Forum Journal & Forum Focus

The Secretary of the Interior`s Standards for Rehabilitation: H. Ward Jandl 

12-09-2015 17:35

Over the past 10 years, the Secretary of the Interior`s Standards for Rehabilitation, which comprise one section of the Secretary`s Standards for Historic Preservation Projects, have been widely adopted by state and federal agencies and a number of historic district and planning commissions around the country. Initially developed in 1976 for use by the National Park Service (NPS) and state historic preservation officers in planning, undertaking and supervising Historic Preservation Fund grant-assisted acquisitions and development project work for National Register properties, the Standards have become most commonly associated with the Federal tax incentives program. Over a half million copies of the Standards have been distributed by the Park Service in the past ten years; and the Standards have just been published in the newly expanded, eighth edition of Ramsey and Sleeper`s Architectural Graphic Standards.

Despite a decade of use and seemingly wide acceptance, the Standards continue to receive their share of criticism. Some architectural historians and preservationists contend that the Standards invite greater intervention and change in historic buildings than they should. Some developers and architects claim the Standards are too rigid and discourage creative new uses for old buildings. Ironically, the three times that the Standards have been published for public comment in the Federal Register (1977, 1979, and 1983), few, if any, suggestions for change were made, and the Standards have survived in their current form since 1977.

In 1986, the Park Service sponsored a symposium to focus on the continuing effectiveness of the Standards and to determine whether the basic preservation principles expressed in the Standards are still valid and reasonable in today`s rehabilitation market. Also addressed was the existing language of the Standards and whether there are ambiguities and inconsistencies that need fixing. The symposium served a specific purpose: to assist the NPS in deciding whether after 10 years it was time to make changes to the Standards and what some of these changes might be. Participants included architects in the private sector; local state, and federal officials involved with preservation and design; and developers involved with rehabilitation projects. There was consensus that the Standards have stood the "test of time" remarkably well; in general, participants felt that the intent, purpose and philosophical basis of the Standards was sound. At the same time, all participants had suggestions for improving and clarifying the language of the Standards, and all agreed that the more serious differences in opinion occurred not with the wording, but with the interpretation of the words and how the standards were being applied to actual building around the country.

Later this year a new version of the Standards will be unveiled in the Federal Register, which will contain a number of the suggestions made at the 1986 symposium. It is hoped that publication in the Federal Register will elicit more comments than had been received in previous years.

One of the fundamental issues that we as preservationists have had to confront is the fact the tax incentives program is aimed at rehabilitation rather than restoration. The 1981 law that spurred so much activity was in fact an economic recovery program, designed to channel dollars into American business and industry. Rehabilitation is not the act of recovering the form and details of a property as it appeared at a particular period of time but rather the act of "returning a property to a state of utility...which makes possible an efficient contemporary use. " I suspect that some preservationists would be more comfortable if the incentives were limited to meticulous restorations, but the intent of the law is clear: the revitalization of our cities and towns, not historic preservation per se.

In reviewing some of the projects that the National Park Service has approved over the past decade, it is fair to question whether rehabilitation as a treatment is appropriate for all historic buildings. While many buildings are well suited to rehabilitation and adaptive use, there are historic buildings, like the Frank Lloyd Wright-designed Meyer May House in Grand Rapids, that demand restoration. There are building types, like grain silos and refrigerated warehouses, that cannot readily accept new uses and still maintain their integrity. And yet, because the rehabilitation tax incentives are available to all depreciable historic buildings, we wind up reviewing some problematic cases and having to make some very difficult decisions.

There is not a reviewer in the program who has not had qualms about some of the questionable treatments and interventions that have been approved in the name of "certified rehabilitation": atrium cuts in warehouses, rooftop additions to office buildings, plan changes for townhouses, dropped ceilings, inferior quality replacement windows...the list goes on and on. Because we make decisions on the merits of overall projects, rather than individual treatments, we sometimes settle for less than the optimum.

As reviewers we have concerns about the new uses to which some historic buildings are being put. The great mills of Massachusetts and Rhode Island have become housing for the elderly; their insides have been emptied of machinery and filled with bedrooms, living rooms and corridors; and their sites have been tastefully landscaped with grass, shrubbery and parking. While there may have been little destruction of historic fabric, no one can deny that the gritty character of these factories and warehouses has been irretrievably lost. Perhaps this change is inevitable; today cloth is woven in Hong Kong and shoes are made in Mexico. However, at the very least we should recognize that something important is occurring in the conversion process. Some of our rehabilitations may truly confuse the public perception of what our past was like. For future generations, will their idea of a mill be the place where grandma lives?

Train stations are now upscale shopping malls selling Adidas running shoes, Sharper Image gadgets and Crabtree and Evelyn soaps. The few remaining trains have been relegated to Amshacks on the edge of town. While the architecture of many of these terminals has been preserved--and indeed enhanced--as part of the rehabilitation project, the use without exception has changed. The grand sheds that were the reason for the landmark designation in the first place have been largely reworked--in some cases, they are barely recognizable for what they once were. Clearly, the railroad companies no longer need or want their spectacular stations and terminals; new uses must be found to keep these resources standing. Yet one day we may well regret the severe interventions that were permitted in the name of certified rehabilitation.

Besides issues relating to the new uses to which some historic buildings are being put, there are legitimate worries about the quality of some of the products used in rehabilitation. In the 1970s, we readily accepted anodized aluminum replacement sash in certified rehabilitations. Thanks to intensive awareness-building on the part of state and federal reviewers, and a window industry receptive to the growing preservation market, architects and developers now have a broader range of window products to choose from. In this arena, we have seen positive, tangible results from the Tax Act. Yet additional time, attention and resources need to be directed towards other such products and techniques that unnecessarily damage or destroy historic fabric.

Another legitimate concern is the long-term future of our recently rehabilitated historic resources. The recent change in the tax law points up that when preservation ceases to be profitable, developers -- being prudent businessmen -- will walk away from historic buildings. When the recapture periods are up or when the retroactive passive activity rules kick in, we may begin to see recently renovated buildings come on the market. If the tax credits were needed to attract investors and make the rehabilitation project economically viable, there may be no new takers. In some cases, we may find ourselves back where we started from: with a rapidly deteriorating, empty building. Time will tell whether the rehabilitations of today will continue to be cared for and maintained -- or whether, because of less-than-optimum materials and workmanship, poor marketing or tenant indifference, they will become the slums of tomorrow.

We have all seen articles about the tremendous success of tax incentives in spurring private investment in rehabilitation. The program appears no only in Historic Preservation magazine but also in The Wall Street Journal; it has been awarded a Presidential Design Award; and rehabilitation has appeared on the cover of Time magazine. Certified rehabilitations have created thousands of jobs, contributed to the revitalization of downtowns in hundreds of cities, added millions to the local and state tax base and made historic preservation big business. These articles and awards were the result of the collective efforts of developers and architects and -- at the risk of sounding self-congratulatory -- the individuals at the state and federal levels administering the programs.

The tax certification program and the criteria used to evaluate projects are not perfect: no matter how finely tuned the Standards are, there will continue to be some differences in their interpretation and application from building to building. The program has been a learning experience for everyone involved: for developers who had previously been involved with "gut" rehabilitations; for architects trained only in the design of new buildings; and for reviewers schooled in architectural history and restoration. As a whole, we have learned that the historic character of buildings is expressed not only on the exteriors but also on the interiors. We have learned that the products and resources available for historic rehabilitation work can be improved. We recognize that we are dealing with fragile and irreplaceable resources that demand special care. Together we must continue to seek creative and economically viable solutions to ensure the preservation of older buildings for the next generation.

Publication Date: Summer 1988



Author(s):H. Ward Jandl