Historic Resources Committee

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  • 1.  POTENTIAL CHANGES TO SECTION 106 OF THE NHPA

    Posted 17 days ago

    The End of Section 106 as We Know It? - NCSHPO

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    The End of Section 106 as We Know It? - NCSHPO
    Late Friday afternoon, the Vice Chairman of the Advisory Council on Historic Preservation (ACHP) circulated a proposed rewrite of 36 CFR Part 800 - the implementing regulations for Section 106 of the National Historic Preservation Act. Though preceded by months of discussion aimed at speeding up federal project delivery, the...
    View this on NCSHPO >

    Upon initial review, one thing is clear: this is not a routine regulatory update. It is a fundamental rewrite of how the federal government identifies, considers, and resolves impacts to historic and cultural resources.



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    Brian Broadus AIA
    Perspectus Architecture
    Cleveland OH
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  • 2.  RE: POTENTIAL CHANGES TO SECTION 106 OF THE NHPA

    Posted 17 days ago

    From the Washington Post yesterday: Critics warn Trump plan would narrow public role in historic reviews - The Washington Post.



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    Joan Pomaranc
    AIA Chicago
    Chicago IL
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  • 3.  RE: POTENTIAL CHANGES TO SECTION 106 OF THE NHPA

    Posted 16 days ago

    FIGHT this.  Mail your Congress Reps. and Senators.  



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    Nelson B. Nave AIA
    Nelson Breech Nave, AIA Architect
    Kalamazoo MI
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  • 4.  RE: POTENTIAL CHANGES TO SECTION 106 OF THE NHPA

    Posted 16 days ago

    This illogic reminds me of Donovan Rypkema's work on the economic benefits of historic preservation as opposed to the idea that somehow it does not produce benefits commensurate or more so than demolition of existing fabric and new buildings (not to say new buildings should not also be built) So I pulled a highlights reel. 

    The economic figures most associated with Rypkema

    These should be treated as illustrative findings from particular studies and periods, not as universal multipliers.

    1. Rehabilitation puts more money into local labor

    Rypkema's most repeated rule of thumb was that rehabilitation is substantially more labor-intensive than new construction. In a 2003 policy paper, he estimated:

    • New construction: roughly 50% labor and 50% materials
    • Building rehabilitation: roughly 60–70% labor, with the remainder in materials

    The mechanism matters as much as the percentage: imported or remotely manufactured materials allow much of the construction expenditure to leave the region, while carpenters, electricians, masons, plumbers, and other trades are generally paid locally and recirculate earnings locally. A later National Trust publication used a similar formulation-about 60% labor/40% materials for rehabilitation versus 40% labor/60% materials for new construction-and estimated that approximately 75% of rehabilitation's economic benefits remain in the community where the project occurs.

    This is probably the single most useful Rypkema idea for contemporary building-reuse advocacy: reuse changes the composition of expenditure from extraction and manufacturing toward skilled local services.

    2. More jobs per dollar than new construction

    In PlaceEconomics' Savannah analysis, $1 million spent rehabilitating a historic building was estimated to produce approximately 1.2 more jobs and $62,000 more income for Georgia residents than the same amount spent on new construction. The precise difference would vary by local labor markets and supply chains, but it illustrates his basic argument that rehabilitation has a larger local employment multiplier.

    He also argued that ongoing rehabilitation can provide a relatively durable employment base. Because building components require reinvestment over time, rehabilitating roughly 2–3% of a community's building stock annually could support continuing-not merely one-time-employment in construction trades.

    3. Historic tax credits leverage much larger private investment

    A PlaceEconomics Connecticut study reported the then-current national finding that $1 of federal historic tax credit generated approximately $5 in private investment. At that point, the program was credited with approximately:

    • $85 billion in rehabilitation investment
    • 1.8 million jobs
    • About 75% of economic effects retained locally or within the state
    • Roughly two-thirds of projects since 2002 located in qualified low-income census tracts
    • A federal tax expenditure of less than $10,000 per job generated

    Those are historical cumulative figures from approximately 2010–2011, rather than present-day totals, but they show how Rypkema framed incentives: not as grants for saving attractive buildings, but as relatively low-cost devices for inducing private capital investment in existing assets.

    Related analyses found that states commonly recovered a significant portion of their historic-tax-credit cost during construction and could fully recoup it through increased revenue within roughly four to nine years, although results differed by state and program design.

    4. Main Street preservation as business development

    A later PlaceEconomics synthesis reported that participating Main Street communities had cumulatively produced approximately:

    • $79 billion in investment
    • 285,000 buildings rehabilitated
    • More than 640,000 net new jobs
    • Nearly 144,000 net new businesses

    These were national Main Street program totals, not impacts caused solely by building rehabilitation, but Rypkema used them to demonstrate that preservation-led downtown revitalization could function as a long-term small-business and employment strategy, particularly in smaller and rural communities.

    His broader claim was that successful downtown revitalization is fundamentally economic development-creating jobs and businesses, expanding the tax base and property values, and increasing local lending-and that historic buildings are nearly always a central component of sustained downtown recovery.

    5. Historic buildings provide space for small and start-up businesses

    Rypkema repeatedly emphasized the importance of older, smaller, lower-rent commercial buildings as business incubators. Their smaller floorplates, incremental ownership patterns, and generally lower occupancy costs make them accessible to local retailers, immigrant and minority entrepreneurs, family businesses, creative businesses, and firms moving out of home-based operations.

    This argument is economically different from heritage tourism. It says that an older building has value not only because tourists visit it, but because its physical and financial characteristics provide a place where modestly capitalized businesses can operate.

    6. Preservation and heritage tourism

    Rypkema summarized repeated tourism findings that visitors interested in heritage tend to stay longer, visit more destinations, and spend more per day than visitors without a heritage interest.

    In PlaceEconomics' New York City study:

    • More than $800 million was being invested annually in historic buildings.
    • That investment supported approximately 9,000 New York jobs and more than $500 million in annual paychecks.
    • Domestic heritage tourism alone was associated with approximately 130,000 New York jobs.
    • Creative-industry employment was disproportionately located in historic districts.

    Again, those are New York-specific findings rather than national averages.

    7. Existing buildings as an affordable-housing resource

    One of Rypkema's more important policy arguments was that affordable housing is not only something governments must construct; it is also something cities must avoid demolishing.

    In his 2003 analysis, he reported that the United States had been losing approximately 530 pre-1950 housing units every day, most through deliberate demolition. His contention was that cities were systematically replacing relatively affordable older housing with housing that could not be affordable without substantial subsidy. At that time, more than 40% of housing units created through the federal rehabilitation tax credit were in buildings originally constructed for other purposes-factories, schools, warehouses, department stores, and similar properties.

    A later Pittsburgh study examined combined housing and transportation costs. The typical household in the metropolitan area spent approximately 50% of income on those two expenses, compared with less than 43% in historic districts. For a household earning $50,000, PlaceEconomics calculated a difference of nearly $300 per month in disposable income.

    His conclusion was not that all historic neighborhoods remain affordable. It was that demolition removes relatively lower-cost units permanently, while preservation regulation can maintain a more varied inventory of building sizes, conditions, types, and rents.

    8. Property values, density, and neighborhood demand

    Rypkema and PlaceEconomics frequently found that property values in designated districts were stable or appreciated competitively, including during downturns. But he opposed reducing preservation's value to higher property prices alone, since excessive appreciation could produce displacement.

    He also challenged the claim that historic districts are inherently low-density. In the New York study, historic districts were the densest residential neighborhoods in every borough, commonly at two to three times the borough-wide density. In Indianapolis, PlaceEconomics found historic-district population density nearly 25% greater than in the comparison area studied.

    The larger policy point was that cities should direct new density intelligently rather than assume that demolishing already dense, walkable neighborhoods is the principal housing solution.

    9. Environmental and infrastructure savings

    Rypkema's environmental argument preceded today's widespread embodied-carbon terminology but follows the same logic:

    • Existing buildings embody previous expenditures of materials, energy, fuel, and labor.
    • Rehabilitation avoids a portion of demolition waste.
    • Reuse consumes no new greenfield land.
    • Existing neighborhoods make use of streets, utilities, transit, schools, and other infrastructure already financed by the public.
    • Compact historic neighborhoods commonly support walking, mixed uses, transportation choice, and reduced land consumption.

    Some of his older environmental comparisons-such as equating demolition with the lost benefit from recycling a specified number of aluminum cans-are memorable advocacy devices but should not be substituted for a contemporary LCA or embodied-carbon analysis.

    Rypkema's policy framework

    His policy ideas were broader than simply "create a historic district" or "offer a tax credit."

    Preservation should be an operating strategy, not merely design review

    In Planning for the Future, Using the Past, Rypkema described seven functions through which preservation is implemented:

    public policy, regulation, incentives, funding, research, education and advocacy, and ownership or stewardship.

    He then framed preservation as five interrelated urban strategies:

    1. Economic development
    2. Housing
    3. Community development
    4. Urban quality
    5. Environmental protection and smart growth

    The central principle was that preservation should be a means of achieving larger public objectives, not an isolated end concerned only with architectural appearance.

    Use both protections and incentives

    Rypkema did not believe markets alone would retain buildings whose demolition value or development potential exceeded their value in current use. Nor did he believe regulation alone could make every rehabilitation feasible. His approach combined:

    • Demolition controls and design review
    • Rehabilitation incentives
    • Technical assistance
    • Financing
    • Public investment
    • Anti-displacement measures
    • Enforcement against neglect

    He described this explicitly as the need for both "carrots and sticks": encourage appropriate reinvestment while preventing the premature destruction of useful assets.

    Make demolition the last resort

    Rypkema did not argue that every older building must survive. He argued that demolition should be the last option rather than the default redevelopment tool.

    Specific mechanisms he proposed or discussed included:

    • Demolition delays while reuse alternatives are evaluated
    • "At-risk" lists for vulnerable building types or neighborhoods
    • Rapid significance and feasibility assessments when demolition is proposed
    • Expedited permits for rehabilitation projects that meet adopted standards
    • Conservation districts that control demolition and incompatible infill even where full historic designation is not appropriate

    This closely resembles the contemporary sequence of assessment → alternatives analysis → reuse/deconstruction planning → demolition only after other options are exhausted.

    Adopt rehabilitation-sensitive building codes

    He advocated codes specifically designed for work in existing buildings rather than applying new-construction requirements without regard to context. He pointed particularly to New Jersey's rehabilitation code as a model for making older-building projects safer and more financially feasible without requiring unnecessary reconstruction.

    This remains highly relevant to building reuse: code barriers can function as an unintended demolition subsidy when compliance is based on replacing existing assemblies rather than evaluating their actual condition and performance.

    Use tax incentives to close the development gap

    Rypkema treated historic tax credits as a mechanism for closing the difference between:

    • the cost of acquiring and rehabilitating a building, and
    • the completed property's supportable market value.

    His preferred program characteristics included:

    • Credits large enough to influence investment decisions
    • Transferability or assignability so nonprofits and owners without tax liability could monetize them
    • Compatibility with federal credits
    • Bonuses for affordable housing
    • Credits for owner-occupied homes, not only income-producing properties
    • Recapture provisions to discourage quick speculative turnover
    • Conversion of credits into mortgage assistance where low-income households lack sufficient tax liability

    He also supported combining historic rehabilitation credits with the Low-Income Housing Tax Credit to produce affordable housing in existing buildings.

    Protect affordability while reinvesting

    Rypkema recognized that successful revitalization could displace existing residents and businesses. His response was not to abandon preservation, but to pair it with targeted protections and assistance, including:

    • Home-repair grants and low-interest loans
    • Maintenance funds to prevent deferred maintenance and demolition by neglect
    • Property-tax relief or assessment freezes following rehabilitation
    • Assistance targeted to elderly, disabled, low-income, or long-standing residents
    • Land banks and nonprofit acquisition
    • Rehabilitation of vacant properties as rental housing, followed where feasible by conversion to ownership
    • Assessment based on the property's existing use rather than its maximum theoretical zoning envelope
    • Preservation of smaller commercial spaces and locally affordable rents

    This was an important nuance in his work: property-value growth is evidence of demand and investment, but not automatically evidence of equitable development.

    Allow growth without requiring destruction

    Among his more sophisticated land-use ideas were:

    • Transferable development rights from historic properties to designated growth areas
    • A publicly supported TDR bank to make the market reliable
    • Directing major density toward transit-oriented development locations
    • Reusing significant buildings as integral components of larger redevelopment sites
    • Allowing localized infill that respects established urban patterns rather than freezing neighborhoods in time

    Thus, his position was not anti-growth. It was that cities should separate the legitimate demand for additional development capacity from an assumed need to demolish existing buildings.

    Invest in the rehabilitation workforce

    Because the economic benefit depends heavily on skilled labor, Rypkema proposed education and workforce-development programs in traditional and rehabilitation trades, including dedicated secondary-school training.

    That translates readily into current policy around deconstruction, assessment, repair, remanufacturing, grading, material recovery, and reuse installation: the economic-development claim becomes much stronger when policy also creates the workforce capable of delivering reuse.

    Require feasibility analysis rather than relying on impressions

    His Feasibility Assessment Manual for Reusing Historic Buildings uses checklists, matrices, market analysis, building evaluation, team roles, costs, financing, and potential uses to determine whether a building can be productively reused. The underlying policy principle is that "obsolete" should be an analytical conclusion, not a casual label attached by an owner or demolition applicant.

    The most useful distilled version for broader building reuse

    Rypkema's work was centered on historic preservation, so historic designation and architectural significance often determined which buildings received protection or incentives. It was not a general circular-economy or salvaged-material policy framework.

    Nevertheless, his fundamental propositions translate well beyond formally historic buildings:

    Existing buildings are economic assets; demolition is an irreversible disposal decision; rehabilitation directs spending toward local labor; and public policy should correct the financial and regulatory biases that otherwise favor replacement.

    For present building-reuse policy, I would condense the Rypkema approach into five propositions:

    1. Measure existing buildings by the economic activity they support, not solely by current assessed value or redevelopment potential.
    2. Count employment and local income, because reuse is more service- and labor-intensive than replacement.
    3. Protect the affordable, small-scale space already present, including both housing and commercial space.
    4. Combine demolition review with positive feasibility tools-rehabilitation codes, tax incentives, financing, technical assistance, and expedited approvals.
    5. Integrate reuse into housing, economic development, land use, climate, workforce, and infrastructure policy, rather than leaving it solely to preservation commissions.

    That is probably his most durable contribution: he made the case that retaining and reinvesting in buildings is not nostalgia-it is a form of place-based economic development.



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    George Guy AIA
    Material Reuse
    Gainesville FL
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