“The goals of the preservation movement have evolved. The methods, for the most part, have not.”
Rast, Raymond W.¹

The Advisory Council on Historic Preservation recently asked for comments on the Secretary of the Interior’s Standards for the Treatment of Historic Properties. These standards have not been redone in over 30 years, and I have been involved in the effort to improve the National Register of Historic Places – and by extension – the Secretary’s Standards – for about fifteen years, including a 2013 panel at the National Trust conference in Indianapolis that included Ray Rast, quoted above.

Rast provided one of the first “Eureka” moments in our efforts to modernize the National Register when he suggested a sliding scale for Integrity. Charged with finding historic sites associated with Cesar Chavez, he was frustrated that State Historic Preservation Offices kept saying that the buildings had no integrity, like the example above where Chavez first organized workers. It has lost historic integrity but can it still tell the story? It happened in this building, in this place, even if windows and walls have been altered.

I have written blogs and a book chapter about this subject many times, including here in 2016. At that time Donna Graves and Shayne Watson provided the next “Eureka” moment by proposing that Integrity – in the context of LGBTQ history in San Francisco – focus on only four of the seven aspects of integrity. In the last year, an eighth aspect of Integrity – Use – has appeared. Eureka!

Alazan-Apache Courts (Los Courts) San Antonio. Many alterations since 1940 but USE is unchanged and they made the 2021 National Trust list of 11 Most Endangered Properties.

All of these efforts derived more from the INPUT side of the National Register – how do we get landmarks of most people listed when the standards are designed for fancy folk and their fancy architecture? But the focus of the Advisory Council right now is on the OUTPUT side – how do we judge and approve treatments for historic properties? Is it all about wood windows? (HINT: No. Here’s my take)

Tell me what the angels are made of.

More importantly, the effort is driven not simply by the ancient nature of the existing standards, but by the great variety of interpretations of those standards by State and Tribal Preservation Offices, the National Park Service, and local landmark commissions. Part of this variety is generational. For some Boomers it IS all about wood windows. When I first proposed revisions to Integrity, the old guard (literally – they are called the “Keeper of the National Register”) were furious.

It’s not always about architecture. Malt House, San Antonio (demolished)

The National Register falls under the Department of the Interior, and new guidances are slowly opening the doors to new types of landmarks and new types of treatments. Take one example that we are very comfortable with in San Antonio – Trex replacement floorboards for porches. We have approved these for landmark grant projects. The Office of Historic Preservation also has, although they will approve them UNLESS they have a faux-grain finish that makes them look like wood. That is a bit too precious for me. (HINT: Skeumorphs)

But I know where it comes from, and this is probably the biggest issue in the Secretary of the Interior’s Standards – internal conflicts. Back in 2006 the National Trust commissioned me to assess a particular situation where interpretations of Standards #3 and #9 came into conflict.

Standard #3 says “Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.” while Standard #9 says “new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing” So new work should look new but also it should fit in. If it fits in too well, Standard #9 defeats Standard #3. Or it whacks it on the head, as in the case above. And the historical fact is that right about the time the Standards were rewritten in 1990, people started creating all sorts of new buildings indistinguishable from the old.

1903 and 1993. Joliet, Illinois

But the real problem is not one of architectural style. The real problem is that architecture and real estate development have their own rules and interactions that don’t really apply when you are dealing with sites that are important because of their history and associations. How do they convey those histories and associations? By architecture, yes, but more by place. And by intentionally conveying that information.

Underground railroad site at a McDonald’s, Maywood, Illinois

Here is where OUTPUT returns to INPUT, because while many organizations like my own are working to nominate more diverse historic sites to the National Register, one of the biggest drivers of nominations (INPUT) are developers who are trying to get tax credits (OUTPUT) and of course their goal is to keep it as simple as possible. If you just focus on architecture, historic preservation is as easy as zoning! No inherent or unique qualities to worry about! It’s just a commodity like all others!

Woot!

In my writings on this subject, I suggested new standards for sites that met Criterion A or B, namely sites that had historic rather than architectural significance. Rather than meet high architectural standards, the treatment for these sites should focus on an interpretive plan. In some ways, my extensive experience with World Heritage sites with their management plans informed this suggestion. If World Heritage sites have management plans, couldn’t National Register sites that are important for who they are associated with or what happened there have interpretive plans? Heck, you could even make the tax credits dependent on effective interpretive plans.

The other aspect of World Heritage that is useful is the Burra Charter, which is my north star for the whole heritage conservation field. The Burra Charter basically requires community input from the moment of inception to the final treatment – a contrast to the old world where the landmarks get picked by the professionals alone. The basic idea is again, the opposite of zoning. Every site has a unique history and form that cannot be commodified. Its treatments – how we fix it up – have no analogues. They are determined by the site itself, its history and cultural continuity, and by the community that wants it in their future. No two sites are treated the same because no two are identical.

I can’t remember if it is in the fridge or the basement…

Heritage conservation is PROCESS, not FORM. The process is IDENTIFY – EVALUATE – REGISTER – TREAT. That four-step process is defined in the National Historic Preservation Act of 1966, and Section 106 basically follows the same four steps for reviewing federal undertakings. The Burra Charter essentially defines the same PROCESS but insists that the community be involved at every step. Those who wrote the NHPA is ’66 or the Standards in the 70s and 80s likely envisioned professionals doing that work. Professionals are needed of course, but they cannot do it without community, since community are the ultimate stewards of whatever structure, site, landscape or traditional practice is being conserved.

Matachines at Mission Concepcion, 2017.

Naturally, developers and public officials dealing with historic buildings want a simple form-based checklist of what they need to do, not a process. The Secretary of the Interior’s Standards are broad principles, and while the National Park Service publishes detailed Guidelines for the use of the Standards. The “checklist” so to speak is not really prescriptive – it is categorized in terms of “Recommended” and “Not Recommended”. The process should yield a different formal result for each site.

At the end of the day, the issue is more the INTERPRETATION of the Standards than the Standards themselves. During my forty years in this field, I have always been aware of how certain State Historic Preservation Offices or certain local landmark commissions had their own tendencies in review of historic projects. Developers using the tax credits want consistency and predictability, but is that reasonable? Are ground soils consistent and predictable? Are building contractors? Are zoning variations? Are interest rates? Climate? Market conditions?

1. “A Matter of Alignment: Methods to Match the Goals of the Preservation Movement,” forum journal, Spring 2014, p. 13. See also Michael, Vincent L, “Addressing the Diversity Deficit: Reform the National Register of Historic Places” in Creating Historic Preservation in the 21st Century, Wagner and Tiller, Eds. Cambridge Scholars Publishing, 2018

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