Historic preservation in DC needs reform

DC is undoubtedly a historic place, and it is essential that we use the tools we have to protect that history. However, DC is also a growing place, and a number of historic preservation cases and debates have revealed a preservation system in need of reform.

Essentially, our historic preservation process is very siloed. It's narrowly focused on reviewing neighborhoods or buildings put before it with broad criteria that encourage applying historic status to a wide net of properties. This is part of the reason that nearly one in five DC buildings are designated historic.

Instead, we need a system that considers the needs of a growing and vibrant city more holistically. Our current historic preservation process does not do that well. On the contrary, it is too easily abused for other means.

After working closely with advocates and neighbors, we have proposed some changes that would make DC’s historic preservation process smarter, more sensitive and more democratic. Here are some of our ideas, sign here if you agree with these reforms.

• Require agencies to balance the needs of preservation with the needs of current and future residents. The Historic Preservation Review Board (HPRB) is legally forbidden from considering factors other than very strict historic criteria in its decisions. Instead, agencies should balance preservation objectives with the other existing District plans (Sustainable DC, Consolidated Plan, etc), and the District should move towards a more proactive system that strategically identifies properties and preservation priorities, rather than relying only on neighbor petitions which can be overused and abused.
• Make designations less blunt. DC’s historic protections are too one-size-fits-all. Regulations on brick-type makes sense when preserving historic architecture, but is that the best way to recognize an historic event or person? The District should develop diverse designation levels that better reflect the varying goals of preservation, rather than using the blunt and limited designations that we currently have.
• Give affected neighbors all the information and ask them what they want. Currently, the HPRB is not required to consider public opinion in making its decisions and the application process does not mandate public engagement. We ask for required public meetings (not currently required), strengthening the role of affected Advisory Neighborhood Commissions (ANCs), and establishing a public vote (not currently required) to approve and/or remove historic districts. What is more, today it's not required that neighbors are given the exact design regulations for a pending historic district until after the HPRB votes, meaning you don’t know exactly how the district will affect your home or business. Affected neighbors should know the details of their options and HPRB should be required to evaluate resident input.

There’s a lot to unpack here, and we will do so in future posts. We want to support the goals of historic preservation, and to do that we are hoping for a system that is less prone to abuse. Let’s start with understanding of how our current system is so reactive and prone to over-designating.

Nearly 20% of DC is marked historic. How did that happen?

Currently 19.4% of the District’s buildings are designated historic in some fashion. When you compare this to other historic cities (like Philadelphia’s 2.2% or Boston’s 7.4%), it indicates our process might be a little overzealous. Yes DC has a lot of historic features, and being the capitol it makes sense that we would have a few more protected buildings compared to other cities. But how did we get to a place where we have nearly three times as many protected buildings as Boston?

Part of the answer is in how DC designates buildings. There are two basic protections that can be applied to a historic site: a historic landmark, which protects a specific building, and a historic district, which adds regulations and protections to a swath of buildings within certain boundaries. DC currently has more than 50 historic districts, over 30 of which are local neighborhoods.

When evaluating whether something is historic or not, the Historic Preservation Review Board (HPRB) has three elements they look at: “Properties are eligible for designation in the DC Inventory if they possess significance, retain integrity, and can be judged from a historical perspective.”

Let’s break that down a little further. “Significance” is defined broadly, and a building or neighborhood is eligible for designation if it possesses or is related to any one of the following: significant events, history, individuals, architecture, artistry, was built by a master designer/architect, or has archaeological significance.

“Integrity” essentially means that the building or place is a good representation of what it is supposed to represent (“properties shall possess sufficient integrity to convey, represent or contain the values and qualities for which they are judged significant”). Finally, “historical perspective” essentially means that that the building or area is old enough (“sufficient time shall have passed to permit professional evaluation and understanding of the properties in the context of history.”)

This criteria is fairly expansive, so under it a lot of things can be considered worthy of historic protections. This has led to a number of DC historic buildings or sites that have raised questions over the years. DC has a historic parking lot, a historic gas station, and a historic Pepco substation. Last year architecture critic Amanda Kolson Hurley argued that designating the old Fannie Mae headquarters would “dilute historic preservation” (it was eventually designated).

This broad understanding of what counts as historic is coupled with a designation process that favors the loudest voices in the room.There are many ways a city like DC can go about identifying and designating its historic sites, but for decades DC’s process has been a rather reactive one.

Instead of surveying and prioritizing potential historic sites or neighborhoods and working to designate them, the Historic Preservation Office (HPO) encourages neighborhood and preservation groups to bring forward potential sites through an application process. Essentially any neighborhood group with a stated “preservation” purpose can do the research and propose a designation for a site or neighborhood. HPO reviews that application, offers feedback, encourages (but doesn’t require, we’ll get to that later) public engagement, and the ushers the application along for a vote the HPRB.

You can see how such a system might lead to DC’s relatively high level of historic designations. As the city continues to experience growth, neighbors who are worried about things like pop-ups or any new development that is out-of-character with the feel of the neighborhood, can reach for the historic designation option to slow or stop those changes.

Do the research and prove how your neighborhood or buildings lines up with the broad criteria, complete an application, and there’s a good chance you’ll win additional regulations for the neighborhood that, while not completely suffocating new development, surely makes it more difficult to expand housing options, in particular affordable ones.

HPRB shouldn’t be so narrowly focused on preservation

This application-based system might work if the deciding body, the HPRB, acted reasonably to balance the needs of a growing city with their mission of protecting DC’s historic resources. Unfortunately, that is not the case. If you review HPRB's record and decision making criteria, you find an organization very narrowly focused on preservation with little to no formal consideration for other important city priorities.

Other District agencies draft a variety of plans that are supposed to work in concert to make the city a better place, such as the District Department of Transportation’s Move DC, or the Department of Energy and Environment Sustainable DC. It even has a super-plan called the Comprehensive Plan which, among other things, is meant to organize, balance and direct those plans.

When making decisions on say a road or park space, other agencies consider the needs of all of these plans, evaluate all of the priorities and balance them. This is not the case with the HPRB, which is particularly siloed and focused on simply deciding if a pending application is worthy of historic status or not.

This leads to a high approval rating of historic district applications, especially as it is the job of HPO staff to support applicants in improving their applications. In fact, in many of cases where an designation attempt did not pass, it was not because of the HPRB but instead because the applicants withdrew their applications after facing resistance from affected neighbors (Chevy Chase in 2008, Eckington in 2016, for example).

It makes sense that the HPRB should prioritize its mission of analyzing and protecting DC’s historic places. But to do so without having the additional mandate to even consider additional city-wide priorities (such as having enough homes or affordable homes or increasing our use of solar panels) is problematic.

Preservation in DC could be smarter

Two simple reforms could go a long way in this situation. First, DC agencies could be more proactive about identifying and prioritizing historic properties. Rather than continuing to simply add to the stock of historic buildings as each neighborhood application comes in, why not catalogue what is currently designated historic, identify other key potential sites, and set some priorities for the future based on what you find?

Second, HPRB should be less siloed in its decision making and could be made to consider other already identified city-wide priorities. This change to HPRB’s mandate, coupled with a more proactive system, could go a long way to better balance the needs of a growing city with the goals of preservation.

There are other reforms we think should be considered as well and we’ll explain those in future posts. In the meantime, if you agree that change is needed, sign our petition and give us additional ideas in the comments below.