HomeMy WebLinkAbout07-15-26 Public Comment - E. Talago - Public Comment for HPAB re_ NCOD updateFrom:Emily Talago
To:Bozeman Public Comment
Subject:[EXTERNAL]Public Comment for HPAB re: NCOD update
Date:Wednesday, July 15, 2026 12:00:06 PM
Attachments:HPAB Comment NCOD.pdf
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Please see attached public comment and disseminate to the HPAB membership prior to theirmeeting this evening.
With gratitude, Emily Talago.
Members of the Historic Preservation Advisory Board,
Thank you for your continued work on the Neighborhood Conservation Overlay District (NCOD)
update. I am submitting this comment because I believe this process presents an important
policy question that extends beyond architectural guidelines alone.
Since its creation in 1991, the NCOD has functioned as a neighborhood conservation tool: one
that recognizes the relationship between existing buildings, neighborhood patterns, compatible
change, and the broader planning goals of the community.
As the City considers updating the NCOD standards, I believe it is important to be clear about
what is actually being regulated and what policy choices are being made.
Several neighborhood associations recently participated in a focus group with City staff and the
Lakota Group regarding the update. I represented Midtown and worked with representatives
from Northeast, Bogert, Cooper Park, SCAN, and UNA to identify shared priorities. There was
remarkable consistency among neighborhoods about what residents believe this process should
address:
● clearer and more enforceable standards;
● compatibility between existing neighborhoods and new development;
● meaningful standards for mass and scale;
● direct consideration of demolition;
● and material standards where they have the greatest community impact, particularly for
larger projects.
These priorities reflect a broader concern: residents are not asking to prevent change. They are
asking that change occur in a way that respects the places, people, and infrastructure that
already exist.
Going into this process, I understood that the primary challenge was improving an existing
framework. The City has appropriately identified concerns with portions of the 2006 guidelines,
including subjective interpretation and a need for clearer standards. Clear, predictable,
enforceable regulations are beneficial for both property owners and the community.
However, during the focus group discussion, a more fundamental question emerged:
What happens to the existing NCOD standards governing building form, massing, compatibility,
and use?
The NCOD is an overlay district. It exists in addition to the underlying zoning. If those standards
are removed from the overlay, what remains is the base zoning. That is not simply a technical
change. It is a policy decision about what kind of change the City intends to encourage in
established neighborhoods.
During the discussion, staff explained that issues such as (adaptive re)use, height, mass,
density, and use are generally zoning questions and suggested that many of these issues had
already been addressed through adoption of the Unified Development Code (UDC).
That interpretation surprised several neighborhood representatives. Many residents understood
those broader compatibility conversations to have been intentionally deferred during the UDC
process because they would be addressed through the NCOD update and landmark project
discussions.
After the meeting, I spoke with Deputy Director of Community Development Rebecca Harbage
to better understand staff’s position. She reiterated the analogy that base zoning determines the
“cake”— the overall size and shape of development— while the NCOD determines the frosting
"decorations.”
I respectfully disagree with that characterization of what the NCOD has historically represented.
Building form is not simply architectural decoration. In planning, form includes the relationship
between buildings and their surroundings: mass, scale, height, setbacks, intensity, and the way
development functions within an existing neighborhood.
Likewise, use is not simply a zoning category. Use determines how places function. It affects
transportation demand, parking, infrastructure needs, public services, neighborhood stability,
and whether existing patterns can evolve successfully.
The distinction matters because zoning is not only about what something looks like. Zoning
establishes expectations about what can be built, where, and at what intensity. Those
expectations have real-world consequences.
Most development codes eventually create different approaches for greenfield development and
redevelopment within an existing built environment. The NCOD has represented that policy fork
in Bozeman since 1991.
Established neighborhoods are different because people, homes, businesses, streets, utilities,
parks, and community networks already exist. Planning these areas requires acknowledging
existing conditions rather than treating every parcel as if it were undeveloped land.
When zoning expectations significantly exceed what exists on the ground, it can create
unintended consequences. Speculative zoning can contribute to land value inflation because
property values begin reflecting hypothetical redevelopment potential rather than realistic,
community-supported outcomes.
Those hypothetical expectations also have fiscal consequences. Development intensity is not
only a private property matter. It affects the City’s responsibility to plan for and maintain
infrastructure and services, including streets, multimodal transportation systems, parks and
recreation facilities, water and sewer capacity, schools, and public safety.
Zoning for what actually exists today does not prevent change. It allows the City to make
intentional choices about how change occurs and ensures that service planning, investment,
and community expectations remain aligned.
This is why the NCOD conversation should not be reduced to architectural details. Material
standards and design considerations have value, especially for larger projects and historically
significant structures (props Lakota, point well taken). But residents have consistently identified
other issues as their greatest concerns: compatibility, mass, scale, use, demolition, and
predictable change.
In conversations over the past several years through neighborhood meetings, surveys, the UDC
process, and broader community discussions, residents have repeatedly described wanting a
city that evolves with them, not one that erases the context they have helped create.
No one is asking to preserve Bozeman in amber.
The question is whether we preserve the social contract that communities rely on: that if people
invest their lives, homes, and businesses in a place, future planning decisions will recognize
that they already exist.
If the City’s long-term vision for NCOD neighborhoods has changed, that conversation deserves
to happen openly and intentionally. It should not occur as an unintended consequence of
reorganizing design guidelines.
I respectfully encourage the Historic Preservation Advisory Board to consider the full role the
NCOD has played since 1991, not only as a tool for architectural preservation, but as a
framework for neighborhood conservation, compatible change, and responsible planning.
The questions before us are not simply “What should buildings look like?”
They are:
What is the NCOD intended to conserve?
What kind of change is the City encouraging in established neighborhoods?
And how do we ensure that growth benefits the community without externalizing its costs?
Thank you for your consideration.
Emily Talago