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The Secretary of the Interior`s Standards for Rehabilitation: Warren Cox 

12-09-2015 17:35

The two decades in which George Hartman and I have been practicing architecture have undoubtedly witnessed the greatest preservation movement in history and, as a result, more preservation related architectural projects than in any other time frame. Our projects have included the full range: completely new buildings in historic districts, the incorporation of parts or the whole of existing buildings in new work, additions to historic structures and straight archeological restorations.

By now, I think we have worked on all the various types and tried just about all of the different design approaches, ranging from the totally different and abstract to the replicative and neo-historic. Since both of us have served on design review boards dealing with preservation projects at various times, we have also been on the other side of the fence. We are, therefore (unless we are the designers, of course) sympathetic to the plights of both the architect and the people entrusted with design review.

It has become clear both in the course of our design work and our review board stints that there are two key areas in the Secretary of the Interior`s Standards and Guidelines for Rehabilitation which cause problems: those calling for clear differentiation between existing and new work, and the effective prohibition of historicism.

National Register listings deal fairly well with issues of quantification: what are the contributing buildings in a district or the contributing elements of a building that should be saved. The architect also has the responsibility to do a little bit of homework of his own; that is, to investigate the building`s history for himself. The salient characteristics of an existing building--if it is any good, and it presumably is if it is on the Register--should be respected by the new work. One should use--to quote Alexander Pope--the "genius" of a building or the "genius" of the place to shape the design.

One of the greatest problems with the Department of Interior`s Standards and Guidelines for Rehabilitation is the issue of infill and additions. The Standards say, on the one hand, that if half the front of a building or the historic interiors are blown away it is perfectly fine, given adequate documentation, to replicate them exactly. If, on the other hand, you`re going to replace an element that is missing entirely or put on an addition, you run into problems. In fact, you will not get the tax credits if the new construction replicates or is in the same style as that to which it is connected or what is around it because, the Park Service argues, you cannot then clearly tell the new from the old, stylistically or otherwise.

Stylistic continuation or replication, according to the Park Service, compromises the original and/or confuses the public (as if, for example, the addition could not be differentiated by a label!). In the Apex Building project, the Park Service wanted us to paint the infill additions a different color. This attitude may be more coherent as an ideal or idea than an architectural solution. Is it more destructive to the original monument to have something "sympathetic" (which it really isn`t) and different in style, or to have something which defers to the existing style and scale and therefore supports the original intention?

We did an addition to Monroe Hall, at the University of Virginia which one might call neo-Thomas Jefferson or neo-University of Virginia, because this campus has its own rather interesting and distinctive architectural style. People drive by Monroe Hall and do not realize it has an addition, which we feel is desirable. Everybody seems perfectly happy with our addition, and I am convinced that it was as correct and responsible a thing to do as anything the firm has ever done. I think it absolutely had to be in that style. Of course, had Monroe Hall been a tax act project the Guidelines would have theoretically prohibited what we did. If your project includes infill in a historic neighborhood, the building shall be compatible with the neighborhood, but the building shall not look like any existing building. Well, would somebody please explain to me how you`re supposed to do that? What you get is amply illustrated in the buildings the National Park Service uses to show good and bad examples (see National Park Service Preservation Brief #14: New Exterior Additions to Historic Buildings). More often than not, the architecturally bad work is the ideologically correct example and vice versa. They show the emperor at work.

How the current Guidelines--the Guidelines perhaps in opposition to the Standards--came into existence is worth considering. Where the Standards say "Contemporary design...shall not be discouraged," for example, the Guidelines say that "new design...should be clearly differentiated so that a false historical appearance is not created." They seem to be the result of two things: a carryover of Victorian moral theorizing about architecture--Ruskin and Morris--and the now, in 1988, increasingly discarded belief in cultural and social salvation through "Modern Architecture."

The issue of replication raises an interesting and relevant point, which is: what is modern; what is the Zeitgeist? At the HEB Arsenal project in San Antonio, which was a tax act project, we had a mixture of old and new--contributing and non-contributing structures were demolished. The two primary historic and contributing structures were restored only, but two of the non-contributing and originally characterless buildings were remodeled and added onto to the extent that they are essentially unrecognizable. Then a major new building was added. All of the new and remodeled work is pulled together by a new stylistic kit of parts based on elements particular to the contributing buildings and other historic structures in San Antonio. Clearly, the resulting design is not "modern", but it isn`t Georgian or Neo-Classical, either. Hopefully, it all hangs together. Preservation-related architecture has come a long way in 20 years, and there are now a very few successful and a lot of unsuccessful "modern but (theoretically) sympathetic" additions to look back on. We think they should tell us something about the relative chances for success of this approach when dealing with a major architectural monument. On the other hand, I am not saying it can`t ever be done. One can successfully abstract elements from the existing fabric. Our interior of the addition to the Folger Shakespeare Library is an example. What I want is the opportunity to use either approach when appropriate.

I can`t help but think there were and are architects who want to discourage replication because they are afraid they can`t do it. They learned only one kit of parts in school, "modern parts." They feel they`ll be out of business or feel guilty if they have to try to do anything but "modern." Actually, we have found that designing in a number of different styles just isn`t that hard. Remember, until "Modern Architecture" came along, architects, almost all architects, worked in a variety of styles. It is only recently that architects have become stylistically handicapped.

Precise Guidelines theoretically make the review person`s job easier and quicker. Unfortunately, the first project that comes in is usually the exception that proves the rule. No precise guidelines can forsee all the good or all the bad solutions. So they may stop a truly bad project--which could be stopped anyway--every now and then. How many good projects did they derail? Also, in practice, minimum design standards have a way of becoming the maximum acceptable standard.

Another oddity or contradiction in the Secretary`s Guidelines is that when you put in a new porch or door, it has to fit the existing building, but if you`re doing a big addition, it should be different. Maybe they would be better off reversing that. Maybe you can stand the small, whimsical, abstract change, and it is the big one that kills you.

Sometimes it is better that the addition be clearly different in style, character, whatever; sometimes it should be "sort of" like the original or existing; and sometimes it should be in the same style. If the building you`re dealing with is mediocre, one may be able to do an addition in a vastly different style. On the other hand, if it`s an especially fine building, the chances are that a very faithful continuation of the style may be the most sympathetic, respectful and least disruptive approach. It is a judgment call, both for the architect and the review body. The demands of a district are often different from those of an individual isolated building.

It`s tough to codify such a subjective area. It really must be handled on a case-by-case basis. I (and others) think it is time for the Park Service to reassess the replication and separation issues.

I would like to make two recommendations to the Park Service: First, convene a study group to look at the current Standards and Guidelines. I have been told that they`ve been revised and I know that the pending revisions have been announced in the Federal Register, but that`s not a document that architects or most people spend a great deal of time poring over as bedtime reading. There has to be a much more concerted effort to get all parties together for discussion, and perhaps the National Trust is the natural vehicle for a summit.

Second, I would recommend that the Park Service consider going to a board system for tax act project approval. Having served on a variety of commissions and boards, I have a keen appreciation for how difficult it is on Park Service staff, of how much pressure they`re under in approving or denying certification. Especially if you`re going to write further subjectivity into the Guidelines, I think it will take a lot of pressure off staff to set up boards of professional architectural historians, architects and preservation activists (the usual mix) to handle the approval process. Boards should meet every two weeks to handle the volume of applications the Park Service gets. To ensure participation, pay board members.

The system now in place has served us fairly well, but it basically dates back to the 1970s, with roots as far back as the 1950s. We now have a whole new set of architects practicing an entirely new kind of architecture, and the Secretary`s guidelines should be brought up to date accordingly.

Publication Date: Summer 1988



Author(s):Warren Cox, FAIA