Ad Hoc historic preservation recommendations

Nine years ago, long before St Augustine and St Johns County property values hit the skids, or the rest of the general economy for that matter, Mayor George Gardner set out on an ambitious project to identify recommendations that could be presented to the City Commission regarding historic preservation — recently, sitting Commissioner Nancy Sikes-Kline, who served on the 2003 ad hoc committee, is trying to resurrect the recommendations.

The logical fallacy of Sikes-Kline’s proposed resolution before the full commission tonight, is that nothing has changed since the original research was compiled. Common sense and acceptable research methodology demand that there be consideration of the current circumstances, and, having been compiled nine-years hence, the data relied on and conclusions drawn are statistically invalid. One glaring example is the fact that the City no longer controls the State owned properties in the Colonial Spanish Quarter — although they did at the time of the 2003 study.

The full text of the 2003 Recommendations

Recommendations for the City of St Augustine regarding historic preservation

Prepared by an Ad Hoc Committee at Mayor George Gardner’s Request
October 22, 2003

Committee Members:
Bill Adams, Ph.D.
Marsha A. Chance
Robert Hall
Roy Hunt, Professor Emeritus
Susan R. Parker, Ph.D.
Herschel Shephard
Nancy Sikes-Kline

Short Term Recommendations

1. Recommendation: Amend the existing Sections 8-89 28-118 2-120 of the City Code and revise the amending Ordinance 2002-17 to include items presented by Dr. Roy Hunt in order that historic structures dating to the Colonial period (constructed between 1563 and 1821, and “Potential Landmark Buildings” (Adams 1986: Appendix I, Comprehensive Plan Update-Historic Preservation Element) be guaranteed protection from demolition.

2. Recommendation: Change the time limit for individuals filing appeals to HARB decisions to 30 days in order to be consistent with appeals made on PZB decisions.

3. Recommendation: Amend all corresponding guidelines in the “Architectural Guidelines for Historic Preservation” and the Comprehensive Plan Historic Preservation Element, Policy 3.11 to state, “demolition permits will not be issued for any Colonial Period (1563-1821) structures or those listed as ‘Potential Landmark Buildings’ (Adams 1986), subject to the adopted appeals process.” A new ordinance should be drafted based upon similar ordinances around the country.

4. Recommendation: Replace the word “structure” in AGHP and Section 28-2 of the code and applicable portions of the comprehensive plan Historic Preservation Element Policy 3.11 with the phrase “sites and structures.” This will allow a broader application to cultural landscapes, sites, buildings, structures and new categories of historic resources that are listed on the Florida Master Site File (FMSF). It will coincide with Recommendation 8.a.

5. Recommendation: Establish a policy requiring that the City itself comply with the procedures established by the City to enable preservation and protection of public property owned by the City.

Specifically, the City does not apply for building permits or other permits from the City for projects on City property and thus the review by HARB is not initiated. There is no procedure to call HARB’s attention to City projects. The City undertakes maintenance, renovation, and new construction projects within the six historic districts that can have as much impact on the integrity of the districts as those undertaken privately. Over the years, HARB has at times been informed of City projects, but not asked for comments. At other times HARB has been asked for an opinion, but the opinion as not considered binding.

Thus the City has at times completed projects that did not meet the criteria of the City’s own “Architectural Guidelines for Historic Preservation.” In doing so, the City has given the appearance of a lack of consideration for its most valuable asset, the appearance and preservation of its ancient resources. Not only are such actions detrimental to the resource, but a negative message is conveyed to the citizens. While a procedural argument can be made that City government is not required to submit its projects for review, this argument focuses on levels of authority and governmental hierarchy and overlooks the more important issue of the resource.

Section 28-89 does not provide for review of City projects by HARB. Such review could be enabled by new legislation in the future, but the Commission should immediately adopt a policy or resolution or should issue an executive order that City projects be submitted to HARB for review and that HARB decisions will have the same effect as decisions rendered for private applicants. The City Commission would act as the appellate body as it does for all applications submitted to HARB. This approach would provide an immediate remedy to a situation that has long existed and that has resulted in detrimental changes and additions to the City. In St. Augustine, the significance and integrity of historic resources cannot be separated into private and public projects.

It is the opinion of the Committee that this type of policy should extend to properties outside of the historic districts, especially those that are listed on the Florida Master Site File. However, this aspect of establishing a policy could be more complex, because there is not an existing mechanism to support it. One way of handling this could be the establishment of a specific chain of command within the City to seek approval for working on historic properties and for the methods to be applied.

One other approach would be to create a new ordinance that uses the following language:
Each city department having direct or indirect jurisdiction over proposed city or city-assisted undertakings shall, in accordance with city policy and prior to the approval of expenditure of any city funds on the undertaking, consider the effect of the undertaking on any historic property that is included in, or eligible for inclusion in, the National Register of Historic Places. Each such department shall afford the Historic Architectural Review Board a reasonable opportunity to comment with regard to such an undertaking.

Each city department shall initiate measures in consultation with the Historic Architectural Review Board to assure that where, as a result of actions of the city, a historic property is to be demolished or substantially altered in a way that adversely affects the character, form, integrity, or other qualities that contribute to historic, architectural, or archaeological value of the property and surrounding historical properties, timely steps are taken to determine that no feasible and prudent alternative to the proposed demolition or alteration exists; and, where no such alternative is determined to exist, to assure that timely steps are taken either to avoid or mitigate the adverse effects, or to undertake an appropriate archaeological salvage excavation or other recovery action to document the property as it existed prior to demolition or alteration.

The City shall establish a program to locate, inventory, and evaluate all historic properties under its ownership or control that appear to qualms for listing on the National Register.

The city shall exercise caution to assure that any such historic property is not inadvertently transferred, sold, demolished, substantially altered, or allowed to deteriorate significantly.

6. Recommendation: Revise all Zoning Codes to state that the maximum height must be 35 feet, measured from the (preconstruction) existing grade, e.g. street level prior to any build up for a current project, in order that excessive heights are not reached in the City, particularly within the Historic Preservation Districts.

Denver, Colorado has defined its “building height measurement” and may be a model for St. Augustine. The language of Denver’s code is provided below as an example. The Comprehensive Plan Historic Preservation Element – HP Policy 1.3 should be revised accordingly.

(23.5) Building height measurement: …the height of a building or structure shall be the vertical distance measured from the highest point of the building described below to the average elevation of the corners of a building at the finished grade. The highest point of the building shall be either the top of the parapet or coping of a flat-roofed building, or the ridge of a sloping roof. No occupied part of any building shall be constructed above the permitted height; however, unoccupied building features such as church spires and towers, flagpoles, antennas, chimneys, flues and vents, cooling towers, enclosures for tanks and elevator penthouses serving the roof including any vertical or sloped screen walls may extend a maximum of twenty-eight (28) feet above the permitted height of the building.

7. Recommendation: Rescind all ordinances and corresponding Comprehensive Plan amendments that create special land use and/or zoning districts that allow 50 foot buildings.

8. Recommendation: Reincorporate the revised version of the Comprehensive Plan update prepared by HPA (Adams 1986) back into City government. The document is presently under revision by its author(s) and members of this Committee. We recommend that, once that step has been completed, it be adopted as official policy; followed by restoration into the City of St. Augustine Comprehensive Plan as soon as possible.

As part of those Comprehensive Plan changes we recommend the immediate reincorporation and changes of the following portions:

a. Recommendation: Amend HP Objective 3 to include “sites and objects” as originally stated in the comprehensive plan update by Adams (1986) as Goal 3, ie. “Identify and preserve historic neighborhoods, sites, buildings, structures, and objects within the City.”

b. Recommendation: Amend HP Policy 2.3 to state, as originally stated in the comprehensive plan by Adams (1986) in Goal 2, Objective 5, i.e. “Provide local protective and interpretive designations to and nominate, as appropriate, significant archaeological sites to the National Register.”

The workload of the person holding the City Archaeologist position presently prohibits meeting fieldwork requirements and simultaneously completing associated tasks such as report production and preparation of National Register nominations. No individual National Register nominations for archaeological sites have ever been prepared by the City. Sites within the larger NR districts, to which they may contribute, were not discussed in the original nominations of 1970. They could be added to the nominations, which would afford them some level of recognition, based on the fact that they contribute to the NR listing.

c. Recommendation: Delete the word “optional” from HP Policies 2.6, 3.9,3.12,B, and C. These policies are identical to those stated within the original HPA document (Adams 1986), with the exception of the addition of this word.

d. Recommendation: Change HP Policy 4.5 to read, “Seek advice on matters relating to preservation of cultural and historic resources and in particular in updating guidelines and development regulations from the St. Augustine Historical Society.”

9. Recommendation: Create an ordinance that prohibits underground parking garages within the portions of Archeological Zones I-A and I-B and parts of I-C that fall within the National Historic Landmark District (NHL) and those portions of the colonial walled city not presently included in the NHL district; and the parts of Zone I-D that include the Fountain of Youth Park. Amend the Comprehensive Plan Historic Preservation and Traffic and Circulation Elements and AGHP accordingly.

10. Recommendation: Create a formal relationship with the St. Augustine Archaeological Association and the St. Augustine Historical Society so that they are available for consultation to the citizen boards and the City Commission in matters concerning historical resources.

Intermediate Recommendations

1. Recommendation: Establish a City revolving fund to facilitate the purchase of threatened archaeological and architectural properties deemed significant by the City Commission in order to protect and preserve them.

2. a. Recommendation: Use the document cited above (Adams 1986) as the basis for a fully detailed Historic Preservation Master Plan of the City of St. Augustine, to be prepared with the National Trust for Historic Preservation document, entitled, “Preparing a Historic Preservation Plan,” by Bradford J. White and Richard J. Roddewig–(1994) as a guide to the process.

The Master Plan should be prepared with the assistance of a qualified professional specialist, and with the assistance of grant funds from the Division of Historical Resources. The City, as a Certified Local Government (CLG), is eligible to receive a special 50/50 matching grant for this purpose with the staff time used as in kind matching funds. These funds are federal monies, available Only to CLG’s and are not affected by the current state budget cutbacks.

b. Recommendation: A planner with a historic preservation background should be hired to accomplish this task. It is also recommended that Dr. Roddewig be asked to provide special training and assistance to the City.

3. a. Recommendation: Revisit the archaeological ordinance with the goal of updating it to address emerging concerns, such as: the preparation of National Register Nominations, large scale below ground construction within the walled City, artifact curation, and timelines for project completion that are too short to allow for an appropriate professional and scientific level of data collection, data analysis and reporting of results.

b. Recommendation: Archaeological concerns should be considered early in project planning especially when impacts are expected to occur in Archaeological Zones (Halbirt 199x). Early review by the Archaeological Division in Planning and Building, before consultation with citizen boards (HARB and PZB) should be implemented in the permitting process.

4. Recommendation: Improve stewardship of City artifact collections in accordance with standards outlined in the NHPA. Develop a program to create a quality curatorial facility for archaeological and historical collections currently safeguarded by the City; and direct City financial resources to implement the facility and associated necessary curatorial positions.

5. Recommendation: For larger developments or impacts:

1). Establish new thresholds of impact that trigger the need for excavation prior to development that will impact larger areas.

2). Extend the time allowable in order for the city archeologist to complete the excavations of larger developments to up to one year.

3). Remove or raise the cap on fees for larger developments or when state and federal permits are needed and the City Archaeologist is required to spend more time. The fee should be based upon the amount of work necessary to mitigate the effects of construction impact.

6. Recommendation: Begin the process of listing City owned archaeological and historic sites on the NRHP that are potentially eligible in accordance with short term recommendation 8.b (see below). Examples are: the seawall; the Garden Center; the City Waterworks; and the remains of the original lighthouse located on the bottom of City owned Salt Run. All future plans for Red Cox Park should include consideration for the preservation and protection of the site from looters and other impacts.

7. Recommendation: Establish a new zoning category to be entitled, “conservation district” in order to create specially protected residential districts. Each conservation district should have its own set of parameters and requirements based upon its specific character. In conjunction with the establishment of the districts, all existing policies, such as land use, zoning and height restrictions should be reviewed and reworked for application to the district.

The best example of this process took place in Roanoke, Virginia, where new districts were established specifically to achieve neighborhood preservation and conservation objectives (“Preparing a Historic Preservation Plan,” pages 32-35). A new Neighborhood Preservation District classification was created that did not impose rigorous design review, but provided guidance. One of the elements addressed should be commercial intrusion and encroachment by public entities, such as schools and churches.

8. Recommendation: In order to seek balance between institutional expansion, the preservation of neighborhoods, and preservation of the City’s tax base:

1) Request that institutional master plans include an inventory of historic properties, a statement of intended use, a regular maintenance program and enforcement mechanisms.

2) Establish a site plan review process for institutional expansion/alteration/remodeling, especially within and adjacent to local historic districts.

3) Create an ordinance, in consultation with the institutions, to establish criteria for evaluating expansions.

Examples of institutions within the city include public or government entities such as the Florida National Guard, Flagler College, the Florida State School for the Deaf and Blind, the National Park Service, the St. Johns County School Board, churches, and other nonprofit organizations. It is possible that size categories could be established with individual sets of criteria for evaluation of expansions.

Long Term Recommendations
1. Recommendation: Assist the National Park Service in its efforts to revisit the National Register Landmark designation for the Colonial Town Plan and update it to reflect information brought forward since the 1970s when the district was created. The nomination was previously redone in 1986, but adds confusion and does not meet the stringent standards required today. For example, the southern boundary has not been defined clearly; all historic resources within the town plan are not included in the document; and no archaeological resources are included or addressed in any way, and sites such as Ft. Mose, Anastasia Island Coquina Quarries, and the Fountain of Youth are not included. In addition, all other NR properties in the City should be reviewed and updated in a like manner.

The purpose of this recommendation is to insure that St. Augustine enjoys the full protection of the federal laws and regulations that apply to historic districts. National Register staff of the Florida Division of Historical Resources may be of assistance in revising the document to meet current standards. Currently, the National Park Service has received a grant to begin updating the National Historic Landmark District designation. Full cooperation and assistance should be given to assist in these efforts.

2. Recommendation: Revise the “Architectural Guidelines for Historic Preservation” to reflect current research. As written, the guidelines are based primarily upon research by Albert Manucy, completed in 1962. While extremely significant as the primary research on colonial structures, Manucy’s work was not all encompassing. New information on issues such as open space, lot coverage, and scale in Spanish colonial cities has been compiled over the years by several professional historians and archaeologists, and this information does not support some of the construction that has taken place in St. Augustine in recent years. Information gleaned since 1962 has resulted in the emergence of a new picture of ancient St. Augustine architecture. The guidelines should be revised to reflect the historical reality. These revisions could expand the possibilities for alterations and construction within the colonial walled city.

It is evident that a new standard for the scale of the average colonial structure must be developed. The current model does not take into account that lot coverage in colonial times was based on a number of outbuildings as well as a house, rather than a single large house.

For example, while 50% of a colonial lot might have supported several buildings, the guidelines presently allow lots to be covered by the same percentage through the construction of a single structure. The percentage of allowable lot coverage needs to be adjusted to reflect the actual colonial pattern of lot usage, when houses were smaller than those that are allowed today.

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