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Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

  • 1.  Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-15-2020 13:44
    I just listened to an interview of Catherine Fleming Bruce, the author of The Sustainers: Being, Building and Doing Good through Activism in the Sacred Spaces of Civil Rights, Human Rights and Social Movements, who is the first African American winner of the annual Historic Preservation Book Prize. (I should mention that the podcast is sponsored by Preservation Maryland who has featured a number of interviews on social justice issues in preservation.)
     
    Starting at about 28 minutes into the interview, Bruce answers a question about how to address the lack of people of color in historic preservation. One item she responds with is that the field needs to do a better job at recognizing what everyday people are already doing to "preserve" places. Although she doesn't specifically mention this issue, many of the places that Bruce focuses on in her book fail to meet basic historical integrity and objective historical significance thresholds for NR eligibility. (In the case of significance, the issue is often lack of written, factual data although much information is potentially available through oral history interviews.) This observation brings up a few questions that I'd love to get others' input on:
     
    • Given that about 75% of historic preservation practice takes place in SHPOs, CRM firms, and local planning offices (e.g., preservation commissions), how would the kind of recognition that Bruce suggests manifest?
      • How would a SHPO, for instance, justify having its employees spend a large amount of time working on properties that are not eligible for the NR?
      • How would a CRM firm justify its employees doing work outside of a Section 106 scope that would promote non-NR eligible properties? How could a billing justification be made to a client in this context?
      • How would a local historic preservation commission justify staff time spent on properties outside of its scope mandated in the preservation ordinance?
    Does anyone have examples that they could share?


    ------------------------------
    Jeremy Wells, Ph.D., Associate Professor
    pronouns: he/his/him
    Historic Preservation Program, School of Architecture, Planning and Preservation, University of Maryland, College Park
    http://www.heritagestudies.org
    ------------------------------


  • 2.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-16-2020 06:33
    This answer doesn't answer or address your conversation about justification except to say that our local government has placed a priority on documenting and recognizing African American history. Historically, local tobacco factories almost exclusively used black workers, who made up just over 40% of the local population.

    The historic resources team for Winston-Salem/Forsyth County (NC) is responsible for developing content for our social media channels every February for Black History Month. We most often tie this to a mix of historic places, some extant and some not. Our historic marker program scoring includes additional points for markers that recognize under-represented history and/or sites where structures are no longer extant. We also develop educational panels for our local public parks when bond projects are undertaken to make improvements. We are in the process of finalizing content for panels that document the history of a local African American neighborhood that has 18th century origins, became a freedmen's community, then was substantially demolished during urban renewal, and was - in turn - redeveloped using HOPE VI funding. Of course, there is very little integrity left and the neighborhood has been found ineligible for the NR. But, census and land ownership records allow us to trace the history of families that have lived in the neighborhood for generations, while historic photos and Sanborn maps give us the ability to show a snapshot of the past. Another way we're considering recognizing historic neighborhoods that are not NR eligible is by using street sign toppers. These would not say "Historic District", but they would recognize an area as historic by using wording like "Historic Alta Vista" and include the date the neighborhood was platted or first developed.

    ------------------------------
    Heather Bratland
    Historic Resources Officer
    City of Winston-Salem
    Winston-Salem NC
    ------------------------------



  • 3.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-16-2020 08:37
    Isn't the problem at least in part that research hasn't been done to identify how these sites meet NR criteria, especially when their significance isn't primarily architectural?

    ------------------------------
    Jeremy Woodoff

    Brooklyn, NY
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  • 4.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-16-2020 11:22
    I have thought for several years that if we can ever get a good model for listing African-American vernacular historic districts as Traditional Cultural Properties (TCPs) under the National Register, we might be able to list more of these districts on the NR. Greektown in Tarpon Springs, Florida is the closest example we have of a neighborhood listed as a TCP. As far as i know, there are no African-American neighborhoods (I would love to hear if there are!)  Greektown is a National Register listed district, which is still used for traditional practices today, and has some heavy modification and newer infill that would normally not have been eligible for NR. One problem I feel is that people refer to neighborhoods (Chinatowns as one common example) as being TCPs, but the aren't actually - because they aren't listed. They were only determined eligible by a SHPO or a consultant at some point. We need to actually start listing them so that we have more examples of how to do it. I think there is a lot of potential for these types of TCP listings. However, for the purposes of Section 106 review, we need to be very careful when assessing TCP elibibilty. I think that SHPOs tend to be more liberal when it comes to determining properties eligible under the Section 106 process. But if SHPOs begin to determine more historic districts eligible as TCPs under Section 106, there will be more scrutiny from developers, and this could backfire and cause undue harm to the Section 106 process. For example, some people think of TCPs as vast areas, but that just isn't feasible in the Section 106 world - but TCP designation for neighborhoods is more practical and could work!!  But, if TCP designation is to be used more heavily in the Section 106 determination process, it will need to be done very carefully, and it will need to be justifiable to the non-preservationist who may not see the value in vernacular structures. Perhaps some sort of rubric is in order.

    ------------------------------
    Alissa Lotane
    Tallahassee FL
    (850)245-6357
    ------------------------------



  • 5.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-16-2020 13:30
    In preparing for an a preservation meeting this morning, I shared Jermey Wells's message to the group because Buffalo's Fruit Belt Neighborhood suffers from urban "removal," i.e., renewal, ravaging and this is just one of the many challenges of our work. When I posted it, Jessie Fisher mentioned how she had responded on Facebook (which I don't belong),  and I asked if I could share it in this Forum. I hope it is not a duplicate for most of you.  I think what Jessie has written is important for continuing the conversation Jeremy Wells has started.  How does PBN justify its involvement? It is in its mission and that mission is reflected in the belief and actions of PBN leadership, personnel hires, and work.  I also have to credit the Preservation League of New York State for getting out from behind desks and making their expertise and resources available.  PBN of course services more than just the City of Buffalo-- Jessie and her crew advocate and assist in the cities Niagara Falls, Jamestown, Lockport -- a 7 county region of western New York State.  In terms of PBN's record in working with POC, again, I have to say it is mission-- no excuses are given ("we can't find anyone"), words are met with action--PBN is not about lipservice, and people and neighborhood's are treated with respect without prejudice -- anyway, Jessie's message is below.  I've added links to her message. thanks all, lp (just an ordinary citizen, Buffalo NY)

    "Here in Buffalo, our local non profit advocacy organizations are doing the work to to expand what gets thought of as appropriate for listing, to challenge assumptions about history and integrity, and to bring the public agencies along in their thinking.  The work is difficult and can be hard to fund, but we find that, led and coordinated by Preservation Buffalo Niagara, we are moving the needle and find that the preservation movement in Buffalo is fairly diverse and over the last few years we have made progress in saving a greater range of places that tell a fuller story of our community.  While we have several examples of individual sites of preservation advocacy that we do in conjunction with individual localized advocacy groups (such as our fight to save Willert Park Courts, the Certified Local District we created in the Broadway Fillmore Neighborhood, our Eliza Quirk House project, and the work we do with local historic sites and neighborhood advocacy groups), we have recently taken on a large project that seeks to challenge the biggest systemic issue locally that closes the door to National Register for many of our Black Neighborhoods. 
    Our East Side Context Study seeks to open the door to NR Listing for a more diverse set of neighborhoods by seeking to build a historic context statement for this area that is less reliant on the "origin" story of when a neighborhood was originally built, but opens the door to seeing Great Migration and Post WW 2 Urban Renewal narratives as equally important in the histNationaory and character of these communities.  If integrity is measured only from the point of view of original construction as many SHPOs and NPS and consultants tend to do, then our neighborhoods that were deeply impacted by later changes to the built environment are disqualified.  However, if we determine that later stories on neighborhood evolution are equally important, and we take the time to expand the narrative of the neighborhood to include other eras of significance outside of original construction, we don't need to change the criteria for Listing, we can use those same criteria to list a more diverse group of stories.  Similar to how a later addition to an individual building can take on historic significance in its own right, these neighborhood changes, if properly understood and contextualized, can also take on their own significance and rather than be a barrier for Listing, can become an important part of telling the full stories of our communities.  This has the added benefit of making preservation more visible and relevant to more people, building a more diverse constituency for our work, and ultimately building a more diverse set of voices advocating for preservation."
    by:
    Jessie Fisher
    Executive Director
    Preservation Buffalo Niagara
    jfisher@pbnsaves.org
    (716) 852-3300
    617 Main Street
    Buffalo, New York  14203
    www.preservationbuffaloniagara.org


    ------------------------------
    Lorna Peterson
    Buffalo NY
    ------------------------------



  • 6.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-17-2020 00:42

    I agree that the preservation field needs to do a better job at recognizing what communities are already doing to preserve places that matter to them. But I would turn Jeremy's questions around.  Rather than accepting the idea that many important historic places cannot meet National Register eligibility criteria for significance and integrity, I think the preservation field needs to recognize the limitations of the criteria, and to work toward expanding them. 

    The 1966 National Historic Preservation Act referenced places significant in American history, architecture, archaeology and culture.  But the National Register regulations only include criteria for history, architecture and archaeology.  What happened to culture?   What could we gain by adding a criterion for cultural significance?  We could gain a lot.  We could find historic places eligible for NR listing because they are valued as part of collective lived experience, not just places valued for their material qualities or associations with the past.  This sounds like a heavy lift, but Australia has recognized social value since their first federal preservation law in the 1970s.    

    What kinds of places have social or cultural value? Community halls, movie theatres, sacred places, schools, public markets, public beaches… all kinds of historic places people love and use and take care of – the kinds of places that communities are already preserving, often without much support from preservation professionals.     

    A criterion for cultural significance would necessitate changes in how we assess integrity and define period of significance, changes already outlined in NR Bulletin 38 on Traditional Cultural Places.  We just need to pull that thinking from the periphery into the center of preservation practice by expanding the National Register eligibility criteria.  If the National Park Service leads on this, local commissions and advocacy organizations will at least consider following (I loved hearing about the work of Preservation Buffalo Niagara earlier in this thread – leading at the local level).  Obviously right now is not the time to propose a major expansion of federal preservation regulations, but it doesn't hurt to be ready with a proposal when the time comes. 

    If we can get a criterion for cultural significance integrated into federal policy, then we can ask how SHPOs, CRM firms, and local planning offices are going to bring in anthropologists and folklorists to do the kinds of people-centered ethnographic research Jeremy has advocated for years, because this expertise will be needed to complete Section 106 reviews.  And if documenting cultural significance was included in the scope mandated by local preservation ordinances, we could call out surveys as incomplete that fail to document community values along with historical, architectural and archaeological values.      



    ------------------------------
    Holly Taylor
    Principal, Past Forward NW Cultural Services
    Affiliate Instructor, University of Washington HP Certificate Program
    Burton, WA
    206-463-3168
    ------------------------------



  • 7.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-24-2020 21:12

    @Holly Taylor's suggestion to look at "cultural" value to amend the official NR criteria mentions the Australian Burra charter. Does anyone else find it curious that Americans were heavily influenced by international ideas about significance and authenticity right up until the Venice Charter of 1964, and then we pretended the rest of the world didn't exist, pretty much up until the present? The Venice Charter, which was mostly written by a bunch of Europeans (a lot of Americans boycotted attending, including Charles Peterson) is fundamental to American preservation practice: It's called the Secretary of the Interior's Standards. And a group of of NPS employees went gallivanting across Europe in the 1950s to inform what became the National Register. If you read With Heritage So Rich, which became the National Historic Preservation Act, there's all sorts of references to European practice. Although the phrase was invented in the US, historic preservation, in terms of how it became today's preservation enterprise, was a European invention. But, boy, did we do an excellent job of preserving 1960s European preservation here in the US, to this day.

    After the early 1970s, when the last American contribution to international preservation took to the form of the World Heritage Convention, American preservationists became increasingly insular. All of the other international developments in terms of preservation doctrine, like the Burra Charter, the Nara Document on Authenticity, and the Historic Urban Landscape approach, are almost entirely unknown to Americans, yet they embody much contemporary thinking in terms of diversity, equity, and inclusion. (And do we ever need these ideas in 2020!) Since the 1970s, Americans have pretty much abandoned participation in the World Heritage Convention, the core of which used to feature the same descriptions for historical integrity found in the NR. (Yeah, Americans contributed those to the World Heritage Convention.) Europeans swapped that out for a much more fluid approach, accommodating of intangible heritage several decades ago.

    So what we have, in contemporary US practice, is a kind of bizarre international time capsule: European preservation frozen in the 1960s, but it's here, today, in the US. Quanto sono strani questi americani per preservare le loro idee e non i loro edifici e luoghi.

    So, yes, we ought to be revising federal preservation regulations like the NR and the Standards, which then would likely filter down to influence local preservation ordinances. Can you imagine what these regulations would look like if they were brought up to current international thinking on built heritage in 2020? Yes, you can. It would probably look like the UK.

    In fact, Scotland is really ahead in this area, in my opinion. Not only in values-based approaches to built heritage conservation, but also in integrating natural and cultural conservation, and addressing climate change. Americans used to lead in heritage conservation, but we're behind the ball on almost every measure compared to many European countries -- bricks and mortar funding, research funding, updated regulatory frameworks, climate change, intangible heritage. Not that things are perfect on the other side of the pond, but there's much that American preservationists can learn from our overseas colleagues, if we'd bother to listen and learn.

    -Jeremy



    ------------------------------
    Jeremy Wells, Ph.D., Associate Professor
    pronouns: he/his/him
    Historic Preservation Program, School of Architecture, Planning and Preservation, University of Maryland, College Park
    http://www.heritagestudies.org
    ------------------------------



  • 8.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-26-2020 12:02

    Spot on Jeremy.

    I keep pushing in my circles for US preservation practice to reform with lessons from Nara, Kimberley, and Burra. I actually have increased optimism through he powerful conversations on difficult history and monuments in the last couple months. We're ready for change and new thinking.

    I do believe that the TCP approach is superior to Nara, Kimberley, and Burra in one significant way. The UNESCO charters and frameworks all rely on the foundation of "outstanding universal value." TCP avoids such an outlandish claim and argues the opposite - that places can be valued by a limited number of people and be no less significant. This is because TCPs are more valued for their continued cultural use rather than their unwavering adherence to physical integrity.

    In fact TCPs are capable of being "heritage" while embracing extraordinary physical change.  What this then points to is the need to worry less about getting things on the register (where stasis is celebrated rather than contemporary use and relevance) and concentrate more on heritage perpetuation - keeping our heritage alive and part of our daily lives.

    We need to embrace a wider spectrum of values on not just what is important and should be protected, but how we preserve and perpetuate places according to varying cultural values. Some places may need to be reinvented and see profound physical change in order to preserve the essence of a place. Other places may require an absolute resistance to physical change in order to retain material evidence of those who came before. Other places must focus on the intangible with little attention to the physical. One value system need not negate another.

    As a place of powerful and resilient indigenous cultures, as a place still dealing with the legacy of human bondage, and as a place of immigrant communities from around the globe, the US is obligated to lead the world in new heritage thinking that recognizes and celebrates the plurality of human culture. The rules and and standards and charters are in the way of this. They're all top down, colonialist thinking. How can we grow new heritage approaches that are bottom-up and truly rooted in place? I've had the extraordinary opportunity to do just this with a few Native communities in New Mexico. Granted, my architectural practice provides me with more opportunities to do the work of preservation without concern of whether a place is NR listed as I am meeting the needs and ambitions of my clients, but I see no reason why more traditional CRM firms can't do the same.

    Put yourselves out there to collaborate with and serve the communities you are surrounded by. Listen. Learn. Write grants. This field isn't going to change by itself. What are you waiting for?

    (That said Jeremy - where can I learn what's happening in Scotland?)



    ------------------------------
    Shawn Evans
    Santa Fe NM
    ------------------------------



  • 9.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 08-03-2020 15:23
    Look at Historic Environment Scotland. For instance, they produced a video about climate change and heritage here. They discuss the use of cultural values in asset management plans here.

    Sîan Jones has an article on "Wrestling with the Social Value of Heritage: Problems, Dilemmas and Opportunities" in the Journal of Community Archaeology & Heritage that discusses some of this work as well, in a broader UK context. (This is open access.)

    Leeds University led a project in "How Should Heritage Decisions Be Made" that is a highly recommended read. (PDF, open access)

    Lastly, read Kate Clark's book on Playing with the Past: Exploring Values in Heritage Practice (New York: Berghahn, 2019).

    These should give you a sense of the relative dynamism on the topics of heritage, people, place, and policy that's just not happening in the US.

    -Jeremy

    ------------------------------
    Jeremy Wells, Ph.D., Associate Professor
    pronouns: he/his/him
    Historic Preservation Program, School of Architecture, Planning and Preservation, University of Maryland, College Park
    http://www.heritagestudies.org
    ------------------------------



  • 10.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 08-03-2020 17:53
    Thanks Jeremy!

    ------------------------------
    Shawn Evans
    Santa Fe NM
    ------------------------------



  • 11.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-26-2020 12:08

    Spot on Jeremy.

    I keep pushing in my circles for US preservation practice to reform with lessons from Nara, Kimberley, and Burra. I actually have increased optimism through he powerful conversations on difficult history and monuments in the last couple months. The US field ready for change and new thinking.

    I do believe that the TCP approach is superior to Nara, Kimberley, and Burra in one significant way. The UNESCO charters and frameworks all rely on the foundation of "outstanding universal value." TCP avoids such an outlandish claim and argues the opposite - that places can be valued by a more limited number of people and be no less significant. This is because TCPs are more valued for their continued cultural use rather than their unwavering adherence to physical integrity.

    In fact TCPs are capable of being heritage while embracing extraordinary physical change.  What this then points to is the need to worry less about getting things on the register (where stasis is celebrated rather than contemporary use and relevance) and concentrate more on heritage perpetuation - keeping our heritage alive and part of our daily lives.

    We need to embrace a wider spectrum of values on not just what is important and should be protected, but how go about the action of preserving places and perpetuate culture according to varying values. We need a bigger tent than the limited standards of preserve, rehabilitate, restore, and reconstruct - all which seem to minimize change. Some places may need to be reinvented and see profound physical change in order to preserve the essence of a place. Other places may require an absolute resistance to physical change in order to retain material evidence of those who came before. Other places must focus on the intangible with little attention to the physical. One value system need not negate another. There are endless permutations.

    As a place of powerful and resilient indigenous cultures, as a place still dealing with the legacy of human bondage, and as a place of immigrant communities from around the globe, the US is obligated to lead the world in new heritage thinking that recognizes and celebrates the plurality of human culture. The rules and and standards and charters are in the way of this. They're all top down, colonialist thinking. How can we grow new heritage approaches that are bottom-up and truly rooted in place? I've had the extraordinary opportunity to do just this with a few Native communities in New Mexico. Granted, my architectural practice provides me with more opportunities to do the work of preservation without concern of whether a place is NR listed as I am meeting the needs and ambitions of my clients, but I see no reason why more traditional CRM firms can't do the same.

    Put yourselves out there to collaborate with and serve the communities you are surrounded by. Listen. Learn. Write grants. This field isn't going to change by itself. What are you waiting for?



    ------------------------------
    Shawn Evans
    Santa Fe NM
    ------------------------------



  • 12.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-26-2020 14:45
    Excellent observations, Jeremy. One obstacle is going to be waiting out the retirements/departures of existing senior-level preservation agency folks. back when I was working on FCC issues (2000-2004), I participated in the working group convened by the ACHP and FCC to revise the Section 106 compliance regulations for telecoms and broadcasters (the infamous programmatic agreements). I described approaches to evaluating visual impacts and resolving issues/effects associated with them used in Europe to a very senior ACHP staffer. The response: That's Europe and it's not how we do things here.

    David
    _________________________________________
    David S. Rotenstein, Ph.D.
    Historian/Folklorist | Adjunct, Goucher College Master's in Historic Preservation Program
    david.rotenstein@earthlink.net
    Phone: (412) 328-3830







  • 13.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-26-2020 17:14
    The "not invented here" mindset is part of the larger anti-intellectual bias that a number of other people have noticed seems to characterize historic preservation. There's so much useful empirical evidence that could inform practice, but it's not used, which is a shame. I'd be guessing as to why this is the case (I have my ideas, but will keep them to myself, for now), but I've noticed that this "let just get the work done" attitude begins in many of the HP educational programs in which students enroll, and then gets perpetrated into practice; in the latter case, sometimes emerging as "you're not paid to think; you're paid to follow the regulation." (Not my original ideas, but the way - read Russell [2014] and Elliott [2019].) 

    Citation: Russell, R. (2014). First Pete and then repeat? Fundamental differences in intention between undergraduate and graduate preservation programs in the United States. In B. L. Stiefel & J. C. Wells (Eds.), Preservation education: Sharing best practices and finding common ground (pp. 42–56). University Press of New England.

    Elliott, J. (2019). The mystery of history and place: Radical preservation revisited. In J. C. Wells & B. L. Stiefel (Eds.), Human-centered built environment heritage preservation: Theory and evidence-based practice. Routledge.






  • 14.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-27-2020 15:19
    I'm late to this discussion but wanted to echo some of the sentiments already stated....The NR program needs to change. Yes, many HP professionals and SHPO's have evolved their interpretation of NR criteria to include a more diverse range of places but the whole program still has such an elitist, white supremacist approach and basis. We need to make fundamental changes to this program, which serves as the basis for much of our work, if we hope to remain relevant.

    In my work in the city of Rochester, NY, in predominantly and historically Black neighborhoods, it is almost impossible to find a neighborhood that would be an eligible district as traditionally interpreted. If usually comes down to physical integrity. Racism and white supremacy culture have caused these neighborhoods to experience disinvestment, and extreme concentrated poverty, which in turn has led to demolitions, vinyl siding, what we would consider insensitive alterations, etc. But isn't that part of the story? Isn't that lack of integrity, in and of itself, significant? But then, it seems that the logical conclusion of that argument, is that anything and everything is NR eligible...I definitely don't have the answers but am struggling w/these concepts on the ground. To their credit, SHPO is willing to hear us and try to work through this stuff but, man, we need a reckoning and we need change.

    ------------------------------
    Caitlin Meives
    Director of Preservation
    The Landmark Society of Western New York
    Rochester NY
    ------------------------------



  • 15.  RE: Role of SHPOs, CRM firms, preservation commissions when "preservation" is not NR eligible?

    Posted 07-27-2020 15:53
    Sorry for my double post!  Fascinating point Caitlin. Absolutely the integrity standard needs adjustment, or perhaps abandonment. Historic places need not be preserved to original configurations, and the modifications are indeed part of the story, but this raises the dilemma of tying significance to the standards. Yes the demo, vinyl siding, and other subtractions from integrity are significant but I'm not sure anyone would argue that those features necessarily then  need to be retained. What our policies are lacking are possibilities for community to determine authenticity, integrity, and value.

    ------------------------------
    Shawn Evans
    Santa Fe NM
    ------------------------------