HomeMy WebLinkAbout04-16-25 Public Comments - Z. Osman - Comments on Preservation Policy Local Landmark Project Phase 1 draft and also Comments on UDCFrom:Zehra Osman
To:elizabeth.darrow@gmail.com; cnholling91@outlook.com; mike@arch118.com; lindasemones@hotmail.com;allycaroline@gmail.com; ashleyharville@yahoo.com; jwebster587@gmail.com; Sarah Rosenberg; Erin George;Jennifer Madgic
Cc:Bozeman Public Comment
Subject:[EXTERNAL]Comments on Preservation Policy Local Landmark Project Phase 1 draft and also Comments on UDC
Date:Wednesday, April 16, 2025 11:54:29 AM
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(Please add this comment to the public record for the UDC and the Historic Landmark Program,
Preservation Policy and Local Landmark Project (PPLLP))
Honorable Historic Preservation Advisory Board Members, Historic Preservation Officer, CommunityDevelopment Director, and Commissioner Madgic:
Now that we have heard each city commission member’s opinion of the NCOD during the 04/15/25
decision on the Guthrie appeal, it is clear how the current Preservation Policy and Local Landmark Project
(PPLLP) needs to move forward.
Last night, with regards to the NCOD, we heard Mayor Cunningham state that we need to “bake it into the
code.” This is where the PPLLP needs to concentrate its efforts. The mayor talked about separate zoning
districts that contain an “N” in their label in deference to the the NCOD.
Please see Bozeman Municipal Code Sec. 38.340.050. - Standards for certificates of appropriateness, which
states:
A. All work performed in completion of an approved certificate of appropriateness must be in
conformance with the most recent edition of the Secretary of the Interior's Standards for the
Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and
Reconstructing Historic Buildings, published by U.S. Department of the Interior, National Park
Service, Cultural Resource Stewardship and Partnerships, Heritage Preservation Services,
Washington, D.C. (available for review at the community development department). (Underline
added by me)
The word “must” is important. So are the words “most recent edition.” The most recent edition of the
Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI STDS) are to be applied
to all historic property types, including districts, sites, structures, buildings, and objects. Please see the
Standards for Rehabilitation within the most recent edition of the SOI STDS. It includes new construction.
New construction within a district includes construction of new buildings. This may be where Community
Development Director was misinterpreted the SOI STDS when she stated that they only applied to
modifying historic buildings. There was a time when the SOI STDS used the word “buildings” however that
wording was changed to “properties” including all property types. I suggest the City Attorney look into this.
I worked with the SOI STDS for decades. I am happy to help any of you, including the City Attorney, with
understanding the SOI STDS. Please see 36 CFR Part 68 https://www.govinfo.gov/content/pkg/FR-1995-
07-12/pdf/95-16953.pdf .
Also, residents should not have to use their own resources to evaluate the National Register eligibility ofhistoric properties, including districts. That is the role of the City. Please include this in your document.
Specific comments on the draft Phase 1 PPLLP document:
Page 22: Please add the following dates of important historic preservation milestones (both positive and
negative) to your timeline. Please add where historic preservation is addressed within the current UDC.
Please add where the city commission made changes without public input, such as Subchapter 4B. Please
add the Bendon Adams study and recommendations. I may have missed some other important dates that
needed to be added to this timeline. The important thing is to accurately portray it so that we may
understand how we got into the mess we’re currently in.
Page 24: All of these recent plans and policies may still be realized though with the caveat that they take a
different form once in the NCOD. This is where the PPLLP must show how these goals can be
accomplished with a different form because it’s within the NCOD.
Page 26: The draft document states that recent changes to Montana’s laws in the 2023 legislative session
requires all permit and design reviews to be conducted administratively by city staff and that decisions must
be factually supported and consistent with state and locally adopted standards and criteria. There has been
some controversy on whether this applies to historic preservation. Please add a statement from the City
Attorney on how these 2023 changes apply to, specifically, historic preservation. We need the attorney to
put this in writing.
Page 26: There are many quotes and captioned photos in this draft document that conjure up good feelings.
However, what is the POLICY you propose to cause these to come to fruition? For example, on Page 26,
there is am un-named quote, “As the City explores how to authentically recognize the heritage of the
Indigenous peoples for whom this valley is ancestral territory, it needs to take an intentional approach to
building relationships, listening, and partnerships.” This is very important. Please state how you will honor
this in plan, code, and policy?
Public engagement, “word cloud,” etc.: These graphics may conjure up good feelings about the public
engagement process, however, what the the document really needs is a detailed analysis of public
comments. Better yet, provide a folder with all public comments so we may see what public engagement
yielded. You asked us for ideas. We spent time getting our ideas to you. Now what?
Demolition: This section is one of the most important in the document. If the NCOD allows demolition to
make room for a new, non-compatible building, the historic integrity of the district is eroded.
As an example, on the pages where this document proposes changing the NCOD boundary due to a lack of
contributing buildings, you essentially make the case for how demolition of contributing buildings leads to
the erosion of the NCOD.
Changing the NCOD boundaries:
This is a VERY concerning part of this draft document. Just because the Whittier School may be
abandoned by the Bozeman School District (BSD) doesn’t mean that it should be demolished or that this
area should be excised from the NCOD. If the BSD wants to sell the property to make money, then the
prospective buyer of the property needs to be aware of and held to the policies within the NCOD. They
must make this school work for future adaptive re-uses.
Once the City allows a new building to go into the NCOD, this should not be a reason to incrementally cut
away at the NCOD boundaries. The properties along the trails along the southeast portion of the NCOD
should not be excised out of the NCOD. Instead, the trails and it’s amenities such as vegetation, views, etc.
should be identified as a feature to preserve. Let’s make sure a developer cannot build an incompatible and
towering complex such as what was recently proposed next to the library.
Page 50: Regarding Local Landmark Program: If Bozeman’s Historic Preservation Program and Historic
Preservation Advisory Board is not able to defend historic properties that are protected by the National
Register of Historic Places, how are you going to defend properties that nominated by local criteria?
Role of the Historic Preservation Advisory Board (HPAB): This section is unclear. What are you
proposing? The HPAB must have review authority for any preservation program to thrive. Please have the
City Attorney show, in writing, what the HPAB authority has been in the past, how/why this has changed,
and how the City intends to use it in the future in order to meet code. Why was the Historic Preservation
Officer position moved to be supervised by the Community Development Director? Shouldn’t this position
be separated?
Respectfully,
ZEHRA OSMAN
312 Sanders Ave. Bozeman 59718