HomeMy WebLinkAboutCity Council Resolution 25-063, Adopting CCP-007, Mills Act PolicyRESOLUTION NO. 25-063
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SARATOGA
ADOPTING THE MILLS ACT PROPERTY TAX ABATEMENT PROGRAM
POLICY
WHEREAS, the City Council recognizes the importance of preserving historic
resources in the community and the need to enhance and maintain the unique character of the
historic resources; and
WHEREAS, the City of Saratoga City Council has chosen to participate and
support the Mills Act Property Tax Abatement Program according to Art. XIIl-8 of the California
Constitution and California Government Code sections 50280-50290 and California Revenue and
Tax Code sections 439-439.4; and
WHEREAS, the City Council finds that participating in the Mills Act Property
Tax Abatement Program is consistent with the City of Saratoga Heritage Preservation Code
Chapter 13, and the General Plan Open Space and Conservation Element Goal OSC-13 “Through
coordination with and implementation of other related General Plan Policies, encourage
preservation of the City’s heritage by providing for the protection of irreplaceable historic and
cultural resources representing significant elements of City and regional history” and
implementation measure IM OSC-13.a in that participating in the Mills Act will aid in the
preservation of historic resources in the city.
WHEREAS, on March 5, 2003, the City Council approved the participation in the
Mills Act Property Tax Abatement Program with Resolution No. 03-016 and limited the approval
of applications under the Mills Act to no more than three per year; and
WHEREAS, on April 17, 2024, the City Council updated the requirements for the
City’s Mills Act program (Resolution 24-019).
WHEREAS, on August 20, 2025, the City Council reviewed a draft policy with
additional requirements for the Mills Act Program, provided recommended changes, and directed
staff to return with a revised draft following a review and recommendation by the Heritage
Preservation Commission; and
WHEREAS, on September 16, 2025, the Heritage Preservation Commission
reviewed the draft policy and provided recommendations to the City Council; and
WHEREAS, on November 5, 2025, the City Council of the City of Saratoga held
a duly noticed public meeting on the subject matter, and considered the staff report and evidence
presented by the public.
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NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of
Saratoga does hereby adopt the City of Saratoga’s Mills Act Property Tax Abatement Program
Policy (Exhibit A). This Policy supersedes all prior Mills Act policies adopted by the City
Council.
The above and foregoing resolution was passed and adopted at a regular meeting of the Saratoga
City Council held on the 5th day of November 2025 by the following vote:
AYES: COUNCIL MEMBERS FITZSIMMONS, WALIA, ZHAO, VICE MAYOR PAGE,
MAYOR AFTAB
NOES: NONE
ABSENT: NONE
ABSTAIN: NONE
Belal Y. Aftab, Mayor
ATTEST:
Britt Avrit, MMC, City Clerk
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CITY OF SARATOGA
_____________________________________________________________________
CITY COUNCIL POLICY
POLICY TITLE: Mills Act Property Tax Abatement Program Policy
POLICY NUMBER: CCP-007
POLICY EFFECTIVE DATE: 11-06-2025
LAST REVISION: N/A
I.PURPOSE
This policy establishes the City’s Mills Act Property Tax Abatement Program. This policy
supersedes all previous City of Saratoga Mills Act policies and practices.
This Policy helps to ensure that property owners who receive a reduction in their
property taxes are reinvesting that savings into the historic landmark and the proposed
improvements have been reviewed for consistency with the Secretary of the Interior's
Standards (see Appendix A) by a licensed Architect, Historian, or other qualified
professional meeting the Professional Qualifications Standards described by the
National Park Service for implementing the Secretary of Interior Standards.
II.BACKGROUND
The Mills Act is a California State law to encourage historic preservation. It grants local
governments the authority to enter into agreements with owners of historic properties
who agree to maintain and rehabilitate their properties in exchange for a reduction in
local property taxes. For additional information on the Mills Act, see California
Government Code Article 12, Sections 50280-50290 and California Revenue and Taxation
Code Article 1.9, Sections 439-439.4
The City of Saratoga Mills Act Property Tax Abatement Program (Mills Act Program) was
established on March 5, 2003 (City Council Resolution 03-016) and amended in 2024
(Resolution 24-019), and 2025 (Resolution 25-063). To participate in the Mills Act
Program, property owners must submit an application that includes a Historic Resource
Evaluation and a 10-Year Restoration & Maintenance Plan (Restoration Plan), subject to
City Council approval, following review by the Heritage Preservation Commission. The
property owner(s) will be subject to a Mills Act Agreement, which outlines the
requirements of the Mills Act Program and commitment to preserve the historic
resource per the Restoration Plan and the Secretary of the Interior's Standards for the
Treatment of Historic Properties.
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III.ELIGIBILITY
To qualify for the City of Saratoga’s Mills Act Program, the property must be designated
as a Historic Landmark on the City of Saratoga’s Heritage Resource Inventory (HRI). If a
property is not yet designated, the applicant may submit an application requesting
designation as a Historic Landmark, concurrent with the submittal of their Mills Act
Program application. See Saratoga City Code Chapter 13 (Heritage Preservation) for
information on the designation process.
Funds saved in property taxes are to be used for the rehabilitation and maintenance of
the historic property. All work on the property must conform to the Secretary of the
Interior’s Standards for Rehabilitation (See Appendix A) and the California Historical
Building Code. The City will confirm owner compliance with the terms of their Mills Act
Agreement and the 10-year Restoration Plan through annual reporting and inspection.
Applicants must pay a fee to cover the costs of processing the application, and property
owners who enter a Mills Act Agreement must pay fees to cover the City’s costs of
administering the agreement, including 10 years of annual inspections and monitoring.
What Properties are Ineligible? Properties that do not pay taxes or are delinquent in
the payment of taxes are ineligible. Properties with outstanding code violations and/or
correction notices issued by any Department or Division within the City of Saratoga are also
ineligible. All code violations and expired permits must be corrected before an
application is accepted. It is also important that the person/entity submitting the
application retains ownership of the subject property through the time the agreement
is recorded at the Assessor’s Office. If not, the Agreement will not take effect since the
ownership on the recordation date will not match the ownership listed in the Mills Act
Agreement. Following recordation, the property owner is required to notify the City of
Saratoga of any change of ownership.
Owners of properties subject to Mills Act Agreements that are not in full compliance with
the Mills Act Program and their Mills Act Agreement may not submit new applications
for additional properties.
IV.APPLICATION PROCESS
Application Requirements.
Applications are due no later than June 30 each year. However, if the property is not yet
designated as a Landmark, the application, including the Historic Resource Evaluation,
must be submitted no later than April 30. Applications must include all required
documents. Incomplete applications will not be accepted. Applicants are responsible for
understanding all of the information contained in this document, including the Secretary
of Interior Standards (also see Appendix A).
The application must include:
1.Copy of most recent property tax bill, which includes the assessed value of the
land and property improvements, and the tax assessment. The property owner will
also be required to submit a copy of their reduced tax bill following reassessment by
the County, within a year after the Mills Act Agreement is executed.
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2.Current Preliminary Title report, which includes the subject property legal
description and all matters affecting title (prepared by a Title company within 45 days
of application submittal).
3.Proposal Statement. A brief description summarizing how the structure qualifies
for the program and the historical improvements and maintenance proposed. The
property owner must also agree that their property can be featured in an exterior
walking tour every three years on the second Saturday of the month of May (National
Preservation Month). Advanced notice and a description of the tour will be provided
to the owner at least 90 days before the tour date. The tour is managed by the
Saratoga Historical Foundation. The Foundation may also ask property owners to
consider allowing interior tours of structures listed on the Heritage Resource
Inventory.
4.Site Plan: Attach a site plan of the entire property, that illustrates the location of the
main building and any other accessory buildings, structures or objects on the
property.
5.Baseline Conditions. As provided in Section V, the application shall include a
Historic Resource Evaluation (HRE), updated DPR 523A (Primary Record) and DPR
523B (Building, Structure, Object) Form 1, and photographs of the historic resource
and property.
6.Historic Landmark Application. If the property is not designated as a Historic
Landmark on the City of Saratoga’s Heritage Resource Inventory (HRI), the Mills Act
application must be accompanied by an application to be designated.
7.Restoration Plan. As provided in Section VI, the application shall include a
Restoration Plan with cost estimates that illustrate that at least 6.25 percent of the
assessed value of the property (as provided on the most recent property tax bill) will
be spent on preserving the historic resource over the course of the 10-year
Restoration Plan. Because the contract is automatically renewed each year unless
cancelled by action of the City or property owner, the property owner must submit a
new 10-year Restoration Plan, no later than July 1 in year 9 following execution of the
Mills Act Agreement, illustrating a new 10-year schedule of projects that invests at
least 6.25 percent of the current fair market value of the property (or the factored
base year value if available from the Assessor) back into the property over the course
of the subsequent 10-year Restoration Plan.
A copy of the new 10-year Restoration Plan will be provided to the City Council in
October of year 9 following execution of the Mills Act Agreement. The City will issue
a notice of nonrenewal if the property owner does not submit a new 10-year plan
that satisfies the requirements of the Program, including the minimum investment
of tax savings for the subsequent 10-year period. The Restoration Plan does not
serve as an official permit or approval of any individual item. The property owner is
1 The Department of Parks and Recreation Primary Record (DPR) form, developed by the California Office of Historic
Preservation (OHP) is used for used for recording and evaluating historic sites and resources.
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responsible for obtaining all necessary approvals and permits before making any
changes to the property and completing the work. Any work performed must
conform to the Secretary of the Interior's Standards for Rehabilitation and the
California Historical Building Code.
Application Review
Staff Review: The City will conduct a preliminary inspection of the property to verify the
baseline conditions (see Section V) provided by the applicant and help inform staff’s
recommendation regarding the merits of the application. Staff may retain a historic
preservation expert at the applicant’s expense to assist in the review of the materials. Staff
may also recommend Conditions of Approval to address any conditions that do not
conform to the Secretary of the Interior's Standards for Rehabilitation. Preliminary
inspections are typically conducted between July and August following June 30
submittals of Mills Act applications, or between May and June following April 30
submittals of a Landmark designation / Mills Act application.
HPC / City Council Review: Mills Act applications are considered by the Heritage
Preservation Commission in September and the City Council in October of the year
applied, concurrently with other applications. However, if the property requires
Landmark designation, the entire application will be considered by the Heritage
Preservation Commission in July. The application will be considered by the City Council
over the course of two meetings, including review of the Landmark application in
September, and adoption of the Landmark Ordinance and the Mills Act Agreement
Resolution in October. If approved by the City Council, a Mills Act Agreement is
processed by the Santa Clara County Assessor’s Office (Assessor’s Office) for the
following tax year. Mills Act Agreements must be recorded with the Assessor’s Office
before the end of the calendar year preceding the first Mills Act tax abatement year for
the property (e.g., the subsequent July-June tax year). The City may approve up to three
Mills Act Agreements per year.
V.BASELINE CONDITIONS REPORT FOR HISTORICAL PROPERTY
The Baseline Conditions Report is included as EXHIBIT C to the Mills Act Agreement.
The application must include a Historic Resource Evaluation (HRE), updated DPR Form2,
and photographs of the historic resource and property that meet the requirements
below. The HRE report provides specific information about the property, its condition,
and the rehabilitation and maintenance items to be undertaken during the initial 10-
year term of the Mills Act Agreement to ensure that the historic/architectural integrity of
the property is maintained. This report, if accepted by the HPC and City Council, will be
an exhibit to the Mills Act Agreement.
Historic Resource Evaluation (HRE) / Updated DPR Form. The owner shall acquire the
services of a licensed Architect, Historian, or other qualified professional (meeting the
Professional Qualifications Standards described by the National Park Service for
2 The form includes two parts: DPR 523A Primary Record, and DPR 523B Building, Structure, Object.
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implementing the Secretary of Interior Standards3), to review the history of the structure
and prepare an HRE and an updated DPR form for the property. The HRE shall:
•define the architectural style, exterior finishes, and character-defining features of
the structure that should be retained;
•describe the current conditions of the historic resource, including any materials or
systems that exhibit distress or deterioration;
•describe any construction or materials that may not conform to the U.S. Secretary
of the Interior’s Standards for Rehabilitation;
•describe and date past construction, additions, alterations, and/or restoration
work that have been made to the original structure, including work affecting
historic/architectural integrity of the structure;
•indicate if the structure has been moved and provide the date(s); and
•provide recommendations on architectural features that should be restored or
reconstructed as part of the initial 10-year Restoration Plan.
Photographs. The HRE report shall include comprehensive labeled and dated color
digital photographs of the historic resource, property grounds, and other historic
accessory buildings, structures or objects on the property. Color photographs shall
sufficiently illustrate the overall condition and historic character of the property and
historic structures. The photographic set shall include detailed images of character-
defining exterior features as seen from the street(s) and from the front, side, and rear
property lines. Each image shall be appropriately labeled (e.g., front, rear side, across
the street).
VI.10-YEAR RESTORATION PLAN AND MAINTENANCE PLAN
The 10-Year Restoration & Maintenance Plan is included as EXHIBIT D to the Mills Act
Agreement.
All City of Saratoga Mills Act Agreements require a minimum 10-year Restoration Plan
that includes a yearly schedule of projects with costs that are equal to or exceed 6.25
percent of the assessed value of the property (as provided on the most recent property
tax bill). The Restoration Plan, if accepted by the HPC and City Council, will be an exhibit
to the Mills Act Agreement.
An architect or licensed contractor shall prepare the estimates for each project in the
Restoration Plan. At least 6.25 percent of the assessed value of the property (as provided
on the most recent property tax bill) shall be used to restore, rehabilitate, and/or
maintain the property over the course of the 10 -year Restoration Plan. Routine
maintenance (e.g., exterior painting, minor landscaping, and minor roof repairs) should
represent less than 10% of the cost to implement the Restoration Plan. Restoration work
completed within the 12 months prior to submittal of the Mills Act application may be
included in the Restoration Plan, if the professional preparing the HRE determines that
3 https://www.nps.gov/articles/sec-standards-prof-quals.htm
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the work complies with the Secretary of the Interior’s Standards for Rehabilitation and
the California Historical Building Code.
Eligible Restoration Plan items. Any work performed on the property must conform to
the Secretary of the Interior’s Standards for Rehabilitation and the California Historical
Building Code. Eligible Restoration Plan items are restricted to interior and exterior
improvements that restore and maintain the historic integrity of the historic resource,
building system improvements, and property ground improvements, including
landscaping and hardscaping. The items below guide the types of work that may be
included in a 10-year Restoration Plan.
Historic Resource Evaluation and annual verification fees. The cost of the Historic
Resource Evaluation and payment of fees for annual verification of improvements may
be counted towards the minimum investment requirements for the Mills Act Agreement.
Interior Restoration. Interior work recommended in the Historic Resource Evaluation as
an appropriate restoration or period-appropriate improvement item may be included in
the 10-year Restoration Plan. Work must conform to the Standards and avoid visible
changes to character-defining features of the historic resource.
Energy Efficiency and Wildland Urban Interface (WUI) Improvements. Improvements
intended to increase energy efficiency such as solar panels and double-pane windows,
and interior / exterior improvements needed to comply with Wildland Urban Interface
(WUI) requirements, can be included in the Restoration Plan if those improvements
appear compatible with the historic home.
Building Systems. The Restoration Plan can include building systems required for the
structural integrity and preservation of the historic resource. Eligible work items include
seismic reinforcement, electrical and mechanical upgrades, plumbing work, necessary
building code requirements (e.g., fire sprinklers), and drainage/flood prevention. All
systems work must conform to the Standards and avoid visible changes to character-
defining features of the historic resource.
Roofs. Historic roofing material should be preserved wherever possible, with the
exception of combustible materials. If replacement is necessary, new material should
resemble the historic material as closely as possible. This includes configuration, size,
pattern, color, texture, etc.
Exterior Cladding and Stucco. Installation of new cladding materials should replicate
historic materials as closely as possible. Painted cladding should be maintained to
ensure the protection/durability of the cladding material. Sandblasting and other
abrasive treatment methods should never be used in treating historic wood or brick
elements. Stucco finishes should be restored to the historical type.
Façade restoration, rehabilitation, preservation. Historic front or side porches and
patios, carriage houses, and other historic ancillary buildings are character-defining
features of a property and should be preserved whenever possible.
Windows and Exterior Doors. Preservation over replacement should be prioritized.
When replacement is necessary, period-appropriate materials (new or salvaged) that
replicate the materials, size, shape, details, and other qualities of the original windows
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and doors should be utilized. Windows and exterior doors that are highly visible from
the public right-of-way should be prioritized over less visible windows or doors (such as
those at the rear of the property). When the original door is present, it should be restored
or treated for its ongoing preservation. Replacement of an inappropriate front door with
a period-appropriate door should be prioritized in the Restoration Plan. Replacement
garage doors should be based on the style of the original doors or on similar period
garage doors, with guidance from City staff. This includes design, material, and
configuration.
Landscape, Fencing, and Garden Walls. Landscape design and maintenance have a
significant impact on the appearance of a property. Historic landscape features should
be preserved and maintained. Deteriorated surfaces should be repaired, and
replacement material should replicate historical features as closely as possible. The
Restoration Plan may include new landscaping, driveways, front walkways (leading to
the front door or driveway), maintenance of trees or shrubs of significant age or size,
planters, and light posts. The installation of new fences and perimeter walls in the front
yard is generally discouraged since they interfere with public visibility of the Mills Act
property. In cases where it is appropriate, the fence design, materials, and finishes
should complement the historic resource and allow visibility into the property.
Ineligible items. Specific items that are not eligible include, but are not limited to: new
additions; modernization of the property or historic resource; interior work on private
residences that is not period appropriate as identified in the HRE; installation of a
security system; and exterior improvements such as a swimming pool or landscaping
items that detract from the historic integrity of the property.
VII.MAINTENANCE STANDARDS
In addition to the items listed in the Restoration Plan, all Mills Act properties are required
to be adequately maintained. All current building and zoning codes will be enforced.
The following are examples of conditions that are not permissible:
•Unpermitted work that would otherwise require a Building or Planning permit.
•Dilapidated buildings or features such as fences, roofs, doors, walls, and windows.
•Abandoned or discarded objects, equipment, or materials such as automobiles,
automobile parts, furniture, appliances, containers, lumber, or similar items stored
outdoors but within property lines.
•Stagnant water or open excavations.
•Any device, decoration, or structure that is unsightly because of its height, condition,
or location.
•Peeling exterior paint.
•Overgrown or dead landscaping exposed bald areas within yards or grounds, and
broken walkways or driveways.
•Yards or porches cluttered with items that detract from the appearance of the
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property.
•Trash cans that are not stored out of view of the public right-of-way.
VIII.ANNUAL REPORTING AND WORK PLAN VERIFICATION
All work described in the initial and subsequent Restoration Plan(s) shall be completed
within the ongoing 10-year term of the approved Mills Act Agreement.
Owners who enter into a Mills Act Agreement and do not rehabilitate or maintain the
property annually in accordance with the approved Restoration Plan and the Mills Act
Agreement, are subject to non-renewal or the City cancelling the Agreement and the Santa
Clara County Assessor collecting a fee of 12.5% of the current fair market value of the
property as required by State law.
Each year on the anniversary of the Effective Date, Owner shall provide City evidence of
maintenance of the Historic Property completed within the previous year. Annual
verification of workplan implementation is conducted by City staff, Heritage Preservation
Commissioners, or a consultant contracted by the City to monitor properties for routine
maintenance and compliance with the terms of the Mills Act Agreement, including
progress of the Restoration Plan and work called for in updates to the Restoration Plan
after the initial term. Inspections will primarily be conducted from the sidewalk and will
evaluate everything visible from the public right-of-way. Interior improvements included
in the Restoration Plan will also be verified. Verification of workplan implementation is
ongoing for the life of the Mills Act Agreement and will continue after all work specified
in the Restoration Plan has been completed, as long as the Mills Act Agreement is in
effect. The City will provide prior notice to the Owner before conducting inspections.
Following the inspection, Mills Act property owners will receive a letter by e-mail (or
certified mail in the case of non-compliance), notifying them of the inspection results
and determination regarding compliance. If at any point during the term of the Mills Act
Agreement the property is deemed noncompliant, the owner will be given a reasonable
deadline to make the improvements. An extension may be granted if there are
extenuating circumstances and the owner has shown good faith efforts to make the
improvements.
Prior to the first inspection and within a year after the Mills Act Agreement is executed,
the property owner must submit to the City a copy of their reduced tax bill following
reassessment by the County.
IX.MILLS ACT AGREEMENT OVERVIEW
The following information is a general summary of the provisions of a Mills Act
agreement. The property owner must comply with all requirements of the executed Mills
Act Agreement.
Term of Agreement: A Mills Act Agreement is executed for an initial term of 10 years.
At the end of each year, the term is automatically extended by one year, thereby
maintaining the 10-year term in perpetuity. The Agreement runs in perpetuity with the
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land, and the terms and conditions of the Agreement bind subsequent owners. If a
property owner or the City wishes to terminate the Mills Act Agreement by stopping the
automatic renewal, the agreement would terminate at the end of the corresponding 10-
year period. If the Mills Act Agreement is cancelled before the end of the 10-year term, the
property owner is assessed a fee (12.5% of the current fair market value of the property),
and taxation resumes at ordinary rates.
Renewal: The City or property owner may choose not to renew a Mills Act Agreement
for any reason. Unless the notice of nonrenewal is served by the owner at least 90 days
prior to the renewal date or by the City Clerk at least 60 days prior to the renewal date,
one year is automatically added to the term of the Agreement. Upon receipt by the owner
of a notice of nonrenewal from the City Clerk, the owner may make a written protest. If
either party serves notice of intent in any year not to renew the Mills Act Agreement, the
existing Mills Act Agreement will remain in effect for the ten years remaining in the term.
Upon execution of the nonrenewal, the owner’s Mills Act tax benefit reduces gradually
on an annual basis. By year 10, the property owner will be paying the same tax they
would be paying without having entered a Mills Act Agreement.
Cancellation/Breach of Agreement: If the property owner is found to be in breach of
the Mills Act Agreement, the City may cancel the Agreement whereupon the County
Auditor-Controller collects a cancellation fee of 12.5% of the fair market value of the
property as determined by the County Assessor and taxation resumes at ordinary rates.
Reasons for cancellation include but are not limited to: failure to notify the City of lease
or sale and transfer of ownership; failure to implement the Restoration Plan; blocking
public view of the historic structure from the public right-of-way; failure to conform to
the Secretary of the Interior’s Standards for Rehabilitation and the State of California's
Historic Building Code; and deterioration to the point that the property no longer
qualifies as a Historic Landmark.
Lease / Transfer of Ownership: The property owner listed on the Mills Act Agreement
must notify the City of Saratoga when a Mills Act property is leased or sold. In the event
of a sale and change of ownership, the City will immediately issue a notice of non-
renewal for the associated agreement, such that the agreement will no longer be in
effect 10 years from the effective date of the non-renewal. The new owner can reapply
for a new Mills Act Agreement upon satisfactorily submitting all requirements for a new
application in accordance with this policy. Failure to provide written notice via certified
mail to the City at least 10 days before listing the property for sale and at least 10 days
before the lease or sale of the property, is considered a breach of the Mills Act
Agreement, and may lead to its cancellation, imposition of the 12.5% fee, and
resumption of standard tax rates. The requirements of the Mills Act Agreement are
binding on the new property owner; the new property owner is required to notify the
City of the sale within ten (10) days following completion of the sale to inform the City of
sale, provide updated contact information for the Mills Act Agreement; and affirm
Owner’s agreement to abide by all requirements of the Mills Act Agreement. It is
incumbent upon the seller of a Mills Act property to disclose this fact to potential buyers.
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Appendix A: The Secretary of the Interior’s Standards for Rehabilitation
1.A property shall be used for its historic purpose or be placed in a new use that requires
minimal change to the defining characteristics of the building and its site and
environment.
2.The historic character of a property shall be retained and preserved. The removal of
historic materials or alteration of features and spaces that characterize a property shall
be avoided.
3.Each property shall be recognized as a physical record of its time, place, and use. Changes
that create a false sense of historical development, such as adding conjectural features
or architectural elements from other buildings, shall not be undertaken.
4.Most properties change over time; those changes that have acquired historic significance
in their own right shall be retained and preserved.
5.Distinctive features, finishes, and construction techniques or examples of craftsmanship
that characterize a historic property shall be preserved.
6.Deteriorated historic features shall be repaired rather than replaced. Where the severity
of deterioration requires replacement of a distinctive feature, the new feature shall match
the old in design, color, texture, and other visual qualities and, where possible, materials.
Replacement of missing features shall be substantiated by documentary, physical, or
pictorial evidence.
7.Chemical or physical treatments, such as sandblasting, that cause damage to historic
materials shall not be used. The surface cleaning of structures, if appropriate, shall be
undertaken using the gentlest means possible.
8.Significant archeological resources affected by a project shall be protected and preserved.
If such resources must be disturbed, mitigation measures shall be undertaken.
9.New additions, exterior alterations, or related new construction shall not destroy historic
materials that characterize the property. The new work shall be differentiated from the old
and shall be compatible with the massing, size, scale, and architectural features to protect
the historic integrity of the property and its environment.
10.New additions and adjacent or related new construction shall be undertaken in such a
manner that if removed in the future, the essential form and integrity of the historic
property and its environment would be unimpaired.
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