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ADVISORY COUNCIL ON HISTORIC PRESERVATION
1100 PENNSYLVANIA AVENUE NW, SUITE 809
WASHINGTON, DC 20004 (202) 606-8503

ABOUT THE COUNCIL

The Advisory Council on Historic Preservation serves as a primary policy advisor to the President and Congress on matters of historic preservation. An independent Federal agency, the Council was established by the National Historic Preservation Act of 1966.

Responsibilities of the 20-member body include advising other Federal agencies to ensure that their actions are carried out with consideration to preserving the Nation's historic resources. The Council is headquartered in Washington, DC, with an office in Denver, CO.

COUNCIL MEMBERS

[image] Cover photo: Mill Knoll, a multi-unit affordable housing project combining rehabilitation and new construction (Tilton, NH) (photo courtesy of New Hampshire SHPO)

A NATION OF NEIGHBORHOODS

America is a Nation of neighborhoods. Large or small, in the heart of a city or on the outskirts of town, neighborhoods provide Americans with a fundamental sense of belonging. They are more than a population, a geographical boundary, or an ethnic enclave, though these may be defining characteristics.

Neighborhoods transcend the streets and sidewalks, blocks of houses and apartments, strips of stores and businesses that give them physical shape. They are about people and how they relate to each other over time, as individuals and members of a larger community.

Viable communities, particularly safe and stable neighborhoods, are a national priority, and the Federal Government expends considerable monies toward making them a reality. While a variety of Federal programs address overall neighborhood stabilization, some of the most important provide funding to maintain housing affordable to moderate- to low-income residents.

To eliminate blight in older neighborhoods, funds are used to rehabilitate vacant and deteriorated housing stock and convert abandoned commercial and industrial buildings for residential use. Many of these neighborhoods are listed in or eligible for listing in the National Register of Historic Places. Because of the age and architectural style of housing stock, neighborhood stabilization and revitalization are preservation priorities.

The Federal Government's commitment to affordable housing translates into considerable expenditures. Since 1990, for example, Department of Housing and Urban Development (HUD) appropriations alone have included $21 billion for affordable housing projects funded through the HOME investment partnership program and the Community Development Block Grant (CDBG) Program. Monies have been spent almost equally on housing rehabilitation and new construction.

In recent years, additional funding for affordable housing has been appropriated in the Public Housing Program as older complexes have been revitalized into mixed-income housing developments.

Housing experts agree that rehabilitation of adjacent housing units is critical to the success of new construction projects. Thus, historic preservation has become a major tool in Federal, State, and local government efforts to expand the number of housing units and to ensure that infill and new construction projects preserve the architectural character and sense of place in communities.

To encourage the continued use of historic properties as affordable housing and to encourage revitalization of historic neighborhoods, the Advisory Council on Historic Preservation developed its Policy Statement on Affordable Housing and Historic Preservation. The statement urges Federal, State, and local governments, housing providers, and the preservation community to work together "to reconcile national historic preservation goals with the special economic and social needs associated with affordable housing."

First issued in 1995, the policy features ten implementing principles to foster the care of the Nation's historic neighborhoods in older communities. This brochure contains the text of the Policy Statement on Affordable Housing and Historic Preservation and the implementing principles for easy reference. It recommends how the implementing principles can be used to incorporate preservation of historic properties into overall neighborhood revitalization.

[Image]
Contractors work on a single-family rehabilitation project in Macon, GA (photo courtesy of the National Trust)

COUNCIL POLICY STATEMENT: AFFORDABLE HOUSING AND HISTORIC PRESERVATION
Adopted June 26, 1995

"The Council seeks to promote a new, flexible approach toward affordable housing and historic preservation which is embodied in the following Principles for Implementation.

"State Historic Preservation Officers (SHPOs), Federal and State agencies, and local governments involved in the administration of the Section 106 review process for affordable housing projects funded or assisted by Federal agencies are encouraged to use these principles as a framework for Section 106 consultation and local historic preservation planning.

"The Council also encourages the Department of Housing and Urban Development (HUD), in consultation with the national preservation community, including the National Conference of State Historic Preservation Officers, the National Park Service, and the National Trust for Historic Preservation, to develop comprehensive historic preservation training programs for HUD staff, State, county, and local officials, and housing providers who implement affordable housing projects."

PRINCIPLES FOR IMPLEMENTATION
(ANNOTATED)

The Council will, and other participants in the Section 106 review process for affordable housing projects should, be guided by the following principles in applying the policy set forth:

1. Emphasize consensus building.
   
   Section 106 reviews for affordable housing projects should place principal emphasis on broad-based consensus reflecting the interests, desires, and values of affected communities, neighborhoods, and residents. Consensus-building should be facilitated through training, education, and consultation focused on historic preservation values, collaborative planning, and dispute resolution.
   
   
   • The goal of the Section 106 review process is to balance affordable housing project goals and historic preservation values.
   • Local governments and housing providers should identify potential conflicts between affordable housing projects and historic preservation values early on so consulting parties can explore alternatives.
   • Early involvement of the Council can help resolve disputes between the agency or housing provider and the preservation community.
     
     
2. Elicit local views.
   
   Identification of historic properties and evaluation of their eligibility for the National Register of Historic Places should include discussions with the local community and neighborhood residents to ensure that their views concerning architectural and historic significance and traditional and cultural values receive full consideration by the Federal agency, State, county, or local government, and the SHPO.
   
   
   • The views of neighborhood residents are important when evaluating properties not already listed in or determined eligible for listing in the National Register of Historic Places.
   • A property or district's significance is usually associated with its architectural character, but its significance may also be based on history and culture as perceived by the residents.
   • Local historic architectural review boards can be a forum for community discussions about the significance and treatment of historic properties included in affordable housing projects.
     
     
3. Focus on the broader community.
   
   When assessing the effects of affordable housing projects on historic properties, consultation should focus not just on individual buildings that may contribute to a historic district but on the broader community, neighborhood, or "target area."
   
   This practice will ensure proper consideration is given to the cumulative impacts of projects within a designated area. Historic preservation issues should be related to social, economic development, housing, safety, and programmatic issues integral to community viability.
   
   
   • The cumulative direct and indirect effects of project implementation should be considered during the development of treatment and mitigation plans.
   • Proposals for demolition and new construction within a district must be reviewed in the context of the community's overall viability.
   • The review of adopted or pending community redevelopment plans can assist consulting parties in understanding how affordable housing projects relate to community redevelopment plans.
     
     
4. Adhere to the Secretary's Standards, when feasible.
   
   Plans and specifications for rehabilitation, new construction, and abatement of hazardous conditions associated with affordable housing projects should adhere to the recommended approaches in the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings, when feasible.
   
   Where economic or design constraints preclude application of the Secretary's Standards, consulting parties may develop alternative design guidelines tailored to the district or neighborhood to preserve historic materials and spaces. Alternative guidelines shall be incorporated into executed Memoranda of Agreement or Programmatic Agreements.
   
   
   • The Secretary's Standards are broad guidelines that outline factors to be considered when adapting historic properties for contemporary use.
   • Cost comparisons of alternative treatments are important when developing treatment and mitigation plans. This is particularly so when considering lead abatement, ADA compliance, and local building code compliance.
   • Communities can develop cost-sensitive design guidelines based on the Secretary's Standards to assist them in setting treatment priorities.
     
     
5. Include adequate background documentation.
   
   Proposals for non-emergency demolitions of historic properties should include adequate background documentation to demonstrate to the SHPO and/or the Council that rehabilitation is not economically or structurally feasible, or that retention of such properties would jeopardize the implementation of an affordable housing project.
   
   
   • Proposals for demolition should include analyses of alternative treatments, such as "moth balling," and any plans for the future development of the cleared site.
   • The demolition of structurally sound buildings is discouraged when rehabilitation, sale, relocation, or transfer of an historic property is a viable option.
   • Prior State and local reuse marketing efforts of an historic property should be well documented.
     
     
6. Emphasize exterior treatments.
   
   The Section 106 review process for affordable housing rehabilitation projects and abatement of hazardous conditions should emphasize the treatment of exteriors and be limited to significant interior features and spaces that contribute to the property's eligibility for the National Register, unless otherwise agreed to by all consulting parties.
   
   
   • Exterior rehabilitation should emphasize the preservation and stabilization of the streetscape of a district or community.
   • Limited treatment of significant interior features, when appropriate, should be agreed to by all parties, including housing providers and residents, and be responsive to the lifestyle and needs of occupants.
   • Recognizing funding constraints, exterior and interior treatments should balance architectural character with the objectives of providing safe, liveable, and marketable housing units.

[Image]
Before: Buildings targeted for rehabilitation as an affordable housing project in Washington, DC

[Image]
After: Affordable housing rehabilitation transforms the buildings into four new townhouses (photos courtesy of H Street Community Development Corporation)

7. Coordinate with other reviews.
   
   Where appropriate, Section 106 reviews for affordable housing projects should be considered in conjunction with applications for Historic Rehabilitation Tax Credits and other State and local administrative reviews to ensure consistency of reviews and to minimize delays.
   
   When Section 106 reviews for affordable housing projects precede other related reviews, applicants seeking Historic Tax Credits are encouraged to seek the advice of the SHPO and obtain early review by the National Park Service (NPS) to ensure final eligibility for Historic Rehabilitation Tax Credits.
   
   
   • Federal, State, and local agencies should identify funding sources for affordable housing projects so that reviews are properly coordinated or consolidated.
   • When Historic Rehabilitation Tax Credits are part of an affordable housing project, the developer should seek SHPO and NPS reviews early in project planning. This will help ensure that the Secretary's Standards are met and documented.
   • In order to avoid delays, local governments should attempt to coordinate the Section 106 review with required local administrative reviews.
     
     
8. Avoid archeological investigation.

   Archeological investigations should not be required for affordable housing projects limited to rehabilitation and requiring minimal ground disturbance.

   • Rehabilitation projects that involve construction of major additions may require archeological investigations by the agency or housing provider
   • Archeological investigations should only be required when it can be documented that there is a "high probability" of significant archeological resources within the project site.
   • Archeological data recovery plans conducted as part of affordable housing projects should recognize and share information that strengthens the history and values of the community.
     
     
9. Develop programmatic approaches.
   
   State, county, and local governments are encouraged to develop Programmatic Agreements (PAs) that promote creative solutions to implement affordable housing projects.
   
   Such governments are also encouraged to streamline Section 106 reviews through the exemption of categories of routine activities; the adoption of "treatment and design protocols" for rehabilitation and infill new construction; and the delegation of Section 106 reviews to qualified preservation professionals employed or contracted by the local community.
   
   
   • PAs among the local government, the SHPO, and the Council should be developed to respond to the various housing programs administered by the State or local government.
   • PAs should provide for meaningful, continued public involvement during project reviews. State and local governments should ensure that the community is aware of them.
   • PAs may be tailored to local historic and architectural review board procedures that adequately reflect historic preservation values in the planning process.
     
     
10. Empower local officials.
    
    Section 106 requires Federal agencies and local governments that receive Federal funding to administer Federal programs with serious consideration to how their actions will affect historic properties and to provide the Council with an opportunity to comment.
    
    This opportunity should take place before the proposed project is approved.
    
    
    • Qualified preservation professionals employed by a State, County, or local government promote a preservation ethic that can help ensure that preservation is incorporated into the planning and design of affordable housing projects.
    • State and local governments that employ or contract with qualified preservation professionals can expedite Section 106 reviews.
    • Agencies and State and local governments are encouraged to consult with qualified preservation professionals early in project planning to identify historic preservation issues that may require further analysis.

[Image]
Interior of the O 'Hem House, a 76-unit assisted-living residence converted from the Red Seal Shoe Factory, Atlanta, GA (photo courtesy of Georgia SHPO)

FREQUENTLY ASKED QUESTIONS

1. What is the Advisory Council on Historic Preservation?

The Advisory Council on Historic Preservation is an independent Federal agency created by the National Historic Preservation Act of 1966 to provide leadership in the National Historic Preservation Program. The Council administers the Government's protective system for historic properties, commonly known as "Section 106 review." The Council's role is to find a reasonable way to use Federal monies to meet agency objectives while protecting the Nation's historic resources.

2. What is the Council's role in affordable housing?

The Federal Government allocates funds that local governments, developers, and other housing providers use to acquire and rehabilitate existing housing units and abandoned commercial or industrial buildings for affordable housing. These buildings may be eligible for listing in the National Register individually or they may be located within a National Register historic district. Federally assisted housing projects that involve historic properties trigger the Section 106 review process administered by the SHPOs and the Council.

3. When does the Affordable Housing Policy Statement apply?

The Affordable Housing Policy Statement applies to any federally assisted housing project involving properties eligible for or listed in the National Register.

4. How do I use the implementing principles?

The implementing principles provide a framework for Section 106 reviews for affordable housing projects. Consulting parties should use the implementing principles to ensure that:

• a balanced and cost-effective historic preservation policy is applied to affordable housing projects;
• flexible approaches are considered rather than rote approaches that could detract from the success of a given project; and
• reviews incorporate all the principles to promote a holistic approach toward neighborhood revitalization.

5. Where can I get further information?

Advisory Council on Historic Preservation
1100 Pennsylvania Ave., NW, Suite 809
Washington, DC 20004
(202) 606-8503/8505
Web site: www.achp.gov

National Conference of State Historic Preservation Officers (NCSHPO)
444 N. Capitol St., NW, Suite 342
Washington, DC 20001-1512
(202) 624-5465
Web site: sso.org/ncshpo/index.htm
(Contact NCSHPO for a list of SHPOs)

National Park Service
Heritage Preservation Services
1849 C St., NW
Washington, DC 20240
(202) 343-9578
Web site: www.cr.nps.gov

National Trust for Historic Preservation
Community Partners Program
1785 Massachusetts Ave., NW
Washington, DC 20036
(202) 588-6000
Web site: www.nationaltrust.org

U.S. Department of Housing and Urban Development
Assistant Secretary for Community Planning and Development
Office of Community Viability
451 7th St., SW
Washington, DC 20410
(202) 708-2094
Web site: www.hud.gov
(Contact HUD for State offices)

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