Changes being proposed to the Certificate of Appropriatemness (COA) Process

[strider]

Basically the changes have to due with what can be approved administratively and what must go before the Historic Preservation Committee (HPC).  While it makes sense to have the HPC decide many things, today that process cost the applicant in both time and money.  Wisdom must be used in determining what the staff at the Historic Preservation Section ( of the Planning and Development Department - Community Planning) can approve administratively and what must be heard by the HPC. 

On MY Springfield,there has already been some discussion about this issue. (http://myspringfield.org/forum/viewtopic.php?f=19&t=2194 It is important though that all residents know what the proposed changes are and how they will affect their own property in Historic Springfield.

Initially, we heard that the proposed changes were going to be acted on this coming Wednesday without the benefit of any public comment except by both RAP and SPAR Council.  While many of the proposed changes seem to have been written by Staff, there are several that have large potential impacts being proposed by SPAR Council's Design and Review Committee. 

We recently have found that the Historic Planning Section is going to propose to the HPC that a subcommittee to study these issues -- what to do about nonconforming structures, and other administrative issues.  These meetings will be noticed SO ALL INTERESTED PARTIES can attend.  I'm sure it will also be recorded.

The proposed changes can be found here: http://forum.preservationsos.org/viewtopic.php?f=5&t=1151

The document is 16 pages so somewhat impractical to post the entire thing.  However, I will be posting the sections that seem to most effect the residents of Springfield.

[strider]

Before I post anything, I think it is only fair to re-post here what SPAR Council had to say about this:

by SPAR Council » Sat Jan 19, 2013 12:02 am
We have worked with Riverside Avondale Preservation (RAP) over several months on recommendations to refine the Administrative Approval guidelines used by Historic Preservation Commission (HPC). This document will be considered at the January HPC meeting and has been distributed. RAP's changes are highlighted in blue, ours are in pink, and the others come from HPC staff. Please email us atsparoffice@sparcouncil.org if you'd like a copy of this document.

HPC Staff is going to advice the HPC to assign consideration of the changes to the Admin guidelines to a Committee, and we have supported that recommendation.

In summary, the four general areas of our recommendations are:

1- ALLEYS - In Springfield, alleys should be considered right-of-ways with the same significance as other right-or-ways. This is not an issue for RAP.

2- ALTERATIONS ON NON-CONTRIBUTING STRUCTURES- The "notification" group of statements at the end (in grey highlighting) are intended to address the type of oversight that led to the demolition of the Westside Church of Chirst steeple.

3- FENCING - We would like to see any application for an 8' fence go to the Commission. We have also requested to embark on a process with HPC Staff to review the Springfield Fencing Guidelines.

4- ROOFING - Metal Shingle Roofs - We recommend that any replacement of a metal shingle roof with another type of material should go to the Commission. This recommendation simply reflects the Dept of Interior Guidelines for Historic Rehabilitation of buildings which state that roof replacements should be made with identical, or like, materials. This recognizes that the roof is a very significant part of a building's facade and integrity as a historic structure. In the past, the metal shingles were apparently not readily available so staff allowed replacement with other types of metal roofing material. Now, the shingles are available, and there are local roofers who can install them. Cost was not the issue for HPC. The issue was availability of product, and ability of local roofers to install the product. Any other type of non-identical roof replacement product, including more expensive products such as barrel tile, is already required to go to the Commission if a substitute product is being proposed by the applicant.

Thus, we are merely requesting application of nationally
recognized historic rehabilitation guidelines developed by the Dept of Interior. These Guidelines are what the HPC uses. These Guidelines are also incorporated in the "Historic Preservation Guidelines for
the Springfield Historic District". Please see the link, and you will see "Roofs" about half way down: http://www.coj.net/departments/planning ... WLEDGMENTS

Please email our Design & Review committee chair for more information or questions about this, as the D&R committee specializes in HPC guidelines and their implementation: joann.tredennick@gmail.com

Thank you!

[strider]

Throughout the document, SPAR Council has asked that the wording be changed from "(seen from) the street" to "right of way".  Their comment is below:

1- ALLEYS - In Springfield, alleys should be considered right-of-ways with the same significance as other right-or-ways. This is not an issue for RAP.

On the surface, this seems great and I agree that the alleys are indeed important and should be considered so. However, the implications of the change of wording in this document goes beyond recognizing the importance of the alleys, in fact, it does nothing at all for the alleys and makes the COA process more complex and expensive for everyone.

Currently, if you wish to restore your house and make sensible changes to the rear of the structure to meet current everyday living demands, there is a certain amount of freedom in what you do. You can remove a window for that needed bathroom, for instance. This can be approved because you can not see it readily from the street. Changing the wording to “right of ways” so it includes rear and side alleys means you might just have to leave that window. If the design and review committee (or someone on it) doesn't like you or the color you choose, they have more power to stop you from doing what you want because you can see it from the rear, over grown alley. There could be lots of unintended consequences from a minor change like this.

[strider]

The Proposed changes in the roofs section:

1)Roof replacement307.107(a)8
Admin
a.Matching existing/documented historic in materials and color 
b.When replacing composition shingles, replacement roofs are recommended for anything in the black, grey or brown family but even alternative colors can be approved (JHPC 2/22/12)**color may be conditioned if considered character defining 

HPC
a. White and alternative colors in any material which cannot be documented
b.If proposed roofing is questionable for the architectural style of the structure
c.Replacing with alternative materials that provide similar visual appearance of historic roofing 
d.Vegetative roofs that are not readily street visible. 

(Thses two items - moved here from Admin by SPAR)
e.Installing metal (shingle, shingle panel, 5V crimp or standing seam) or roofs for structures in Springfield that are Frame Vernacular but with no evidence of historic metal roof
f.In Springfield, the replacement of metal shingles with metal shingle panel, 5V crimp, standing seam or grey composition shingles

Today, if you have original metal shingles on your house and want to go back with a new metal roof, you can have the COA done administratively. Walk in (or e-mail), walk out and have your COA.

SPAR Council wants it changed to having to go to a HPC meeting unless you go back with the exact kind of metal shingle. That has never been done, by the way, due to the expense. (A couple have done front porches though - ask them about the expense.) Most go with 5 V crimp or an approved standing seam. A few have gone with the newer panel shingle systems, but that is also more expensive. A search on line lead to the possible cost of metal shingles compared to a standing seam material in the area of a 2 to 4 times cost increase to the owner.  There are, however, finacial hardship clauses within the codes that will still allow for the less expensive roofs to be approved.

What the proposed change means in the end is that it will delay the repair of your roof, cost you time personally (the meetings start at 3:00 PM during normal work hours)and cost you that $300.00 HPC fee for no reason at all. Except that SPAR Council wants you to pay it so they have a chance to give you a hard time at their Design and Review meeting about your COA to convince you to use the much more expensive roof.

And to the comments about insuring that the Department of Interior guidelines are followed?  The Historic Prexservation Staff must follow those guidelines whenever they approve a COA  as it is today anyway.

[Dog Walker]

There is another problem with considering the alleys as "right-of-way" for the purpose of COA's.  Many of us have solar hot water heaters and rain harvesting tanks in our back yards out of sight of the street that might not be permitted in the future.

It is my understanding that Federal law protects antennas and satellite dishes from being regulated by historic districts and HOA's.  Maybe the same protection needs to be extended to solar energy installations.

Wonder if there is a business opportunity for someone to manufacture metal roof shingles in the original style again.  Those old ternplate shingles have lasted for over 100 years in some cases.

[sheclown]

If we are honest with each other, there's nothing that we can't accomplish for Springfield.  If we aren't, there's nothing we can accomplish.

[strider]

Wonder if there is a business opportunity for someone to manufacture metal roof shingles in the original style again.  Those old ternplate shingles have lasted for over 100 years in some cases.

There has been for decades a company doing just that.  WF Norman offers an exact match for a victorian style shingle.  The estimated cost for the shingles themselves is at about $550.00 a square with shipping.  I would think that you could do better in quantity.  Newer companies are producing them as well and I have requested pricing info but from what I can see, it will be in the neighborhood of $250.00 to $300.00 per square. Last time I priced clip loc standing seam (a few months ago) it was $135.00 a square.  By the way, we are working on a house that all new WF Norman shingles were install on the porches.  They are about 12 years old now and are beginning to rust through the galvanize in places. Perhaps like wood, the materials used today just are not as good as they once were.

[Dog Walker]

The old shingles were coated with lead, not galvanized.  Today they should be using aluminum over steel, not galvanized.

At $300 per square and just galvanized, they are gouging.

[strider]

6)Demolition (307.106a)

Admin Approval
a. Accessory structures that are not architecturally significant and are deteriorated
b. Noncontributing structures (307.106a)
c. Demolition of a feature/space that is not architecturally significant or  right-of-way visible
d. MCC emergency declared NOTICE TO JHPC REQUIRED BY NEXT MEETING

HPC Approval
a.Contributing structures
b.Demolition of a significant feature
c.Unclassified (contributing/noncontributing) structures
d.Architecturally significant accessory structures
e.Demolition of retaining walls and 6’ walls


31) Alterations or additions to accessory structures

Admin Approval
a.When not readily visible from ROW and reasonably consistent with Regulations

HPC Approval
a.Second story additions
b.Dormer additions
c.2-story additions


32) Alterations to noncontributing structures built outside the period of significance

Admin Approval
a. Small/cosmetic changes such as the installation/ replacement of railings, window replacement and door replacement
b. Work that restores the historic appearance that is documented through pictorial, historic, physical evidence (see Restoring missing features)
c. When the proposed work does not negatively impact the historic design or overall character and otherwise meets the Regulations

HPC Approval
a. Larger scale changes that affect setbacks, wholesale change of style, and changes height
b. Wholesale changes in materials

33) Alterations to noncontributing structures built within the period of significance

Admin Approval
REVIEWED CASE BY CASE

The above are the proposed sections that really have to do with the steeple issue the most. At the time of the loss of the steeple, the wording was simply "reviewed case by case" for everything to do with noncontributing structures. The above changes that considerable.

However, when you read through the above sections, you will see that it would now be easier to demolish the entire church than to just remove the steeple.

This is what I personally think those sections should be:

26)Demolition (307.106a)

Admin Approval
a. Accessory structures that are not architecturally significant and are deteriorated
b. Demolition of a feature/space that is not architecturally significant or  right-of-way visible
c. MCC emergency declared NOTICE TO PUBLIC AND COMMUNITY ORGANIZATIONS REQUIRED PRIOR TO DEMOLITION.

HPC Approval
a.Contributing structures
b.Noncontributing structures (307.106a)
c.Demolition of a significant feature
d.Unclassified (contributing/noncontributing) structures
e.Architecturally significant accessory structures
f.Demolition of retaining walls and 6’ walls
g. MCC emergency declared demolitions justified to the HPC

31) Alterations or additions to accessory structures

Admin Approval
a.When not readily visible from ROW and reasonably consistent with Regulations

HPC Approval
a.Second story additions
b.Dormer additions
c.2-story additions


32) Alterations to noncontributing structures built outside the period of significance

Admin Approval
a. Small/cosmetic changes such as the installation/ replacement of railings, window replacement and door replacement
b. Work that restores the historic appearance that is documented through pictorial, historic, physical evidence (see Restoring missing features)
c. When the proposed work does not negatively impact the historic design or overall character and otherwise meets the Regulations

HPC Approval
a. Larger scale changes that affect setbacks, wholesale change of style, and changes height
b. Wholesale changes in materials

33) Alterations to noncontributing structures built within the period of significance

Admin Approval
a) determination if structure needs to follow the contributing or noncontributing COA path.
b) determination of the structure can be included in the contributing structure list.

[strider]

"Notification group of statements

Both Neighborhood Organizations would like Notification before Administrative Approval under the Following Conditions:
Work on corner lots
Work on a façade fronting a commercial corridor, including Urban Transition Area
Where there exists prominent visibility of structure due to massing and height in relation to surrounding structures or location on block
Where there is a significant architect or builder for structures built outside period of significance
Demolition request of any building or significant feature

Other areas of concern:
·         Accepting incomplete applications (JHPC to provide guidance on what they see as a complete application?)
·         Last minute alterations to scope of work or last minute submissions of vital information such as materials (JHPC to request deferral where last minute alterations do not provide appropriate time for neighborhood, commissioner and nearby property owner review â€" concern about public notice).
·         Staff reports should be provided at least one week in advance (JHPC to require staff report deadline or require deferral of item).

What SPAR Council has to say about this:

2- ALTERATIONS ON NON-CONTRIBUTING STRUCTURES- The "notification" group of statements at the end (in grey highlighting) are intended to address the type of oversight that led to the demolition of the Westside Church of Christ steeple.

What they are not saying is that under the municipal codes governing this, every single administratively issued COA can be appealed. The appeal must be filed under the same guidelines as an appeal of a HPC decision. However, there never was a system or policy put into place to notify anyone of the issuance of a administrative COA. This is one thing that PSOS requested, that everyone concerned be notified of all COA's, not just the HPC ones. There needs to be a public posting, not a private notification to RAP and SPAR, that everyone can see. It needs to be done at least weekly so that concerned people have the time they are legally given to review and appeal if they so choose.

While there is some risk of abuse in a case where one neighbor doesn't like another, for the most part, this simply is a check and balance on the administratively approved COA's. Frankly though, this risk has always been there and it hasn't been much of a problem. The real benefit is things like the past issue with the steeple. Had the public been given time to appeal that COA, Main Street would almost certainly still have that steeple. In addition, MCCD has a number of houses that were previously approved for demolition (placed on the “formal Track”) by the HPC with SPAR's consent. The only way to save these houses if MCCD decides to proceed with the demolitions is to appeal the administratively issued COA they must get to pull the demolition permit.

The other issue the above recommendations cover is the modification of a approved COA. This one the surface may make sense, but the reality is that it is a burden on everyone involved. Say you get permission for one window brand and then find it will take 6 months to get them. Now, staff can approve the switch to a different company's windows by simply insuring that the new windows comply with the guidelines. Under this proposal, you would have to go back to the HPC, spend more time and money to accomplish the same thing. Again, I have to ask, Why? Staff can and does follow the same guidelines HPC does. Staff can and should make decisions like this and keep the process streamlined and easier for the home owner. This part of the proposed change is simply hindering at it's best and should not be adopted.

[iloveionia]

What I take overall from this is that it will be more difficult to rehab properties in Springfield due to the hoops added to jump through.  Not looking to circumvent the historical guidelines, but staff should be able to administratively handle business as usual. 
That said.  The original uproar at least from PSOS was about the demolition of the steeple.  A preventative measure needs to be in place to prevent this from happening again.  And all people need to have the opportunity to be involved, not just select groups or people (as it seems to stand right now.)
Additionally, from the get-go (2007) I have always gone directly through the HPC staff and not the local neighborhood group.  That is the only thing that ever made sense to me, that being go to the source. 
Strider has an excellent perspective and experience in the hood and I agree with his statements.  He'd best show up to HPC when the time comes to voice his opinion.  (hint, hint.)

[chris farley]

Ionia states as follows
quote
Additionally, from the get-go (2007) I have always gone directly through the HPC staff and not the local neighborhood group.  That is the only thing that ever made[/i] sense to me, that being go to the source. "[/i]
end quote

Funny - and I do not know why I am bothering to answer this, but there are so many distortions.  PSOS have come to me several times when needing some help persuading the powers that be that certain things must and should be done.  I can go back and produce such exchanges.

Below is part of a series of private messages sent by you to me regarding your carriage house on Ionia.  You had been somewhat turned away by Joel's office when you requested that you be allowed to mothball the place.  Since it was discovered that the house was non contributing and so could not be part of the mothballing procedure.
Here is one of your pms, I can get others. The one below is not the original, in that you asked me how a house in Springfield could not be contributing.

Quote
Re: My Carriage House on Ionia

Sent: Sun Mar 04, 2012 3:59 pm
From: iloveionia
To: Chris Farley
What arguement do you think I would have against the commission to mothball it? I have all the blueprints and am ready to go in the fall for rehab, but mothballing stops the fines and harassment from code enforcement which is what i want.

User avatar
iloveionia
     
    Posts: 720
    Joined: Mon Nov 02, 2009 8:27 pm

end quote

When you came to me, as in other situations, I went looking for the history and found photos of other such carriage houses.   I contacted Joel's office and said I thought the building should be recognized, since I believed that the house that stood in front of it had lost its integrity and so was not counted and that caused the carriage house to also be discounted.  I will find the photos if you wish.
You were given permission to mothball, I do not know if you ever did

There is so much misconception re the DRC. Always, the SPAR office has advised people to approach Joel's office directly, but used to offer help in filling out COAs.  By the time the DRC gets to see the items that are passing through the HPC, that office already has made a quasi decision on what they believe should happen.  We listen, and mostly just agree with them.  If someone comes to the committee not happy with the route the HPC is taking we do try to help them, as I did with you.  Often a little digging can really help.  There is an item this week that is following that route.

I know this will bring more nonsense down on my head, but Springfield is not my future, so go ahead.  Just stay with the truth. 

[iloveionia]

Ionia states as follows
quote
Additionally, from the get-go (2007) I have always gone directly through the HPC staff and not the local neighborhood group.  That is the only thing that ever made[/i] sense to me, that being go to the source. "[/i]
end quote

Funny - and I do not know why I am bothering to answer this, but there are so many distortions.  PSOS have come to me several times when needing some help persuading the powers that be that certain things must and should be done.  I can go back and produce such exchanges.

Below is part of a series of private messages sent by you to me regarding your carriage house on Ionia.  You had been somewhat turned away by Joel's office when you requested that you be allowed to mothball the place.  Since it was discovered that the house was non contributing and so could not be part of the mothballing procedure.
Here is one of your pms, I can get others. The one below is not the original, in that you asked me how a house in Springfield could not be contributing.

Quote
Re: My Carriage House on Ionia

Sent: Sun Mar 04, 2012 3:59 pm
From: iloveionia
To: Chris Farley
What arguement do you think I would have against the commission to mothball it? I have all the blueprints and am ready to go in the fall for rehab, but mothballing stops the fines and harassment from code enforcement which is what i want.

User avatar
iloveionia
     
    Posts: 720
    Joined: Mon Nov 02, 2009 8:27 pm

end quote

When you came to me, as in other situations, I went looking for the history and found photos of other such carriage houses.   I contacted Joel's office and said I thought the building should be recognized, since I believed that the house that stood in front of it had lost its integrity and so was not counted and that caused the carriage house to also be discounted.  I will find the photos if you wish.
You were given permission to mothball, I do not know if you ever did

There is so much misconception re the DRC. Always, the SPAR office has advised people to approach Joel's office directly, but used to offer help in filling out COAs.  By the time the DRC gets to see the items that are passing through the HPC, that office already has made a quasi decision on what they believe should happen.  We listen, and mostly just agree with them.  If someone comes to the committee not happy with the route the HPC is taking we do try to help them, as I did with you.  Often a little digging can really help.  There is an item this week that is following that route.

I know this will bring more nonsense down on my head, but Springfield is not my future, so go ahead.  Just stay with the truth. 

It's all good.
Posting PRIVATE Messages that is.
However this is from Nicole Lopez (iloveionia) to Chris Farley.
Not PSOS to SPAR as you seem to indicate.
I emailed you simply because you have an affinity for history and preservation.  An email (PM) from preservationist to preservationist.
I was simply looking to save yet another house, i.e. the Carriage House which I own under a coropoation called coincidently "I Love Ionia." 
It is still my opinion that matters that involve Historic Springfield should include public comment and input.  Plain and simple. Going to the source (HPC) is what I have done since 2007.  I am not sure how posting this particular PM or any others proves that I am some sort of liar as you incinuate.  But you can certainly do as you may.
Yes.  I received that COA for the Carriage House.  Yes.  I mothballed and completed the requirements of that COA to make it official.  Did you help in this process? Maybe.  Not sure.  But your email certainly didn't hurt.  But I'm gonna bet I, Nicole Lopez, had a little (or shoot maybe even a lot) of something to do with garnering the COA for the Carriage House. 
Not gonna argue with you Chris.
At some point maybe you will see we are both here for the same thing.
Saving houses.

[strider]

[quote  author=chris farley link=topic=17274.msg314450#msg314450 date=1358914813]
Quoted in part.

Funny - and I do not know why I am bothering to answer this, but there are so many distortions.

There is so much misconception re the DRC. Always, the SPAR office has advised people to approach Joel's office directly, but used to offer help in filling out COAs.  By the time the DRC gets to see the items that are passing through the HPC, that office already has made a quasi decision on what they believe should happen.  We listen, and mostly just agree with them.  If someone comes to the committee not happy with the route the HPC is taking we do try to help them, as I did with you.  Often a little digging can really help.  There is an item this week that is following that route.

I know this will bring more nonsense down on my head, but Springfield is not my future, so go ahead.  Just stay with the truth. 

[/quote]

And the fact is, the posts on this thread by me and others have indeed been the truth.   Rather than post something trying to make Nicole out to be some kind of lair (and doing a poor job of it at that) and since you are (or so we have been told) on the DRC, how about explaining the reasoning behind some of the proposed changes?

Do you feel that Staff can't be trusted to follow the guidelines?  The summary from SPAR certainly implyes that.

It seems you feel that the alleys are important,  but what do you really hope to accomblish by making the wording change from "street" to "right of ways"?  Do you see any potential issues from that change?

What about why you think the roofs need to go to HPC rather than remain with staff? The summary seems to say because they should be requiring the more expensive metal shingles.  Is that the intent?

[strider]

I have been told that it is official that the changes have been sent to a committee for future public content and so no real action has been taken on the document in question.

Hopefully, there will be a noticed meeting announced soon.