HomeMy WebLinkAboutItem 6 Regulatory Mechanisms Regulatory Mechanisms(based off pg. 65 of Cedar Rapids Plan)
Regulatory mechanisms allow the community to protect its historic properties. The primary regulatory
mechanisms are the historic preservation ordinances and zoning regulations. The design review process
and design standards that regulate treatment of Oshkosh's Downtown and historic districts. These
provide a basic framework for preservation related activities with some room for improvement.
As the Commission undertakes efforts to revise the current preservation ordinance, it will be important
to consider the other local, state, and federal regulations. The Commission will have to ensure that the
preservation ordinance does not conflict with any other existing standards. Different zoning
mechanisms such as the Traditional Neighborhood Overlay(TND-O) can serve as effective management
tools for particular districts. In designated historic districts,strengthening the application and/or
enforcement of the existing Historic Preservation Ordinance could serve as an effective means of
preserving historic properties.
The City recently updated its comprehensive plan in 2018. The revised zoning ordinance took effect on
January 1st, 2017. The current zoning ordinance is a form-based ordinance and includes unique design
standards for the Downtown area. Within the new ordinance there are a number of means by which to
protect the City's historic assets. Within the code there are revised parking and landscaping standards.
Special design standards can help protect the character of historic districts and older neighborhoods.
The more the City integrates underlying zoning with preservation and design objectives for an area,the
more effective the Landmarks Commission will be in carrying out its duties.
Municipal Code
A number of ordinances in the Oshkosh Municipal Code serve together as the basic standards for work
conducted on historic sites and properties. These ordinances also determine the processes for
establishing protections for these properties depending on their historic designations. Chapter 7 of the
Municipal Code is the chapter that addresses buildings. Chapter 30 of the Oshkosh Municipal Code is
the Zoning Ordinance. The following sections especially apply to historic properties: Chapter 30:Article
VI Overlay Districts, Chapter 30:Article VIII Exterior Building Design Standards, Chapter 30:Article XIV
Historic Preservation.
Chapter 7
This chapter addresses construction and establishes basic standards for life-safety purposes. The
chapter adopts the State building code which addresses requirements for fire safety, emergency exiting,
light and ventilation, etc. Within the International Building Code used by the State of Wisconsin and
Oshkosh Inspections Services Division, provisions exist for historic structures. City staff can help
property owners find design options that are historically sensitive options while meeting building code
requirements. However, property owners must ensure that their solutions meet the requirements of all
pertinent City departments. Right now this occurs without a project lead to coordinate the efforts of
the property owner with the objectives of the Commission and other City departments.
Chapter 30 Zoning Ordinance
The Oshkosh zoning ordinance was revised and took effect January 1st, 2017. This ordinance shapes
existing and new developments in the City. It defines basic zoning districts and uses permitted within
them. It also defines maximum densities and dimensions such as height,area,and setbacks. The base
standards of the zoning ordinance apply to all properties within the City.
The ordinance includes base districts and overlay districts that can apply. For base districts,the
regulations apply to all properties in each district. In overlay districts,specific additional regulations can
apply as needed unique to the particular district. The zoning ordinance addresses residential, multi-
family, mixed use, commercial, industrial, institutional,and various other uses. It includes districts
defined to accommodate various densities and scales. Traditional Neighborhood Overlay districts and
the Central Mixed Use districts include standards designed to preserve the historic character of these
areas. These districts have standards that apply to new construction and work performed on existing
structures. At the time of the plan however, no Traditional Neighborhood Overlays exist in practice.
Sometimes overlay districts may benefit the historic character of older areas of the City as in the case of
the Traditional Neighborhood Overlay. However, in other cases, overlays have the potential to conflict
with historic preservation efforts because they can allow for development that deviates from the
historic fabric. In other situations,the base zoning requirements can conflict with preservation efforts
because the base standards can be too restrictive. For example, many older lots in the Center City are
too small to comply with the basic zoning standards currently. Years ago however, many houses were
often built closely together. Therefore, current zoning setbacks may not integrate well with the
preservation aim of preserving the character of older neighborhoods.
Chapter 30:Article VI Overlay Districts
The Traditional Neighborhood Overlay(TND-O) is the primary overlay district meant to preserve historic
character of an area. It is intended for neighborhoods where there is an established pattern of
architectural character. This district is meant to allow for a greater degree of control over the character
of existing and new development than is the case in base zoning. Usually areas built up before 1950
would potentially qualify for this overlay designation. The Traditional Neighborhood Overlay includes its
own set of more stringent design standards and these go beyond what is included in the regular design
standards.
Design Standards for Overlay and Special Districts
The TND-O mentioned above, the Central Mixed Use and Riverfront Overlay districts have their own
prescriptive design standards. These address preservation along with other context-specific standards.
If an overlay district is ever combined with an historic district or other areas of historic significance,the
city-wide standards from the historic preservation ordinance should apply to historic properties within
these overlay districts whenever and however possible. These city-wide standards could be re-iterated
within the overlay standards or there could be a reference to these preservation guidelines when the
overlay standards address potential work for historic properties.
For each individual type of overlay district,there can be more context-specific guidelines or standards
for new construction. Guidelines can also exist for elements such as signage,street furniture, and other
fixtures located or proposed within the public realm.
Chapter 30:Article VIII Exterior Building Design Standards
The Exterior Building Design Standards apply to most structures constructed in the City after the
adoption of the ordinance. These are the base standards for regulating the exterior design of most
properties in the City. They establish minimum standards to ensure higher quality development than
would result without design standards. These standards provide criteria by which proposed
developments or work can be evaluated to determine whether the development is appropriate. The
design standards provide examples of acceptable and unacceptable fagade treatments. Successful
design standards also provide means by which property owners may prioritize what elements or
features of a property to preserve and what features perhaps are less integral to the historic integrity.
For rehabilitation purposes, design standards could address sustainability. This would include both
energy conservation and the energy involved in making new components(embodied energy). The
standards should help property owners in the decision-making process when choosing between
alternative options. For example, many property owners often opt to replace original wood windows
with vinyl double pane windows because they believe that these windows are more energy efficient.
The Landmarks Commission has seen many cases where property owners opt for new replacement
windows over rehabbing and maintaining the original windows. However,the pay-back time for new
replacement windows may be much greater than what property owners imagine. Perhaps more cost-
effective measures could be explored, such as adding more or higher quality insulation in walls and
roofs. These methods, focusing on the interior of the property would allow for greater impact on energy
savings and not disrupt the historic integrity of the property.
Communities such as Cedar Rapids have adopted special design guidelines for historic districts. Perhaps
Oshkosh could follow suit by examining some of these other communities'design guidelines and
creating custom guidelines for Oshkosh historic properties and districts. An alternative could be to add
additional design guidelines to the historic preservation ordinance. Such guidelines could consider non-
contributing structures also and new construction within historic districts. The guidelines or standards
should not only play a regulatory role;they could also perform an advisory function. In order to fulfill an
advisory function however,the guidelines would need to provide sufficient detail and materials options
in an understandable manner to help property owners and staff. The overhaul of existing design
standards within the historic preservation ordinance should be a high priority.
Chapter 30:Article XIV Historic Preservation
The Historic Preservation ordinance currently determines the process for designating properties as
landmarks under the local ordinance. It also regulates the work that is performed on Landmarked
properties and within historic districts and on properties nominated for inclusion on the National and
State Registers. The preservation ordinance provides basic standards for work performed on existing
properties. With these standards there is room for clarification and expansion. Currently the standards
serve a regulatory function and state which work is appropriate and which work is not but they could
include an advisory component that presents a number of options for various project types depending
on the owner's ability to undertake the work.
The standards could become more effective with the addition of visuals and with the following
elements:
• Preservation best practices or principles (based on the National Parks Service or Secretary of the
Interior)
• Sustainability-related assistance (suggestions for the conservation of materials while increasing
energy efficiency)
• Design guidelines/standards for additions to historic structures
• General guidelines/standards for the design of new buildings in historic neighborhoods or
districts. These could apply for all of Oshkosh's districts.
• Context-specific guidelines/standards for specific historic districts. These would provide
assistance and perhaps regulations for infill sites within specific historic districts (example
Washington Avenue or Algoma Boulevard)
• Landscaping guidelines for properties in historic districts(including public and private locations
on the properties).
The Technical Preservation Briefs and additional Standards and Guidelines for Rehabilitation by the
Secretary of the Interior would serve as the underlying principles for these preservation guidelines.
These would supplement the existing standards listed in the historic preservation ordinance and apply
to existing historic properties. They would apply to alterations and improvements to these properties
whether the properties are landmarked, individually listed,or contributing structures in historic districts.
Urban Design Guidelines
If the City adopts general urban design guidelines,these should reference historic properties and the
historic preservation ordinance. Often communities adopt urban design guidelines to ensure
pedestrian-friendly design, adoption of specific material palettes and styles,and branding the
community.
Demolition Process
The Landmarks Commission has witnessed an increasing number of demolitions of historic properties in
recent years. Regulations and mechanisms that can restrict or prevent demolition or destruction of
historic assets are integral to preservation efforts. Every time the Commission witnesses a loss of an
historic property, they question their effectiveness and indeed the effectiveness of the entire historic
preservation efforts in Oshkosh. Sometimes owners will neglect historic resources until they are
dilapidated to the point where they fail to meet code and must come down. "Demolition by neglect"
can occur for many reasons. Some of these include:
• Financial hardship for the owner that prevents the owner from affording the necessary upkeep
and care due to personal financial situations.
• Lack of willingness on the owner's part to invest in the property
• Perceived greater rate of return through reuses or redevelopment opportunities for the site
than by simply maintaining the existing historic structure
• Lack of an apparent economic use for the property as it currently exists
• Owner is removed from the day to day care or maintenance of the property and perhaps is not
informed on the current property conditions.
In some cases,the property is left to deteriorate to such a point that the Inspections Services Division
will issue a Raze or Repair order and obtain a court abatement to demolish the structure(s). By this
point the property owner has almost always faced a citation because the property is deemed a threat to
safety. The Historic Preservation Ordinance does explain that if a property poses an immediate risk to
public safety it can be demolished. The idea is to ensure that properties do not fall into such a state of
disrepair.
With many properties in the City, if they reach the point where they are threats to the safety of the
occupants or general public,they are often missing or were stripped of their significant details,glazing,
siding, roofing, or other features. The Commission and City departments must remain aware of this
path and prevent the property from heading down this path of losing its historical integrity before
requiring demolition.
Currently the City ordinances and Historic Preservation Ordinance require a demolition permit. Usually
this is a means by which to prevent or delay some demolitions. Currently the Landmarks Commission
may delay requests for demolition for landmarks and historic properties but the Commission does not
have the legal authority to deny these requests. The idea of delaying demolition is to see if the structure
can be saved, moved, or if significant features or elements can be saved. At the very least the exterior
and interior of the structure can be documented. The ability to deny demolition would afford the
Commission greater oversight and properties greater protection. However, additional alternatives exist
such as financial incentives, potential rehab loans and grants unique to historic properties, and public
education and outreach to create and foster a culture of historic pride in neighborhoods amongst
historic property owners. Oshkosh preservation efforts could become more effective by combining the
following action items:
Correction notices to the property owner and tenant notifying of the need to repair the
property.
Creation, updating, and maintenance of a database of endangered properties
Emergency protection mechanisms in the preservation ordinance
* Forced sale or condemnation
Code compliance rehab funding set aside for code deficient properties
Continual improvement of the economic atmosphere in Oshkosh
Economic Hardship
When a property owner seeks to demolish or modify an historic property, questions of financial ability,
economics, hardships, and return on investment typically come up. Currently the Commission does not
have a system of objective criteria to evaluate the potential of preserving an historic structure.
Demolition Reviews-Different Property Types
Currently a number of properties exist pertaining to demolition reviews.
HISTORICALLY SIGNIFICANT PROPERTIES
Local Landmarks
Local landmarks are designated under the Historic Preservation ordinance as significant to the historic
fabric. These properties may be designated individually, as is currently the case with the two
landmarked properties in the City. It is possible to designate contributing properties in historic district
as local landmarks. The historic preservation ordinance gives the Landmarks Commission the most
oversight over properties that are locally landmarked. Any work performed on a landmarked property
requires Commission review and a Certificate of Appropriateness. According to the Historic
Preservation ordinance any demolitions require Commission review. If the property is also a
contributing structure in an historic district or individually listed,the State Statutes require that the
municipality notify the SHPO before approving a demolition permit.
Oshkosh has good documentation regarding whether properties in historic districts are contributing or
non-contributing. Most of the district nomination forms include this information. However, a number
of situations arose in the past where staff or the Commission did not know whether a property was
contributing or not. A demolition permit was issued and demolition occurred before the Commission
was notified. As property owners request demolition permits in the future, staff should verify whether
the property is individually listed or in an historic district. Staff should always err on the side of caution
and determine whether the property is a contributing structure or not. Once staff determines this,they
can decide whether or not the demolition requires Commission review.
Properties listed in the National Register, but not a Local Landmark
Many properties in the City are listed on the National and State Registers but are not locally
landmarked. The Wisconsin State Statutes require a delay period during which time the municipality
must notify the state. The goal is to see if there are alternatives to demolition,whether some items can
be saved, and to at least document the exterior and interior of the property. Delays provide the
Landmarks Commission, property owner, City staff, and other residents time to consider alternatives to
demolition. The Commission could work to landmark the property or explore options to move the
property to another site or explore tax credits or loan/grant incentives for rehabbing the property.
Properties listed in the Historic Resources Surveys but not currently a local landmark or listed in the
National Register
A number of properties are listed in the historic surveys but are not locally landmarked and are not
listed on the National or State Registers or contributing properties in historic districts. Regardless, many
of these properties warrant further examination and protection. Some of these properties could have
eligibility for individual listing on the National and State Registers or could be contributing structures for
potential historic districts. If the Historic Preservation ordinance could include a delay provision that
applies to these properties also,this would afford the Commission an opportunity to determine whether
these properties can be saved. If these properties are simply demolished,their absence later could
prove detrimental if the Commission tries to establish an historic district.