07.12.23 Item 5D Civic Area HD Initiation Memo
MEMORANDUM TO THE LANDMARKS BOARD
July 12, 2023
STAFF
Brad Mueller, Director of Planning and Development Services
Kristofer Johnson, Comprehensive Planning Senior Manager
Lucas Markley, Assistant City Attorney, City Attorney’s Office
Marcy Gerwing, Principal Historic Preservation Planner
Clare Brandt, Historic Preservation Planner
Aubrey Noble, Historic Preservation Program Coordinator
Olivia Simard, Historic Preservation Intern
INITIATION OF LANDMARK DESIGNATION
Public hearing and consideration of a motion to adopt a resolution to initiate the process for the
designation of a historic district encompassing a portion of the area from 1777 Broadway to 14th Street
and between Canyon Boulevard and Arapahoe Avenue pursuant to Section 9-11-3 of the Boulder
Revised Code, 1981.
Address: 1236 Canyon Blvd., 0 13th St., 1300 Canyon Blvd., 1770 13th St.,
1750 13th St., and a portion of 1777 Broadway
Owner: City of Boulder
Applicant: Historic Boulder, Inc., Friends of the Bandshell, and Friends of
the Boulder-Dushanbe Teahouse
Case Number: HIS2023-00081
Case Type: Initiation of Historic District Designation
Code Section: 9-11-3, B.R.C., 1981
EXECUTIVE SUMMARY
This is an application to designate city-owned properties in the Civic Area as a contiguous historic
district, including Central Park and five designated landmarks. The application was submitted by Historic
Boulder, Friends of the Bandshell and Friends of the Teahouse. The hearing is legislative and the criteria
is found in 9-11-3, B.R.C., 1981. The Landmarks Board may either vote to initiate the designation
process, or vote to not accept the application. If the board votes to not initiate designation, a historic
district could be considered in the future through a new application.
STAFF RECOMMENDATION
Staff recommends the Landmarks Board not initiate the process for historic district designation in order
to allow for the completion of the Cultural Landscape Assessment (CLA) to assess the parkland as a
designed landscape, and understand its characteristics as defined by the National Park Service, such as
its spatial organization, circulation, vegetation and views and vistas, in addition to the significance,
integrity and treatment recommendations. It will also allow for more robust community engagement to
assess the level of support for the proposed designation as well as inter-departmental collaboration
necessary for City-owned properties.
RECOMMENDED MOTION
If the Landmarks Board chooses to not initiate the process for reviewing the designation boundary, staff
recommends the following motion language:
I move that the Landmarks Board adopt the staff memorandum dated July 12, 2023, as the findings of
the board and not initiate the historic district designation process for a portion of the Civic Area, as
shown in Figure 2, finding that while the area may be potentially eligible for historic district designation,
the request is not in the public interest to proceed at this time and therefore does not meet the criteria
for such initiation pursuant to Section 9-11-3 “Initiation of Designation for Individual Landmarks and
Historic Districts” of the Boulder Revised Code 1981.
ALTERNATIVE MOTION LANGUAGE
If the Landmarks Board chooses to initiate the historic district designation process, staff recommends
the following motion language:
I move that the Landmarks Board adopt a resolution (Attachment B) to initiate the historic district
process for a portion of the Civic Area, as shown in Figure 2, finding that it meets the criteria for such
initiation pursuant to Section 9-11-3 “Initiation of Designation for Individual Landmarks and Historic
Districts” of the Boulder Revised Code 1981, and, in balance, is consistent with the goals and policies of
the Boulder Valley Comprehensive Plan.
SUMMARY
• On Aug. 27, 2021, the Landmarks Board received a letter from the Friends of the Bandshell (link)
requesting Landmarks Board consider an expansion of the landmark boundary of the Glen
Huntington Bandshell, an individual local landmark (Ordinance 5751), to include the entirety of
Block 13 (1236 Canyon Blvd.).
• In November 2021, the Landmarks Board initiated the process to expand the boundary and in April
2022, the Landmarks Board voted to recommend expansion of the boundary. The Parks and
Recreation Advisory Board (PRAB) requested that the decision be postponed in order to allow time
for additional review and coordination with the forthcoming Civic Area Phase 2 planning and design
process.
• On June 14, 2022, City Council held a public hearing and voted against the expansion of the
boundary and gave a Nod of Five to “have Landmarks staff investigate and explore the creation of a
downtown area historic district that would include this area, saying they would work with the
Landmarks Board and Parks Board moving forward.” See City Council 06.14.2022 recording (link).
• Following Council’s direction at the June 14, 2022 meeting (item 4B, page 70), Historic Preservation
and Parks and Recreation staff jointly established an approach to evaluate a Historic District in the
Civic Area by developing a Cultural Landscape Assessment, which would be integrated into the
Reimagining Civic Area Phase 2 process and timeline, and inform the next phase of park design for
the Civic Area. See City Council 05.18.2023 information packet item (link).
• On May 30, 2023, the Planning & Development Services Department accepted a complete
application for a proposed historic district in the Civic Area. See Attachment C: Historic District
Application.
• Pursuant to Section 9-11-3 of the Boulder Revised Code, 1981, the Landmarks Board must hold an
initiation hearing within 45 days.
UPDATE ON THE CULTURAL LANDSCAPE ASSESSMENT
A Cultural Landscape Assessment focused on Central Park is currently underway by Boulder Parks and
Recreation (BPR) staff and is anticipated to be complete by September. The report is being prepared in a
stepped approach and a consultant will be hired to peer-review the assessment. First, the chronological
history of Central Park will be assembled and divided into historic periods associated with the
development of the park; this will enable identification of a historic period for historic significance. If
there is no historic period with historic significance, the assessment will stop, as future steps will be
unnecessary.
If the park is determined to have a historic period that is historically significant, the integrity for the
period will be then assessed. If the historic period of significance also retains integrity, Central Park will
be deemed to have significance for the associated period of significance and will require Treatment
guidelines. Treatment guidelines begin with providing an overall approach (Rehabilitation, Preservation,
or Restoration) and then further guidelines are provided regarding the major characteristics of the
landscape. If the first and second steps of this assessment conclude the area does not possess
significance or integrity, then work on the CLA will stop and the City will not apply for historic district
designation. If the area is found to be historically significant and retains its integrity, the City will
consider the historic boundary for the period of significance related to the park landscape and initiate
Historic District designation and the treatment recommendations will be proposed as design
guidelines.
The benefit of the CLA is to assess the parkland as a designed landscape, and understand its
characteristics as defined by the National Park Service, such as its spatial organization, circulation,
vegetation and views and vistas, in addition to the significance, integrity and treatment
recommendations. If there is historic significance, The CLA will be integrated into the Reimagining Civic
Area Phase II process and timeline, and will inform the next phase of civic design along with other
factors such as accessibility, public engagement, BPRs Design Standards manual, floodplain
requirements, etc. The Civic Area Phase II project is currently in its planning phase, with site analysis
starting in 2024, schematic design anticipated to begin at the end of 2024 and implementation starting
in 2026.
PROPOSED HISTORIC DISTRICT BOUNDARY
The proposed historic district includes Central Park (the area between Arapahoe Avenue and Canyon
Boulevard, and Broadway and 13th Street), five individually designated buildings and a portion of each
of the properties (Figure 1).
The proposed district includes the area to each of the property lines of the designated landmarks with
the exception of the western portion of 1777 Broadway (the Penfield Tate II Municipal Building) and the
southern portion of 1750 13th St. (City Storage and Transfer Building/BMoCa). The proposal also
includes the three lots to the south of 1236 Canyon Blvd. (the Glen Huntington Bandshell) that comprise
the southern part of Central Park and are addressed 0 Canyon Boulevard The proposal also includes
portions of public rights-of-way – Broadway (a Colorado state highway) and 13th Street (a local road).
Figure 1. Proposed district (blue outline – property lines are solid; across property lines are dashed) and
areas already designated through ordinance (noted in blue). Staff analysis.
Figure 2. Proposed district provided by applicant.
SITE DESCRIPTION AND AREA HISTORY
The site description and history of the area is included as Attachment A: Site Description and Area
History – Preliminary Analysis. The history of the area proposed as a historic district spans the course of
the Twentieth Century, with the following general periods of development:
• 1859 – c.1900: Prior to the Formation of the Boulder City Improvement Association
• 1903-1922: Boulder City Improvement Association and Frederick Law Olmsted, Jr.
• 1923-1947: FLO Jr., Saco DeBoer, and the Creation of Central Park
• 1945-1961: Development of the Municipal Building and Civic Area
• 1969-1998: Development of the East Bookend
As a whole, this area in downtown Boulder illustrates a progression of styles spanning the Twentieth
Century, including the following buildings and features. If the Landmarks Board initiates the designation
process, additional analysis would be completed to define the period of significance and identify
contributing and non-contributing features.
• Central Park, an urban park designed by Olmsted Brothers in 1924;
• The Storage and Transfer Building, an early 20th century commercial building constructed in
1906;
• The Glen Huntington Bandshell, completed in 1938 after designs by its namesake, a prominent
architect and one of the few examples of Art Deco design in Boulder and one of only two
bandshells in the state of Colorado;
• The Penfield Tate II Municipal Building, designed in the International Style by notable architect
James Hunter and the location of Boulder’s civic activities since its completion in 1952;
• The Atrium Building, a Rustic Modern building designed by notable architect Hobart Wagener
and constructed in 1969;
• The Boulder-Dushanbe Teahouse, constructed in Tajikistan between 1988-1990 and
reconstructed in Boulder in 1997-1998. It is the only “chaikhona” (Central Asian/Tajik Teahouse)
in the Western Hemisphere. At the time of the gift, the Teahouse was the largest gift ever given
to an American city by the former Soviet Union.
• Boulder Creek Path (1980s), 13th Street Community Plaza, Civic Park Plaza and Sister Cities Plaza
(1996-2006);
• Boulder and White Rock Ditch, North Boulder Farmers, and Boulder Left Hand Ditch, which
bisects Central Park;
• Broadway Bridge, completed in 1921 and an example of early-twentieth century bridge design.
PURPOSE AND CRITERIA FOR THE BOARD’S DECISION
The Landmarks Board may hold a public hearing to consider initiating landmark designation and may
consider, Section 9-11-3 Initiation of Designation for Individual Landmarks and Historic Districts B.R.C.
1981, Section 9-11-1, Purpose and Legislative Intent, and Section 9-11-2, City Council May Designate or
Amend Landmarks and Historic Districts. Initiation hearings are legislative, not quasi-judicial.
To assist in the interpretation of the historic preservation ordinance, the Landmarks Board has adopted
significance criteria to use when evaluating applications for historic districts. The criteria are included in
Attachment D: Significance Criteria for Historic Districts (link) and will be evaluated in greater detail if
the designation process is initiated.
STAFF ANALYSIS
The following is the staff’s analysis of the standards for determining whether to initiate designation:
Section 9-11-3(d), Initiation of Designation for Individual Landmarks and Historic Districts
(1) There is probable cause to believe that the building or district may be eligible for designation as
an individual landmark or historic district consistent with the purposes and standards in sections
9-11-1 Legislative Intent, 9-11-2 City Council May Designate or Amend Landmarks and Historic
Districts, and 9-16-1, General Definitions B.R.C. 1981;
As detailed below, staff considers there is probable cause to believe the area may be eligible for
designation as a local historic district, based on:
1) Its inclusion of five significant buildings and their sites that have been previously designated;
2) Its historic significance in the history of Boulder’s park development and for the role played by
the Boulder City Improvement Association, Frederick Law Olmsted Jr., the Lions Club, and
consulting city planner S.R. DeBoer and its contribution to the social and cultural life of the city
for over a century;
3) Its architectural significance that includes work by notable architects, master builders, and
urban planners representing examples of a progression of architectural styles;
4) Its environmental significance for its planned and natural site characteristics that represents an
established and visual feature of the community.
Additionally, past determinations of eligibility have included assessment of the following structures:
• The Bandshell and its site is eligible for listing on the National Register (1995, 2016);
• Atrium Building is eligible for listing on State Register (2000);
• Boulder-Dushanbe Teahouse is eligible for listing on the National Register (2006);
• Broadway Bridge is eligible for listing on the National Register (2004).
Central Park was surveyed in 1995. However, an eligibility determination for local designation was
not made. The form states that the park is “significant for its association with the development of
the Boulder park system and with the activities and events for which the park provided a setting.”
(2) There are currently resources available that would allow the city manager to complete all of the
community outreach and historic analysis necessary for the application;
Designation of publicly-owned property requires a high level of analysis and community
engagement. If the designation process is initiated, staff will have 2-4 months to conduct a series of
stakeholder outreach efforts, including meetings with representatives from multiple city
departments, CDOT, and the Boulder and White Rock Ditch, North Boulder Farmers Ditch and
Boulder Left Hand Ditch companies. Community engagement efforts are also necessary and
anticipated to include several opportunities for walking tours, pop-up events and an online presence
through BeHeard Boulder.
Additional historic analysis will include determining the period of significance, historic district
boundary and name, identification of contributing and non-contributing features, and the
development of design guidelines.
Historic Preservation staff are currently collaborating with Parks & Recreation (BPR) staff on the
development of a Cultural Landscape Assessment (CLA) to thoroughly document the site and
understand the area as a designed landscape (see above “Update on Cultural Landscape
Assessment).
Completing the community outreach and historic analysis within the code-mandated timeframes
required through the designation process, in addition to work on the CLA and on-going program
operations, will stretch staff capacity and require other initiatives to be delayed or reduced in scope.
Those projects include improvements to the LDRC process, new Landmarks Board orientation
(August 2023), preparation for the 2024 Saving Places Conference, the Historic Preservation
Program’s 50th Anniversary Celebrations (2024), and the 10-year update to the Historic Preservation
Plan (2024).
Designation of publicly-owned property lends itself to an increased level of analysis and
community engagement. Not initiating the designation process at this time allows staff to focus
on exploring a potential historic district through the CLA and associated Civic Area Phase 2
planning processes. City staff will be able to streamline resources to build a more complete and
in-depth historic assessment of the area and be afforded greater flexibility to engage in robust
community outreach.
(3) There is community and neighborhood support for the proposed designation;
Three local historic preservation organizations, Historic Boulder, Inc., Friends of the Bandshell, and
Friends of the Teahouse, have partnered on the historic district designation application. Since the
application was submitted May 30, 2023, one letter of support for the historic district has been
received.
During the public hearings to consider expansion of the Bandshell boundary, public comment
included:
• Nov. 3, 2021, LB meeting: 8 people wrote to the LB regarding the application and 2 people
spoke regarding the application.
• April 6, 2022, LB meeting: 9 people wrote to the LB regarding the application, 4 people
spoke regarding the application.
• June 14, 2022, CC meeting: 9 people spoke.
As noted above in item (2), staff have not yet engaged in community outreach activities to gauge the
level of support across a broad spectrum of residents, businesses, and visitors that may be affected
by the proposed historic district designation.
(4) The buildings or features may need the protection provided through designation;
The proposed historic district includes five locally-designated landmarks, which already have the
protections provided through designation. Additionally, BPR’s Historic Places Plan (HiPP), currently
underway, will inform changes to the Bandshell site over time. In 2021, an extension of the
Community, Culture, Resilience and Safety Tax was approved by voters and includes funding to
“Improve the Boulder Creek Path Corridor; Implement the Boulder Civic Area Phase 2/Central Park
Improvements.” The Civic Area Phase 2 project is currently in the project scoping phase, with site
analysis starting in 2024, schematic design anticipated to begin at the end of 2024 and
implementation starting in 2026.
Historic District designation would add a layer of review for exterior changes to the landscape areas
within the district boundaries to ensure changes preserve and enhance the historic character of the
district and do not damage or destroy its contributing historic features.
(5) The potential boundaries for the proposed district are appropriate;
The application states “This boundary incorporates five landmarked city-owned properties, the full
extent of the historic Central Park, and the plaza between the Teahouse and the Atrium Building.
The proposed historic district provides area integrity by combining these significant properties in a
cohesive whole and celebrates the sense of place. The proposed boundary intentionally includes the
parking lots to the east of the Atrium Building, Teahouse, and the City Storage and Transfer
buildings. Proposed development on these properties should be reviewed for potential impact on
the historic structures and features. The applicants do support change here that is sympathetic and
respectful to the adjacent historic buildings, especially as the city begins to repurpose their
buildings.”
The National Register Bulletin for Defining Boundaries for National Register Properties provides the
following guidance:
o Select boundaries to encompass but not exceed the extent of the significant resources and
land areas comprising the property.
o Include all historic features of the property, but do not include buffer zones or acreage not
directly contributing to the significance of the property.
o Exclude peripheral areas that no longer retain integrity due to alterations in physical
conditions or setting caused by human forces, such as development, or natural forces, such
as erosion.
o Include small areas that are disturbed or lack significance when they are completely
surrounded by eligible resources. "Donut holes" are not allowed.
o Define a discontiguous property when large areas lacking eligible resources separate
portions of the eligible resource.
The proposed boundary includes Central Park, five designated City-owned buildings and their sites
and the related streets, plaza and parking lots. Staff considers the inclusion of Central Park, the five
City-owned landmarks and the streets and plaza to be appropriate as a concentration of significant
sites representing distinct periods of time spanning the Twentieth Century. However, staff considers
the inclusion of the parking lots on the eastern side of the proposed district to be inappropriate, as
they are not significant features, do not contribute to the district’s historic significance and are
proposed as a “buffer zone,” an approach discouraged by best practices. Inclusion of Broadway and
13th Street is also worthy of further review. Broadway acts as a physical and visual barrier and may
not be appropriate to include in the proposed district. However, 13th Street is more integral to the
character of the area and may be important to include, particularly in its current and future role as
an activated festival street.
(6) In balance, the proposed designation is consistent with the goals and policies of the Boulder
Valley Comprehensive Plan;
Designation of eligible historic districts is consistent with the following Boulder Valley
Comprehensive Plan policies:
2.27 Preservation of Historic & Cultural Resources The city and county will identify, evaluate
and protect buildings, structures, objects, districts, sites and natural features of historic,
architectural, archaeological or cultural significance with input from the community. The city
and county will seek protection of significant historic and cultural resources through local
designation when a proposal by the private sector is subject to discretionary development
review.
2.28 Leadership in Preservation: City- & County Owned Resources, which states, “The city and
county will evaluate their publicly owned properties to determine their historic, architectural,
archaeological or cultural significance. Eligible resources will be protected through local
designation, including secondary buildings or elements that are part of and convey the cultural
significance of a site, such as a farm complex and alley buildings.”
2.30 Eligible Historic Districts & Landmarks The city has identified areas that may have the
potential to be designated as historic districts. The Designated and Identified Potentially Eligible
Historic Districts map shows areas with designation potential as well as areas that are already
designated as historic districts (see Figure 6-1 on page 132). These potential historic areas and
historic survey information will continue to be assessed and updated. There are also many
individual resources of landmark quality both within and outside of these eligible areas.
Additional historic district and landmark designations will be encouraged in accordance with the
Plan for Boulder’s Historic Preservation Program. Such resources may contribute to cultural and
heritage tourism values.
2.32 Preservation of Archaeological Sites & Cultural Landscapes The city will develop a plan
and processes for identification, designation and protection of archaeological and cultural
landscape resources, such as open ditches (where practicable and in coordination with the
irrigation ditch company), street and alley-scapes, railroad rights-of-way and designed
landscapes.
(7) The proposed designation would generally be in the public interest.
Historic designation protects buildings and sites significant to Boulder’s history and enhances
property values, stabilizes neighborhoods, promotes tourist trade and interest and fosters
knowledge of the city’s living heritage.
Local historic district designation will not preclude alterations, additions, or even new construction
from occurring in the area but will ensure that such changes are undertaken in a manner compatible
with the historic character of the district.
Central Park and the surrounding civic buildings are important for the role they have played in the
social and cultural life of the city, as examples of a progression of architectural styles, and for
Central Park’s contribution to the history of park development in Boulder.
However, while there is probable cause to believe the area may be eligible for designation as a local
historic district, staff considers designation at this time would generally not be in the public interest
because the additional research and analysis to determine the significance of this area as a designed
landscape afforded through the CLA process is incomplete. Furthermore, the designation of publicly-
owned property requires an additional level of inter-departmental coordination and community
engagement because of the value it provides to all residents and visitors of Boulder. If the
designation process is initiated, staff will have relatively limited time to conduct the thorough
internal and external outreach efforts that are appropriate for a potential district of this importance.
BOARD OPTIONS
(1) DO NOT INITIATE LANDMARK DESIGNATION
The Landmarks Board may make a motion to not initiate landmark designation. A historic district could
be considered in the future through a new application.
(2) INITIATE DESIGNATION OF THE PROPERTY AS AN HISTORIC DISTRICT BY ADOPTING THE
RESOLUTION UNDER ATTACHMENT B.
If the Board chooses to initiate the process for reviewing the designation of the property, it must do so
by resolution. A draft resolution is included in Attachment B: Draft Resolution. If initiated, the
application will be scheduled for a public hearing before the Landmarks Board between 60 to 120 days
in order to determine whether the proposed designation conforms with the purposes and standards in
Sections 9-11-1 Legislative Intent and 9-11-2 City Council May Designate Landmarks and Historic Districts
B.R.C. 1981.
NEXT STEPS
If the Landmarks Board chooses not to initiate the process designating the historic district, the
application will be denied. A denial of the historic district application does not impact the five
designated individual landmarks, and the boundaries will remain as defined in the designation
ordinances for each individual landmark.
If the board chooses to initiate the process for reviewing the designation, it must do so by resolution. A
draft resolution is included in Attachment B: Draft Resolution.
Initiating designation is the first step in the process of considering historic district designation.
Subsequent steps include meetings with property owners/representatives, development of draft design
guidelines, and public hearings and recommendations on the proposed designation by the Landmarks
Board and the Planning Board. The City Council reviews the application and, if appropriate, designates a
district by ordinance.
If initiated, the designation process outlined above will begin and the application will be scheduled for a
public hearing before the Landmarks Board between 60 to 120 days in order to determine whether the
proposed designation conforms with the purposes and standards in Sections 9-11-1, “Legislative Intent,”
and 9-11-2, “City Council May Designate Landmarks and Historic Districts,” B.R.C. 1981.
ATTACHMENTS
A: Site Description and Area History – Preliminary Analysis
B: Draft Resolution
C: Historic District Application
D: Significance Criteria for Historic Districts (link)