It went on to advertise that expert panelists would
present case studies that dealt with the challenges of adaptive re-use: energy efficiency, sustainability, code
compliance, and accessibility. ‘Sign me
up,’ I thought, ‘this is what I’m all about!’ The repurposing of existing buildings for new
or continued use is the most important issue on the horizon of the built
environment today. And preserving the “historic features that define the
character of significant cultural resources” is a challenge close to the heart
of those engaged in such endeavors. 
Before I get to the point, here’s some background for
the uninitiated or a refresher for my colleagues in the field. The Secretary of the Interior provides four
distinct but interrelated approaches to the treatment of historic properties: preservation, rehabilitation, restoration,
and reconstruction. Preservation is the
most desirable approach and focuses on the maintenance and repair of existing
historic materials and retention of a property's form as it has evolved over
time. Rehabilitation acknowledges the
need to alter or add to a historic property to meet continuing or changing uses
while retaining the property's historic character. Remember that last part—retaining the property's historic character—it’ll be important
later.
I was surprised that the presentation was on the
standard of rehabilitation … poster boards on easels spelling them out in bold
letters. Literally, it was on the standard of rehabilitation, not preservation. Two historic preservation consultants presented
one tax credit project after another and one slide even listed substitute
materials that were gaining acceptance: Azek instead of wood, copper-colored aluminum
sheet metal, aluminum windows instead of steel, Hardi-board instead of cedar
clapboard. An attendee in the audience raised the
question of the all-too-common practice of replacing the fenestration in
large-scale adaptive re-use projects, but the issue of wooden replacement
windows was dismissed as we were told that no “cost effective” options are
available. The presentation should have
been titled Pushing the Envelope: What
you can get away with when pursuing preservation tax credits.
According to the National Park Service’s website, the
Federal Historic Preservation Tax Incentives program “encourages private sector
investment in the rehabilitation and re-use of historic buildings ... It has
leveraged over $62 billion in private investment to preserve 38,000 historic
properties since 1976.” The heading on
the NPS web page advertises Tax Incentives for Preserving Historic Properties,
but that’s not technically correct. Our
government offers a 20% income tax credit for “the rehabilitation of historic, income-producing buildings that are
determined by the Secretary of the Interior, through the National Park Service,
to be ‘certified historic structures.’” 
The Massachusetts Historical Commission and the
National Park Service review the proposed rehabilitation work to ensure that it
complies with the Secretary’s Standards for Rehabilitation. The tax credits can be applied to offset the
project investment or sold privately.
IRS regulations significantly limit the ability of non-profits to redeem
the credits, for obvious reasons—you know, they don’t pay taxes. However, they may pursue them and then “syndicate”
them. Syndicate is a fancy word for “sell”
in this context. Interestingly, many of
the projects presented were for non-profits. The presenters also stated that
Bank of America is the largest buyer of tax credits, nationally. 
The modern day robber barons strike again, and it comes
out of our pockets—yes, our pockets—that's
where tax credits come from. Since we're
all invested in this system, I'd like to see the Standards of Rehabilitation,
if not elevated to Preservation, actually enforced. Why give in immediately to the replacement of
the fenestration to satisfy some empty goal of LEED certification? They give points for replacement windows, but
not restoration of the existing sash and frames. LEED isn’t interested in full life cycle
analyses of systems. And the designers
of these projects are looking for low- and no-maintenance solutions to the
issues of the envelope as they fly the “green” flag of the USGBC.
In the beginning I quoted the Standards: “Rehabilitation
acknowledges the need to alter or add to a historic property to meet continuing
or changing uses while retaining the
property's historic character.” And
the session description that indicated that preserving the “historic features
that define the character of significant cultural resources” is at the heart of
such endeavors. What are these features?
The walls, the roof and the fenestration are the character-defining,
distinctive features of the envelope. Rehabilitation
standard number six states that “where the severity of deterioration requires
replacement of a distinctive feature, the new feature will match the old in
design, color, texture, and, where possible, materials.” Translated: In-Kind. Yet, here are the experts promoting the
wholesale replacement of said features in a manner other than in-kind.
Consider the Village Hall in North Hadley,
Massachusetts. A developer wants to buy
it and repurpose it into an income-producing property. He can create a Disney World version of an
Italianate by replacing the standing-seam roof with copper-colored sheet metal,
the trim, moldings and cornice with Azek, the original clapboard siding with
Hardi-board, and the 150 year old windows with something double-paned and clad
in anodized aluminum. And he can obtain
tax credits as a reward, selling them if he wants to a bank. Or he can use them to offset the costs
associated with his private investment. 
If the alternative is losing a building like this to demolition
by neglect, is the Disnefication better?
You bet it is. I don’t blame the
developers for this. That would be like blaming
a lion for attacking a zoo keeper who sticks her arm in the cage. They’re animals, it’s what they do, devouring
whatever they can without a second thought.
As preservationists, it is our job to safeguard the significant,
character-defining features of historic buildings. When the state of deterioration is such that
replacement is warranted, we must demand replacement in kind.
We need to resist and reverse this trend of pushing the
envelope, assisting developers as they push harder and farther to see what they
can get away with. We must hold the
line: “Where the severity of
deterioration requires replacement of a distinctive feature, the new feature
will match the old in design, color, texture, and, where possible, materials.” They
still make materials with wood, copper, and slate. If private entities want to profit from these
buildings, and gain tax credits in the process, make them follow the Standards.
Don’t be a historic preservation consultant. Be a historic preservationist.
Don’t be a historic preservation consultant. Be a historic preservationist.
