April 24, 2019 | Speak Up Regarding Proposed Changes to the National Register of Historic Places
Historic Warehouse District, Cleveland, Ohio
As you may have seen from our partners at the National Trust for Historic Preservation, the National Park Service is seeking public comment on proposed revisions to Title 36 of the Code of Federal Regulations, parts 60 and 63, governing the listing of properties in the National Register of Historic Places. These revisions to how properties are designated would negatively impact the preservation of historic places around the country and ability to access the Historic Tax Credit program, including in our downtowns and neighborhood commercial districts.
Please consider speaking up against these proposed rule changes.
Currently, a majority of the private property owners in a potential district must support a historic district nomination on a “one vote per person” basis. The proposed changes would alter the requirements for historic district designation in two substantial ways impacting Main Street communities:
1) The proposed change would allow private owners of the majority of land area within a proposed district to object to the district listing. This would give large landowners – developers, downtown anchors, industrial owners – the ability to impede the listing of the entire district, thereby impeding the ability of individual property owners to access the benefits of historic district designation.
The Historic Warehouse District in Cleveland, Ohio, is a clear example of how this revision could negatively impact commercial corridor revitalization. In 1982, the district was added to the National Register of Historic Places despite the fact that major property owners within the district’s boundaries—who owned parking lots—did not support the designation. At the time of the district’s listing, only six of 60 buildings were occupied. Today, only four buildings have not been renovated, and the district’s listing has spurred further reinvestment in the downtown:
"The Warehouse District was a learning laboratory for Cleveland’s revitalization. If the rules envisioned were in place at the time, this historic district and the city’s revitalization may not have happened.” – Tom Yablonsky, Executive Director of Historic Warehouse District and Historic Gateway Neighborhood
2) The revisions also include the ability for federal agencies to block listing on the National Register, including for federal properties within proposed historic districts. This, too, would have negative impacts for communities attempting to create national register districts.
Federal properties dot our communities and appear in our districts in ways that should be compatible with, rather than opposed to, revitalization. In Washington, Mo., for example, a downtown post office, contributing to the National Register historic district, was transformed into the offices of the Main Street program and a contract postal unit, bringing income and foot traffic to the heart of the district.
Both changes have the potential to allow singular objections to derail an entire historic district listing. In prioritizing the objections of large landowners or federal agencies, these changes negatively impact individual property owners and comprehensive commercial district revitalization efforts.
Listing on the National Register of Historic Places is required to access the benefits of the Historic Tax Credit program, a vital tool for closing financing gaps and leveraging investment in historic structures. The proposed revisions would alter the requirements of property owner objections to historic district designations and make it more difficult for a Main Street district to secure tax credits.
Main Street advocacy was instrumental in retaining the Historic Tax Credit in 2017. Act now to ensure your community – and other Main Street communities – can access these incentives for development projects. If you’ve you had a successful tax credit project in a historic district or are currently attempting to assemble the resources to create a district or utilize tax credits, use the comment form here to speak up and share your story before the April 30, 2019 public comment deadline.
For more information on these proposed changes, read more from the National Trust for Historic Preservation and Preservation Action.