The Chevy Chase DC historic district application fails on the merits

On October 16, 2023, the Chevy Chase DC Conservancy (CCDCC) filed an application to designate the Chevy Chase DC neighborhood a historic district. If approved by the District’s Historic Preservation Review Board (HPRB), this designation would limit and regulate the kinds of changes that could be made to the exterior of buildings in the neighborhood, including the height and mass of expansions and new construction.

For HPRB to approve a historic-district application, its applicants must show that the area in question meets at least one of the designation criteria laid out by federal preservation law. In this case, the applicants are applying under the following:

Criterion A: For being “associated with events that have made a significant contribution to the broad patterns of our history.”

Criterion C: Applicable when a district “embodies the distinctive characteristics of a type, period, or method of construction or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components lack individual distinction.”

These criteria are very broad, and this iteration of HPRB appointees, and current Historic Preservation Office (HPO) staff, have shown a willingness to interpret criteria quite liberally and “massage” historic evidence to make them appropriate for a vote of approval from HPRB. But even given loose precedents, the applicants fail to present evidence that the proposed Chevy Chase historic district qualifies under either of their chosen criteria.

Criterion A: History

Here is the entire argument the applicants make for Chevy Chase being associated with “events that have made a significant contribution to the broad patterns of history:”

“The Chevy Chase Historic District meets National Register Criterion A with Community Planning and Development as its Area of Significance for the dominant role it played in the urban planning and development of upper Connecticut Avenue NW in Northwest Washington, D.C. Through the construction of Connecticut Avenue and the development of the Rock Creek Railroad, these new suburbs within the Chevy Chase Historic District were connected with downtown Washington. To create the 130-foot-wide Connecticut Avenue, laborers dug a total of five miles of roadbed over difficult terrain and erected two large iron bridges, one over Klingle Valley and the second over Rock Creek just south of Calvert Street. This massive project was completed in just a few short years and, in the process, succeeded in opening up Connecticut Avenue and the entire northwest section of the city to development. In addition to Chevy Chase DC, the neighborhoods of Woodley Park, Cleveland Park, and Forest Hills are all a result of this ambitious project.”

This is not a persuasive case for the historic merits of Chevy Chase as a neighborhood; this is simply the history of Connecticut Avenue. Suburban development along streetcar lines is a consistent pattern of local and national history, and by nature of being one of those suburbs Chevy Chase is technically associated with it. But the National Register guidelines, which support the federal preservation criteria (which the District’s parallel criteria are are largely copies of), make clear that “mere association with historic events or trends is not enough, in and of itself, to qualify under Criterion A: the property’s specific association must be considered important as well.”

The applicants fail to make that case for how Chevy Chase uniquely represents any given history, and their presented facts, unfortunately, point clearly in the opposite direction. Chevy Chase was not one of the first streetcar suburbs in DC. That honor goes to Anacostia (then Uniontown), Mount Pleasant, and LeDroit Park, all historic districts already. Chevy Chase wasn’t even the first of the Connecticut Avenue-specific streetcar suburbs referenced in the application—that was Cleveland Park, also already a historic district; it’s merely one of a handful of neighborhoods that followed. Woodley Park (also already designated historic), Forest Hills, and Washington Heights all share the same association. A historic district’s burden of proof is on the applicants to explain why Chevy Chase’s particular version of that history rises above these other neighborhoods, or at the least adds something distinct not captured by existing historic districts that tell this same story.

The contrast is starkest when compared with examples of historic districts in DC that meet this associated-and-important charge much more clearly: U Street, a cultural and economic haven for Black Washingtonians during the Jim Crow era and beyond; Gallaudet’s campus, representing a unique touchstone in the history of higher education and the Deaf community; even Union Market’s commercial and agricultural history, which charts changes in local markets and commerce. In these examples, the history these buildings are landmarked to preserve is directly and uniformly embodied by the buildings themselves. You could not tell these stories with different buildings in the same neighborhood, and certainly not with other neighborhoods.

Every neighborhood in DC is an example of some pattern of history, but that’s not, ostensibly, what our laws are interested in. The charge of preservation law is supposed to be to find distinctive and important examples.

Criterion C: Architecture

The applicants’ case for Criterion C, Architecture, is similarly lacking:

The Chevy Chase Historic District meets National Register Criterion C with Architecture as its Area of Significance as an architecturally intact and cohesive early twentieth century, planned residential suburb. The Chevy Chase Historic District is characterized by its modified grid plan, tree-lined streets, sizeable lots with detached and semi-detached dwellings representing a variety of early- to mid-twentieth-century design styles, its neighborhood-based commercial corridor, and an array of institutional buildings that were built for and contribute to a comprehensive community. The main thoroughfare, Connecticut Avenue NW, is defined both by its local commercial district and the large apartment buildings that line both sides of the street. Side streets radiating off Connecticut Avenue NW are lined with residential dwellings. The dwellings are characterized by eclectic revival styles, such as Colonial Revival, Dutch Colonial Revival, Spanish Colonial Revival, Classical Revival, Renaissance Revival, and Tudor Revival. Alleys cut through each block, creating service lanes to access garages and other utilitarian areas at the rear of the lots.

This is, once again, a description of Chevy Chase, not an argument. Every neighborhood has buildings and streets. Under Criterion C, an application for a historic district is supposed to explain why a grouping of structures is exceptionally notable and deserving architecturally.

Criterion C’s definitional clauses include: “embodies the distinctive characteristics of a type, period, or method of construction or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components lack individual distinction.” The applicants fail to make a case for inclusion in the District Inventory or National Register under any of those clauses.

Consider, in contrast, the Foxhall Village historic district, which is notable for being composed almost exclusively of uniform rowhouses in the Tudor Revival style and is the only neighborhood of its kind in the District. Foxhall Village “embodies the distinctive characteristics of a type, period, or method of construction.” Chevy Chase, which contains a mish-mash of styles built over 60 years, does not.

Similarly, the applicants can’t summon the “work of a master” clause, because, as their application lays out on page 5, the proposed district is an amalgamation of three different subdivisions laid out by two different planners and built lot-by-lot by over 150 different architects and builders.

According to the National Register guidelines, the next clause, about “possess[ing] high artistic values,” is a particularly high bar: “A property is eligible for its high artistic values if it so fully articulates a particular concept of design that it expresses an aesthetic ideal. A property is not eligible, however, if it does not express aesthetic ideals or design concepts more fully than other properties of its type.”

A DC historic district here that meets this standard is the Financial Historic District on 15th St NW, a “cohesive array of monumental Beaux Arts-style buildings” which were “built to impress” by that era’s financial elite to project their power through architecture. To support this, the Financial Historic District’s nomination included contemporary evidence of the buildings being “acclaimed for their architectural beauty.” The Chevy Chase nomination, on the other hand, presents no such evidence; while it faithfully documents the architectural details of relevant structures, there are no claims within it that the buildings there are anything other than modest examples of their disparate styles, which the National Register guidelines says is a no-no: “A building that is a modest example (within its historic context) of the Craftsman Style of architecture…would not qualify for high artistic value.”

The final architectural-criterion clause, that the proposed district “represents a significant and distinguishable entity whose components lack individual distinction,” is specifically crafted for historic-district applications, because, even if the architecture of individual buildings may not rise to the standard of the previous clauses, it sanctions the concept of a whole being greater than the sum of its parts. A good example of a district that fits this description is Union Market, where the individual industrial buildings may not be the most notable on their own, but “as a wholesale market complex,” the district “represents a building type that is unique to the District of Columbia.” Chevy Chase’ architecturally common individual buildings do, of course, make up a neighborhood, but they are no more architecturally significant as a whole.

A clear comparison

Perhaps the best comparison for understanding how Chevy Chase’s application does not meet the National Register’s standards is a very recent historic district application that came before the board, for another Ward 3 neighborhood.

Just as the Chevy Chase applicants have done, Colony Hill residents applied under Criterion A for social history, arguing that their neighborhood represented “the evolution that occurred in residential development in Washington, D.C., during the twentieth century,” specifically as an example of the rise of suburban neighborhoods in the city. But just like Chevy Chase, the Colony Hill applicants failed to make the case for why their particular suburb was uniquely noteworthy.

When the Colony Hill application came before HPRB in January of 2021, members found it unpersuasive and voted 5-3 against designating Colony Hill historic. This was shocking—it was the first time a historic district has ever been voted down by HPRB members. After the applicants protested, however, HPRB re-opened deliberations the following week and reversed its initial decision. This time, members took separate votes on each individual criterion. A 4-3 majority again voted against the social history criterion, but the application was approved under the criteria related to architecture, specifically under the argument the neighborhood was the work of a master architect, Horace Peaslee, and a cohesive, uniform collection of outstanding examples of Colonial Revivalist homes.

Even though HPRB ultimately approved the Colony Hill historic district, the contested votes were still unprecedented and prompted at least one member who voted in favor to reflect on whether she and her colleagues had come up against a minimum threshold. During deliberation, seven-year HPRB member and former chair Gretchen Pfaehler mused, “This is really a fine hair … it’s just I feel like we’re close to crossing this. I don’t know if we’re clearly across it, I think we’re on the line.”

If Colony Hill represents the line of legitimate applications for historic districts, Chevy Chase obviously crosses it. Applicants for a Chevy Chase historic district are hindered by the same weakness in their social-history argument as Colony Hill’s proponents and don’t have an architectural case to fall back on. Chevy Chase is neither a cohesive, representative collection of buildings, nor the work of a singular master; it does not meet the “aesthetic ideal” standard of the “high artistic value” clause, and is not more significant simply for being a collection. Both the text of preservation law and the clear precedent recently set by HPRB reinforce that this nomination should fail on the merits.