Way back in 2009 I embraced Donovan Rypkema’s challenge to rebrand “historic preservation” as “heritage conservation,” which I did in a blog here. I had recently finished my dissertation on the history of historic districts, observing how the community planning movement of the late 20th century changed historic preservation from a curatorial pursuit to an exercise in democracy. To be truly democratic, more stories reflecting ALL populations needed to be told, and “heritage conservation” to me included the invaluable efforts to rescue lost history and those sites that have great community significance but little or no architecture.

Or both.

Shortly after that I began an effort which continues to this day to look at ways that the National Register of Historic Places could tell the full American story. The curatorial – and architectural – emphasis of the 1930s-1960s limited these stories. Ned Kaufmann estimated at the turn of the millennium that only 2-4% of National Register sites told the story of women and people of color, and today the number is still likely below 10%. Since 2012 I have participated in or moderated several sessions at the annual PastForward conference of the National Trust for Historic Preservation looking at this issue. 2015 was a highpoint, with a panel discussion at PastForward that included two State Historic Preservation Officers (SHPOs), a presentation at the Advisory Council on Historic Preservation (thanks Brad White!) and a lecture at the Eighth National Forum on Historic Preservation Policy and Practice that was published in 2018 with specific recommendations for amending the National Register and the Secretary of the Interior’s Standards for Rehabilitation. The rubric was Addressing the Diversity Deficit and many people contributed valuable ideas and insights.

My initial presentations on the subject of reforming the National Register and the Secretary’s Standards were met with anger by Carol Shull, longtime Keeper of the National Register, although by 2016 she told me they were “getting better.” I can recall meeting with Julianne Polanco before she was SHPO for California and telling her I wanted to totally redo the National Register. She calmed me down and pointed out that you could do a lot of good for diversity with existing tools if you just used them properly. She was on my 2015 panel at PastForward along with Allyson Brooks, Washington state SHPO. They both used the existing tools very creatively to promote diversity. Consequently, my 2018 recommendations were reforms, not radical recasting. In fact, official National Register guidance began to shift toward heritage conservation that same year when they issued a guidance that said interior spaces that had lost all of their architectural finishes could still retain historic significance under Criterion A (history).

Like this interior of the Forum on 43rd in Chicago. Actually, it has some of its finishes. But is needs to be conserved not because of those finishes but because of the community story they circle.

In 2020 I moderated a PastForward panel that included the new head of the National Register, Sherry Frear and my San Antonio colleague Sarah Zenaida Gould, one of the founders of Latinos in Heritage Conservation (along with Julianne Polanco and many other friends) called “A Deep Dive On Integrity.” This was COVID times, so it was a Zoom panel and it managed to attract over 500 participants. In four weeks I will be on another panel with Sherry and Sarah on the issue of Integrity, at the PastForward conference in New Orleans. In addition to the diversity question, there is also the confusion of “integrity” with structural integrity. The word itself is the problem, dating to 1966 when we Americans were too scared to use the word “authenticity.”

This house has historic integrity, but not structural integrity. The Park Service will be knocking it.

So now there is a dust-up between the Advisory Council on Historic Preservation, led by Sara Bronin, who has issued policy statements and comments on a whole variety of contemporary issues and how preservation should react to them. On the other side are State Historic Preservation Offices and National Park Service folks who actually implement the National Register and the Secretary’s Standards. Most recently, there is a call from ACHP for comment on a series of regulatory streamlining proposals to promote climate resilience.

Pointing to the flood level lines at Mies’ Farnsworth House, c.2009.

Like many of my colleagues in the National Preservation Partners Network, I do not find myself in one camp or another. On the one hand, some of the streamlining proposals from the ACHP comment are canards that either don’t happen (transit line and bike lane planning, review of the inside of residences, mechanical and electrical systems) or have already been accepted as reasonable or reversible (solar panels, engineered wood products). On the other hand, the Secretary of the Interior’s Standards have not been updated or reviewed in over 30 years, which is way too long.

Even in 1990 we did not regulate paint color.

On the one hand, the idea of streamlining regulatory processes is attractive. If it works. If current regulations are turning around in an average three business days, then that is not exactly earth-shattering. The issue does not seem data-driven but anecdote-driven. It feels like a series of solutions in search of a problem. Also, many of the “solutions” were long ago implemented by various agencies who are quite skilled at following the rules.

Not the Postal Service.

On the other hand, I have watched regulators argue about very silly minutiae. Admittedly, I am the opposite of the precious preservationist. I love original materials because they can’t be had today for love or money, but if they are already gone, game over. Bring on the Hardie Board and plastic lumber.

Modern wood is so bad you can see how bad it is at 60 miles an hour.

In addition to not being terribly precious, I am not an architect, so I don’t have tons of faith in technology. One of the articles of faith is that energy upgrades work. I have a lot of experience with energy upgrades whose claims are driven by sales, not data.

One of the suggested policies:

• Broadening the scope of building envelope energy efficiency improvements, including replacement windows, doors, and insulation, without further historic preservation review.

My response:

This fails to take into account three facts.  First, many historic windows and doors perform as well as modern replacements.  Restored old-growth windows are warrantied for 50-60 more years than contemporary products.  Second, window and door ratings are based on the uninstalled product, yet most of the thermal leakage, even in new construction, happens at the frame.  Third, while interior insulation could go without review, exterior insulated finish systems (EIFS) can significantly shorten the life of a building’s skin due to the method of installation and quality of materials.

Just do what Barrio Dogg did – ignore the permits and regulations and cover the building with enough goop to change the original proportions!

And then there is the profit motive. Windows and doors may be less than 10% of construction costs but they are among the biggest markups (20-25%) for contractors, so they are a profit center.

At the end of the day it is not about policies or practices, but process. Whether a given state or federal agency is fast or slow in the process is a consideration, but the larger consideration in any democracy is having a public process. If we want to tell the full American story, we need to have a place for everyone to speak.

I have always said that the brilliance of heritage conservation reviews is that unlike zoning, the resource is not graded or commodified: every review is about the individual resource and the conservation of its characteristics as defined and valued by the community. Let’s not lose that.

DECDEMBER UPDATE:

Sara Bronin, Chair of the ACHP, spoke at our Duda Forum on November 16 right after the DRAFT Program Comment on Housing, Climate and Transportation issues was released. I have taken a look at the new document and find that many of the objections I raised in my own comment on the comment were in fact addressed, and I no longer see a tendency to give blanket approval to unproven replacement windows and insulating systems. Much of the document is now focused on glossing over reviews involving repair or maintenance of windows and doors (fine) and maintenance, repair or in-kind replacement of elements like roofing, foundations, canopies and foundations (mostly fine). It encourages caulking, pointing, and weatherstripping and has benefited from some wise input regarding previously painted surfaces and low-pressure water washing. So someone listened!

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