Do heritage conservation districts work? The case of Kitchener's Upper Doon district.
Article Type: Case study
Subject: Historic sites (Protection and preservation)
Authors: Kovacs, Jason F.
Shipley, Robert
Snyder, Marcie
Pub Date: 12/22/2008
Publication: Name: Canadian Journal of Urban Research Publisher: Institute of Urban Studies Audience: Academic Format: Magazine/Journal Subject: Social sciences Copyright: COPYRIGHT 2008 Institute of Urban Studies ISSN: 1188-3774
Issue: Date: Winter, 2008 Source Volume: 17 Source Issue: 2
Topic: Event Code: 310 Science & research; 970 Government domestic functions
Product: Product Code: 7949130 Historic Sites; 9106330 Historic Site Programs NAICS Code: 71212 Historical Sites; 92412 Administration of Conservation Programs
Geographic: Geographic Scope: Ontario Geographic Name: Kitchener, Ontario Geographic Code: 1CONT Ontario
Accession Number: 210868152
Full Text: Abstract

Many countries including Canada use the designation of heritage conservation districts as a tool to manage change in historic areas. Designation attempts to provide an orderly way of reviewing potential changes in an effort to ensure the maintenance of historic value. However, there has been some opposition to district designation in Canada, often based on myths and false premises. Those opposing designation view it as restricting property rights and undermining property values. However, research from across North America generally shows a correlation between designation and increased property values. The current study examined the Upper Doon district established in Kitchener, Ontario in 1988. Several questions were asked: has the district achieved its stated goals, how do residents feel about it and what has happened to property values. Results affirm that residents are knowledgeable about the functioning of their district and satisfied. Furthermore, the data show that all applications for changes were approved speedily, and that properties performed above average in the market.

Keywords: heritage, conservation district, property value, Ontario


Plusieurs pays, incluant le Canada, emploient la designation de district de conservation du patrimoine (DCP) comme outil d'amenagement pour gerer les changements au sein de secteurs historiques. Cependant, il y a eu quelque opposition a la designation de DCP au Canada, plus souvent qu'autrement base sur des mythes et de fausses premisses. Les opposants revendiquent que cette designation impose une limite aux droits eta la valeur de propriete. Neanmoins, les etudes en Amerique du Nord illustrent generalement une correlation entre la designation de district de conservation du patrimoine et une hausse accrue de la valeur de propriete. Notre etude se concentre sur le district Upper Doon de Kitchener, Ontario etablie en 1988. Nous avons adresse plusieurs questions: est-ce que les buts exposes ont ete realise dans le district, qu'elle est la perception des residants au sein du district et quelle ont ete les consequences sur la valeur de propriete. Les resultats demontrent que les residants sont satisfaits et bien informes du fonctionnement et des reglements concernant leur district. En outre, les donnees illustrent que toutes les demandes pour des changements ont ete approuvees rapidement et que la valeur des proprietes est au-dessus de la moyenne du marche.

Mots cles: heritage, district de conservation du patrimoine (DCP), valeur de propriete, Ontario


What is a Heritage Conservation District?

There is a long established practice in urban planning of identifying sites and structures of heritage significance (Machacek 2004). The body of practice is perhaps best viewed from the perspective of the World Heritage Convention (WHC) to which Canada and over a hundred other United Nations member states are signatories. The so called Venice Charter of 1964, one of the foundation documents of the WHC, accepted that the definition of a heritage structure applies: "not only to great works of art but also to more modest works of the past which have acquired cultural significance with the passing of time." It also says that this definition "embraces not only the single architectural work but also the urban or rural setting in which is found the evidence of a particular civilization" (ICOMOS).

Under the WHC, signatory states recognize the ongoing threat to sites of historic significance posed not only by natural decay but also from modern development pressures and they undertake to ensure "the identification, protection, conservation, presentation and transmission to future generations of the cultural and natural heritage" (UNESCO 1972). Recognition of heritage sites, therefore, is intended as the first step in their conservation and their retention for the use of future citizens. As a Federal state, the legal expression of Canada's obligation under the WHC fell to the Provinces, and in the 1970s most jurisdictions in Canada adopted Heritage Acts designed to protect heritage sites. Ontario's Heritage Act was first passed in 1975 and updated most recently in 2005. It makes provision for the designation (recognition) of both individual sites (Part IV of the Act) and groups of buildings and their surroundings (Part V). The latter are referred to as Heritage Conservation Districts (HCDs).

Why are Heritage Conservation Districts Instituted?

While the conservation district or area has long been the management mechanism of choice in many other countries, such as the United Kingdom, the focus of historic preservation in North America has for the last generation been on individual properties. In Ontario there are currently more than 6000 individual designated sites but only about 90 districts, many of which are relatively recent. To be clear, designation of either individual structures or groups of buildings does not prevent change and is not intended to unduly encumber owners. Rather, designation attempts to provide an orderly process of reviewing potential changes in an effort to ensure the maintenance of historic value as identified in the designation by-laws which are the legal instrument of recognition (Ascroft and Quinn 2007). The experience in other countries has encouraged heritage planners in Ontario as well as elsewhere in North America to adopt the conservation district as the best tool for managing change in historic areas.

Why are Some People Opposed to Them?

In European countries the decision as to which buildings have historical significance is generally entrusted to experts. In much the same way as environmental professionals decide what zones around rivers and watercourses are ecologically sensitive and therefore subject to development restrictions, heritage professionals indicate which buildings will come under preservation rules. There are clear criteria and the judgement of heritage significance is considered a matter of fact that can be evaluated by those with the requisite knowledge.

In many parts of North America, however, historic significance has been considered a matter of taste, or even eccentricity. Restrictions resulting from designation have been treated by some as interference in property rights rather than a celebration of shared community values. Restrictions on what can be done to a property are thought by some to narrow the range of potential buyers and therefore lower property values. Myths have grown up about onerous obligations and bureaucratic red tape. As one critic of heritage districts said: "However benign and liberal these [heritage conservation district] plans are made to appear at first glance, make no mistake, they are not. They are vulnerable to bureaucracy creep and have the insidious potential of being amended or 'ramped-up' in baby steps to become unacceptably onerous and restrictive" (Kitchener-Waterloo Record, 23 June 2001, A11).

Questions to be Asked and Answered

This study set out to examine one particular Heritage Conservation District in the City of Kitchener and to determine if the district was "working." A number of questions were posed for the research:

* Do residents know about HCDs and how they work?

* Has it been possible for them to make changes and how long did that take?

* Did residents want their neighbourhood to be a HCD in the first place and how do they feel about the designation status now?

* Has there been any impacts on property values?

* Has the area realized the goals set out in the original plan?

The paper will first outline previous study results and then explain the designation and management process for districts in Ontario. The methods used in the study will be outlined and the results described. Finally we will conclude by answering the questions posed based on the findings of the study.

Previous Studies

In 2005, Professor Randall Mason of the University of Pennsylvania completed a study for the Brookings Institution of Washington, DC entitled Economics and Historic Preservation: A Guide and Review of the Literature. In this comprehensive work, Mason examined over 270 studies many of them dealing with property values within conservation districts. Quoting work by such researchers as Asabere and Huffman (1991); Listokin, Lahr, McLendon, and Klein (2002); Rypkema (1997, 1998); and Vivian, Gilberg, and Listokin (2000), he concludes that "the economics literature clearly comes down in favor of a positive effect of historic districting on property values" (7). Estimates of the impact of designation on property values ranged in the studies from simply maintaining the pre-designation level to increases of 5 to 20 percent and as high as 70 percent. While most of these studies were conducted in the US, Shipley (2000) found the same trend in Canada. Only Sharpe's study (2006) of St. John's Newfoundland found no "heritage premium" in terms of property values. However, he concluded that that may have been because the city did not enforce heritage regulations rigorously enough.

The Ontario Situation

Legislation, Procedure and Focus of this Study

The Ontario Heritage Act mandates municipalities to create Heritage Conservation Districts. The procedure begins with a preliminary study followed by consultation and the creation of a district plan. The HCD designation process is not inexpensive since the entire procedure can take two to four years and can cost in the neighbourhood of $50,000. While this cost pales in comparison to engineering studies and other assessment projects municipalities undertaking designation have to take it seriously.

Of the 90-plus Heritage Conservation Districts in Ontario, only about 20 have been in place for more than 15 years. Since the district is a planning tool intended to help shape and guide an area over the long run, for this study it was decided to concentrate on one of the longer established districts where the cumulative effects of decisions could be properly evaluated.

Problems Encountered by Municipalities

In spite of the evidence from previous research in Canada and the US, the exacting nature of the pre-designation planning, and the long established practice of district designation in Europe, there remains opposition to establishing districts in some communities in Ontario. In cases such as the Kingsway in west Toronto, opponents managed to convince their City Councils to vote down the creation of districts in the past few years. Sometimes the negativity comes from unexpected sources. In the City of Waterloo, Wilfred Laurier University fought the designation of a district all the way to the Ontario Municipal Board (OMB) because they wanted to have a free hand to buy and demolish the buildings near their campus in order to accommodate expansion. However, for those who believe districts are a good planning tool there is some good news. Laurier University lost their appeal and recently one of the most prestigious neighbourhoods in the country, Toronto's Rosedale, became an HCD.

This study sheds light on at least some of the issues that give rise to opposition and is intended to arm proponents with some reliable information in order to make their case.

Case Study: Upper Doon Village, Kitchener

On 24 November 1988 the OMB approved the designation of the Upper Doon area, in south-eastern Kitchener (annexed in 1968), as an HCD. Upper Doon was to be the first of four conservation districts in the City, and is now recognized as one of the oldest HCDs in the Region. Under the provisions of Kitchener Bylaw 88-77, Upper Doon HCD was intended to "conserve the intrinsic rural and historic character of the Village" and "ensure that new development, both within and outside the Village, did not destroy this character." The "timely" nature of the district's designation, with the encroachment of new residential subdivisions, was to help the City "conserve the charming ambience" of the area and "ensure that new development is complementary and supportive of that ambience" (Hill, 1988, p. 1).

The OMB approved HCD plan had a dual focus: it established guidelines to conserve both the historical residential character and the environmental qualities of the former village. (1) Historically, the area was significant not only as one the first tracts of land settled during the initial Mennonite migrations to Waterloo Region in the early 1800s but also because of its distinctive industrial heritage. Although few visible clues remained, Upper Doon had been home to a variety of agricultural, textile and saw mills as well as one of the largest brickyards in the Region. Moreover, the former village once boasted the first successful flax mill in Upper Canada (1853). (2) Today, an old mill warehouse and two row houses built for mill and factory workers are testament to the area's agricultural and industrial past.

Unlike many other HCDs, however, the value of the district, when it was established, was not focussed exclusively on the architectural and historical significance of its built heritage (modest vernacular style) or on the quantity of historic buildings (comparatively small--18). Rather, the district's value was seen in a random cluster of historic and new buildings set in a valley with an expansive treescape and water-associated natural environment. Its "unplanned quality" and "harmonious blend" of built structures and natural features was different from the new subdivisions that encircled the area and represented a "unique opportunity" to conserve a small area of Kitchener that had managed "to retain its original rural character and identity" (Hill, 1988).

In order to conserve the district's character, the designation process outlined three interrelated objectives: aesthetic objectives such as the conservation of visible history and the preservation of the rural and historic character of the former village; social objectives that included the maintenance of a small village atmosphere and strengthening of a "neighbourly quality"; and economic objectives that included limiting non-residential uses in the district with the aim of furthering the development of the area as a residential community. While the primary reasoning behind the designation of Upper Doon as a HCD was to conserve the built and natural environment, the plan like most others, emphasized that the process was not intended "to create a museum-like character"; it was "vital that the Village remain a living and vibrant part of the City." (3)

Method of Study

A growing number of empirical studies on heritage districts have been made since the 1970s (Sharpe 2006; Mason 2005). However, with few exceptions, these studies have been limited in their research scope towards addressing the effects of heritage district designation on property values. This long established focus is not surprising given the importance that economic considerations play in both policy circles and in the public mindset towards designation proposals. However, as Shipley (2000) strongly argues, heritage is ultimately about cultural values and not economics. The economic emphasis in much of the academic literature on the HCD strategy, while important in its own right, is limited in its value when other related considerations including resident perceptions and choice are not taken into account. While this study does consider the effects of HCD designation on property values it also addresses several important issues that are fundamental in any attempt to access the effectiveness and future of HCDs.

In order to examine resident perceptions of and knowledge about HCD designation, a door-to-door survey was conducted in the Upper Doon HCD beginning in April 2007. To maximize our response rate the initial survey trip to the district was supplemented by a second visit in September 2007. In total, responses were obtained from 43 of the 74 properties in the Upper Doon HCD. This represents a 58 percent survey response rate. In addition, approximately half of the owners of the 18 historic properties in the HCD were consulted during these survey trips. The specific questions posed to the district's property owners included an initial query over their awareness of the neighbourhood's designated status. This was followed by asking residents whether they had moved to the district before or after Upper Doon's 1988 designation and what their respective concerns and expectations of the heritage conservation status were. In addition, residents were asked for a short explanation of how they understood HCDs to operate. Because HCDs are often implicitly equated with excessively stringent building renovation codes, we asked residents if they had made applications for building alterations in the past and, if so, whether these were approved and within what length of time. In addition, a question concerning resident satisfaction towards living in an HCD was posed followed by two questions that addressed, in a different manner, the traditional research focus of previous studies: the designation effect on property values. Residents were asked firstly about whether they thought HCD designation had impacted the value of their properties and secondly whether they thought the designated status of their district would impact their ability to sell their properties.

In addition to surveying residents, building alteration data was obtained from the City of Kitchener's heritage planning department and analyzed, and property value trends for the district and city as a whole were calculated from land registry records. Sales records over a thirty one year period (1976-2007) were used to analyze HCD property values against the city average. It must be recognized that besides the simple locational factor within an HCD our study did not take into account a variety of other issues that affect sales prices (e.g. interior space, architecture, lot size, etc.). Finally, survey responses were coded and entered, together with building alteration and sales data, into SPSS 14.0 software to generate frequency tables and graphs for further analysis.

Answers to Principal Questions

Do residents know about HCDs and how they work?

Overwhelmingly, residents were aware that they lived in an HCD (42 yes, 1 no). Furthermore, the majority of residents surveyed were familiar with some of the basic principles of how HCDs work. That is, they were aware that permission had to be acquired before significant changes could be made to historic and even to newer structures in the district. Of the 43 residents surveyed, one admitted that they did not know how the HCD worked while nine failed to answer or comment on the question. However, responses greatly varied from in-depth explanations to very brief statements that did not necessarily suggest a complete understanding of the concept. For example, some residents simply stated that the HCD was intended to preserve older buildings and homes, others said that it was more to do with saving the appearance of structures by limiting changes to building facades, and for several of those surveyed it was about keeping "everything original"--about keeping things "the way they were initially." One resident stated that the HCD hindered major changes in the area but added that that "was not a terrible thing." Others saw it as a "way to keep history alive." As one resident maintained, the designation of Upper Doon as an HCD not only served to protect the history of the area for future generations, it also served to enhance it and make it available to current residents. Despite the dual focus of the original HCD plan on built and natural heritage, only three residents mentioned how designation guidelines applied to the district's environment. Moreover, their responses were largely limited to aesthetic concerns (e.g. tree removal and fencing).

Can residents ever make changes to their houses? If so, how long will it take to get approval?

One of the common concerns about HCD designation is that home owners are unduly restricted in their right to make building alterations. In fact, the opposite is often true. As is evident in the Upper Doon HCD plan, homeowners of historic buildings are frequently encouraged to renovate their properties in line with established guidelines, while owners of newer structures are often encouraged to complementarily alter components of their homes to strengthen the character of their districts. Since the 1988 designation of Upper Doon, the City of Kitchener has received over forty applications for building alterations. Significantly, with the exception of one application that was under review at the time of the survey, all applications had been approved. The absence of any rejected application was confirmed by both the City's heritage planning records and by residents surveyed (9 reported applications approved, 1 under review).


Another assumption about HCD building renovation applications is that a significant amount of time must be taken before an application is reviewed and either approved or rejected. In fact, as is evident in the case of Upper Doon, the process can be quite rapid (figure 1). (4) According to the city records that were analyzed, the average length of time from application to approval was 6 weeks. However, on closer inspection, and taking into consideration a 24 week "anomaly," the majority of building renovation applications had been decided upon within a three week period. Again, these documented cases are also confirmed by residents surveyed. Of the nine residents who had had applications reviewed in the past, three stated that it had taken "a couple of months" in contrast to five whose applications had either taken a few days (1), a couple of weeks (2), or "not too long" (2). One resident was unsure of the time it took for their application to be approved.

Did residents want their neighbourhood to be a HCD?

An important consideration about HCDs that has not been examined in the literature is the resident perception, and concern, towards proposed heritage district designation. Approximately half (21) of the 43 residents surveyed had lived in Upper Doon before the area was designated in 1988. Of these, 18 responded to the question, "how did you feel about designation at the time?" The majority of those surveyed stated that they had either felt good (8) about the City's decision or were neutral (6) towards the designation process. In particular, several residents said that they were delighted about the decision while others stated that it "didn't matter or mean much" or were "not too worried." Two residents had mixed feelings about the process, which could be attributed to their lack of knowledge of what the HCD designation status entailed. Another two residents stated that they were opposed to the plan; one emphasized that they were opposed "at the time" while the other was still adamant to a process that they felt had been "rammed down their throat" by others.

How do they feel about it now?

Of the 43 residents surveyed, which included an almost equal number of people who had lived in the district before designation as those who had moved in afterwards, the vast majority (36) stated that they were satisfied (figure 2). Indeed, the majority of these residents (26) indicated that they were "very satisfied" with the remainder choosing the "satisfied" category. In contrast, three residents were neither satisfied nor dissatisfied and only one resident was dissatisfied (very dissatisfied). An additional two residents were unsure about how they felt. More tellingly, of the 20 residents who moved into Upper Doon after it was designated only two stated that the designation status had affected their decision to move there. However, of these two, one indicated that they had moved there because it was a conservation district and because they knew the character of the area would be protected (figure 3).



What happened to property values?

From an examination of the land registry records it was evident that comparatively few houses, historic or newer, were bought or sold more than once within the last 30 years. Of the 74 properties included in the district only six had verifiable records of sales. Moreover, only five properties could be used for a before and after comparison of property values since the area's designation. Another property only had recorded sales subsequent to 1988. One could postulate that the small number of sales records may simply be an effect of the quality of place in this setting; that is, residents are highly satisfied with the location and environment and perhaps even with the designation status itself. While such conclusions are purely speculative, several properties were available for analysis and should be presented if only for comparative purposes with the survey findings.

Although far too few to give conclusive results, it was evident from a comparison of sales history trends that newer properties in the district had either performed better than the market trend or performed near to the city average. For example, one structure built in the late 1960s, and sold on two separate occasions in recent years, performed significantly better than the market trend for the City of Kitchener (see figure 4), a second similarly aged structure which was sold several years before and after designation illustrated an above average sales performance (figure 5), while a third property which represented an older structure also performed well since district designation, as is evident from its most recent sales transaction (figure 6). A fourth more moderately aged property clearly followed the city average market trend (figure 7).







Two vernacular style historic buildings with multiple sales histories during the examined time period show slightly varied responses since designation. While both generally follow the market trend, the first (figure 8) perfomed at the average while the second (figure 9) fared better than the city average.

The cases above provide a fairly clear reading into the effect that designation has had on property values. The somewhat higher than average trend in sales prices when compared with the city average mirrors what residents in the district expect from their community's designation. Most residents when asked whether HCD status impacted their property values said that they thought that designation had either increased it (15) or had no impact at all (15). Of the 15 who believed HCD designation increased their property values only two thought that it increased the value "a lot." Thus, it is clear that most residents who do expect increased property values only anticipate a relatively modest increase. Of the very small minority of residents (3) who thought designation had negatively impacted their property values, all expected only a modest decrease in sales prices--no residents expected designation to substantially reduce their property values. An additional number of residents surveyed (10) were unsure or did not comment on the designation-property value connection. It is also important to note that some of those who were either hesitant at addressing the question or had negative expectations of how their property fared in comparison to non-designated neighbourhoods may have had locational or other concerns on their mind. For example, one resident stated that property sales might be negatively impacted by the presence of a nearby floodplain.

In a similar vein to the above survey findings, when asked whether they thought Upper Doon's designated status would impact the ability to sell their property the majority (26) of residents responded no while a smaller number of residents said yes (9) or were unsure (6). After further clarification it was found that eight of the nine residents who answered yes believed that designation would improve their ability to sell their properties.


In conclusion it can be said that the people living in the Upper Doon HCD are quite clear about the fact that they live in a conservation district and they have a reasonable understanding of how it works. Any fears they may have had concerning their ability to change and develop their properties never materialized. Plans for change have virtually always been approved and approval has been timely. Their properties have not only maintained their value but have generally appreciated at a greater rate than the city average.

On first view the Upper Doon neighbourhood appears to have kept its rural and historic character as foreseen by the original plan. However, several residents, although happy with their community, were disappointed by the extent of encroachment that was allowed for an adjacent subdivision. One resident complained of increased traffic in the area--one of the issues that the establishment of this HCD was meant to address. Another claimed that the existence of a mere 50 foot buffer between the "historic village" and new residential community was a telling example of how the City, in their view, had not "upheld the spirit of the [original] plan." The aesthetic goal of the original plan can be said to have been partly realized but some residents feel there has not been sufficient development controls in and around the district.

The social goal of the plan has perhaps been more successful. According to our survey the great majority of Upper Doon residents appreciate the HCD status of their community and enjoy the quality of life that the district affords. The economic goal has also been reached in that the residential character of the neighbourhood has been preserved.

The results of the study on Upper Doon District in Kitchener demonstrates how well the HCD concept can serve as a good and useful planning mechanism. It ensures sensitive change and development and helps to maintain the quality of place in an historic area. The lesson for other municipalities is that HCDs can work and they work even better when heritage regulation rules are respected and enforced.


Parks Canada HPI Contribution Agreement, City Corp Realty (Edmund Pries), Ted Scarf Realty, Leon Bensason (City of Kitchener Planning Dept.) and the people of Upper Doon.


Asabere, P.K., and F. Huffman. 1991. Historic districts and land values. Journal of Real Estate Research 6 (1): 1-8.

Ascroft, S. and C. Quinn. 2007. Heritage conservation districts under pressure. Heritage Canada 10 (4): 20-31.

Hill, N. 1988. Upper Doon: a heritage conservation district plan.

ICOMOS. The Venice Charter, (Accessed April 3, 2008).

Listokin, D., Lahr, M., McLendon, T. and J. Klein. 2002. Economic impacts of historic preservation in Florida. University of Florida Levin College of Law.

Machacek, J. 2004. Urban issues in the context of EIA. Sustainability in global services. Prague: Economic University.

Mason, R. 2005. Economics and Historic Preservation. Washington, DC: The Brookings Institution.

Rypkema, D. 1997. Historic preservation and the economy of the Commonwealth. Washington, D.C.: National Trust for Historic Preservation, Preservation Books.

Rypkema, D. 1998. Economic benefits of historic preservation. Forum News (National Trust for Historic Preservation). 4 (5).

Sharpe, C.A. 2006. House prices in a heritage area: The case of St. John's, Newfoundland. Canadian Journal of Urban Research 15 (2): 175-201.

Shipley, R. 2000. Heritage designation and property values: Is there an effect? International Journal of Heritage Studies 6 (1): 83-100.

UNESCO. 1972. The Convention Concerning the Protection of the World Cultural and Natural Heritage, (Accessed March 16, 2008).

Vivian, D., M. Gilberg and D. Listokin. 2000. Analyzing the economic impacts of historic preservation. Forum Journal (National Trust for Historic Preservation). 14 (3).

Jason F. Kovacs

Robert Shipley

Marcie Snyder

Copeland Stupart

School of Planning

University of Waterloo


(1) Subsections under the general conservation heading in the district's heritage conservation plan illustrate the dual historical-environmental focus: village character; land use; building; and watercourses; treescape; natural environment; floodplain; and topography.

(2) Despite its initial Pennsylvanian roots the emerging village in the area was named in 1834 after a Scottish settler's birthplace--Logh Done, near Ayrshire.

(3) Of course, building conservation activities do form an important component of the heritage designation plan. The conservation activities listed include: "Prevention of the deterioration of the historic fabric; Preservation of the existing state of the building; Consolidation of the building fabric; Restoration to parts of the building that have been badly altered or lost; Rehabilitation of the building for a useful purpose; Reproduction of parts of the building that have deteriorated; Rehabilitation of parts of the building that have deteriorated beyond repair or are lost; and Reconstruction of deteriorated parts of the historic fabric" (Section 5.9.1). Historic buildings in the HCD are intended to be conserved in their "original form with a minimum of changes other than to restore the fabric back to its original condition" while non-historical buildings in the district are also to be conserved if compatibly designed or complementarily altered to strengthen the historic/rural character of the district.

(4) Of the forty building alteration applications made only fifteen fully recorded transactions were available for analysis. The remainder of transaction files were either incomplete or missing from the City's renovation permit files.
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