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Home My WebLink About04-22-25 Public Comment - Z. Osman - Historic Landmark Study, UDC Update, Parks and ForestryFrom:Zehra Osman To:Terry Cunningham; Joey Morrison; Jennifer Madgic; Douglas Fischer; Emma Bode; Erin George; SarahRosenberg; Chuck Winn; elizabeth.darrow@gmail.com; cnholling91@outlook.com; mike@arch118.com;lindasemones@hotmail.com; allycaroline@gmail.com; ashleyharville@yahoo.com; jwebster587@gmail.com;Mitchell Overton Cc:Bozeman Public Comment Subject:[EXTERNAL]Public comment: Historic Landmark Study, UDC Update, Parks and Forestry Date:Tuesday, April 22, 2025 11:53:44 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. (Please include these comments in the public record for the UDC, for Parks and Forestry, and for the Landmark Study. Also, please forward to the City Attorney, as I could not find their email on the website) Honorable Mayor, Deputy Mayor, Commissioners, Historic Preservation Advisory Board Members, and City Staff: During their presentation on April 1, 2025, city staff made an incorrect comment that the Secretary of the Interior Standards for the Treatment of Historic Properties (SOI STDS) was intended to address only alterations to existing historic buildings and that they did not apply to new construction. This is incorrect. I would like to present some important links that support the fact that: The city municipal code references and applies not only the standards within the SOI STDS , it also applies the SOI STD guidelines The SOI STDS absolutely apply to all historic property types, including buildings, structures, objects, districts, and sites. The SOI STDS address the the property and its environment, which includes the building site, setting (district/neighborhood). Within the SOI STDS: “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.” https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1- preservation-rehabilitation.pdf A. Bozeman Municipal Code (Code) Re: Application of Secretary of the Interior’s Standards for the Treatment of Historic Properties: https://library.municode.com/mt/bozeman/codes/code_of_ordinances? nodeId=PTIICOOR_CH38UNDECO_ART3ZODILAUS_DIV38.340OVDIST_PT1NECOOVDIHIPR_S38 .340.050STCEAP "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).” *Please note that the code references the standards and guidelines B. Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI STDS): Here’s what the SOI STDS says about new construction and how the SOI STDS applies to all 5 property types including buildings, structures, sites, districts, and objects: “the revised standards may be applied to all historic resource types, including buildings, sites, landscapes, structures, objects and districts.” https://www.govinfo.gov/content/pkg/FR-1995- 07-12/pdf/95-16953.pdf Regarding Rehabilitation Standard #9: “New additions, exterior alterations or related new construction will not destroy historic materials, features and spatial relationships that characterize the property. The new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment. https://www.govinfo.gov/content/pkg/FR-1995-07-12/pdf/95-16953.pdf “It is possible to add new construction within the boundaries of historic properties if site conditions allow and if the design, density, and placement of the new construction respect the overall character of the site. According to the Secretary of the Interior’s Standards for Rehabilitation – Standard 9 in particular – and the Guidelines for Rehabilitating Historic Buildings, new construction needs to be built in a manner that protects the integrity of the historic building(s) and the property’s setting.” https://www.nps.gov/subjects/taxincentives/new-construction-in-historic-properties.htm "The Secretary of the Interior’s Standards for the Treatment of Historic Properties apply to all grants-in-aid projects assisted through the Historic Preservation Fund (authorized by the NHPA) and are intended to be applied to a wide variety of resource types, including buildings, sites, structures, objects, and districts.” https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1-preservation- rehabilitation.pdf “The section on exterior additions to historic buildings in the Rehabilitation Guidelines has been broadened also to address related new construction on a building site.” https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1-preservation- rehabilitation.pdf Within the SOI STDS: “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.” https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1- preservation-rehabilitation.pdf In honor of Earth Day, please note in the above item that street trees and other landscaping are part of the character of a district or neighborhood. C. The NCOD contains many historic properties that have been listed or determined eligible for listing on the National Register of Historic Places.https://bozeman.maps.arcgis.com/apps/webappviewer/index.html? id=e23fc824ee954e819268e744447d00bb The setting/environment of a historic property is an important part of its character. “new construction so that it does not negatively impact the historic character of the building or its site.” https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1- preservation-rehabilitation.pdf If there is a potential historic district around these properties, who (City, Project Proponent, or residents) has to first evaluate the property’s NR eligibility before determining the effect the project will have and issuing a certificate of appropriateness? It seems to me to be an undue burden to require residents to spend resources to evaluate a property’s NR Eligibility when it’s the developer/project proponent who is proposing and benefitting from the project. If there isn’t anything in the Code that requires identification of historic properties affected by the project, please include this as park of the updated UCD (with funding from the developer or from the City). C. Bozeman Municipal Code (Code) Re: Qualifications of the Historic Preservation Officer: https://library.municode.com/mt/bozeman/codes/code_of_ordinances? nodeId=PTIICOOR_CH2AD_ART5BOCO_DIV6HIPRADBO_S2.05.910ST "B. The preservation officer shall satisfy the Secretary of the Interior's Professional Qualification Standards.” D. Secretary of the Interior’s Professional Qualification Standards: Since the Code references these standards, here is what they say about historic architecture: https://www.nps.gov/articles/sec-standards-prof-quals.htm "Historic Architecture The minimum professional qualifications in historic architecture area professional degree in architecture ora State license to practice architecture, plus one of the following: 1. At least one year of graduate study in architectural preservation, American architectural history, preservation planning, or closely related field; or 2. At least one year of full-time professional experience on historic preservation projects. Such study or experience shall include detailed investigations of historic structures, preparation of historicstructures research reports, and preparation of plans and specifications for preservation projects." Does the Historic Preservation Officer meet these qualifications? They should. City staff stated that the City is considering hiring an architect to revise the guidelines for the NCOD. This person should be a HistoricalArchitect. Respectfully, Zehra Osman 312 Sanders Avenue, 59718