2A - Discussion of Historic Preservation Enforcement IssuesMEMORANDUM
June 15~', 2005
TO: Landmarks Preservation Advisory Board
FROM: Ruth McHeyser, Director of Long Range Planning
James Hewat, Historic Preservation Planner
SUBJECT: Discussion of Historic Preservation Enforcement Issues
SUMMARY:
^ T'he Board has requested information regarding the policies and
procedures regarding the enforcement of provisions of the historic
preservation ordinance.
~ Section 10-13-22 of the code ensures that "no person shall violate
or permit to be violated any of the requirements of this chapter or
of a landmark alteration certificate" in order to ensure compliance
with the legislative intent of the historic preservation ordinance as
outlined in Sectionl0-13-1 of that document and Section 2.30 of the
Boulder Valley Comprehensive Plan.
The purpose of this meeting is to provide information to the Board
regarding current historic preservation enforcement and to discuss
the effectiveness of the program.
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The Board has requested information regarding the policies and
procedures regarding the enforcement of provisions of the historic preservation
ordinance. To thaY end, staff has prepared current policy and practice in terms
the reporting and enforcement of violations.
Section 10-13-22 of the code ensures that "no person shall violate or permit
to be violated any of the requirements of this chapter or of a landmark alteration
certificate" in order to ensure compliance with the legislative intent of the
historic preservation ordinance as outlined in Sectionl0-13-1 of that document
and Section 2.30 of the Boulder Valley Comprehensive Plan. While consistent
enforcement of violations is critical to the irnplementation of the City's historic
preservation program, public education to ensure compliance can significantly
lessen the number of violations. Ultimately, the goal of the historic preservation
enforcement process is ensure compliance with the code and where v.iolations
have occuned, to resolve them in a manner consistent with the ordinance.
Enforcement of city land use and building code violations is coordinated
by zoning and enforcement; a division of planning and development services as
summarized in Attachment A..
The specific provisions regulating the enforcement of the landmarks
ordinance can be found at Section 10-13-22, B.R.C. 'Those provisions can be
summarized as follows:
1. If staff considers that a violation has occurred, the owner of the
property must first be given written notification of the violation.
2. The property owner then has thirty days to correct the violation from
the date of the notice.
3. If the violation is not corrected within thirty days, then the City may
issue a summons and complaint to the landowner charging the sections of the
code that have been violated.
4. However, this notice requirement does not apply to violations of
Section 10-13-23, B.R.C. This section requires a permit for the demolition,
moving and removal of buildings over fifty years old.
5. Except as described in #6 below, violations are punishable by a fine of
not more than one thousand dollars per violation, or incarceration for not more
than ninety days in jail, or by both. However, in order to impose a jail sentence
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the court must be satisfied that the defendant acted intentionally, knowingly, or
recklessly.
6. For violations of Section 10-13-12, B.R.C. "Landmark Alteration
Certificate Required" or Section 10-13-23, B.R.C., "Review of Permits for
Demolition, Moving, and Removal of Buildings," a fine of not more than $5,000
per violation may be imposed or incarceration in jail for not more than 90 days or
both such fine and incarceration. Since most violations that the Landmarks
Board is interested in would fall in these two categories, this will generally be the
controlling section.
'The following flow chart is intended to summarize cunent practice in the
enforcement of violations to the historic preservation ordinance:
~ Receive Compla,int ~
Reterred to
Inspectlons -
Validate Complaint
Inspection Performed Inspeetlon Pertormed
Notlce oi Violationl No Violatlon
3top Work*
Summons issued to Municipal
Court or other remedies as
pravlded by law pt vtoisuon uot
corrected wlthlo 30 daya or notlce)
Violation Cosected
(,~~nm ao aays oe nonce~
Case closed
Penalty: up to~i5000 andlor 90
days in iail per vlolation
Plus up to 52000 it in alolation
ot a building permit
" It a vlolatlon to Chapter 13 is conflrmed a letter is sent to the alalator inlorming them as
to the vlolatlan and ta the 30-day perlod during wLich they must bring the project Into
compllance. in many cases, more than 30 days is allowed tor resolutlon ot a vlolatlon.
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During 2004 and the first half of 2005, there were twelve violations to the
historic preservation ordinance. In handling these violations, the historic
preservation section works with enforcement to resolve them. Typically, a
violator wiil either bring the violation into compliance with the Landmark
Alteration Certificate as shown on the petmit set of drawings or bring the
violation the Design Review Committee of the Landmarks Board for a revised or
new LAC within the thirty day period. For those not brought into compliance,
court summons are sought. An example of this is the unauthorized window
replacement at 24416~ Street.
Currently there is not a system in place to specifically track historic
preservation violations from beginning to resolution. Staff periodically meets
with inspections staff to train them on issues related to historic preservation in
order that conditions of the LAC are inspected in addition to life safety, building
code, and zoning as part of the certificate of occupancy process. Such a training
with inspection staff is due.
Representatives from the City Attomey's Office and Inspections will be in
attendance at the meeting to participate in the discussion and answer c{uestions
regarding issues and concerns about historic preservation ordinance violation
provisions or enforcement procedures.
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Attachment A
ENVIRONMENTAL & ZOPIING ENFORCEMENT
May 4, 2005
Resources
Four code enforcement officers (including a Code Enforcement Supervisor), a half-time
administrative person and one-quarter of the Chief Building OfficiaPs position (for a total
of 4.75 FTE) provide Environmental and Zoning Enforcement services. Work performed
in this azea includes the enforcement of regulations involving noise, nuisance party, trash,
sidewalk snow removal and weeds and activities involving over-occupancy, illegal
uses/units and enforcement of the sign code. This staff also provides support for the
enforcement of the city's building and housing codes which can involve historic
preservation issues.
This work group is part of the Public Works Department and is included in the service
area and fund lmown as Planning & Development Services (P & DS). The P& DS Fund
includes a General Fund transfer that pays for "general govemance" activities including
Environmental & Zoning Enforcement. The 2005 Budget for this program is $383,093
and includes all personnel (salaries and benefits) and non-personnel costs (such as fleet
and computer replacement chazges and staff training).
Audit History
A Univers~ty Hill Action Gmup (UHAG) was established in 2000 to recommend specific
actions to the City Council to improve the quality of life in this neighborhood. One of the
recommendations was to initiate an independent management audit to examine the
effectiveness of Environxnental and Zoning Enforcement. A Management Review was
completed in May 2001. A detailed Performance Audit for Envimnmental Code
Enforcement (Environmental and Zoning Enforcement) was undertaken in 2001, and a
final repor[ was issued in January 2002. Please refer to the following link for the
Performance Audit:
http://www.ci.boulder.co.us/buildingservices/environmenUenvironmentalenfaudit.pdf
During this audit, the equivalent of 5.67 FTE were included in this program. General
Fund revenue reductions resulted in expenditure reductions across the organizarion during
2003/2004. Specifically, this work area experienced a reduction in staffing and the
elimination of the overtime budget.
Implementation of the audit has achieved results, including the adoption of more cleazly
defined policies and procedures. Actions taken are summarized in the following links:
httu://www.ci.boulder.co. us/clerk/WIP/2003/4-3-03/item4b.pdf
httn://www.ci.boulder.co.us/clerk/WIP/2004/09-09-04/3d.ndf
1
Policy Direction
The audit recommended that the City Council adopt guiding principles and policies for
code enforcement. Resolution 903 was adopted on Apri12, 2002. Please refer to the
following link for Resolution 903:
httn://www.ci.boulder.co.us/buildingservices/environmenURes903.pdf
Enforcement Response
Data associated with complainUcontact and summons information is posted on the city
web site and periodically updated:
http:/(www.ci.boulder.co.uslbuildineserviceslcrvstaUCPUcpI summons sum ce.ndf
http://www.ci.boulder.co.us/buildin¢services/documents/complaintsummons.pdf
httu://www.ci.boulder.co.us/buildinQServices/documents/kewiolations.pdf
Both the Police and Public Works Depattments respond to noise and nuisance party
complaints. Information associated with enforcement responses in these areas is
summarized in Attachment A.
Envimnmental and Zoning Enforcemeni activities are seasonal in nature and staff hours
are adjusted accordingly. For example, from mid April through CU's May Graduapon
and from the beginning of CU's Fall Semester through Halloween, Environmental and
Zoning Enforcement staff focus on trash, noise and nuisance party enforcement and work
hours include Thursday, Friday and Saturday evenings.
Enforcement actions aze both officer-initiated and taken in response to complaints. With
respect to the former, this includes scheduled work fime in the Goss-Gmve, Martin Acres
and the University Hill neighborhoods. In 2004, approximately 48% of code
enforcement cases were officer-initiated.
2005 Focus
In addition to providing support for the analysis and implementation of proposals in
support of Resolution 960 (alcohol abuse), 2005 work efforts include:
Mapping recent code enforcement history for the University Hill, Martin Acres and Goss
Grove neighborhoods in order to inform and further refine code enforcement responses
and strategies,
2
Improving communication with residents by implementing a web-based tool to assist
residents in filing complaints and generating a standard report for residents which
outlines the actions taken by staff in response,
Evaluaring with stakeholders the International Property Maintenance Code as an
alternarive to the existing Housing Code, and
Preparing the 2006/2007 Budget, Business Plan and associated metrics for Environmental
& Zoning Enforcement to support City Council decision-making for the allocation of
resources.
Attachment A
NEIGHBORHOOD NOI5E ENFORCEMENT*
2003 5UMMARY
Complaints` Field ContactsZ Summonses Issued'
3197 2314 113
Police Department
Public Works Dept. 1275 1044 135
EZEO
4472 3358 248
Total
2004 SUMMARY
Complaints Field Contacts Summonses Issued
2945 2400 115
Police Department
Public Works Dept. 1291 1049 136
EZEO
4236 3449 251
Total
' Data source: Public Works LandLink database and BPD CAD system
' OfFicecs are dispatched in response to naise cox~q~laints, but pmactive efforts are also undertaken. T'hese
numbers include both complaint-based and of~'icer-iniriated contacts.
Z Not all complaints aze located in the field. These numbers retlect verified cornplaint locarions.
' Summonses include bo[h Noise and Nuisance Party. The Nuisance Party prohibited regularion states thst
no owner, occupant or tenant of any premise shall sponsor, conduct, or permit a social gathering which is or
bewmes a public nuisance. Such a gathering consututes a public nuisance when iY results in one or more
city violations, including noise.