Forum Journal & Forum Focus

A Thirst for History: An Assessment of the Compatibility of Federal Rural-Development Program and Historic Preservation 

03-14-2019 11:25

The National Trust for Historic Preservation was awarded a contract from the U.S. Department of Agriculture, fulfilling a directive from the U.S. Senate Agriculture Appropriations Committee, under the authority of the Rural Development Act of 1972, to study the compatibility of federal rural development and historic preservation. The National Trust was assisted by a multidisciplinary team, including staff of the Urban Institute and Housing Assistance Council. The study involved site visits to twenty-three counties in thirteen states, interviews with historic preservationists and rural-development staff in twenty-three federal agencies, and an analysis of forty-six rural-development programs. The following material explains the genesis of the study, and the methodology used, and includes reactions and responses to the study by representatives of federal agencies and individuals associated with organizations working with those agencies.

RURAL RESOURCES AND PRESERVATION

The history of this nation is overwhelmingly the history of its people and their development of the land and its resources. Farms, mines, fishing villages, timber camps, hamlets, and waterways are all tangible documents of that history. As a nation, we lack a full understanding of ourselves as a people if we do not recognize and understand the importance of our rural heritage. Historic preservation as a federal policy and as a popular movement cannot give Americans a sense of their past, nor a base for their future, if it fails to identify and protect our nation’s rural history.

The Senate agriculture appropriations subcommittee’s recognition and concern for America’s agrarian heritage was the impetus for the National Trust’s new study, “A Thirst for History.” As the 1980s brought farm foreclosures to America’s heartland, the committee recognized the fact that America was losing both its farmers and its agricultural heritage. As farms came into the possession of the Farmers Home Administration (FmHA), we were concerned that the agency meet its responsibility to protect the related historic resources.

When we learned that staff unfamiliarity with historic preservation law resulted in the loss of a farmland and damage to an archaeological site in my home state of North Dakota, we knew it was time for action. As chairman of the subcommittee, I responded by directing FmHA to undertake an evaluation of the relationship between historic preservation and rural development, two vitally important federal policies. “A Thirst for History” is the result, and demonstrates both the possibilities for and problems with improving the lives of rural Americans and protecting our nation’s rural heritage. Most importantly, the study reveals, as its title illustrates, that rural Americans care deeply for their heritage, want to protect it, and see it as a useful tool in their efforts to create and control their own future. The problems arise in providing leadership at the federal level and in equipping rural residents with the necessary knowledge, skills, expertise, and funding to identify and protect essential components of their rural history.

As often happens, however, raising large policy issues results in incremental improvements in daily practices. In North Dakota, the state historic preservation office and the Farmers Home Administration staff now work together to evaluate properties and ensure the protection of those worthy of national recognition. “A Thirst for History” contains hundreds of recommendations ranging from changes to individual program guidelines to major shifts in departmental policy. Through

its thorough analysis of forty-seven programs, the report provides a framework for moving forward to rural America’s rich heritage. I commend it to rural Americans, government policymakers, and rural-development leaders across the country.

THE HONORABLE QUENTIN N. BURDICK

D-North Dakota
Chairman, Subcommittee on Agriculture,
Rural Development, and Related Agencies:
Committee on Appropriations
United States Senate

THE NATIONAL TRUST’S COMMITMENT TO RURAL HERITAGE

The potential for compatibility between historic preservation and rural development is strong, dynamic, and of vital interest to the National Trust for Historic Preservation. The Trust has more than a decade’s commitment to preserving America’s rural heritage. In 1979 we established the Rural Conservation Project in response to requests for assistance from communities where development threatened both farmland and cultural resources. Over the course of the last decade Trust staff have provided technical assistance to rural areas in a variety of ways: through grants and loans, conferences, publications, and the successful Barn Again! program. Cazenovia, New York, and Oley, Pennsylvania, were the focus of demonstration projects in which local citizens worked together to identify and analyze valuable natural and cultural resources and developed plans for their preservation. These projects served as background for the widely acclaimed textbook on rural preservation, Saving America’s Countryside: A Guide to Rural Conservation by Samuel Stokes and Elizabeth Watson, et al.

The National Trust is not alone in its concern for rural preservation. In the last decade America’s land-conservation movement has become much more broad-based and sophisticated. More than 900 land trusts are now in business around the country, and numerous public/private partnerships have been formed at the local level to preserve individual structures, historic districts, and such historic corridors as canals, roads, and trails. Rural revitalization programs have shifted their foci from trying to attract large-scale industry to developing diversified economies that conserve the indigenous natural, human, and cultural resources. Economic-development specialists are now developing farmers’ markets and cottage industries, attracting tourists, and inviting retirees to relocate to rural areas.

One concern of the National Trust is the impact of federal programs on America’s rural heritage. Federal agencies have an obligation under the National Historic Preservation Act to take into account the effect of their actions on properties listed in, or eligible for listing in, the National Register of Historic Places. The impetus for this study of compatibility between historic preservation and federal rural development—“A Thirst for History”—was an incident that occurred in North Dakota in 1988. The Farmers Home Administration, which acquires family farms that are victims of persistent agricultural crisis, purposely burned a farmhouse in its inventory and, in so doing, damaged the historic site of an Army campground. In this instance, the agency failed to identify and consider the historic qualities of the property in question. The event received national media attention, and a year later Congress mandated the Farmers Home Administration to assess the extent to which federal rural development policy and national historic preservation policy are compatible.

The assessment, conducted over an eighteen-month period by a multidisciplinary team of professionals, was a rigorous analysis of public policy: both federal rural development policy and historic preservation. The study methodology involved analysis of forty-six rural development programs in twenty-three federal agencies. For a sample of the programs, the regulations were analyzed for barriers and incentives to potential compatibility. Site visits to twenty-three counties in thirteen states were undertaken to learn firsthand the incidences of compatibility and incompatibility in the field. Altogether, interviews were conducted with more than 325 people. The results of the assessment are based on structural analysis and close observation of federal rural-development and historic preservation programs and policy, both in Washington, D.C., and in the sites visited.

The National Trust is grateful to the Senate Agricultural Appropriations Committee for sponsoring this ground-breaking assessment, which required the efforts of dedicated legislators and their staff, of staff within the U.S. Department of Agriculture, and of numerous private citizens and organizations wanting such a study to occur. Indeed, the assessment is a reflection of the popular interest in rural preservation issues nationwide. The National Trust thanks all of those who helped to make the assessment happen, especially those within USDA. We are honored to have conducted the assessment and will use it as a basis for our on-going efforts to provide leadership in preserving America’s rural heritage.

JACKSON WALTER

President
National Trust for Historic Preservation

FINDINGS, RECOMMENDATIONS, AND METHODOLOGY

Principal Findings

The study found that few federal agencies exercise leadership in promoting the compatibility of rural-development programs with historic preservation.

  • There is strong development potential for mutual compatibility between federal rural- development programs and historic preservation, although opportunities for interaction between the two are frequently missed. When opportunities for interaction were realized, the study found, historic preservation benefit - ted rural-development activities more than it harmed them and, similarly, rural-development activities benefitted historic resources more than they harmed them. The study found frequent and widespread positive interaction between historic preservation and rural development in the activities of such federal land management agencies as the National Park Service (NPS), the U.S. Forest Service (USFS), and the Bureau of Reclamation (BOR), and in the Department of Housing and Urban Development’s (HUD’s) Community Development Block Grant (CDBG)/Small Cities Program.
  • Many barriers to using historic resources to meet rural-development goals are embedded within agency regulations and guidelines for rural-development programs. The study found significant barriers in USDA’s Farmers Home Administration (FmHA) housing construction and repair programs, as well as in infrastructure and civil works programs.
  • Few federal agencies actively encourage the incorporation of historic resources into rural-development projects through policies or program incentives. Few agencies make a conscious attempt to use historic resources in rural-development projects. Such a goal is not articulated or communicated to staff or program constituents, even when the incorporation of historic resources could significantly aid rural-development goals.
  • Federal agencies, as a rule, are not locating their offices in historic buildings, thereby missing the opportunity to set an example of stewardship of historic resources. In twenty of the twenty-three counties visited in this study, local USDA staff were located in newly constructed buildings, often outside of towns, instead of in available historic buildings in rural communities.

Historic preservation law is necessary but not sufficient to ensure compatibility.

  • The requirement of Section 106 of the National Historic Preservation Act (NHPA) that federal agencies consider the impacts of their activities on historic resources minimizes the adverse impacts of federal rural development on historic resources. However, Section 106 does not encourage compatibility. The process tends to focus agency attention on avoiding historic resources instead of on promoting their use to meet program goals.
  • Federal agencies have made significant progress in meeting their obligations under historic preservation law. Most federal agencies have a federal preservation officer (FPO), many have hired staff with cultural resources expertise, and a few have instituted historic preservation training for program staff and have developed programmatic agreements (PAs) with the Advisory Council on Historic Preservation (ACHP).
  • Some federal agencies involved in rural development have failed to meet the basic requirements of national historic preservation laws. The USDA’s Extension Service (ES) and the Small Business Administration (SBA) have not appointed an FPO, as required by the NHPA. Additionally, the study found that at least six other agencies, although having designated an FPO, demonstrate a low institutional commitment to meeting historic preservation mandates.

Available historic preservation information and incentives are insufficient to promote compatibility between federal rural development and historic resources.

  • Although there are staff with cultural resources expertise in most federal agencies, staff responsible for program implementation are trained inadequately in the identification of rural historic resources, historic preservation law, and the techniques for preserving historic resources. Therefore, program staff lack the skills needed to promote compatibility between rural-development programs and historic preservation. In many agencies, historic preservation training is limited to staff who have defined historic preservation responsibilities and is not available to staff who implement programs.
  • Federal agencies consider the impact of individual federal actions on historic resources but give little or no consideration to the cumulative impacts of such actions. The Section 106 process lacks effective mechanisms for assessing impacts that are interactive or additive over time and space. The state of the art of assessing such impacts is poor.
  • Federal agency program staff and program beneficiaries often fail to consider the cultural heritage of the rural environment. As a result of narrow definitions of historic resources, opportunities for compatibility are missed. Federal staff tend to define rural historic resources as archaeological resources. Local citizens tend to identify rural historic resources in terms of individual structures or sites.

The greatest evidence of the potential for compatibility was found in the rural counties themselves.

  • The residents of rural communities have a strong interest in local history, which can provide a basis for using historic preservation as a tool of rural development. However, this interest is not supported by either a vision of how to make the connection between preservation and development or the skills necessary to initiate the process.
  • There is significantly more rural-development and historic preservation activity in counties experiencing economic growth than in counties with stable or depressed economies. The study found more professional planners, more historic preservation organizations, and more federal programs using historic resources in growth counties than in counties with stable or depressed economies.

Principal Recommendations

Realizing the full potential of compatibility— the use of America’s rural heritage to contribute to the revitalization of rural communities—requires a clearly articulated commitment on the part of Congress, USDA, historic preservation organizations and professionals, and federal agencies active in rural areas. Implementing this commitment will be a complex and challenging process, involving thousands of individual daily decisions by a multitude of federal, state, and local agency staff and by a variety of professionals in distinct and dispersed rural communities. Implementation will require, first, that all agencies meet their legal responsibilities for compliance with historic preservation law. Second, agency staff must be provided with appropriate historic preservation training, information, and incentives and have access to needed expertise. And third, historic preservation organizations and agencies must invest their knowledge and resources in the preservation of America’s endangered rural heritage.

The recommendations that follow, which are based on the study’s principal findings, are a road map for implementing a national commitment to America’s rural communities and their heritage.

Leadership

As the congressionally recognized leader for the implementation of policies aimed at rural America, USDA must exercise national leadership in the achievement of compatibility. The Secretary of Agriculture should issue a formal policy statement that rural economic development and America’s rural heritage provide opportunities for supporting and enhancing each other and that the exercise of leadership in achieving compatibility is a basic USDA responsibility. This affirmation needs to be given the highest level of USDA support. The Secretary of Agriculture should:

  • Appoint a senior official with expertise in rural heritage and rural community development who reports directly to the Secretary of Agriculture. This specialist should be a full participant in coordinating the USDA’s rural- development programs. This person should serve as a spokesperson and advocate for rural America and should be authorized to work with other federal agencies, historic preservationists, and rural communities.
  • Direct the administrators of the FmHA, the SCS, the ES, and the USFS to establish a mechanism for staff at regional, state, and local levels to meet and share information and expertise on the use of historic resources to achieve program goals.

Leadership is not the sole responsibility of the USDA. All federal agencies need to exercise leadership through demonstrating compatibility. Federal agency staff should:

  • Identify, document, and publicize successful rural historic preservation projects and reward responsible agency staff. Set aside program funds to demonstrate compatibility with historic preservation. Aggressively distribute project materials to program staff.
  • Implement an office-leasing policy that rewards the use of buildings listed in or eligible for listing in the National Register of Historic Places (NR). Establish guidelines for considering such factors as the impact of office- location decisions on retail and professional services.

Historic preservation professionals, agencies, and nonprofit organizations also have a leadership responsibility in protecting and caring for America’s rural heritage. They should:

  • Ensure that all historic preservation programs are responsive to rural historic resources and the threats they are experiencing. Hire professionals in such relevant fields as agricultural history, cultural geography, and folklife. Develop publications and other information resources on rural historic resources and their preservation needs.

State historic preservation offices (SHPOs) should:

  • Establish a mechanism to ensure frequent interaction between SHPOs and federal program staff. Know the responsible personnel for programs that constitute the bulk of SHPO caseloads. Assign staff to spend a few days a year at federal agencies and conduct annual briefing sessions for agency staff.
  • Conduct historic resources surveys documenting the full range of significant rural resources. Develop and distribute to federal agency staff historic context reports for each state’s principal rural industries and regions.

Compliance

Commitment to compatibility will be built upon compliance with historic preservation laws. Federal agencies with vague or unstated commitments to historic preservation need to take every step possible to meet basic legal requirements. Federal agency staff should:

  • Appoint an FPO with the appropriate professional background whose location within the agency allows for relevant interaction with program managers and for review of program guidelines.
  • Assess all program guidelines for barriers to full compliance with historic preservation regulations, and make every effort to eliminate or alter those guidelines.
  • Ensure attendance at the training program conducted by the ACHP on Section 106 for all staff who are responsible for implementing programs that affect historic resources.
  • Support and encourage frequent interaction between federal agency staff and SHPO staff.

Training

It will not be possible to achieve compatibility if federal agency staff are inadequately informed about historic resources and historic preservation techniques. The ACHP, SHPOs, and the NTHP should:

  • Develop and implement a training course on the techniques and costs of rehabilitating historic buildings within rural-development program guidelines. The course should feature examples of federal program use of historic resources and analyses of program regulations.

Federal agency managers should:

  • Encourage and support the participation of federal agency program staff in training courses specifically focused on rural development and rural historic resources. Training information should be distributed to staff, and their participation should be encouraged and facilitated.

Funding

Although many of the requirements for compatibility are in place, some new incentives are required and some research needs remain. These initiatives require Congress to appropriate needed funds. Congress should:

  • Fund rural heritage incentive programs to enhance the realization of historic preservation goals within existing federal programs. Historic preservation professionals currently have few incentives to offer federal agencies. A rural heritage grant program, historic rehabilitation tax credits, and other financial incentives will enhance historic preservation efforts.
  • Fund a program through which nonprofit organizations with expertise in rural historic preservation can provide communities technical assistance in identifying and using their historic resources.
  • Fund ACHP and Council on Environmental Quality (CEQ) research into the techniques for assessing the cumulative impacts of federal programs and projects. Currently, the state of the art of assessing additive and interactive impacts over space and time is embryonic. Investigation and analysis should focus on the interactions among various federal programs.
  • Fund research for federal agencies and nonprofit organizations with rural expertise to identify and analyze exemplary projects and best practices in the compatibility of rural development and historic preservation. Case studies of the successful rehabilitation of rural historic structures as a component of rural heritage tourism, for example, should be undertaken and promulgated.

Methodology

“A Thirst for History” presents the results of the assessment of the compatibility of federal rural-development programs and historic preservation. The first step in the assessment was to define these two terms. According to the National Historic Preservation Act, historic preservation is defined as the “identification, evaluation, recordation, documentation, curation, acquisition, protection, management, rehabilitation, restoration, stabilization, maintenance, and reconstruction” of historic property or resources.

The congressional definition of rural development is stated in the Rural Development Act of 1972, which established guidelines and directed the Department of Agriculture to lead the nation’s rural-development efforts. Rural development is the planning, financing, and development of facilities and services in rural areas that contribute to making these areas desirable places in which to live and to make private and business investments; the planning, development, and expansion of business and industry in rural areas ...; and the planning, development, conservation, and the use of land, water, and other natural resources of rural areas to maintain or enhance the quality of the environment.

The second step was to develop an operational definition of compatibility. To assess compatibility, four considerations were identified:

  • Incompatibility as evidenced by federal rural-development programs’ adverse effects on cultural resources.
  • Compatibility as evidenced by federal rural-development policies, procedures, or activities that benefit cultural resources or historic preservation efforts.
  • Incompatibility as evidenced by cultural resources or the historic preservation process having adverse effects on federal rural-development efforts.
  • Compatibility as reflected in the furtherance of federal rural-development program goals through the use of cultural resources.

Program Selection

The first phase of the assessment was the selection of federal rural-development programs. FmHA provided an initial list of 133 programs to which were added several regulatory commissions and the planning programs in federal land-management agencies. Consultation of published sources and interviews with SHPO staff, federal agency staff, ACHP staff, and rural-development, conservation, and historic preservation advocates contributed to the program list. Then the programs with the greatest potential to affect cultural resources were identified, principally on the basis of the amount and proportion of funding spent in rural areas and their potential impact on NR-eligible sites, buildings, or objects. Finally, forty- six rural-development programs were selected for assessment.

Site Selection

Twelve states were then selected for site visits to represent a geographical cross section of the country. They were selected in adjoining pairs to economize on travel. The pairs of states selected were Idaho/Oregon, Colorado/New Mexico, Iowa/North Dakota, Kentucky/Indiana, Mississippi/Arkansas, and New York/Vermont.

Within each state, two nonmetropolitan counties were selected—based on their type of economy—through a random process. In one state, a land-management entity—a national forest—was substituted for a county. Finally, geographical considerations, logistics, and consultation with SHPOs, federal field staff, and National Trust field staff influenced final site selection. Additionally, St. Mary’s County, Maryland, was visited as a pilot test of the study procedures.

Data Collection

Data collection was carried out both at federal agency headquarters and in the thirteen states visited. Nine guides were developed for the following interviews: federal preservation officers (FPOs), federal program managers, SHPO staff; county or regional planners; field program managers; local preservationists; FmHA, Soil Conservation Service (SCS), and Cooperative Extension Service (CES) focus groups; recipients of federal funding; and local observers.

Site Visits

Two-member teams were assigned to each of the twelve states visited (after Maryland). Interviews were scheduled first with the SHPO, next with field program managers, and then with interviewees in each of the selected counties. In twenty-two of the counties visited, US- DA “focus group” interviews were conducted with representatives, as available, from FmHA, SCS, and CES.

Document Analysis

For programs with the potential to use cultural resources to meet their goals, program regulations were reviewed and analyzed. A total of thirty programs qualified. Analysis focused on federal eligibility requirements, program activities, and the project-review process.

Analysis

Data analysis proceeded from an assessment of the regulatory potential for compatibility to a comparative analysis of data gathered in headquarters and in the field. Data were analyzed by federal agency, by type of program, and by type of county visited; additionally, the cumulative impacts of federal rural development on cultural resources were assessed.

A draft of “A Thirst for History” was reviewed by the FmHA project officer and advisory committee, which included the National Conference of State Historic Preservation Officers (NCSHPO), the ACHP, and the NPS. Additionally, a series of meetings was held within NTHP to facilitate the exchange of program information and preservation expertise.

SHELLEY MASTRAN

Acting Director
Rural Heritage Program

CULTURAL RESOURCES AND RURAL DEVELOPMENT: THE POTENTIAL FOR CULTURAL RESOURCES TO CONTRIBUTE TO RURAL DEVELOPMENT

Cultural resources, those remnants of past activities on the landscape of America, are often best preserved in the rural settings of the nation. Development and urban sprawl have obliterated much of the historic and prehistoric remnants of the past in other places. It is the backroads and byways of the country where we frequently find the connections between our lives and the lives of those who preceded us. Although some Americans’ heritage lies elsewhere, most of us trace our roots to rural America.

The role of cultural resources in the rural American community is as yet largely untapped. The opportunities and interest are present. Most rural communities express an immense pride in their heritage, and it requires little effort to elicit their assistance in the protection, preservation, and interpretation of their historic properties. “A Thirst for History” is a timely examination of the role that agencies involved in rural development can play in assisting rural America to preserve significant parts of its historic past.

The Forest Service believes in rural development and has an active program to explore ways to accomplish it. Whether it is grazing livestock on the national forests, providing water resources for rural towns and villages, the production of timber and mineral resources, or the attraction of tourists to the outdoors, the National Forest System has long been a provider of jobs, income, and recreation for rural populations.

Rural cultural resources are just now being recognized for the potential economic value they contain. Only a few years ago the Forest Service developed the National Recreation Strategy. The purpose of the NRS was to increase the attention paid to recreation resources in the national forests. The recreation industry of the United States, reported to be a $2-billion-a-year activity, is a significant part of the economic system of the nation. The Forest Service, which provides 40 percent of all federally sponsored outdoor recreation in the nation, recognized cultural resources as an obvious way to increase the recreational value of the National Forests.

One segment of the National Recreation Strategy was a focus on the role and potential that cultural resources could play in enhancing the visitor’s experience in the national forests. Called Windows on the Past, it called for developing opportunities for the public to view the past though partnerships, quality interpretation, and volunteer activities. Each unit of the National Forest System was encouraged to open a “window” on the past and invite the public to participate. Soon hundreds of projects were occurring across the country. Historic cabins were stabilized and opened for visitation, historic buildings were stabilized to prevent their collapse, auto and walking tours of historic and prehistoric resources were developed, interpretive signs were placed where important resources could be explained, and partnerships with local communities and groups resulted in widespread support for preserving and interpreting local prominent historic features. A video was produced to explain what Windows on the Past was all about, and soon a booklet will be available on the subject.

The volunteer part of the Windows on the Past program has been developed into a national program for matching volunteer opportunities to volunteers. This program, called Passport in Time, provides a listing of projects designed especially for volunteers as a way of providing a unique recreational experience. Individuals from California can sign up for a week to assist in the excavation of a prehistoric campsite in Minnesota. Volunteers from Wisconsin can take in a week of work at a historic military encampment in Utah and then a week at a historic mining town in Nevada, all worked around a vacation with relatives in California. No fee is charged for participation, and a central clearinghouse collects all the information and matches volunteers to projects. This program, now completing its second year on a nationwide basis, is having phenomenal success and growth.

The success of the Forest Service’s Windows on the Past program and its Passport in Time volunteer effort is further evidence for the public’s thirst for history. What we are just beginning to recognize is the potential such efforts hold for affecting the rural communities in which the majority of these projects occur. In purely economic terms, the effect of a volunteer crew of fifteen working for a week near a small community in rural America can be estimated by the amount of money spent. Motels and meals would average $50 per day for most rural projects, a total of $4,500 per project. Many projects run from four to seven weeks, bringing the potential expenditure up to $30,000 per project. In 1991 a total of thirty-seven projects was scheduled, representing a total amount expended by volunteers of $1.2 million. If the program continues to expand, his amount could easily increase ten-fold over the next five years.

Other benefits from Passport in Time projects and other types of Windows on the Past projects are the visitors they attract, which far outnumber the volunteers involved. People stay longer than they would otherwise stay in the national forests to participate in or visit the projects, and, therefore, they spend more for meals and lodging. An average project attracts about 1,000 visitors a week. Depending on the proximity of population centers and the amount of publicity the project receives, projects may draw more than 1,000 visitors per weekend. Estimating the average visitation at 1,200 visitors per week and assuming they spend $10 in the local area that they would not otherwise spend, a total economic potential of $3.1 million is not unlikely.

Clearly, the potential for cooperation and coordination in using cultural resources to further rural development is much greater than present programs accomplish. The Forest Service is committed to continuing its efforts with Windows on the Past. We are committed to looking for ways of participating in the preservation and development of rural communities through the sensitive development of heritage resources.

EVAN I. DEBLOOIS

Historic Preservation Officer
U.S. Department of Agriculture Forest Service

HOUSE ON ELM STREET

The Farmers Home Administration (FmHA) Housing Preservation Program is a direct grant program to nonprofit organizations or public bodies and is designed to eliminate safety hazards from owner-occupied houses. To be eligible, a homeowner must meet FmHA “Low-Income” or “Very Low-Income” standards and the house must be located in an area that is served by the FmHA and that is outside the 100-year floodplain. Assistance to individual homeowners may assume the form of loans or grants. The state of Idaho has decided to utilize grants because of the income level of the recipients and the costs that would be associated with processing and maintaining a number of small loans.

The FmHA has entered into a programmatic memorandum of agreement with the National Conference of State Historic Preservation Officers and the Advisory Council on Historic Preservation. This agreement outlines the responsibilities of the Housing Preservation Program grantees with respect to work performed on houses that are considered historic properties. The realities of complying with the historic preservation requirements become apparent during the actual implementation of a housing rehabilitation program.

In 1989 the Housing Preservation Program was approached about rehabilitating a small Victorian-style house. The single-story two- bedroom house encompassed approximately 1,000 square feet of space and had been built circa 1910. Subsequent to the original construction, the house was expanded on one side to include a bathroom, the kitchen wall was expanded outward to provide additional kitchen space, and the back porch and basement entry had been covered. A front window in the master bedroom had been removed and replaced with wood siding that did not match the siding on the house.

The house had a complicated roof that was covered in ceder shingles that had been patched in several areas and had shown signs of leaking, especially in and around two abandoned chimneys. The front porch of the dwelling was in the process of collapsing and the wooden front steps that were anchored directly into the ground had suffered extreme moisture damage.

It was our intention to remove the unused chimneys, strip the old shingles from the roof, and apply a fiberglass composition shingle over plywood decking and felt paper. We also planned to rebuild the front porch and add supports to the kitchen addition. Because the building was more than fifty years in age our program submitted photographs and a form indicating the work to be done to the State Historic Preservation Office. I had assumed that the additions and alterations would exclude it from any special historic consideration. I was very wrong.

The SHPO responded that the house was included in the office’s site inventory and that it met the eligibility criteria of the National Register of Historic Places as contributory to a potential historic district. The SHPO further responded that the removal of one of the chimneys and the replacement of the leaking wooden shingles with composition shingles would be considered an “adverse effect.” The issue of the chimney did not pose a serious problem, but the type of roofing material was a different situation. Three options were listed by the SHPO: leaving the existing roof intact (and leaking); replacing the existing roofing material with wooden shingles or with a composition shingle that would match the existing material; or, as a last option, using the fiberglass composition material, which would be considered an “adverse effect” and would require a request for comments from the Advisory Council on Historic Preservation.

The option of roofing with cedar shingles was out of the question. Given the complicated roofline that would require extensive trimming and the high cost of cedar shingles, this option would have cost more than double the proposed composition roof. An unsuccessful attempt was also made to locate a composition roof that would match the existing material, leaving only the option of contacting the Advisory Council for comments. This was done and resulted in another memorandum of agreement spelling out the color of composition shingles, the treatment of the foundation repairs and the repairs to the chimney. From the time that I made my initial contact with the SHPO to the time that the final memorandum of agreement was signed, five months had passed.

Apart from the lost time, the major problem that I had with this process was the apparent lack of thought and commitment that Congress and the federal agencies have put into this concept. Congress has historically underfunded housing rehabilitation programs for low-income families. The entire national allocation for the Farmers Home Administration Rehabilitation Program is only $23 million for this year. Our state is allocated $208,000, an increase of $24,000 from last year, but it does not take a great mathematician to realize that this sum of money will not rehabilitate very many housing units. The house in question cost in excess of $9,000, more than twice the average cost of a house rehabilitated under our program. It seems extremely unfair to take funds from an already underfunded poverty program to promote historic preservation.

Wooden shingles are not an allowable building material in some areas because of their increased fire threat, and roofing contractors recommend that wooden shingles be treated with an oil solution every few years to prohibit weathering. Realizing that the home- owners in this program fit into the lower-income categories, it seems preposterous that anyone would recommend that materials be used that will cause increased fire insurance expenses and increased and costly maintenance. The Housing Preservation Program was designed to help low-income families improve their housing conditions, not increase their housing costs.

A final factor that really points out the lack of planning that has gone into this situation is that, after the rehabilitation work has been completed, the homeowner is able to modify the house in any manner and without regard to any historic guidelines. This could include unsightly additions, the application of inappropriate siding, or any other modifications. If the dwelling needs additional work several years after it has participated in the Housing Preservation Program, it will be the homeowner’s responsibility to make the repairs. In the case of low-income homeowners, the type and quality of work will be dependent upon their financial resources, not in regard to the historic significance of the house. It seems ridiculous to require that a federally funded rehabilitation program comply with historic preservation regulations that do not apply to the homeowner.

If the Farmers Home Administration Housing Preservation Program is expected to operate in an effective manner, the goals of the program need to be focused on preserving safe, habitable, and affordable housing for the low-income population. This will not be possible if Congress continues to underfund the program and federal agencies continue to inhibit the program with additional, and sometimes conflicting, goals.

JAY SMITHMAN

State of Idaho
Department of Health and Welfare
Division of Community Rehabilitation

HISTORIC PRESERVATION AND RURAL-DEVELOPMENT PROGRAMS

It is difficult to argue with any of the findings of the National Trust for Historic Preservation report “A Thirst for History” assessing the compatibility of federal rural-development programs and historic preservation. While historic resources literally define rural America in the collective American mind, rural-development programs rarely, if ever, use these resources as a basis for program development and implementation.

In fact, compatibility, when it is present, usually evolves out of mitigation. The initiative to develop rural areas within a historic resource context does not come from the rural-development program offices but rather from the community or the state historic preservation office. Through an often torturous process of education, officials from the various rural program offices either acquiesce to the community (or state) preference or simply put up bureaucratic obstacles until the pest goes away.

How many of us have called upon public officials and politicians to remove the red tape in order to see worthwhile programs go through? How many of us have inquired about sources of funding only to find out that the Farmers Home Administration, for example, will not fund rehabilitation of older buildings as a matter of policy (probably not written down!)? This, by the way, exerts a double impact on a small (rural) community: 1) it eliminates one opportunity to reuse a building that contributes to the integrity of that village or town; and 2) it reduces and often financially eliminates other options for reuse of the building for at least several years because of the relatively small amount of development that a rural community can absorb over any given period of time.

One need only compare the 1990 U.S. Census data to the results of the NTHP report to understand the extent to which “rural development” is failing. Rural America suffered greater population losses during the 1980s than had been expected; rural-development programs and historic preservation enjoyed the greatest level of cooperation among those rural counties that were experiencing population growth. The point is simply this: rural-development programs are failing to benefit those areas in which the programs are most needed, and those most needy areas usually include important and numerous historic resources.

But rather than attempt to place the blame on others, those of us actively working in the field of historic preservation should look within. Why, twenty-five years after the passage of the National Historic Preservation Act, do we find ourselves continually having to educate policymakers, administrators, and the general public about the socioeconomic benefits of historic preservation?

I am reminded of a recent incident in my home state of Vermont in which the scheduled demolition of a seventy-year-old bungalow- style house was stopped at the eleventh hour by the state Division for Historic Preservation. The property is owned by the state, and the building was being removed to make way for a new courthouse. A newspaper article implied that the division was obstructionist and that the state buildings department official was simply uninformed. However, the Vermont Historic Preservation Act has been on the books since 1975 and reads in part: “An agency, department, division, or commission [of the state of Vermont] shall... consult the Vermont Advisory Council on Historic Preservation before demolishing, altering, or transferring property that is potentially of historical, architectural, archaeological, or cultural significance.” In other words, the state buildings department was in violation of state law! To have the media in a state with one of the most highly regarded historic preservation offices in the national portray the Division for Historic Preservation as the obstructionist party is enormously frustrating sixteen years after passage of our state historic preservation act. In the days and weeks following this incident not one individual or organization spoke out publicly on behalf of the Division for Historic Preservation.

The environmental movement is not much older than the historic preservation movement. Yet it has been far more effective in gaining the support and active involvement of the general public. This includes preservation of land, recycling, waste management, and resource management. What did environmentalists do differently? Education. Environmental issues have been incorporated into elementary-school curricula nationwide. How many parents have school-aged children who gently chastise them when they fail to recycle containers and packaging at home? Unfortunately, the same cannot be said for historic preservation. It is truly extraordinary when one finds even a general architecture appreciation course developed for and taught to elementary school-aged children.

The findings contained in “A Thirst for History” should not surprise any of us. Historic preservation has failed with the fundamentals. We continue, twenty-five years later, to sell our product door to door. The success that historic preservation achieved under the 1981 Economic Recovery Tax Act and the subsequent setback it suffered as a result of the 1986 Tax Reform Act, illustrates and even amplifies our shortcomings as a movement. Historic preservation was mainstreamed between 1981 and 1986 not because the general population was educated about the value of our historic resources to our communities and our quality of life, but because of the financial reward. When the financial reward was taken away, did those people stay involved in historic preservation? Most of them did not. Were they continuing to press state and federal officials (those people responsible for administering rural-development programs) to integrate historic properties into their program plans? Generally speaking, no.

I submit that historic preservationists must redirect their attention. If our historic resources are going to be successfully integrated into community development on an enduring and significant basis, we must first successfully integrate historic preservation into the collective American mind and spirit. Until our children come home from school and tell us about the beauty and value of the “old Queen Anne building on the corner” and how important it is to the integrity of our community, we cannot honestly say that we have succeeded. Nor can we expect state and federal administrators to willingly and actively integrate historic preservation into rural-development programs until they are responding to the overwhelming desires of the communities in which those programs are being implemented. When the message is coming from the general public, rural- development program officials will participate in kind. After all, they probably will have already received the message from their children, or joined the bureaucracy with an introduction and/or academic understanding of historic preservation already on their resume.

TOWNSEND ANDERSON

President
Preservation Investments, Inc.
Middlebury, Vermont

RURAL-DEVELOPMENT AND HISTORIC PRESERVATION

The study entitled “A Thirst for History” was prepared by the National Trust for Historic Preservation at the request of the Senate Appropriations Subcommittee on Agriculture, Rural Development, and Related Agencies, and the Committee on Appropriations with the concurrence and authorization by the Secretary of Agriculture. The study was funded by the Farmers Home Administration. We believe the study will have beneficial results by identifying the status of historic preservation efforts being made in rural areas by local communities and by county, state, and federal programs. The study provides an increased level of awareness of rural historic resources and the need to protect and preserve them.

We were pleased to note that, for all counties visited, the benefits to historic properties from federal rural-development activities outweighed adverse impacts. Within the limits of the study’s scope it recommended additional efforts needed to achieve maximum compatibility between historic preservation and those federal programs. Those additional efforts are related to levels of agency commitment, funding, professional staffing, training, and coordination between federal agencies and state historic preservation officers.

The goals of historic preservation do not inherently conflict with the ultimate goals of the Farmers Home Administration. On a short-term basis, however, some of those recommendations obviously cannot have an equal priority. Within available resources, economic constraints, and the department’s mission as defined by applicable states, we will develop a phased plan to further explore and implement the study’s recommendations as appropriate. We expect that this plan will be the basis of subsequent actions by the department.

The study’s contents and opinions are those of its authors and do not represent the opinions or policy positions of the National Trust for Historic Preservation, the Department of Agriculture, the Farmers Home Administration, or other organizations.

LA VERNE AUSMAN

Administrator
United States Department of Agriculture
Farmers Home Administration

“THIRST FOR HISTORY”: A REVIEW

Any effort to review “A Thirst for History: An Assessment of the Compatibility of Federal Rural Development Programs and Historic Preservation” should probably begin with a comment about the document’s unabridged title. In truth, the title does not fully convey the essence of the report’s subject matter. The report does devote some attention to federally sponsored rural-development programs and how they relate to historic preservation. However, in the broadest sense, the report is really an effort to analyze the degree to which various federal agencies are fulfilling their responsibilities under the National Historic Preservation Act.

The publication of this report corresponds with a great convergence of preservation anniversaries. For example, 1991 marks the centennial of the Forest Reserve Act of 1891, which foreshadowed the creation of the U.S. Forest Service by authorizing the president to establish timber reserves through executive action. Additionally, the National Park Service celebrates its seventy-fifth anniversary this year, while the historic preservation community gears up to observe the twenty-fifth birthday of the National Historic Preservation Act of 1966.

Less attention is being paid to the fact that precisely twenty years have passed since the signing of Executive Order 11593. Congress enacted the National Historic Preservation Act in response to federally sponsored dam building, highway construction, and urban-renewal programs that had resulted in serious harm to the nation’s historic and archaeological resources. By actually implementing the provisions of the National Historic Preservation Act that applied to federal agencies, E.O. 11593 provided the real impetus for these agencies to initiate historic preservation programs. Twenty years later, the time is right for a study like “A Thirst for History” to evaluate the performance of federal agency historic preservation activities.

In spite of the timely release, “A Thirst for History” neither provides a comprehensive assessment of the past twenty years nor suggests radical new directions for federal-agency historic preservation programs to pursue in the future. In fact, readers may have some difficulty discerning the central objective of the report. The project’s Scope of Work specified that the Senate Committee on Appropriations should receive the completed report, but the study contains no clarion call for additional congressional funding. The Executive Summary does contain a listing of “Principal Findings,” but these findings lack the sort of penetrating insight that causes people to sit up and take notice. Additionally, the report’s awkward organization may prevent busy legislators and federal-agency directors from taking the time to discover any valuable messages that may exist within the document.

Although the message remains obscure, those who take the necessary time to explore the study’s considerable contents will reap some rewards for their effort. Readers will find some of the most useful material tucked away in Appendix B. This section contains more than 200 pages of “Program Assessments” that evaluate contemporary historic preservation issues in twenty-three federal programs. Among other things, these assessments discuss the tension between natural and cultural resource management within the National Park Service, the related problems the U.S. Forest Service encounters trying to properly manage historic structures in wilderness areas, and the historic preservation dilemma that the antiquated Mining Law of 1872 poses for the Bureau of Land Management.

Without specifically mentioning E.O. 11593, Appendix B highlights certain contemporary preservation issues that originated with the executive order. For example, E.O. 11593 established July 1,1973, as the deadline by which federal agencies were to have located, inventoried, and nominated all of their properties eligible for listing in the National Register. Today, officials at the Bureau of Land Management, a federal land-management agency with authority over nearly 350 million acres, estimate that comprehensive identification of all historic and archaeological properties on the agency’s land would require the full-time effort of their current historic preservation staff for the next 150 years! This estimate suggests the wild optimism of the executive order deadline. Additionally, the realization that a comprehensive survey of all federal lands will not be achieved anytime soon indicates that alternative approaches are needed for effective cultural resource management.

Appendix B also touches on current federal-agency approaches to determining the eligibility of resources for the National Register. Given the massive work load involved in identifying resources in the field, it is not surprising that agencies sometimes resort to the course of least resistance when it comes to eligibility determinations. This tendency affects the preparation of National Register nominations, a process that many federal agencies choose to avoid. E.O. 11593 established the distinction between properties listed in the National Register versus those that are eligible for listing. Although agencies must consider both listed and eligible properties during project planning, the simplicity of reaching an agreement with a SHPO regarding a property’s eligibility for listing serves as a powerful disincentive to nomination preparation. Appendix B notes, for example, that the U.S. Forest Service has approximately 80,000 properties eligible for listing, but only 450 properties listed in the National Register.

The discrepancy between listed and eligible properties tends to result from the manner in which the Section 106 process drives most federal-agency historic preservation programs. Agency staff must deal with the immediate necessity of complying with Section 106 in the course of granting clearance to federal projects that must abide by a predetermined construction schedule. Time is a critical factor and recent efforts by the National Park Service to streamline the nomination process have not yet counteracted the conventional wisdom that less time is required to reach an eligibility agreement than to prepare a nomination.

Although E.O. 11593 represented a well-in- tended effort to enforce more rigorous federal-agency compliance with the National Historic Preservation Act by requiring agencies to consider both listed and eligible properties when planning development projects, certain present-day consequences remain. For example, the pressure to give pending projects the “green light” means that many eligibility determinations are based on rather superficial information. The resulting data ends up in an obscure file that is not readily retrievable in the future. This leads to an inability to effectively utilize this information to answer research questions and resolve management issues. More importantly, this system frequently defeats the objective of preservation when identified sites are destroyed by the very projects that led to their discovery in the first place.

Who will benefit from reading “A Thirst for History”? Appendix B, in particular, should interest various segments of the professional historic preservation community. State historic preservation office staff members will gravitate toward Appendix B as a way of learning more about the organization and philosophy of some of the federal programs that affect cultural resources in their states. Federal-agency personnel will recognize an opportunity to use Appendix B as a basis for comparing their historic preservation programs with those conducted by other agencies. The staff of the Advisory Council and those working in the cultural resource programs of the National Park Service can use Appendix B to identify federal-agency preservation issues that can be addressed through training efforts or new technical publications.

In truth, Appendix B contains enough valuable information to justify publishing it separately as a stand-alone document. Additionally, the twenty-three federal-program chapters in Appendix B should be divided into separate documents and mailed to the federal preservation officer and director in each of these agencies. The recommendations in each federal-program chapter are sufficiently important that they should be placed in the hands of program managers who have the authority to implement them.

Although this review has devoted considerable attention to Appendix B, this massive report contains a great deal of additional information. However, most readers will probably find that the bulk of the study is less appealing than Appendix B. As mentioned previously, part of the problem results from the fact that the document does not deliver a clear message that has the potential to influence the direction of the nation’s historic preservation program. Furthermore, the report is sprinkled with charts, graphs, program rating systems, and methodological discussions that are too obtuse to offer many revelations. Only by digging deeply will readers discover the strengths within “A Thirst for History.”

BRUCE NOBLE

Federal Program Liason
Preservation Planning Branch
Interagency Resources Division
National Park Service

COMMENTARY ON “A THIRST FOR HISTORY”

The principal findings and recommendations of the United States Department of Agriculture (USDA) study “A Thirst for History: An Assessment of the Compatibility of Federal Rural-Development Programs and Historic Preservation” were right on the mark regarding the Farmers Home Administration (FmHA) Section 515 Rural Rental Housing Program. The 515 program is primarily used to finance new construction in rural areas but has also successfully been used for financing the substantial rehabilitation of historic hotels, hospitals, schools, fire halls, and other buildings into affordable housing. The 515 program was created in 1963 when FmHA, an arm of US- DA, was given the authority to make direct loans at greatly reduced interest rates to developers who would build affordable multifamily housing. In 1974 Congress changed the definition of rural areas from 10,000 in population to 20,000 and also authorized a rental- assistance program that is similar to the Department of Housing and Urban Development’s (HUD) Section 8 Program. Since 1963, the program has financed approximately 450,000 apartment units at a cost of approximately $12 billion. Annual appropriations have never exceeded $1 billion, and most recently have hovered at $510 million.

The organization of FmHA provides for an office in almost every rural county that deals with agricultural financing and the single-family mortgage program. Each state is divided into five or six districts, each staffed by four or five people. In addition to overseeing the county offices, the district offices handle the community facilities and the 515 programs. The district offices receive support and supervision from the state FmHA office, which is headed by the state director, who is appointed by the president. A typical state office will have six or seven staff people who are responsible for all housing programs—usually an architect or engineer, a housing chief, and a multifamily housing coordinator as well as two or three other administrative or support personnel. The national FmHA office in Washington, D.C., provides overall coordination, supervision, and support. There are approximately sixty people in the housing section in Washington.

When a developer initially contacts a district office about pursuing 515 financing for a project, the usual immediate response is to discourage the developer. There are several reasons for this. The first is that there are normally more applications on hand than there are funds available, and adding another application to the process just increases the work load without necessarily providing any more housing. Additionally, if the developer is not experienced with the 515 program, or does not have experience with that particular district office, the office will tend to be concerned about the developer’s ability to perform. It is easier to continue to do business with a developer who has completed several projects and with whom a good working relationship has been already established. These factors are common to government agencies and other organizations, and there is nothing particularly different about FmHA.

The developer who would like to substantially rehabilitate a historic building into housing will often be met with even greater resistance. Most district offices have never been involved in a substantial rehabilitation or in a project involving a historic building. Indeed, there are many states that have never undertaken a substantial rehabilitation project. Therefore the challenge is to persuade the FmHA district and state office to work with you on a historic building. The developer must remember that most 515 projects are one- and two-story buildings and are often located on the edge of a rural community. A historic building, however, is often several stories high and will require an elevator, much more complicated HVAC and life-safety systems, and security systems.

These obstacles can be overcome by convincing FmHA that the developer has experience with the 515 program and/or substantial rehabilitation of historic buildings. When I undertook my first 515 substantial rehab project twelve years ago, I made sure that I hired an architectural firm that had a great deal of experience with government-assisted housing as well as substantial rehabilitation of historic buildings. I also hired a general contractor who had similar experience. The makeup of the development team is extremely important.

It is also very helpful to obtain local support for the project. The first historic project that we did in Wisconsin involved an old school that had been built in 1871 in Black River Falls. The district office happened to be located in the community and there was a great deal of community support for the project. The community leaders were constantly asking the FmHA district office people how the project was coming. I think this placed a lot of pressure on the district office staff to try and make this project work, and, indeed, it has been a very successful project.

Another example of where strong local support made a difference was our experience in Kansas last year. That state had never used the 515 program for a substantial rehab. We had been invited by Arkansas City, Kansas, to substantially rehabilitate the five-story historic Osage Hotel into affordable housing. The city sponsored the first meeting with the district office, doing a very good job of persuading FmHA of the project’s importance to the community and stressing that they had found a developer with a great deal of experience. The district office was also provided with names and telephone numbers of their counterparts in other states where we had worked. The state architect, Nate Ericson, became involved in the early stages. Often the state architect is reluctant to tackle a new type of project and would just as soon stick with new construction. In Ericson’s case, he indicated he was excited about tackling something different and really looked forward to working on the project. This response was similar to that of Jack Neubauer, the North Dakota state architect, who has overseen more historic rehabs under the 515 program than any other state architect.

Several changes could be made by FmHA to encourage development of 515 projects in conjunction with historic buildings. I believe the present FmHA leadership in Washington is supportive of the concept. However, I think there is a need to establish a higher priority to find a champion in the leadership that would promote the 515 program in conjunction with historic rehabilitation. The leadership that is needed is that which was demonstrated by Fred Gengler, FmHA state director in North Dakota in 1979 when the City of Devils Lake wanted to substantially rehabilitate the historic Great Northern Hotel into housing. At the time, FmHA regulations did not allow 515 projects in the central business district. Fred showed great leadership in pursuing this issue at all levels, and we were finally able to get those regulations changed to make the project possible.

I agree with USDA’s “Thirst for History” study that there needs to be more education and training of FmHA staff as to the viability of this type of project. This training should include case studies of successful 515 historic rehab projects showing not only how historic structures can be converted into housing, but also how the location within the community is superior to a site on the edge of town.

There is also a need to remove some of the roadblocks for historic preservation projects in the 515 loan-processing system. At the present time, all such applications have to be sent to Washington. I think this is a good idea if the developer or the state architect has not previously been involved in a historic rehab project. However, this should not be required when the development team and the state architect are experienced with this type of project.

FmHA is currently revising the point system that it uses to determine which 515 projects are funded. If FmHA wanted too show its commitment to the national goal of preserving our heritage, it could award twenty points for projects involving historic buildings.

There has certainly been some progress made during the 1980s in combining the 515 program with preservation of historic buildings. I hope that this concept will blossom in the 1990s.

GARY L. STENSON

MetroPlains Development, Inc.
St. Paul, Minnesota

MEETING THE NEEDS OF THE LOW-INCOME HOMEOWNER

In “A Thirst for History” the National Trust has produced a ground-breaking study that should set an agenda for linking rural-development programs and historic preservation. Yet in the field of low-income rural housing, historic preservation is a strategy with both promise and problems. The Housing Assistance Council and the many housing groups with which we have worked since 1971 share a common goal: decent, safe, and affordable shelter for the rural poor. To achieve that goal, we are interested in whatever works. Sometimes historic preservation and rehabilitation as part of a low-income housing strategy have worked—and at other times they have not been successful, particularly in terms of cost.

Is it possible for rural communities to provide low- and moderate-income housing, restore economic vitality to downtown areas, and preserve historic buildings, all in one package? The nonprofit housing development world’s answer to that question is, “Yes, but it’s tough, if you want to use some of the federal programs that make housing both attractive to capital and affordable to the poor.”

Small towns with a stock of older buildings are obviously not like Chicago, Denver, and New York and do not have the same preservation issues. Rural communities are very unlikely to have gentrifying older downtowns with low-income displacement or older buildings lost to development pressure. Instead many small towns—losing downtown business to regional malls and students to a consolidated school district—have empty buildings with potential for adaptive use as housing. Developers are hardly clamoring to tear down that old hotel, school, or hospital. It’s just sitting there—forlorn, abandoned, and possibly crumbling. It’s a natural for housing conversion, if the economics are right. There is a recipe for this that can be prepared with a number of variations. The basic mix includes low-income housing tax credits (as provided in the Tax Reform Act of 1986), historic rehabilitation tax credits, and subsidized public funding programs such as those of the U.S. Department of Agriculture’s Farmers Home Administration. These and other tools can be used to turn older structures into rental housing for elderly people or families. The result can be new life for historic buildings, decent housing for needy rural people, and economic revitalization for communities. A team effort is needed, with cooperation among builders, syndicators, community groups, and other resources to convert historic buildings into affordable rural housing. Historic schools, hotels, and other types of buildings may be in danger of demolition but have potential as excellent resources for housing. Many rural areas also have a great need for low- and moderate-income housing.

All of that is the theory, and it sounds great as policy. Implementation is more difficult. Consider two projects developed by the Rural Housing Action Corporation of Rochester, New York. (The corporation is the housing arm of Rural Opportunities, a farm-worker and rural-advocacy nonprofit active in several Northeastern states.) In Arendtsville, Pennsylvania, the Rural Housing Action Corporation converted Mountain House, an inn built in 1843, into seven units of low-income housing. The project did not seek listing in the National Register of Historic Places because of the complexities involved, and does not use tax credits or Farmers Home programs. The project was financed by the Pennsylvania Finance Agency and federal Section 8 funds.

In Clifton Springs, New York, the corporation converted an old hospital annex built in the 1860s into a forty-four-unit housing project. This time the organization used both historic rehab and low-income housing tax credits, but it was necessary to hire a special consultant to work almost full-time for a year and a half just on the historic preservation requirements for the project. Eventually the project succeeded, saving a building and serving low-income people. But even the Housing Action Corporation, a very experienced and capable nonprofit, found its resources and patience stretched to the limit. Less-experienced builders shy away from such complications— or fail when they try.

“A Thirst for History” notes that compatibility exists between preservation and rural programs when, for example, “a rural housing program rehabilitates a historic building for elderly housing.” But left unsaid is that in real estate development, especially in a low-in- come project, cost is crucial. Too often historic standards add cost and cause delay. Often the extras are enough to push a project out of low- income affordability. I contend that in a low- income housing project we should consider relaxing the standards slightly in order to make it all work. This should be done only so long as tenant protections are not compromised. But the bottom line is that the preservation and housing communities need to seek some middle ground. They need to get together more. Some strategies might include:

  • Technologies, training, and consultation to help builders with historic restoration and preservation projects;
  • Training and techniques for completing a preservation project at the lowest possible cost;
  • Architectural and engineering advice on how to restore and replace with historic accuracy.

Our mutual goals ought to be to save a building and help a family. The rest is detail. When low-income needs compete with historical correctness, we vote for the people.

MOISES LOZA

Housing Assistance Council

Moises Loza is Executive Director of the Housing Assistance Council (HAC), a Washington, D.C.-based nonprofit organization. Working with community-based housing groups and public agencies, HAC helps create affordable housing in the poorest rural areas by providing seed-money loans, technical assistance, research, information, and training.

COMMENTS ON “A THIRST FOR HISTORY”

The harvest is in and ready to be distributed through the lean months ahead. The National Trust’s contract study for the U.S. Department of Agriculture, “A Thirst for History,” contains a mountain of fodder that will be heavily chewed on for some time: There are some grains of truth, some hard-to-digest chaff—and a few rocks that might break a tooth or two. There are also some missing additives that could have enhanced the yield of this study considerably.

Responding to a 1988 congressional mandate to “conduct an assessment of federal rural-development policy as it affects historic preservation,” USDA’s Farmers Home Administration (FmHA) awarded a contract to the Trust. An assessment strategy was developed that combined local site visits with interview data from federal headquarters and selected local federal-program officers, state preservation officers, and other parties to piece together a picture of the “compatibility” between rural-development programs and historic preservation activity. FmHA requested assistance from a number of agencies and organizations to help FmHA with technical oversight of the study and report, including the Soil Conservation Service, the Forest Service, the National Park Service, the National Conference of State Historic Preservation Officers, the National Preservation Institute, the Conservation Foundation, and the Advisory Council on Historic Preservation. At several points, recommendations were offered on key areas of investigation outlined in the methodology or earlier drafts of the report; unfortunately, not all of these were adopted or pursued by the report’s preparers. I am disappointed to note that a number of these suggestions were not adopted, because some of the problematic material in the report centers around these areas of disagreement.

What are some of the grains of truth contained in the report? First and foremost, I would agree that there is a high potential for mutual compatibility between federal rural- development programs and historic preservation. As the report points out, “Historic preservation can provide rural communities with a mechanism for identifying local resources (including traditional skills and institutions), understanding their economic value, and using these resources to help build long-term economic vitality.” Unfortunately, the report implies that barriers to achieving this compatibility and encouraging protection and use of historic resources are largely a matter of agency program administration and education that can be addressed by agencies internally, with some leadership from USDA. I do not believe this to be the case.

The report’s recommendations fall into four areas: leadership, compliance, training, and funding. Of these, only the funding category includes recommendations for legislative action, and none recommend executive branch leadership from the White House. Funding formulae tied to statutory language may well discourage the use of historic preservation to further rural development; so, too, may levels of appropriations for programs, including the Historic Preservation Fund that helps to fund the state historic preservation office. New programs are not the answer in this case; responsible appropriation levels for existing programs, new allocation formulas, changes in federal-assistance match, and accompanying language on such priorities as historic preservation could help considerably. Passage of new legislation or an executive directive pressing federal agencies and programs to give more serious attention to development/preservation compatibility in general would also be helpful. It is hard to predict where such recommendations may lead, but they need to be made forcefully in an appropriate forum.

As far as the chaff goes, the report correctly notes that there is considerable confusion about precisely what rural-development policy is. I believe that the report’s authors compound this confusion by their imprecise explanation of historic preservation policy. By focusing almost exclusively on one section of the National Historic Preservation Act—Section 106, the so-called federal “compliance” review process—the report virtually ignores other programs and approaches throughout the federal government. Additionally, the authors consistently misunderstand Section 106 and how it is implemented. The study provides few examples of the many innovative approaches combining rural-development needs and historic preservation goals existing throughout the Section 106 process.

The most important thing to note about the Section 106 process, and its governing regulations, is that they collectively establish a framework for planning, consultation, and conflict resolution among concerned parties with the ultimate goal of protection and enhancement of the historic properties at issue. It is the “conflict resolution” end of the process that this study scrutinizes, where the result was often less than fully successful; the report ignores the rest of the process that either successfully disposed of or resolved any conflicts. (For a somewhat different view of rural preservation through the Section 106 microscope, the Advisory Council’s recent “Report to the President and Congress” also focuses on some of these issues.) Of the estimated 100,000 cases that enter the review process through early planning and consultation between federal agencies and state historic preservation officers annually, only approximately 2,000 are submitted for Advisory Council review. Far fewer result in compromises or unresolved conflicts that are truly negative and harmful to historic resource values.

Much of what is missing in the report is any serious discussion of Section 110 of the National Historic Preservation Act, which goes beyond the planning standard embodied in the “take into account” language of Section 106 and directs federal agencies, “consistent with the agencies mission and mandates ... [to] carry out agency programs and projects ... in accordance with the purposes of this Act, and give consideration to programs and projects that will further the purposes of this Act” (16 U.S.C. 470h-2). The National Park Service and the Advisory Council on Historic Preservation jointly published guidelines for implementing Section 110 in 1989 that can provide a basis for assessing agency historic preservation programs and implementation. The report alludes to some of these measures as part of the “agency commitment to historic preservation” (Chapter II), but focuses only on agency historic preservation staffing, general measures of “training” for this staff, and “compliance” as rated by SHPOs in an extremely subjective survey. A valid study of federal-agency commitment to historic preservation, with examination of objective as well as subjective measures of agency performance and positive suggestions for improvement, is long overdue and sorely needed; in attempting to evaluate agencies without such a rigorous study, the report unfortunately is likely to create more animosity toward historic preservation among some federal agencies.

Another particularly hard thing to swallow is the report’s assertion that one dimension of compatibility is where “the historic preservation process may have an adverse effect on selected rural-development program-funded projects.” This measure, while valid in some ways, is also misleading, dangerous, and readily subject to misinterpretation. Insofar as there may be a conflict between historic preservation goals and the specifics of any rural-development program or project, and money or time may be required to identify affected historic resources or deal with them beyond what would have been budgeted for the development project, it is true that historic preservation “regulation” may delay or hamper otherwise worthy rural development. It is not true, however, that all rural-development programs “may be adversely affected by cultural resources.” This kind of characterization can result in the introduction of a legislative waiver from environmental requirements for a given project or program.

The other major item that is missing is any discussion of the historic resources that are the subject and goal of all of this. Report readers need to understand that we are not talking simply about saving nice old barns, an occasional mill, a prehistoric ruin, or a small town post office. There has been considerable preservation emphasis in recent years on the protection of rural landscapes and traditional ways of life, spurred on by the cooperative efforts among the National Park Service, the National Trust, the American Folklore Center of the Library of Congress, state historic preservation offices, and others. The field patterns and stone walls of a New England countryside, the high-timber settlements and logging communities of the Pacific Northwest, or the grain elevators and corn- cribs of the Midwest are an important part of the American heritage and rapidly fading from view. Protecting and preserving them necessarily leads to a discussion of how to protect and preserve the economy and society that created those resources, and continue to use them. This is the sort of collection of resources that the federal government, with its separate and scattered programs, is hardest pressed to be “compatible” with, yet there are some excellent examples of federally supported attempts to do so that need to be recognized and held up as models for emulation. The Trust publication “Saving America’s Countryside” cites some of these examples while focusing on nongovernmental approaches to such problems; some of this information needs to be summarized and disseminated to key government policymakers and decision makers.

Just as the USDA, in a report on rural social and economic structure, pointed out that “rural policies based on an aggregate analysis of rural-development needs cannot accurately reflect the extremely diverse social and economic structure of rural America,” historic preservation policy in broad terms is equally difficult to articulate. Both seek to preserve the various resources of the American countryside. In that sense they are extremely compatible. Where the incompatibility may arise is in the perception that the new will serve needs better than the old; that creating anew is less expensive than revitalizing the old; that many of the resources that historic preservation interests seek to preserve to the seeming detriment of positive, badly needed development are rather arcane and only of value to a narrow “special interest” group; and that the nation’s “thirst for history” can be quenched by a visit to a museum or a national park. There are, unfortunately, some grains of truth in those perceptions. Those of us firmly committed to historic preservation and to balancing historic values with other societal needs must therefore do more to direct the debate toward areas of agreement and mutual goals, and in the process come up with more cost-effective and innovative approaches to achieving those shared objectives with increasingly scarce financial resources.

RONALD D. ANZALONE

Ronald D. Anzalone is Director, Office of Program Review and Education, Advisory Council on Historic Preservation. He served on the technical advisory panel formed by the Famers Home Administration to help oversee the rural study. The opinions expressed are his, and do not necessarily represent the opinions of the Advisory Council on Historic Preservation.

THE AUTHOR’S RESPONSE

As coprincipal investigator and an author of “A Thirst for History,” I am both delighted and honored that so many individuals have taken the time and made the effort to write a response to the report. I am particularly pleased with Senator Burdick’s comments. Through the entire process—from the initial discussion of our original concern to the final report—the senator’s leadership inspired all of us and provided an assurance that we were on the track of something important to the future of rural America.

I am also pleased that three housing professionals have responded to the study based on their experiences. As their comments, taken together, demonstrate, it is possible for low-income programs to use historic buildings, but the task is not easy. Their experiences directly support the report’s finding that avoidance of buildings with the potential to be declared historic is the most likely course of action for many federal program administrators. Preservationists may debate whether their avoidance is based on accurate or inaccurate perceptions, but our research confirmed that the perception is real.

The study will have achieved a major goal if its findings are examined by preservationists and low-income housing professionals alike, and if such findings then lead to new and creative efforts to use historic buildings to meet housing needs. Moises Loza makes it clear that, when he perceives the choice to be between buildings and low-income housing, he will choose to meet the needs of constituents —the rural poor. Preservationists need to understand this and be willing to work creatively with low-income housing interests if our national heritage is not to be the exclusive right of the affluent.

The comments of Mr. Anzalone and Mr. Noble, however, are problematic. Their comments ignore the report’s twelve principal findings and seventeen secondary recommendations. Instead, their criticisms call for what they would like the report to have been, irrespective of the scope and process set forth in the USDA’s Request for Proposals. As explained in the methodology section, research data were limited to what was found in federal and state agency interviews and in twenty- three randomly selected counties. Such a methodological structure ensured that the report was an objective picture of the interactions of historic preservation and federal rural development actually occurring in rural America. The study uses sound sampling and research techniques to present a representative picture of the extent to which compatibility exists between these two important policies. This methodology required that the report not be many of the things Mr. Anzalone and Mr. Noble would like it to be—a comprehensive analysis of federal agency actions or a report of creative preservation efforts, for example. As part of the data collection proves, however, researchers did gather substantial information about agency performance beyond the analysis of compatibility. That information is made available to preservationists in Appendix B. Mr. Noble found this information most useful, and we hope others will do so likewise.

It should be noted that the original proposal by the National Trust for the project was to identify and analyze innovative and exemplary instances of historic preservation and rural development benefitting each other. The RFP, however, turned the focus away from such an analysis and directed it toward providing a representative picture of actual interactions. Such an analysis could be conducted within time and budget constraints only on the basis of a random selection of counties. We believe the report is extremely important. We also again recommend, as noted below, that the best-practices study be initiated.

The criticism that the report does not culminate in a call for additional congressional funding for historic preservation misses the point. As the list of recommendations shows, the report calls for additional funding aimed at specific shortcomings identified through the research. This includes funding for rural heritage incentive programs in federal agencies, increased technical assistance for rural historic preservation, research into techniques for assessing the cumulative impacts of federal programs and projects, and identification and analysis of exemplary projects and best practices.

It would be a great step forward if preservationists would support the need for more funding for rural development from Congress. Preservationists have a great opportunity for building an important alliance and for gaining additional dollars for programs that clearly have an important effect on rural historic resources.

Finally, Mr. Anzalone’s complaints that the report focused almost exclusively on Section 106 and that it limited itself to individual structures at the expense of the broader rural cultural landscape ignore one of the central findings of the research. As the report clearly explains, Section 106 was only one of the four measures of compatibility against which each interaction between historic preservation and rural development was measured. However, only in the federal land-management agencies did we encounter staff who had knowledge or awareness of any federal agency historic preservation responsibility other than Section 106. The report could only set forth and analyze the facts as they were discovered.

Much the same answer must be given to the criticism that the report does not include efforts to preserve cultural landscapes. As stated in the report, the researchers did not encounter individuals in the field, in local communities, or within federal agencies who had the vaguest notion of anything other than a building or an archaeological site as a historic resource (again, with the exception of some of the land-management agencies). Reporting and trying to analyze data that was not, in fact, found would have been contrary to the standards of professional research, regardless of what the researchers would like to have found.

The real significance of the report is that it exists, that it was done as research rather than advocacy, and that it provides preservationists and rural-development staff with a view of what actually is happening, and not happening, in rural counties.

Thus, when the National Trust staff first turned an interested eye to this subject six years ago, the historic preservation community and rural-development community were almost total strangers to each other. Through the commitment of leaders such as Senator Burdick and Jack Walter, congressional staff and National Trust staff were able to identify a problem and an opportunity, to learn about differing federal policies, initiate a process, and create a ground-breaking study.

The result of this is that the report provides an opportunity to look beyond what is supposed to happen and beyond preconceived viewpoints. This clear look at reality provides all of us with the challenge to go beyond the confines of enforcing regulatory compliance and to use this information to modify current operating procedures. In this way, and through creative and innovative leadership, preservationists and rural-development participants, working together, can attain the report’s central finding: that rural development can be enhanced through the use of historic resources.

MARILYN FEDELCHAK

Marilyn Fedelchak is the former director of the Rural Heritage Program of the National Trust for Historic Preservation.

 

(Several agencies and organizations, including the U.S. Postal Service and the National Conference of State Historic Preservation Officers, were invited to write a response, but declined for various reasons.)

The “Thirst for History’’ executive summary is available from the National Trust Rural Heritage Program for $6 including postage and handling. Checks payable to the National Trust for Historic Preservation should be sent to (NOTE: As of 2019, this contact information is outdated.): 

Rural Heritage Program

National Trust for Historic Preservation

1785 Massachusetts Avenue, N.W.

Washington, D.C. 20036

For copies of the full report, contact:

Vernon Rozas

Program Support Staff

Farmers Home Administration

U.S. Department of Agriculture

Washington, D.C. 20250

 

Publication date: November/December 1991


#ForumJournal
#Rural
#development

Author(s):The Honorable Quentin N. Burdick, J. Jackson Walter, Shelley Mastran, Evan I. Debloois, Jay Smithman, Townsend Anderson, La Verne Ausman, Bruce Noble, Gary L. Stenson, Moises Loza, Ronald D. Anzalone, and Marilyn Fedelchak
Volume:5
Issue:6

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