HomeMy WebLinkAbout11/08/2017 - Landmark Preservation Commission - Agenda - Work SessionMeg Dunn, Chair City Council Chambers
Per Hogestad, Vice Chair City Hall West
Doug Ernest 300 Laporte Avenue
Bud Frick Fort Collins, Colorado
Kristin Gensmer
Dave Lingle
Mollie Simpson
Alexandra Wallace
Belinda Zink
Fort Collins is a Certified Local Government (CLG) authorized by the National Park Service and History Colorado based on its
compliance with federal and state historic preservation standards. CLG standing requires Fort Collins to maintain a Landmark
Preservation Commission composed of members of which a minimum of 40% meet federal standards for professional experience
from preservation-related disciplines, including, but not limited to, historic architecture, architectural history, archaeology, and urban
planning. For more information, see Article III, Division 19 of the Fort Collins Municipal Code.
The City of Fort Collins will make reasonable accommodations for access to City services, programs, and activities and will make
special communication arrangements for persons with disabilities. Please call 221-6515 (TDD 224-6001) for assistance.
An audio recording of the meeting is available upon request.
Work Session
November 8, 2017
5:30 PM
• CALL TO ORDER
• ROLL CALL
• THE REGULAR MEETING FOR NOVEMBER 15TH HAS BEEN CANCELLED, SO THERE WILL BE
NO REVIEW OF MEETING AGENDA ITEMS.
• POLICY AND LEGISLATION
o Discussion of Areas of Adjacency and Compatibility
The purpose of this item is to discuss the codes and processes related to areas of adjacency
and compatibility criteria for the review of new construction abutting or adjacent to historic
properties.
• BOARD TOPICS
o LPC Work Plan - Progress and Priorities
The regular recurrence of this discussion item is intended to provide the Commission with the
opportunity to measure ongoing progress and identify action items.
• OTHER BUSINESS
• ADJOURNMENT
Landmark
Preservation
Commission
DATE:
STAFF:
November 8, 2017
Karen McWilliams, Historic Preservation Planner
WORK SESSION ITEM
Landmark Preservation
Commission
SUBJECT FOR DISCUSSION
Discussion of Areas of Adjacency and Compatibility
EXECUTIVE SUMMARY
The purpose of this item is to discuss the codes and processes related to areas of adjacency and compatibility
criteria for the review of new construction abutting or adjacent to historic properties.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
At this Work Session, the LPC will be discussing Clarion, Associate’s analysis of the area of adjacency
pertaining to the review of new construction, used for evaluating compliance with LUC Section 3.4.7.
The Commission will also be asked to consider what criteria helps to ensure compatibility with historic
buildings. The Commission’s comments will be provided to Clarion and used to help develop tailored
solutions that best support Council’s policies.
Questions for discussion include:
• What are the most significant compatibility criteria?
• Which compatibility elements are most important for responding to abutting historic buildings?
• Which compatibility elements are most important for responding to other nearby historic
buildings/general character?
• Is there a hierarchy of importance for compatibility strategies?
• Is a standardized Area of Adjacency desirable, and if so, what should that look like?
BACKGROUND / DISCUSSION
Building upon the comprehensive review of historic preservation policies completed in 2014, the
Historic Preservation Division has contracted with Clarion Associates to analyze the relevant codes and
processes. This analysis, which will conclude in early 2018, will examine traditional processes, such as
landmark designation, design review of designated buildings and districts, and the review of demolitions
or alterations of buildings 50 years or older, as well as emerging issues important to the community,
such as identifying appropriate and compatible infill development.
ATTACHMENTS
1. Clarion Draft Memorandum on Adjacency (DOCX)
2. CAC Nov 1, 2017 Meeting Draft Minutes (DOCX)
3. Staff Presentation - Area of Adjacency (PDF)
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Planning | Zoning & Land Use | Real Estate | Sustainability & Resiliency
Clarion Associates
303.830.2890
621 17th Street, Suite 2250
Denver, CO 80293
www.clarionassociates.com
MEMORANDUM
TO: Karen McWilliams, Historic Preservation Manager, City of Fort Collins
FROM: Matt Goebel, Clarion Associates
DATE: November 1, 2016
RE: Defining “Adjacency” in the Preservation Ordinance
The City of Fort Collins Department of Historic Preservation requested that Clarion Associates conduct
research related to a relatively new provision in the Land Use Code that requires heightened review of
projects in areas “adjacent” to a designated or individually eligible historic resource. The research
assignment includes:
Research into best practices, specifically other communities that have addressed this issue;
Preparation of a memo summary of research findings, including a recommended approach and
rationale for Fort Collins; and
A conference call with staff to present the research findings and recommendations.
Background
Sec 3-4-7 of the Land Use Code is part of a set of general development standards that apply to all
development in Fort Collins. It is intended to ensure that, “to the maximum extent feasible,” both
historic resources are preserved and incorporated into new development projects, and also that new
construction respects established historic character of both the immediate development site and the
“surrounding neighborhood.”
Subsection 3-4-7(B) states: “New structures must be compatible with the historic character of any such
historic property, whether on the development site or adjacent thereto.”
Further, subsection (F)(6) states that, “In its consideration of the approval of plans for properties
containing or adjacent to sites, structure, objects or districts that: (a) have been determined to be or
potentially be individually eligible for local landmark designation or for individual listing in the National
Register of Historic Places or the State Register of Historic Properties, or (b) are officially designated as a
local or state landmark or are listed on the National Register of Historic Places or (c) are located within a
officially designated national, state or local historic district or area, the decision maker shall receive and
consider a written recommendation from the Landmark Preservation Commission unless the Director has
issued a written determination that the plans would not have a significant impact on the individual
eligibility or potential individual eligibility of the site, structure, object or district.” (italics added)
2.1.a
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.2
For purposes of applying both of these provisions, the term “adjacent” is defined in Section 5.1.2:
“Adjacent shall mean nearby, but not necessarily touching. The determination of ‘nearby’ shall be made
on a case-by-case basis, taking into consideration the context in which the term is used and the variables
(such as but not limited to size, mass, scale, bulk, visibility, nature of use, intensity of use) that may be
relevant to deciding what is ‘nearby’ in that particular context. Adjacency shall not be affected by the
existence of a platted street or alley, a public or private right-of-way, or a public or private transportation
right-of-way or area.”
The operative term is “nearby,” which we understand has been administered to date on a case-by-case
basis per the “adjacent” definition. We understand that staff typically suggests a geographic area to use
for each project, but the staff recommendations are sometimes expanded by the preservation
commission, which has reportedly led in some cases to unpredictability and create some frustration for
applicants. We understand there is some frustration with the subjectivity and lack of objective
parameters. To provide more consistency and predictability, the city is looking for a metric to
supplement or replace the “nearby” term.
The remainder of this memo first reviews approaches to defining “adjacency” in other communities,
then suggests a recommended approach for Fort Collins.
Tucson, Arizona: Unified Development Code (esp. Downtown Area Infill Incentive District)
As background for this project, we first researched how other preservation ordinances address the issue
of defining “nearby,” or “adjacent,” or set other triggers for heightened review of major projects that
may impact historic character. We found a limited number of good examples right on point. Few
preservation ordinances attempt to regulate new construction based on the potential impact to
proximate historic resources. By far, the most common approach is to limit the review of projects to
actual designated resources.
However, by expanding our review to zoning ordinances generally—beyond the context of historic
preservation—we identified a number of potential approaches for Fort Collins to consider.
The Tucson Unified Development Code is a complex document with a relatively high number of districts
and detailed overlays, but it provides one of the more comprehensive examples we found of elaborating
on the “adjacency” concept. The term “adjacent” is defined generally as: “Two or more parcels or lots
sharing a common boundary or separated by an alley or other right-of-way 20 feet or less in width.
Parcels or lots having only a common corner are considered adjacent.”1
More detailed definitions apply in specialized areas of the city. The Infill Incentive District is a special
optional district (with multiple subdistricts) intended to encourage sensitive redevelopment in the
historic downtown. Within this district, “adjacent” means: 2
o Two or more parcels or lots sharing a common boundary or separated by an alley or a local
or arterial street 30 feet or less in width. Parcels or lots having only a common corner are
also considered adjacent.
o Where the development parcel is an interior parcel, adjacent lots include all residential lots
on either side of the development parcel, those lots fronting on the same street in the same
block as the development parcel, and all those lots on the opposite of that street.
1 Tucson Unified Development Code Sec. 11.4.2.
2 Tucson Unified Development Code Sec. 5.12.
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.3
o Where the development parcel is a corner lot, the term “adjacent” includes all the
residential corner lots or developments diagonally opposite the development parcel,
fronting on the same two streets in the same block, and on the opposite sides of those
streets.
o Where the development parcel is adjacent to a Historic Preservation Zone (HPZ), the term
“adjacent” includes all lots across the street and diagonally across from the development
parcel.” (see figure below)
The Tucson approach illustrates one important feature in most of the ordinances we reviewed that is
different from the Fort Collins current approach: the existence of a street often is used as a formal
demarcation line for purposes of establishing adjacency. While the presence of a street should not
always be a determining factor, the approach does help provide certainty and predictability. The Fort
Collins approach, on the other hand, says that the presence of a street should not be a factor in
determining adjacency.
Tucson’s Downtown Area Infill Incentive District (Sec. 5.12) elaborates on the adjacency concept in the
context of protecting historic resources. The district is intended to “provide for appropriate transitional
design standards where the development or expansion of a use is adjacent to existing single-family
residential development.” A particular goal is to “protect historic structures and historic neighborhoods
and existing residential neighborhoods from potential negative impacts of new development.” The
district applies specific development standards—including lot dimensions, building heights, permitted
uses, design review procedures, and parking requirements—to properties within the four designated
subdistricts within the IID.
A noteworthy feature of the IID is that it distinguishes between major and minor design review based in
part on the location of the project. Triggers for major design review include the following, in part:
Structures that are higher than
o 4 stories or 49 feet, or
o 2 stories or 25 feet if adjacent to single-family residential or duplex dwellings
The development is located at any one or more of the following locations:
o At an intersection of one or more arterial streets
o Adjacent to or across from:
A detached single-family residential or duplex dwelling, or
A historic or contributing structure
o On a vacant Historic Preservation Zone (HPZ) or Neighborhood Preservation Zone (NPZ) parcel
o On a multi-zone parcel
o Within, or adjacent to an HPZ or NPZ, or a National Register Historic District, or any combination
of the three.
2.1.a
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.4
All projects that do not meet any of the above criteria are considered minor. Major projects are
considered and given a recommendation by a Design Review Committee and decided by the Director;
minor projects are decided by the Director with no committee evaluation or recommendation. Both
categories of projects are required to hold a neighborhood meeting and are reviewed by the city’s
Design Professional. Both types of projects are subject to the same development standards, which
address site and building design.
New development that is either adjacent to a preservation zone or adjacent to a listed or eligible
structure is also reviewed by local historical commission plans review subcommittee for compliance with
the design requirements of the applicable subdistrict and for general “design compatibility,” which
requires:
“New development must be designed to complement and be compatible with the architecture
of adjacent historic properties.
Compatibility with adjacent historic structures is to be achieved through architectural elements
such as building setbacks, building step-backs, textures, materials, forms, and landscaping.”
Defining Adjacency in Other Communities
Beyond Tucson, we researched a number of other ordinances to see how the communities approach the
issue of defining “adjacency” near historic areas. Many helpful examples can be found in ordinances that
include “transitional design standards,” which are used to help manage the intersecting areas of
different intensities or character, such as where mixed-use or nonresidential development abuts
residential neighborhoods (which sometimes include historic resources). The tools used in such
instances help illustrate techniques that may be used to manage land use impacts in transitional areas.
Jacksonville, Florida: Urban Transition Design Standards3
Applicability: The code identifies character areas (including historic areas) within certain overlay
districts. “Compatibility requirements” apply if new development is adjacent to a Historic
Residential Character Area. (Plus, additional standards apply to development that lies solely within
the Historic Residential Character Areas.)
“Adjacent” defined: Any non-residential development that has a rear or side yard adjacent to at
least one single-family use. Also, abutting: “[A]djacent to or across the street from single family
residential.” [in re: building width of attached residential units and complementary rooflines]
Standards: Specific development standards—including lot dimensions, building heights, permitted
uses, design review procedures, and parking requirements—applicable to properties within
designated character areas. “Compatibility requirements” (see 656.399.21) address:
o Buffer. A buffer shall be utilized when any use other than a single family residential use
abuts another single family residential use. (alley or landscape buffer)
o Lighting. The proposed development shall also control the effects of lights from automobiles
or other sources.
o Building Design. The side of the building that is facing or backing up to any residential
development must be treated with the same architectural design standards as the front of
the building.
o Historic Residential Character Area: Supplemental standards address mass and scale of new
buildings, parking, rooflines, garage apartments, and interior apartments.
3 656.399.24
2.1.a
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.5
Breckenridge, Colorado: Conservation District4
Applicability: Conservation district includes Transition Character Areas, which are outside the
Historic District and “serve as buffers from impacts of development in newer areas of the
community.” Few historic buildings are located here, but “the Town does wish to direct
development such that it will contribute to the traditional character of the core of the community.”
“Adjacent” definition. Not formally defined. Various standards use the term “adjacent” to refer to
any properties that are immediately next door. Also, an overall theme of the standards is to consider
impact on any boundary, or edge, of the historic district. There are no relative distance references to
help define adjacency, though the overall boundary of the character area effectively sets the
distances. (Example: “New buildings should step down in scale along the edges of properties that lie
adjacent to smaller historic properties.”)
Standards address:
o Lot dimensions, building heights, permitted uses, design review procedures, and parking
requirements.
o Standards designated “high-priority standards” must be met to be considered in “substantial
compliance.”
o There are seven different transition character areas with slightly tailored standards.
o Some contextual standards (e.g., “use building setbacks that are similar to those in
comparable neighborhoods.”)
Biloxi, Mississippi5
Applicability: Manage the transition from more intense development (anything from duplexes to
multi-story and multi-unit residential, plus nonresidential) to single-family detached development.
“Adjacent” definition. Not formally defined. Applied as “abutting or across a local street, driveway,
or alley from an existing single-family detached dwelling or vacant land zoned RE, RER, S-, or AHO.”
Standards address:
o Setbacks: New, more intensive development shall be consistent with those with other
buildings on the block face and across the street. Building setbacks shall vary not more than
10 percent from those of adjacent buildings.
o Height: New building height is based on relative distance references:
Building abutting a single-family detached dwelling: same height
Building within 150 feet of a single-family detached dwelling: 35 feet max
Building within 150 feet of vacant land in certain zone districts: 35 feet max
Any other building allowed to exceed 35 feet must be broken into “modules or
wings,” with the smallest portions located nearest the abutting SF detached
building.
o Building design: exterior colors, architectural features, porch orientation, etc.
o Roof forms
o Use intensity: for multi-building development, continuum must be established, with least-
intensive use located nearest to abutting single-family detached development.
4 Handbook of Design Standards for the Transition Character Areas of the Conservation District. 2012.
5 Sec. 11: Transitional Standards
2.1.a
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.6
o Service and loading area location and screening
o Parking and driveways location
o Operational impacts: location of drive-throughs, outdoor activity areas, vending machine
placement, hours of operation, etc.
Dallas, Texas: Historic District Transition Area6
Applicability: The PD 877 is designed as a transition area to “recognize the area’s unique identity as
a bridge” between the State Thomas Historic District and several other neighborhoods, including
Uptown, Oak Lawn, and Downtown.
“Adjacent” definition. Not formally defined, and there are no specific distance references. The
district boundaries set the area within which the transitional standards apply.
Standards address: Specific development standards—including lot dimensions, building heights,
permitted uses, design review procedures, and parking requirements—applicable to properties
within a designated PD.
La Conner, Washington: Transitional Commercial Zone7
Applicability: The Transitional Commercial Zone District lies “at the intersection of commercial,
residential, public and industrial uses and at the southern terminus of the National Historic
Preservation District (HPD). “…the zone must respect and carry forth the design requirements of the
HPD to avoid compromising the values of the HPD.”
“Adjacent” definition. Not formally defined. The district boundaries identify the area within which
the transitional standards apply. (Elsewhere in the code, “adjacent” means within 100 feet of
proposed project site boundaries for steep slopes; 25 feet of a nontidal wetland; and 300 feet of
lands classified agricultural.)
Standards address:
o Process: Any development proposal must undergo design review for compliance with the
Historic Preservation District (HPD) guidelines by the planning commission. Design review
purposes include “to ensure that new construction and additions are consistent with the
scale, forms, and proportions of the adjacent Historic Preservation District.”
o Uses: Uses must “take into account the transition from and to these diverse uses”
o Design/development standards: Specific standards apply, including lot dimensions, building
heights, and parking requirements. Some specifically require compliance with the HPD
standards, including front setbacks on some streets, or require new development to “have
the appearance of” buildings in the historic district.
6 PD 877 Sec. 51P-877-103(a).
7 UDC Sec. 15.36.
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.7
Other Examples (Without Transitional Design Standards)
Beyond the examples noted in detail above, we also reviewed other preservation ordinances and/or
general land use codes that we thought might be useful based on the reputation of the community. Few
of these other examples contained provisions especially relevant examples for this assignment.
Most of these codes do define “adjacency,” most typically like Longmont, CO: “Adjacent means abutting
or separated only by a public street, alley, or private drive…. Abutting means bordering or touching, such
as sharing a common lot line.” 8 This approach allows the adjacency situation to cross a street, as is the
case in Fort Collins. The Philadelphia approach is similar: “To touch or share a contiguous boundary or
border, or to be separated by an alley, driveway, or street.”9
Denver is an outlier and takes a different approach in terms of the presence of a street, saying that a
street negates adjacency: Adjacency means “sharing a zone lot line or being separated only by an alley.
Named or numbered streets destroy adjacency, except where specifically allowed by this Code.”10
Other codes reviewed included Boulder, Glenwood Springs, Golden, and Greeley; we did not find
provisions especially relevant or helpful to this assignment in these codes.
Recommendations
Moving forward, we understand that Fort Collins is looking to provide more consistency and
predictability in its evaluation of new construction in areas near historic resources. Below are several
recommendations for the city to consider. Each of these could considered independently (i.e., they do
not all have to be embraced in order to improve the ordinance).
Refine the Definition of “Adjacency.” The current Fort Collins definition of “adjacency” is actually better
than many of the models we reviewed in that it captures various contextual considerations like size,
mass, scale, etc. The main flaw is the lack of specific, objective parameters for “nearby” to identify
specifically where those contextual issues should be considered. The quickest, simplest way to address
this problem and improve the definition is to remove “nearby” and replace it with specific lot identifiers
that frame the area within which adjacency applies. Specifically, we recommend adopting the Tucson
definition of “adjacency” that appears earlier in this memo, which identifies specific lots that should be
addressed. Or, the city could simply set a distance marker (e.g., defining any adjacent lot as one within
500 feet of the subject property). However, we recognize that both of these fixes could result in a
smaller area than is currently being used by the LPC, so the below approach should be considered.
Define a project’s “Radius of Impact.” Taking the idea to the next level, the idea of “adjacency” could be
extended beyond the immediate lots through development of a “radius of impact” concept, which
would be developed for each project based on relative project size and scale. If a designated or eligible
historic resource falls within the radius of impact, the project would require LPC review. Projects with
greater impacts should have a larger radius of impact; i.e., the city should cast a broader net around
more significant projects when considering the potential impact on historic resources.
8 LDC Sec. 15.10.020
9 Zoning Code Sec. 14-203(4).
10 Zoning Code Sec. 13.3.
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.8
Developing a radius of impact should be based on a list of objective criteria. A helpful model for such a
list might be the list of thresholds for “major design review” in Tucson. The list below is a slightly tailored
version of the Tucson list. New construction meeting any of the following criteria would be considered
“adjacent” and require LPC review:
Height: Structures that are higher than
o 4 stories or 49 feet and within 500 feet of a designated or eligible historic resource; or
o 2 stories or 25 feet if within 1000 feet of a designated or eligible historic resource
Building Size/Massing: Structures that are
o More than 5000 square feet gross floor area and within 500 feet of a designated or
eligible historic resource; or
o At least 1000 and no more than 5000 square feet gross floor area if within 1000 feet of a
designated or eligible historic resource
Any development located at any one or more of the following locations:
o Adjacent to a designated or eligible historic resource (based on the new definition of
“adjacent” recommended above).
The list is based primarily on height and building size as indicators of impact. Other potential criteria
might be use type (e.g., any commercial use might have a greater radius than a residential use), and/or
operational impacts (e.g., presence of drive-through). Staff may have additional suggestions for criteria
that could bump a project above the threshold requiring LPC review.
Tailor the Level of Project Review. One thing the Tucson example illustrates is a helpful distinction
between major and minor projects, which offers a tailored review based on the perceived impacts of the
project. We do not believe that this option is currently available in Chapter 14 of the Fort Collins
ordinance. There is just a “LPC review” if new construction is “adjacent” to a historic resource. However,
a tailored approach would offer some advantages. For an “intensive” or “major review,” the LPC might
be authorized to conduct a more detailed review of the proposed development and its physical
relationship to the historic resource. For a “minor project,” the review might be capped by the number
of issues the LPC would be authorized to address, or by the time allowed for LPC review. Or, the review
might be by the LPC (with a public hearing) for major projects and by the staff for minor projects.
In our preliminary conversations, staff mentioned the idea of a matrix tool that would provide specific
measurements to define “adjacency,” with, for example, taller and/or more massive buildings requiring
more in-depth review. The matrix concept has merit and could be a tool to illustrate this type of
calibrated review. It would build on the list of threshold criteria suggested above. The approach should
account for a range of potential approaches based on project scale.
Minor Review Major Review
Height
Above 2 stories or 25 feet Not adjacent but between 500 to
1000 feet of a designated or eligible
historic resource
Not adjacent but within 500 feet of
a designated or eligible historic
resource
Up to 2 stories or 25 feet Not adjacent but between 200 and
1000 feet of a designated or eligible
historic resource
Not adjacent but within 200 feet of
a designated or eligible historic
resource
Building Size/Massing
More than 5000 square feet gross
floor area
Not adjacent but between 500 to
1000 feet of a designated or eligible
Not adjacent but within 500 feet of
a designated or eligible historic
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.9
Minor Review Major Review
historic resource resource
Up to 5000 square feet gross floor
area
Not adjacent but between 200 and
1000 feet of a designated or eligible
historic resource
Not adjacent but within 200 feet of
a designated or eligible historic
resource
Other?
Even if the city does not embrace the major/minor distinction at this time, the matrix approach could
potentially be adapted to the list of threshold criteria above (e.g., by keeping height and building size in
the X axis and putting distance from the resource in the Y axis.) Or, different columns could set different
radii for designated versus eligible projects. We did not come across an exact approach like this in our
research (or anything approaching it), but would be happy to brainstorm other variations with staff.
Consider Alternative to “Maximum Extent Feasible.” The current 3-4-7 requires compliance to the
“maximum extent feasible” for all projects. This term is defined in the code as “no feasible and prudent
alternative exists, and all possible efforts to comply with the regulation or minimize potential harm or
adverse impacts have been undertaken.” While this is not uncommon, it is the only option in 3-4-7, and
it is a relatively strict standard that provides little opportunity for more flexibility.
Another way of calibrating the level of review (assigning different levels of review to different types of
projects based on relative impacts) would be to introduce an alternative, slightly looser definition of
compliance. For example, we have sometimes used the term “maximum extent practicable” as a
stepped-down version of “maximum extent feasible.” This is defined as: “Under the circumstances,
reasonable efforts have been undertaken to comply with the regulation, that the costs of compliance
clearly outweigh the potential benefits to the public or would unreasonably burden the proposed
project, and reasonable steps have been undertaken to minimize any potential harm or adverse impacts
resulting from noncompliance with the regulation.”
This new, stepped-down standard could potentially be used to allow a little more flexibility for certain
projects that are not quite as sensitive as others – perhaps because they are located farther from a
historic resource, or because the resource itself is not as sensitive, or because compliance with the
particular standard is not as important as compliance with other standards.
Clarify Applicability. Regardless of how the city chooses to ultimately better define “adjacency,” we
should emphasize that the overall applicability of the current Sec. 3.4.7 is unclear and should be
tightened up – specifically, the provisions relating to new construction. The final sentence of 3.4.7(B)
clearly is intended to apply to development projects that include designated resources or potentially
eligible resources (as determined by the Director). We believe that the intent is to also apply this
provision to development sites that do not contain designated or eligible resources, but are merely
“adjacent” to such resources. However, the exact language is ambiguous. The title of subsection (B) is
“General Standard,” implying that the section defines the overall applicability of 3.4.7. And the
introductory sentence of (B) states that the section only applies to projects on the actual development
site, not to adjacent sites.
Reading 3.4.7(B) in conjunction with (F)(6) suggests the city’s intent is to regulate new construction on
development sites that do not contain designated or eligible historic resources; but again, the language
is ambiguous in our view and should be clarified.
2.1.a
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Memo – Ft. Collins Research, Adjacency, p.10
Rather than implying applicability through the purpose statement and the “general standard,” we
recommend that the city draft a new a new, clearer statement of applicability clearly for all of 3.4.7. It
should include the city’s preferred approach to the “adjacency” issue, as discussed above.
Define Other Key Terms. Beyond “adjacent” and “nearby,” it is worth highlighting other key terms in
3.4.7 that appear to be undefined and have the potential to lead to inconsistencies in interpretation and
enforcement of these standards. In particular, “significant impact” in 3.4.7.(F)(6), which is the basis for
the Director’s determination of whether development plans would affect a designated or eligible
historic resource. And, some standards require new development features to be “in character” with
those on surrounding historic resources, though this term appears to be undefined.
2.1.a
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Attachment: Clarion Draft Memorandum on Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
CAC November 1, 2017 – Areas of Adjacency and Compatibility
I. Should we add more time to the discussions? Are you getting all the time you really need?
Majority felt that we do need time.
Majority felt that we should extend the meeting for thirty more minutes.
2. Review of Action Items to Date: Have we accurately captured your thoughts?
Karen: Overarching question—is this working for you? Do you feel that you are getting the
opportunity to provide input? Do you feel your voice is being captured appropriately?
Matt: feels that we should review all of Clarion’s recommendations one by one with an informal
vote.
Karen: Will highlight action items that relate to Clarion’s recommendations. We have a list for
staff and LPC as well. We are organizing these into immediate, mid-term, and long-term
Meg: Would like the action items organized topically
Chris: Can we take the 100 items and categorize into our goals? For example, all that work
toward streamlining or goals that we have already established.
Lucia: On the action items, they are a compilation of comments or something that the whole
group has agreed upon?
Karen: These are captures of comments and then start addressing them. We want to make sure
we’ve captured the comments accurately.
Lucia: So these are individual comments that will be reviewed as a group?
Tom: These are comments and not a fully agreed upon set of action items. We will have to
review as a group.
Sherry: Clarification on timeline?
Karen: Discussed timeline and process, including LPC’s review and formal input later by both LPC
and P&Z.
Jennifer: When it comes to P&Z, we should do a joint meeting with LPC
Karen: If I have missed any comments, please email me and make sure I have your comments so
I have your voice while I craft the action items.
3. Spencer: Update on integration-team working on NCB/transition area codes and Downtown.
This is using Article 4 as a jumping off point. They are also using Downtown Plan as jumping off
point. They are using character sub-districts to inform discussion—some re-zoning happening,
much in line with structure plan. Objective is to be more streamlined and using a form-based
idea—not wholly form-based, but using things like street typology. Critically looking at how NCB
areas with compatibility and integration of new buildings. Making the conversation less vague,
looking for resolution on compatibility with densification. Once they have some solid content for
people to respond to, they will be doing outreach . They are working with Peter Park and Tryba.
Karen: AIA presentation, please come.
Per: Will change in code eventually inform the rest of the LUC?
Spencer: It has yet to be determined. There is probably a full code re-write in the near future.
The work that we are doing, we are looking to do the best we can for the Downtown area—if
our ideas relate to the rest of the City, that would be great, but we do not want to dilute the
uniqueness of the character of Downtown. There could be elements that translate to the rest of
the LUC. We are not doing a fully form based code. We are taking things that are applicable and
using those. It is not a dogmatic, plug and play code. We are looking for street typology/frontage
character as an organizing structure. A lot is still to be determined.
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Jennifer: So many pieces and players doing their own thing that we may be all going in all
different directions. I am not feeling that we are coordinating very well—I don’t see it as a
citizen, maybe you are doing it as staff, but I am worried we will come to different conclusions.
Karen: Next Thursday there is a joint P&Z/LPC meeting about these efforts. Part of the issue is
that our section of the code has not been integrated into the rest of the code. It often comes as
a surprise to the developer.
Spencer: A lot of the conversations we are having with our consultants is more fundamental .
We have a limited budget so some is being done in-house ie modeling. We do imagine our
consultants highlighting difficult spots in our Downtown to make sure it works. Overall
compatibility is being addressed. It’s really challenging, but that’s the aim.
Karen: What I’m hearing is that you are looking for more coordination between the groups?
Lucia: Could we see the products Spencer’s team is working toward?
Spencer: We will have deliverables soon, looking at about a month out. We are hoping to have
stuff to respond to then. We want to make sure this conversation doesn’t go too far into the
rabbit hole. We want you to be looking at this through the lens of historic perseveration and
compatibility.
Karen: Coordination of meetings? Would CAC like more meetings with different groups to do
that?
Chris: No, data transfer. We just want their information.
Jennifer: There’s also DRAC happening. We have so many important, challenging projects going
on and it feels a little separated. I want to make sure it is integrated.
Spencer: We are coordinating. We are making sure we’re all coming together. It’s an inter-
related dance.
Tom: I think something else is that the transitional standards have been lagging—it’s just now
starting to ramp up. So now the two are just now starting to merge. This is actually perfect
timing.
4. Maren’s presentation: Area of Adjacency.
What are some of our options for creating predictability? What are the compatibility elements?
Understanding the spatial piece of area of adjacency requires looking at some elements of
compatibility.
Karen: The Clarion report in front of you is one that was done a year ago. We have asked them
to delve more deeply into the topic now. I consider this Area of Adjacency lite—this is a draft of
what they will come up with next month.
Maren: To remind everyone, we are talking about development review. This is NOT design
review of infill inside historic districts. Entire LUC informs compatibility. LPC makes a
recommendation to the decision maker using 3.4.7—respect historic character in new
construction. Adjacent means nearby, not necessarily touching. The area of adjacency is
determined case-by-case. We are investigating ways to make that more predictable and
transparent.
Maren: Which compatibility elements are more important? What are the special
considerations? That’s what we need to talk about today. How is that review/comment process
different than our general standards? The scope needs to be made more predictable. We also
need to find a balance between prescription and flexibility. What needs to be specific and what
needs to remain flexible? And consider proximity. Where do the criteria apply spatially? There
are differences between abutting properties and nearby properties.
Chris: What’s the goal of area of adjacency?
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Maren: Identify the significant historic properties in the area—most are designated, but can also
include those that are individually eligible. This identifies those resources that are going to
remain, that will continue to provide context. We talk about new construction being a good
neighbor, whether it’s historic or not. It’s about site design and how the buildings relate to each
other. The idea there is that we are identifying important historic character and how new
construction can be a good neighbor.
Chris: Clarion found that most communities don’t do this. Why are we?
Council implemented this process in 2014.
Maren: Is there a difference between abutting or nearby?
Sarah: It’s getting to the historic integrity question. I think it’s dangerous to set a specific
boundary. For one property, a four story office building might work and some it won’t. I think
there needs to be flexibility in defining area.
Per: Area of adjacency provides a context to the new construction. They don’t exist by
themselves. They set up the setting of the new buildings. I agree with Sarah. To say it’s two
blocks square isn’t feasible.
Matt: I’m intrigued by what Sarah said. You’re referring to Secretary of Interior definitions—
aspects of integrity. I don’t think that’s what we do today. There’s no finding of impact to those
aspects of integrity when LPC looks at infill projects. Is it the elements of integrity that we’re
talking about? I think that is far more predictable for applicants.
Sarah: It’s about defining a process. What adversely affects a historic property? How can we use
the aspects of integrity? Does it interrupt important view sheds? Affect setting? Affect
association? Even though those characteristics would be different—here is a very clear process.
Lucia: You can’t have something completely open ended because it can cause arbitrary
decisions. We need limits. I think we need to develop something that is based on proximity.
What is it doing to things even though it isn’t immediately effect? What are those effects on
each kind of property? We can’t have something entirely open.
Meg: Immediately important: horizontal alignment, windows for abutting properties. Further
away it’s less about details, but mass and scale. How does it compare to the others?
Chris: But isn’t that already talked about in 3.4.7?
Meg: Not with abutting/nearby defined and proximity
Karen: Area of adjacency is meant to identify area of effect. It’s the starting place for assessment
of properties.
Chris: Do we have examples of projects that used nearby rather than abutting?
Per: Example of park-like setback, LPC said to do that they would expand Area of Adjacency,
applicant was unhappy
Matt: City’s area of adjacency goes past Webster definition. When you start to add additional
meaning to a word, you enter risk zone of idioglossia-language only known to insider. It needs to
be understood by outsider. Given that, if you have a property that fits under Webster definition
of adjacency, if it doesn’t negatively affect those immediately adjacency?
Meg: Change words, use proximity and adjacency. Doesn’t change process.
Jennifer: What if we used area of notification? We could use the same logic to use bounds of
area of adjacency? Neighborhood meeting notification area could be limit. The 800 ft would be
area of proximity.
Lucia felt that was too wide of an area. That’s a lot more than what’s being done today.
Jennifer: People in notification area because city feels there is an impact and they have the right
to comment. Logical to use same area – how can they be affected under one process but not
under other.
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Maren: put a pin in the number question, it will come up later. Slide on Character of the “Area of
Adjacency”—these are ideas that have already come up. These have come up over the course of
the last five years. One of the things we want to establish is a set of criteria—what’s important
for historic compatibility? Some of these things are for general compatibility, but what rises to
the top for historic compatibility? Does anything jump to mind that you would think should be
added or respond to?
Lucia: I think the one that has caused the most difficulty has been size/mass/bulk/height.
Developers can deal with setbacks/stepbacks. Are we supposed to be doing build out according
to Downtown Plan or does historic go further? How do we build the downtown we want if we
can’t go up higher/bigger? Uncommon. What is the City standard on this?
Jennifer: Would lay down in front of the bulldozer to retain criteria for size/mass/bulk/height.
That’s the most important. That is the one that will make or break us for the historic downtown.
It needs to be defined, but needs to be defined with the importance of historic downtown
valued more than new construction. You can’t make it smaller by articulation. Sometimes the
answer is that it’s just too big. Just because there’s enough space on lot doesn’t mean it should
get the go ahead. Somehow we need to define it down and get a better direction for it. If people
knew when they are building with historic buildings around it, they need to know transparently
that is going to be an issue.
Lucia: We need better understanding of what we are trying to protect historic structures from.
I’m not suggesting that developers shouldn’t scale back, but there’s a point where people say
it’s too simplistic ie it’s bigger than the height of the historic so it can’t go up.
Maren: We will have basic standard for buildings, we would have other standards for buildings
with historic area of adjacency.
Matt: Two-three years, the bank towers will be historic. Is height and scale—are we only talking
about limiting height because the historic stock currently is all under 4 stories? In two years we
will have buildings that are too short.
Maren: There’s a preponderance issue that Matt is indirectly bringing up - you have x number of
3 story and y number of 11 stories.
Per: Meg mentioned it earlier-there are ruling lines, setbacks, stepbacks. You can be taller.
Lucia: It’s not about a set height, but we need to articulate how you can be compatible despite
height.
Sarah: What’s the effect of construction against EACH historic structure. Compatibility is not the
same for each building.
Maren: Case study—Living Oaks. This is the map of their area of adjacency. You have a range of
architectural style, typology, commercial and residential. It’s one of the best examples of one I
can think of that has a mixed area of adjacency. You’ve got a little bit of everything. The way this
works currently is that people come in with a design context, then we do area of adjacency, and
then we look at compatibility.
Chris: How far is that area of adjacency?
Maren: It’s between 450-500 ft out.
Per: Those houses were defined as park-like, setbacks, etc.
Maren: In terms of referential design, it was not looking at each property the same. They did not
reference the houses in design.
Per: LPC wasn’t talking about specific things with the blue buildings (Laurel School District)—it
was more about general characteristics.
Maren: Setback on both block faces were important. There were things called out in the review:
window proportion and orientation, pattern, and detailing. The flat roof relates to nearby
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commercial buildings. The materials were really interesting. In this example, they had terra cotta
panels that were different in scale. We are looking for ways to integrate new, sustainable
materials. We see our problems in this example: it would be hard for them to come in and know
predictably what the area of adjacency is, but allowed us to have that flexibility.
Maren: We could have metric approach. 250 ft is close to what we currently do. 500 ft is about
a full block out. This is a 1000 ft buffer. The area of notification would be a little smaller than
that.
Jennifer: Could we use the character sub-districts to help with this?
Spencer: The beauty of the metric approach in my eyes is that we could address transitions—it
would address sub-districts and transitions.
Karen: The circle does not mean that all buildings in that circle have importance and those that
do may not have equal importance so I want to clarify that.
Spencer: Maybe there is a way to look at the different variables. Maybe abutting properties are
looked at differently than nearby/adjacent? Maybe the scale influences the adjacency
determination. Maybe it can be a more nuanced conversation.
Sarah: I like that approach. A taller building is going to have more affect more than smaller ones.
Matt: But which element of integrity is being affected by height?
Sarah: May affect one or all seven. We have to evaluate all aspects of integrity every time.
Maren: We are running out of time, we are providing a foundation for our conversation next
month. Do we have any final thoughts? Does anyone fundamentally disagree that height
relationship with area of adjacency.
Meg: I like that. Clarion did not address rural properties. Something about property line versus
structure/building needed in the report. You don’t want to include an empty lot. They didn’t
include any rural aspects to this. I think we have those situations. I think the conical idea works,
but need to specify that we are looking at buildings.
Maren: Circling back, is there a difference between abutting and further away? Is that a general
direction we should pursue?
Majority yes, Per: but there are always key buildings. Parks, view sheds, etc. that are critical to
historic area that could go beyond area.
Lucia: You might have different things you look at the further away you are.
Per: That can be, but I don’t want to exclude that a key building could be outside of area.
Spencer: Living Oaks example, further out the broader the look.
Matt: irony that we are looking at eras of history Can stand on the 200 Linden Street and see
National Bank Tower. To me, to acknowledge that both of those are working together and
acknowledge that our history is not about one single era. We are acknowledging the best of the
best of those eras.
Jennifer: You have to take historic district differently. There are some buildings that are outliers.
They don’t contribute to the feel of the historic district the way that most of them do. There are
two or three of them. I think we need to learn from our mistakes. If they proposed today, I don’t
think they would be allowed. You can recognize them for what they are and recognize that they
don’t feel right.
Matt: Mountain and College
Jennifer: Those buildings aren’t the same style, but the mass and scale fits.
Spencer: There is this debate everywhere about whether scale and height should be limited.
Jennifer: To me, what we’re talking about is historic downtown. We are not downtown Denver.
Lucia: What’s the right mix that doesn’t keep you locked in time, but allows you to make the
bold buildings? Example of DC.
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Meg: What we’re saying is historic core is different than Canyon sub-area.
Chris: Don’t just apply one element from Old Town Square to other sub-areas.
Jennifer: What we’re trying to protect is keeping it from losing vibrancy and losing what’s there.
Matt: No, each stands as each and the diversity adds value.
Jennifer: We have different ideas of historic core and what should be protected. Outside of core
different.
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Attachment: CAC Nov 1, 2017 Meeting Draft Minutes (6113 : Discussion of Areas of Adjacency and Compatibility)
TOPIC 3.1: AREA OF ADJACENCY 1
CAC November 1, 2017
Adjacency
Adjacent:
• Nearby, but not necessarily
touching
• Case by case basis
• Context, project variables
2
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Attachment: Staff Presentation - Area of Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Status Quo Example
3
Status Quo Example
4
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Status Quo Example
5
Status Quo Example
6
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3.4.7 Identified Issues: Area of Adjacency
• Clarify which compatibility elements and/or standards are specific to
resonating with historic buildings (area of adjacency)
• Scope of area of adjacency needs to be predictable and justifiable
• Compatibility standards should balance prescription and flexibility
• How does proximity to infill parcel affect how each compatibility
standard is applied?
• Relating to abutting properties: key elements of compatibility
• Relating to nearby properties: same elements or ?
• Is there a natural hierarchy of importance for compatibility criteria?
7
Character of the “Area of Adjacency”
• Historic buildings: Proximity, preponderance and level of significance
• Dimensional qualities: Size, mass, bulk, height, scale, form, shape
proportions, articulation
• Building typology: Predominantly residential? Commercial? Civic?
• Represented historical eras and patterns of development
• Materiality, including type, scale and durability of materials
• Rhythm and block pattern
• Solid to void; window patterns; roof shape
• Existing architectural styles, and character-defining features
• What’s missing? What’s most important?
8
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Attachment: Staff Presentation - Area of Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
Goals: Compatible New Construction
• Good Neighbor: promotes viability of existing buildings
• Good Design: creative, enduring response to existing character
• Options for balancing predictability and flexibility:
• Which compatibility elements are most important for
responding to abutting historic buildings?
• Which compatibility elements are most important for
responding to other nearby historic buildings/general
character?
• Is there a hierarchy of importance for compatibility strategies?
9
Metric Approach
250 foot buffer
10
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11
Metric Approach
500 foot buffer
12
Metric Approach
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Attachment: Staff Presentation - Area of Adjacency (6113 : Discussion of Areas of Adjacency and Compatibility)
DATE:
STAFF:
November 8, 2017
Maren Bzdek, Senior Historic Preservation Planner WORK SESSION ITEM
Landmark Preservation
Commission
SUBJECT FOR DISCUSSION
LPC Work Plan - Progress and Priorities
EXECUTIVE SUMMARY
City Code requires all boards and commissions to file work plans on or before September 30 for the following
year. According to the Boards and Commissions Manual, work plans should set out major projects and issues for
discussion for the following year. The LPC adopted the attached 2018 work plan at its August 16, 2017 meeting.
Beginning with the September 13, 2017 work session, consideration of pending priorities associated with the work
plan will be a regular discussion item. The regular recurrence of this discussion item is intended to provide the
Commission with the opportunity to measure ongoing progress and identify action items.
ATTACHMENTS
1. LPC 2018 Work Plan signed (PDF)
2.2
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Attachment: LPC 2018 Work Plan signed (6114 : LPC Work Plan - Progress and Priorities)
2.2.a
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Attachment: LPC 2018 Work Plan signed (6114 : LPC Work Plan - Progress and Priorities)