Item 5C LDRC Adjustments 10.09.24MEMORANDUM TO THE LANDMARKS BOARD
October 9, 2024
STAFF
Brad Mueller, Director of Planning and Development Services
Kristofer Johnson, Comprehensive Planning Senior Manager
Chris Reynolds, Deputy City Attorney, City Attorney’s Office
Marcy Gerwing, Principal Historic Preservation Planner
Clare Brandt, Historic Preservation Planner
Aubrey Noble, Historic Preservation Program Coordinator
Meron Shiferaw, Historic Preservation Intern
AGENDA ITEM
Public hearing regarding process improvements for the Landmarks Board and historic preservation staff:
consideration of an administrative rule to expand the types of projects that can be reviewed by staff, and
consideration of a code amendment to extend the time for initial review and project approval.
EXECUTIVE SUMMARY
The purpose of this item is for the Landmarks Board to review community feedback received related to a pending
Administrative Rule to expand the types of Landmark Alteration Certificate (LAC) projects that can be reviewed by
staff.
On Sept. 4, 2024, the Landmarks Board voted to adopt an Administrative Rule to expand the types of projects that
can be reviewed by staff (see Attachment B) and voted to recommend to City Council code amendments to
extend the initial review period from 14 to 21 days and the approval period (expiration date) from 180 days to
one year for Landmark Alteration Certificate (LAC) and Non-Designated Demolition applications. Reference the
Sept. 4, 2024 Landmark Board Memo (link).
The Boulder Revised Code requires publication of the Administrative Rule in a newspaper, followed by a 15-day
Public Comment period. An online questionnaire was available between Sept. 1-30, with the option to email
additional comments directly to the Landmarks Board.
In total, 38 responses were received, with the majority in favor of the proposed changes. No comments were
received suggesting specific modifications to the Administrative Rule, and many comments made broad
statements about historic preservation and permit review in Boulder. See Attachment A.
This is a public hearing item and the Landmarks Board has the following options:
Item 5C - LDRC Adjustments
1.Make no further changes to the Administrative Rule. The rule would go into effect once signed by the
chairperson of the Landmarks Board and the City Attorney’s Office, and then filed with the city clerk.
2.Add or remove items from the Administrative Rule. The revised rule would then be reviewed by the
City Attorney’s Office, followed by another newspaper publication and 15-day public comment period
and a public hearing to review the comments.
RECOMMENDED MOTION LANGUAGE
Make No Further Changes
I move the Landmarks Board not make further revisions to the Administrative Rule included as Attachment B and
adopted by the Landmarks Board on Sept. 4, 2024 to expand the types of projects that may be reviewed by staff.
Make Further Changes
I move the Landmarks Board make further revisions to the Administrative Rule included as Attachment B and
adopted by the Landmarks Board on Sept. 4, 2024 to expand the types of projects that may be reviewed by staff.
The changes include:
1.Remove [placeholder]
2.Add [Placeholder]
3.Revise [Placeholder]
COMMUNITY ENGAGEMENT
The Administrative Rule process included a public hearing at the Landmarks Board on Sept. 4, 2024, followed by a
public notice published in the Daily Camera on Sept. 11, 2024 inviting comments during the 15-day public
comment period.
An online questionnaire was posted on the P&DS Code Change website from Sept. 1-30, 2024. Additionally, staff
notified approximately LDRC applicants from the last 6 months (approximately 80 recipients) of the proposed
changes and included information in the P&DS Newsletter (approximately 5,000 recipients).
The questionnaire asked respondents whether they agreed or disagreed with each of the three proposed changes
and provided an open comment box for additional comments. In total, 38 responses were received, with the
majority (61%) strongly agreeing or agreeing to the proposed changes. No comments were received suggesting
specific modifications to the Administrative Rule, and many respondents made broad statements about historic
preservation and permit review in Boulder. See Attachment A: Questionnaire Responses Received Sept. 1-30,
2024
PROCESS AND TIMELINE
The Landmarks Board may adopt an Administrative Rule, while code amendments require review by the
Landmarks Board and City Council. The following table outlines the respective processes.
Timeline Administrative Rule Code Amendment
Item 5C - LDRC Adjustments
August 7, 2024 Confirm direction with Landmarks Board (Matters)
Analysis
Draft Administrative Rule and Landmarks Board Memo
Approval by CAO as to form Review by CAO
September 4,
2024
Landmarks Board Public Hearing to Adopt Administrative Rule and Recommend
Code Amendment to City Council
Publish in Newspaper
Prepare City Council Memos
15-day Public Comment Period
October 9, 2024 Landmarks Board Review of Comments
(Matters); if no changes, rule goes into
effect.
November -
December 2024
City Council 1st Reading
City Council 2nd Reading (Public Hearing);
if adopted, changes go into effect.
Update Forms and Website
December 2024 Internal and External Communication
NEXT STEPS
If the Landmarks Board does not make additional changes to the Administrative Rule, it will go into effect
immediately. If the board chooses to make additional changes, the revised rule would be reviewed by the City
Attorney’s Office, followed by another newspaper publication and 15-day public comment period and a public
hearing to review the comments.
The Landmarks Board recommendations on the proposed code amendments will be included in the City Council
memos. Staff is currently drafting the memos and ordinance, and it is anticipated to be reviewed by the City
Council on November 21, 2024 and December 19, 2024 (dates subject to change based on Council Agenda
Committee).
ATTACHMENTS
Attachment A: Questionnaire Responses Received Sept. 1-30, 2024
Attachment B: Administrative Rule
Item 5C - LDRC Adjustments
ATTACHMENT A: QUESTIONNAIRE RESPONSES RECEIVED SEPT. 1-30, 2024
Question No. 1: I support expanding the following types of historic preservation projects that may be reviewed by
city staff: Structural repairs, sidewalk and/or driveways, re-grading, hardscaping and/or retaining walls, fences,
patios, decks and/or railings, trim and/or siding, painting and/or paint colors, storm windows and/or doors,
window rehabilitation, skylights, roofing, solar panels and/or solar battery storage, mechanical units, commercial
awnings, signs, lighting, gutters, bike racks and/or e-bike stations, electric vehicle chargers, Historic Preservation
Residential State Tax Credits
Of the 36 responses received for the first question, 25 percent strongly agree, 36 percent agree, 28 percent
disagree and 11 percent strongly disagree with the proposed change to expand the types of LAC projects that can
be reviewed at the staff level.
Question No. 2: I support extending the initial review period from 14 days to 21 days.
28%
11%
36%
25%
Expanded Staff Review of LAC
applications
Strongly Disagree Disagree Agree Strongly Agree
Item 5C - LDRC Adjustments
Of the 36 responses received for the second question, 11 percent strongly agree, 42 percent agree, 19 percent
disagree and 28 percent strongly disagree with the proposed change to extend the initial review period from 14 to
21 days.
Question No. 3: I support extending the approval period (expiration date) from 180 days to one year.
Of the 36 responses received for the third question, 44 percent strongly agree, 42 percent agree, 6 percent
disagree and 8 percent strongly disagree with the proposed change to extend the approval period (expiration
date) from 180 days to one year.
28%
19%
42%
11%
Extend Initial Review Period from 14 to
21 Days
Strongly Disagree Disagree Agree Strongly Agree
8%
6%
42%
44%
Extend Expiration Date from 180 days to
1 Year
Strongly Disagree Disagree Agree Strongly Agree
Item 5C - LDRC Adjustments
Question No. 4: Do you have any additional comments related to potential changes to the historic preservation
review process?
The full set of comments received is included in the table below.
I support
expanding the
following types of
historic
preservation
projects that may
be reviewed by
city staff:
[reference list
above]
I support
extending the
initial review
period from 14
days to 21 days.
I support
extending the
approval
period
(expiration
date) from 180
days to one
year.
Do you have any additional comments related to
potential changes to the historic preservation
review process?
Agree Agree Agree As a counterbalance, demolition permit reviews
could provide more time to accommodate
community appeals, and processes for those
appeals to be heard and ruled upon.
Strongly Agree Strongly Agree Strongly Agree How about the single dissenting vote that can
move a project from LDRC to full Board. Maybe
switch to a majority instead? Seems like a fair
number of cases end up before the full Board that
doesn't change the opinion of the majority at
LDRC.
Strongly Agree Strongly Agree I don't understand th impact of an initial review
period extension so left that answer blank
Agree Strongly Agree Agree I need to know more about this in order to give
the best feedback
Strongly Disagree Strongly Disagree Strongly Agree I would highly suggest enabling more decision
making to happen at the LDRC level. The LAC
process can be prohibitively costly, in time and
monetary costs, dissuading homeowners from
making improvements that would extend the lives
of their historic homes, or new, motivated buyers
to move to historic areas and invigorate the
neighborhood. I think opening up the projects
outlined above to be handled by city staff is a
great first step!
Item 5C - LDRC Adjustments
Strongly Disagree Strongly Disagree Strongly Agree I would highly suggest enabling more decision
making to happen at the LDRC level. The LAC
process can be prohibitively costly, in time and
monetary costs, dissuading homeowners from
making improvements that would extend the lives
of their historic homes, or new, motivated buyers
to move to historic areas and invigorate the
neighborhood. I think opening up the projects
outlined above to be handled by city staff is a
great first step!
Agree Strongly Disagree Strongly Agree I'm fine with letting staff review more things,
provided (a) they are required by ordinance to do
so in a timely manner (ideally 1 week, definitely
no more than 2 weeks) and (b) the owner can
appeal denials to the LDRC and/or the Landmarks
Board.
Strongly Disagree Strongly Disagree Strongly
Disagree
It's already so difficult for people to get through
the City review process and you guys are
apparently too busy to help businesses and so the
best ones leave and incur unnecessary costs and
taxes. Fresh Thyme and Under the Sunb are two
recent examples. Reviewing all of this stuff makes
it more expensive. Get more employees who are
efficient and helpful and stop wasting our tax
money on this and a private library district, both
of which are expensive and elitist. And trust me,
most middle aged and younger people are not
commenting. Very little of Boulder's architecture
is actually nice and pretty soon staff will be saying
a tract home in Martin Acres needs to be saved
because it represents an instrumental and
impactful period of history.
Agree Disagree Strongly Agree I've always thought that it might be more helpful
when it comes to the Historic Demo Permit for a
house over 50 years old but has no historic
significance at all, that maybe Landmarks should
actually go throughout the City and make a
permanent list of houses/address that would
require this historic demo permit. Instead of
having this usually be a pointless requirement for
majority of the homes in Boulder.
Strongly Agree Please make it more user friendly and allow for
energy conservation and renewable energy to be
used.
Item 5C - LDRC Adjustments
Disagree Disagree Disagree There should be fewer restrictions and a more
streamlined process, not more restrictions and a
slower process.
Strongly Disagree Strongly Disagree Strongly Agree
Strongly Disagree Strongly Disagree Strongly Agree
Strongly Agree Strongly Agree Agree
Agree Agree Strongly
Disagree
Disagree
Strongly Disagree Strongly Disagree Strongly
Disagree
Strongly Agree Agree Agree
Disagree Disagree
Strongly Disagree Strongly Disagree Strongly
Disagree
Disagree Disagree Disagree
Strongly Disagree Strongly Disagree Strongly Agree
Agree Agree Agree
Strongly Disagree Strongly Disagree Strongly Agree
Strongly Agree Disagree Agree
Strongly Agree Strongly Agree Agree
Agree Agree Agree
Agree Agree Agree
Agree Agree Strongly Agree
Strongly Agree Agree Strongly Agree
Strongly Disagree Agree Strongly Agree
Strongly Agree Agree Agree
Agree Agree Agree
Agree Agree Agree
Strongly Disagree
Strongly Agree
Disagree Strongly Agree
Agree Disagree Agree
Agree Agree Agree
Strongly Agree Agree Strongly Agree
Item 5C - LDRC Adjustments
Disagree Agree Agree
Item 5C - LDRC Adjustments
STANDARD
Contract Routing Cover Sheet
Please print and attach to your document
You can view the status of your contract using the Contract Tracking Status Page.
Routing Number 20240813-2420
Originating Dept Planning & Development Services
Contact Person Amanda Cusworth Phone Number 303-441-3215
Project Manager / Contract
Administrator
Marcy Gerwing E-mail gerwingm@bouldercolorado.gov
Counter Parties City of Boulder
Contract Title / Type Staff Review of Landmark Alteration Certificates
Number
Description Non-emergency Rule Change to Staff Reviews related to Landmark Alteration Certificates and the
business of the Landmarks Board
Special Instructions Was not sure who counter party should be. Route to CAO Route to CMO Route to City Clerk Return
Document to Document Administrator
Amount Expense Type
Dept. Head Signature_______________________________________
NOTE; Originating Department: Identify with a check mark all areas document needs to be routed.
Purchasing_________________________________________________
Budget_____________________________________________________
Sales Tax__________________________________________________
CAO _______________________________________________________
City Manager_______________________________________________
Central Records____________________________________________
Contract Tracking Home | Signature Routing Form | Track Contract Status | Update Contract Status
8/13/24, 2:45 PM Contract Tracking > Thank You
https://work.bouldercolorado.gov/ContractTracking/servlet/Controller 1/1
9-11-14.A(24)
STANDARD (NON-EMERGENCY) REGULATION/RULE
Staff Review of Landmark Alteration Certificates
BRC Section that is the subject of this Rule: Section 9-11-14(a)(2) B.R.C. 1981
1.The Landmarks Board hereby identifies the following common types of alterations that
are very familiar to the City Manager and that may be reviewed and approved
unilaterally by the City Manager pursuant to paragraph 9-11-14 (a)(2) B.R.C. 1981:
1.Structural Repairs
2.Sidewalk and/or driveways
3.Re-grading, hardscaping and/or retaining walls
4.Fences
5. Patios, decks and/or railings
6. Trim and/or siding
7.Painting and/or paint colors
8. Storm windows and/or doors
9. Window Rehabilitation
10. Skylights
11. Roofing
12. Solar panels and/or solar battery storage
13.Mechanical units
14.Commercial awnings
15. Signs
16. Lighting
17.Gutters
18. Bike Racks and/or e-bike stations
19.Electric Vehicle chargers
20.Historic Preservation Residential State Tax Credits
2.To the extent only of any conflict, this Rule supersedes any conflicting Rules or parts
of Rules, including, without limitation, 10-13-14.B(99) and 10-13-14.A(00).
9-11-14.A(24)
*** NOTICE TO THE PUBLIC ***
Rule ___________________
As adopting authority, on September 4, 2024 the Landmarks Board, filed with the city
clerk a Rule proposing to:
This rule expands the types of alterations to historically designated properties that can be
reviewed by staff.
Copies of the Rule are available for public review at the Central Records Office at the
Municipal Building, 1777 Broadway, 2nd floor.
The public has a right to submit written comments on the proposed rule for 15 days from
the date of this publication (September 26, 2024). Please direct written comments to:
Marcy Gerwing
Principal Historic Preservation Planner
City of Boulder - Planning and Development Services
PO Box 791
Boulder, CO 80306
historicpreservation@bouldercolorado.gov
For more information, visit
https://bouldercolorado.gov/government/departments/historic-preservation or call 303-
441-3207.
If no written comments are received, the Rule will become final when the time for
comments has passed.
9-11-14.A(24)
STANDARD (NON-EMERGENCY) RULE SIGNATURE PAGE
Staff Review of Landmark Alteration Certificates
Originating Department – B.R.C. Section Granting Rulemaking Authority:
Section 9-11-24
City Attorney’s Office – Approval as to form and legality:
The proposed Rule was approved as to form and legality for adoption on
________________________ (date).
Signature: _______________________________
City Manager / Adopting Authority – Approval as to substance
The proposed Rule was approved as to substance prior to publication and three copies were
filed with the City Clerk on ________________________ (date).
Adopting Authority Signature: _______________________________
City Clerk Publication:
The public notice will be published in the Daily Camera on ______________________
(date), starting a 15-day written comment period ending on ______________________.
____No comments were received. The proposed Rule is in effect as of the end of the
comment period.
City Clerk Signature: _________________________________
City Manager / Adopting Authority - Comment Review/Effective Date:
8/21/2024
September 11, 2024
September 26, 2024
____ Written comments were received for this Rule, and no change has been made. The
Rule is in effect as of the end of the comment period.
____ Written comments were received for this Rule. The Rule was amended and returned
to the City Attorney’s Office for review on __________________. The Rule is effective
upon approval of the City Attorney.
City Attorney approval Date:________________________________
Signature: ____________________________
____ Written comments were received for this Rule. The Rule has been amended and will
be republished.
Adopting Authority Signature: _______________________________