HomeMy WebLinkAbout2022-08-02 1554 CHNI meeting scheduled email first attempt1
Ratzlaff, Hannah K.
From:Ratzlaff, Hannah K.
Sent:Tuesday, August 2, 2022 3:54 PM
To:'Denise L'
Subject:RE: Central High Moratorium
Good afternoon Denise,
I wanted to follow back up with you concerning the upcoming proposal to establish a local ordinance district for the
Central High Neighborhood Historic District. A good portion of the Central High Neighborhood Association residents live,
or own property, within the proposed LOD boundaries. I want to make sure that people who are affected by this
possible change have opportunities to ask questions of staff, comment on the proposal, and are aware of upcoming
public hearings. Currently, the proposal is set to be heard by the Historic District Commission on October 6 th. Staff will
be sending out letters to property owners about three weeks before the public hearing. Public notice will also be in the
Daily Record newspaper. And, if anyone would like to keep updated online, the HDC has a social presence now.
Following the hearing, the proposal (if approved by the HDC) will go before the Board of Directors at a later date (TBD).
Before we get farther in this process, is there a time that planning staff can meet with the Central High NA leadership to
discuss the proposal and answer any questions? If there is a possibility that the association would like staff to present at
a neighborhood meeting, we would also like to go ahead and get it in our calendars.
Thanks,
Hannah Ratzlaff
Urban Designer &
Historic District Commission Staff
Planning & Development,
723 W. Markham
Little Rock, AR 72201
hratzlaff@littlerock.gov
501-371-4789
From: Denise L <dannleeson@gmail.com>
Sent: Thursday, July 14, 2022 6:00 PM
To: Ratzlaff, Hannah K. <hratzlaff@littlerock.gov>
Subject: RE: Central High Moratorium
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Hannah,
I’m so glad you’re familiar with the neighborhood and know Paul.
At tonight’s meeting, we’ll briefly talk about the moratorium and the OLD proposal. Surely, there will be questions and
comments that I can share.
Denise
Sent from Mail for Windows
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From: Ratzlaff, Hannah K.
Sent: Thursday, July 14, 2022 11:47 AM
To: Denise Leeson
Cc: Paul Dodds
Subject: RE: Central High Moratorium
Denise,
Great to meet you virtually, looking forward to meeting with you in person at some point!
My first home in Little Rock was actually one of Paul’s rentals across the street from Central High School a few years ago.
I had a wonderful time living in the neighborhood and am familiar with Paul’s investments throughout. Paul’s comments,
in my experience, are always worthy of consideration.
Please let me know if you have any questions or comments about the two initiatives (the moratorium and the LOD
proposal) before we are able to get together. I’m happy to assist.
Thanks,
Hannah Ratzlaff
Urban Designer
Planning & Development,
723 W. Markham
Little Rock, AR 72201
hratzlaff@littlerock.gov
501-371-4789
From: Denise Leeson <dannleeson@gmail.com>
Sent: Thursday, July 14, 2022 10:57 AM
To: Ratzlaff, Hannah K. <hratzlaff@littlerock.gov>
Cc: Paul Dodds <paul@dodds.us>
Subject: Re: Central High Moratorium
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Hannah,
Paul is a respected owner of numerous properties in our neighborhood, whose years of advocacy and rehabbing have
added inestimable value to our neighborhood. If you are unfamiliar with Paul's work, you would be well served by
driving by a few of his properties. Paul is an inspiration and an invaluable resource to others who wish to live and invest
in our neighborhood.
Paul's years of experience provide him with knowledge that results in the types of thoughtful comments he provided in
his email. I'm confident you will also find his comments worthy of consideration as amendments to the resolution being
put before the Board on the 19th.
I look forward to working with you.
Denise
On Thu, Jul 14, 2022, 10:22 AM Ratzlaff, Hannah K. <hratzlaff@littlerock.gov> wrote:
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Good morning Paul,
Thanks for reaching out! I’m happy to receive your comments.
To clarify, the moratorium is going before the Board of Directors on July 19 th. It is not a Planning Commission item. The
agenda item for today on the Planning Commission concerning the Central High Neighborhood Historic District is a
first look (non-voting item) at a proposal to establish a local ordinance district (“LOD”) for the CHN historic district. The
City is following the procedures set out by the Arkansas General Assembly (A.C.A § 14-172-203) and the City’s own
Historic Preservation ordinance (Sec. 3 Article IV). The process requires a strong amount of public communication and,
as staff to the HDC, I am eager to have as much input as possible. The purpose of the proposal is certainly to support
the district in its aims. The LOD process requires the composition of a report, which is now available on the City’s
website: https://www.littlerock.gov/business/planning-and-development/boards-commissions/local-ordinance-
district/. The report will likely go through a number of drafts on its way to the Board of Directors with an
accompanying ordinance. Please feel free to review the report!
To give internal context, and the report speaks to this, the impetus for the LOD proposal came from the concern by
staff for the National Register condition of the district. After recognizing the number of demolitions and alterations
that have occurred since the last survey in 2012, we conducted an in-house analysis of the district based on permit
data, the 2012 NR data, and consultation with AHPP’s NR team. The results were worrisome. Bringing this to
attention, leadership in our department as well as City management, were sympathetic and eager to move forward
with solutions to avoid the loss of the district and loss of property owner access to rehabilitation economic tools. As
we moved forward with preparing the LOD proposal, we discussed with other historic preservation officers in the
nation, that I have contact with through NAPC, possible obstacles they have experienced. We found that many utilized
a moratorium on demolitions while an LOD was being proposed. They utilized this to discourage a “rush” in permitting
that could add more harm to the district. I truly appreciate your comments on the moratorium resolution, and I’ll
bring attention to these points for the draft leading to the July 19th Board meeting, that is: the recognition of
rehabilitations approved by the NPS Part 2 for tax credits that have not yet applied for permits, Historic District
Commission involvement, code officer training, NR status consideration in staff review, standards surrounding
damaged structure, and neighborhood engagement.
To address a few of your comments:
1. To clarify the role that the HDC would take in the review process outlined in Section 5 of the proposed
resolution, it is only HDC staff (myself) that will take part in this review and provide recommendations to the
Board. No applications would go to the HDC for public review. That would be putting the cart before the horse,
I agree. I believe this clarification would also address your concerns in the last paragraph of point 1 of your
email below. Please correct me if you were referring to a different issue.
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Concerning code officers, historic preservation education is in the plans internally for Central High, and
MacArthur Park as well. I’m not sure what our previous practices have been with code enforcement but I
certainly agree there is a need and opportunity there.
Concerning the support of non-contributing structures becoming contributing structures, this will be one of
the main considerations in staff review. I agree that making these types of projects administrative review only
would be supportive of the larger goal. I will bring this comment forward with the rest.
1. Concerning structures that are damaged following the adoption of the resolution, this is a strong point. There
would certainly be a review process with our staff to determine this case by case. I’m happy to explore ways of
using the moratorium as an incentive for the use of HTC and AHPP grants while still allowing those property
owners—who typically care for their buildings and have incurred damages like a tree falling— to seek the
permits required to address damages.
1. We have reached out to both neighborhood associations concerning the LOD proposal and the moratorium once
the items were officially put on the proper agendas. I completely agree that neighborhood engagement should
be robust. We have asked both associations how they would like us to engage with their organization and are
happy to provide presentations. @Denise Leeson, I believe you invite us to your potluck tonight! I don’t believe
Walter or I can make it with Planning Commission being tonight depending on when it ends, but I am sad to
miss out. I believe you are coordinating with Walter and I on a best time to meet and discuss the LOD proposal.
There will be a number of public meetings for the LOD report and ordinance. Planning Commission will be
hearing the LOD draft report this afternoon (as a non-voting item). This will be a task for me to educate them
on what is being asked of them, as well as historic preservation efforts in general.
Paul, if you would like your comments included on the moratorium resolution item, you will need to submit them to
the City Clerk’s office or to your representative board member. Here is a link to the clerk’s contact information:
https://www.littlerock.gov/city-administration/cityclerksoffice/.
Thank you again for your comments,
Hannah Ratzlaff
Urban Designer
Planning & Development,
723 W. Markham
5
Little Rock, AR 72201
hratzlaff@littlerock.gov
501-371-4789
From: Paul Dodds <paul@dodds.us>
Sent: Wednesday, July 13, 2022 11:38 PM
To: Ratzlaff, Hannah K. <hratzlaff@littlerock.gov>
Cc: Denise Leeson <dannleeson@gmail.com>
Subject: Central High Moratorium
Dear Hannah,
I wanted to submit comments on the draft demolition moratorium and external building permit limit ordinance that is
on the agenda for the Planning Commission tomorrow. I generally support and welcome the ordinance, but would like
to submit two substantive and one procedural comment.
1. External Building Permit Limits: While I generally support the idea of external building permit limits, I am concerned
that the procedure is unnecessarily burdensome and that applying Historic District Commission standards as a first
step could lead to real resistance.
Instead of having a blanket requirement like the one proposed, I would urge that the ordinance instead focus on
maintaining and increasing the number of contributing structures to the District, and on encouraging certified historic
rehabilitations. The ordinance does not do this, thus missing a real opportunity. I know of several planned historic tax
credit projects in the neighborhood that could be negatively impacted by the external building permit limits. This
unintended consequence would only undermine the goals of the ordinance.
Instead of requiring all people wanting to do external renovations to seek full City Board approval, after staff and
Historic District Commission review and comment, the ordinance should exempt from its ban any projects that have
an approved National Park Service Part 2 Historic Tax Credit Application. These projects should be permitted to go
forward subject only to a requirement that the project be completed according the terms of the NPS or State
approved application (for non-Federal HTC projects). The owners should submit a copy of this approval and the
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application to Planning staff, not to the whole HDC. Code officers should be made aware of these terms, be given
training in historic rehabilitations and help ensure project completion in accordance with NPS standards.
Next, the ordinance should be used to help make non-contributing structures contributing ones. I have converted
several properties in the Historic District from non-contributing to contributing status, including most recently the
unsafe and vacant 1721-23 Dennison. In that case, all it took was the removal of some cheap paneling around an
enclosed porch. The ordinance should recognize the possibility of and need to convert non-contributing structure to
contributing status. Applicants seeking an exemption for any property built during the period of historic significance
should be also be able to benefit from a simplified staff level approval procedure, if they own a property that can be
made contributing - if they are willing to do so. Active City staff engagement with applicants, helping them work with
the AHPP to make a property contributing, can increase, and not just stop the loss, of historic properties. Once it is
contributing, the applicant would then be able to get a permit on staff approval, once its HTC Part 2 receives NPS or
State approval.
My understanding is that HDC has quite different and more burdensome guidelines than those required by the
National Park Service. If the goal is to help encourage owners to retain historic properties and defend the district’s
Federal status, the NPS standards, as interpreted by the Department of Arkansas Heritage are sufficient and should be
applied. If the Historic District Commission wishes to have a role in review, I would urge that the review be limited to
ensuring that contributing structures, or properties that could be made contributing structures with historically
appropriate changes, not be changed in ways that would jeopardize their contributing structure status. This should be
the only review purpose. While the historic district might sometime be at a point where full HDC review of projects
according to their standards would be accepted by most owners and residents, we are not there yet. Let’s not get
distracted, and stick just with defending our Federally recognized status.
2. Damaged Structures: I do not like the “damaged structures” loophole in Section 3. It is vague and could have the
perverse incentive of encouraging people to damage their properties to get a building permit. It is not clear what it is
trying to accomplish, and provides no standards for what kind of damage would trigger an exemption and why. It
should certainly NOT be linked to the City’s existing and opaque standards for finding properties unsafe and vacant. I
have renovated a number of UV homes, many of which had had fire damage - and all of which are contributing
structures the historic district. Just because there is a fire or a tree falls on a house is not a reason to give an owner a
pass.
So many of the houses in the area are in such poor repair, that repairing this moderate fire, tree or other damage can
be only a small fraction of the total cost needed to bring a building fully back. Using the ordinance to nudge owners of
damaged historic properties into undertaking certified historic rehabilitations, rather than permitting poor and
minimal repairs that ruin the property’s contributing status, can lead to real neighborhood stabilization. For
example, I bought the historic T.H. Miller House fourplex at 2017-2019 W. 17th St. after a fire put a stop to its long
term crack house/ very shabby rental use. The house was terribly run down before the fire, and I estimate that
repairing the fire damage added less than $15,000 to the overall $280,000 project investment costs. Rather than
letting damage to an historic property be an excuse for yet another minimal slumlord “remuddling", use it as a way to
help owners get HTC funds, and really improve the neighborhood. Again, this is a place where the ordinance really
should serve an educational and incentivizing function, but fails to do so.
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3. Procedural Concerns: I am copying the president of the Central High Neighborhood Association on this letter. I
have not previously heard of the draft, though I am quite actively engaged with the association and planning efforts in
the area. While I am generally pleased that someone is undertaking this effort, my sense is that it could benefit from
more neighborhood engagement. I do not know if this was presented to the Wright Avenue Neighborhood
Association, which also includes a large part of the Central High National Historic District. Both WANA and CHNI
should be included in this discussion.
Have there been any public meetings held on this draft? If so, can you please provide the notices, notes,
presentations and attendance records? Again, in general I am glad to see it, albeit somewhat surprised.
Thanks very much for permitting me to make this input, and please let me know if I need to do anything further to
have this included as a formal comment.
Yours truly,
Paul Dodds
Managing Director
Urban Frontier LLC
501 791 4135