HomeMy WebLinkAbout01-13-26 Public Comment - Z. Osman - UDC Update_ Please retain Affordable Housing Bonus Density code provisions in B3From:Zehra Osman
To:Joey Morrison; Douglas Fischer; Jennifer Madgic; Emma Bode; Alison Sweeney; Bozeman Public Comment
Subject:[EXTERNAL]UDC Update: Please retain Affordable Housing Bonus Density code provisions in B3
Date:Tuesday, January 13, 2026 11:55:32 AM
Attachments:Memo re Historic Preservation 11 Jan 2026.pdf
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Honorable Mayor, Deputy Mayor, and Commissioners,
Newly seated Mayor Morrison has committed to prioritize solutions to the affordable housing crisis during
his term. He is exploring ways to develop public housing. I fully support this approach. This is a
commendable goal that will require funding. What an exciting time for Bozeman!
Fortunately, the City's Affordable Housing Bonus Density code provisions were put in place to raise funds
from private developments to address those needs. These provisions allow the City to let developers build
additional floors on their buildings in the B3 above the current building height allowance of 70' in exchange
for paying the City funds for its affordable housing program. A report by a City consultant estimates this
could yield $1 million/floor. This is currently the only primary tool that the city currently holds to extract
affordable housing funds from private developers.
I support Mayor Morrison's goal and propose the following recommendations towards achieving this goal.
With this in mind I strongly encourage the City Commission to take the following actions:
Immediate Action:
As mentioned above, the City's Affordable Housing Bonus Density code provisions were put in place to
raise funds that would make Mayor Morrison's goal of public housing possible. However, the Commission's
December 16, 2025 decision to increase the allowed B3 height to 90' effectively eliminates this sole tool
and foregoes obtaining millions of dollars of Affordable Housing Bonus Density payments from private
developers. This 12/16/25 decision would be enacted on February 1, 2026. This action effectively guts the
City's Affordable Housing Bonus Density Program and ability for the City to raise funds to support
Affordable Housing.
Given the clearly expressed priority of Mayor Morrison and other City Commission members to find ways
to raise funds to address the City's Affordable Housing needs, I strongly encourage the City Commission to
promptly take action to delay or stop the pending increase in allowed B3 building heights before its
pending implementation on February 1, 2026. Let's not give up our only remaining negotiating tool to
raise affordable housing funds from private developers.
No matter what prompted the 12/16/25 decision to eliminate the only tool Bozeman has to fund the building
of public housing and no matter what thoughts one may have on 90' buildings downtown, our city needs this
funding source provided by this provision in the B3.
Short-Term and Long Term Actions:
Under this heading are some ideas that are intended to enhance Mayor Morrison's goal of forming solutions
for Bozeman's affordable housing crisis.
Create walkable nodes or "villages" throughout Bozeman’s city limits, not just in the downtown. I've heard
city officials state that Bozeman's core is where all affordable housing opportunities should be because it is
walkable and workplaces are within walking distance. This is where I submit that all Bozeman residents
deserve to have opportunities to live in a walkable and livable community. I live on the west side of town
which is a huge sprawling sea of houses. We on the west side need to drive everywhere because there has
been little to no opportunities for walkable destinations.
Please consider planning new development to be around multiple walkable nodes throughout all of
Bozeman. These nodes should provide needed destinations at a residential-scale such as small grocers,
shops, cafes -- similar to what is found on the in Bozeman's Northwest side. These nodes should also allow
for diverse housing opportunities nearby that allow residents to be within walkable distance to workplaces,
art studios, day care, etc. Let's change our planning focus to open up opportunities that benefit residents
from diverse incomes throughout all of Bozeman and not just the city core. Let's also support these multiple
walkable nodes with a coordinated public transportation system via an updated Transportation Management
Plan.
Consider concurrent alternative affordable housing solutions in concert with the building of public housing.
In this article, the author proposes a housing strategy that gets around land purchasing costs as a means to
cutting the costs associated with new affordable housing https://kasperbenjamin.substack.com/p/why-more-
housing-wont-deliver-affordability?utm_campaign=post-expanded-
share&utm_medium=web&triedRedirect=true. Below are exciting and practical examples quoted from this
article:
Unlock underutilized space. Allow communities, tenants, and housing associations to
renovate, retrofit, and subdivide existing homes and buildings.
Remove land from speculation. Stop selling land to the highest bidder. Enable municipalities
or public trusts to retain ownership and lease land for affordable housing development at non-
market rates.
Introduce strong regulations. Implement rent controls, ban the purchase of housing you don’t
live in, and phase out ownership models that prioritize speculation over shelter.
Transition private housing into social and cooperative housing. Support models that are not
driven by shareholder profits, but by long-term affordability, democratic control, and care for
residents.
Subsidize renovations, not just new construction. Shifting investment toward improving and
repurposing existing buildings reduces environmental impact, avoids the need for new
infrastructure, and supports a more circular economy.
For All Immediate, Short-Term, and Long-Term Solutions, Let's Honor Our Natural and HistoricEnvironment:
Embrace the concept that we protect and preserve our natural and historic resources while we address the
affordable housing crisis.
It is absolutely possible to build affordable housing while respecting our natural environment
including creeks, wetlands, and trees with environmentally responsible development designs
and practices.
Bozeman's existing existing preservation policy will be revised under the ongoing Landmark
Program update. With regards to this next phase of the Landmark Program Update, I submit
the attached document titled, "Recommended Actions on UDC Implementation and
Preservation Protections drafted by John Amsden of the PRESERVE HISTORIC BOZEMAN
COALITION. I submit that these recommendations serve as a bridge between the UDC
Update and the Landmark Program Update. They also give the community a sound means of
understanding upcoming proposals. Please read the attached document.
(Please post attachment below)
Respectfully,
Zehra Osman59718
PRESERVE HISTORIC BOZEMAN COALITION 1
To: City Commission, City of Bozeman
Subject: Recommended Actions on UDC Implementation and Historic
Preservation Protections
Issue Summary
The City Commission recently adopted, over significant objection and lacking a correct
procedural basis, a revised Unified Development Code (UDC) that includes a maximum building
height of 90 feet in the B-3 downtown district, effective February 1, 2026. This change was
incorporated into the final UDC adoption.(Engage Bozeman) The current code also includes a
new B-3C downtown core zone intended to reflect the historic downtown context.(Engage
Bozeman) At present, the UDC lacks explicit requirements for assessing development impacts
on historic resources in procedural or design standards.
This memo recommends: (1) delaying implementation of the 90-foot as-of-right provision, (2)
adopting five targeted UDC amendments to embed historic preservation protections into the
code, and (3) articulating the principal rationales for these actions directly to the City
Commission.
1. Delay Implementation of “90-Foot as of Right” Provision
The current UDC establishes a 90-foot maximum height in the B-3 district without
accompanying design standards or impact assessment requirements.(Engage Bozeman)
Implementing this as a matter of right height limit absent clear criteria for evaluating context,
scale compatibility, or impacts to historic resources may result in development that materially
alters the historic character of downtown before appropriate safeguards are codified.
A short delay or the establishment of an interim overlay zone in defined historic influence areas
would permit the Commission and staff to:
• Finalize draft historic preservation standards that are compatible with the Community
Plan and UDC.
• Incorporate measurable impact assessment requirements (e.g., shadow/shade
analysis) before approving taller buildings adjacent to historic structures.
• Provide clarity to developers and the public through predictable, codified standards
prior to broad application.
2. Recommended UDC Amendments for Historic Preservation
The following code amendments should be adopted promptly to strengthen the UDC’s ability to
protect historic resources and the character of downtown:
PRESERVE HISTORIC BOZEMAN COALITION 2
a. Mandatory Shadow/Shade Impact Studies
Require applicants proposing buildings in or adjacent to defined historic areas to submit
quantitative shade/shadow studies demonstrating projected shading effects on existing
historic structures and public spaces.
b. Visual Context and Massing Compatibility Criteria
Integrate contextual compatibility standards that require comparative visual analyses of
proposed building massing and scale relative to adjacent historic properties. This should
include elevation renderings and narrative justification tied to historic character.
c. Historic Resource Impact Assessment
Codify a historic resource impact assessment requirement into the development review
process that evaluates potential direct and indirect effects on identified historic
properties, including preservation of defining features and setting.
d. Transitional Height/Step-Down Standards
Adopt transitional height standards that mediate differences in height and scale
between taller buildings and adjacent lower-scale historic properties or residential zones
to preserve contextual integrity.
e. Expanded Design Review Triggers
Extend design review triggers to encompass all development within a defined historic
influence zone around downtown historic resources. This ensures aesthetics, materials,
and overall design quality are considered in relation to historic character.
These amendments anchor historic preservation within the core regulatory framework of the
UDC rather than treating it as an adjunct or advisory consideration.
3. Rationale for Action
Preservation of Irreplaceable Assets
Bozeman’s historic downtown is a unique cultural and economic asset with properties that
contribute to community identity and economic vitality. Without clear contextual controls,
development permitted under the new height limit could compromise these assets.
Regulatory Gap in the UDC
While the UDC modernizes zoning and reorganizes districts (including the B-3C downtown core
district), it currently does not mandate impact assessments for historic resources or context
compatibility standards tied to architectural or scale concerns. These gaps undermine the
Commission’s ability to ensure that large-scale development preserves the essential qualities of
historic downtown.
PRESERVE HISTORIC BOZEMAN COALITION 3
Alignment with Best Planning Practices
Municipal land-use codes in communities with significant historic cores routinely include
shadow/shade analysis, massing compatibility standards, transitional height provisions, and
design review procedures to prevent adverse effects on historic fabric. Adopting similar
standards positions Bozeman’s regulatory framework with recognized best practices.
Predictability and Certainty for Developers and the Public
Codified standards reduce uncertainty in the development review process by articulating
measurable criteria for approval, reducing appeals, and facilitating efficient decision-making.
Balanced Growth and Character Preservation
The Community Plan envisions accommodating growth while preserving the character of
historic areas. Integrating these amendments ensures that the UDC enables development
consistent with both objectives.
Conclusion
Delaying immediate implementation of the 90-foot as-of-right provision, combined with
adopting the recommended UDC amendments, will align regulatory implementation with
community expectations and planning best practices. Embedding measurable historic impact
requirements and contextual standards into the UDC ensures that growth supports long-term
preservation of downtown’s historic character and economic vibrancy.