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Item 6C - 870 University Ave - DemolitionAgenda Item # 6C Page 1 M E M O R A N D U M August 3, 2016 TO: Landmarks Board FROM: Lesli Ellis, Comprehensive Planning Manager Debra Kalish, Senior Assistant City Attorney Marcy Cameron, Historic Preservation Planner James Hewat, Senior Historic Preservation Planner William Barnum, Historic Preservation Intern SUBJECT: Public hearing and consideration of a demolition permit application for the house and accessory building located at 870 University Ave., non-landmarked buildings over 50 years old, pursuant to Section 9- 11-23, Boulder Revised Code 1981 (HIS2016-00103). STATISTICS: 1. Site: 870 University Ave. 2. Date of Construction: 1922 3. Zoning: RL-1 4. Existing House Size: 1,924 sq. ft. (approx.) 5. Lot Size: 7,056 sq. ft. 6. Owner/Applicant: 870 University Ave., LLC / Chris Gray STAFF RECOMMENDATION The Planning, Housing and Sustainability Department (PH&S) recommends that the Landmarks Board adopt the following motion: I move that the Landmarks Board approve the demolition permit application for the building located at 870 University Ave. finding that, due to a loss of architectural integrity, the property is not eligible for landmark designation, and adopt the staff memorandum dated August 3, 2016, as the findings of the board. The Landmarks Board recommends that prior to issuance of the demolition permit, staff require the applicant to submit to CP&S staff for recording with Carnegie Library: 1. A site plan showing the location of all existing improvements on the subject property; 2. Measured elevation drawings of all faces of the buildings depicting existing conditions, fully annotated with architectural details and materials indicated on the plans. Agenda Item 6C Page 2 Should the board choose to issue a stay-of-demolition, a 180-day stay period would expire on Oct. 29, 2016. If the board chooses to place a stay of demolition on the application, staff recommends the following motion language: I move that the Landmarks Board issue a stay of demolition for the building located at 870 University Ave., for a period not to exceed 180 days from the day the permit application was accepted by the city manager, findings listed below, in order to explore alternatives to demolition of the building. 1. The property may be eligible for individual landmark designation based upon its historic and architectural significance; 2. The property contributes to the character of the neighborhood as an intact representative of the area’s past; 3. It has not been demonstrated to be impractical or economically unfeasible to rehabilitate the building. EXECUTIVE SUMMARY On April 13, 2016, the Planning, Housing and Sustainability Department received a demolition permit application for the house and detached garage at 870 University Ave. The buildings are not in a designated historic district nor locally landmarked, but are over 50 years old and the action proposed meets the definition of “Demolition (Historic)” found in Section 9-16-1, B.R.C. 1981. On April 27, 2016, the Landmarks design review committee (Ldrc) referred the application to the Landmarks Board for a public hearing, finding there was “probable cause to believe that the building may be eligible for designation as an individual landmark” and that the proposed alteration would constitute a significant impact or detrimental effect to a potentially historic resource. PURPOSE OF THE BOARD’S REVIEW Pursuant to section 9-11-23(d)(2), B.R.C. 1981, demolition requests for all buildings built prior to 1940 requires review by the Ldrc. The Ldrc is comprised of two members of the Landmarks Board and a staff member. If, during the course of its review, the Ldrc determines that there is “probable cause to consider the property may be eligible for designation as an individual landmark,” the issuance of the permit is stayed for up to 60 days from the date a completed application was accepted and the permit is referred to the board for a public hearing. If the Landmarks Board finds that the building proposed for demolition may have significance under the criteria in subsection (f) of Section 9-11-23, B.R.C. 1981, the application shall be suspended for a period not to exceed 180 days from the date the permit application was accepted by the city manager as complete in order to provide the time necessary to consider alternatives to the building demolition. If imposed, a 180-day Agenda Item 6C Page 3 stay period would start when the completed application was accepted by the city manager (May 2, 2016, when the Landmarks Board fee was paid) and expire on Oct. 29, 2016. Section 9-11-23 (g) and (h), B.R.C. 1981. DESCRIPTION The property is located on the south side of University Avenue between 8th and 9th streets in the Buena Vista Heights Addition within the identified potential Expanded Highland Lawn historic district, west of the identified potential University Hill local and national historic district, and half a block north of the Columbia Cemetery National Register Historic District. The 7,056 square foot lot contains a 1,924 square foot house with an alley bordering the southern property line. A 236 square foot frame shed is located at the southwest corner of the lot. Figure 1. Location Map showing 870 University Ave. Agenda Item 6C Page 4 Figure 2. North Elevation (façade), 870 University Ave., 2016. Originally constructed in 1922, the one-story, hipped roof-dominated house at 870 University Ave. was significantly remodeled in 1987 with the construction of a second story and rear addition. The 1987 design referenced the original Craftsman elements through its roof form and tapered window surrounds. Remaining features from the 1922 house include the entry, with a centrally located door, clipped gable overhang supported by triangular braces, and entry stairs, original window openings on the first story, and 4- over-1 double-hung windows with tapered surrounds. A low, shed and clipped roof portion of the building wraps the southeast corner of the building and appears to have been original to the construction of the building. This portion of the building appears on the 1929 tax assessor card and features a side entrance and original doors and windows. The south (rear) elevation has been obscured by the 1987 addition. Agenda Item 6C Page 5 Figure 3. Northeast Elevation, 870 University Ave., 2016. Figure 4. South Elevation, 870 University Ave., 2016. Agenda Item 6C Page 6 Figure 5. Southwest Corner, 870 University Ave., 2016. Figure 6. Southeast Corner, Accessory Building, 2016 Agenda Item 6C Page 7 Figure 7. Southwest Corner, Accessory Building, 2016 An accessory building is located on the southwest corner of the property and was likely constructed at the same time as the house. The one-story stuccoed building features a low pitched gable roof with exposed rafters, and a contemporary pedestrian door and casement window on the north (interior) elevation. The east, south (alley) and west elevations do not have openings. The tax assessor card notes a private garage was located on the property and that the garage was extended 4’ in 1958. The building no longer retains evidence of the garage door opening. The accessory building was approved for demolition in 2007, and building permit records indicate the building was clad in stucco in 2008. Agenda Item 6C Page 8 Figure 8. Tax Assessor Photo, University Ave., c. 1929. Figure 9. Existing roof plan showing modifications to the building. The National Park Service’s Standards for the Treatment of Historic Properties states that, “changes to a property that have acquired historic significance in their own right will be retained and preserved.” The alterations to this building were made approximately 30 years ago and are not considered to have historic or architectural merit Agenda Item 6C Page 9 on their own. While the first level of the original building remains, the resulting loss of original fabric weakens the property’s architectural integrity as a representative turn-of the-twentieth-century Craftsman Bungalow inspired house. Condition The house appears to be in good condition, with no significant damage evident. No information had been provided on the interior and structural condition of the house. SCOPE OF DEMOLITION Section 9-17 Definitions, B.R.C., 1981 defines “Demolition (Historic)” as the removal of more than 50% of the roof, more than 50% of the exterior walls, or the removal of a street-facing wall. The demolition permit application proposes the removal of a street- facing wall. See Figure 10. Existing and Proposed Elevations. Figure 10. Existing (left) and Proposed North Elevations, 870 University Ave. Shaded area on existing drawing shows scope of demolition. Staff considers that due to the extent of alterations to the building, notably the addition of a second story in 1987, the house is no longer eligible for designation as an individual landmark. As such, the proposed alterations would not have a significant impact or detrimental effect on a potential historic resource in the city. PROPERTY HISTORY The house is located within the Buena Vista Heights addition, which was originally part of Marinus Smith’s sizable landholdings in eastern Boulder. Due to the vast size of his estate and the number of potential heirs, a legal battle over inheritance followed Smith’s Agenda Item 6C Page 10 death in 19021. The suit, Della M. Eschenburg et al. vs. Herbert M. Smith et al., resulted in an agreement to plat many of Smith’s lands into new subdivisions, the lots of which were then parceled out to the various parties2. As part of this settlement, 870 University was deeded to the Harrington family3. In 1922, Jessie L. Harrington, widow of George W. Harrington, sold it to Sophrona “Frona” McNair and her daughter Madge. They held the property for just over three months before deeding the property to Edward B. Bain, husband of Jeannette Allen (McNair) Bain, Frona’s daughter. The original house, a one story Craftsman inspired bungalow, was constructed in 1922. Edward B. Bain was born on March 1st, 1887, in Clinton, Missouri, the son of John and Mattie Bain4. John was born in Ireland, emigrated to the U.S. in 1872, while Mattie was born in Canada, immigrating in 18765. They married in 1884, and by 1900 had moved to Denver with Edward6. By 1910, Edward had moved to Salina, a small mining town near Boulder, where he worked as a salesman at a grocery7. He took over ownership of J. O. Mercantile, a general store in Salina on May 19, 1916, and ran it until November, 1918, when he joined the United States Army8. Bain was assigned to the Army Air Service, and, after 60 days basic training in Colorado Springs, trained at the radio school at Kelley Field, near San Antonio, Texas9. He served with the 145th Headquarters Squadron, receiving promotion to Sergeant in February, 1919. The First World War having ended shortly after he joined, Bain was discharged on June 14, 1919. Just over a year later, on July 25, 1920, he married Jeannette McNair in Denver10. Jeannette Allen McNair Bain was born in 1893 in Mason City, Iowa to John and Sophrona McNair 11. In 1909, the McNairs moved to Boulder to take advantage of the educational opportunities for Jeannette and her sister Madge12. Jeannette attended the Boulder Preparatory School and two years at the University of Colorado13. She then taught elementary school at Saguache and Salina for one year each, and in Boulder for two years, one of which was spent at Highland Elementary School14. 1 Simmons, R. Laurie and Christine Whitacre, 1989 Boulder Survey of Historic Places: Highland Lawn. City of Boulder, 1989. 2 “Map of the Lands Belonging to the Heirs of Marinus G. Smith, Dec.” May, 1902. Boulder Carnegie Library. 3 Ibid. 4 Daily Camera, “Obituaries: Edward Bain”, January 20, 1975. Boulder Carnegie Library. 5United States of America, Bureau of the Census, Twelfth Census of the United States. 1900. Ancestry.com. 6 Ibid. 7 United States of America, Bureau of the Census, Thirteenth Census of the United States. 1910. Ancestry.com 8 Photo Caption, Boulder Carnegie Library. 9 Daily Camera, “Miss Jeanette A. McNair and Edward Bain Married.” July 26, 1920. Boulder Carnegie Library 10 Ibid. 11 “Miss Jeanette A. McNair and Edward Bain Married” 12 Daily Camera, “Services will be Held Thursday for Mrs. McNair.” September 22, 1943. Boulder Carnegie Library. 13 “Miss Jeanette A. McNair and Edward Bain Married” 14 Ibid. Agenda Item 6C Page 11 Figure 11. Jeannette Bain, 1934. Photo Courtesy of the Boulder Carnegie Library Figure 12. Edward Bain, 1942. Boulder Carnegie Library. Following her marriage to Edward, Jeannette was highly active in numerous local, regional, and national women’s organizations, and held several prominent positions. She served as president of the Boulder Woman’s Club from 1930 until 1932, and was elected president of the Northern District of the Colorado Federation of Women’s Clubs (CFWC) in 1934, serving as president from 1944 until 1947.15 She was appointed Treasurer of the Women’s Christian Temperance Union of Colorado in 1955. She was regent of the Arapahoe Chapter, Daughters of the American Revolution (DAR), Regent of the Colorado State Society, DAR, from 1965 until 1967, and Vice President General of the national DAR from 1965 until 196816. She also taught Sunday school for the First Presbyterian Church for 15 years, and was organizing president of the United Presbyterian Women’s Association17. She died on April 23, 1988, at the age of 94. Edward Bain worked at Graham Furniture, located in the Ehrlich Building at 1407 Pearl St.18 Starting as an assistant manager, he would eventually become owner and president of the company in 1944.19 Edward was active as a Scout Master for Boy Scout Troop 75 of Boulder for 12 years, receiving the Silver Beaver, a high honor for Scout masters, in 1943. He was a member of the American Legion for 52 years, and the Boulder Rotary Club for 39. He retired as president of Graham Furniture in 1965, and died ten years later on January 18th, 1975, at the age of 87.20 The Bains had one son, Edward McNair Bain, Jr., who served as an officer in the U.S. Navy and lived at 870 University until 1946. 15 Mrs. Edward Bain Elected State Federation Head.”; Daily Camera, “Mrs. Edward Bain Elected Northern District President.” April 28, 1934. Boulder Carnegie Library; The Colorado Club Woman, “Mrs. Edward Bain Candidate for Treasurer CFWC.” Boulder Carnegie Library. 16 17 Daily Camera, “Obituaries: Jeannette A. Bain.” 28 April, 1988. Boulder Carnegie Library. 18 Ibid. 19 Daily Camera, “Mrs. Edward Bain Elected State Federation Head.” September 20, 1944. Boulder Carnegie Library. 20 “Obituaries: Edward Bain” Agenda Item 6C Page 12 The Bains lived at 870 University Ave. until 1960, when they moved to a new house at 400 Christmas Tree Drive. They retained ownership of 870 University Ave. and rented the house out until 1974, when it was sold to the First National Bank. The property was purchased by David S. and Elaine Ogle, a retired couple, in 1975. They were the sole occupants until 1978, when two additional rental units were created out of the house. The Ogles rented these to various tenants, before the house passed to David H. and Penelope Ogle in 1979. Over the following four decades, the property passed through five owners, each owning the property for less than 10 years. The current owner, 870 University Ave., LLC, purchased the property in 2014. CRITERIA FOR THE BOARD’S DECISION: Section 9-11-23(f), B.R.C. 1981, provides that the Landmarks Board “shall consider and base its decision upon any of the following criteria: (1) The eligibility of the building for designation as an individual landmark consistent with the purposes and standards in Sections 9-11-1 and 9-11-2, B.R.C. 1981; (2) The relationship of the building to the character of the neighborhood as an established and definable area; (3) The reasonable condition of the building; and (4) The reasonable projected cost of restoration or repair. In considering the condition of the building and the projected cost of restoration or repair as set forth in paragraphs (f)(3) and (f)(4) …, the board may not consider deterioration caused by unreasonable neglect. As detailed below, staff does not consider this property to be potentially eligible for designation as an individual landmark. CRITERION 1: INDIVIDUAL LANDMARK ELIGIBILITY The following is a result of staff's research of the property relative to the significance criteria for individual landmarks as adopted by the Landmarks Board on Sept. 17, 1975. See Attachment E: Individual Landmark Significance Criteria HISTORIC SIGNIFICANCE: Summary: The house located at 870 University Ave. meets historic significance under criterion 1 and 2. 1. Date of Construction: 1922 Agenda Item 6C Page 13 Elaboration: The tax assessor card lists the date of construction as 1922 and the address first appears in the 1923 city directory. 2. Association with Persons or Events: Jeannette and John Bain Elaboration: Jeannette Bain was president of the Colorado Federation of Women’s clubs, vice president general of the national Daughters of the American Revolution, and held several other noteworthy positions in local, state, and national women’s organizations. John Bain was owner and president of Graham Furniture, a prominent local business, from 1944 until 1965. They lived at 870 University Ave. from its construction in 1922 until 1960, a period of 38 years. 3. Development of the Community: University Hill/Highland Lawn Elaboration: The house is typical of houses constructed in the 1910s and 1920s, when the University Hill neighborhood was growing. The expansion of the house into a multi-unit dwelling illustrates the long-term change in the character of University Hill from low-density single family areas to higher density rental ones. 4. Recognition by Authorities: Front Range Research Associates, Inc. Elaboration: The 1995 Historic Building Inventory Form notes that “Although the house has been extensively remodeled, it is notable for its original details, which include its half-timbering, slanted surrounds, and 4/1 light windows.” There is no historical background information on the survey, and it was not found to have specific architectural or historic significance. ARCHITECTURAL SIGNIFICANCE: Summary: Due to extensive remodeling, the house located at 870 University Ave. is no longer architecturally significant. 1. Recognized Period or Style: Bungalow Style Elaboration: Though originally an excellent example of modest Craftsman Bungalow house construction in Boulder , extensive alterations have diminished its significance. The 1987 addition of a full second story has significantly impacted the original one-story roof-dominated form and character of the house. 2. Architect or Builder of Prominence: Unknown 3. Artistic Merit: The alterations to this property have diminished the artistic merits of its original construction. 4. Example of the Uncommon: None observed. Agenda Item 6C Page 14 5. Indigenous Qualities: None observed. ENVIRONMENTAL SIGNIFICANCE: Summary: The house is not environmentally significant. 1. Site Characteristics: Residential Historic Character Elaboration: The house is located on the south side of University Avenue between 8th and 9th streets. It is located within the identified potential Expanded Highland Lawn historic district, west of the identified potential University Hill local and national historic district, and half a block north of the Columbia Cemetery National Register Historic District. 2. Compatibility with Site: Residential Historic Character Elaboration: While the house retains the original front and side yard setbacks, the house itself no longer contributes to the historic residential character of the neighborhood. 3. Geographic Importance: None observed. 4. Environmental Appropriateness: None observed. 5. Area Integrity: The property is located within the identified Potential Expanded Highland Lawn Historic District, which retains a high degree of historic integrity to the original development of that neighborhood, however, because of the extent of remodeling, staff does not consider the house would contribute to the potential historic district. CRITERION 2: RELATIONSHIP TO THE CHARACTER OF THE NEIGHBORHOOD: Extensive alterations to this house have diminished its architectural, historic and environmental integrity. It is no longer contributing to the neighborhood. CRITERION 3: CONDITION OF THE BUILDING: Little information has yet been provided regarding the condition of the building. Externally, the house and accessory building appear to be in good condition. CRITERION 4: PROJECTED COST OF RESTORATION OR REPAIR: No information has been submitted regarding the cost of restoration or repair. Agenda Item 6C Page 15 NEIGHBORHOOD COMMENT: Staff has received no comment to date from the public on this matter. THE BOARD’S DECISION: If the Landmarks Board finds that the building to be demolished does not have significance under the criteria set forth in section 9-11-23(f), B.R.C. 1981, the city manager shall issue a demolition permit. If the Landmarks Board finds that the building to be demolished may have significance under the criteria set forth above, the application shall be suspended for a period not to exceed 180 days from the date the permit application was accepted by the city manager as complete in order to provide the time necessary to consider alternatives to the demolition of the building. Section 9-11-23(h), B.R.C. 1981. A 180-day stay period would expire on October 29, 2016. FINDINGS: Staff recommends that the Landmarks Board adopt the following findings: Issuance of a demolition permit for the house and accessory buildings at 870 University Ave. is appropriate based on the criteria set forth in Section 9-11-23(f), B.R.C. 1981 in that: 1. While the property possesses historic significance, it is not eligible for individual landmark designation as the extensive alterations, including a full second-story addition, have compromised its historic and architectural integrity; 2. The property does not contribute to the character of the neighborhood, due to the extent of alterations. ATTACHMENTS: Attachment A: Current Photographs Attachment B: Boulder County Tax Assessor Card c. 1929 Attachment C: Historic Building Inventory Form Attachment D: Deed & Directory Research Attachment E: Significance Criteria for Individual Landmarks Agenda Item 6C Page 16 Attachment A: Current Photographs Photo 1. North Elevation (façade), 870 University Ave., 2016. Photo 2. Northeast Corner, 870 University Ave., 2016. Agenda Item 6C Page 17 Photo 3. South Elevation (rear), 870 University Ave., 2016. Photo 4. Southeast Corner, 870 University Ave., 2016. Agenda Item 6C Page 18 Photo 5. Southeast Corner, Accessory Building, 870 University Ave., 2016. Photo 5. Southeast Corner, Accessory Building, 870 University Ave., 2016. Agenda Item 6C Page 19 Attachment B: Boulder County Tax Assessor Card c. 1929 - 1966 Agenda Item 6C Page 20 Agenda Item 6C Page 21 Agenda Item 6C Page 22 Agenda Item 6C Page 23 Agenda Item 6C Page 24 Attachment C: Historic Building Inventory Form Agenda Item 6C Page 25 Agenda Item 6C Page 26 Photo from Historic Building Inventory Record, 1989. Agenda Item 6C Page 27 Attachment D: Deed & Directory Research Owner (Deeds) Date Occupant(s)/Directory Madge and Frona McNair 3/2/22 – 6/21/22 1922 Bain, Edward 5/19/22 – 11/6/74 1923-60 *first appears Bain, Edward (Jeannette A.), Graham Furniture Co. 1960 Posphala, Steve J. (Bertha M), electrician. 1961-62 Hill, Robert D. (Joan M.), Student 1963-74 Sharp, Betty A. (Widow of Floyd) retired. First National Bank 11/06/74 – 6/2/75 1975 Vacant David S. and Elaine Ogle 6/2/75 - 1979 1976 -78 Ogle, David S. (Elaine), Retired. 1978 Ogle, David S. (Elaine); A – Jacobs, Cindy; B – Reynolds, R. 1979 Ogle, David S. (Elaine); A – Milkovich, Gary; B – Schaefer, Priscillia. David H. and Penelope Ogle 1979 – 8/23/85 1980 Swenson, Pete; A – Behnke, Tom; B – Veit, Chris Christopher and Stephen Soper 8/23/85 – 2/22/93 1985 Lora Thorne- Smith 2/22/93 – 6/27/01 1993 Robert G. Taylor, II 6/27/01 – 10/27/04 2001 Theodore A. Hartridge 10/27/04 – 11/18/09 2004 Agenda Item 6C Page 28 870 Boulder, LLC. 11/18/09 2009 Naren S. Tayal 11/18/09 – 3/7/14 2009 870 University Ave, LLC 3/7/14 – present 2014 Agenda Item 6C Page 29 Attachment E: Significance Criteria for Individual Landmarks SIGNIFICANCE CRITERIA Individual Landmark September 1975 On September 6, 1975, the City Council adopted Ordinance #4000 providing procedures for the designation of Landmarks and Historic Districts in the City of Boulder. The purpose of the ordinance is the preservation of the City’s permitted cultural, historic, and architectural heritage. The Landmarks Board is permitted by the ordinance to adopt rules and regulations as it deems necessary for its own organization and procedures. The following Significance Criteria have been adopted by the board to help evaluate each potential designation in a consistent and equitable manner. Historic Significance The place (building, site, area) should show character, interest or value as part of the development, heritage, or cultural characteristics of the community, state or nation; be the site of a historic, or prehistoric event that had an effect upon society; or exemplify the cultural, political, economic, or social heritage of the community. Date of Construction: This area of consideration places particular importance on the age of the structure. Association with Historical Persons or Events: This association could be national, state, or local. Distinction in the Development of the Community of Boulder: This is most applicable to an institution (religious, educational, civic, etc) or business structure, though in some cases residences might qualify. It stresses the importance of preserving those places which demonstrate the growth during different time spans in the history of Boulder, in order to maintain an awareness of our cultural, economic, social or political heritage. Recognition by Authorities: If it is recognized by Historic Boulder, Inc. the Boulder Historical Society, local historians (Barker, Crossen, Frink, Gladden, Paddock, Schooland, etc), State Historical Society, The Improvement of Boulder, Colorado by F.L. Olmsted, or others in published form as having historic interest and value. Other, if applicable. Architectural Significance The place should embody those distinguishing characteristics of an architectural type specimen, a good example of the common; be the work of an architect or master builder, known nationally, state-wide, or locally, and perhaps whose work has influenced later Agenda Item 6C Page 30 development; contain elements of architectural design, detail, materials or craftsmanship which represent a significant innovation; or be a fine example of the uncommon. Recognized Period/Style: It should exemplify specific elements of an architectural period/style, i.e.: Victorian, Revival styles, such as described by Historic American Building Survey Criteria, Gingerbread Age (Maass), 76 Boulder Homes (Barkar), The History of Architectural Style (Marcus/Wiffin), Architecture in San Francisco (Gebhard et al), History of Architecture (Fletcher), Architecture/Colorado, and any other published source of universal or local analysis of a style. Architect or Builder of Prominence: A good example of the work of an architect or builder who is recognized for expertise in his field nationally, state-wide, or locally. Artistic Merit: A skillful integration of design, material, and color which is of excellent visual quality and/or demonstrates superior craftsmanship. Example of the Uncommon: Elements of architectural design, details, or craftsmanship that are representative of a significant innovation. Indigenous Qualities: A style or material that is particularly associated with the Boulder area. Other, if applicable. Environmental Significance The place should enhance the variety, interest, and sense of identity of the community by the protection of the unique natural and man-made environment. Site Characteristics: It should be of high quality in terms of planned or natural vegetation. Compatibility with Site: Consideration will be given to scale, massing placement, or other qualities of design with respect to its site. Geographic Importance: Due to its unique location or singular physical characteristics, it represents an established and familiar visual feature of the community. Environmental Appropriateness: The surroundings are complementary and/or it is situated in a manner particularly suited to its function. Area Integrity: Places which provide historical, architectural, or environmental importance and continuity of an existing condition, although taken singularly or out of context might not qualify under other criteria.