6A - Revisions to Option B of the Historic Preservation and Environmental Sustainability IntegrationMEMORANDUM
November 1gt, 2006
TO: Landmarks Preservation Advisory Board
FROM: Susan Richstone, Interim Long Range Planning Manager
James Hewat, Historic Preservation Planner
Chris Meschuk, Historic Preservation Planner
Alice Gilbertson, Historic Preservation Intern
SUBJECT: Revision to Option B of the Historic Preservation and
Environmental Sustainability Integration Project. (HIPESIP)
EXECUTIVE SUMMARY:
In its July 18u, 2006 review of findings of the Historic Preservation and
Environmental Sustainability Integration project, the City Council continued the
public hearing to provide staff with additional time to further investigate the
implications of adopting changes to the city's policy regarding the replacement
of historic windows on designated buildings. In particular, the City Council
requested that staff clarify the impact adopting identified Option B might have
on the city's Certified Local Government status and modify Option B
accordingly. The City Council's direction to staff was based upon their
consideration that Option B provides flexibility for property owners to replace
windows, where appropriate, but should also be consistent with the Secretary of
the Interior's Standards.
On August 3~d, 2006, historic preservation and environmental affairs staff inet
with Joseph Saldibar and Amy Pallante, historic preservation architects with the
Colorado Historical Society, to clarify what aspects of Option B might be
inconsistent with the Secretary of Interior's Standards for Rehabilitation. Based upon
this meeting, staff has revised Option B in an attempt to make it more consistent
with the Secretary of the Interior's Standards for Rehabilitation. The revised Option
B provides for consideration of the replacement of windows on primary and
tertiary elevations of a building based upon their significance to historic
character of the building. This revised option provides for more flexibility by
approaching window replacement on a case-by-case basis while taking into
consideration the importance of looking at each building as a whole.
Staff also considers that the Revised Option B draws a reasonable compromise
between the preservation and replacement of windows and doors on historic
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buildings; and one that is consistent with current historic preservation
philosophy.
One disadvantage of the revised Option B(like the original Option B) is the extra
level of complication and uncertainty of case by case review. Implementation of
this policy would require the development of standards to assess the historic
importance and relative conditions of historic windows and doors. It could add
time to the review j approval timeline for a Landmark Alteration Certificate
(currently approximately one week). (For context, the total review/ approval
timeline for a remodel or addition project that requires an alteration certificate as
well as a building permit [with or without a Green Points requirement] is about
6-10 weeks.)
PURPOSE:
To solicit comments and suggestions from the Landmarks Board on proposed
revisions to Option B, as requested by the City Council on July 18~, 2006.
ANALYSIS:
What effect would adopting Option B have on the City's Certified Local
Government (CLG) Status?
The city's historic preservation program is certified as implementing a program
that is generally consistent with the Secretary of Interior's Standards for the
Treatment of Historic Properties. These include standards for historic preservation
and rehabilitation, which specify that, "The historic character of a property will
be retained and preserved. DisHnctive materials, features, finishes, and
construction techniques or examples of craftsmanship that characterize a
property will be preserved. The removal...or replacement of intact or repairable
historic materials or alteration of features...that characterize a property will be
avoided. Deteriorated historic features will be repaired rather than replaced."
On August 3~d, 2006, city staff from historic preservation and environmental
affairs met with Joseph Saldibar and Amy Pallante, historic preservation
architects with the Colorado Historical Society, to clarify what aspects of
proposed option B might be might be inconsistent with the Secretary of Interior's
Stundards fm Rehabilitation.
Saldibar and Pallante explained that the Standards for Rehabilitation are the
nationally recognized set of guidelines upon which most historic preservation
programs are based. In Colorado there are thirty-eight communities that employ
the standard through the Certified Local Government program, and over 1200
communities nationally have programs that use them. The Standards are neither
technical nor prescriptive, but are intended to promote responsible preservation
practices that help protect important cultural resources. For example, they
cannot, in and of themselves, be used to make essential decisions about which
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features of a historic building should be saved and which can be changed. But
once a treatment is selected, the Standards provide philosophical consistency to
the work. Saldibar and Pallante consider the approach of choosing windows on a
building based upon which elevation they are located (original Option B) is
philosophically inconsistent with the Standards.
The Secretary of the Interior's Standards were originally published in 1977, and
revised in 1983,1990, and 1995 as part of Department of the Interior regulations
(36 CFR Part 67, Historic Preservation Certifications). They pertain to historic
buildings of all materials, construction types, sizes, and occupancy and
encompass the exterior and the interior of historic buildings (the City of
Boulder's historic preservation program has no purview of the treatment of a
building's interior). No plans to revise the Standards are currently underway,
though technical information in the form of Preservation Briefs and Technical
Notes are regularly published by the National Park Service and intended to
supplement the Standards as preservation technology evolves. The Standards also
encompass related landscape features and the building's site and environment as
well as attached, adjacent or related new construction.
Saldibar and Pallante consider that Optio~ C, `which allows replacement of all
historic windows, would be inconsistent the Standards and would threaten
Boulder's CLG status. The same is true of Option B, as originally presented, as it
determines the appropriateness of limited replacement of historic windows on
the basis of which elevation on a building a window is located. Under this option
any window could be replaced on a tertiary elevation while no windows could
be replaced on a primary elevation. Saldibar and Pallante point out that this
"elevation based" approach fails to take into consideration the importance of
looking at each building as a whole and the possibility of unique circumstances
under which such an application might conflict. For instance, there may be
circumstances where a contributing building in a historic district or an individual
landmark may contain important character defining features on a secondary
elevation. Likewise, non-historic windows may exist on the primary elevation of
a designated historic building which could not be replaced under Option B, as
originally presented.
Staff has revised Option B in an attempt to make it more consistent with the
Secretary of the Interior's Standards for Rehabilitation. The revised Option B
provides for consideration of the replacement of windows on primary and
tertiary elevations of a building based upon their significance to historic
character of the building. This revised option provides for more flexibility by
approaching window replacement on a case-by-case basis while taking into
consideration the importance of looking at each building as a whole.
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1) Revised Option B: Preservation based upon importance of window or door
to the building as a whole.
• Generally reflects current historic preservation practice.
• Replacement depends on historic significance of the window (or door):
Primary elevation ("front") - in most cases windows and doors
must be preserved on these elevations. If windows are non-historic
(less than fifty years in age) they may be replaced with energy
efficient windows that closely replicate what were on the building
historically.
Secondary elevation ("side") - in most cases windows and doors
should be preserved. Limited replacement may be appropriate
based upon the historic character and value of windows and their
public visibility. If windows are non-historic (less than fifty years in
age) they may be replaced with energy efficient windows that
closely replicate what were on the building historically.
Tertiary elevation ("rear") - in most cases windows and doors may
be replaced. If windows or doors are deemed to impart exceptional
character or value to the building they should be rehabilitated and
fitted with a storm system to improve energy efficiency.
• Character and value of windows and doors would be assessed on a case-
by-case based (with specific criteria for determination developed by staff
and adopted by the Landmarks Board as administrative regulation);
• An additional insulating layer of glazing, such as a storm window (or
door) or a second interior pane, is encouraged on inefficient historic
windows. Exterior storm windows (or doors) should match the material,
proportions, and profile of the underlying window or door as closely as
possible.
• Historic windows (or doors} if deemed deteriorated beyond repair, may
be replaced. Approval of a replacement would be based on a formal
evaluation of the window (door) condition/deterioration against criteria
developed by staff and adopted by the Board. This could be a form filled
out by the homeowner and submitted with photos for review by staff.
• Any replacement of a historic window (or door) should replicate the
material, design, profile and dimensions of the original as closely as
possible.
• Solar collectors and skylights are allowed on more visible elevations of a
building.
• Shutters are allowed on primary elevation if there is historic precedent,
and on secondary and tertiary elevations.
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Options Evaluation
Option A: Preserve all Revised Option B: Preservation Option C: Allow
Goal: historic windows based upon importance of window replacement of all
or door to the building as a whole. historic windows
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certificate. , ` '
Original Option B
Staff originally recommended Option B to the EAB and LPAB, considering that it
would provide a reasonable compromise between replacement and preservation
of historic windows, based on the historic significance and visibility of the
elevation where the windows are located (and on the historic value of the
windows on the secondary elevation). The objective of this option was to offer
property owners flexibility to replace windows for energy efficiency or other
personal reasons where less historic significance is at stake, while being more
protective of windows that are more historically significant.
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Revised Option B
At the Apri126, 2006 joint meetings of the EAB and LPAB, the boards both opted
for Option A. The majority of board members stated that they considered the
difference in energy efficiency between Options A and B wasn't great enough to
justify allowing the removal of historic resources, particularly if property owners
are encouraged to weather-strip and add an additional layer of glazing, such as a
storm window or second interior pane. There seemed to be agreement that on a
broad environxnental perspective, allowing windows to be replaced on the small
percentage of designated historic buildings whose owners might consider new
windows (currently less than 2% of the buildings in Boulder are designated
historic) will not make a notable difference in reducing city-wide greenhouse gas
emissions.
Staff considers that revised Option B provides a more reasonable compromise
between the preservation and replacement of windows and doors on historic
buildings; and one that is more consistent with existing historic preservation
philosophy.
The main disadvantage of adopting revised Option B would be the increased
level of complication and uncertainty of case by case review for the replacement
of historic windows and doors. Implementation of this policy would require the
development of standards to assess the historic importance and relative
conditions of historic windows and doors. It could add time to the review/
approval timeline for a Landmark Alteration Certificate (currently
approximately one week) (For context, the total review/ approval timeline for a
remodel or addition project that requires an alteration certificate as well as a
building permit [with or without a Green Points requirement] is about 6-10
weeks.)
NEXT STEPS:
On November 8~', the Environmental Advisory Board will review the revised
Option B, and if appropriate, amend their Apri126~' motion that the City Council
direct staff to adopt a policy consistent with Option A. The City Council is
scheduled to take the matter up in a public hearing on December 5~. If the City
Council chooses to adopt revised Option B, staff will draft administrative
regulation consistent with the policy that will be reviewed, and if appropriate,
adopted by the Landmarks Board. This administrative regulation would consist
of amendments the design guidelines and development of specific criteria to
assess the relative importance and condition of windows and doors on historic
buildings.
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ATTACHMENTS:
Attachment A: 10/25/061etter from Joseph Saldibar regarding proposed
revisions to Option B.
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James Hewat - Option B
From: <Joseph.Saldibar@chs.state.co.us>
To: <hewatj @bouldercolorado.gov>
Date: 10/25/2006 3:44:58 PM
Subject: Option B
James,
Attached are my comments for the revisions to Option B, part of Boulder's
Environmental Sustainability Integration Project.
On page 4, the idea of historic windows as being inefficient (and of new windows
being energy efficient) is presented several times. I'm concerned that this may
give folks the impression that old windows are naturally inefficient, which is not
entirely true. It also makes it seem as if people are "stuck with" these old
inefficient windows because they happen to be in a certain spot, or of a certain
sryle.
On the same theme, there is no real definition for what "closely replicate" means
(with regards to replacement windows.) The folks who sell vinyl windows with
the snap-in grids market their products as :closely replicating" historic windows,
but it takes a good imagination (and perhaps some poor eyesight) to believe that
statement. Perhaps an addendum is needed to describe what kinds of features
make a replacement window a"good" replacement or a"bad" one?
I'd also recommend some guidelines for the placement of solar collectors and
skylights on the roofs of homes, particularly when placed on the front elevation
(or other public-viewable area).
Finally, although Option B would increase review time, it does not appear to
substantially increase review times, as noted on Page 7. One Page 6, the
estimated review time is given as "one to two" weeks, just a bit longer than the
one week predicted for Options A and C.
On the whole, however, I think that Option B is very flexible and fair, and
balances the needs of energy efficiency and historic presenration.
n~ ~,. R~'~~ ~;~ a-~~ _~=aU~ ~~
file://C:~Documen[s and Settines\hewail~L.ocal Settines\Temn\GW }00OO1.HTM 10/26/2006
ra~e ~ ui t
Joe Saldibar
Architectural Services Coordinator
Colorado Historical Society
303-866-3741
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