural heritage, and demonstrate good-faith adherence to preservation goals. Minimizing Perceived Scale 2.Stepping Down Heights Toward Adjacent Structures: ◦Guideline: "Step down a building's height toward the street, neighboring structures, and the rear of the lot." ◦Violation: The Guthrie’s four-story height overwhelms adjacent single-story and split-level buildings. Its uniform vertical mass disregards the established neighborhood rhythm, creating an overbearing and disruptive presence. ◦Argument: A height reduction with stepped-back upper ﬂoors would align with the NCOD’s goal of gradual transitions and create a design more sensitive to neighboring properties. 3. Breaking Up Mass Into Modules Guideline: "Divide a large facade into subordinate wall planes that have dimensions similar to those of single household buildings." •Violation: The Guthrie’s Villard and west-facing facades lack meaningful articulation or modular massing. These uninterrupted, monolithic walls starkly contrast with the articulated and rhythmically divided structures traditionally found in the neighborhood. •Argument: The building should incorporate subordinate wall planes and recessed modules to create a façade that reﬂects the neighborhood’s architectural cadence and minimizes its perceived bulk. This would better align with the neighborhood’s architectural rhythm, ensuring that the building complements rather than overwhelms its surroundings. Traditional Features and Human Scale 4.Incorporating Human-Scale Elements: ◦Guideline: "Use traditional features that will convey a human scale." ◦Violation: While a one-story front porch is included, the overall design lacks essential human-scale features. Additionally, the lack of operable windows makes it commercial and inhumane for people seeking longterm meaningful housing. Height and Streetscape Continuity 6.Height Compatibility: ◦Guideline: "A new multi-household building should not overwhelm existing single household structures, in terms of height." ◦Violation: The four-story height of The Guthrie stands in stark contrast to the one- and two-story buildings that dominate the neighborhood. This height discrepancy disrupts the visual continuity and undermines the NCOD’s intent to preserve consistent streetscapes. ◦Argument: Limiting the building’s height to three stories with a recessed ﬁrst ﬂoor and stepped-back fourth ﬂoor would harmonize it with neighboring structures while adhering to the NCOD’s emphasis on proportionality. 7. Primary Building Face Width Guideline: "A primary building face should not exceed the width of a typical single household building in a similar context." •Violation: The Guthrie’s excessively wide face on the North and West side far exceeds the proportions of single-family homes in the neighborhood. This unbroken width results in a visually overpowering structure that contrasts sharply with the neighborhood’s scale. •Argument: Reducing the width of the primary face and dividing it into visually distinct recessed segments would better reﬂect the established building widths and maintain neighborhood harmony. This approach would also align the development more closely with NCOD guidelines, ensuring the design respects the neighborhood's architectural rhythm and human-scale proportions. Materials and Design 8.Use of Preferred Materials: ◦Guideline: "Brick, stone, and painted wood are preferred primary building materials." ◦Violation: The Guthrie relies predominantly on ﬁber cement, which is neither historically compatible nor a preferred material under NCOD guidelines. Minimal brick usage fail to meet material standards as seen on ALL major Multifamily developments. ◦Argument: At least 80% of the façade should incorporate preferred materials like brick, to ensure compatibility with ALL of the large neighboring neighborhood’s multifamily buildings traditional character. Open Space and Parking 9.Functional and Useful Open Space: ◦Guideline: "Provide some useful, functional common open space that can be enjoyed by all residents in the development." ◦Violation: The proposed open space appears tokenistic and lacks sufﬁcient dimensions or features to meet the activity needs of residents. The design fails to integrate open space as a meaningful component of the development by placing some of open space in the setbacks. Not having operable windows adds to the lack of a meaningful interface between the indoors and outdoors. 10. Minimizing Parking Impacts •Violation: The parking lot, visible from 5th Avenue, lacks adequate screening or landscaping to mitigate its visual impact. The absence of substantial visual buffers conﬂicts with NCOD guidelines. •Argument: Parking should be heavily screened with evergreen landscaping and fencing/ electronic gates to minimize its visual intrusion. Kibbey Plaza 801 West Villard Legion Villa 1215 Durston HBP “Block M” 20 North Tracy Darlinton Manor 606 N 5th Ave Multifamily 303 N 5th Bridger Heights 802 N Grand Bridge Commons 17 West Lamme Bridger View Rehab Center 321 North 5th Avenue