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  • Writer's pictureWG Main Street Matters

Open Letter to the City of Winter Garden Commissioners

Updated: Aug 28, 2018

A letter to the Commissioners and leaders of the City of Winter Garden regarding the future preservation of the Downtown Historic District.

Winter Garden Clocktower
Winter Garden Clocktower

Dear Sirs and Madam:

We were involved in the early stages of the creation of the Historic District and assisted the Main Street organization through State Representative Everett Kelly’s office in order to clear up issues with the application and speed up its acceptance. We remain the owners of the Edgewater Hotel which we purchased before the founding of the District. As a result of our early work in historic preservation on the Edgewater, we know most of the initial founders of the Historic District are aware of the goals of the founders, and know of their strong desire to protect the contributing properties as well as the businesses that support them. We worked with the first Main Street Director of the Historic District, who prior to the time that the district was established in the mid nineties, established an office at the Edgewater Hotel to secure those goals of historic preservation and creating the historic district.

We believe that neither the citizens of Winter Garden nor its honored Commissioners have been properly briefed on the impact that this proposed building will have on the Historic District in general. We further highlight the importance of understanding that impact prior to voting on any issues that may negatively affect the district. Therefore, it may be impossible for the commission to make an appropriate determination that meets the requirements of State Statute as well as the obligations outlined in the Secretary of the Interior’s Standardswhich also includes protecting the integrity of the location of contributing properties, as well as the State’s Statutory interest in the economic effect of an action by the City concerning the district.

Within Florida’s Comprehensive Planning structure, it is our understanding that Winter Garden is required by law to address historic preservation in the comprehensive planning process, even if the City does not have a separate historic preservation element. We also are under the impression that Florida law requires that all historic buildings effected by proposed development be addressed in the comprehensive planning stage by the City of Winter Garden. Further, the establishment of policies and objectives within the Historic District are required, also we believe by law, to be based on the actual survey of those same contributing properties.

Considering that this project could not possibly have been addressed in the City’s Comprehensive plan for the Historic District, we cannot see how the Commission can move forward with any vote until such an evaluation is properly conducted.


We are asking you to table the vote concerning the hotel proposal for the following reasons: First, it is vital that we establish healthy debate on the direction of the Historic District from this point forward as we are nearing a tipping point and we are in danger of losing our identity as a Historic District. We have only had a few hours to prepare this document due to the private nature of the City’s actions thus far and so we know it leaves a lot to be desired, but we believe it is vital to stress that mistakes made this late in the development of the Historic District and their negative effects on the contributing properties cannot be easily reversed, if they can be reversed at all. As a consequence, some of the contributing property owners and their tenants in the Historic District could be negatively impacted due to a failure to properly inform the City Commission prior to casting a vote and thereby risk damaging the assets of the Historic District beyond recovery. Therefore, we must speak out now before it is too late.

For that reason, it is imperative that the City Commission convince the citizens of Winter Garden that they are properly informed, or will be fully informed. If it is found that the public is not properly informed on the issues facing the Historic District and made aware of the goals or demonstrate knowledge of the goals of the Secretary of the Interior’s standards for historic districts, the mandates of the State Statutes as well as the needs and desires of the owners of the contributing properties, plus the citizens who will be overwhelmingly affected by any substantial changes in the makeup of the district must be heard and considered before moving forward on any new development or changes in the zoning within the Historic District. This includes the impact of the addition of roundabouts and other substantial, expensive changes to the historic traffic flow into the community since such additions to the Historic District are often in opposition to the recommendations of the Secretary of the Interior.

There is Not a Meeting of the Minds

It is becoming obvious now that not only is the new development overshadowing the old, along with the living history, businesses and buildings that once defined the historic community, but it may be the direction the city officials have desired to evolve the district into all along, considering that their desires have gone unimpeded by the desires of the owners of the contributing properties due to lack of proper representation. It is a very unhealthy situation when the pulse of the community is not guaranteed to be represented by the desires of the leaders of the City, and we do not believe that the direction that the City is currently taking concerning the Historic District is widely supported by the owners of the contributing properties of the district, many of whom already feel abandoned by the City. We believe that there is a fiduciary responsibility for the City to conduct a survey of all of the owners of the contributing properties and their tenants, as well as a survey of the citizens of the Winter Garden community, which if it had been conducted, would already have proved or disproved our assertion that the proposed building in the Historic District would not get wide support.

Advocate for Historic District

The problem is that the Historic District does not have an independent advocate with competent experience and the authority to represent the historic community. Without an independent advocate to protect the interests of the Historic District (which we have not had for at least 15 years), there is no one to educate the leaders of the community as to what a historic district is, of the intention of the Historic Preservation Act and of the goals of the Secretary of the Interior’s Standard for Rehabilitation of historic buildings. Further, there is no one on the Commission to recognize the importance of support and participation in historic preservation policy and programs at the community and district level. Without an advocate, the Commission has no one to turn to for advice in balancing concerns regarding the best interests of the district. This is the very reason why we need a competent program director and Main Street Program in order to educate the public and its elected officials as to the programs needed to protect historic districts, encourage a cooperative climate among downtown interests and local public officials, and to build strong and productive relationships.

When the district is left without proper representation, it is very unfair to the community as a whole. If action is not taken in a very short time to involve and protect the Historic District, the heart of the Historic District will be lost to the establishment of the new “city center” that any educated person can see is far from historic. The effects will be that all of the businesses in the contributing properties will be replaced by new businesses in new buildings and the infrastructure that allowed for the establishment of the new properties in the first place will crumble back into the condition that they were in when the district was formed. History will once again repeat itself if we don’t take a lesson from the past.

Need to Conduct Study

The proposed development is a prime example of what is jeopardizing the success of the historic community on which the new development is proposed to be founded. In attempting to move forward with development, the City government is giving no thought to the protection of the legacy businesses or proper consideration to the contributing properties of which the district was founded and is instead favoring new development to the potential detriment of the contributing properties and the legacy businesses that sustain them. The proposed building will not only duplicate the services already offered by one of the contributing properties that contains a couple of legacy businesses but will also create confusion as to what is new and what is original. It does not take into consideration the Secretary of the Interior’s Standards which also includes protecting the integrity of the location of contributing properties. A historic community is more than the sum of its parts. Businesses in historic structures that make it possible to maintain the structures must be protected from new development that will threaten those businesses and the buildings in which they exist. Otherwise, the buildings will fail with the Historic District and the buildings will be replaced in favor of “better development” as has happened in Winter Park.

The impact that the new proposed business will have on the district and its legacy businesses has not been evaluated even to the extent that consideration for a hotel on the outskirts of the district was evaluated by a study conducted a few years ago. Yet, we cannot understand how the Commission felt the overwhelming and aggressive need to create a study for hotel rooms on the outskirts of the Historic District, yet finds absolutely no need thus far to make the same consideration for an evaluation for a new hotel to be placed directly into the substantially restricted area of the Historic District. A study should be commissioned that takes into consideration the Secretary of the Interior’s Standards, as well as the welfare of the Historic District, its contributing properties, and the legacy businesses that support them before it moves forward with actions that will require investors to make extensive expenditures on a project in a location that may not prove to be prudent. The study should take greater pains to get its facts correct when dealing with the more sensitive issue of the Historic District. For this reason, it is vital that the City Commission vote to direct the City of Winter Garden staff to both conduct a study on the need, effects, and impact of another hotel in the Historic District, and take the immediate steps necessary to assist in the re-establishment of the Main Street Program which supports local community action that builds economic vitality, quality of life, and community pride centered in a city’s historic district. It is imperative that a Program Director be hired by the Main Street organization and confirmed by a vote of the majority of the owners and renters in the contributing properties in order to help conduct and evaluate the study as well as represent the members of the contributing properties. It is imperative that a Director be allowed to become familiar with all persons and groups directly and indirectly involved in the downtown development and conduct on-going public awareness and education programs designed to enhance appreciation of the downtown’s assets and to foster an understanding of the Main Street Program’s goals and objectives and to make sure that there is a meeting of the minds between the City’s objectives, the Secretary of the Interior, and the State Statutes, as well as of that of the district as represented by the Director as its advocate. The Main Street Program is recognized as a catalyst for efforts to preserve, revitalize, and sustain historic business districts.

  • The City Commission needs to direct the Town Manager to instruct the City staff to make sure this program is properly staffed with individuals that can work and function independent of City Management, so that it can properly advocate for the Historic District.

  • The program director should have excellent written and verbal communication skills, as well as an education and/or hands on experience in as many of the following areas as possible: public relations; historic preservation and architecture, district management, business and/or non-profit administration.

  • The program director must be knowledgeable on preservation issues and must be capable of understanding the problems confronting downtown historic districts and their businesses, as well as the issues effecting all contributing properties.


We propose that there be a temporary moratorium on all new construction and proposals for new construction in the Historic District until the Commissioners and the decision makers of the City have had the opportunity to be properly informed of the goals and obligations set forth from the Secretary of the Interior and until the Main Street Program is re-established and a competent director is hired who can coordinate the activities within the downtown Historic District and foster revitalization programs that utilize the Historic District assets as a primary foundation for the Historic District’s continued economic development. Currently the district has no advocate representing the community locally, regionally or nationally, which is a great disadvantage.

The reason why we make this appeal is, to name a few, the following:

Main Street Program

  1. Protects the integrity of the Historic Districtwhen it is staffed by an individual or individuals who understand the Federal and State and local criteria on how a successful Historic District functions.

  2. Represents the district and mediates between the property owners in the district and the City personnel.

  3. Main Street creates and maintains a framework that is well represented by business and property owners, bankers, citizens, historic preservationists, entrepreneurs, public officials, chambers of commerce, and other local economic development organizations. 

  4. The Main Street Program offers a road-mapfor locally-owned, locally-driven prosperity that will help to keep Mom and Pop operations thriving in the Historic community. 

  5. Assists current, new, and replacement businesses to the Historic District.

  6. Main Street personnel assist in the operation of street festivals, parades, retail events, provides education on what’s downtown and encourages customer traffic.

  7. Establish marketing campaigns for the district.

  8. Promote historic building rehabilitation, landscaping, street furniture, signage, visual merchandising and lighting.

  9. Produce, store and maintain files, photographs and video on the restoration and alteration of the contributing properties within the district.

  10. Foster job creation and business retention.

Education on the Economic Engine that Supports the Contributing Properties in a Historic District

Citizens, as well as Commissioners and community leaders who are not properly educated on the operation of a successful district may say that they love the old buildings in town, but one can’t protect any business from competition; however, that is a one-sided point of view that is not shared by the historic district communities across the nation that understand the absolute necessity of protecting and preserving not only the historic structures, but also the economic engine that supports them and guarantees their survival.

The makeup of this engine are the legacy businesses and the "Mom and Pop" operations that are made up mostly of members of the community, some of which are generational. There are many historic communities around the country where books stores, stationary stores, clothing, and toy stores still flourish amid chain stores drying up all around them outside of the districts, due to the active support of the community at large and the elected officials. One of the byproducts of the chain stores and online stores competing against each other is that it is opening up opportunities for the small "Mom and Pop" shops to flourish once again within the historic districts and become a source of pride to the local community. Authentic historic buildings by their nature draw tens of thousands of tourists per year, who come to experience the genuine attributes of the Historic District, where such authenticity is proven to increase the enjoyment of visiting the district by not only residents, but also tourists, which benefits the new businesses as well who enjoy the traffic drawn to the area by the district.

Some of the ways in which people are drawn to the historic district is to assist individual tenants or property owners in the Historic District with physical improvement projects. In addition to being a liaison between the City and the Historic District commercial district, there has been no one to assist in locating appropriate contractors and material; or to participate in construction supervision; or to provide advice and guidance on necessary financial mechanisms for physical improvements.

The Main Street Program therefore is vital in providing this guidance as they are the City’s and the District's partners in preservation.

Historic districts are not traditional commercial districts and they should never be treated as such. The economic impact of a successful historic district, however, per capita can far outpace its traditional commercial siblings and have proven very successful already in Winter Garden and elsewhere in the country in establishing sustainable, vibrant communities. The intention of the Preservation Act is the protection of historic buildings along with protecting or developing the mechanism which allows for that protection is typically established and or fostered through a Main Street Program Director. If you don’t protect the infrastructure of the historic community, then how can it be protected? Historic district--along with their assets--include the protection of the infrastructure that supports the contributing properties. Bottom line is, by its nature, businesses in a historic district cannot be compared to other businesses outside of the Historic District and they must be protected from not only chains but also businesses in new buildings that are built to mimic authentic historic buildings.

With that said: Where has this proposed land use been addressed in the City of Winter Garden’s Comprehensive plan for the development of the Historic District? Designs in new construction should be sympathetic to the existing properties and not block their primary elevations as this proposed project will do. As well, historic buildings in a historic district that by tradition have been surrounded by open space must not be crowded with dense development. The lot in question is the only area left that gives us any hope of maintaining an open area in the center of town.

Loss of Identity and Legacy Businesses

New construction should support and enhance, rather than detract from the protected buildings in the Historic District. Currently we are in the early stages of losing both our sense of place as well as our sense of time and are in danger of transitioning from authentic history to fake history and perhaps a phony narrative. In an era of false history, it is essential to protect not only heritage buildings but as well legacy businesses within the district. Otherwise, a historic district will transition from its traditional “Mom and Pop” operations to the undesirable element for a historic district and that is “chain stores”, which will turn Winter Garden into a poor imitation of Winter Park. For this reason, all buildings in the Historic District should be labeled with the date of construction and owners of legacy businesses along with all of the elements that make our Historic District unique should be identified and catalogued along with its unique history.

One of the biggest problems we are facing is the size of the new buildings being constructed specifically within the boundaries of the Historic District. All new construction should be compatible with the size, scale, color, material, and character of the property and the neighborhood in which it sits and although buildings should be in the style of the surrounding community, they should not be allowed to be confused with the historic buildings in the community.

The proposed building will forever alter the contributing properties adjacent to the proposed building and create a skyline that completely obliterates not only their view, but also the view of them from the developing new City Center and creates a wall that splinters the Historic District. This is known as creating a “hard line” between old and new development in an historic district and should be avoided. The narrower the streets, the shorter the buildings should be. Therefore, new buildings should be in proportion to or transition from the size and proportion of adjacent buildings. Considering that the adjacent buildings are one story and the rest of the buildings in the area are two story, any new buildings should maintain the relationship to the street characteristic of the district, which would limit the building to two stories. The proposed building however alters the historic density of the Historic District in that area. A much better use for the proposed site considering the congestion in the area due to the farmers market and events that are being drawn away from the heart of the Historic District to the new City center should be an upscale park that can function as an overflow for crowds.

Where Do We Go from Here?

The City was approved for becoming a federally recognized Historic District under specific classifications of buildings that embody the distinctive characteristics of a type, period, or method of construction as well as location; none of which--as far as we can tell--has been properly addressed prior to any action being considered or taken unless there has been a violation of the Florida Sunshine Law.

Under State Law, the City of Winter Garden is required to designate and protect historic properties, create clear boundaries for the Historic District, review of all alterations, relocations, demolitions or new construction within a historic district or of historiclandmarks, and establish procedures for review criteria for reviewing alteration, relocation, demolition and construction proposals equivalent to those contained in the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings.

Comprehensive Plan

We also do not see where this is publicly being addressed as to how this proposed action will specifically affect the Historic District or how it fits into the City’s “comprehensive plan” that has already been accepted by the Commission.

A comprehensive study as well as a survey of all the contributing property owners in the district, as well as a survey of the community at large should take place prior to taking action to accept proposals for the property in question and prior to any consideration of proper due process in changing zoning that includes public notice that directly takes into consideration the community’s priorities.

It is imperative that the considerations of the general public, as well as property owners specifically listed in the Historic District that would be affected by the change of zoning be given a direct, honest, documented, and educated voice.

The City sends out notices to all affected businesses that it is going to pressure wash the sidewalks, but not when it is considering altering the historic character of the Historic District? City Commissioners cannot be expected to vote on such vital issues without the City staff properly addressing the impact of new development on the existing district, because the Commission would be, in our opinion, not making a vote based on the best information available. In order to protect the Historic District, a survey should be sent out, at the very least, because we believe it is or should be required for the historic preservation element of the City of Winter Garden’s comprehensive plan, specifically for the future land use in the district.

The mere fact that the property in question owned by the City should remain substantially restricted in that it must adhere to the best interests of the Historic District as an asset that is subject to the strictest interpretations of the Secretary of the Interiors Standards.

The City was to establish an ordinance that provides for a delay of demolition on specifically listed properties in the Historic District that give the citizens and leaders of the community the opportunity to assess and attempt to protect the asset from being lost. This is not being done and properties that are specifically listed on the historic register are being demolished (some in the middle of the night), in which the negative effects on the Historic District have not been properly addressed, which leads us to suspect that this project could as well follow an improper route.

The City of Winter Garden was required to submit, identify, and depict Historic District boundaries and must designate historically significant properties meriting protection. The Florida Administrative Code mandates, as a requirement for Future Land Use Goals, Objectives and Policies, that “the element shall contain one or more specific objectives for each goal statement which address the requirements of paragraph 163.3177(6)(a), Florida Statutes, and which … 4. Ensure the protection of natural resources and historic resources.” Historic preservation is also included as an additional optional element in its own right. § 163.3177(7)(i), Fla. Stat. (2008). This element, if included, should set out “plans and programs for those structures or lands in the area having historical, archaeological, scenic, or similar significance.”

Significant alterations within the Historic District can and do have a negative effect on the public health, which includes the spiritual, physical, aesthetic as well as monetary attributes of the community. Setting a three story structure in the center of the “Town Square” is not a alteration to the Historic District that should be taken lightly.

We appreciate your consideration on the matter.

Board of Directors

Historic Edgewater Hotel

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