Are AI The Sea Peoples?
Remember in the olden days for doctor’s visits you had to fill out all of these forms 15 minutes before the appointment and then fill them out again and then repeat them verbally after that? Thanks to technological advances, it now takes 30 minutes to fill out the same forms the same number of times because you also have to download two apps and create two passwords and four identity queries only to have the doctor tell you to lay off the technology because you have carpal tunnel syndrome.
Oh, and then they want you to fill out a survey. The process is demonstrably slower thanks to technology. That’s not precisely true – it is demonstrably slower because of all the ads and popups and other digital demons trying to monetize the technology. And then there is the technology trying to monetize itself by creating unnecessary layers. I get to update this website in WordPress, but with another website I work on, it was constructed in WordPress with another app called Elementor that someone got someone to pay for because it did something that the original app didn’t do and now we are back to 30 minutes for a 15 minute task.
There is so much sludge on the internet now that opening links takes forever – I was trying to register for a conference and by the time the form came up there were three because I must have hit the button three times in my impatience. Here’s my favorite: If you ever try to look at once of these listicles on Ranker or Weird History you better be sure that the list is no more than 12 items long, because otherwise the endless hulking sludge of ads will kill the listicle before you ever get to Number 13, leaving you with a whiteout screen with nothing on it. Only way out of the whiteout is to quit the app and reboot.
I think Odysseus was surfing the web rather than the Aegean and Tyrrhenian because he got whacked by more popups than my YouTube account. He goes from the 15 minute task pre-AI to the 30 minute task post-AI to 10 years getting from Troy to Ithaca without even visiting Saratoga Springs. At least at the movie theater all the ads were before the movie.
And since Odysseus the movie had a minutelong scandal a couple weeks back, here is my take:
As a historian, I am sometimes critical of movies that are replete with anachronisms (Braveheart) but on other occasions (Elizabeth and Marie Antoinette) they aren’t true to historical events but they somehow manage to capture the essence of the historical figure. So, I am not a purist, and I am less likely to be a purist about a lengthy lyric transmitted orally for five hundred years. The tiny fragment from the third century BC currently on display in New York City has three lines that aren’t in the standard text, so we are not dealing with hard evidence here. I do agree that Nolan removed the humor (and most of the sex) from the lyric, but he didn’t pervert or subvert the essence of the story. (also John Leguizamo steals everything he is in.). He also avoided a surprising amount of CGI, like in the Giants scene where he used actual people tall and short.
The Odyssey is set at the beginning of the Bronze Age collapse, caused by the ill-defined “Sea Peoples” referenced in the movie, which leads me to posit: AI are the Sea Peoples of today. AI are doing their best to precipitate our collapse through misinformation and the pandemic of endless mediocrity. Not to mention making everything take longer and go slower.
Now, if this is a parallel to the Bronze Age collapse, we should have first seen the collapse of the palatial economies and ensuing diaspora of craftspersons and landscapers. But the damn McMansions are still there with their armies of workers. Everywhere.
Nowadays we have a very visible ultrarich predator class, which would seem to parallel the Bronze Age rulers on their own private islands throughout the Aegean and Mediterranean, and, indeed, private islands are a thing. But their economic collapse has not happened. Granted, the predator class has seized power and is trying desperately to win a culture war by making everything dumber and gaudier.
And more boring. AI will like totally try to sell you the most popular thing even when you instruct it otherwise, because it is impressed ONLY be quantities of data. Not by quality. Quality can be singular and special and lonely, which is the opposite of a big dataset. So, I asked AI for “museums that only had a few objects.” AI gave me “tiny museums” like the Mmuseumm in New York which is an elevator shaft full of ordinary objects. I corrected its error and AI was very apologetic, acknowledged I was correct and then came up with a couple museums in the UK. So I had to prompt AI for a third time, telling it to look in Japan. It finally came up with the Teshima and Chichu, which is what I was looking for. It also corrected me that the Miho (below) actually has a large collection, even though it only displays a small number of items. So, three for me, one for AI.
Ok that AI adventure was a bit of a slog – hard to get away from the stuff that is highly advertised and thus a bigger dataset. I mean you could fix that, but that is not necessarily in the interest of the predator class – they need you dumb. And they need you to think AI graphics look good. If I was 13, I would think they look good. If I was a gamer, I would think they look like game graphics, which have a cachet. So, a contemporary counterpart of the Bronze Age collapse – a dumbing down of culture – does seem plausible.
Teshima art museum – home to one artwork. The artwork is also made of water. Like AI is. But less water.
Just learned today that AI can manage country and pop songs, but is a complete disaster with Baroque counterpoint. I guess music isn’t math after all…
AI Slop
The phrase “AI Slop” is already commonplace, and it inspires me to invent more neologisms like “Cry me a data center” or “Grok willing and the creek don’t pop-up”. I have written all 670 blogs over the last two decades without AI, or have I? I am a late-adopter with Post Technology Stress Disorder and you can see that in my blogs from the aughty-aughts. Heck, you can see it from a couple of months ago when I ranted about how real retail service companies cannot ever, ever change an old email or recognize a different phone number, no matter who is dead. And they are willing to give up months of revenue just to carry that rotting corpse further.
So what do I think of AI? My first reaction to AI writing was that it was like a 14-year-old who has been asked to turn in a three-page essay but only has one page of material. Repetitive. You see it in tons of social media posts which look like proper long-form discussions but hammer the emotional hinge of the story like six times in 400 words. That is the written version of the AI image that has the wrong number of fingers or arms. Of course, both of those examples are a year old so I suppose by now AI is like 15 and knows how to draw hands better.
This is a real life photo from 12 years ago no AI.
I have attended one workshop and one training in AI in the last 24 hours so here is what I learned, mostly from Huy Pham and Paul Kim, whom I first saw present on this issue almost a year ago in Arkansas.
AI is a marketing term for the latest iterations of pattern recognition technology. Basically it looks at large amounts of data and identifies patterns and recurring themes. So, like you learned in computer science 40 years ago – GIGO. Garbage in, garbage out. Huy and Paul work for APIAHiP (Asian and Pacific Islander Americans in Historic Preservation) and if they ask AI about Asian sites in the National Register of Historic Places and if AI looks at all 100,000 nominations and sees less than 1% it will tell you basically NO. There aren’t any. Not significant. Not important.
Since AI is basically pattern recognition, everything it produces will tend toward the mean, the median, the average and ordinary. It is not a place to look for exceptionalism or new ideas. Culturally, it has a flattening effect. What is new about it in the last few years – as opposed to the pattern recognition software of 20 and 30 years ago – is the Large Language Model. Basically you give it tonnes more examples. So it gets even meaner. It cannot provide conclusions, only predictions. It reflects what is common, not what is true. Garbage in, garbage out.
I guess I’m not a big fan
If you want the National Register of Historic Places to identify underrepresented stories, you need to do it yourself, because it requires not lots and lots of old data, but a new approach. You need to reconceptualize the process, which is not something in AI’s wheelhouse. Garbage in, garbage out.
“Hallucinations,” however, are in AI’s wheelhouse. They will confidently answer a nonsense question like “Who won the Nobel Prize in Economics in 1956?” and even provide fake citations from nonexistent journals, as we have seen recently. It seems the AI doesn’t know how to say “I don’t know” which is a prerequisite of real intelligence. It eagerly answers queries because – like the 14 year old – it can’t not. Even if it is hallucinating.
If you get the “Nobel Prize in Economics,” you will get it here, in Stockholm, but it will actually say Sveriges Riksbank Prize in Economic Sciences in Memory of Alfred Nobel, and it only began in 1969. Four of the five original Nobel prizes are also delivered in Stockholm under the terms of Alfred Nobel’s 1895 will, with the Peace Prize awarded in Oslo.
Presents predictions as conclusions. Repeats what is common rather than what is true. Hallucinates.
No wonder the predator class and the oligarchy are so enamored of it.
More microdosing and unlocked tranches than Sand Hill Road.
So, does AI work with historic preservation? I have always said that the beauty of historic preservation is that it treats every resource as an individual, with individual characteristics and individual significance that cannot be commodified. Zoning treats properties as a category, like grain being graded and loaded into a silo. It becomes a commodity sans terroir. Pattern recognition technology might be suited for zoning or other commodifying tasks, but telling the story of a place is specific and nonfungible.
Terroir.
So, to answer the question: AI can help if you need to find out how many 1926-29 Tudor Revival houses in the Monte Vista district have casement windows or how many National Historic Landmarks are shaped like elephants.
But if you are nominating a site with a story that has not been heard before – AI doesn’t know. Because it hasn’t been told. And it doesn’t know what it doesn’t know.
Why doesn’t someone get AI to do the dishes or wash the floor? Something useful, you know?
106 under attack
I have regularly taught on online one-hour course for public officials on how to navigate Section 106 of the National Historic Preservation Act of 1966. Section 106 is a consultation process that reviews federal undertakings for their effect on historic resources. This makes it a regulation, so knuckle-dragging mouth-breathers with no knack for capitalism think of it as an obstacle. Skilled practitioners recognize it as a way to find solutions that satisfy constituents and guarantee return.
There is no law that prevents demolition of landmarks. Full stop. There are only laws that make it more difficult. But not impossible. In my class I share the story of the USPS in 1991 which decided to tear down a Daniel Burnham building. They knew how Section 106 worked, and that a federal agency can always out-wait the process and tear down the building. So they did.
This is when I was out standing in my field.
The virtue of Section 106 is that it may take time, but it saves lawsuits and conflicts that come afterwards. This week, the Advisory Council on Historic Preservation is proposing eliminating this consensus-building process, presumably at the behest of the aforesaid Neanderthal-adjacent. The National Trust for Historic Preservation has publically opposed the move, as has the National Preservation Partners Network. Here is our statement.
Position Statement: Opposition to Proposed Changes to Section 106 of the National Historic Preservation Act
Issued: July 23, 2026
Who We Are
The National Preservation Partners Network (NPPN) is a coalition of statewide and local preservation organizations and preservation professionals working alongside State Historic Preservation Offices, Certified Local Governments, and Tribal partners to protect historic and cultural places in communities across the country. Our members work directly with the Section 106 process on a daily basis — advising project sponsors, sitting at the consultation table, and helping communities and federal agencies reach outcomes that work for everyone. We offer this statement as practitioners with on-the-ground experience with the process.
Summary
The existing Section 106 process reduces conflict, identifies problems early, creates predictable outcomes, and avoids costly litigation. It is a process that works — not despite its consultation requirements, but because of them. The National Preservation Partners Network (NPPN) therefore opposes the draft rewrite of 36 C.F.R. Part 800 — the regulations implementing Section 106 of the National Historic Preservation Act (NHPA) — that was circulated by the Vice Chairman of the Advisory Council on Historic Preservation (ACHP) on July 17, 2026, for an expedited Council vote by July 24, 2026. NPPN urges the ACHP to withdraw the draft, restore the deliberative process it previously committed to, and preserve the collaborative consultation framework that has worked for sixty years.
Statement of Position
NPPN believes the proposed rule, both in the manner of its introduction and in its substance, is an unwarranted departure from the collaborative, multi-party consultation model that Congress established when it enacted the NHPA. NPPN calls on the ACHP to:
- Withdraw the current draft and restore the previously adopted 30/60-day process for developing and reviewing any revisions to Part 800.
- Reject an unassembled, one-week vote on a rule of this magnitude, and instead ensure Council deliberation occurs in a transparent, recorded public forum.
- Preserve the core consultative structure of Section 106 rather than replacing it with a model of unilateral agency control.
- Engage Tribal Nations through genuine government-to-government consultation on any changes affecting places of religious and cultural significance.
- Engage with the broader preservation community and the public in order to improve the Section 106 process without endangering or destroying historic places.
Background
For six decades, Section 106 has required federal agencies to identify historic properties, consult with State Historic Preservation Officers (SHPOs), Tribal Historic Preservation Officers (THPOs), Tribal Nations, local governments, and other interested parties, and consider alternatives before undertakings that affect historic properties move forward. It has never functioned as a veto over federal projects; rather, it has provided a structured process for balancing infrastructure, energy, housing, broadband, and disaster-recovery needs against the preservation of the nation’s irreplaceable historic and cultural resources.
Earlier this year, the ACHP adopted a resolution directing its staff to develop a public timeline for revising Part 800 within 30 days and to give Council members 60 days to submit comments before any regulatory action proceeded. That process was never completed. Instead, on the afternoon of Friday, July 17, 2026, the Vice Chairman distributed a nearly complete rewrite of the regulations and asked Council members to cast an unassembled, email-based vote within one week — abandoning the process the Council itself had adopted. The Council set a deadline of Friday, July 24, 2026, for that vote; the National Trust for Historic Preservation, a Council member, has already voted no. If approved, the draft would move to the Office of Information and Regulatory Affairs (OIRA) for review before publication in the Federal Register, triggering a 30-day public comment period.
Why Section 106 Benefits Everyone — Not Just Preservationists
Section 106 is not an obstacle that pits preservation against progress. In practice, it does the opposite. Section 106 works because it creates better projects: earlier identification of issues, fewer late-stage surprises, negotiated solutions, greater public confidence in federal decision-making, lower litigation risk, and greater certainty for project sponsors. Federal agencies, applicants, local governments, Tribal Nations, and the public all rely on the same process to get to “yes” on projects that serve infrastructure, energy, housing, and disaster-recovery needs. Weakening that process does not make federal projects move faster or cost less — it removes the mechanism that prevents costly conflicts and litigation from happening.
Key Concerns with the Proposed Rule
A shift from consultation to unilateral agency control. The draft replaces the collaborative consultation process with a single Section 106 report prepared by the federal agency, which would then be circulated for comment. SHPOs, THPOs, Tribes, local governments, and other consulting parties would react to a completed agency analysis rather than helping shape it — removing a substantive planning process. Agencies would decide unilaterally whether competing priorities, such as budget and schedule, outweigh historic preservation concerns.
Narrowed participation. Local governments and Certified Local Governments would no longer be entitled to consult, and preservation organizations and members of the public would lose recognized status. Public involvement becomes discretionary, with agencies deciding whether public input is worth the time and cost. Collaborative, negotiated solutions are lost.
Broad new exclusions from review. The proposal would exempt whole categories of projects — including state- or locally administered federal programs, actions involving minimal federal funding or control, and projects carried out under delegated authority. It would align many NEPA exclusions with Section 106, removing review of projects that currently receive it.
A narrowed definition of “effect.” The draft limits adverse effects to those that are foreseeable, closely tied to the undertaking, and involve material physical alteration. This curtails consideration of setting, visual impacts, and other indirect effects, and raising serious questions about how places of Tribal religious and cultural significance would be protected.
A narrowed definition of “historic property.” The proposal excludes certain cultural landscapes — mountains, valleys, and ethnographic landscapes — from protection. Combined with the loss of Traditional Cultural Landscape protections and the elimination of “avoidance, minimization, and mitigation” as an operating standard, these changes will reduce protection for Tribal sacred sites and Traditional Cultural Properties and disregard practical, positive alternatives that preservation review makes possible.
Mitigation becomes optional. The current process encourages negotiated Memoranda of Agreement among consulting parties. The proposed rule makes Memoranda of Agreement optional and allows agencies to make unilateral decisions without the agreement of consulting parties, likely leading to conflict.
Legal vulnerability and more delay, not less. The proposed regulations contradict both the National Historic Preservation Act and ACHP’s own rules and procedures. The internally inconsistent draft contains many errors, inviting regulatory confusion. Stripped of the well-established consultation process that has long produced negotiated, durable outcomes, agencies and applicants should expect more legal challenges and delays, not less — undermining the efficiency the proposal claims.
The draft is a complete rewrite that places decision-making authority in the very agency proposing the undertaking. It discards the independent expertise SHPOs, THPOs, Tribal Nations, local governments, and the public bring to federal decisions. Under the narrowed definition of “historic property,” federal agencies would no longer be required to take into account adverse effects to significant cultural landscapes like the Grand Canyon.
Call to Action
NPPN encourages its members and the broader preservation community to:
- Track the rulemaking closely and prepare to submit substantive comments once the rule is published in the Federal Register.
- Contact their Members of Congress to express concern about the proposed rule and the process by which it was introduced.
- Contact State Historic Preservation Officers, Tribal Historic Preservation Officers, and state and local elected officials to coordinate a unified response.
- Submit written comments during the forthcoming public comment period via regulations.gov once the docket number is available.
Conclusion
Section 106 has succeeded for nearly sixty years not despite its consultation requirements, but because of them. NPPN urges the ACHP to reject an accelerated, closed-door process for rewriting regulations and to engage the full preservation community — Tribes, SHPOs, local governments, preservation organizations, and the public — to uphold, rather than dismantle, Congress’s intent in enacting the National Historic Preservation Act.
NPPN’s opposition to this draft is not opposition to reform. NPPN stands ready to participate in a collaborative review of Part 800 that improves efficiency, provides greater clarity, reduces delay, maintains consultation, honors Tribal sovereignty, preserves public participation, and fulfills Congressional intent. We welcome the opportunity to work with the ACHP to that end.
Sources: Cultural Heritage Partners, “War Room for Threats to Section 106” (July 2026); National Conference of State Historic Preservation Officers, “The End of Section 106 as We Know It?” (July 20, 2026); Arizona Preservation Foundation, “ACHP Proposes New Federal Regulations that Devastate Protections for Historic Properties” (July 2026); National Alliance of Preservation Commissions, member advisory on proposed Section 106 regulatory changes (July 2026); National Trust for Historic Preservation, “Section 106 Is Under Threat: What You Need To Know” (July 2026).
The world economy rests on a dead cell phone
Ah, the joy of two-step verification! I have just spent an hour unsuccessfully trying to log in to my business Amazon account, all because COMMERCE is dependent on a dead cell phone. No use trying to call customer service, for they will insist on sending a text to the dead cell phone. You will not be able to sign in online, because the account does not have a number (well, it does, but it is not used for anything). It does, however, have a cell number. If that cell phone is lost, dead, deleted or no longer employed, you have now successfully exited the economy.
Now, I did speak to a very nice gentleman who understood my problem before putting me on silent hold for 20 minutes. The website shows you how you can update your account information, but only AFTER you have signed in, which means you still need that cell phone. You cannot sign in without it. All of the online customer service is similarly dependent in its entirety on that dead cell phone and the ethereal unrequited beauty of two-step verification.
What happens to the phone that gets flushed? The employee who retires? There was briefly an option to have them call a landline instead of texting a cell, but the algorithm resists that option with a ferocity that would make Longshanks blush. Then, just to make sure you are defeated, they make you wait before sending another code, by which time it is too late. Code by Kafka, I guess.
We shouldn’t be giving Amazon custom anyway, but I did try. And it isn’t just them. Every vendor in the world rests their entire customer relationship on a single cell phone number. That number can only be changed/edited if it is still working! It is like a massive inverted pyramid of relationships and transactions and accounts and credit cards, none of which can function without the dead cell phone being reanimated.
I can’t even turn on my work computer without two-step verification. I need my cell phone. I have used two-step verification for years when teaching at the local Uni, so I know how to do it. The challenge at work is that business accounts are similarly dependent on personal cell phones. You call the Amazon help line – from a landline – and the automated voice asks to send you a text. It does not give you any other option. If that old line is long gone, so is your account. All of the ways to recover the account will require that cell phone.
This seems a strange and fragile way to run an economy.
APRIL UPDATE: I learned this week that when they drain the San Antonio Riverwalk every two years, they find about 500 cell phones. That’s a lot of business not getting paid. Wonder how many cell phones are lying in the Strait of Hormuz rn?
Oh, and just went through this with AT & T – we wanted to make sure the issue – which caused a TWO MONTH ABSENCE OF SERVICE – did not happen again, so we closed the old account and opened a brand new one. We made sure no personal cell phones were involved, so we could prevent this clusterfracas from happening again. No dice. Neither Apple nor AT & T will allow a business to be a business – it needs to be some individual’s phone. And they were willing to lose two months of custom just to maintain this silly, flimsy system. I would say bring back the party line, but Que será, será.
Section 106 of the National Historic Preservation Act
Last week the Advisory Council on Historic Preservation put out a call for review of the Section 106 process. What is Section 106? Well, it is basically the federal review process for properties listed on (or eligible for) the National Register of Historic Places. I have taught this process to public officials for decades, and I have been party to the process in many cases, including several projects here in San Antonio.
Foundations of 1875 St. James AME Church as uncovered in 2020. Below is the result of the Section 106 process, completed 2022.
In a time characterized by assaults on civil institutions small and large, a “review” of this process, which has existed in some form for nearly 60 years, is cause for concern. Section 106 is a type of regulation, and regulations are often categorically opposed by self-styled populist politicians and struggling subpar businesspersons. The nuanced reality is that any consultative process will tend to improve outcomes.
With the notable exception of the Milton Historical Society, a Section 106 review that was a perfect storm of bad outcomes. I was hired by the National Trust to figure out what went wrong here 20 years ago. Architect, client, and agency were all at fault. In that order.
Almost a year ago, the Executive began trying to get around regulations like Section 106 through imaginary energy crises, military readiness, and other performative red herrings. Heck, they even demolished a federal building illegally (and of course performatively, without a long-range plan – see my blog about it). But this is not to put Section 106 under one political banner, because in 2024 Section 106 was being challenged as an impediment not to knuckle-dragging capitalists, but to progressive causes like climate change and renewable energy. And bike lanes. I blogged about it here.
There is also an exception being drawn up for military housing, which makes sense intuitively.
Well of course I’m going to pick an architecturally significant example of military housing.
Your intuition is not wrong, but it has no context. The context is that military housing is like all things military – it never has to justify its budget. That means that the housing got “improved” regularly in the 1950s and 1960s and 1970s. That means it has lots of layers added, with each having the potential to become a unique mold biome. And of course those of us involved in actual Section 106 reviews in a city with lots of military bases knows that this has been an issue for more than a decade. Not new.
Tile looks 1930 but that sink looks scallopped in the awful 80s.
Here is how Section 106 works:
1. There is a federal project. This could be obvious, like a highway or a building, or it could be a permit from the Army Corps of Engineers to build along a navigable waterway.
2. There is – or is not – a historic resource.
3. There is – or is not – an effect on that resource.
4. If there is an adverse effect, you oughta try to do something about it.
5. If nothing can be done, you go ahead anyway.
Here is one of my favorite results – the Solomonic baby sliced in half:
The LITERAL bottom line in the process is that the project can proceed, something the Post Office knew back in 1991 when the above article appeared. They knew they could tear it down after they went through the process. (BTW photo proves that I was out standing in my field).
Or you can just repackage the project into different phases that do not engage Section 106 as much.
At her request, I spoke to National Trust for Historic Preservation CEO Carol Quillen last summer about this issue and what should be done. After all, Section 106 has not been revised in over two decades. The conclusion I shared with her is the same I reached years ago in the effort to get the National Register of Historic Places to reflect the diversity of American history. The issue is rarely the law or regulation itself, but the practice of its implementation.
Ah yes, Federal Building West. We encouraged them NOT to worry about the original 1974 bathroom in the basement.
As with many current initiatives from the federal government, it appears that they are trying to solve a problem that doesn’t exist. In over 40 years of dealing with historic preservation review at the federal, state and local level, I have consistently seen that at least 97 percent of reviews are dispatched in a few days. My friend and Washington State SHPO Allyson Brooks provided statistics from last year. They did 5,371 reviews with a response time of 3.7 days. 45 of the projects were “adverse affects”. It could be that there is not a problem, or perhaps there is that one guy with a problem who wants to make everyone pay for it.
Moreover, most federal agencies have executed Programmatic Agreements that essentially resolve potential Section 106 issues in advance, and provide an agency-specific and resource-specific process for dealing with the rules in a more streamlined way. But that doesn’t play well in a media landscape designed for third graders.
Our National Historic Landmark army base is a decade older than Fort Sheridan in Chicago.
So what specifically is the ACHP looking to review?
1. Defining the undertaking and establishing the area of potential effects
I suppose this is to fend off surprises by limiting the scope of the undertaking. The old newspaper clipping above is a case where the new building did not require the demolition of the old building per se. It’s just that, in order to stage the construction of the new building, the old one had to go.
2. Assessing indirect and cumulative effects
I guess this is to try to limit the review to immediate effects rather than long-term or indirect ones. I can’t imagine this affects a large number of cases. One of the interesting ones I witnessed – which was resolved by the Advisory Council in favor of the military, was the issue of cutting trees at the 1930 Randolph Air Force Base. The Air Force wanted to cut down trees to limit bird strikes, and the SHPO wanted them to keep original trees. The Air Force won, and yes, it took a while.
3. Managing review/scope of review for long linear projects with limited federal involvement
This could be for projects like San Pedro Creek or Brackenridge Park that are primarily projects of state and local agencies and the federal role is a permit. Again, Programmatic Agreements can help with this.
4. Managing timelines for review.
Yeah, well that would be good. In fact, this is the big one. European countries have more stringent regulations than we do, and their businesses are used to going through the process. It must be worse there, right? No. See, they have a process which has an endpoint. The US has so many lawyers that projects can get tied up forever not by the regulations, but the ancillary and attendant lawsuits. There is no endpoint in a litigious environment. That doesn’t happen in Europe.
They are better at trains too
You can tweak the regulations all you want, but unless someone sets an example of NOT filing frivolous lawsuits, the timelines will get longer not matter how short the laws are. Anyone know anyone who could set such a noble example? Bueller? Bueller?
My prediction is that the review will cause more problems than it solves. If you go digging into a legal process that is slow 3% of the time, you will reduce the quality of outcomes at the very least, and likely harm that high-performing ratio.
JULY UPDATE
Well, the Advisory Council has flouted its own process, in order to flout the process. Like a suicide bomber! See my latest blog and the preservation community response.
Ease of movement
One could argue that the whole of human history is a journey toward ease of commerce and communication with hydraulics on the side. Roman roads and aqueducts remain two millennia later to underscore their importance to that empire. Endless layers of burnt and polished lime forming walkways still snake through the Guatemalan jungle as testimony to the communications link of the Classical Maya. The Tayrona of Colombia’s Sierra Nevada de Santa Marta built arguably too many stone walkways in an attempt to maintain commerce and communication in the obtusely moist and mountainous high jungle. The incomparable monuments of Angkor existed only because of the massive barays that held the water that made civilization possible. I suppose you could add the US interstate system to this list, which we cling to and amend daily, defying its manifest obsolescence.
In architectural history, the 20th century styles of Art Deco and Modernism celebrated the continuity of materials and lines, visually and materially embodying the ethos of commerce and communication and free-flowing hydraulics. The train and the automobile sought to symbolize sleekness and speed and the mythology of the unencumbered in their relentless windswept contours. You can still see it in the modern trains of China and Japan.
I’ve had a Mayan archaeologist comment on the hubris of their lime walkways and compare it to our own material profligacy. Each civilization burns itself out on the hulls of its kernel concepts, lost in materiality because they invested too much meaning into the thing and were afraid to let it go, confusing gross domestic product with wealth and wealth with the economic everyday. Upon its invention, the thing – the walkway, the road, the car, the chariot – meant commerce and communication and control. That meaning remained even as it drifted into obsolescence, so the civilization invested even more in it because of what it meant, not what it could do.
Civilization literally comes from the word for cities, and commerce is both the source of wealth and an end in itself, an activity that is the economic everyday. Stadtluft macht frei, nicht wahr? Six years ago I wrote about cities and the logic of concentration and how every event from the telegraph in the 1840s to the telephone in the 1870s to COVID in 2020 spurred hyperbolic predictions about the end of concentration that were wrong, as they always are. Commerce is civilization, and it means much more than money and goods, it means ideas and inventions, and new ways of smoothing surfaces, increasing speed and building up. We want to be on top of each other because that is where new and interesting things happen.
It wasn’t a wall, it was a road. And it’s name means Long City.
Photos copyright Vincent L. Michael 1996-2025
Fast Track
The demolition of the East wing of the White House suddenly brought historic preservation into the mainstream consciousness this week, with valid recriminations from the National Trust for Historic Preservation, American Institute of Architects and other bastions of civil society. Now, many of those knew that, in fact, the executive does not need to follow the same preservation laws as the rest of the country, and while the Advisory Council for Historic Preservation and others opined on a restraining order, the entire 120-year old wing was gone in a week.
That is because they resorted to mechanical demolition with a (rented) backhoe, which makes for the best visuals. Given the executive predilection for reality-TV-style-theatrics above realpolitik, the choice makes sense. It wastes dollars, though, and contradicts modern practice regarding deconstruction and re-use of valuable materials, a topic I covered recently. Clearly, leadership has their broughams mired in the weird 80 years.
The demolition of the Epstein East Wing is a rare moment when historic preservation spends some brief time at the height of national consciousness, and heck, it could continue next week when some western legislator with a bee in his buckskins is holding a hearing on the National Historic Preservation Act of 1966. We might not wish for that, though, because everything that rises up in this performative administration tends to fall and crash just as fast (except prices).
Yes, it is the People’s House, and yes, the approach drew the appropriate rebukes from the bastions of civil society, and yes, at the end of the day there was precious little anyone could do about it. And yes, it is dumb and artless and clumsy and cowardly. They follow the fast track because they can’t do the actual work. The renderings of the oversized replacement building work in the media, even though they don’t work architecturally, as anyone who looks closely can see. But then again, it’s probably just a pretence for rebuilding the underground bunker…..
Photos by me from March tour of WH – except the featured image – you have to guess where that is.
Remember when the buck stopped here? Good times.
DECEMBER UPDATE:
Kudos to the National Trust for Historic Preservation for filing a lawsuit last week against the demolition of the East Wing. Reality stars reign in media fights, but they fold when evidence is required.
Deconstruction and the weird 80 years
I saw a wonderful presentation by Mae Bowley at the Destination Downtown 2025 conference last week in El Dorado, Arkansas. Deconstruction is the systematic dismantling of older buildings in order to re-use their materials. San Antonio adopted one of the best deconstruction ordinances in the country a couple of years ago and Stephanie Phillips and the rest of Shanon Miller’s team got plenty of kudos.
Opening of the Material Innovation Center at the Kelly Bungalows in November, 2022.
Mae’s presentation was electric for many reasons, but the one that stood out to me was the historical one. Deconstruction is not a new thing – it is what everyone everywhere did until about 1940. Only during the last 80 years did we do something different. That different thing was demolishing buildings and throwing them in the trash. No one did that before.
And Mae provided another historical tidbit I had missed completely. Mechanical demolition with bulldozers and the like was a product of World War II, where those machines were needed to clear jungles for airfields or urban debris for troop advancement. Urban renewal started immediately after World War II, and all of a sudden we had new mechanisms – like bulldozers, which derive from tanks – for reshaping place. Urban renewal continued through the 1960s and the National Historic Preservation Act is traditionally seen as a reaction to urban renewal and interstate highways, which required the bulldozing of many, many buildings.
Now, I was aware of the economic shift that took place during this same weird 80 year period. In the early 20th century and before, buildings were commonly moved and reused. Heck, I have seen a significant building moved in San Antonio every year over the last decade. When that happened in 1900 – and it happened everywhere – the economic rationale was simple. The fixed asset of the building was worth more than the land. Even when places like Euclid Avenue in Cleveland saw demolition of mansions, it was because a new use – industry – was MORE valuable. Same in LA circa 1915.
Moving the 1880 Claudius King house in San Antonio, 2019.
Mae even illustrated the long history of deconstruction when she illustrated the deconstruction she did of a 1920s house. By the time they got under the sheathing and onto the walls themselves, they found evidence of earlier materials that had been reused. In other words, the deconstruction revealed evidence of earlier deconstruction.
Which made me think of buildings around the world built from materials scavenged from other buildings. Like this Jacobean house constructed from the stone of Fountains Abbey (Yorkshire, UK) after the dissolution of the monasteries.
Or this mosque in Delhi (India) composed of the ruins of a couple dozen Hindu and Jain temples.
Or, like, most of Rome. Or even like our San Antonio Missions, whose limestone and sandstone walls migrated over the decades into nearby buildings.
The Sisson House near Mission San Juan – this house was itself a deconstruction project last year.
Deconstruction of the Sisson House at Graf and Presa, October 2024.
Mae also spent a lot of time talking about wood – because deconstruction allows you to get some old-growth wood, which is not something that exists in the market in 2025. Old growth wood is straighter, more disease and rot-resistant and has a tighter grain. It is one of the most notable materials that can be easily recycled (once you pull the nails out). Brick, too. When I started in heritage conservation in 1980s Chicago I saw that even then demolition sites would save the Chicago brick and “send it to the South”. When I got to San Antonio in 2016, I finally saw a building made of Chicago brick. In 2009.
Also it is Ladino one of the best restaurants at the Pearl – where they re-used EVERYTHING.
I looked back and it seems I blogged about Deconstruction in 2009 and was pretty negative – I compared it to the difference between recycling and reusing. Recycling requires a lot of energy and produces a lot of waste compared to reuse. I can reuse a bottle by cleaning it, but to recycle it I have to grind it up and remelt the glass. But what I did not realize at the time was that deconstruction is something we have been doing since we first made cities and towns. And it makes sense – why should the landfill get all of the good wood?
Preservation cuts proposed
The random, awkward budget cutting process finally reached the heritage conservation world last week as the Historic Preservation Fund was nearly zeroed out by the administration. This would decimate state and tribal historic preservation offices and make compliance with the National Historic Preservation Act nearly impossible. The Historic Preservation Fund comes not from taxes but from offshore oil leases, a detail significant to those of us who do the work, but perhaps not to those doing the supposed cutting.
The Creamery – an historic tax credit project in San Antonio – I should have included it with my last blog about Art Deco – which included three other Art Deco buildings in San Antonio being restored with tax credits.
Historic Preservation Offices review both federal undertakings under Section 106 of the National Historic Preservation Act as well as buildings being restored with historic tax credits. The National Park Service also has a role in both activities, and the cuts look to be deep there as well.
Stilwell House, part of the National Historic Landmark Fort Sam Houston, San Antonio.
Now, as with the other chaotic and uncoordinated cuts proposed during the recent recrudescence, one has to consider 1. Will it change on its own or, less likely, by action of legislature or judiciary?, 2. Will it remain in its present colossal form or shrink?, 3. Are the cuts the actual goal? Other goals manifest recently include: chaos and disorientation; maintaining presence in the news cycle; performative “sin” or “virtue” signalling; or a desire to distract attention from an earlier performance.
St. Anthony Hotel, San Antonio. One of the first projects to combines the 2015 Texas historic tax credit with the federal historic tax credit.
Burns Building – one of two historic tax credit projects on Houston Street that our Capital Club donors will be touring next week.
Time will tell. In the next week or so. The National Preservation Partners Network recently joined other national groups objecting to the colossal cuts, and you can see the statement here. Everyone has been lobbying for the continuation of historic tax credits, and even their enhancement, which has bipartisan support. In Texas in the last decade the federal and state tax credits have created 515 projects worth hundreds of millions of dollars.
Public money and real estate
When the City received its first official briefing on Project Marvel six weeks ago, there was constant reassurance that no public money would go into a private sports stadium. That mantra vanished within a month when the Spurs admitted they were polling taxpayers about using Bexar County funds. They even wanted to get it on the May ballot. The public funded Hemisfair (first Spurs stadium), the Alamodome (second Spurs stadium) and Frost Bank Center (third Spurs stadium) and now they are on Spurs IV (A New Hope.) They have the most exciting NBA player, so you can’t fault their timing.
The reality is that most real estate development has public funding. And it has always been that way.
Go back almost two centuries to the era of steam railroads and canals. How were those financed? Usually by land sales, and generally those were pure raves of speculation where people would sell the same parcel multiple times in a day. Look at the sale of canal lands in Chicago in the 1830s. Absolute madness. Railroads – whether intercontinental or local – were funded the same way. You got land to finance the railroad and that land became more valuable because it would be connected to rail so you could sell it to finance the railroad construction. Not much different to tax-increment financing (we call it TIRZ in SA). You borrow against the increased value you will realize when you finally build. Neat, eh?
There is almost no example of real estate development that is not seeking a public subsidy. In the early 20th century it took the form of amenities like streets and sewers and sidewalks and fire and police and even schools (Remember public schools? Good times!)
In the last 75 years the subsidy has usually been in the form of highways and zoning. You will recall that zoning emerged in the 1910s after the truck and automobile suddenly rendered the location of the railroad tracks irrelevant. Zoning guaranteed that you stayed on the right side of the tracks. Zoning is a form of financing as well, as I explained here in 2008.
Hey, historic preservation has been in the public subsidy game for a half century. Every March we go to Washington to argue for historic preservation tax credits, which are another form of financing. The basic idea in 1976 was: Even the playing field. Bankers preferred to finance new construction because there was less uncertainty. So, you give rehabilitations of historic buildings a tax credit (taxes you don’t have to pay, not a check from the government) after they finish. 10-25 percent covers most uncertainties.
Wait – how does that work? You get the tax credit afterwards? No, you sell the tax credit at a slight discount and turn it into equity at the front end. So…it becomes a form of financing. The clever thing about land sales, tax increment financing, tax credits, highways and zoning is that they are public subsidies that do not require you to write a check. So, no tax dollars involved…directly.
And you can always sell the stadium to a casino. (Caesar’s Superdome, New Orleans)
This is not to say that real estate developers are rent-seeking lampreys (we’ll leave that to the insurance industry). In my current role on the Board of the National Trust Community Investment Corporation (NTCIC), I see first-hand the complexity and fragility of putting together a real estate deal. Quite frankly, tax credits and tax increments DO make projects happen. And there are plenty of small developments that happen in conurbanities without a public subsidy – aside from roads and sewers and water and utilities and garbage collection.
Affordable housing always requires a subsidy because a million bucks only buys four units at any level.
To be fair, many of the hundred-plus unit sprawl developments actually operate at such a scale that municipalities have – on occasion – been able to ask THEM TO PAY for things like sewers and utilities and even roads. These were originally called “impact fees” and were passed on to the consumer. On the other hand, the current upzoning movement is actually adding another subsidy – for increased density in mature urban communities.
We tend to idolize the private market because it seems to reward individualism, a key aspect of American character. In truth, the smart money is always chasing the public subsidy. Real estate is the only asset whose value is entirely externalized, and the shape and value of those externalities lies within the public sector.