Revisions to the Secretary of the Interior's Standards for Rehabilitation
This blog post will be a fast take on proposed revisions to the Secretary of the Interior’s Standards for Rehabilitation. The National Park Service (NPS) is in the process of revising the Secretary of the Interior's Standards. This will be their first revision since 1995. NPS is seeking public input on the revisions. The public comment period ends April 29, 2016. Please find a link to the relevant documents here.
The Secretary of the Interior's Standards and Guidelines for the Treatment of Historic Properties govern acceptable treatment practices for historic properties. There are four sets of standards: rehabilitation, preservation, restoration, and reconstruction. The Standards for Rehabilitation will be the focus of this blog post. The Standards for Rehabilitation are used by NPS, State Historic Preservation Offices (SHPO), and local preservation commissions to review historic tax credit applications, assess adverse effects under Section 106, and award certificates of appropriateness. This blog post will review these standards one-by-one, comparing old to new with my quick takeaways on the revisions as well as how these Standards are often applied. NPS has also prepared more detailed descriptions of the standards, which are worth review. This post will simply look at the standards as written.
Old: A property shall be used for its historic purpose or be placed in a new use that requires minimal change to the defining characteristics of the building and its site and environment.
New: A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.
Standard 1 addresses the proposed new use for a building after rehabilitation. Clearly, it would require the least amount of change were a building to retain its historic use, e.g. an apartment building being rehabbed into a new apartment building. The first question one should ask when pursuing a historic tax credit project is "What new use would be most compatible for this building?". A rehabilitation project shouldn't force an incompatible use into a historic building. This is like fitting a square peg into a round hole. For example, it would be nearly impossible to convert a windowless industrial building into light and airy loft apartments without losing its historic integrity. Similarly, a high-style hotel with decorative plaster and ornate light fixtures will not easily adapt to become an industrial-chic office building with exposed brick and steel beams. The revised Standard 1 above clarifies the existing standard and using new language. "Defining characteristics" becomes "distinctive materials, features, spaces, and spatial relationships." I believe that this is clearer to non-preservation-professionals who are less familiar with preservation terms such as "character-defining features". I also believe that the inclusion of “spatial relationships” is key to our understanding of how easily the interior layout of buildings can be adapted (see Standard 2 for more discussion of this subject).
Old: The historic character of a property shall be retained and preserved. The removal of historic materials or alteration of features and spaces that characterize a property shall be avoided.
New: The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.
Standard 2 suggests that the character-defining features of an old building be preserved. The revised standard replaces “historic” with “distinctive” and adds “spatial relationships” to the list of characteristics. These are key revisions. Oftentimes, property owners doing historic tax credit projects have the misconception that anything original must stay. The phrase “historic materials” may suggest that all original or existing materials and features must be preserved in the rehabilitation, creating a sense of preciousness to what is there. While ideally a project will save as much original material as possible, the real key to a successful rehab project is the retention of “distinctive” characteristics. The other key revision in Standard 2 is the addition of “spatial relationships” to the list of characteristics worth consideration. Spatial relationships would refer to the relationship between features and rooms as well as the organization and flow of the building. Spatial relationships are crucial to our understanding of the original function of a building. For example, the spatial relationships of a historic school are often the most crucial features. Historic schools are typified by wide, double-loaded corridors lined with classrooms, which are often organized around large open rooms such as auditoria and gymnasia. Were the corridors truncated or the rhythm of the classroom doors interrupted, the perception of the school’s original function would be less legible. The integrity of spatial relationships often comes up in review of rehab projects, but it had yet to be clearly codified in the Standards until this revision.
Old: Each property shall be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or architectural elements from other buildings, shall not be undertaken.
New: Each property will be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.
Standard 3 shall, it appears, remain unchanged. The key to Standard 3 is the prohibition on creating a “false sense of history”. This is often a sticking point in historic tax credit projects in which property owners/developers wish to make a building “old looking” even if there is no evidence that a specific feature or material was present originally. For example, oftentimes property owners will want to install a decorative feature, such as elaborate crown molding or a stamped tin ceiling in an old Main Street building because it seems appropriate for a building of that age (it very well might be); however, without any evidence of those two features, installing them would be conjectural and it would be best to install a compatible contemporary ceiling (flat plaster, e.g.). I like to say that we want to avoid “Ye Olde” features and finishes, as in, elements that evoke “old” but which lack authenticity. Without evidence of a particular element, new features and finishes should be compatible and contemporary. New interior partitions should feature base trim that is simple and compatible with the extant original base trim but is distinct from it, for example.
Old: Most properties change over time; those changes that have acquired historic significance in their own right shall be retained and preserved.
New: Changes to a property that have acquired historic significance in their own right will be retained and preserved.
Revisions to Standard 4 are clarifying. All buildings change over time. Some of those changes acquire their own historical significance, especially if those changes occurring during the building or district’s period of significance. Period of significance is the time span during which activities related to the significance of a building or district occur. For example, the period of significance for a donut factory that is significant for its donut-making innovations would be the time period during which donuts were produced, excluding any later uses. If donuts were produced in this building from 1903 to 1947 and tires were produced there from 1948 to 1966, the time span that includes donut production (1903-1947) becomes the period of significance and later uses (tire manufacturing) are not significant and changes made during that time period, even though they may be 50 years old, needn’t be retained for the purposes of rehabilitation. For a good discussion of how buildings change and adapt over time, see Stewart Brand’s seminal work.
Old: Distinctive features, finishes, and construction techniques or examples of craftsmanship that characterize a property shall be preserved.
New: Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.
The only revision to Standard 5 is the addition of “materials” to the list of characteristics which should be retained in a rehabilitation project. One of the overarching goals of this recent revision to the Standards is to address the increasing number of midcentury buildings now considered historic. Many midcentury buildings lack the traditional features of “craftsmanship”, eschewing ornament in favor of a clean, pure, Modern aesthetic. Midcentury buildings are often characterized more by their materials and construction techniques than specific examples of fine craftsmanship in the traditional sense. Many new or new-to-architecture materials, such as enameled steel or aluminum, plastics in various applications, laminate, asphalt tiles, and lightweight concrete became popular and character-defining features of Modern architecture. Many of these materials make the characteristic forms of the Modern Movement physically possible, such as the ability of lightweight concrete to form parabolic roofs. In short, Standard 5 suggests that distinctive characteristics of a building should be preserved and the new revisions broaden the scope of what may be defined as distinctive.
Old: Deteriorated historic features shall be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature shall match the old in design, color, texture, and other visual qualities and, where possible, materials. Replacement of missing features shall be substantiated by documentary, physical, or pictorial evidence.
New: Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.
Standard 6 features a couple of small revisions. The fuzzy phrase “other visual qualities” is removed from the list of characteristics which a replacement much match. Additionally, the revised Standard emphasizes that replacement of deteriorated features should be substantiated by “documentary and physical evidence”, removing “pictorial” evidence as sufficient. Furthermore, the revised Standard asks for both physical and documentary evidence, rather than using “or” in the phrase. This suggests to me that, in order to justify the removal and replacement of deteriorated historic features, extensive evidence, beyond just photographs, is required. This may mean that, for example, a window restoration expert prepare a windows survey and report documenting specifically that windows cannot be repaired. Under the old Standard, sometimes photographic evidence was sufficient to document the need for replacement. The revision of Standard 6 holds the property owner/developer and consultant to a higher level of scrutiny.
Old: Chemical or physical treatments, such as sandblasting, that cause damage to historic materials shall not be used. The surface cleaning of structures, if appropriate, shall be undertaken using the gentlest means possible.
New: Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used.
Standard 7 is simplified in its revision. Rather than providing specific examples of inappropriate treatment (“sandblasting”), the Standard is made broader in an effort to prohibit any treatment that damages historic materials. Since different materials require different care, this revision means that treatment measures should be addressed on a case-by-case basis in order to ensure that historic materials are not damaged.
Old: Significant archeological resources affected by a project shall be protected and preserved. If such resources must be disturbed, mitigation measures shall be undertaken.
New: Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.
Archeological resources must always be protected if they are uncovered or suspected, though we rarely come across them in most historic tax credit projects. It is worth reaching out to the State Historic Preservation Office if you suspect or uncover any below ground resources. Standard 8 revisions simply remove the qualifier “significant”, thereby broadening the definition of what archeological resources warrant protection and sensitivity. Decisions regarding significance ought to be left to professional archeologists.
Old: New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property. The new work shall be differentiated from the old and shall be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment.
New: New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.
Standard 9 is one of the most frequently cited Standards for historic tax credit projects because of the frequency with which additions, alterations, and related new construction are part of the rehab projects. Revisions to Standard 9 add to the list of characteristics that should not be destroyed in the process of making additions or alterations. No only do historic materials warrant protection, but also “features and spatial relationships”. The revision also rephrases the differentiated and compatible phrase regarding new construction. As alluded to in Standard 3, all efforts should be made to mitigate damage to historic features while at the same time new features and construction should be compatible and contemporary.
Old: New additions and adjacent or related new construction shall be undertaken in such a manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
New: New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
Standard 10 remains as it was after revisions. In essence, Standard 10 states that the historic building should remain intact beneath any new additions.
My takeaway from these revisions is generally positive. It seems to me that the Standards have been updated, clarified, and simplified. Some Standards now have a broader reach in order to be more flexible for the vast variety of buildings in the nation as well as to accommodate Modern Movement architecture. I look forward to seeing the completed revisions and new illustrated guides.