Annual COSCDA Training Conference

CDBG Disaster Recovery:Renovation, Reconstruction, and Renewal of

Historic Properties and Neighborhoods

A. Elizabeth BrummettState Coordinator for Project

ReviewTexas Historical Commission

September 17, 2012

Keys to Successful Section 106 Consultation

• Hire qualified staff to ensure members of the project team are familiar with Section 106 requirements.

• Consider rehabilitation vs. reconstruction. How your program is structured, particularly the “rehab cap,” can have major implications for historic properties.

• Seek partners. Local stakeholders may provide valuable input and creative solutions.

• Think big. When demolition cannot be avoided, mitigation should serve the community and your program.

Keys to Successful Section 106 Consultation

• Hire qualified staff or a preservation consultant to facilitate consultation with the State Historic Preservation Officer

• Determinations of National Register of Historic Places eligibility and effect• Agreement documents and mitigation

• Work with local historic preservation staff and stakeholders• Ensure that your process meshes with local Landmark Commission approvals.• Give stakeholders an early opportunity to be involved, when their input is

meaningful, not after planning has already taken place.• Capitalize on local resources.

Galveston Historical Foundation, Architectural Salvage Warehouse

Consider rehabilitation vs. reconstruction

• The “rehab cap” is the biggest stumbling block in balancing historic preservation with disaster recovery.

• Demolition of a historic property is always an adverse effect, requiring further consultation and potential delays under Section 106.

• Consider using a flexible rehab cap with greater latitude for historic properties.

East End National Historic Landmark District, Galveston

• Tailor work at historic properties to meet the Secretary of the Interior’s Standards for Rehabilitation.

• Follow accepted guidance for historic properties, such as the National Park Service’s Preservation Briefs (www.nps.gov/tps/how-to-preserve/briefs.htm).

• Perform selective, in-kind replacement of damaged materials, rather than full replacement of exterior cladding, windows, or other materials.

• Changing the scope of work to meet the Standards may result in cost savings.

Consider rehabilitation vs. reconstruction

• Rehabilitated home in Beaumont, Texas• Initial scope of work entailed demolition of this residence.• Through negotiation, most work was brought in line with the Standards.

Replacement of historic windows was mitigated by adding wood window screens.

Consider rehabilitation vs. reconstruction

Seek partners and creative solutions

• Relocated home in Beaumont, Texas• Local landmark home donated by the owner to the Beaumont Heritage Society, who

relocated and rehabilitated it. Owner received a new home on her property.• Early involvement of local partners facilitated the creative solution.

Think big for mitigation

Historic American Buildings Survey documentationHenry Rosenberg House, Galveston

• When demolition cannot be avoided, mitigation should serve the community and your program.

• Mitigation is intended to help offset the loss of the historic property.• Documentation is the minimum standard, but consider whether a format other than

HABS is appropriate.

Think big for mitigation

• Large-scale mitigation may serve a broader purpose.• Survey of a historic area can assist with future reviews by confirming National

Register of Historic Places eligibility.• National Register of Historic Places nomination addresses an entire neighborhood

at once, in lieu of individual documentation of properties.

National Register of Historic Places nominationIdylwood neighborhood, Houston

Mitigation for FEMA floodplain buyout program