INTERPRETING THE SECRETARY OF THE INTERIOR'S STANDARD FOR REHABILITION Page Separator
Interpreting The Secretary of the Interior's Standard
for Rehabilition
Box #
43
Folder #
4
Delray SO 8373
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
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Volume I
Cover drawing: Sharon C. Park, AIA
Interpreting
the Secretary of the Interior's
Standards for Rehabilitation
Introduction
One of the most daunting tasks that a local historic preservation board faces is design review. The
ten Secretary of the Interior's Standards for Rehabilitation have been incorporated into many local
historic preservation ordinances to guide design review. These Standards were developed by the
National Park Service in the mid 1970s and continue to form the basis for review of historic building
rehabilitation projects under the federal rehabilitation tax incentives program, as well as a variety of
other federal and state funded or licensed programs.
The Standards pertain to historic buildings of all materials, construction types, sizes and occupancy,
and address the exterior and interior of buildings, related site and landscape features, as well as
attached, adjacent or related new construction. In 1997, the Park Service developed the Guidelines
for Rehabilitating Historic Buildings to help with application of the Standards during the project
planning stage by providing general design and technical recommendations.
Even with this additional guidance,there are specific design issues that cannot be clearly addressed
within the framework of the generalized rehabilitation model provided by the Standards and
Guidelines. Beginning in 1980, such issues were addressed by the enclosed series of case studies
Ale entitled Interpreting the Secretary of the Interiors Standards for Rehabilitation. These case studies
explain decisions made by the National Park Service in considering appeals of rehabilitation projects
denied certification under the rehabilitation tax incentives program. It is important to note that the
enclosed Interpreting the Standards bulletins are case-specific and are not necessarily applicable
beyond the unique facts and circumstances of each case. Nonetheless, they have significant value in
providing insight regarding the manner in which the National Park Services evaluates compliance
with the Standards.
An understanding of the Standards and their application is critical for all members of a local historic
preservation board. Without such knowledge, it will be impossible to render consistent and fair
decisions regarding the appropriateness of proposed work. Board and local program staff members
are encouraged to review these enclosed case studies and use them as a reference tool when
considering design treatments that are not clearly consistent with the Standards.
For additional information and guidance on technical preservation and rehabilitation techniques for
historic buildings, contact the architectural staff of Bureau of Historic Preservation:
Bureau of Historic Preservation
R.A. Gray Building, 500 South Bronough Street
Tallahassee, Florida 32399-0250
telephone: (850) 487-2333
fax: (850) 922-0496
e-mail: wmarder@mail.dos.state.fl.us or dferro@mail.dos.state.fl.us
111 This material is not copyrighted and can be reproduced without penalty. Normal procedures for
credit to theauthors and the National Park Service should be followed.
INTRODUCTION
"Interpreting the Standards" bulletins were initiated in April 1980 by the Preservation
Assistance Division (then Technical Preservation Services Division) to explain
rehabilitation project decisions made by the National Park Service, U. S. Department
of the Interior. Rather than describe every aspect of the overall rehabilitations in
great detail, the bulletins focus on specific issues—alterations to storefronts, through-
the-wall air conditioning, interior alterations—that posed problems in the review
process. To this extent, then, the bulletins may emphasize controversial aspects of a
project and neglect, or make only passing reference to, other aspects of the work that
posed no special concerns.
The following ten Standards for Rehabilitation are used by the Secretary of the
Interior to determine if a rehabilitation project qualifies as "certified rehabilitation"
pursuant to sections 48(g), 167(o), and 191 of the Internal Revenue Code. The
Standards comprise the sole regulatory basis for determining whether or not a
rehabilitation is consistent with the historic character of the structure or the district
in which it is located. The applicable Standards as well as project conformance or
nonconformance to those Standards is referenced at the top of each bulletin in italics.
1. Every reasonable effort shall be made to provide a compatible use
for a property which requires minimal alteration of the building,
structure, or site and its environment, or to use a property for its
originally intended purpose.
2. The distinguishing original qualities or character of a building,
structure, or site and its environment shall not be destroyed. The
removal or alteration of any historic material or distinctive
architectural features should be avoided when possible.
3. All buildings, structures, and sites shall be recognized as products of
their own time. Alterations that have no historical basis and which seek
to create an earlier appearance shall be discouraged.
4. Changes which may have taken place in the course of time are
evidence of the history and development of a building, structure, or site
and its environment. These changes may have acquired significance in
their own right, and this significance shall be recognized and respected.
5. Distinctive stylistic features or examples of skilled craftsmanship
which characterize a building, structure, or site shall be treated with
sensitivity.
6. Deteriorated architectural features shall be repaired rather than
replaced, wherever possible. In the event replacement is necessary, the
new material should match the material being replaced in composition,
design, color, texture, and other visual qualities. Repair or replacement
of missing architectural features should be based on accurate
duplications of features, substantiated by historic, physical, or pictorial
evidence rather than on conjectural designs or the availability of
different architectural elements from other buildings or structures.
7. The surface leaning of structures shall be undertaken with the
gentlest means possible. Sandblasting and other cleaning methods that
will damage the historic building materials shall not be undertaken.
8. Every reasonable effort shall be made to protect and preserve
archeological resources affected by, or adjacent to any project.
9. Contemporary design for alterations and additions to existing
properties shall not be discouraged when such alterations and additions
do not destroy significant historical, architectural or cultural material,
and such design is compatible with the size, scale, color, material, and
character of the property, neighborhood or environment.
10. Wherever possible, new additions or alterations to structures shall
be done in such a manner that if such additions or alterations were to be
removed in the future, the essential form and integrity of the structure
would be unimpaired.
"Interpreting the Standards" bulletins are designed for use primarily by program
administrators at the State and Federal level who make recommendations and
decisions on rehabilitation projects. The bulletins are case-specific and are not
necessarily applicable beyond the unique facts and circumstances of each case. The
bulletins are explanations of past decisions and should not be considered as the basis
for approving or denying other projects. The procedures for obtaining certifications of
rehabilitation are explained in Title 36 of the Code of Federal Regulations, Part 67.
These regulations control in the event of any inconsistency with these bulletins.
Bulletins are arranged in order of issuance. The number assigned to each is composed
of the fiscal year in which the bulletin appeared and an overall cumulative number
(e.g., 80-001, 80-002). Each bulletin bears the name of the author. The index keys the
bulletins to particular Standards and to such topics as Abrasive Cleaning, Roof
Alterations, and Windows. A looseleaf format has been followed in order to allow for
easy removal for xeroxing as well as for easy insertion of future supplements.
This material is not copyrighted and can be reproduced without penalty. Normal
procedures for credit to the authors and the National Park Service are appreciated.
"Interpreting the Secretary of the Interior's Standards for Rehabilitation," has been
developed under the technical editorship of Lee H. Nelson, AIA, Chief, Preservation
Assistance Division, National Park Service, U.S. Department of the Interior,
Washington, D.C. 20240. Comments on the usefulness of this information are
welcomed and can be sent to Mr. Nelson at the above address.
Additional information and guidance on technical preservation and rehabilitation
techniques for historic buildings may be found in the Preservation Briefs, Technical
Reports, and Preservation Case Studies developed by the Preservation Assistance
Division. For a complete list of publications including price and GPO stock number
information, write to: Preservation Assistance Division, National Park Service,
Washington, D.C. 20240.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 80-001
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance; nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (conformance;
nonconformance)
Subject: PORCH ENCLOSURES
Issue: Enclosing previously open porches is often seen as an easy way to provide
additional interior space at relatively low cost to an owner. Where such porches
contribute to the architectural character of a building or are a distinctive feature of a
district, NPS takes the position that enclosing such spaces may represent a significant
loss in character. Factors weighed in such a determination include location of the
porch (whether it is on prominent facade or not) and the proposed enclosure treatment
(whether existing historic fabric is retained and whether the open spaces, when
enclosed by glass, still give the appearance of a porch). Depending on the particular
situation, such a treatment may result in disapproval of the overall project.
Application: A 19th-century mansion within a historic district was recently converted
to office space, and part of the rehabilitation involved enclosing the second floor of a
two-story porch located at the rear of the building. Because this facade was a
prominent feature of the building, considerable care was taken to retain the form and
integrity of the porch. Large glass walls were placed behind the porch's columns and
balusters, with most of the framing members and meeting rails hidden behind the
columns and balustrade (see illus. 1 and 2). None of the columns or balusters was
removed or altered in the process. Because of the sensitive manner in which the porch
was enclosed, NPS approved the project.
A second project, also in a historic district, involved the conversion of servant
quarters of a large house into rental residential use. Plans called for the enclosure of
a two-story, four-bay porch that, while at the rear of the property, nonetheless was
visible from the street. Clapboarded walls with 6/6 windows were inserted between
the columns and behind a simple balustrade. While it was possible to discern the
original configuration of the porch, what had been an open area--a void now read as a
solid wall (see illus. 3).
NPS identified the two-story gallery as a distinctive feature not only of the building
but of many other 19th-century buildings in the area. NPS determined that the
historical and architectural character of the building had been significantly altered by
enclosing the prominent two-story porch with dapboarding and disapproved the
project on those grounds.
80-001
Following this determination, the owner supplied photographs of the building prior to
rehabilitation showing that several porch bays had been enclosed by a previous owner
some years before. NPS subsequently approved the project because the current owner
was not legally responsible for the initial alterations to the porch.
Prepared by: H. Ward Jandl, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 80-002
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: ALTERATIONS TO THE ENVIRONMENTAL CONTEXT OR SETTING
Issue: Increasingly, historic residential districts and individually listed National
Register buildings located in landscaped settings are facing development pressure in
the form of new construction or expanded onsite parking. The environmental context
of an individual building or the relationship between structures and open space within
a district are often significant aspects of the historic character of a building or a
district.
In planning for rehabilitation and adaptive use of historic buildings, distinguishing
landscape features that have traditionally linked buildings to their environments
should be retained (Standard 2). Features such as parks, gardens, street lights, signs,
benches, walkways, streets, alleys and building set-backs may be considered part of
the distinguishing original qualities or character of a building or a district. New
construction and expanded parking, if needed, should be located unobtrusively and with
the least amount of alteration to historic landscape features.
Application: The rehabilitation of an 1840 Greek Revival mansion was determined not
to meet the Secretary of the Interior's Standards for Historic Preservation Projects, in
large part because the physical setting for the building was drastically altered in the
course of rehabilitation. Individually listed in the National Register and termed"one
of the most architecturally significant structures" in the State, the classically
designed masonry building historically was within a landscaped yard with a double row
of magnolia trees planted from the front steps to the street. Although the magnolia
trees no longer existed at the time rehabilitation began, the walkway extending across
an expanse of lawn with trees retained the landscaped context of the house (see illus.
1).
Rehabilitation plans included restoration of the exterior of the house and substantial
new construction of clustered townhouses flanking the historic house for the depth of
the lot. Extensive paved parking areas were added to the front and rear of the
historic house, leaving little remaining green space (see illus. 2). NPS determined that
the landscaped setting for the house was a distinguishing original quality that should
have been retained in the course of rehabilitation. Alternative parking locations,
fewer new townhouses, and sympathetic landscaping could have resulted in a more
sensitive and successful reuse project. The restored exterior of the mansion now
appears out of context and overwhelmed by the parking lots and new construction.
Upon appeal of the denial of certification, the hearing officer agreed with the finding
that the Standards had not been met, yet because of mitigating factors certified the
rehabilitation. Primary consideration was given to the fact that the Standards had not
80-002
been published by the Department at the time work began on the building. The appeal
decision stated that "environmental damage to the property is extreme as a result of
the size and placement of the parking areas" and that the integrity of the setting "has
been severely compromised. I would not expect to make a similar finding with regard
to projects where the owner had full and proper access to the Secretary of the
Interior's Standards for Rehabilitation."
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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'II -r1 80-002
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 80-003
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (conformance)
Subject: STOREFRONT ALTERATIONS
Issu: When renovating commercial buildings with a storefront on the ground floor,
owners and their architects are often faced with a question of what to do when
original or early storefronts no longer exist or are too deteriorated to save. In these
situations, NPS recommends that the commercial character of the building be retained
through 1) contemporary design on the ground floor that is compatible with the
historic structure in scale, design, materials, color and texture; or 2) an accurate
restoration of the missing storefront based on historical research and physical
evidence. Retention of a building's commercial qualities is especially important when
seen in the context of an entire streetscape. Contemporary treatments that
substitute masonry for glass on the ground floor or that introduce new design elements
incompatible with the historic commercial and architectural character of the building
or that alter its relationship with the street may result in denial of the overall
project.
Application: A two-story Victorian masonry building was denied certification because
the new ground floor treatment significantly altered the historic commercial
character of the building (in violation of numbers 2 and 9 of the Secretary of the
Interior's Standards for Rehabilitation).
This new design repeated the arched window motif of the second floor and
substantially reduced the amount of glass at the street level. The building, and others
like it in the historic district, originally had a plate glass storefont at the ground level
with a pronounced cornice separating it from the upper floor (see illus. 1).
Traditionally, the architectural elements on the second floor--notably the cast iron
decorative elements—were not repeated on the ground floor (although an adjacent
building had been recently renovated in this fashion). The historic commercial
qualities of the building, characterized by a wide expanse of glass on the ground floor,
were largely destroyed by the new, predominantly masonry treatment at the street
level (see illus. 2). Even though little or no significant fabric existed at the street
80-003
level when rehabilitation was undertaken, the alterations were determined to have
changed the character of the building and to be incompatible with the district (see
ill us. 3).
On appeal, the initial certification denial was sustained by the hearing officer.
Prepared by: H. Ward land', TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
80-003
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Department of the Interiorhe Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 80-004
Applicable Standard: 3. Recognition of Historic Period (nonconformance)
Subject: USE OF HISTORICALLY INAPPROPRIATE DETAILS
Issue: In an effort to "improve" the appearance of their properties, owners of historic
buildings occasionally utilize architectural details that create an earlier appearance
than is appropriate. Standard 3 states, "All buildings, structures, and sites shall be
recognized as products of their own time. Alterations which have no historical basis
and which seek to create an earlier appearance shall be discouraged." In planning a
rehabilitation project, property owners should evaluate the historical and architectural
significance of their buildings to determine appropriate stylistic details. National
Register forms and photographs should be consulted and other sources of historical
documentation explored to establish the types of decorative ornament in keeping with
the historic character of a building. By encouraging owners to submit historic
preservation certification applications before work begins, State and Federal
preservation offices can help prevent the "earlying up" of historic buildings.
Application: A turn-of-the-century brick commercial building with Italianate details
was to be converted into law offices. The major decorative elements of this simply
detailed, two-story building were its bracketed metal cornice, brick corbelling, and
one-over-one windows on the second floor. A storefront of glass and metal, installed
in the 1950's, extended the full width of the ground floor (see illus. 1). Plans called for
the replacement of existing second floor windows with Georgian nine-over-nine sash
and the installation of two matching windows with keystone lintels and a pedimented
doorway with flanking pilasters on the ground floor (see illus. 2). NPS determined that
the proposed rehabilitation did not meet Standard 3, citing the Georgian detailing as
inappropriate to the character of the building.
Although the building did not have significant historic fabric on the street level prior
to rehabilitation, the proposed design for replacing the storefront with two
residential-type windows and historically inaccurate architectural details would have
dramatically changed the appearance of the building. NPS was further concerned that
the proposed treatment might establish a precedent for replacing other storefronts on
the street with similar door and window treatments. In appealing the decision, the
owner presented photographs of other buildings in the multiple resource nomination
that had pedimented entryways and multipaned windows. These structures, however,
were earlier than the building in question, and the hearing officer sustained the
determination by NPS that the proposed rehabilitation would not be consistent with
the historic character of the building.
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
80-004
1. The existing condition of the
- �7 - building. The major decorative elements
of this turn-of-the-century simply
. - --_�-: - "-rt ''-=-- : detailed, two-story building are its
r �.` ri-:~ = N.
=w' r_` = ..: , bracketed metal cornice, brick corbelling,
._. ---+ - '= and one-over-one windows on the second
i- =--__ _ �.,., - floor. The storefront of glass and
�= =j^ - ---• metal was installed in the 1950s.
s-: ''1 •
•
_.-____ �_rt... =;'y_-•mac...__ _
•
--
{ FL. i y y �.� yJC.
NUL: I {1 Li l.i .1 L JJ `L 11�-
Iina_11 I lr—!(L 11- d L_I G 11.
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Kew
2. The proposed design. The proposedM4:1\ 2^ "r
rehabilitation design called for the 111 El
installation of Georgian detailing as seen I4s
in the nine-over-nine window sash with
keystone lintels and a pedimented doorway ;°
with flanking pilasters. As there was no . grate
historical basis for these details, the .__ r--- --1,�
project was denied certification.
�DRicK -ro Mara1 E5a r-*dr
1 -- 1 IF AVAIL•
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Department of the Interiorhe Secretary of the Interior's
Washington, D.C.
rStandards tor Rehabilitation
Number: 80-005
Applicable Standard: 3. Recognition of Historic Period (nonconformance)
Subject: USE OF HISTORICALLY INAPPROPRIATE MATERIALS
Issue: In rehabilitating historic buildings, property owners occasionally utilize
materials that are inappropriate to the style and character of their building. Standard
3 states: "All buildings, structures, and sites shall be recognized as products of their
own time. Alterations which have no historical basis and which seek to create an
earlier appearance shall be discouraged." Before undertaking a rehabilitation project,
the property owner is encouraged to evaluate the historical and architectural
significance of his or her building and to determine which materials are appropriate to
its style and period. This may include consulting National Register nomination forms
and photographs and other available sources of historic documentation. It is important
that this research be undertaken, because use of historically inappropriate materials
can dramatically alter the appearance of a building and can lead to disapproval of the
overall project.
Application: A mid-19th century brick house and attached later frame warehouse
addition were converted into three rental apartment units and an effort was made to
"colonialize" the appearance of the buildings (see illus. 1). NPS denied certification of
the rehabilitation based on Standard 3, having determined that the "rustic" wood shake
siding used on the side elevations was historically inappropriate to both the brick
building and the frame addition. While possibly appropriate to 18th-century
Nantucket, the shake siding was out of place on mid-19th century brick structures in
this mid-Atlantic state (see illus. 2).
Having decided to remove the Bricktex that covered the side elevations of both the
house and warehouse prior to rehabilitation, the owner could have repainted the brick
side walls of the house and/or selected a siding for the warehouse similar in
appearance to the remnants of clapboards uncovered beneath the Bricktex. The owner
contended that the wood shake siding was commercially available and improved the
appearance of the buildings.
NPS also determined that the conversion of an industrial elevator shaft on the
warehouse into a residential entrance with French doors salvaged from another
building added to the stylistic confusion of the buildings. The use of colonial details in
windows, doors, and trim along the side elevations of the warehouse and on the fence
and adjoining garage was found to be stylistically inappropriate and highly visible from
the street. The result of the rehabilitation was to obscure the fact that the buildings
80-005
had developed over a period of time through a mixture of commercial and residential
uses. The "improved" appearance actually detracted from the architectural integrity
of the buildings and the neighboring structures in the historic district. The denial of
certification was sustained upon appeal by the hearing officer.
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
80-005
MULTIPANED SASH
1 OVER 1 SASH
BRICKTEX SIDING
A;', ': SHAKE SIDING
`. ems.: �
3
.,44 ,--' : . D . .
,..,...,..:
, ....
. .- - -
, •
f .J - .. ..
I, si•.i .'it,
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. . , ..3-:;..;.e.,-....,,, ,_,.
i ...___ _
_ I i ti: NEWLY ADDED "COLONIAL" TRIM
i •
, :�,� ,---d - PAINTED BRICK
1. Before rehabilitation. Bricktex siding
covered the side elevations of the brick
building and frame addition.
2. After rehabilitation. The "rustic" wood shake
siding installed by the owner was determined to be
historically inappropriate to both the brick building
and the frame addition. The installation of French
doors and use of colonial details on the side
elevations further added to the stylistic confusion of
the buildings.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Department of the Interiorhe Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 80-006
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
3. Recognition of Historic Period (nonconformance)
Subject: INSTALLATION OF ARTIFICIAL SIDING AND LOSS OF DECORATIVE
FEATURES
Issue: When rehabilitating historic frame buildings, property owners are often
tempted to replace or cover wood siding with artificial materials such as imitation
stone, brick veneer, asphalt shingles, and vinyl or aluminum siding. In addition to the
loss of architectural detailing found on historic wood siding (beveling or beading, for
example), installation of artificial siding often results in removal of decorative trim
around doors and windows and under the roof line. Such treatments can alter the
distinguishing original qualities or character of a building, thus violating Standard 2.
The artificial siding can also cause damage to the historic fabric underneath by
trapping moisture and encouraging decay or insect infestation. The loss of these
features can have a cumulative detrimental effect on the architectural character of a
neighborhood or district.
Application: A property owner chose to rehabilitate a two and a half story frame
house dating from 1900 within a historic district to create a single family rental
property (see illus. 1). In an effort to modernize the structure and reduce
maintenance, the owner removed the front porch and installed four inch wide
aluminum siding over the clapboards (see illus. 2). NPS denied certification of the
rehabilitation, stating that the architectural character of the building had been
significantly diminished through the removal of the front porch (typical of many
buildings in the historic district), the installation of aluminum siding over the original
clapboard, and the subsequent loss of wood details. The width of the aluminum siding
did not match the clapboards; the loss of the porch and decorative trim further
detracted from the historic character of the building.
A second project, also within a historic district, involved the rehabilitation of a two-
story frame double house dating from 1820. The original narrow clapboards had been
covered by asbestos siding in the 1920's; however, in rehabilitating the house, the
owner decided to install wide vinyl siding, which was equally inappropriate (see illus.
3). NPS denied certification, supporting the State Historic Preservation Office's
determination that the installation of vinyl siding was incompatible with the historic
character of the building. While it was understood that the frame building was
covered with asbestos siding at the time rehabilitation began, resurfacing the building
with another new material that was unavailable when the building was constructed and
that did not match the original clapboards in size and texture was viewed as a
historically inappropriate treatment. The design of the new storm doors in a colonial
80-006
motif, violating Standard 3, and the chain link fence constructed around the front yard
were additional factors in the denial. The conclusion drawn was that the overall result
of the rehabilitation left little of the historic finishes characteristic of a 19th-century
frame house.
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
80-006
Ar :` s -' 1. First house before rehabilitation.i _- _ Decorative bargeboards, narrow novelty
yY Y ynj'w- '-
., - siding, and front porch characterize this
simple turn-of-the-century frame structure.
le—
: � 4` 1 ,
-•. • � , 1,
•
-'1 .Mew ,.y-. .. K = r ,
— ``^ ' _ .
•
0 111 N t1 •
y 0 I t .i
2. First house after rehabilitation.
The loss of the porch and decorative - ■ i i"
trim, in addition to the installation l I �."`' : �
of aluminum siding, all have had a i ` i I:�r:r1
cumulative negative effect on this .; 1 4 M.. __. • .
certified historic structure. •~ _
.., ` 3. Second house after rehabili-
tation. Installation of wide vinyl
siding was determined to be inappro-
riate to this 19th-century frame
r•; .,.11 structure. Additional inappropriate
'z':: details include the colonial type storm
'�` W C . doors and chain link fence.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 80-007
Applicable Standards: 9. Compatible Contemporary Design for New
Alterations/Additions (conformance;
nonconformance)
Subject: APPROPRIATE LOCATION OF GREENHOUSE ADDITIONS
Issue: To maximize available square footage in rehabilitated historic commercial
buildings, developers often resort to greenhouse or glass-enclosed additions. Such
additions may be incompatible with the historic character of a building, and have a
negative visual impact when located on a prominent elevation, violating Standard 9.
In reviewing proposals for glass-enclosed additions to historic buildings, NPS considers
the location and size of the proposed addition and its overall effect on the appearance
of the historic building. The extent of alteration to the historic building necessary to
attach the new addition and the reversibility of the treatment are also important
factors in determining whether the addition meets the Standards.
Application: In the first project the developer rehabilitating an interconnected group
of buildings individually listed in the National Register of Historic Places, which date
from 1902 and occupy one-third of a city block (see illus. 1), proposed a sidewalk cafe
enclosed in a glass "greenhouse" to be installed along a primary street facade. The
glass-enclosed area was to extend 10 feet onto the sidewalk along a frontage of 65
feet, obscuring part of the ground floor level of the imposing Beaux Arts building to
which it was to be attached (see illus. 2a and 2b). After consulting with NPS, the
State Historic Preservation Office advised the developer that the proposed greenhouse
addition did not meet Standard 9, citing "the visual incompatibility of the light, airy,
open glass lower level with the much heavier, solid Beaux Arts facade above the first
floor level. These two segments of the building (lower 'greenhouse' versus upper Beaux
Arts style facade) would be incompatible in scale, material and character." The State
Historic Preservation Office was also concerned about the impact of this proposal on
the rest of the city block. The developer reconsidered his plans and withdrew the
proposal to install the sidewalk greenhouse.
A second project involves the rehabilitation of an individually designated brewery
complex, dating from the 1890's, which will be adaptively used as a specialty shopping
and entertainment center. NPS approved the proposed rehabilitation work, which
includes a large glass enclosure over a pedestrian plaza at the rear of the complex,
linking the main brewhouse, the keg storage buildings, and the former bottling plant
(see illus. 3). The glass structure was approved in part because it will be located at
the rear of the complex abutting facades of lesser significance than the main facade,
80-007
which faces the city. It is also designed to be freestanding, with its own self-
contained structural system. Finally, little destruction of historic fabric will be
involved because existing openings will be used as connections into the glass structure.
Prepared by: Floy A. Brown, TPS, with Judith Kitchen, Ohio State Historic
Preservation Office.
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
, . , 1
r I _frmum ilimmim ,
80-007
1. Existing south elevation showing _�[r 7 � "_ / s,/ =A_
later storefront additions. r fk-; I� AI= Mil • , C
I -=a:1 1:M 1�1 •ii III
f! = ., a, . . er as 1 *1 a
1-r -r-lrap,t=tt._.- -...1-.,,,-‘.-., =--..---_
i.i-- =-::,..
pasts'
olIIIl .„4, lnuunNll=1 RIMED lq(IIIIIIIID t=1(IIIIDIIDIalD111101Q i
2a. The pro- 11 11170 lm d[Ill JfOdl, 0TIFQ LiQr r
posed projecting S _
greenhouse addi- L ���_
tion was deter-
mined to be �'
- '
incompatible III -
with the Beaux- 1111 — —
Arts design of — ,;�.7"
the building. (� j
. . ,,
,.1 . Li "UFA
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, ,
2b. Section. Note
. ,.: ___` removal of store-
_ ;�= = fronts.
i - 1 .. ' 'T
..ice / '= ` _ z
%, %�. 3. The proposed glass structure
�_�� was approved because it was located
_ - _ _--� at the rear of the complex; with its
-t` own self-contained structural system,
= — „� __'� _ it involves little destruction of
F -- - historic fabric.
•
, x.,--- • IftoRionwiii ,----., - amiczaw----____________ /,
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Paris Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 81-008
Applicable Standard: 3. Recognition of Historic Period (nonconformance)
Subject: ALTERATIONS WITHOUT HISTORICAL BASIS
Issue: Standard 3 states that "All buildings, structures, and sites shall be recognized
as products of their own time. Alterations which have no historical basis and which
seek to create an earlier appearance shall be discouraged." It is generally
inappropriate to copy details and stylistic features from similar neighboring buildings
unless physical research or historical evidence clearly substantiates the suitability of
recreating such an appearance for the building being rehabilitated. This is particularly
true where the details and stylistic features are distinctive and establish the
architectural character of the building. By adopting a"prototype" historic appearance
for rehabilitated buildings within a district, property owners may also be inadvertently
diminishing the architectural diversity of the area.
Application: A rehabilitation was denied certification for tax purposes when the owner
proposed adding an ornate two-story gallery across the front facades of his two 19th-
century buildings (built in 1836; renovated in the 1870s) (see illus. 1 and 2). The
documentation made it dear that the gallery was based not on physical research or
historical evidence but on examples located elsewhere in the historic district. Denial
of certification•was based on Standard 3.
In appealing the decision, the owner pointed to other buildings in the immediate
vicinity that had balconies similar to the one being proposed, using these examples as
justifications for his proposal. The hearing officer sustained the initial NPS
determination that the balcony design was inappropriate for these two buildings,
stating that while other buildings of the period may have been constructed with
galleries, there was no evidence that these particular buildings ever had such a
feature. The owner also contended that the balcony was required to provide a second
means of egress; building plans, however, indicated several other alternative means of
egress that would have less of an impact on the building's historic character, and this
argument was dismissed.
Prepared by: H. Ward Jandl, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-008
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1. This drawing shows the buildings prior to rehabilitation. The fire escape across the
facade is nonhistoric; the altered storefronts are faced with permastone.
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2. This drawing shows the proposed two-story gallery NPS found to be inappropriate.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interiors
Washington, D.C.
[Standards tor Rehabilitation
Number: 81-009
Applicable Standard: 7. Cleaning with Gentlest Method Possible
(nonconformance)
Subject: SANDBLASTING EXTERIOR BRICK SURFACES
Issue: Sandblasting or any other cleaning method that damages historic building
materials is specifically prohibited by the Secretary of the Interior's Standards. It not
only changes the visual qualities of a historic brick wall but is a generally destructive
treatment that erodes the outer surface of brick masonry, thus increasing the
likelihood of water damage. Sandblasting is an irreversible act, which often hastens
the deterioration of the masonry and cannot be considered a preservation treatment.
For these reasons, except where sandblasting was undertaken by a previous owner,
sandblasted projects involving historic brickwork do not meet the Secretary's
Standards and cannot be approved.
In very limited circumstances a sandblasted building can be approved, providing all of
the following four conditions are met: 1) if the owner undertook the abrasive cleaning
prior to the fall of 1977 (when technical information on the dangers of abrasive
cleaning, such as Preservation Brief No. 1 and the Standards for Rehabilitation, was
made widely available) and was unaware of the dangers of abrasive cleaning at that
time; 2) if the overall project is otherwise commendable; 3) if the exterior sandblasted
surface historically had been painted; and 4) if the owner agrees to repaint the
sandblasted surface with an approved paint of a historically compatible color. This
approval has occurred administratively in the appeals process.
Application: A completed preservation project in a historic district, was denied
certification for tax purposes in 1978 after it was learned that sandblasting of the
front facade had been undertaken (see illus. 1). In appealing the decision, the owner's
preservation consultant acknowledged that historically the building had been painted
to protect the particularly soft brick. The owner having begun the protect in early
1977, had been unaware of the dangers of abrasive cleaning while undertaking his
otherwise commendable work. At the recommendation of NPS , the owner agreed to
repaint the brick facade (which had never been exposed) in a color appropriate to
other Victorian structures in the district (see illus. 2). Once this work was completed,
the hearing officer certified the rehabilitation.
Prepared by: H. Ward Jandl, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
.
•
81-009
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d ............_.... , . _- - - - -- - - - -
f•_. R_• tan
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1. The building after sandblasting had removed the ,M ti-`-- - - -_._ --
protective coatings of paint. The soft, low quality
brick had never been exposed.
A Wf
� r; I . t
.111 ■
2. The building after it had been repainted a dark brown •
color compatible with other Victorian buildings in the - '•`
district. Repainting, in this particular case, was seen as < -.:-_ •-rm— .
an appropriate treatment to mitigate the damage caused _.
by abrasive cleaning. • 'd ,? t:t,,: ,ir:gr`e * iit -V s.
Technical ti n Preservation ServicesDDivision
Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 81-010
Applicable Standards: 3. Recognition of Historic Period (conformance)
9. Compatible Contemporary Design for New
Alterations/Additions (conformance)
Subject: NEW CONSTRUCTION AS CONNECTOR INFILL
Issue: Connecting adjacent buildings to form a large complex makes economic sense,
in certain situations, when these smaller buildings can share services, such as
elevators, which would be prohibitively expensive for each building. Such infill
construction, however, should not destroy significant historical, architectural or
cultural material, and should be compatible with the scale and character of the
property, neighborhood or environment.
Application: A developer undertaking the rehabilitation of several apartment
buildings wanted to connect two smaller four-story apartments. Both were excellent,
though deteriorated, examples of late 19th-century brick bow-fronts typical of a large
portion of the historic district. The developer was concerned that the two smaller
buildings, which were walk-up apartments, might not have the market appeal of the
other rehabilitated buildings in the complex. As the two buildings were adjacent to a
larger apartment building with elevator service, the developer asked the architect to
connect all three buildings (see illus. 1). By designing two small connectors in the
areaways between the larger building (A) and the smaller buildings (B and C), the
architect connected all three on an axis with the main entrance and elevator service
in Building A. In addition to the corridor connections, the infill structures provided a
required stairway and an additional room on each floor.
This first proposal was not acceptable to NPS. The connector between Buildings B and
C was treated as a masonry infill that replicated the historic detailing of the 19th-
century buildings. The proposed design would have made the two bow-front buildings
appear as one structure, thus altering the scale and character of the historic district,
which is noted for its freestanding smaller apartment buildings. The proposed
connector between Buildings B and C also made unclear what was historic fabric and
what was new construction. NPS requested that the architect redesign the connector
providing for a greater set-back and a change of detailing. This was accomplished
when the architect modified his plan to bring a smaller stairway to the narrowest part
of the areaway and by placing the additional bedroom to the rear. A set-back of 12
feet was achieved, keeping the connector behind an important side bay of Building C
(see illus. 2 and 3). The architect also selected large glazed panels for the infill
material. These modifications retained the separate identity of the historic buildings
81-010
while the contemporary infills succeeded in connecting the three buildings to meet
functional needs. With the modifications described above, NPS approved the overall
project. •
Prepared by: Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-010
1. Proposed plan (rejected). I 1 1
Note that the infill structure EL
j ::::::-...L
between Buildings B & C is too
close to the front facade, thus I II I
making the two buildings appear
as one. Also the architectural
detailing of the infill duplicated
the historic detailing making unclear I i
what is original and what is new J .
construction. I, I - I
portion Z Z
!—BUILDING A— ,p -BUILDING B—r�- BUILDING C --,k-
I I I i 1
e :>, 7 _ r
e. an . .
2. Approved plan. 1 t
Note that the infill structure <>`'b
EL
between Buildings B & C has been _
pulled back behind the side I,
bay on Building C. The 12'
setback plus the contemporary L..detailing of the structure
infill allows Buildings B and
C to retain their identities as N - •
separate buildings.
I LL 2
Port ion Z Z
-BUILDING A-0- --.-BUILDING B '-BUILDING C-0-
2
oc I]o ► . '
l: .
3. Approved elevation. o DunE
n EEL
L
r. Ll ....
The contemporary designs of a-.=
0°
the infill structures plus their �A .oQ deep set-backs allow the historicU!-TEEU,
buildings to retain their identities o
as separate buildings although connected as part of a large complex. .17;�— (� ull1101:10A0.;..-,::.::,..:20_0_211,n,2
`11 ( -cP
portion fi,
i 1 . :I I
4-BUILDING A BUILDING B —it #—BUILDING C --rj-
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 81-011
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
Subject: PAINTING HISTORIC MASONRY
Issue: The color of historic masonry is often one of the most visually prominent
features of the exterior facades of buildings. Color can be used in complementary and
contrasting ways as part of the overall character of the building, and, over the years,
color can acquire historic significance. To paint the proverbial red brick schoolhouse
white, or the White House red would represent major changes in both categories of
historical and architectural character, even though no physical destruction of building
fabric would occur.
Changing the color of masonry buildings through paint applications often is considered
by property owners as a way to give a refreshing "new look" to the exterior
appearance of historic buildings or to "unify" a building with many additions. In cases
where the masonry is unpainted, however, the application of a paint coating usually is
not recommended by NPS, as it may set in motion a series of visual and physical
effects that can drastically alter the character of a historic building.
Application: The rehabilitation of an early 19th-century, three-story residence was
determined not to meet the Secretary of the Interior's Standards for Rehabilitation
primarily because of the changes in the historic character of the building as a result of
the application of a light-colored paint coating to an unpainted brick surface. Like
many other Federal style buildings in the historic district, the house was not intended
to be painted; quite the contrary, the variation in brick color, bonding pattern,
treatment of mortar joints and the texture of the masonry were subtle yet important
components of the historic character of this particular building. The following
Standards, therefore, were not met in the course of rehabilitation:
2. The distinguishing original qualities or character of a building,
structure, or site and its environment shall not be destroyed. The
removal or alteration of any historic material or distinctive
architectural features should be avoided when possible.
5. Distinctive stylistic features or examples of skilled craftsmanship
which characterize a building, structure, or site shall be treated with
sensitivity.
81-011
Five important areas of the masonry building were adversely affected by the
application of the light-colored paint coating:
1. The dark red color of the brick was a local characteristic of brick buildings
constructed in the Federal style. Subtle variations in color also added to the visual
qualities of the brickwork and reflected the technology, firing practices, and clay
deposits used during the period. The application of a paint coating and the use of a
light color contrasts with the historic appearance of the house (see illus. 1 and 2).
2. The semi-circular arch over the main door and the jack, or flat, arches over the
window represented ornamental as well as structural features of the building. The
color of the brick used in these features contrasted for decorative purposes with the
predominantly darker color of the brick used throughout most of the exterior walls;
this contrast was lost as a result of the application of paint to the masonry (see illus. 3
and 4).
3. The high quality face brick used as a veneer on the front facade represented an
important feature of the building and was the result of an early alteration. The brick
facade contrasted with the lesser quality brickwork on the sides of the building; this
contrast was lost through the application of a paint coating.
4. The brick bonding pattern was a functional as well as a stylistic feature. Each
successive coat of paint will further obscure this original stylistic feature of the
building.
5. The mortar joints, through their coloration, tooling, texture, and width of the
joints, were design and stylistic elements that contributed to the historic character of
the building and reflected the skilled workmanship of the era. The visual qualities of
the mortar joints were altered as a result of the paint application (see illus. 5 and 6).
In denying certification of rehabilitation, NPS also advised the property owner that
the painting of the structure was a decision with both immediate and long term
consequences, architecturally and financially. The Brick Institute of America notes
that once painted, exterior masonry generally will require repainting every three to
five years. Each successive coat will further obscure the original masonry
characteristics of the building.
Upon appeal of the denial of certification, the hearing officer sustained the decision
by NPS.
Prepared by: Charles E. Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-011
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1. House before painting. 2. House after painting.
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3. Before. Note the color contrast 4. After. Note the loss of architec-
between the lighter colored bricks in tural details of the bricks over the
the arch and window lintels as opposed doorway and windows as a result of the
to the facade face bricks. application of paint.
81-011
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6. After.
Note that the visual qualities of the mortar joints were
changed as a result of the paint application. On the rear
portion of the building there was historically a strong
interplay between the mortar joints and the brick that was
lost as a result of the painting.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 81-012
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
4. Retention of Significant Later
Alterations/Additions (nonconformance)
Subject: DEMOLITION AS PART OF CERTIFIED REHABILITATION
Issue: Industrial or mill complexes listed in the National Register often include a
number of structures varying in use, age, condition, and significance. Adaptive uses
(such as housing, shops, or offices) are frequently chosen for these complexes.
Unfortunately such plans may propose the selective demolition of certain buildings or
additions or industrial features such as smokestacks and millraces. This work will be
reviewed as part of the overall rehabilitation plans (see regulations 36 CFR Part 67.6)
and evaluated in accordance with the Secretary of the Interior's Standards for •
Rehabilitation. In limited situations, demolition of components of a historic complex
may be approved as part of the overall rehabilitation when 1) the component is a
secondary structure or feature lacking special historic, engineering, or architectural
significance; and 2) the component does not comprise a major portion of the historic
site; and 3) persuasive evidence is presented to show that retention of the component
is not technically or economically feasible.
Application:t Proposed changes to a mill complex were denied approval because of the
extensive demolition planned as part of its conversion into housing for the elderly. In
the National Register nomination forms, 11 brick structures were identified as
significant, in part because they comprised an urban textile mill complex that grew by
accretion from the 1820s up until around 1900. Many of the structures have
architectural significance, with dentilled cornices and flat-arched windows
characteristic of 19th-century mill buildings. Even though a main street bisects the
complex, the buildings are related as a cohesive unit both historically and
architecturally (see illus. 1, 2 and 3). NPS determined that the proposed demolition of
four large 19th-century structures comprising nearly half the complex (see illus. 4)
would greatly alter the distinguishing character of the historic resource; because the
buildings proposed for demolition were integral to the entire complex, approval was
withheld.
In appealing the decision, the owners cited the deteriorating condition of the buildings
and the apparently limited development potential of the site. No evidence was
presented to show that the structural condition of the buildings necessitated their
81-012
demolition. The initial determination of NPS—that a sufficient portion of the complex
was not being retained and that the industrial setting was not being adequately
preserved—was sustained by the hearing officer.
Prepared by: H. Ward Jandl, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
1 . tti r ^ `-`r
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�! !�!"� 1. This historic photograph shows the mill
III . . I ill'
If - complex ca. 1875. Note bridge across the
1 il'il , . street connecting mill buildings.
1 "` ':"" --`' =�- r 2. Although greatly altered, the buildings
,I` •
--^M* ••.».._ " ''� " . •i shown here are still standing, including the
• v,• . ` bridge across the street.
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3.
s „`y " fi + 3. This photograph shows three of the major}; � 4 , buildings (nos. 5, 7, 9) proposed for demo-
1111\7.--lie, 0
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, �•,• lition as part of the overall rehabilita-
,...�_ . ...— tion; this includes buildings on both
ji sides of the street. °o
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4 - I'� 4 4. This site plan shows the buildings (nos. IV
o e I o — 5, 6, 7, 9, 10, 11) to be demolished as part
i t 1 ! i - of the rehabilitation.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service U.S. Depart the Secretary of the Interior's
Department of the Interior
Washington, D.C.
[Standards for Rehabilitation
Number: 81-013
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance; nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (conformance; nonconformance)
Subject: EXPOSED INTERIOR BRICKWORK: WAREHOUSE AND COMMERCIAL
BUILDINGS
Issue: •Exposed interior brickwork is a popular treatment in rehabilitation projects, but
has only limited suitability for historic structures. There are historic buildings, such
as warehouses, where brick walls are not traditionally finished but rather were left
exposed or merely painted. These walls were usually left unfinished for utilitarian
reasons (considering the function of the building) and also were a way to limit initial
construction costs. In some cases, exposed brick walls on the interior of a warehouse
may represent a significant architectural feature contributing to the historic
character of the building.
In most masonry structures, however, interior walls were traditionally finished with
plaster, wainscoting or both; exposing the brick walls to create a new interior
environment could change the historic character of the building. In removing wall
finishes from masonry walls in most houses and commercial buildings, not only is there
a loss of historic finish, but also raw, unfinished walls are exposed, giving the interior
an appearance it never had. The brick thus exposed is usually a poor quality common
brick and the mortar joints are wide and badly struck. (In some cases physical
problems result: removal of plasterwork causes interior brick to "powder," and
methods to seal the exposed brick frequently result in changing the color and surface
of the brick.) If such brick walls are exposed in a widespread manner throughout a
building or in the principal spaces, a significant change in the.historic character would
result, and the project usually would fail to meet the Secretary of the Interior's
Standards for Rehabilitation.
Application: An 1890's warehouse located in a historic district was rehabilitated for
use by an accounting firm. With the exception of a small area on the first floor, the
interior surfaces of the load-bearing walls were exposed brick. The walls had never
been plastered. The large, unobstructed warehouse spaces gave the architect
flexibility in adaptively using the space by installing free-standing partitions and
carrels (see illus. 1). The brick walls were retained and needed only to be cleaned with
water, a mild detergent, and a natural bristle brush. A minimal amount of repointing
was carried out using a mortar similar in composition to the original. The project
resulted in certification. A second project, an 1890's commercial structure, also in a
historic district, was rehabilitated to house a building construction firm. Unlike the
warehouse, which served as strictly a storage facility, the commercial structure
housed a retail concern, therefore necessitating the finishing and trimming out of the
81-013
interior walls. The application stated that all plaster was removed to expose the
brick. The photographs clearly show entire walls in highly visible areas where the
plaster had been stripped away (see illus. 2).
In reviewing the overall project, it was noted that most preservation treatments were
handled in a very sensitive manner. However, because such a large amount of historic
fabric was lost and a new appearance created, the project was denied certification.
Specifically, the treatment violated number 2 of the Standards.
Prepard by: Rudy Massengill, Southeast Region, NPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-013
1. Commonly, warehouse spaces
were simple and open, exhibiting
brick walls that were never
plastered.
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2. Brick walls were rarely left ," {: i ��+r Y
exposed in commercial buildings. �°"-
This contemporary treatment cre- ___
ated a change in the historic try .. f'
character of the interior and7 ,z
resulted in denial of certifi- s t ,-.
cation for tax purposes. '' �
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service I the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards tor Rehabilitation
Number: 81-014
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: INSTALLATION OF THROUGH-THE-WALL AIR CONDITIONERS
Issue: Rehabilitation of historic buildings often includes installation of modern
heating, ventilating, and air conditioning equipment. In planning for installation of
new mechanical systems in historic buildings, owners and architects should carefully
consider the effect of these systems on the historic and architectural character of the
building. An effort should be made to install modern mechanical systems in the least
intrusive manner, causing the least amount of damage to historic fabric with minimal
visual impact. Insensitive installations of mechanical systems can result in denial of
certification.
Application: A three-story frame Italianate house proposed for individual listing in
the National Register was rehabilitated to create a 25-room guest house. Although
the owner repaired and repainted the existing wood shingle siding and bracketed
cornice, selection of an air conditioning system was less sensitive to the historic
character of the building. Installation of through-the-wall air conditioning units on
the upper floors destroyed historic fabric and created visual intrusions on primary
elevations of the historic building (see illus.). NPS denied certification, based on
violation of Standards 2, 5, and 9. While recognizing the need to air-condition guest
rooms on the upper floors in orders to meet contemporary standards for comfort, NPS
determined that alternate systems could have been selected that would not have
compromised the visual character of the exterior. A system utilizing a central
chilling plant and piped chilled water to individual fan coil units was a recommended
alternative that would have avoided alteration to the exterior of the building and
would not have caused undue damage or loss of historic fabric on the interior. The
owner had considered this option, but selected instead the least expensive solution for
air conditioning.
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-014
1
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_
Air conditioning units have pierced the walls of this Italianate
structure in a random pattern, destroying historic fabric and
altering the appearance of the primary elevations.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards tor Rehabilitation
Number: 81-015
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
Subject: INAPPROPRIATE ALTERATIONS TO WINDOWS AND DOORS
Issue: The rehabilitation and adaptive use of a historic building should preserve its
distinguishing qualities or character, as stated in number 2 of the Secretary of the
Interior's Standards. The placement, design, and materials for doors and windows
often are significant elements in the architectural character of a building. Changes to
door and window size and configuration, especially on primary facades, ostensibly to
accommodate building codes or to accomplish energy conservation, should be avoided
when such changes would dramatically alter the character of a building.
Rehabilitation should retain original fabric wherever possible. Replacement doors and
windows should either match the historic in size, configuration, and materials, or
substitute new materials and a design sympathetic to the original.
Application: Rehabilitation of a 1926 one-story, brick automobile showroom located
in a historic district was denied certification for tax purposes following conversion to
a restaurant. Denial of certification by NPS was based on Standards 2 and 6
(alteration of distinctive features; repairing rather than replacing deteriorated
features). The replacement of the automobile showroom windows and doors with
bricked-in panels and residential-type windows caused an unfortunate and irreversible
change in the historic character of the utilitarian commercial building. Originally
constructed for car sales and repairs, the one-story brick building was defined by the
large show windows and multi-paned wood/glass doors (see illus. 1). The rehabilitation
work blocked in most of the openings with brick and replaced commercial showroom
windows with those inappropriate in scale and design (see illus. 2). The overall effect
was a drastic alteration to the character of the building.
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
E1-015 ;
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1. The 1926 automobile showroom with its original storefronts, garage doors,
and industrial metal windows intact.
2. The opposite elevation post-rehabilitation; some openings have been bricked
up and others have had new residential-type windows inserted. The dramatic changes
to the appearance of this automobile showroom resulted in denial of rehabilitation
certification for tax purposes.
"L ` -r•t, ` -� '▪ ` :-mod--t"-"--�""N
111111
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards for Rehabilitation
Number: 81-016
Applicable Standard: 4. Retention of Significant Later
Alterations/Additions (nonconformance)
Subject: REMOVAL OF SIGNIFICANT LATER ADDITIONS
Issue: In urban areas where land values and zoning often encourage higher-density
construction, historic buildings undergoing rehabilitation may be threatened by the
demolition of significant later additions. In an effort to create space for a new
addition or parking on site, property owners and architects may overlook the
significance of later additions to historic buildings or historic outbuildings located on
the same lot. Demolition of later additions that are evidence of the history and
development of a historic building and that have acquired significance in their own
right violates Standard 4 and results in denial of certification for the overall
rehabilitation project.
Application: An 1840s brick house in Greek Revival style within a small historic
district was rehabilitated to house a restaurant and bar in a downtown urban area. In
an effort to capitalize fully on the limited land area, the owner demolished an 1890s
ell attached to the rear of the house and a late 19th-century brick barn with a
fish-scale shingled gable end (see illus. 1). The owner, however, also restored the
classical porch and street facade of the house. The State Historic Preservation
Officer recommended that the rehabilitation work be denied certification based, in
part, on demolition of the ell and barn. Gutting of the interior also was cited in the
recommendation for denial of certification.
NPS supported the recommendation from the State, emphasizing that the
rehabilitation project had resulted in the demolition or alteration of a substantial
portion of the architectural and historical features of the property (see illus. 2). The
brick, gable-roofed barn and the two-story ell attached to the rear of the main house
both had acquired significance over time. Other rehabilitation treatments that were
not consistent with the Standards included removal of the existing wrought iron fence
on the front of the property, removal of interior detailing, and construction of a
clapboard wall along the north elevation of the house.
Prepared by: Floy A. Brown, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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1. This 1890s rear ell and barn were demolished as part of the
rehabilitation. NP5 determined that the structures had acquired
significance in their own right and should have been preserved.
--....." ...m.
2. In its conversion to a restaurant,this Greek Revival house
underwent major changes;although the main facade was left intact,
the rear ell and adjacent barn were demolished and replaced with
a one-story brick pavilion surrounded by a two-story L-shaped
structure faced with shingles recalling the original ell.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 81-017
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (conformance)
Subject: REMOVAL OF SIGNIFICANT INTERIOR WOODWORK
Issue: In rehabilitating multi-family residential structures, developers often want
maximum flexibility in working with interior spaces to comply with local and state
building codes as well as State housing authority and HUD minimum property
standards. In some cases this means gutting--the complete removal of interior
features and detailing. Many historic residential structures, however, contain interior
woodwork such as window and door trim, cornices, wainscoting, chair rails, built-in
cabinets, and ornamental stairways, which add to the buildings' architectural
character. As a result, a developer's desire to gut a building's interior and "start with
a clean slate" may be in conflict with retention of significant woodwork in accordance
with Standards 2 and 5, which call for the preservation of distinctive architectural
features and examples of skilled craftsmanship.
Application: The developer of eight turn-of-the-century apartment buildings
submitted his request for rehabilitation certification to the State Historic
Preservation Officer (SHPO) when project plans were being formulated. Although
almost total interior gutting of the building was called for in the rehabilitation, the
SHPO felt that the developer's plans were satisfactory and forwarded the application
to NPS with a recommendation for approval. Because most of the woodwork in both
the public spaces (foyers, stairways, halls) and the apartment units was
machine-planed and relatively simple, and because similar woodwork was very
common in other buildings in the historic district and around the State, the SHPO
believed that it was not significant and its removal would not violate the Standards.
Upon reviewing the application, NPS agreed with the SHPO that much of the work met
the Standards, but determined that the woodwork--especially that located in foyers
and stairways--was significant, and that a sufficient amount of it should be retained to
preserve the architectural character of the spaces (see illus. 1 and 2). The total
gutting and modernizing of interior spaces, NPS felt, would destroy the turn-of-the-
century character of the public areas, thus violating Standards 2 and 5.
With this view in mind, NPS began negotiating with the developer in an effort to save
as much woodwork as possible. The buildings were to be converted to HUD section 8
housing for elderly and low-income persons. After initial consultations with his HUD
area office, the developer anticipated that numerous changes in stairways would have
to be made in order to accommodate new elevators. By changing the proposed
locations of elevators in order to lessen the need for stairway demolition, however,
81-017
the owner agreed to retain most of the woodwork that NPS had determined was
significant. A letter of preliminary approval containing as a condition the retention of
these elements was subsequently sent to the owner.
Prepared by: William G. MacRostie,TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
+`.1 81-017
i
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1. The stairway of the above build-
IIIIing is shown at right. The handrail,
balusters, newel posts, chair rails
and window trim are being retained, _
although initial plans called for
their removal.
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2. The main stairway in the building at left. The handrails, balusters, newel posts,
window trim, marble treads and risers, characteristic of this style and period of
architecture, are being retained in the rehabilitation.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. 20240 for �el ICUJ���t�t�on
rStandards
Number: 81-018
Applicable Standard: 4. Retention of Significant Later
Alterations/Additions (nonconformance)
Subject: REMOVING SIGNIFICANT ADDITIONS
Issue: Many historic buildings have had additions over the years, with new ornamental
detail, storefronts, porches, windows, wings, stories or lean-tos modifying a structure's
original appearance. These modifications often mark a change in building ownership, a
change in an owner's stylistic preferences or, in the case of a new story, wing or lean-
to, an owner's need for additional floor space accompanied by an improvement in his
or her economic circumstances. Changes of this sort may therefore help convey the
history of the building's occupants as well as the area in which it is located. For these
reasons, Standard 4 states that changes to a structure over time "may have acquired
significance in their own right, and this significance shall be recognized and
respected" during rehabilitation.
Application: A frame farmhouse individually listed in the National Register was
constructed in 1860 by joining two older structures. When constructed, the front of
the house apparently had a small covered porch at its center, but sometime before
1893 (judging from a historic photograph of that vintage) the porch was enlarged to
the full length of the facade. Ornamental scrollwork, appearing with the enlarged
porch in the 1893 photograph, was apparently added at the same time (see illus. 1 and
2). The current owner, wanting to restore the building to its 1860 appearance,
removed the later portions of the porch during his rehabilitation of the building.
Three small additions at the rear and on one side wall were also demolished (see illus.
3, 4a and 4b). The owner submitted his request for rehabilitation certification after
the work was completed. The State Historic Preservation Officer (SHPO)
recommended denial of certification for the project based on the existence of flush
siding across the front of the building at the first floor level—a local practice often
used in conjunction with porches. The SHPO's recommendation for denial was also
based on the belief that the three additions removed in the rehabilitation possibly had
acquired significance over time. NPS requested further information from the owner
regarding his decision for altering the porch, and learned of structural evidence
suggesting the presence of an earlier, smaller porch. The significance acquired by the
existing, full-length porch, however, became the key issue in the NPS review. NPS
determined that regardless of the varying evidence relating to the original size and
evolution of the porch, its appearance at the time of rehabilitation was significant to
the character of the building. In its letter of denial to the owner, NPS included the
following comments:
We understand that the demolished portions of the front porch were
probably added after the house was assembled on its present site.
However, the dominance on the main elevation of this full-length porch
with its Victorian brackets and decorative detailing leads us to the
81-018
conclusion that the front porch in its entirety had acquired significance
over the course of time. Removal of the outer portions, therefore,
violates Standard 4. Our determination was also influenced by the
demolition of additions on the south and west sides, all of which we
feel may have acquired significance over the history of the house.
The SHPO had a further concern regarding an inconsistency in the rehabilitation, in
that the current owner's reduction of the front porch should have been accompanied by
a replacement of the flush weatherboarding with whatever was "original." The SHPO
also felt that there was no consideration given to the damage now possible to the
house because of the exposed flush weatherboards.
During the course of the owner's appeal it was learned that all of the rehabilitation
work in question had been executed in 1976 and early 1977. Although agreeing with
the SHPO and NPS that the project did not meet the Secretary's Standards, the
hearing officer overturned the denial of certification, citing the fact that the work
was performed prior to issuance of the Standards by the Department of the Interior
(they were published in the Federal Register in March, 1977) as the mitigating factor.
Prepared by: William G. MacRostie, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
i
i
81-018
anztaar
. , . . r j . 1 I fir; - --1 1-1;7 r-:
i ilivo.i._ 1,, e •:. .- .iii__ . --- ,
:IL
_ .,
•
1. The farmhouse with its full-length front porch _ T$IT :iiIlf-
-before rehabilitation. The portion marked(A)is ■what the owner maintained was original. Portions - r
marked(B)were added to the building at a later ^�!•' ,: .- .
date and removed during rehabilitation. s q r_..j�
Jy -.
2. A detail photo of the front porch. According to the
r — owner,the portion of the porch illustrated here was its
_`,� approximate original width.
MT `
a — j 3. The south side of the building, showing
- !- e . the historic additions. The front of the
�_ _ 1_ ` ��r-- • building is at the right in the photo, the
' 1.051 sessa
�asaar rear at left.
4a.and 4b. After
lir rehabilitation,showing
altered rear additions
(left)and size of `
front porch(right). �i-•• III
I 0 M la � --
•4
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rstandards for Rehabilitation
Number: 81-019
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: ALTERATIONS TO SIGNIFICANT INTERIOR SPACES
Issue: Historic buildings often contain opens multi-storied spaces that are
architecturally significant but that, from a real estate developer's standpoint, may
represent potential rentable floor area being wasted. Standard 2 states that "the
distinguishing original qualities or character of a building, structure, or site and its
environment shall not be destroyed." Therefore, interior spaces such as church
sanctuaries, theater auditoriums, and hotel lobbies and ballrooms normally should be
retained intact in a rehabilitation project if they are significant either for their
ornamental detail or for their relation to the building's original character and use.
While some rehabilitations that call for inserting inobtrusive balconies and partition
walls have been approved in the past, certification for projects that completely
obscure or destroy the sense of significant interior space and details have been denied.
Application: The rehabilitation of a 1909 neo-classical stock exchange building
individually listed in the National Register included plans for the insertion of a new
floor within the two-story trading room space. Originally, two mezzanine-level
galleries on either side of the trading room looked down on a horseshoe-shaped counter
and trading desk on the floor below (see illus. la and lb). The proposed additional
floor was to span the open space at the mezzanine level between the galleries, with
the horseshoe counter and trading desk relocated to another room in the building. The
trading room floor, as well as the newly created floor, were to be converted to
reception areas and open office space (see illus. 2).
NPS determined that the two-story trading room was the primary interior space in the
structure, was significant to the exchange building throughout its history, and helped
to distinguish the building from others of the same period and style. NPS stated that
the proposed changes would dramatically alter the character of this space and would
therefore violate Standard 2.
The owner did not appeal the denial of certification.
Prepared by: William G. MacRostie, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-019
1 1.
•
ilr
y r il 0 I f .,:i' !..,„:„.
I
w •Ti--e.
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ill
t
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la. and lb. The trading room in its original condition. Project plans called for
flooring over the entire mezzanine level, creating additional rentable floor space.
•
'. sue— 'y , �
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=s ` "'III
e 'Allitu,sw i ---1 __ ,_ r•— ii
IN.%\ •-•,.......4..• ....." I. f " .,
• 1 . s t'_ .-.: 1 f
2. This rendering illustrates what was planned for the trading room floor. The new
second story above this room would have received a similar treatment. NPS denied
the owner certification, citing the major alteration to the primary space that would
result.
•
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 81-020
Applicable Standards: 1. Compatible New Use (conformance;
nonconformance)
2. Retention of Distinguishing Architectural
• Character (conformance; nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (conformance; nonconformance)
Subject: INTERIOR ALTERATIONS TO ACCOMMODATE NEW FUNCTIONS
Issue: Rehabilitating historic buildings for a new use often requires the owner to make
changes to the existing floor plan. If distinguishing original qualities or the character
of the building are lost or if significant details or features are removed in the process
of the rehabilitation, the new plan or layout may be in violation of the Secretary of
the Interior's Standards for Rehabilitation (particularly Standards 1, 2 and 5). A loss
of character of the interior may result from changes such as when a distinct plan
arrangement is substantially altered by permanent partitions, distinctive trim is
removed or when the orientation of the building is changed by the introduction of new
entrances.
In looking for potential new uses for an historic property, an owner must consider how
to integrate the new function into the existing historic resource without destroying its
character. Each new use will have its own set of requirements, and some of these
requirements may not be compatible with the existing character of the building.
Application: Following are two examples of historic residences that were altered to
accommodate new office functions. The first example failed to meet the Secretary's
Standards and was denied certification even though the exterior was carefully restored
to its Greek Revival period. The modifications to the interior radically altered the
symmetrical, formal plan and the loss of the interior trim further added to the loss of
character. The owner of the second project, however, sensitively reused the existing
plan and highlighted the period ornamentation of the interior features.
The first building is an early 19th-century two and a half story house with a formal
center hall plan. It was extensively remodeled early in its history, both inside and
outside, using the then-popular Greek Revival Style. The continuity of detailing on
the interior and exterior, added during ther mid-19th-century remodelling, contributed
to the architectural significance of this building and was compatible with its historical
significance as an early courthouse. The property was individually listed in the
National Register of Historic Places. Even though the property had a number of uses
during the course of its history, the original plan was never seriously altered (see illus.
1).
The property had been vacant for a number of years when it was purchased for
rehabilitation. The new owners investigated numerous alternative uses for the
81-020
building and determined that the only feasible use, at that time, was for doctors'
offices. Unfortunately, this initial decision concerning a new use was not for a
compatible use (Standard 1), because the doctors' offices required numerous small
rooms (examining rooms, dressing rooms, storage areas), and the plan of this house was
an arrangement of formal rooms off of a central hall (see illus. 2). In addition to the
change of plan, the owners wanted to insulate the exterior frame walls in a manner
that required the removal of the inside plaster and trim. The modest budget for the
rehabilitation did not allow for the replacement of the decorative window trim,
baseboards, etc. While the trim was not original to the house, these Greek Revival
features had gained significance over time and enhanced the character of the interior
(Standards 2 and 5).
Not only was the trim removed from the inside face of the exterior walls, but all the
remaining trim, doors, mantels and brick fireplaces were removed as part of the repair
and repartitioning of the interior (see illus. 3 and 4). Also, the original open stair was
replaced with an enclosed fire rated stair. While it is often difficult to obtain a fire
rating on an open stair, some jurisdictions will provide variances for historic
properties if the open stairs are properly sprinkled or if a second fire rated exit is
provided. The combination of the change of plan, loss of original details and the
overall loss of character of the interior spaces resulted in the denial of certification
for tax benefits for this property.
The second example of an interior remodeling to incorporate professional offices is
that of a late 19th-century Richardsonian Romanesque mansion located within a
historic district (see illus. 5). In this case, only a few of the secondary rooms were
subdivided and all of the major spaces were retained. This included the retention of
the large entrance hall and the open panelled staircase, which became an attactive
receptionist's area (see illus. 6 and 7). All interior trim, fireplaces, mantels, and
chandeliers, were restored and added greatly to the character of this rehabilitated
property; the project was certified as meeting the Standards.
Prepared by: Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-020
pi J) 911. r #3 j)K #44 #5
vii - #2
=a LL1
11.1
Room#1 #4 Room#1
1...1..r2-4"...mi(Ir #7 J 4
LiLN4_ 1
Entrance Entrance
1 M r 11
1. Before Plan. The original plan was of 2. After Plan. The interior plan was
a central hall with large rooms located drastically altered during the reha-
symmetrically on each side. Each room bilitation to accommodate numerous
had a fireplace with a mantel and deco- small offices and examining rooms.
rative trim in the Greek Revival Style. In addition, the open stair was replaced
with a boxed-in stair and the original
trim and fireplaces were removed.
81-020
1 ;
1/4 •�' �'.1
.Y •Y���� I �ii�
�j
--•---- c r, Ti V f i-- -- •
L1 •
3. Exterior of carefully restored - 3'
Greek Revival style house used for -f'- `•
doctors' offices. Even the exterior
chimney caps were rebuilt after re- 4. Interior of the same house, which was
moval of the interior fireplaces. subsequently stripped of all the trim,
moldings, doors, mantels and fireplaces,
resulting in denial of certification.
a�",
:F '..�:.- —'mac' la.z p. '
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5. Exterior of carefully restored
Richardsonian Romanesque mansion.
81-020
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6. Receptionist's Area. The main stair and the entrance hall were retained as a
receptionist's area in the approved rehabilitation project. Many jurisdictions will
allow the stairs to remain open in historic properties if an approved sprinkler system is
installed to provide the necessary fire protection.
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7. Interior Office. The fireplace, mantel and wooden window trim and baseboards
were retained as decorative features in the approved rehabilitation.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 81-021
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: WINDOW REPAIR vs. WINDOW REPLACEMENT
Issue: The decision to repair or replace windows is an issue that can pose considerable
problems in the rehabilitation of a major historic commercial structure. If a small
number of undistinctive windows on secondary elevations are deteriorated, then total
replacement of these windows may be appropriate. Stock windows are often chosen as
adequate replacements due to their availability, low cost, and energy efficiency.
Certain historic structures may contain highly distinctive windows that are a major
component of the overall exterior design. Standard 2 states that such distinguishing
original features shall not be destroyed. In this case, careful repair of the
deteriorated features in order to retain the architectural character of the structure is
the preferred approach. In the event that repair is not technically or economically
feasible, new windows that match the original in material, size, general muntin and
mullion configuration, and reflective qualities of the glass may be substituted for
missing or irreparable windows.
Application: NPS was asked to review the window replacement proposals for a theater
that exhibited highly detailed facades punctuated by a considerable number of
windows on each floor level (see illus. 1). The large window openings and slender sash
members provided an interesting juxtaposition of architectural treatments with the
heavily adorned masonry surfaces. The window sash and frames had deteriorated over
the years and consequently the decision was made to return the windows to a
serviceable condition. The window repalcement would be done concurrently with
other Historic Preservation Fund grant-assisted work but would not receive a grant-in-
aid itself.
Three proposals were submitted by the architectural firm as bid alternatives. The
first alternative included repairing or replacing the deteriorated existing wood sash
with wood members that duplicated the existing configurations (see illus. 2). The
architectural firm indicated that the existing sash were original to the theater. The
second alternative proposed replacing the existing wood sash with aluminum fixed sash
(see illus. 3). The third alternative was to replace the existing wood sash with wooden
double-hung sash clad with aluminum (see illus. 4).
NPS determined that the first alternative was acceptable in all respects. The second
alternative was also determined acceptable with one exception: the proposed windows
for the second and third floor levels were not appropriate replacements due to the
different sized panes, which deviated in scale and design from the original windows.
The overall proportion of these proposed windows would have altered the exterior
appearance of the building. Finally, the third alternative was not acceptable in any
81-021
respect since the replacement windows on all floor levels differed severely from the
originals and would have resulted in a totally altered exterior appearance.
NPS commented that alternatives two and three would be acceptable only if the
replacement sash were specially fabricated to duplicate the equal-sized, one-over-one
sash configurations of the original windows. The architectural firm indicated that the
bid for alternative one was considerably more than alternative three. The firm stated
that alternative two could be specially fabricated, but the cost would be similar to
alternative one. They indicated that alternative three would fit the window openings,
but since the aluminum dad wooden windows were stock items they could not be
fabricated to match the original sash configurations. This was also the least expensive
alternative and was subsequently chosen by the architectural firm as their
recommended proposal.
After further negotiations with the architectural firm, NPS ultimately recommended
repairing and replacing as many windows as possible within the allotted budget using
new wood sash as proposed in alternative one. The remaining windows could be
secured and weatherproofed in order to seal the building from adverse climatic
conditions. These windows could then be restored in a future phase. The architectural
firm eventually recommended that the project sponsors select alternative one;
repairing the existing wood sash, where necessary, with new wood members that
duplicated the original designs. However, due to overriding project budget
constraints, a decision was made to limit work to scraping and repainting the existing
window sash rather than to install replacement sash.
Prepared by: Christopher A. Sowick, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-021
__ .:'s.r' '':
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1. Exterior of theater.
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1✓tE7-Z 'FL047t2 si=-0t.rp .4 THLR-t, FaLrRTN F1A02
V INDOw ' FLOOQ •WINDOWS wINDow-
2. Alternative One. Existing sash to be repaired/replaced with new matching wood
members. This approach was fully consistent with the Secretary's Standards and
was approved by NPS.
I 4 L 7 H i 510 Xa
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3. Alternative Two. Proposed replacements using 4. Alternative Three. Proposed replacements using
aluminum fixed sash. The designs for the second and wooden double hung sash clad with aluminum. These
third floor windows were found to be inappropriate by designs radically altered the appearance of the
NPS because the meeting rail did not bisect the sash. windows and were determined unacceptable by NPS.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 81-022
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: APPROPRIATE SCALE OF GREENHOUSE ADDITIONS
Issue: Greenhouse additions to historic building are sometimes used by developers to
obtain additional floor space or for passive solar heat collection. NPS does not
discourage new additions to historic buildings under certain conditions. A number of
projects that include contemporary greenhouse additions have been certified for tax
purposes where they have been proposed for non-significant elevations and have been
compatible in size and scale with the existing structure. In addition, their
construction should not involve demolition of significant historic fabric or obscure
significant architectural detail or features. Greenhouse proposals that do not meet
these criteria may jeopardize certification of the project work.
Application: The proposed rehabilitation of a four-story Federal style structure
included plans for a wrap-around greenhouse to be built on two of the building's three
elevations. At the end of a long row of wharf buildings, this structure projected
prominently into a square near the center of a downtown historic district (see illus.
1). NPS determined that all three of the building's elevations were equally significant,
and therefore it would be especially important that the size and scale of any addition
be sensitive to the existing structure.
The developer of the building planned to convert the first two floors to a restaurant,
and several hundred square feet of additional floor space would be provided by the
greenhouse (he sought no solar energy benefits from the addition). The initial proposal
submitted to NPS called for a two-story, lean-to greenhouse whose roof would connect
to the building just below the third floor window sills (see illus. 2). NPS determined
that the two-story height of the greenhouse would dominate the four-story facades for
which it was proposed, thus violating Standards 2 and 9. NPS suggested that if
additional space was required, a one-story greenhouse would be more compatible with
the scale of the building. A one-story addition would obscure only the ground floor of
the building (comprised of storefronts that had been altered several times in the
building's history) and would leave the upper three stories unimpaired. Such an
addition, however, would not be a recommended rehabilitation approach.
The developer responded by presenting a slightly scaled-down greenhouse design, with
the sidewalk depth reduced and the height lowered from the third-story window sill
line to the second-story lintel line. By reducing the size of the greenhouse in this way,
the developer gave up some seating space in a second floor balcony which had been
included in the original design (see illus. 3 and 4). In arguing for their revised two-
story design, the developer and his architect maintained that all of the greenhouse
81-022
would be glazed and that only very light framing would be required to carry the sloped
roof, allowing a person on the sidewalk adjacent to the greenhouse to look up through
the glass and readily observe the historic brick wall above. They argued that a
one-story greenhouse would require an almost flat roof because of the relationship of
its height to its depth. In order to carry the weight of the glass roof, therefore, the
framing would have to be heavier and would, they maintained, obscure the view up
through the glass.
NPS did not agree with this assessment of the addition's impact, and in its letter of
denial to the owner, stated:
the scale of a two-story greenhouse would dominate the facades for
which it is proposed. A one-story (design) would not have the same
overwhelming effect—from either a close-up or distant perspective--on
the existing structure.
In appealing this NPS decision, the developer wrote:
...we believe the sloped roof of the greenhouse reflects the line of the
existing roof of the (building) as the one-story design would not....The
configuration of the two-story) canopy, combined with sensitive
lighting will high-light the components of the historic (facade); a one-
story addition would intrude upon and obscure the significant features
of the (facade)....The dramatic alteration caused by the proposed
greenhouse addition will have a positive effect on the...building. At
night, "suitably illuminated," the greenhouse becomes invisible from
any sight line, and the facades of the...building are dramatically
revealed.
After reviewing the facts of the case,the hearing officer sustained NPS's denial of
certification and, in his letter to the owner, wrote:
I agree that with illumination of the facades of the...building the
greenhouse would be nearly transparent at night, and that the facades
would therefore "read" through the glass much as your elevation
drawings depict. I would hasten to point out, however, that the
drawings overlook the reflective quality that glass possesses during
daylight hours. As a result of this quality, I believe that glass in a
greenhouse is not a neutral material, "virtually invisible," as you
maintain. It is a dynamic material with bold visual qualities very
different from the red brick of the...facades. (These) visual
characteristics...would make a two-story greenhouse less an invisible
addition and more one which would stand alone as an architectural
statement, competing with and altering the historic character of the
building.
The hearing officer reiterated to the developer that a one-story greenhouse likely
would receive certification. In a resubmitted application, however, the developer
81-022
eliminated the greenhouse entirely, proposing instead outdoor seating on the sidewalk
during the summer months only. Upon receipt of this new plan, a preliminary approval
of the developer's proposed work was issued.
Prepared by: William G. MacRostie, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
. � 1
81-022
. lii441„-.-- .--_,.., . 4
l f'''' / II ,► r 1. Corner of the Federal Style build-
..I l i�� - I ) 1i.. ' u. 1' ing for which a two-story greenhouse
1' ' i f.i I J ' ' • ' t was proposed. The greenhouse would
.':if • 111 i ` I ! I- I I I 11 have run half the length of the facade
�_ rig;.:..:., at right and the entire length of the
'", I,� '! II p a •`�, facade at left.
1.
•
t I r `'- , 2. Initial design proposal. NPS deter-
]_ , 1 --7=1 mined that this two-story addition would
I � � a
j1 1 = dominate the two facades and overwhelm
�. • --_- the building.
•�1 ' n m Y .M •
1...: II
U +n -
:• 3. The developer's second design pro-
_! = posal reduced the height of the green-
- _ house to the level of the second story
II. window lintels. NPS continued to with-
_d._. r � hold approval for the project.
:,.. _ •:. : •
'" °_ I: "` "' 4. NPS suggested a one-story green-
•
— — — — house, similar to this, which would
• .., in ,,,an Ninot have the same overwhelming effect
j,EMEE'EE��_LI�somm on the building as the proposed two-
■■-.11_ !=I 1
story addition.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 81-023
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: USE OF UREA-FORMALDEHYDE FOAM INSULATION IN WOOD
FRAMED BUILDINGS
Issue: Insulating the walls of an existing wood framed building is a common energy
conservation retrofitting measure. Some types of insulation are installed by removing
the inside or outside building materials, a process that is time-consuming, expensive
and which can result in the loss of important intact historic fabric. A recent
alternative method of insulating frame walls is to inject foam insulation directly into
the framing cavity through holes selectively drilled through the exterior siding. This
insulation is known as urea-formaldehyde foam and is usually referred to as u-f foam.
NPS has determined that u-f foam is not an appropriate material for retrofitting
historic buildings. It causes immediate as well as long-term damage to adjacent
building materials. Use of u-f foam cannot be considered a good preservation practice
and violates number 2 of the Secretary of the Interior's Standards for Rehabilitation,
which deals with the alteration of historic materials.
The alteration and subsequent deterioration of the historic matrial comes about as
part of the curing process of the urea-formaldehyde foam (see illus.). Moisture is one
of the worst problems for an old building, and u-f foam is injected wet into the frame
structure. U-f foam is the consistency of shaving cream, and as it dries or "cures" as
many as five quarts of water for each stud cavity of approximately 2' X 8' are released
and must be absorbed by adjacent materials. This excess moisture can result in
rotting of wood members, the formation of fungus within the walls, damp plaster, and
blistering and peeling paint. In some cases it can also result in the rusting of metal
elements within the wall including nails, metal lath, electrical fittings, and anchorage
devices. The rapid release of moisture during the curing process can also result in
standing water accumulating on the structural wood sills creating conditions for
potentially severe damage.
Long term damage may result from condensation that forms within the cavity walls
once u-f foam has cured. The curing process, which can take many years, results in
the foam shrinking as the moisture within the insulation dissipates. Tests conducted
by the National Bureau of Standards have proven that after approximately 2 years, u-f
foam will have shrunk at least 7 percent. This shrinkage will reduce the effectiveness
of the insulation by at least 15 percent. As the foam shrinks away from the studs,
sheathing and lath, a gap of about 1/8 th inch will form on either side of the foam. As
humidity within the house from cooking, bathing and laundering migrates through the
wall to the cooler outside, moisture can condense within the gaps formed by the u-f
foam. This trapped moisture can further damage the historic materials of the
building. In addition to the instability of the material within the wall, there is also the
81-023
chance for the installer to mix the ingredients improperly, resulting in foam that will
not properly set and that subsequently must be removed by tearing out one surface of
the wall.
Although not of concern to the deterioration of the building materials within a house,
another important concern is the possible danger to humans from the vapors released
by the formaldehyde gas within the u-f foam. After investigating numerous cases of
illness, nausea and dizziness reported by inhabitants of houses insulated with u-f foam,
the U.S. Consumer Product Safety Commission has determined that u-f foam can
present serious health hazards to occupants. Consequently, the commission banned u-f
foam in residential buildings and schools.
Application: U-f foam was injected into the walls of a ca. 1869 wood framed building
in New England during the summer of 1979. No initial moisture damage or paint
blistering was observed, and no such moisture damage was apparent when NPS
reviewed the project. The injection of the foam and some minor cosmetic repainting
of the building were the only items of work identified on the Part 2 application for
rehabilitation certification.
The Mid-Atlantic Regional Office, NPS, after consulting with the Washington office,
denied certification to the owner, based on the high probability that moisture damage
had occurred (although hidden from view) and the likelihood that damage would occur
in the future from condensation forming within the wall cavity. Both the regional
office and the Washington office felt that the use of u-f foam is not, under any
condition, a sound preservation practice for the reasons cited above and illustrated in
the sketch below.
Prepared by: Baird M. Smith, AIA, and Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
81-023
''•�` ,':' U-f foam releases approximately
Paint can peel and blister ,� i`.:.� •, • i : PP y
on the exterior surface of kb•?R • 5• quarts vity s of of water
for 2 X Seach
as part
moist wood siding. N its,,.. ,,.
,.`R of the curing process.
U-f foam shrinks as it cures by
at least 7%, thereby reducing �1 *tee.: •; Metal, including metal lath,
the effectiveness of the \ ! ;, • i�: anchors and electrical fittings,
insulation and causing gaps �� ..�,.•`,+ within the cavity wall can rust
for condensation to settle. lL .....A._....._• •�• ; ` from the moisture released by u-f
•,,
4.. i o ir�•,sOr �c, foam or from condensation.
Fungal growth and wood rot ^ i►'•+" ••`• i:,.
can develop on moist wood r1 s•••...-.� •,••'� Plaster walls can become damp and
0.`«;•> paint can peel as a result.
sheathing. �- ct - i,,•„
•., ✓'
Vertical wood studs supported „f. " U-f foam gives off formaldehyde
�• .•'••' � . as it which is believed
by wood sills can absorb standing J1 �„��•,�� ., gascures,
moisture through capillary 0� -P•..•`•; to be harmful to humans.
action resulting in possible _`�4,. ,
severe structural damage. '0 t«.i• � Excess moisture from curing and
:• t. condensation formed in the walls
.
S, lea Li 0 on the surface of the shrunken
/� �. �
' •'� insusillslationand can settle on the wood
lye create a situation where
r F��a ..�
«4 »`, rot and fungal growth can set in.
--DOILL
Exterior Iu' _7101.5T Interior
Detailed wall section showing injected u-f foam
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 82-024
Applicable Standards: 3. Recognition of Historic Period (conformance)
Subject: CREATING EARLIER/LATER INTERIORS WHERE NO SIGNIFICANT
SPACES, FEATURES, OR FINISHES EXIST
Issue: Property owners or developers may sometimes "create" interiors that are
inappropriate to the style or period of historic buildings because they feel certain
styles are more "fashionable" in the business community. The Standards are intended
to encourage treatments that respect the character of historic buildings; thus,
Standard 3 states "All buildings, structures, and sites shall be recognized as products
of their own time. Alterations which have no historical basis and which seek to create
an earlier appearance shall be discouraged." This Standard assumes that the
distinguishing interior spaces, features, and finishes are substantially intact and would
be lost or damaged by inappropriate alterations, i.e., creating styles that are either
earlier or, by inference, later than the historic building, or an eclectic combination of
styles that reflect no particular period. In certain very limited situations, however,
creating a non-historic appearance may be acceptable in a rehabilitation project if:
1. The existing interior retains no significant spaces or features or finishes and, thus,
conveys no sense of historic character; 2. There is minimal destruction of historic
fabric; and 3. All other aspects of the rehabilitation clearly meet the standards. All
three criteria must be met before interior spaces can, in effect, be re-designed to suit
re-use needs. Where historic documentation (old photographs, drawings, etc.) exists,
owners should strongly be encouraged to undertake a "reconstruction" based on such
evidence but, under the tax benefits legislation, cannot be required to do so.
Application: An 1840s tavern in a historic district in the Midwest was being
rehabilitated for use as an antique and gift shop. The approach to the exterior work
was generally "restorative" in the removal of a historically inappropriate bay window
and door pediments, all of which had been added in the 1970s. This part of the project
was determined clearly to meet the Standards (see illus. 1). On the other hand, the
regional office questioned the appropriateness of the interior work, even though the
interior had been totally modernized and, thus, conveyed no sense of historic
character (see illus. 2). In order to better market his products in the antique and gift
shop, the owner felt it was important to create an interior decor that was "appropriate
to provincial Britain and Eastern Europe" (see illus. 3). The regional office denied
certification of the project based on nonconformance to Standard 3, asserting that the
interior had no place in this mid-19th century American building. When the owner
appealed, the hearing officer overturned the regional office's decision because the
past modernization of the interior resulted in the total loss of significant spaces,
features, and finishes. Because there were no preservation issues involved, the owner
had the option of creating an interior style--either earlier or later than the historic
building--to suit his needs. The hearing officer would have preferred that the owner
create an interior that was historically appropriate to the building, but the Standards
for Rehabilitation do not require reconstruction of historic features.
82-024
A similar decision was reached in an appeal involving a 1903 bank building proposed
for individual listing in the National Register. Although the original main banking
room with its neo-classical detailing (see illus. 4) had been modernized in the 1950s so
that the historic character had been destroyed (see illus. 5), the owner's rehabilitation
was denied certification because it was felt than an earlier, Victorian appearance had
been created by the work (see illus. 6). In the appeal, the denial decision was
overturned on grounds that the 1950s interior alteration had essentially destroyed all
significant spaces, features, and finishes so that there was, in effect, no historic
character to preserve when the later rehabilitation work was undertaken. It should be
noted that in many of the other rooms in the bank, the original plaster walls and wood
trim were still intact and were saved in the rehabilitation project.
In summary, the hearing officer stated: "For this reason, I have determined that,
should the building be listed in the National Register of Historic Places (and thereby
becomes 'a certified historic structure'), the rehabilitation work undertaken will not
preclude certification of rehabilitation for the project."
Prepared by: Kay D. Weeks, and William G. MacRostie, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
--t 82-024
1,/ "P4e1A,:;-.•-• . i
�f�
1. Exterior of the 1840s tavern. 4 —='�
r:. _. b:.� --- y.t 4
This project was submitted for ` I r�
certification of rehabilitation. [}
Standard 3,which deals with f.�
alterations that seek to create I� -
earlier appearances,was at issue. 71-
The exterior work fully met 1 _
the Secretary of the Interior's , —•,n
_,.....,..,
}
Standards for Rehabilitation, but 1.5s Lk
..-r../ L. ,..j
- / ‘ ...-• t .
.',, ate.
2. Interior of the tavern prior to ith
the rehabilitation. This interior
was a result of a 1970s remodeling. f
All visible historic fabric, including ( FJ r , ,fz_: '`
the floors, walls and ceiling, were ' ! I , J �. '=,t_ �,,,
removed and replaced with modern • i '•! .1' i ' ( I + l' -
materials. It was determined by NPS r I ' I i '
that there was no historic character _ I . Tj..
to this space. € 4 r 0.
h�
a, t - `t .. _` , 0
Le•
1 -
3. Interior of the tavern after ''
the rehabilitation. (The same view J °`
as that of the above photograph).
This interior reflects a style and {_ `.i •
period that is inappropriate for an , + t
1840s tavern. However,because the ''= ''
existing interior had been determined 1.F. .• - ~
to have no historic character and ?`•
because the project fully met all z
three criteria outlined in the text,
the project was certified.
NIIIIIIII d
--'..47
F' Y
82-024 -
fa IL*ii
tri -`
T.
s a111Pe- 1. ' r-r •.H. . i 4q4: , ._ . ,
• p .:.� -
4. This historic photograph documents / '^PM •a t 5 yliGP I I' 1 i , iti'
the original 1903 Neo-classical into- =i PM .,-- '� -
rior of the banking room. ' AK._ '•b.' • !'
:'k * Y,
•
_ - Y xrr. ,a.S MS'
". . fir(' " 't .?, 1
f h 7 • i r a
V
'- h} kv f,r ya y 1 ' _ *. •- yy.
5. Interior of the banking room J• 'q Via- ' .;, 4 . -.--Mg ;
prior to Thisphotograph,latsrehabilitation. l : =: w d .-..., -
the same view as -r «; • sr '*
the photograph above,documents the 4 .- ! ..
interior of the banking room after h•�-"- '-� j- - ns�
the 1950s remodeling that removed '' ` "s nC
all significant historic fabric. 'g �
L s
r A +'}
am- ''.•'L RY „�,�'"V�;i
+tit T -._ \. " 1 _-..` .- --;.
T
1 , •
1
6, Interior of the banking room , Ill umw•
after the most recent rehabilitation. o�
This view is of the banking room after .
the rehabilitation in which a Victorian - 1 i = ,t .
style interior was installed. Because 'e ',.,. :'. - .. -
•
the interior prior to the rehabilitation \
had been determined to have no historic ;:.;;i
- •I INti::4 .
character,and because this projecta •
fully met all three criteria outlined in `f` '
;!..
the text,it was certified. I - -- `- _ y+ -. i
_ 0
F
Technical Preservation Services I Interpreting
Preservation Assistance Division
National Park Service I the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards tor Rehabilitation
Number: 82-025
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
4. Retention of Significant Later
Alterations/Additions (conformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (conformance)
Subject: ENTRYWAY ALTERATIONS IN CARRIAGE HOUSE CONVERSIONS
Issue: The rehabilitation of historic carriage houses into usable living spaces often
poses difficulties for owners undertaking such conversions. These structures are often
more modest in detail than the main house they serve, and generally lack architectural
features such as window and door surrounds, elaborate cornices, and high quality
brick-work. Nonetheless it is important that their essential form and integrity be
preserved during the course of rehabilitation.
Doors and openings are frequently the most distinguishing features of carriage
houses. Owners, however, often find it necessary to modify these features for the
following reasons: to allow for privacy, for adequate light and air, and for more
efficient access into the interior living spaces. Owners should be concerned about the
possibility of violating Standards 2, 4, and 5 by damaging historic fabric or severely
altering the integrity of the structure through the use of inappropriate infill designs.
Additionally, where original or historically significant doors have survived, they should
be retained rather than removed, and the sense of opening should be preserved.
Projects that fail to retain their "carriage house" character can result in denial of
certification. The following project provides an example of the mitigating
circumstances that existed to enable the approval of a particular infill design.
Application: The owner of an 1840 carriage house in a historic'district rehabilitated
the structure for use as rental units and upon completion of the project requested that
the work be designated a "certified rehabilitation." The two-story brick building had
been constructed with a balcony across the second floor and two arched doorways that
opened into the interior carriage spaces on the first floor. In 1934 the structure was
converted into apartments, and wooden doors were installed in the arched entryways.
These doors were not original elements of the structure nor were they significant to
the character of the carriage house. The rehabilitation work performed by the present
owner, according to the certification application, included refinishing the interior
woodwork; repairing existing wood sash, doors, and shutters on the balcony level;
paving the existing gravel courtyard with exposed aggregate concrete; repairing the
balcony elements; and replacing the wooden carriage doors with fanlights, sidelights,
and French doors.
82-025
The regional office determined that the project did not meet Standards 2, 4, and 5,
primarily due to the infill designs for the elliptical-arched doorways. The denial letter
stated:
Our office would have suggested, had the application been submitted
before work was begun, an alternative design solution which would have
incorporated a simple, contemporary entry into the large garage doors
to 'scale down' the openings.
The regional office also expressed reservations over the apparent replacement of the
balcony balusters and the extensive amount of paving that occurred within the
courtyard.
The owner subsequently appealed the decision. After hearing the appeal, the decision
was made to designate the work as a "certified rehabilitation." Although additional
balusters were apparently installed on the balcony, the hearing officer determined
that the replacement features maintained the simplicity in design and austere
detailing that existed prior to rehabilitation. Regarding the courtyard space, the new
paving covered the existing gravel surface, but its appearance as an informal
courtyard and not a formal garden or patio was retained, preserving its historical and
architectural integrity.
The major source of concern was the infill design for the carriage house doors. The
hearing officer agreed with the regional office that installation of fanlights,
sidelights, and French doors was an extremely formal solution for adaptively reusing
the existing doorways. A more appropriate approach would have been to design a
doorway that incorporated as much of the character of the existing fabric so that the
doors are able to maintain their original definition and historic character.
Nevertheless, because the need for light and air in the first floor spaces was dearly
established and no historic fabric was destroyed, the architectural elaboration of the
doorways was approved—although not recommended--as an acceptable treatment for
this particular structure.
Prepared by: Christopher A. Sowick, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-025
T+ a
. --- 4
A.... . ._... ' _
r i . 3 ` t____:0 t t .�i1
..t
��,-# ,.i I
. .....,.
i•
.r✓ .'.. }
-
wX ' L1,..„. ...1,... .
. y A . ms y ` `- -F. f e ,.;
1. Carriage house prior to recent 2. Completed rehabilitation 47
rehabilitation. This view incorporates showing formal infill design, repaired
1934 changes, including interior balcony railing, and paved courtyard.
alterations and wooden entrance doors This work was found to meet the Standards.
in archway.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 82-026
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
10. Reversibility of new Alterations/Additions
(nonconformance)
Subject: NEW ADDITIONS TO HISTORIC BUILDINGS
Issue: When rehabilitating historic buildings for tax benefits, the construction of new
additions to the original building often occurs. Such additions are usually necessary to
increase the available square footage and make the rehabilitation commercially
successful. To meet Standard 2, such additions should not significantly alter the
original distinguishing qualities of the building including its form, materials,
fenestration and stylistic elements. New construction should also be clearly
distinguishable from the original building and, as stated in Standard 3, should not give
the property an earlier appearance without historical basis. Additionally, it should be
compatible in size, scale, color, material, and character of the property, neighborhood
or environment, according to Standard 9. Finally, additions or alterations to historic
buildings should result in minimum damage to historic building fabric to meet Standard
10.
Application: An 1840s Classical Revival home, individually listed on the National
Register, was rehabilitated into five rental apartments (see illus. 1). The original
brick building had a projecting wing and stair tower on the rear of the building and a
roof configuration which reflected these projections. The projecting wing and stair
tower gave the building a distinctive F-shaped form visible from the east (side) and
rear of the building. A two-story frame addition was constructed on the rear in 1931.
The rehabilitation called for the demolition of the non-significant frame addition and
the construction of a large, two-story brick addition on the rear of the building. While
the 1930s frame addition had to some extent altered the shape of the building, the
original form was still discernible due to the small scale of the frame addition, its
separate roof, and its use of different fenestration and materials from the original
brick building. In the project work, the new brick addition transformed the irregular
shaped plan of the building into that of a rectangular plan and a substantial portion of
the external walls of the historic building became internal walls (see illus. 2).
The new addition also was constructed so that it appeared to be an integral part of the
original building. On the east facade, the new addition was constructed flush with the
original wall; the brick keyed into the original; and the addition painted the same color
as the rest of the building (see illus. 3). The cornice and beltcourse on this facade
were repeated on the addition, and the windows were duplicated in size, pane
configuration and lintel shape (see illus. 4). Two original windows on this east facade
were enlarged to complete the consistent appearance. On the west facade, two
windows were removed so that window placement would be more similar between the
82-026
original and new portions of the building. Further, where roofs of varying height and
shapes previously covered each projection, the original building and the new addition
were unified under a new symmetrical hip roof. For these reasons, the Southeast
Regional Office determined that the addition did not meet Standards 2 and 10 and
denied certification for the project.
The owner appealed the denial on the basis that enough difference existed between the
new and historic brickwork, cornice detailing and window placement for the building
to appear as if it had been constructed at different times. Also, a contemporary
addition had been originally planned, but the local historic review board required a
more traditional design.
The decision of the regional office was sustained on appeal. The hearing officer
affirmed that approval by local review boards does not ensure certification by NPS,
and that the Secretary's Standards take precedence over State and local regulations.
The hearing officer did not believe sufficient difference existed between the new and
old construction, which also contributed to the denial of certification. However, the
strength of the decision rested on the fact that the building's character had been
changed by both the overall scale and prominent location of the new addition which
substantially altered the historic building form.
A new addition of smaller dimensions could have met the Standards by using
contemporary, non-Classical Revival details, a setback between the new addition on
the east and rear facades, and by retaining varying roof configurations between the
original building and the addition.
Prepared by: Jean E. Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-026
al
3}sea;• I EM
fit! i''4 i7 ylip )1r 1 •• .ili"iiti 4F9.1t1:r t
. (.. I.. �S. i ti .j
: i i r
i
1. Front (south) facade after the rehabili-
tation. The front facade was not substantially
altered during the rehabilitation. Many of the
historic features, such as the lintels over the
windows, were highlighted during the rehabili-
tation of the front facade.
— ---=;---m ‘• *11111*.1140,1116461.1114bZU%iiioN.
P`•i��� ` ...1 - New brick addition
di :
-C i I, -11
L ' i
1 rM'eT P•
IF . l' , .
. .
.............A, - _
2. Plan after the rehabilitation. The black
line indicates the original configuration of
the historic building. The new brick addition
(indicated with a cross-hatching) replaced, in
part, a 1930s wooden addition.
82-026 original construction �k, new construction
3. East facade after the rehabili- '�' - `�'
tation. Note that the similarity _ �;4. .; =
in windows, beltcourses, flush wall --- -- — — '
construction and the new roof make
differentiating the new work from r.., mg -
the original work difficult. *-- — •
4.
M: - I J . .
41
{ .ti47' 1 ` .._ 4:.1sue.- t ti;;A:w .4lga
original wall ` new construction
r\
4. Connection detail between old and ' '�"`_
new construction. The new brick wall _,„ "
was keyed into the original brick wall . -
where the brick courses lined up. - . r r"" -
Note the continuation of the projecting "- "
beltcourse from the original wall to the - .._�' • : R R :
new construction and the similar treat- '
ments of the windows. : , r s
is,,,-, - ftS
17
. ,,,„...:,,.,,,,..,..,,,,kt...
....,.......,„....., .....,....:,, ...... „2,.....,.,
,.....,,,,, i
........ ...„.......... ..„.„.....,....,....., %AC*. , -
v("?s
11
T 4
A
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 82-027
Applicable Standard: 4. Retention of Significant Later
Alterations/Additions (conformance)
J
Subject: REMOVAL OF SIGNIFICANT EARLIER EXTERIOR ALTERATIONS
Issue: Property owners and architects sometimes underestimate the significance of
prior alterations and additions when planning rehabilitation work on historic
buildings. Motivated by a desire to restore the original appearance of a building, to -
create space for a new addition, or to modernize the existing features, the owner or
architect may remove non-original elements, such as wings, porches, bays, or
storefronts that are evidence of the history and development of the building. These
features may have acquired architectural or historic merit in their own right.
Removal of significant alterations and additions may violate Standard 4 and result in
denial of certification for the overall rehabilitation project.
Application: A four-story, brick commercial building in New England dating from
1883 with alterations in the 1920s was proposed for rehabilitation to provide prime
office space with a restaurant on the ground floor (see illus. 1). Initial plans for
rehabilitation included a new recessed addition and the removal of features added in
the 1920s, notably the decorative clad metal projecting bays and the storefronts. The
bays were in good physical condition while the storefronts had rusted beyond repair.
These 1920s features were to be replaced with new glass and metal bays and new
projecting storefronts in a contemporary design reflecting the detailing of the
proposed addition (see illus. 2). In reviewing the application, NPS referred to the
National Register nomination for this individually listed property, which described the
significance of the building in terms of its continued use as a local commercial
enterprise and its physical evolution to meet the changing demands of its commercial
use. The 1920s additions were therefore, significant to the architectural evolution of
the building, and NPS determined that they should be retained. The owner was
notified that loss of these features would result in denial of certification.
The owner agreed to repair the existing bays, which were in good condition. The
owner was also willing to submit revised designs for replacing the storefront which
would retain the character of the building as it appeared in the 1920s.
When the modified storefront design was submitted (see illus. 3), NPS was able to
complete its review. The proposed storefront design, which was of contemporary
wood and glass configuration, was determined to be compatible. As part of the overall
82-027
review, the design for the proposed recessed addition was evaluated and also
determined to be compatible with the historic building. The project was therefore
given preliminary certification.
Prepared by: Floy A. Brown and Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable.beyond the
unique facts and circumstances of each particular case.
1. NE corner before rehabilitation. 82-027
This 1883 brick commercial building ->
had projecting metal bays and storefronts i. -,..low
added in the 1920s. These 1920s features y f " :_`" .i ��_
�= ice: to 4 .
were determined to be significant elements . -�:—�;,, _ � _
that reflected the commercial development ` ' i °` I- -i �1�`
of this property. As part of the reha- I� '--_ 0 t _t_
bilitation, it was determined by NPS that i �. I i t Lk
these features should be retained. -! 111172 . , ...- - -.. ci,
• --- I
f
-
J la A •
- F 1 • 14 , .-- _ = == -
2. Proposed rehabilitation: east facade. F` `K . , ,„ , 41 in
_• _.
This first proposal called for the removal
of the corner storefronts and the replacement
of the side storefront and projecting bays
with a projecting storefront and bay combi- - =—_ - -- -- -
nation. A small recessed contemporary addition ' . I 1 1 1 I I ;
Ik
was also proposed to the side and rear of _ 1
the building. This proposal was not approved _ n r__ _ L __
because of the loss of significant features -
of the building. ! e. '��`
1 il
EL 0 D.(7.....) ] ,
uuur .4 -1 0 _ t__,
lli
EI .
1171
..=_-_.-g 1--=':‘--) 0 1"3"=•t
7 -, ;MI6-, \, i 0 0
G I , J� L_..-.n , uur-
--•-.-.•
1 I as N•••1 4/.•L
3. Approved design for rehabilitation. _-. -_- . _ r'_T._ __._-_ ___ _�,�} i_. �_ .__ i'
This proposal retained the significant - _ '- .� if- 1 ➢ r: I. : __ t.r
features of the building and met the �R ,
Standards. The bays, which were in l�Il�wllw._I lat,I U1
good condition, were repaired. The .,I'- 'Al i ��� - -s �, �I
storefronts which were in poor condition, �- a . -• ' Pi I� _ -. l_i
were replaced with sympathetic new y ' — _._
infill material and the proposed recessed , i
greenhouse addition was approved as being II'' 1 II i
compatible with the historic building. mina -
The rehabilitation proposal was given ` t�Ital1M. •;1_il.i •- ' `=,I
preliminary approval. I 11 i • i�,
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior s
Washington, D.C.
[Standards for Rehabilitation
Number: 82-028
Applicable Standards: 1. Compatible New Use (nonconformance)
2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Contemporary Design for new
Alterations/Additions (nonconformance)
Subject: INCOMPATIBLE DESIGN FOR ALTERATIONS AND ADDITIONS
Issue: Historic buildings can be successfully rehabilitated for new uses--such as
restaurants--with the effect of stimulating business in an entire community. A new
use that differs dramatically from the original use of a building will usually require
some alterations or additions. Standard 9 recognizes this need and states:
"Contemporary design for alterations and additions to existing properties shall not be
discouraged when...such design is compatible with the size, scale, color, material, and
character of the property, neighborhood, or environment." Therefore, when a
rehabilitation project is being planned that involves such broad considerations as
installation of kitchen equipment, guest seating, alternative means of egress, and
additional mechanical and electrical systems needed to fulfill code requirements for
the new use, it is particularly important to work out.a design that does not result in
visually obscuring or physically altering the building or the site's distinctive features.
Ultimately, adaptive uses requiring new additions or alterations that overpower the
scale of the historic building are not considered compatible new uses and will thus fail
to meet Standard 1 as well. This Standard states: "Every reasonable effort shall be
made to provide a compatible use for the property which requires minimal alteration
of the building, structure, or site and its environment...." Therefore, through careful
planning by the owner and architect and submission of the historic preservation
certification application before construction gets underway, a design solution for the
new use can usually be reached that respects the character of the property, and, at
the same time, is sensitive to the owner's economic goals for the rehabilitation
project.
Application: An 1868 railroad station in a small, northeastern city and individually
listed in the National Register was being rehabilitated for use as a restaurant (see
illus. 1). Although the railroad station was saved for almost certain demolition and
much of the project involved preserving significant architectural features such as the
cupola, main stairway, and slate roof, certification was denied because the overall
design for the new use introduced numerous additions and alterations that changed the
character of the building (see illus. 2). In its comments to the owner, the regional
office concluded that the project could not be certified because the scale of the
original station and its historic character and setting were changed as a result of
several areas of work, including: dosing-in a 1920s baggage platform with solid
masonry; creating a large-scale, glass roof enclosed platform adjacent to the 1920s
platform; constructing a new enclosed platform on the end of the building opposite the
original platform, and adding railroad cars ("rolling stock") to the end platform in a
82-028
manner which had no historical basis. Although certain additions and alterations were
essential for the railroad station's new use as a restaurant, the architect's total design
resulted in obscuring three of the original facades, when, historically the station had
had four highly visible facades. Again, while the selective addition of rolling stock
was not opposed by the regional office in principle, that, together with the other new
design features, created a cumulative effect that was incompatible with the character
and setting of the property.
When the owner appealed the regional office's decision, the hearing officer sustained
the earlier decision to deny certification; however, the appeal decision was later
reversed when new information was presented by the owner showing that "considerable
work on the station was underway in the fall of 1977" before issuance of final NPS
regulations (see "Review of Historic Preservation Projects" Number 81-03). In the
final certification letter to the owner, the hearing officer reiterated:
I am...convinced that your basic conceptual plan for rehabilitation
could have been achieved in a manner in keeping with the "Secretary of
the Interior's Standards for Rehabilitation" by making several
reasonable changes. I believe that this office could have offered sound
and practical advice drawn upon the experience which we have had
with hundreds of preservation projects throughout the nation, including
underutilized and abandoned railroad stations.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-028
III
•
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1. The historic railroad station, built in 1868, as it appeared prior to the rehabilitation
and the construction of major addition. .
the historic railroad station
(-enclosed platform enclosed platform
1
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A
.......:„....:.::::::::*:::::i*......::::::::. :,-,, ,.,.::::::•,..:;,:::::,..;:•• ••:: ::::::"...:::g•'.7';';:::::::••;:::-:,:,:::-.:Ir:••.2:'::::.::',-:;::':::::: :::::::::::::::,::::`:::;i:ii.ii.ii:.:iiiiiiiii,
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roiling stock
2. The original historic station (dark shading) has been surrounded on three sides with
enclosed platforms and permanently affixed rolling stock. All are interconnected with
roofs that have added an imposing new scale to the project. This drastic change of
scale was in part responsible for the original denial of certification.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Intenor's
Washington, D.C.
[Standards for Rehabilitation
Number 82-029
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
3. Recognition of Historic Period (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
Subject: INAPPROPRIATE EXTERIOR ALTERATIONS:
INDUSTRIAL/WAREHOUSE BUILDINGS
Issue: In converting historic industrial/warehouse buildings into prime office space,
owners and developers sometimes fail to pay adequate attention to the goals for
rehabilitation and re-use defined in the Secretary's Standards. While alterations must
usually be made in conversions to office space in order to accomodate a new clientele
(e.g., air conditioning, efficient lighting, code required electrical/mechanical systems,
public spaces, etc.), Standard 2 should still be central to all rehabilitation project
planning: "The distinguishing original qualities or character of a building, structure, or
site and its environment should not be destroyed. The removal or alteration of any
historic material or distinctive architectural features should be avoided when
possible."
When a historic industrial/warehouse building is viewed in the planning stage of a
rehabilitation project, the structure's distinctive features such as multi-paned windows
and unpainted brick are sometimes overlooked. From this erroneous starting point, a
series of cosmetic changes may be planned in an effort to "improve" the building's
exterior appearance. Unfortunately, the "improved" building often no longer bears a
significant relationship to the historic industrial/warehouse building or its historic
setting. In some situations, when exterior alterations result in the loss of
distinguishing original features or character, the building may not qualify as a
"certified historic structure," and, in consequence, will be ineligible for tax benefits.
If the building has already been declared a"certified historic structure," the
rehabilitation work may be denied certification.
Application: A six-story 1913 brick warehouse located in a historic manufacturing
district in a large southwestern city (see illus. 1) was rehabilitated for use as an office
building. Assessing certain of the building's exterior elements as unattractive or
beyond repair, the owner planned and carried out extensive renovations (see illus. 2).
In an effort to "reduce energy use and create a comfortable working environment," the
original wooden window frames and their six-over-six panes—by far the most
distinguishing architectural features of the exterior--were removed and replaced by
windows with aluminum frames and single sheets of light bonze, non-reflective glass.
The traditionally unpainted brick was painted a reddish brown, and the precast
82-029
concrete lintels and sills were painted a cream color to unify what was considered an
uneven appearing facade. Additional work included the introduction of an arch entry
with etched glass, a front brick plaza, and carriage lamp and awnings.
When the regional office conducted its review of Part I of the application, work had
already been completed. The property was determined not to contribute to the
district because "the integrity of the original architectural features have been
irretrievably lost." Shortly thereafter, Part II of the application was reviewed and the
work declared to violate Standards 2, 3, 5, and 6. Removal of the original windows;
introduction of carriage lamps, which created an earlier appearance; and painting of
the facade for cosmetic purposes were specifically cited. The regional office's denial
letter also informed the owner of the right to appeal Part I and Part II simultaneously.
When the owner appealed, the hearing officer sustained the region's decision to deny
certification of the building as contributing to the historic district. In the letter, he
stated: "the recently altered building no longer expresses the architectural character
or the sense of time and place which define the district. As a result, the building does
not qualify as a 'certified historic structure' for purposes of the Tax Reform Act of
1976, as amended, and is exempt from the historic preservation provisions of the act
which apply to 'certified historic structures."
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
- i 82-029
!�
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1. Before the rehabilitation, this warehouse retained many of the original multi-paned
windows and its unpainted red brick exterior walls.
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2. As a result of the rehabilitation, which converted the building to office use, the
windows were replaced with fixed glass and the exterior was painted. These changes
altered the character of the historic building, and the project was denied certification.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Department of the Interiorhe Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 82-030
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
9. Compatible Contemporary Design for New
Alterations/Additions (conformance)
Subject: CREATING RECESSED ARCADES WHERE COMMERCIAL
STOREFRONTS FORMERLY EXISTED
Issue: When a commercial retail structure with street level storefronts is being
rehabilitated for a new commercial use that does not involve retail merchandising,
property owners or developers sometimes plan to replace the existing storefronts
because those elements are no longer needed and because owners wish to give the
building a new image to reflect its change in ownership and use.
The Secretary of the Interior's Standards are intended to encourage rehabilitation
while respecting the character of historic buildings; thus Standards 2 and 9 state:
"The distinguishing original qualities or character of a building shall not be
destroyed. The removal or alteration of any historic material or distinctive
architectural features should be avoided when possible"; and "contemporary design for
alterations and additions to existing properties shall not be discouraged when such
alterations and additions do not destroy significant historical, architectural or cultural
material, and such design is compatible with the size, color, material, and character
of the property...."
The removal of a storefront or storefronts in order to create an arcade at the street
level can alter the historic character of a commercial retail structure in two ways:
(1) by destroying historic material or distinctive architectural features; and (2) by
introducing a void or negative space where there had formerly been enclosed space;
thus altering the relationship of the first floor to the streetscape. When exterior
alterations result in the loss of a historic building's distinguishing architectural
features or character or an incompatible contemporary design solution is introduced,
the rehabilitation work will not be in conformance with Standards 2 and 9; in
consequence, certification will be denied.
Application: An 1883, five-story brick commercial structure in a mid-western city,
and individually listed in the National Register (see illus. 1 and 2) was to be
rehabilitated as the corporate headquarters of a manufacturer of industrial mixing
equipment. The company intentionally chose to rehabilitate an important historic
structure in a marginal urban location as a commitment to the revitalization of the
decaying urban center. The company also wanted, however, to impress its corporate
image on the historic structure so that the revitalized building would be clearly linked
with the firm in the eyes of the community. To accomplish this, the rehabilitation
proposal called for a new plaza entrance created on the site of two demolished non-
historic structures, the erection of a new glass "pyramidal" structure for an entrance
82-030
lobby immediately adjacent to the historic building, and a recessed arcade where the
storefronts were located. The owners' stated purposes for the recessed arcade were to
show the change in function of the structure and to lead the pedestrians through the
arcade to the new plaza entrance. Glass block was to be used in the arcade as well as
throughout the interior, reflecting the thematic use of industrial glass as part of a
strong design concept. The project had several dynamic qualities; however, the
proposal to remove the storefronts and create a glass block wall recessed eight feet
behind the front plane of the structure was found to be in violation of Standards 2 and
9 (see illus. 3).
The denial letter outlined the reasons for this decision: "The historical photographs of
the building show that the ground floor, although altered a number of times throughout
its history, was used for commercial purposes up until the present. This commercial
character is largely defined by storefronts. We concur with the State Historic
Preservation Office that the commercial character of the first floor is an important
feature of the building and that the open design of the ground floor is not compatible
with the scale and character of the solid, heavier appearing upper stories of the
building. We also question whether glass block, a modern material which is to be used
extensively in your designs, is an appropriate infill material for the ground floor of
this historic building. The proposed arcade design violates Standards 2 and 9 and is
inconsistent with the Department of the Interior's guidelines for rehabilitating
storefronts..."
When the owners appealed the denial of certification, the hearing officer sustained the
denial while encouraging the owners and their architects to work with NPS to explore
alternative designs that would meet the Standards.
The project was subsequently redesigned (see illus. 4) to include a storefront
appearance with non-recessed glazed windows, raised sills and transoms. The central
doorway, a prominent feature in the original ground floor design, was reestablished in
the new proposal. A corridor was permitted behind these glazed"storefronts" because
it was determined that there would be no loss of historic material in the creation of
this new architectural feature.
Prepared by: Gary L. Hume, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
•. -
I
82-030
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82-030 Ali\ •-_-.-----,
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3. Model showing the proposed first floor recessed arcade. This design was
determined not to meet the Standards.
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4. The approved design restored the original historic entrance and the store-
fronts were glazed.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Intenor's
Washington, D.C.
rStandards tor Rehabilitation
Number: 82-031
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (conformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
Subject: INAPPROPRIATE ALTERATIONS TO ROOFS
Issue: When working with rehabilitation projects, owners are frequently confronted
with the problem of dealing with historic buildings which have undergone substantial
changes over the years. While some of these earlier alterations may have been carried
out with sensitivity and may even have acquired significance in their own right, other
changes may not be sympathetic or appropriate to the original design of the individual
building or building complex.
Roofs, including features such as dormers, may be highly visible components of
historic buildings and may also be integral parts of overall design and architectural
style. Because roofs perform the function of keeping buildings weathertight, they are
especially subject to change, usually because of necessary repairs and routine
maintenance. Therefore, when rehabilitating buildings which have previously
undergone inappropriate roof alterations, it is particularly important that the new
design respect any remaining original roofing materials and features in order to
conform to Standards 2 and 5. Previously altered architectural features should either
be retained as they currently exist (they may have acquired significance in their own
right); replaced in a manner known to be an accurate duplication of their original
appearance; or, where those alternatives are not possible, treated in a contemporary
style in accordance with Standards 4, 6, and 9.
Application: The owners of two adjacent, mansard-roofed, Italianate rowhouses (part
of a row of three) converted these formerly residential buildings into professional
offices and submitted a single application describing the completed work. (The third
building, House C, although rehabilitated at the same time, was not part of this
project.) The buildings were certified as contributing to the significance of the
historic district. Prior to rehabilitation, House A, the house on the left end of the
row, still retained its original segmental arched dormer with applied decoration, and
imbricated slates still covering the roof (see illus. 1). Its companion, House B, had
long ago lost its original dormer, as had the third member of the row, House C. The
dormer on both B and C had been replaced by a hipped double dormer, and the
decorative slate had been replaced with asphalt roofing shingles.
82-031
The rehabilitation included complete remodeling of the interior into first lass office
space, and, in addition, much exterior work was done. During rehabilitation, the one
remaining original arched dormer was removed from House A, and in its place, two
new hipped dormers were constructed, matching the two new dormers which were
constructed on each of the other rowhouses (see illus. 2). The design of these new
dormers was not based on the previously existing and original segmental arched
dormer, but adapted from the dormers on Houses B and C prior to rehabilitation. In
addition, the original slate was removed from House A and replaced with asphalt
roofing shingles. This was apparently done in an effort to give the roofs of the three
buildings a sense of continuity.
When the application for the completed project was submitted to NPS, the project was
denied on the basis of Standards 2, 5, and 6 in concurrence with the recommendation
of the State Historic Preservation Officer. The reasons stated for the denial were:
"The segmental dormer with its applied wood detailing was replaced
with a pair of hipped dormers rather than being repaired. If the
original dormer was in deteriorated condition, its fabric should have
been repaired or replaced with like materials in a duplicate design."
"The surface of the mansard roof was originally covered with slate cut
and laid in a decorative pattern. This roof and its surface were a
significant historic feature of the structure. The slate was replaced by
asphalt shingles which have diminished the historic character of the
structure."
The owners appealed the NPS decision, and defended their project by quoting from the
Standards. They argued that the hipped dormers previously on Houses B and C should
be recognized as changes that had taken place over time, and had assumed their own
significance. The owners also stated that replacement of the roof of House A had
been necessary due to its deterioration, and that by recovering it with asphalt
shingles, like those on Houses B and C, the three houses once again presented a
uniform appearance.
Upon review of this appeal, the hearing officer at first sustained the initial denial.
Several weeks later, however, based on the property owners' follow-up letter, he
reconsidered his decision to deny certification for both buildings. At this time he
determined that the rehabilitation of one unit of the project, House B, did meet the
Secretary's Standards, since that building had neither an original dormer nor an
original slate roof immediately prior to rehabilitation, thus, no significant historic
fabric had been lost. However, he upheld that part of his original decision denying
approval of the second unit, House A, because it had lost significant historic fabric
when the original dormer and slate roof were removed during rehabilitation.
Prepared by: Anne E. Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-031
. ;
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1. The houses prior to rehabilitation. House "C" was not part of the project.
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2. The houses following the rehabilitation with identical hipped dormers and
asphalt shingled roofs.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior I the Secretary of the Interior's
Washington, D.C.
(-Standards for Rehabilitation
Number: 82-032
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Evidence (nonconformance)
Subject: REMOVAL OF ENTRYWAYS ON PRINCIPAL FACADES
Issue: The new use of a building sometimes requires changing the main entrance of
the building to meet various building codes. In some situations it may be possible to
close off the historic entry while retaining the hardware, doors and surrounding trim.
However, entryways on principal facades are often important architectural features,
with distinguishing stylistic elements and fine craftsmanship. The entryway is usually
an integral part of the overall design of the facade and is often a highly ornamented
focal point. Altering entryways without respecting this design relationship may result
in serious damage to the character and appearance of a historic building, and thereby
violate Standards 2 and 5. If the doorways and their surrounding features are
deteriorated, they should be repaired rather than removed, according to Standard 6.
Violating these Standards can result in denial of certification of project work.
•
Application: The rehabilitation of a 1909 two-story Classical Revival bank building
proposed for listing in the National Register was denied certification by NPS because
the project work included the removal of a recessed corner entryway (see illus. 1 and
2). This entryway was an important element in defining the historic character and
appearance of the building. The large, pedimented porticos were a distinguishing
feature of the building's style. The recessed entrance, positioned at the corner of the
building, created a focal point on the otherwise symmetrical facade and thus
contributed greatly to the architectural character of the building.
When the entryway was eliminated, the pedimented porticos were removed and the
doors replaced with windows set flush with the exterior facades. Also, the original
first floor windows were replaced. Each window, originally composed of a fixed,
single pane sash and a multi-paned transom, was replaced (including the transom), with
a fixed, single pane, double glazed window. The project work did, however, include
several desirable repairs. The facade of a 1950s addition to the historic building was
replaced with one more visually compatible with the materials and detailing of the
historic building. Missing cornice and pilaster pieces of the historic building were also
replaced (see illus. 3 and 4). However, the positive effect of this work was not
sufficient to outweigh the damage done to the historic appearance of the building once
the entryway and original first floor windows were removed.
82-032
In his request for an appeal, the owner stated that the pediments were too
deteriorated to be repaired, and the corner entryway-presented security and
handicapped access problems, which required compliance with various Federal and
State building codes. He also stated that the contractor had removed the first floor
windows without his approval. Replacement with double glazed windows covered the
damage which occurred when the original windows were removed and also met the
State's energy conservation code.
The hearing officer sustained the original decision on the basis that the project did not
meet Standards 2, 5, 6. The irreversible alteration of the first floor window, and,
especially, the removal of the porticos and the blocking in of the recessed corner
entryway, resulted in a serious loss of significant historic building fabric that
substantially altered the historic appearance of the building. Additionally, the
contractor's error in removing the first floor windows was unfortunate, but does not
waive the requirement that project work must meet the Secretary's Standards for
certification. The hearing officer reiterated that the Secretary's Standards take
precedence over other building codes for the purposes of certification, and stated that
compliance with State and other Federal building codes could have been accomplished
without the substantial changes which occurred. The corner entryway could have been
securely locked and handicapped access could have been provided through the newly
constructed street level entrance on the addition.
Prepared By: Jean E. Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-032
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1. and 2. Pre-1978 rehabilitation. Note the original recessed corner entrance and the
stairway. Also note the original windows with multi-light transoms. The existing side
addition was not sympathetic to the historic building.
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3. and 4. After rehabilitation. The recessed corner entrances were removed along
with the steps and the overhanging pediments. The corner was infilled with new
windows flush with the exterior walls, eliminating all traces of this original corner
feature. The first-floor windows were replaced with fixed thermal glass, including
the multi-light transoms. Although the addition was sympathetic in scale and
materials to the original building, the change3'to the historic structure did not meet
the Standards, and the project was denied certification.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards for Rehabilitation
Number: 82-033
Applicable Standards: 1. Compatible New Use (nonconformance)
2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
Subject: INAPPROPRIATE PORCH ENCLOSURE TREATMENTS ON SIGNIFICANT
REAR FACADES
Issue: As a general rule, the front and street facades of most buildings tend to be
more ornamental or of a higher architectural quality than secondary facades. Many
secondary facades, however, can be significant in their own right and make an
important historical and architectural contribution to a property or district. An open
courtyard behind a 19th-century townhouse in New Orleans, a municipal building with
an identical appearance on the "front and rear," or a two-story open porch on a side
facade of a residence in Charleston, are all examples where "secondary" facades play
an important role in defining the character of a historic building. Renovation work
that destroys or irreversibly alters the architectural character of important secondary
facades fails to meet Standard 2 and will result in denial of rehabilitation.
Porches are a very common and often dominant feature on the rear facades of many
residential buildings, and owners are encouraged to preserve them in the course of
rehabilitation. The historic and architectural significance of traditionally open
porches varies from building to building; at the same time porches may also be
important as a common or unifying feature within a district or group of buildings. In
some historic buildings, the architectural significance of a one-story or two-story
porch on a rear facade is great enough to prevent porch enclosure treatments from
meeting the Secretary's Standards.
In assessing the need to preserve porches on secondary facades, the existing physical
condition and general historic integrity must be considered. Insensitive previous
alterations to significant porches are considered in the course of review; however, if
the porch is in good condition and retains its basic architectural integrity, the historic
appearance rather than subsequent changes remains the principal basis for evaluating
the effect of the proposed rehabilitation work. •
In the two cases discussed below, the owners of the properties substantially altered or
destroyed the historic character of rear elevations by enclosing or demolishing original
porches. Both projects were determined not to meet the Standards, but in each case
NPS established that part of the porches could have been enclosed in a manner that
would have preserved the overall character of the facade.
82-033
Application: The first building is located in a historic district in a Southern town and
was in deteriorated condition prior to rehabilitation (see illus. la and lb).
Photographic documentation indicated that the two-story porch on the ell extension
had lost considerable architectural integrity due to numerous inappropriate changes
that had occurred over time, as well as from neglect. On the ell porch, both the far
right (end) bays had been enclosed along with the lower left bay, and considerable
physical deterioration had also occurred. Despite its condition, however, the ell porch
remained a significant historic feature of the building and merited a sensitive
rehabilitation treatment.
NPS established that infill of the bays on the ell porch was approvable in concept for
the following reasons: half of the bays had previously been enclosed; the ell porch was
considerably deteriorated; the porch was on a secondary facade; and the owner was
maintaining the open porch on the rear of the main house. In order to preserve the
general historic and architectural character of the building, however, a proposed
design would have to maintain the ell porch as a structural entity as well as retain
selective visual qualities of the porch design. The owner undertook the enclosure of
the porch prior to asking for guidance from the State and selected a treatment that
was not in keeping with the Standards. The end of the porch was rebuilt to align with
the back wall of the ell, and continuous siding was extended across the now-enlarged
rear facade. Thus, from the back of the building, the porch realignment and
subsequent work to the porch roof obscurred any visual evidence of the porch's original
configuration. Instead of maintaining the three-bay division of the porch, the owner
removed the existing columns and balustrades and added windows and siding to create •
an entirely new facade treatment (see illus. la-lc). This treatment left no clues as to
the original design of this portion of the house.
In providing future guidance to the owner, who was developing similar projects in the
district, NPS made the following comments:
A. The outer plane of many of the porches in the district consists of
three delineating features: columns which divide the porch into bays; a
roof or soffit overhang which establishes the upper and usually the
outer limits of the porch structure (excluding stairs); and balustrades
which serve to further define the plane of the bays. The National Park
Service recommends that the plane of the new wall be set back to
preserve these features when a new outer wall is constructed to
enclose a porch.
B. Often the most difficult problem to be overcome in enclosing a
porch is the loss of the original sense of openness. Porches are
frequently an integral part of the architectural style and design of
buildings and in many southern climates also serve as connecting
passageways between rooms and between entire sections of a building.
Because of these important characteristics and functions of porches,
the National Park Service strongly encourages property owners to
retain the sense of openness, the visual presence of the original
exterior wall, and some of the shadow and light characteristics of
porches. In some cases, property owners have accomplished this by
using large sheets of glass within the bays (see Bulletin 80-001). Where
greater privacy is required, porch shutters might be retained or, if
suitable, added; in other cases, large roll-up blinds or shades might be
82-033
installed behind the glass to provide greater flexibility in light and
privacy control. Solid material, such as wood or stucco, sometimes can
be used depending upon the character of the individual building
involved. If operable windows are necessary and appropriate, they •
should be designed so as to respect the particular character of the
porch as well as the general architectural character of the building.
The owner was informed that few if any of the special concerns discussed above were
carefully addressed, and the rehabilitation failed to meet Standards 2, 5, and 6.
In the second case the one-story main residence (ca. 1875) was connected to a two-
story rear wing. As with many buildings in this residential district in the southwest,
the house was characterized by open porches on both the front and rear elevations,
reflecting not only the architectural style of its construction period but also
representing very practical climatic considerations. The only apparent previous
alteration to these distinctive features of the building was the installation of
bathrooms, which had led to the enclosure of a single bay on each of the porches on
the main house and on the two-story wing. Plans to demolish the one-story porch and
replace it with a larger masonry addition and also to alter the two-story porch
substantially by enclosing all the bays precluded the project from meeting the
Secretary's Standards (see illus. 2a-e).
NPS encouraged the property owner to retain the historic two-story porch in its open
state. Previous enclosure of the upper left bay had had only a minimal impact on this
important facade; the enclosure of all the remaining open bays, especially as proposed,
however, would have a major adverse visual impact. On the other hand, both principal
elevations of the one-story rear porch had already been altered in the past by the
enclosure of the one end bay. NPS was willing to consider further enclosure of the
one-story rear porch if additional space was necessary. A sensitive enclosure
treatment using large sheets of glass set behind the balustrades could meet both
functional needs while preserving the basic architectural character.
The hearing officer in the appeal made an inspection of the property and, with work
already underway, sustained the denial of certification of rehabilitation based on the
project not meeting Standards 1, 2 and 5.
Prepared by: Charles E. Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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, - r7 tation shows that only one of the rear porches
.S , " was preserved while the connecting ell porch
iv _.�I •'��' �';•.,, has lost its architectural identity. The bay
i► configuration of the ell porch and all historic
. i. ,
4. ‘'.41. �. a t/ detail has been destroyed as a result of the
y •' •• 1' -i ' application of continuous siding across the
'x _., .'i_ .�f! outer face of the bays. The ell porch also has
• - �• been made flush with the end of the back wall,
li i _ - _ further obscuring its original form.
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82-033
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_ > 2a. and 2b. The original open porches
=•,, -''`�. _"`"=.`I I..-- _ ' - (2a) represented a significant architectural
.,.- •-if .b__Jj ` I i' -/-•,-.,,111(�j ;. _:_ - feature of the building (left). In comparing
- ,_ -fir the photograph of the historic porches with
- = _ s �'.` J� =": = the rehabilitation plan (2b), note that all the
. - .L--�} r ' ;.- bays on the two-story porch (shaded) are to be
` - --� a&,?-.�„,,4 '• '- enclosed.
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2c. Only the upper left bay of the two-story porch had previously been enclosed.
Plans called for the use of windows and stucco finish to fill in all the bays of the two-
story porch. Rehabilitation elevation is shown here.
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bay •
previouslyenclosed (2e) was demolished to • �:� ' •s' '_�`•' ,
allow construction of a masonry addition (2d) t. I: ;--- 1, - •. • • , , A
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nearly twice as deep as the original porch. ;^; �� , �
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 82-034
Applicable Standard: 9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: ADDING ADDITIONAL FLOORS TO HISTORIC BUILDINGS
Issue: In some situations, one or more floors are added to the top of a building in the
process of rehabilitation in order to increase the usable floor area. Standard 9 of the
Secretary's Standards for Rehabilitation does not discourage such additions if the new
floors do not destroy significant historic or architectural fabric and the design is
compatible with the size, scale, color, material, and character of the property and
neighborhood. Adding one or more floors to a two- or three-story building generally
results in denial of certification. Such additions to buildings that are located in a
historic district comprised of two- and three-story structures can also have a negative
impact on the scale of the district. It is possible in some instances, however, to
increase a building's height without a major change in character. Adding one or two
floors to a six- or seven-story building, for example, may be appropriate if the new
addition does not result in the destruction of significant fabric and the new addition is
not visible from the street level.
Application: A six-story industrial structure in a commercial historic district was
proposed for conversion into office and apartments. Constructed ca. 1864, the
structure was considered one of the most important in the district with its five-story
cast-iron front largely intact (see illus. 1). The building's sixth story was a severely
deteriorated woodframe penthouse added at a later date. The district is largely
comprised of 4-6 story brick and stone warehouse structures along two relatively
narrow streets.
In his rehabilitation proposal, the owner proposed removing the penthouse and
replacing it with two new floors set back from the principal (cast iron) facade (see
illus. 2). The owner provided a sight line sketch in his application showing that the
new addition would not be visible from the street (see illus. 3). The new addition
would, however, be visible from the side and rear elevations but by design and
material was judged compatible with the district (see illus. 4). The National Park
Service concurred with the State's opinion that the penthouse had not acquired
significance in its own right and that the new addition "with two additional floors, set
back, not to be visible from the street, is a more considerate treatment and will serve
to enhance the architectural features of the facade." Rehabilitation work was
completed as proposed and the project received certification.
Prepared by: H. Ward Jandl, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-034
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1. Front elevation of the 1864 cast-iron industrial building before rehabilitation. The
sixth-floor wooden penthouse, added at a later date, was in a deteriorated condition.
82-034
1' = =
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section front elevation
2. Sight line sketch showing proposed 3. Front elevation showing the
two-story addition that replaced the compatibility of design between the new
deteriorated penthouse. addition and the historic building.
stair and elevator penthouse (7th)
extended sixth floor
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4. Rear and side of the industrial building prior to rehabilitation. The sketch lines
indicate the proposed addition for the roof of the building.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 82-035
Applicable Standard: 6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
Subject: INAPPROPRIATE WINDOW REPLACEMENT
Issue: Among the most common and perplexing issues in rehabilitation certification
review is that of window replacement. During rehabilitation, developers frequently •
replace existing windows with new sash for reasons of energy efficiency, ease of
operation and maintenance, or even to give buildings a new, rehabilitated look. In
cases where windows are part of a major facade and are significant to the character •
of a building, Standard 6 will generally apply. Missing or irreparable windows should
be replaced with windows that match the originals in material, size, general mullion
and muntin configuration, and reflective quality. Developers who install inappropriate
replacement windows risk having certification of their entire project denied.
Application: The rehabilitation of a 1929 four-story apartment building (see illus. 1)
within a historic district involved replacing all the windows in the structure (see illus.
2). The original windows--intact but severely deteriorated at the time work began—
were wood casements, most in a tripartite arrangement with two wide mullions
dividing each opening. The owner replaced these casement windows with new side-by-
side pairs of double hung windows (see illus. 3) with the result of creating one wide
mullion in the center of each opening. Because the new windows had been ordered
before the SHPO received the owner's application, neither the SHPO nor the regional
office was given an opportunity to comment beforehand on the appropriateness of
their design. In denying certification to the project, the regional office emphasized
the important contribution made by the casement windows to the building's original
character and the change in that character caused by the replacement windows.
On appeal, the regional office's decision was sustained. The hearing officer made the
following comments in his letter to the owner: "In this particular building, the mullion
and pane configuration of the original windows played an important role in defining its
character. I agree with the regional office that the replacement windows have
changed that character. Had the State Historic Preservation Officer or the regional
office been given an opportunity to comment on the window designs before their
purchase, I believe a solution more consistent with the design of the original windows
could have been reached."
Prepared by: William G. MacRostie, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-035 .:,'' " '
•
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t ; In �' pp. . window opening into three distinct parts.
' "e-'• ` '- - 1 i� ''_- New side-by-side pairs of double-hung
,tii • • - windows (bottom) give the effect of one
�; ' — _ .G'�,• . ^ - wide mullion in the center of each opening.
F ` -. The double-hung sash gives the opening a
strong horizontal line at the meeting rail.
2. The new double-hung windows,
found not to meet the Standards.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 82-036
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: USING NONHISTORIC FINISHES ON EXTERIOR WOODWORK
Issue: One of the major reasons for painting exterior woodwork is to deter the
harmful effects of weathering (moisture, ultraviolet rays from the sun, wind, etc.) and
thus slow deterioration of a building's exterior wooden cladding and decorative
features. Another important purpose for painting exterior woodwork is to define and
accent architectural features. Arbitrarily removing paint from historically painted
exterior woodwork and applying clear finishes to create a "natural look" alters the
character of a historic building and therefore violates Standard 2. Also, ultraviolet
rays from the sun tend to cause clear finishes to break down faster than primer and
finish coats of paint, which can result in exposing the historic exterior woodwork to
the effects of accelerated weathering.
Application: A two-story, late Victorian wood structure with cypress shingle siding
and decorative bargeboard located in a small, Mid-Atlantic coastal town was being
rehabilitated for use as a rental residential property. This building and other wood-
framed structures in the historic district had traditionally been painted. Although not
yet a"certified historic structure" in the district, the owner submitted Part 2 of the
application for review. At that time, work already accomplished on the house
included removal of all previous paint layers from the shingles (see illus. 1). The
proposed treatment, not yet undertaken, involved the use of a clear wood finish on the
stripped shingles (see illus. 2a and 2b) with a contrasting white paint on the window
frames.
In a letter to the owner—which supported the State's earlier review comments—NPS
stated that total removal of the paint as well as the proposed finish on the window
trim violated the Standards, and, should the structure be determined contributing to
the historic district at a later time, certification of the work would be denied unless
the owner agreed to re-coat the wood shingles in a traditional opaque primer and paint
in a color appropriate to the historic building and district.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-036 -
•
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1. Most of the white paint—the historical finish on the exterior woodwork of this
house—has already been removed. The owner's new finish proposal involved the use of
a dear finish over the exposed woodwork, a treatment that does not meet the
Standards_
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2a. and 2b. Details of the cypress shingles (left) and the decorative bargeboard (right)
show the paint stripped to the bare wood.
1
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 82-037
Applicable Standards: 9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
10. Reversibility of New Alterations/Additions
(nonconformance)
Subject: EXTERIOR STAIR TOWER ADDITIONS
Issue: Creating two separate means of egress from the upper floors of commercial
buildings is a fire code requirement that generally must be dealt with in rehabilitating
older buildings. Only in a very limited number of cases are variances given for this
important life safety feature. In a historic rehabilitation project, this code
requirement often makes it necessary to construct a second stair, either within the
building or as an exterior addition.
When such a new interior or exterior fire stair addition is required to meet code
requirements, its construction and detailing must be in conformance with Standards 9
and 10. These Standards address the important issues of retaining historically
significant building material during rehabilitation and designing contemporary new
additions that are compatible in scale, color, and material with the historic character
of the building. Finally, the new additions should be attached in such a way that
future removal will not impair the essential integrity and form of the historic
structure.
If it is determined that locating the new fire stair within the building would result in
the destruction of significant interior fabric, the required stair should be redesigned as
an exterior addition, preferably on a secondary facade. NPS certification that an
exterior fire stair is necessary to avoid loss of significant interior fabric means that
the owner's construction costs are eligible for tax benefits under IRS regulations 26
CFR Parts 1 do 7. If, on the other hand, the owner chooses to construct an exterior
fire stair rather than an interior fire stair solely to avoid losing valuable interior
rental space, the cost of the new construction may not be included in the overall
rehabilitation expenses.
Application: A 1909 two-story stone building, formerly a town hall and individually
listed in the National Register, was being rehabilitated for use as professional offices
(see illus. 1). The interior had been altered several times and there was little
remaining original fabric. The exterior, however, was almost in its original
configuration and the owner was taking great care to dean the stone and replicate any
deteriorated features.
82-037
As part of the rehabilitation, the owner was required by the local code to provide two
fire rated exits. The building contained one interior stair which could be rated and
one exterior fire escape at the rear (see illus. 2). Because the owner wished to provide
an elevator and did not want to use interior space to construct a second rated stair, he
decided to replace the fire escape with a combination fire stair tower and elevator.
However, because the property line was within nine feet of the building, he was unable
to accommodate the new addition as a freestanding element. Therefore, it was
necessary to attach the new addition to the rear of the building. While the facade
chosen was a secondary facade, the addition would be dearly visible from the side
street and the adjacent public parking lot.
The regional office was concerned with several aspects of this proposed new
addition. First, there would be a loss of historic fabric on the rear wall of the building
and on a portion of the slate roof where the new addition would be attached (see illus.
3). Second, the use of a gable feature on the new addition imitated the historic gable
on the front entrance of the building (see illus. 1), making the addition appear as a
modification of an original feature and not as an entirely new element. This gable
feature also increased the loss of historic fabric, notably at the roof, and increased
the scale of the addition. A third issue, though not as serious as the others, was the
selection of a variegated brown brick as the material for the new addition. The
historic building was constructed of cobblestones with strong architectural trim
features cut from brownstone. The regional office felt that a different material
would have been more sympathetic to the lighter color of the historic masonry. The
owner was thus requested to resubmit his stair tower design reflecting the above
concerns.
In the resubmission, the owner was able to address the three concerns of the regional
office (see illus. 4). First, the loss of historic material was reduced by eliminating the
roof gable from the stair tower addition (this feature was purely ornamental and was
not needed to house elevator equipment). Second, the scale of the addition was
reduced by eliminating the roof gable. Third, a new material was selected--a buff
cementitious coating that was scored at the watertable, beltcourse, and roof line to
pick up the proportions of the historic building's features.
The regional office was still concerned with the insertion of the addition into a third
of the rear wall and the subsequent loss of historic fabric (see illus. 5 and 6); however,
upon further investigation, it became evident that there had been some modifications
to this area of the rear wall at the time of the fire escape installation. The triple
windows and doors did not appear to be original after all. Much of the area impacted
by the new addition was therefore not historic, and, in its final review, the regional
office determined that the insertion of the exterior fire stair tower was marginally
acceptable.
In evaluating the overall project, the regional office took into consideration several
important factors. The exterior of the building was being carefully restored; the
original front entrance was being retained as the main entry; the new addition would
not alter the remaining historic windows on the rear facade; the redesign of the
82-037
addition resulted in loss of less historic fabric; and the addition was clearly
contemporary in design, and of a scale, color, and material appropriate to the historic
structure. Accordingly, the overall project was determined to meet the Secretary's
Standards.
Prepared by: Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
l v-fI 1
• •
% " J ' .'4i r
•
f+ ,s 'mil r' 1NJ
1, 0?;. r (`j .,
+ ,� /r 1. Front entrance of the
'•, '"— ....:•_. ��~ - • ~,: former Town Hall. The : _, I, I
•.�,;•, ' ��.. historic gabled entrance ...�.. '• 1' 1 �.• �,� 111 ,. ...
• " '--- ' , was retained as the main -' .I ._
; `. L, .,; • \ �'~ ' entrance to this building, r � 1 � � =s uss. �1�r
1'i'%, �, •- which was being converted ;',>• J r`:�Ir! j '` i
r Y • into private offices. t g�;,,tt, - le • ., rm-1'- ,.. ` 1 tom.
C �•-� I'd lln �j , ,h:�1'
• _,of
.. •741 r. .:t;.E. . ,
.. _tv., ,...L.,i.t ...
;ids, -1,4 v p
i ,y r ' i _ ' _�.1". �- ; 2. The rear of the former Town Hall with fire
• c. Z.•t '-'""''�' '' !,i,.,.....,a ? Ir escape. This is the proposed location for the
• • ! . • new fire stair and elevator tower.
•
.— •r 1 I �Y L:e
;+, t• ,, .w.. 1 • , , •,�.-•c�_ � .pViz, nwI ::, ,•' ''. + � ' ' •mo . is: •illi 1 r` 1 1 i I .1:} lb 3 .•�_�1�yr...�•, �, ,!
Pt
ell
1 }jl ".�.;!r»h 'y '.'• hl
.I ii�, •i-• R�AI .��•_�!Tit• ' • ;f
Tr,1 �iS1 IUI •� �11n J ._,�, r I L t�hill �•.i (.,.• ': �+
3. Rejected proposal. This proposal called for a 4. Approved proposal. This revised design eliminated the
gabled addition, which cut into the roof and rear wall gabled feature, thereby reducing the scale and the amount
of the historic building. The proposed brick was of a of historic fabric to be removed. The material was changed
mixed brown color, which would have detracted from the to a buff cementitious coating, which was more sympathetic
cobblestone and brownstone trim of the historic building. to the historic materials.
82-037
,eoP eTr 1-1!'E�
ef.Ae a&rrlt�
1 extettrf-. _mii
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I rib_ _
.:k. ..t:1 II..".
ill
lac iuiiuir,__ _I 1E—
ff
f°cor wn«trE.
5. Existing plan of the building. 6. Plan of the building with
proposed stair tower shaded in.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards for Rehabilitation
Number: 82-038
Applicable Standard: 6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
Subject: REPLACEMENT OF DETERIORATED ROOFING MATERIALS
Issue: Owners of historic properties are often confronted with the task of repairing
deteriorated roofs. This task becomes complicated either when the original roofing
materials themselves are highly significant features of the historic property or when
they are not original but the overall design of the roof is architecturally distinctive.
In the first situation, the owner must decide whether to replace the original roofing
materials in kind or use substitute materials that duplicate as closely as possible the
appearance of the original. The second situation requires the owner to decide whether
to replace the existing non-historic materials with something similar or replace them
with materials that would restore the original appearance of the roof. The Secretary
of the Interior's Standards for Rehabilitation state that the removal of historic
materials or distinctive architectural features should be avoided if possible, and that
any replacement material should match the existing fabric in composition, design,
color, texture, and other visual qualities. The two examples that follow cite specific
projects in which deteriorated roofing materials needed to be replaced and show how
the various alternatives for replacement were evaluated using the Secretary's
Standards.
Application: In the first example, the congregation of a midwestern church, built in
1901 and located within a historic district, requested Historic Preservation Fund grant
money to replace portions of the original Spanish tile roof that had deteriorated and
were causing water damage to the interior of the structure. The areas to be repaired
included two sides of the east-west gable and an unusual conical-shaped roof located
at the far western end of the gable (see illus. 1 and 2).
The roof, although stylistically distinctive, had not provided effective protection
against the weather. The tile had been designed and installed in such a way that water
became trapped beneath the courses and leaked into the structure. Repairs had
recently been attempted on the cone but proved to be ineffective in protecting the
interior from leakage. Repairs had also been performed on other portions of the roof
structure. On these areas the contractor installed a replacement tile that came close
to matching the original Spanish tile (see illus. 3). These replacement tiles not only
resembled the original tile in appearance but corrected the inherent design problems
of the original tle and subsequently eliminated any further leakage.
The consultant for the project proposed replacing the existing tiles on the east-west
gable with this same replacement tile. For the cone, the firm proposed three
replacement alternatives: flat tiles; asphalt shingles; or a red cooper standing seam
82-038
roof. The firm believed that the new Spanish replacement tile would not resolve the
moisture leakage problems, which were particularly evident at the apex of the cone.
Consequently, the firm did not include the new Spanish tile as a bid alternative.
The congregation evaluated the proposals and submitted a grant application to install
the new Spanish tile on the east-west gable and the flat tile on the cone.
NPS reviewed the proposal and concurred with the State Historic Preservation Officer
that the installation of the flat tile would not be in conformance with the Secretary's
Standards. The original Spanish tile was a highly visible and distinctive feature of the
building. Replacing this historic fabric with anything other than materials that
duplicate the visual appearance would destroy an architecturally significant feature of
the structure (see illus. 4).. NPS encouraged the congregation to consider repairing the
underlying wood decking and securely covering the cone with roofing felt in order to
use the replacement Spanish tile.
The church subsequently chose the least expensive treatment and installed asphalt
shingles on the conical-shaped roof (see illus. 5). The State Historic Preservation
Officer then withdrew the grant application with the support of NPS.
In the second example, the owner of a midwestern Queen Anne style mansion, built in
1892, requested Historic Preservation Fund grant assistance for the preservation and
restoration of the dilapidated structure. Listed individually in the National Register
of Historic Places, the single family residence had been neglected over the years and
had deteriorated considerably (see illus. 6). The grant application requested funds for
work items that were necessary in order to make the building immediately habitable.
Among these items were replacing the existing boiler and electrical systems, replacing
deteriorated or missing windows, insulating the attic, and installing new asphalt
shingles on the highly visible roof in order to provide immediate protection.
During the review of the application, NPS questioned why the original materials on the
roof were not being restored. The SHPO maintained that while cedar shingles were
originally used, certain circumstances precluded the reinstallation of similar
materials. First, the structure was in dire need of immediate repair and would
continue to need extensive preservation work in future years. Therefore, the asphalt
shingles would serve as adequate protection until future circumstances would allow
the possible restoration of the cedar roof. Second, the house had had asphalt shingles
for the past twenty years. In this case, reinstalling this type of roofing material would
not change the existing character of the residence.
NPS concurred with the SHPO's argument and decided that the entire project,
including the work on the roof, was in conformance with the Secretary's Standards.
To summarize: both of these projects dealt with the replacement of materials on
highly distinctive roofs. In the church project, NPS determined that restoration of the
historic roofing fabric was essential in order to help retain the architectural character
of the structure. Since a duplicate material had been used on other areas of the roof,
NPS considered it an appropriate replacement alternative.
In the Queen Anne mansion project, the owner was faced with an extensive list of
necessary preservation and stabilization work. Although the roof was highly
significant in design, NPS determined that immediate stabilization of the roof was
82-038
essential and that restoration of an historic appearance could be done in the future.
Furthermore, the roof was covered with twenty-year-old asphalt shingles. Therefore
replacement of the existing asphalt shingles with new shingles of that type was
determined to meet the Secretary's Standards.
Prepared by: Christopher A. Sowick, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-038
. I I I t
—
8 7 —
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in.&
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....r2 :..... 3 ‹ New FL&T dfl ut
...,..N
1. Sketch indicating new Spanish tile for sections 2 and 4, and flat
tile for section 3. The flat tiles were not considered an appropriate
treatment by NPS.
•
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(-L J±ft ,ii
; , "Lj ii t
-,,-.....,• _. . • 11 : 011 0 0 n Li : : :, ,4 :..
nAk
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err
• 2. View of conical-shaped roof at far western end of east-west gable. The
shaped Spanish tiles are a significant design element of the church.
82-038
Sy?
cqi: -,1
je •
^ice ,'
3. The dipped corners of the
replacement tile helped water
r �� pn
,'` to runtrap edo ffu thederneath underside
the back overlap
n4
- = out to the sloped exterior
;Ai ri_*� "� :' -'' V. . . drainage channels.
Drainage channel
t
t4" A,
.
• - ; i• e_' A r"ry .,,
j'i
f i i 4 sa. . tiaer• a0s IIa ifs\1t\�1\\P r••
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''"" e i, 14,%fit-0,,ra,I a a ilb
ry,t A al t y,; - a*
tN.NANNk i'i1 •.
4. View of cone with existing Spanish tile. The texture
and character would be lost if flat tiles were used.
82-038
rilil"
t% aw. Itt•titit.i..41..,,,,,t, ..1 .r� .♦�►ryJ� t
.I�%^�% �.i tVi
•
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4.4111011.
ttit
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5. Cone after installation of asphalt shingles. The architectural
significance of the cone had been destroyed due to the inappropriate
replacement materials.
. .t ;.ter
fib.
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•
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6. Street facade view of midwestern, Queen Anne mansion showing
considerable deterioration. Wood shingles originally covered the
roof surface but had been replaced with asphalt shingles years ago.
Technical Preservation Services interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior tie Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 82-039
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
7. Cleaning with Gentlest Method Possible
(nonconformance)
Subject: REMOVING PAINT FROM EXTERIOR WOODWORK USING
INAPPROPRIATE METHODS
Issue: Removing paint from exterior woodwork—with the exception of cleaning, light
scraping, and hand sanding as part of routine maintenance—should be avoided unless
absolutely essential. Within this maintenance context, deteriorated paint can be
scraped and sanded down to the next sound layer, and the surface repainted with a
color or colors appropriate to the style and setting of the historic building.
If, on the other hand, painted exterior wood surfaces display continuous patterns of
deep cracks or if they are blistering and peeling extensively so that bare wood is
visible, the old paint should be completely removed before repainting (of course, the
cause of paint failure should always be identified and corrected first, particularly if
moisture problems are evident). When such total paint removal is required, the
gentlest method possible should be selected for the particular wooden element of the
historic building (general recommendations include, for example, an electric heat-
plate for flat surfaces such as siding, window sills and doors; an electric heat-gun for
solid decorative elements; or chemical dip stripping for detachable wooden elements
such as shutters, balusters, columns, and doors when other methods are too laborious).
Harsh abrasive methods such as rotary sanding discs, rotary wire strippers, and
sandblasting should never be used to remove paint from exterior woodwork because
they can leave visible circular depressions in the wood; shred the wood; or erode the
soft, porous fibers of the wood, leaving a permanently pitted surface. Also, harsh
thermal methods such as those involving hand-held propane or butane torches should
never be used to remove paint from exterior woodwork because they can easily scorch
or ignite the wood. Causing damage to exterior woodwork by using any of these harsh
removal methods violates Standard 7 and will usually result in denial of certification.
Application: A two-story Victorian, white frame structure, ca. 1894, (see illus. 1)
located in a historic district in a small southern town was being rehabilitated for use
as a restaurant. When the owner submitted Part 2 of the certification application to
the State, several major areas of work had already been completed. Because the
existing layers of paint were cracking and peeling to bare wood, the owner elected to
remove all of the paint by means of sandblasting, then apply a light colored wood
stain. In addition, the deteriorated front terraces were removed (see illus. 2 and 3).
In its review recommendations to NPS, the State approved the interior rehabilitation
work but cited the exterior work as being in probable violation of the Standards.
82-039
After final review of the project, NPS agreed with the State, giving as its prime
reason for denial the sandblasting of the clapboards and stating that
"sandblasting...causes irreversible destruction of historic building fabric." This
treatment thus violated Standard 7. Other reasons for denial were the removal of the
front terraces and the staining of the clapboards, which, according to NIPS, constituted
major changes in the character of the building, therefore violating Standard 2.
Although NIPS apprised the owner of the appeal process, the denial was not
subsequently appealed.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-039
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1. 1894 photograph shows the structure's exterior woodwork painted white. Also, note
front terraces and second-story balustrade as part of the overall design.
82-039
41 g.
ru
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•
2. After project work. The front terraces have
been removed (second-story balustrade was
removed earlier) and the exterior woodwork has
been sandblasted and stained. The project was
denied certification.
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3. The clapboards were permanently pitted as a
result of sandblasting. Also, staining the siding
changed the building's historic character.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
_it
hD gtoD.Cof the Interior the Secretary of the Interior's
[Standards for Rehabilitation
Number: 82-040
Applicable Standard: 6. Repair/Replacement of Deteriorated or
Architectural Features Based on Historical
Evidence (conformance)
Subject: SUBSTITUTE MATERIALS OR SUITABLE REPLACEMENT MATERIALS FOR
SANDSTONE
Issue: A frequent problem encountered in rehabilitation projects is how to repair
deteriorating stone. One of the types of stone most susceptible to decay, and an
element common to many historic buildings, is sandstone (often known as
brownstone). Sandstone is not a durable stone. It is inherently fragile, a
characteristic further accentuated by the fact that it was frequently laid incorrectly
during the original construction of the building, exposing bedding planes to accelerated
weathering, spalling or delamination. At this time there is still no conservation or
preservation treatment that has been successful either in retarding decay or in
"cosmetizing" deteriorating standstone. Matching replacement stone is usually not
available because most of the original quarries have long since closed, and other
sandstones seldom come dose to providing a suitable match. We are generally left
therefore, with two somewhat limited options of traditional repair methods for
spalling brownstone: 1) to cover it with a cementitious stucco coating, or 2) to find
appropriate substitute or replacement materials. Both options, if carefully
undertaken, are consistent with the Secretary's Standards. When the repair or
replacement of deteriorated historic sandstone is necessary within a rehabilitation
project, work must be in conformance with Standard 6. "Deteriorated architectural
features shall be repaired rather than replaced, whenever possible. In the event
replacement is necessary, the new material should match the material being replaced
in composition, design, color, texture, and other visual qualities."
Application: The following two projects were submitted to the NPS for review as to
their eligibility for tax benefits. Both involved historic sandstone or brownstone
buildings in the Northeast. While both buildings suffered equally from severely
deteriorating stone, the restoration techniques chosen for the two buildings were
entirely different.
A. The first building (illus. 1-6) is an 1870 Italianate rowhouse located in a historic
district within a heavily populated urban area. The owners planned to use most of the
building for rental housing, and a portion of it for their own living quarters. The
application was submitted to NPS as an already completed project. In general the
work which had been done was very straightforward, and respectful of the basic
architectural character and significance of the building. The problem, however, lay in
the fact that the facade, covered with a brownstone veneer, was in a very serious
state of deterioration. Typical of a great many rowhouses of the mid-nineteenth
century in this area, this building was faced with a rather poor quality sandstone. In
82-040
addition, it is likely that the blocks of stone were incorrectly laid. Instead of placing
the stones on their natural bedding planes as they lay in the quarry (the correct
method), the blocks of stone were "face-bedded," which caused the stones to scale in
layers because they were placed on end with their bedding planes parallel to the face
of the wall.
The owners of the brownstone selected a technique of stone repair that called for the
delaminating stone to be scaled back to a sound layer of stone in order to provide a
"key" or "bond" for a coat of portland cement stucco. The first coat of stucco applied
to the stone substrate was tooled to match, as much as possible, the original shape,
design, and profile of the stone trim and moldings, then covered over with a finish
coat of stucco, pigmented like brownstone, and finally scored to resemble the original
blocks of stone. The resulting work closely matched the original appearance of the
brownstone, and approval for the project was given by NPS. The project had also been
approved by the local landmark commission and the State Historic Preservation
Officer, who noted the following: "The front elevation resurfacing simplified
ornamental detail (notably the foliated door brackets and molded window architraves)
and gave the building a Neo-Grec flavor somewhat different from its original
Italianate form. However, the resurfacing craftsmanship is good, and the original as
so deteriorated that the simplification (which was economically dictated) is quite
acceptable." (See illus. 3-6 especially.)
B. The small Renaissance Revival bank located in a historic district (see illus. 7), was
another building with a deteriorating brownstone facade. This badly delaminating
sandstone is possibly from the same, or nearby quarry as that on the previously
discussed building. The project proposal as submitted to NPS promised to be a
sensitive rehabilitation project, or as the project architect stated"an exacting
restoration." One rather unusual aspect of the project was the fact that the
"adaptive" use chosen for the building fulfilled its original function—that of a bank,
and the owner was the same banking firm that constructed the building in 1853. (In
recent years prior to the rehabilitation, the former bank had been converted to a
district courthouse.) Because the bank was "restoring its former head office as a
public gesture towards community rehabilitation efforts," it was willing to spend a
considerable sum of money on the building, and an extensive search was begun to find
a suitable replacement stone for the exfoliating sandstone of the facade. This
investigation explored many possibilities and came up with the following results: 1) It
would not be possible to re-open the long-closed quarry that was the source of the
original stone, nor was there any other American sandstone that would be suitable
(replacement stone was available in neither adequate amounts, sizes nor correct
color); 2) EngIish, German and Indian sandstones were investigated, but were also of
unsuitable color (too red, while the original was a purple-brown), the pieces of stone
were too small, and delivery was too uncertain; and 3) replacement of the decaying
sandstone with a granite that would closely match the color of the sandstone, and
would be carved locally. The project architect recommended the last-mentioned
alternative—replacement of the exfoliating sandstone with matching granite. NPS
requested and received samples of 1) the exfoliating sandstone, 2) the foreign
sandstone, and 3) the red granite. After careful analysis and comparison of the
82-040
samples, NPS agreed with the architect's recommendation, and the rehabilitation
project proposal was approved as being in conformance with the Secretary of the
Interior's Standards.
Prepared by: Anne E. Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-040
� —
l. Brownstone cowhuusebefoce
stucco repair. 2. "Brownstone" after stucco repair.
--ft �-- 3, Front door. Foliated brackets
of deteriorating brownstone.
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4. Repaired "bcownstone" doorway
brackets (simplified)
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
=shington, D.C.
rStandards for Rehabilitation
Number: 82-041
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
4. Retention of Significant Later
Alterations/Additions (nonconformance)
Subject: DEMOLITION AS PART OF REHABILITATION
Issue: The Economic Recovery Tax Act of 1981 established significant tax incentives
for the rehabilitation of certified historic structures provided that the rehabilitation is
generally consistent with the historic character of the building or the district in which
it is located. The Act states that only those buildings subject to depreciation that
have been substantially rehabilitated and that retain 75 percent or more of the
existing exterior walls in the rehabilitation process may qualify for preservation tax
incentives. •
Due to certain economic constraints, developers of rehabilitation projects sometimes
find it necessary to reduce the amount of available floor space in order to meet
limited market needs. A typical approach is to demolish portions of the structure for
one of two reasons: to eliminate the excess floor space that would otherwise remain
vacant; or to create parking facilities to serve the tenants and bring in added
revenue. As indicated in Bulletin #81-012, in limited situations, demolition may be
approved as part of the overall rehabilitation when: 1) the component to be demolished
is a secondary element or feature lacking special historic, engineering, or
architectural significance; and 2) the component does not comprise a major portion of
the historic site; and 3) persuasive evidence is presented to show that retention of the
component is not technically or economically feasible. When historic structures with
highly significant components are involved, demolition often conflicts with the
Secretary of the Interior's "Standards for Rehabilitation." Demolition of significant
portions of the historic structure alters the essential character and integrity of the
building and the district in which it is located and is contrary to Standards 2 and 4.
Application: The owners of a corner bank building located in the commercial district
of a northeastern city purchased the adjacent structure with the intention of
rehabilitating it for commercial purposes. Both structures are listed individually in
the National Register of Historic Places as well as being located in a Registered
Historic District.
The recently purchased building wrapped around the corner bank and had been
constructed in three phases (see illus. 1). The first section was built in 1897, the
82-041
second section in 1899, and the third section in 1906 (see illus. 2 and 3). According to
the National Register nomination, the first section:
"...was designed in a Romanesque Revival style. The first
floor...consists of large plate glass and cast iron storefronts, while the
upper stories are faced with buff brick and limestone trim. A deeply
projecting modillion cornice over a wide frieze completes the design."
The second section is a simpler version of the first, "utilizing the same brick and
limestone trim above the plate glass and cast iron storefronts." The third section:
"...employs red brick with granite trim rather than buff with
limestone. However, this...section relates to the others in scale and
decorative motifs of round arched windows in the upper floor and
deeply projecting cornice."
The owners proposed rehabilitating the original section as well as the corner bank
building. The proposal also called for demolishing the two later sections and
constructing a parking garage on their sites (see illus. 4). The owner and the State
Historic Preservation Officer felt that the later additions "were of little significance
and were included in the nomination because they were attached to the first section
proper." Additionally, the owners had conducted studies that showed the local market
would only support a limited amount of first class office space, and that adjacent
parking facilities were necessary in order to market the first class office space at the
highest rents possible.
The regional office denied the project on the grounds that it violated Standards 2
and 4. The denial letter stated that the regional office:
"...did not consider these additions to be minor later alterations lacking
significance. Their design features are similar in quality and character
to the first section...They were constructed within 10 years of the
original block to serve the same purpose. The projecting cornices,
upper floor and arched windows, stone lintels and sills, and horizontal
belt-courses are similar in scale and design motif to the earlier block.
Through design, use, and construction, these additions contribute
substantially to the property's significance. The loss of these additions
is in violation of Standard No. 4. The removal of these historic
buildings, with their distinctive architectural features, violates
Standard No. 2."
The owners subsequently appealed the decision. The hearing officer determined that
the work to be performed on the corner bank building met the Secretary's Standards,
while the rehabilitation and demolition proposed for its neighbor did not meet the
Standards. The hearing officer agreed with the regional office that through similar
design features, scale, and use, the two later additions contributed substantially to the
property's significance. This finding was strongly reiterated by the Acting Keeper of
the National Register of Historic Places. Therefore the substantial demolition work
would not constitute adequate preservation of the historic resource. The hearing
officer also expressed concern that the work might not meet the statutory
requirement of retaining 75 percent of the existing exterior walls following
rehabilitation. Although the economic necessity for demolishing the two later
82-041
additions in order to construct parking facilities was thoroughly considered, the
hearing officer decided that in the final analysis, the retention of the original
structure and demolition of the two later additions would not preserve the historic
character of the structure or the district in which it is located.
Prepared by: Christopher A. Sowick, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-041
di I
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!) , I j��k k:z." v r/ .. First Section�/ 1!• , ;,. Built in 1897 I1 ''
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1. Site plan showing layout of the project, proposed demolition shaded.
,
2. The corner bank building is on the left and
"' the first section of the adjacent building
m._,__.......................... .....................is%tioir
(constructed in 1897) is on the right. Both
will be rehabilitated according to the proposal.
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82-041
i
;� Q 3. The additions on the left and in the
r• middle are to be demolished for the new
,' / parking facility. The building on the
4#.kt far right is the corner bank building
•w and will be rehabilitated according to
•* the proposal.
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4. This drawing shows the design of the proposal parking facility.
Note the entry features to be retained from the demolished section. o0
N
1
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I-
Technical Preservation Services interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Tshington, D.C.
[Standards for Rehabilitation
Number 82-042
Applicable Standard: 6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (Conformance)
Subject: INAPPROPRIATE REPLACEMENT MATERIALS: CHANGES IN COLOR AND
TEXTURE
Issue: When rehabilitating historic buildings that have architectural elements or
materials so deteriorated as to necessitate replacement, owners may make the
mistake of choosing inappropriate replacement materials. Although Standard 6 calls
for repair of deteriorated features wherever possible, it also acknowledges that
replacement may be necessary and states that
"the new material should match the material being replaced in
composition, design, color, texture, and other visual qualities. Repair
or replacement of missing architectural features should be based on
accurate duplication of features, substantiated by historic, physical, or
pictorial evidence rather than on conjectural designs or the availability
of different architectural elements from other buildings or structures."
The choice of an inappropriate replacement for a significant but deteriorated material
may result in a change in the historic character of a building and lead to denial of
certification of that rehabilitation. In very limited cases, color may be able to help
lessen the negative visual impact of the replacement material, although generally it
will not be possible to recapture the historic character simply by painting over the
problem.
Application: A badly deteriorated 1880's New England beach resort hotel located in an
historic district (see illus. 1) was being rehabilitated for its original use. All of the
windows had to be replaced, but the owners used matching one-over-one wooden sash
and repaired the existing frames. Some of the rotten roof decking was replaced and
the roof reshingled with asphalt shingles. The deteriorated exterior doors were
replaced with reproductions of the originals on the first floor and reconditioned period
doors on the basement level. All of the exterior decorative trim was carefully
repaired. These repairs and replacements were approved.
Much of the original clapboard was missing and the remaining clapboard was badly
deteriorated. The owners decided to replace all the clapboard with cedar shingles.
The owners and the State Historic Preservation Officer felt that the shingles were not
a visually obtrusive change because they were installed in even rows similar to the
width of the clapboard they replaced (see illus. 2). The owners stated that an
important aspect in their decision to use shingles instead of commercially available
clapboard was that modern clapboard was too wide and duplicating the historic
clapboard would have required having it specially milled. Having duplicate clapboard
82-042
custom-milled would have been triple the expense of the cedar shingles. Another
consideration was ease of maintenance in a harsh, damp climate, so a preservative was
applied to the shingles. NPS denied certification because it determined that
"replacement of the clapboarding with shingles is a major change in the character of
the building" and, therefore, the rehabilitation did not meet Standard 6. However, in
denying certification NPS suggested that painting the shingles white to match what
appeared to be the original color would lessen the negative visual impact of the
change of materials and that this might result in approval of the project as minimally
meeting the Standards.
The owners appealed the NPS decision with the strong support of the SHPO who
stated:
"The replacement of the clearly deteriorated clapboard with shingles is
not a visually obtrusive change. The shingles are hung in even rows,
with exposure similar to that of the clapboards. As they have been
treated with a preservative, it is unlikely that the shingles will now
accept a white stain, and to paint them would make repainting
necessary, given the unusual weather conditions...I should mention, too,
that white was not the building's original color."
The hearing officer sustained the NPS decision that without painting or using an
opaque stain on the shingles to mitigate the significant visual change to the texture
and character of the exterior walls, the rehabilitation would not meet the Standards.
Additionally, the hearing officer pointed out that even with the application of a
preservative, the shingles would still require cyclical maintenance. However, the
hearing officer did agree with the SHPO that the shingles did not necessarily have to
be painted white, but rather an appropriate opaque color or stain. The owners agreed
to apply an opaque yellow stain, which the hearing officer considered "a mitigating
treatment sufficient to warrant approval of the project."
The owners then consulted with a representative of the manufacturer of the
preservative that had been applied to determine how soon the initial application would
be weathered enough to permit the opaque yellow stain to adhere to the shingles.
After two years sufficient weathering had occurred so that a second application was
possible. The owners have now repainted the hotel with an opaque yellow stain
containing a preservative.
Prepared By: Sara K. Blumenthal, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
•
82-042
ma c. y"
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,ter III,J ..i` ;��_ 4. a `` -�_` _ Il.li1
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•
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-
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1. Pre-1977 rehabilitation. .•
= ,' +
Note badlydeteriorated _ _�'I I 1 1i
condition of hotel, 1,' I � 2.71
-r '-.
particularly windows and
clapboard. '
2. After rehabilitation.
The use of shingles to replace the clapboard has changed the texture and
character of the exterior walls, even though the width of the rows is
similar to the original clapboard and the decorative trim has been care-
fully repaired. The owner agreed after certification was denied upon appeal
to apply an opaque yellow stain as a mitigating treatment to qualify the project as
minimally meeting the "Standards."
Technical Preservation Services Interpreting
Preservation Assistance Division
U.S.Natel Park Servicetthe Secretary of the Interior's
U.S. Department of the Interior
—Washington, D.C.
(-Standards for Rehabilitation
Number: 82-043
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
4. Retention of Significant Later
ALterations/Additions (conformance)
Subject: DEMOLITION AS PART OF CERTIFIED REHABILITATION
(INDUSTRIAL/MILL COMPLEXES)
Issue: Industrial or mill complexes listed in the National Register often include a
number of structures varying in use, age, condition, and significance. Adaptive uses
(such as housing, shops, or offices) are frequently chosen for these complexes. While
the removal of clearly nonsignificant modern additions is a frequently proposed,
integral part of rehabilitation planning, unfortunately such plans often propose the
selective demolition of other buildings or additions, or industrial features such as
smokestacks, boiler rooms, elevators, and millraces that may play an important role in
the complex as a whole. In general, the demolition of structures in a registered
industrial or mill complex will violate Standards 2 and 4, and result in denial of project
certification. In limited situations, however, demolition of components of a historic
complex may be approved as part of the overall rehabilitation when: 1) the component
is a secondary structure or feature that lacks special historic, engineering, or
architectural significance; and 2) the component does not comprise a major portion of
the historic site; and 3) persuasive evidence is presented to show that retention of the
component is not technically or economically feasible.
Application: A National Register mill complex dating largely from the 1840s and
located in a small northeastern town was being converted into housing for the elderly
(illus. 1). Overall rehabilitation work proposed was extensive, including structural
repairs to the main factory building; roof repairs; reconstruction of the bell tower and
cupola based on photographic and physical documentation; installation of replacement
windows duplicating the historical six-over-six configuration; and repair of an 1867
elevator tower for use as a community space on the first floor and as living space
above. The work proposal also involved demolition of a 1950s concrete block loading
dock; an 1850s metal exterior fire escape; and an 1850s boiler room and smokestack
(see illus. 2 and 3). (The boiler room addition had been enlarged in 1857 and further
expanded ca. 1900.)
In a preliminary review of the project, NPS indicated that demolition of the
nonsignificant concrete block structure would be acceptable as part of the overall
work; similarly, removal of the exterior fire escape would be acceptable because an
internal fire stair was being utilized. However, both NPS and the Advisory Council
(reviewing the project because HUD money was involved) expressed concern over the
proposed demolition of the 1850s boiler room and smokestack.
82-043
In response to these concerns, the architects/engineers provided additional
information that satisfied the three-part criteria for demolition of the secondary
components. First, although the boiler room and smokestack were integral parts of
the historic mill complex, they did not possess any "special" historic, engineering, or
architectural significance that, alone, would warrant their retention. Second,
compared to the 55,000 sq. feet of the main mill building plus the area of the elevator
tower, the boiler room and smokestack comprised only a small portion of the entire
complex. Finally, and most important, the engineers presented an analysis of the
structural condition of these components, citing the particularly serious deterioration
of their exterior walls and roofs. Because such persuasive evidence was presented
prior to final project review, NPS agreed that rehabilitation of the secondary
components in this case would be technically infeasible; subsequently NPS approved
their demolition as part of the overall rehabilitation and certified the project.
("Review of Historic Preservation Projects," No. 81-02, further defines the
documentation required in establishing the structural condition of a building for
purposes of the Federal Tax Incentives Program.)
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
82-043
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INDEX
Abrasive Cleaning
81-009; 82-039
•
Additions to Buildings
See Also: Greenhouses
Infill Construction
Storefronts
Additional Floors
82-034
Demolition of Additions
81-016; 81-018
Inappropriate Designs
81-022; 82-026; 82-028; 82-037
Administrative Issues
See: Previous Owner
Project Work
Air Conditioning
81-014
Arcades
82-030
Artificial Siding
80-005; 80-006
Balconies
See: Porches, Galleries
Brick
Mitigating damage of abrasively cleaned masonry
81-009
Painting previously unpainted brick
81-011; 82-029
Removing interior plaster to expose brick
81-013
Brownstone
See: Sandstone
Building Codes
Fire safety
82-037
Handicapped access
82-032
Ceilings
See: Interior Spaces, Alterations
Cleaning, Damaging Methods
See: Abrasive Cleaning
Complexes
See: Demolition, Buildings within Complexes
Demolition
See Also: Interior Spaces and Features, Alteration
Buildings within complexes
81-012; 82-041; 82-043
Demolition/alteration of non-original features that have achieved significance
81-016; 81-018; 82-027; 82-041
Significant fabric and features
82-032; 82-039
Deteriorated Buildings and Features, Repair versus Replacement
82-029; 82-031; 82-038; 82-040; 82-042; 82-043
Doors and Entranceways
See Also: Interior Spaces and Features, Alteration
Replacement, inappropriately designed
80-004; 82-025
New construction on original facades
82-029
Removal or replacement of entrance
81-015; 82-032
Entrances
See: Doors and Entranceways
Environment/Setting, Alteration of
80-002
Exterior Surfaces
See: Artificial Siding
Brick
Paint, Removal of
Replacement Materials
Sandstone
Wood
Fireplaces
See: Interior Spaces and Features, Alteration
Floor Plans, Alterations
81-020
Floors, Addition of New
81-019; 82-034
Galleries
See Also: Porches
New construction
81-008
Greenhouse Additions
80-007; 81-022 •
Historically Inappropriate Alterations and Additions, Construction of
See Also: Brick, Removing interior plaster to expose brick
80-004; 80-005; 81-008; 81-018; 82-024; 82-029
Infill Construction
81-010
Insulation, Urea-formaldehyde Foam
81-023
Interior Spaces and Features, Alteration
See Also: Brick, Removing interior plaster to expose brick
81-017; 81-019, 81-020; 82-024
New Construction
See: Additions to Buildings
Environmental/Setting, Alterations
Greenhouses
Historically Inappropriate Alterations
Infill Construction
Porches
Roof Alterations
Storefronts
Paint
See Also: Abrasive Cleaning
Mitigating damage to exterior by painting
81-009; 82-042
Painting previously unpainted surfaces
81-011; 82-029
Retention of unpainted surfaces after paint removal
82-036; 82-039
Plaster, Removal of
See Also: Interior Spaces and Features, Alteration
81-013
Porches
See Also: Galleries
Demolition
80-006; 81-018; 82-033; 82-039
Enclosures
80-001; 82-033
Previous Owner, Project Work Undertaken by Previous Owner Which Does Not Meet
the Standards
80-001
Regulations, Project Work Undertaken Prior to Issuance of
81-018; 82-028
Replacement Materials
See: Artificial Siding
Doors
Roofing
Sandstone, Replacement of
Windows
Wood
Roof Alterations
82-031; 82-038
Sandblasting
See: Abrasive Cleaning
Sandstone, Replacement
82-040
Setting, Alteration of
See: Environment/Setting, Alteration of
Siding
See: Artificial Siding
Wood, Replacing clapboarding with shingles
Stairtower, Construction
82-037
Standards for Rehabilitation, Secretary of the Interior's
Standard 1 (Compatible New Use)
81-020; 82-028; 82-033
Standard 2 (Retention of Distinguishing Architectural Character)
80-001; 80-002; 80-003; 80-006; 81-011; 81-012; 81-013; 81-014; 81-015; 81-017;
81-019; 81-020; 81-021; 81-022; 81-023; 82-025; 82-026; 82-028; 82-029; 82-030;
82-032; 82-033; 82-036; 82-039; 82-041; 82-043
Standard 3 (Recognition of Historic Period)
80-004; 80-005; 80-006; 81-008; 81-010; 82-024; 82-029
Standard 4 (Retention of Significant Later Alterations/Additions)
81-012; 81-016; 81-018; 82-025; 82-027; 82-031; 82-041; 82-043
Standard 5 (Sensitive Treatment of Distinctive Features and Craftsmanship)
81-011; 81-014; 81-017; 81-020; 82-025; 82-029; 82-032; 82-033
Standard 6 (Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical Evidence)
81-013; 81-015; 82-029; 82-031; 82-032;82-035; 82-038; 82-040; 82-042
Standard 7 (Cleaning with Gentlest Method Possible)
81-009; 82-039
Standard 8 (Protection/Preservation of Archeological Resources)
Standard 9 (Compatible Contemporary Design for New Alterations/Additions)
80-001; 80-003; 80-007; 81-010; 81-014; 81-022; 82-028; 82-030; 82-031; 82-034;
82-037
Standard 10 (Reversibility of New Alterations/Additions)
82-026; 82-037
Storefronts
80-003; 80-004; 82-027; 82-030
• I
Stucco
82-040
Timing
See: Project Work Undertaken Prior to Issuance of Regulations
Vinyl Siding
See: Artificial Siding
Windows
See Also: Storefronts
Alteration/Demolition
81-015; 82-031; 82-032; 82-040
Replacement
81-021; 82-029; 82-035
Wood
Abrasive cleaning
82-039
Removing interior woodwork
81-017
Removing paint from previously painted wood
82-036; 82-039
Replacing dapboarding with shingles
82-042
.U.S. GOVERNMENT PRINTING OFFICE:1985 483-217/32734
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior s
Washington, D.C.
rStandards for Rehabilitation
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Volume II
Cover Illustration: The Times Building (also known as the Dome Building), Chattanooga,
Tennessee. Rehabilitated under the historic preservation tax incentives program.
Drawing by Judson McIntire for the Historic American Buildings Survey. 1973.
INTRODUCTION
"Interpreting the Standards" bulletins were initiated in April 1980 by the
Preservation Assistance Division (then Technical Preservation Services Division) to
explain rehabilitation project decisions made by the National Park Service, U. S.
Department of the Interior. Rather than describe every aspect of the overall
rehabilitations in great detail, the bulletins focus on specific issues—alterations to
storefronts, through-the-wall air conditioning, interior alterations--that posed
problems in the review process. To this extent, then, the bulletins tend to emphasize
limited aspects of a project and de-emphasize other aspects of the.work that posed
no special concerns or that were noteworthy or innovative.
Issued at intervals to program administrators in National Park Service regional
offices and State historic preservation offices, the first 43 "Interpreting the
Standards" bulletins were collected in a single volume in 1982. Since then, 32
additional bulletins have been issued. The present compilation includes these
bulletins, bringing the total to 75.
"Interpreting the Standards" bulletins are designed for use primarily by program
administrators at the State and Federal level who make recommendations and
decisions on rehabilitation projects. The bulletins are case-specific and are not
necessarily applicable beyond the unique facts and circumstances of each case.
Many of the bulletins present projects denied certification by National Park Service
regional offices that were later appealed to the Chief Appeals Officer. While the
final decisions in these cases have been incorporated into the discussions of such
projects, appeal decisions are individual and are made on the facts and circumstances
specific to the project, including information on aspects of a project that are not
treated in the bulletin itself. Consequently, care should be taken not to consider
portions of appeal decisions quoted as directly applicable to other projects of a
generally similar nature. Appeal decisions do not accumulate as precedent in the
legal sense. The procedures for obtaining certifications of rehabilitation are
explained in Title 36 of the Code of Federal Regulations, Part 67. These regulations
control in the event of any inconsistency with these bulletins.
The following ten Standards for Rehabilitation are used by the Secretary of the
Interior to determine if a rehabilitation project qualifies as "certified rehabilitation"
pursuant to sections 48(g), 167(o), and 191 of the Internal Revenue Code. The
Standards comprise the sole regulatory basis for determining whether or not a
rehabilitation is consistent with the historic character of the structure or the district
in which it is located. The applicable Standards as well as project conformance or
nonconformance to those Standards are referenced at the top of each bulletin in
italics.
1. Every reasonable effort shall be made to provide a compatible use
for a property which requires minimal alteration of the building,
structure, or site and its environment, or to use a property for its
originally intended purpose.
2. The distinguishing original qualities or character of a building,
structure, or site and its environment shall not be destroyed. The
removal or alteration of any historic material or distinctive
architectural features should be avoided when possible.
3. All buildings, structures, and sites shall be recognized as products of
their own time. Alterations that have no historical basis and which seek
to create an earlier appearance shall be discouraged.
4. Changes which may have taken place in the course of time are
evidence of the history and development of a building, structure, or site
and its environment. These changes may have acquired significance in
their own right, and this significance shall be recognized and respected.
5. Distinctive stylistic features or examples of skilled craftsmanship
which characterize a building, struture, or site shall be treated with
sensitivity.
6. Deteriorated architectural features shall be repaired rather than
replaced, wherever possible. In the event replacement is necessary, the
new material should match the material being replaced in composition,
design, color, texture, and other visual qualities. Repair or replacement
of missing architectural features should be based on accurate
duplications of features, substantiated by historic, physical, or pictorial
evidence rather than on conjectural designs or the availability of
different architectural elements from other buildings or structures.
7. The surface cleaning of structures shall be undertaken with the
gentlest means possible. Sandblasting and other cleaning methods that
will damage the historic building materials shall not be undertaken.
8. Every reasonable effort shall be made to protect and preserve
archeological resources affected by, or adjacent to any project.
9. Contemporary design for alterations and additions to existing
properties shall not be discouraged when such alterations and additions
do not destroy significant historical, architectural or cultural material,
and such design is compatible with the size, scale, color, material, and
character of the property, neighborhood or environment.
10. Wherever possible, new additions or alterations to structures shall be
done in such a manner that if such additions or alterations were to be
removed in the future, the essential form and integrity of the structure
would be unimpaired.
Bulletins are arranged in order of issuance. The number assigned to each is
composed of the fiscal year in which the bulletin appeared and an overall cumulative
number (e.g., 83-046, 85-072). Each bulletin bears the name of the author. The
index provided at the end of this volume references all bulletins in the series. It keys
the bulletins to particular Standards and to such topics as Abrasive Cleaning, Roof
Alterations, and Windows. A looseleaf format has been followed in order to allow for
easy removal for xeroxing as well as for easy insertion of future supplements.
This material is not copyrighted and can be reproduced without penalty. However,
normal procedures for credit to the authors and the National Park Service are
appreciated. "Interpreting the Secretary of the Interior's Standards for
Rehabilitation," has been developed under the technical editorship of Lee H. Nelson,
FAIA, Chief, Preservation Assistance Division, National Park Service, U. S.
Department of the Interior, P. O. Box 37127, Washington, D.C. 20013-7127.
Comments on the usefulness of this information are welcomed.
Additional information and guidance on technical preservation and rehabilitation
techniques for historic buildings may be found in the Preservation Briefs, Technical
Reports, and Preservation Case Studies developed by the Preservation Assistance
Division. For a complete list of publications including price and GPO stock number
information, write to: The Preservation Assistance Division at the above address.
Technical Preservation Services Interpreting
Assistance Preservation
sistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 83-044
Applicable Standard: 2. Preserving the Distinguishing Character of a
Building (nonconformance)
Subject: PORCH ALTERATIONS
Issue: Porches are a very common and often dominant feature on the primary facades
of many residential buildings and yet represent that portion of a building which is
often subjected to insensitive changes. The size of the porch, its architectural style,
the ornateness or simplicity of detailing, the sense of openness, and delineating
features such as columns and balustrades, are all important attributes. "Interpreting
the Standards" No. 82-033 discusses problems and concerns with enclosing historic
porches, a change which is often sought by owners undertaking rehabilitation in order
to gain additional year-round living space. Porches may also suffer from owners'
attempts to deal with inherent maintenance problems that often stem from the nature
of their construction and exposure to the effects of weathering and decay. Encasing a
decorative but deteriorated balustrade, removing or simplifying brackets and
fretwork, or boxing-in open eaves are all usually inappropriate alterations to an
architecturally significant porch. Work that at first glance may be considered only a
small physical change to a porch can often have a major impact on the historic or
architectural character of the building and be clearly in violation of the Standards as
in the case described below.
Application: An early twentieth-century frame house was one of many buildings in a
historic district undergoing extensive renovation work by a single developer. The
house is somewhat unusual in that it was apparently built as a duplex in an area of
mostly single family houses. The twin porch design is thus both historically and
architecturally significant in its contribution to the character of the building (see
illus. 1). In the course of the rehabilitation, the developer connected the two porches
with a new eight-foot section, purportedly to shelter the steps from the rain (see illus.
2). Both the State Historic Preservation Officer and the National Park Service
considered this treatment as a violation of Standard 2, thus preluding certification of
rehabilitation despite the rest of the work being handled in a sensitive manner. In
rebuilding the porch to extend across the entire front, the following changes had
occurred:
1. The historic twin porch design was lost;
2. A strong horizontal element created by the large continuous porch
was created for the first time;
3. The projecting center portion of the duplex was interrupted by the
porch, obscuring this original strong architectural feature; and,
4. The historical and architectural character of the building as a duplex
was substantially diminished.
83-044
The sole justification for the porch alteration was the need to alleviate water
accumulation at the steps. Traditionally, such porch roofs were pitched away
from the steps and the building in order to properly shed water; the owner should
have thus repaired the porch and added gutters and downspouts, as necessary, to
correct the water problem.
After considering the tax implications of denial of certification and the cost of
undertaking corrective measures, the owner offered to remove the porch linkage
and was subsequently advised by the appeal hearing officer that such a measure
would bring the project into conformance with the Standards and would lead to
certification of rehabilitation.
Prepared By: Charles Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the
U.S. Department of the Interior. The resulting determinations, based on the
Secretary of the Interior's Standards for Rehabilitation, are not necessarily
applicable beyond the unique facts and circumstances of each particular case.
83-044
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2. In connecting the two historic porches,
the twin porch design was lost; a strong
horizontal element was created by the
large continuous porch; and the sense
of a duplex building was diminished.
To obtain certification, the owner
agreed to restore the porch.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 83-045
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: REPLACING NONSIGNIFICANT LATER ADDITIONS
Issue: One aspect of overall rehabilitation work may involve replacement of a
deteriorated nonsignificant later addition with a new addition in order to meet certain
functional needs. An example of such work is the replacement of previously existing
enclosed vestibules both for convenience to patrons and to highlight business
entrances. Whatever the reason for a new addition, all contemporary design must
conform to Standards 2 and 9; that is, it must be neither visually intrusive nor
physically damaging to historic building material.
Application: A nine-story, late Victorian brick and brownstone commercial building
located in a historic district within a large northeastern city was being rehabilitated
for use as a multi-purpose business and shopping complex (see illus. 1). When the
proposal for extensive interior and exterior work was forwarded by the State Historic
Preservation Officer to NPS for review, NPS concurred with the State's general
assessment of nonconformance with the Secretary's Standards and denied
certification, listing violations of Standards 2, 5, 6, and 9. Exterior work cited for
nonconformance included window alterations and the design for new glass canopies to
cover areaways flanking a main entrance. Nonconforming interior work included
demolition of an existing skylight; large cuts in the main floor; introduction of a
mezzanine; and construction of two curved staircases linking the interior levels.
Rather than appeal the denial, the owner chose to revise the project plans and over a
ten-month period worked with NPS staff so that the entire project might be
reconsidered. After all major components of the proposed interior work had been
satisfactorily resolved, the one exterior item still being negotiated was the design of
the two new glass and metal canopies to replace the two deteriorated wooden
vestibules (see illus. 2). (The need per se for canopies to replace existing non-
significant coverings had never been disputed from either the standpoint of patron
convenience or commercial viability.)
The architect's initial design for the glass and dark colored anodized aluminum
canopies incorporated a standard vault with a flat roof section which NPS felt was a
visual intrusion upon the substantially unaltered facade. Although there would be no
destruction of historic material, the curved roof line of the proposed canopy extended
well above the level of the earlier vestibule and obscured the lower portion of the first
floor windows, a distinguishing feature of the building (see illus. 3). For the overall
project to meet the Standards, NPS informed the owner that any new canopy would
have to be located below the sill of the first floor windows. In response, the architect
prepared one alternative design for the canopies which met the height condition, but
which—both NPS and the owner agreed—introduced several other design problems (see
illus. 4) which might affect pedestrian safety.
83-045
At a later date, citing these problems and increased construction costs, the owner
again sought approval of the initial design. NPS continued to maintain its earlier
position that the initial design did not meet the Standards but felt that alternative
canopy design options still existed that would meet the Standards yet at the same time
be practical and esthetically pleasing. At this point, the owner elected to appeal
the denial, seeking approval of the overall project including the initial canopy design.
Prior to the hearing, however, the architect submitted two new scaled-down
alternatives for the glass canopies, both of which were approved by NPS (see illus. 5),
thus enabling the entire project to be certified. Following project approval, the
Option"A" canopy was actually constructed (see illus. 6).
Prepared By: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
_ 83-045
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83-045
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 83-046
Applicable Standards: 3. Recognition of Historic Period (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: WINDOW ALTERATIONS: Inappropriate Contemporary Design
Inappropriate Historic Appearance
Issue: In rehabilitating historic buildings, property owners may sometimes consider
replacing original windows with those of a different design, not only to reduce
maintenance and energy costs but to try to "improve" or "enhance" the appearance of
the building. For example, some owners believe that next to cleaning or repainting,
the easiest way to give an office building a new look is to install a contemporary
window and use tinted glass to serve as a sharp contrast between the old and the
new. Another unfortunate approach is to remove the original windows and install a
window design from a different historic period in an effort to make the building look
either older or grander than it actually is. On the other hand, the recommended
approach—according to the Standards--is to preserve historic features such as
windows, whenever possible. If energy conservation is an integral part of the planning
objective in order to make a project economically viable or to meet regulatory
requirements, ways of improving the performance of the existing windows should
always be explored first. Then, if windows cannot be easily repaired, an evaluation
should be made to determine their contribution to the overall architectural character
of the building before any replacement proposal is considered.
Throughout the planning process, however, changing the historic window design to
"improve" or "enhance" the appearance of the building should not be considered. If the
windows are a distinguishing feature of the historic building and must be replaced
because of their physical condition, they should be duplicated as closely as possible in
accordance with Standard 6. Where the windows are not significant in their own right
but are located on significant facades, there is more flexibility in the type of
replacement windows that can be installed. However, even within this more flexible
context, the replacement window units should never give the building a"historic"
appearance it never had (Standard 3), nor should a design be selected that is
incompatible with the historic character of the building (Standard 9).
Application: Inappropriate Contemporary Design
Constructed in 1911 with a white glazed brick covering the upper floors, this
individually listed National Register property is a visually prominent and
architecturally significant building, located in a small southern town (see illus. 1). As
the National Register nomination indicated, "at the ends of the building each of the
upper floors had three double-hung windows. On the south side each floor had seven
pairs of double-hung windows. The windows collectively provided very bright and
agreeable work space inside the building." The building has a relatively austere facade
83-046
reflecting its commercial character and results in the simple double-hung windows
becoming a significant design feature.
In the course of rehabilitating the building for mixed commercial and residential use,
the double-hung clear-glazed wooden windows were removed (and stored) and replaced
with metal windows with a single vertical division created by a meeting rail. In
addition, a dark tinted glass was used in place of the original clear glazing (see illus. 2
and 3). The change in the design and the use of dark tinted glass gave the new
windows a strong contemporary look not in keeping with the historic character of the
building. Upon submitting a certification application, the owner was advised that the
window alterations did not meet numbers 2, 5, 6 and 9 of the Secretary's Standards.
The owner was further advised by NPS that the original double-hung wooden windows
were typical of the time in terms of technology and design consideration and for the
building were a significant feature. As such, the windows should have been repaired
and if that was not practical, the replacement units should have matched the
configuration of the original double hung sash and the reflective qualities of the
glass. Representatives from both the state historic preservation office and the NPS
regional office inspected the completed project and observed major changes in the
design and the reflective qualities of the windows. With the new dark tinted glass and
dark trim finish, the windows now appear as dark voids, contrasting with the white
glazed brickwork. The denial of certification by the regional office was sustained on
appeal by the owner.
Application: Inappropriate Historic Appearance
Plans for the rehabilitation of a small late nineteenth century cottage, located in a
historic district in the South, were submitted prior to undertaking the work. After the
determination was made by NPS that the proposed work met the Standards, the owner
elected to revise the plans to include the removal of the two original first floor
windows and subsequent replacement with floor-to-ceiling windows (see illus. 4 and
5). Upon completing the work and requesting final certification the owner was advised
by NPS that the introduction of the new sash and exterior shutters which extend to the
porch floor created a design feature that never existed in this particular structure and
gave the building an inappropriate historic appearance. Moreover, NPS indicated to
the owner that this particular type of window generally was found in buildings of an
earlier period in that area.
On appeal the owner provided sufficient evidence to show that such large windows
were common in the local historic district but acknowledged that he had removed the
original windows in rehabilitating his building. When the appeal hearing officer
sustained the decision that the project did not meet Standard 3, the owner offered to
reinstall the original sash, which had been restored for use in another building. The
corrective work has since been undertaken and the project certified (see illus. 6).
Prepared by: Charles E. Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
83-046
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wing and were of a one over one pane and a vertical division on the upper floors
configuration. were not in keeping with the character of the
building.
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83-046
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4. The 1880s cottage was in deteriorated 5. In the course of rehabilitation
condition prior to rehabilitation. Ghost the owner elected to remove the original
marks of missing porch are evident. The windows and install new ones in a historic
original 2 over 2 windows had survived on design which extended to the first floor.
the front and were to be repaired according Full-length blinds were also added.
to the plans submitted to NPS for prior review.
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6. After the work was determined not to meet the
Standards because of the window alterations, the
owner proceeded to reinstall the original ones and
thus obtained certification.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Paris Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 83-047
Applicable Standards: 1. Compatible New Use (nonconformance)
2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
10. Reversibility of New Alterations/Additions
(nonconformance)
Subject: INTRODUCING NEW OPENINGS INTO MAJOR ELEVATIONS
Issue: The introduction of new window or door openings to accommodate new
functions is a common component of projects submitted for rehabilitation
certification. In most cases, a limited number of new openings cut in party walls
or other non-significant elevations will not alter the historic character of a
building. On the other hand, where such openings are introduced on a principal
facade, the loss of significant historic building material, change in rhythm of the
bays, or other nonconforming treatments that, together, destroy the historic
building's essential form and integrity, will generally result in denial of
certification.
Application: An abandoned Elks lodge located in a historic district was proposed
for reuse as the home office of a life insurance company. Located on a site that
slopes steeply down from front to back, the building has two stories on the front
facade and three on the rear elevation (see illus. 1 and 2). Since the building
occupies the full width of a city block, both the facade and rear elevations front
directly on streets. The facade is highly ornamented in the Second Renaissance
Revival style, while the rear elevation is less ornately decorated.
Because office use would require more parking than was available on the street or
in adjacent lots, the developers proposed incorporating a parking facility at the
basement level in the rear of the building. The SHPO and the NPS regional office
approved the concept of parking in this portion of the basement, a space which
had been used as a gym.
The location of the driveway entrance to the parking area posed a problem, and
became the issue over which the project ultimately was denied certification. The
best location would have been on the less ornately decorated rear elevation. The
plan originally considered by the developers to locate the entrance at the rear,
however, contained a ramp that the city traffic engineer would not approve. As a
result, the entrance was proposed for the main elevation (see illus. 3). The
regional office felt this design adversely affected not only the facade's character
and historic fabric, but also would destroy significant fabric located inside the
building in a library (see illus. 4).
83-047
In its letter of denial to the developers, the regional office wrote:
The introduction of the garage entrance on the principal facade
alters the character of that well-detailed, Second Renaissance
Revival-style facade. Not only does it result in the demolition and
removal of historic material of significance, but it would would also
interrupt the rhythm and balance that is characteristic of this
symmetrical facade (Standard 2). In addition, significant
architectural features of the library--the bookcases, fireplace
mantel, and decorative frieze--would be lost if the garage entrance
is constructed as proposed (Standard 5). The Standards recommend a
compatible use for a building that requires minimal alteration
(Standard 1). Parking which requires a major opening on a principal
facade cannot be considered a compatible use requiring minimal
alterations. It is irreversible and destroys the form and integrity of
that facade. The essential form and integrity of the structure
should be unimpaired should alterations be removed in the future
(Standard 10). While this office recognizes the arguments presented
on the parking issue, the rehabilitation still must be consistent with
the historic character of the structure and the Standards.
Rather than appeal the regional office's decision, the architect for the developers
redesigned the parking space, placing the entrance at the rear of the building. The
new design was acceptable to the city traffic engineer.
The resubmitted design was approved by the regional office, and construction on
the project is going forward.
Prepared by: William G. MacRostie, TPS
These bulletins are issued to explain preservation project decisions made by the
U.S. Department of the Interior. The resulting determinations, based on the
Secretary of the Interior's Standards for Rehabilitation, are not necessarily
applicable beyond the unique facts and circumstances of each particular case.
83-047
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83-047 i /
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have necessitated removal of the fireplace and
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Intenor s
Washington, D.C.
rStandards for Rehabilitation
Number: 83-048
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
10. Reversibility of New Alterations/Additions
(nonconformance)
Subject: INAPPROPRIATE EXTERIOR ALTERATIONS: WAREHOUSE TO
APARTMENTS
Issue: In order to market abandoned and functionally obsolete historic buildings,
owners are often tempted to make major alterations as a statement of the new
life and vitality of the area and in order to accommodate the new use of the
building. This is particularly true when warehouse buildings are converted to
apartments. Not only must these large buildings be modified to meet light and
ventilation code requirements for residences, but they must often compete with
modern new construction nearby that has highly marketable amenities.
Some types of buildings can more easily accommodate new uses and alterations
than others. Nineteenth-century warehouses, with thick masonry walls and small
window openings, present a particular challenge to owners; depending on the
design of the particular warehouse, the alterations that can be made to the
building without destroying its historic warehouse character may be limited. The
key is identifying the distinguishing architectural features of the building and then
planning a rehabilitation that allows for the retention of these features.
If the proposed alterations do not conform to the Secretary of the Interior's
Standards for Rehabilitation and as a result, the historic character of the building
is destroyed, the project cannot be certified for tax benefits.
Application: A circa 1890s six-story brick tobacco warehouse located in a historic
waterfront district was purchased for conversion to 204 apartments and first floor
commercial space. The building was in good condition, although it had been
vacant for many years. The city hoped that the conversion of this warehouse to
apartments would be the first step in revitalizing this portion of the waterfront
area, particularly since the building was the largest in the primarily residential
district and formed the corner of the historic district boundary. A market study
was commissioned by the owners to determine what changes would be necessary to
make the building marketable. The study recommended that at least 85% of the
residential units have a waterfront view, that a portion of the interior of the
building be removed to provide necessary light and ventilation to meet code
requirements, that some of the windows be widened as well to meet code
requirements for light and ventilation, that all units have an exterior balcony and
that a seventh floor be added to the structure to increase the number of rentable
83-048
units. This information was then used by the architect to develop the
rehabilitation plan.
The state historic preservation office had worked closely with the owners in the
evolution of the design and strongly recommended certification of the project.
The regional office, however, reviewed the project and expressed concern over a
number of the proposed changes. The most drastic alteration to the building was
the proposal to create an interior court with a waterfront orientation by removing
7 of the 17 bays of one facade. Two other controversial changes proposed were to
widen the windows in select vertical bands, and to attach lightweight metal
balconies to the exterior. While there was also concern for the cumulative effect
of the other proposed changes, these three issues resulted in regional denial of
certification for the project based on Standards 2, 5, 9, and 10. These changes
would have altered the historic character of the warehouse building by removing
historic material, by failing to respect the skilled craftsmanship of the building,
and finally, by incorporating incompatible and non-reversible elements of new
work. The owner, with the support of the State, appealed the decision of the
regional office.
In reviewing the proposed changes, the appeals hearing officer determined that
the architectural elements that contributed to the historic character of the
building should be clearly outlined: e.g. the massiveness of the 200' x 400'
structure; the highly articulated facades composed of alternating bands of
windows openings and pilasters; and the vertical effect of these bands with a
hierarchy of openings from the ground floor to the top floor complemented by the
horizontal beltcourses, top floor frieze and corbelled cornice. The brickwork was
well executed and even with the substantial detail on the surface of the building,
the facade retained a strong sense of flatness as there were no deep surface
penetrations (see illus. 1). In summary, the architecture of the warehouse was
very sophisticated for this type of construction and was significant both to the
building and to the 19th-century district in which it was located.
Following an onsite inspection of the warehouse and the district, the hearing
officer sustained the denial of the regional office for a number of reasons. He
felt that the planar quality of the exterior walls would be drastically altered by
the addition of projecting balconies with their inherent shadow lines (see illus. 2).
He felt that widening selected bands of windows would interrupt the regular
rhythm of the window bays. Widening the upper floor windows would also alter
the hierarchy of window openings from large openings on the first floor to the
small openings on the top floor. His last major concern was the proposed cut in
the building, which not only removed the significant original materials of the
facade, but altered the massive quality of the warehouse structure (see illus. 3).
While sustaining the decision of the regional office, the hearing officer
encouraged the owner to reconsider the proposed changes to the building and
resubmit his application with a proposal that would meet the Standards. While the
hearing officer felt that the building could not accommodate any external
projecting balconies, he felt that an atrium court that did not remove any of the
83-048
facade and a modified scheme for widening the windows that reflected the
hierarchy of existing openings could be considered.
Prepared by: Sharon C. Park, AIA, TPS
•
These bulletins are issued to explain preservation project decisions made by the
U.S. Department of the Interior. The resulting determinations, based on the
Secretary of the Interior's Standards for Rehabilitation, are not necessarily
applicable beyond the unique facts and circumstances of each particular case.
•
•
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1. The existing south elevation of the 1890s warehouse building with its
alternating bands of pilasters and window openings. The size of the
openings decreases as the building progresses from the base to the top
floor. The brickwork was quite sophisticated for a warehouse structure.
83-048 n. - . -�, .,�,.� '. .,{Tt .= r s
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2. The proposed south elevation with bands of projecting balconies. The
window openings would be widened or lengthened in order for each of the
204 apartment units to have one balcony. Not only would the windows be
altered in selective bands, but the proposed balconies would create deep
shadow lines on the facade. While the owner felt that the balconies were
a reversible feature that could be removed in the future, the hearing
officer determined that both the visual clutter of the balconies and the
change in the hierarchy of the window openings did not meet the
Standards.
- , ♦ . :..0... E. _ , f r -_..._ • •
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3. Perspective view of the proposed changes shows the large courtyard
and the removal of seven bays of the waterfront facade in order to
provide a water view for 85% of the apartment units. The hearing officer
determined that the loss of significant original historic material and the
drastic change in character created with the new "U" shaped plan did not
meet the Standards. The projecting balconies and widened windows were
also cited as not meeting the Standards. The setback rooftop addition,
however, was not a concern as it would not have been visible from the
street level of the historic district.
Technical Preservation Services interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the lntenor s
Washington, D.C.
rStandards for Rehabilitation
Number: 83-049
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical
Evidence (nonconformance)
9. Compatible Design for New Alterations/Additions
(nonconformance)
Subject: INAPPROPRIATE STOREFRONT ALTERATIONS
Issue: Storefronts frequently define the historic character of commercial buildings.
Entrances and display windows are particularly important features of storefronts; the
number of entrances and their placement in relation to windows can create a distinct
rhythm on the primary facade that should be retained in the course of a rehabilitation. If
new entrances are required because of code requirements or new interior use, their
design and placement should not detract from the importance of the storefront to the
building.
Application: A commercial building, located in a historic district and constructed circa
1880-90, was enlarged from three bays to seven bays sometime around 1900 (see illus. 1
and 2). The added storefront, consisting of double doors flanked by window bays,
duplicated the original storefront. The two fronts were separated by a narrower bay
containing a single door.
In the most recent rehabilitation, which converted the building to office space, the
owners replaced the two sets of double doors with windows copied from those existing in
other bays of the storefronts. To accommodate ground floor offices, an arched entrance
was added to the side elevation (see illus. 3). The design for this doorway echoed an
interior doorway and an arched entrance on a neighboring building. The original side
entrance was replaced with a window.
The regional office denied certification to this project, citing Standards 2, 6, and 9. The
State Historic Preservation Office supported this decision. In its evaluation, the region
noted that "the new arched entrance is not compatible in character with the exterior of
the building as a whole, as the design of the new entrance bears no similarity to the
building's other window and door openings." Equally important in the denial were the
changes to the storefronts, which were "significantly altered by conversion of two,
original entrances to windows and by the consequent removal of the original
transoms. Although the removed doors themselves may not have been original, the
placement of entrances as they were, with double doors and a transom between the
windows, constituted a distinct rhythm to the storefront."
The owners appealed, stating that the doors they replaced with windows were not
original, and were badly deteriorated. The new windows, on the other hand, matched
83-049
the existing windows, thus "creating an elegant front with distinct 'rhythm."' They
also contended that the arched side entrance was consistent with the character of the
structure since it was patterned on an existing interior arch and reflected entrances
on neighboring buildings.
Upon appeal, the decision of the regional office was sustained. The chief appeals
officer noted that the "two entrances were an important part of the commercial
character and architectural detailing of the storefront facade." Furthermore, the
"functional relationship of the storefront facade to the partially blank wall on the
ground floor of the /side/ facade also reflected the commercial use within this portion
of the building." The new entrance on this facade introduced a major new design
element into the "strong rectilinear character of the building." This change further
diminished the importance of the storefront to the structure.
Prepared by: Michael Auer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
83-049
11
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la. and lb. Historic photograph (1a) showing original three-bay storefront
building (ca.1880-1890). With minor alterations, this storefront survived
until most recent rehabilitation. Side door led to second floor
apartments. Drawing (1 b) shows the building's main features clearly.
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2b.
2a. and 2b. Building as it looked after ca. 1900 enlargement. Two
identical storefronts (double doors flanked by window bays) were
separated by a bay containing a single door.
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3b.
3a. and 3b. After rehabilitation. Double doors on the front have
been replaced with windows, an arched side entrance has been cut,
and the former side entrance has been replaced with a window.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards tor Rehabilitation
Number: 83-050
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (Conformance)
9. Compatible Contemporary Design for New
Alterations/Additions (Conformance)
Subject: NEW OPENINGS IN BLANK EXTERIOR WALLS
Issue: A change of use of a historic structure may necessitate cutting new openings for
windows or doors in blank exterior walls. Usually, such blank walls are secondary
elevations, i.e., those exterior walls without special architectural treatment or emphasis
such as common or party walls, or the side or rear walls that are not readily visible from
the main thoroughfare. However, for some building types, such as ice houses, grain silos,
creameries, etc., blank walls are highly significant to a building's character. New
openings that would alter this character would not be approved. Therefore, owners
contemplating new openings should be careful not to consider a blank wall a "throwaway"
feature but should design the new openings to conform with Standards 2 and 9 and to be
subsidiary elements in the overall building. If the design for new openings makes such a
strong architectural statement as to change the appearance of the building radically or
overwhelm the historic facades, certification of the rehabilitation will be denied.
Application: An 1880's Romanesque Revival warehouse in a midwestern city was
converted into luxury office space. The 5-story brick warehouse was actually two long,
narrow buildings divided by a central load-bearing masonry wall. The north (street) wall
was the principal facade and contained virtually all of the architectural and stylistic
details (ornamental brickwork, windows, storefronts). The west wall was a blank brick
wall covered with a sprayed-on stucco-like coating for weather protection and may have
been a party wall originally although it has been exposed for some time. The first floor
1960's aluminum and glass storefronts were without intrinsic significance (see illus. 1).
The building was individually listed in the National Register as one of the few remaining
nineteenth century warehouses in an area that is now almost exclusively new high-rise
hotels, offices, a convention center, and vacant lots.
In planning for the rehabilitation of this warehouse, the owner determined that the only
economically viable use was as luxury office space and that increasing the attractiveness
of the space would require introducing windows into the blank west wall. Although the
east wall did have some existing windows, the central load-bearing wall precluded
"borrowing" natural light from the east across the width of the building. Additionally,
the owner discovered that severe water damage had left the northwest corner of the
warehouse structurally unsound and that part of the west wall would have to be rebuilt
from the ground up.
The rehabilitation, developed in close cooperation with the State, incorporates the new
window openings into the rebuilt section of the west wall. The new windows are similar
in size, shape, and rhythm to the windows on the primary north wall but the brickwork,
sash, and glazing are clearly contemporary. The new brickwork is a slightly different
color from the original and flush around the new windows rather than projecting; the sash
- is aluminum and a different color from the original, and the glazing is single-light. In
rehabilitating the north facade, the owner carefully repaired the existing 2-over-2
wooden double-hung sash (see illus. 2).
83-050
The non-significant 1960's storefronts were removed and replacement storefronts were
constructed, although the new use of the building might not include retail on the first
floor. The replacement storefronts incorporate new matching brick and stone piers and
new wooden windows and multi-light transoms. The newly constructed west wall also
incorporates two "storefront bays" but uses a less decorative brick pier and plain
transoms in order to continue the differentiation between the historic north facade and
the contemporary section of the west wall. The entrance was moved from its 1960's
location in the center of the north facade to the northwest corner of the building.
Access is through open storefront bays from both the north and west which create a
recessed entrance at the corner of the building (see illus. 2).
In denying certification of the rehabilitation, the regional office stated that:
This new facade competes with the original front facade for perception as the
dominant design element of the building. There would be acceptable ways of
adding windows to a blank and insignificant wall, if the alteration retained
the simple and secondary character of the facade. The new wall and windows
already installed in this building attract much attention, make a strong
architectural statement, and are located on the side of the building most
visible from the nearest major intersection. The new design violates
Standards 2 and 9.
The other reasons for denial of certification related to the recessed entrance, which was
determined to be uncharacteristic of the original storefront in violation of Standards 5,
6, and 9. The owner, with the strong support of the State, appealed this decision.
During the appeal the owner provided photographs that had been unavailable to the
regional office at the time of the initial review. These photographs clearly show the
juxtaposition of the new west wall, which reads as a compatible, contemporary design,
and the original north facade (see illus. 2). They also demonstrate that from one major
intersection, the original north facade is the most visible and that from the other major
intersection, the west wall will be almost completely obscured upon completion of a new
hotel to be constructed on the adjacent lot.
The Chief Appeals Officer overturned the regional office denial and determined that the
project met the Standards, providing that a wooden column was installed at the center of
the north entrance bay to maintain the rhythm of the storefronts. In certifying the
project, the Chief Appeals Officer said of the new openings in the western wall:
The resulting new construction, successfully repeating window sizes and
shapes from the original facade, reads as a clearly recent and subsidiary
statement. This is due to the use of frankly contemporary details: flush
brickwork of a slightly different color from the old construction; aluminium
windows, again of a different color from the old; and single-light sash.
The owner installed the required column and the project was certified.
Prepared by: Sara K. Blumenthal, PAD
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
83-050
ii R
• fiu - - Ulm i
. PUMPS
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1. North and west facades of warehouse.
The 1960's storefronts are non-significant.
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2. New windows and
entrance on west i 1
facade. Certification t I s :, -
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was conditional upon
owner adding a wooden Li.
'► , r column in center of - =• 4r 'westernmost storefront. J __J .! .� t` i ' `e 6,.
ii. i: .,.la
Technical
rese v ti n Preservation ServicesioInterpreting -1
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 83-051
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
9. Compatible Design for New Alterations/Additions
(conformance)
10. Reversibility of New Alterations/Additions
(conformance)
Subject: CONTEMPORARY ADDITIONS
Issue: The economic viability of some rehabilitations is dependent on the construction of
new space for additional rental income or for the housing of new services which cannot
be accommodated in the historic structure. In order to meet the requirements of the
Secretary of the Interior's "Standards for Rehabilitation," particularly numbers 2, 9, and
10, it is important that the new addition be designed and constructed so that the
character-defining features of the historic building or buildings are not radically
changed, obscured, damaged, or destroyed in the process of rehabilitation. Further, new
additions should be compatible in terms of mass, materials, relationship of solids to voids
and color; and the size and scale of the addition should be in proportion to the historic
building, and attached if possible, to the rear or inconspicuous side. New designs may be
contemporary or may be in the "style" of the historic building as long as there is a clear
distinction between the two and the new work does not appear to be part of the historic
resource.
Application: A pair of 4 story brick rowhouses was to be rehabilitated for use as an in-
town hotel. The Federal style buildings were constructed in 1809 as part of a row of
large residences, but shortly thereafter, they were converted for commercial use. In the
1870's, the two adjacent buildings were modified and connected for use as an inn, and
continued in that use until the 1970's. The two buildings, now identified as one structure,
were recently listed in the National Register.
The new owner wanted to reopen the historic building as a small in-town hotel, but the
structure lacked certain features necessary for the successful operation of a modern
hotel. The interior needed remodeling along with new elevators, restaurant facilities and
additional rental rooms. The new owner proposed three small additions to accommodate
these needs: a recessed rooftop shed dormer to house elevator equipment, and two small
4 story additions in the rear. While the rooftop addition would not be visible from the
street, one of the rear additions would be highly visible as the property was located on a
corner (see illus. 1).
The original design proposal submitted to the State historic preservation officer showed
the rear additions constructed in brick which replicated the brick details of the historic
resource. In addition, the existing hip roof was expanded to cover the new rear
additions. As a result, the new construction could not be differentiated from the historic
building.
83-051
In reviewing the initial application, the State office made note of several important
aspects of the project that would require redesign. As a Federal era design, the pair of
town houses was distinguished by narrow, one room deep "T" shaped plans. The state felt
that the infilling of this plan should not give the appearance of earlier mid-Georgian
plans that were heavier in mass and proportion. As such, the State recommended that
the new additions read as separate structures connected to the historic resource, thereby
preserving the original sense of the Federal plan. In addition, the new construction
should be attached to the historic building with a minimum of damage to historic fabric
so that if, in the future, the additions were to be removed, the basic form and integrity
of the historic structure would remain.
The SHPO suggested that a contemporary design for the additions be considered, that
the materials used provide a neutral backdrop for the historic resource, that the roofline
of the additions be lowered so as not to damage the ornamental historic cornice, and that
care be taken to minimize removal of historic fabric. In essence, the new rear additions
should be treated as separate pavilions that would read as new construction in order to
preserve the character-defining features of the historic resource. The owner was
amenable to these suggestions and resubmitted his design (see illus. 2), which was then
forwarded to the regional office with a recommendation for approval.
In reviewing the proposal, the regional office agreed with the State on the need to
clearly differentiate the new construction from the historic resource through the use of
materials and setback connection details, while achieving compatibility in terms of scale,
proportion, and location. A modern flush metal panel system was selected for the
exterior sheathing of the new construction to act as a neutral backdrop to the carefully
restored historic brickwork. The use of glazed panels recessed between the historic
masonry and the new addition would allow the distinct feature of the Federal plan to be
exposed. In addition, much of the original rear walls of the historic structure would
remain exposed with the windows in place as part of the new construction. This would
reduce the loss of historic fabric while leaving clear evidence of the connection between
the original and new construction (see illus. 3).
On the exterior, the new additions would reflect the scale, massing, and proportions of
the historic building without replicating the original detailing. The placement of the
window and door openings on the exterior of the new pavilions would match the scale and
proportion of the historic facade, but the detailing would be executed in a modern
fashion. The use of a separate hipped roof for the pavilion additions would maintain the
scale of the historic rowhouses and the neighborhood (see illus. 4).
The regional office approved the proposed rehabilitation as the existing historic resource
was being carefully preserved and the new additions were compatible with the historic
character of the property.
Prepared by: Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
I40 •— �'r'- 1I 83-051
)
11 a 4 9 1 , 1.) Ii Illustration #1. Site Plan
4 ill I The proposed two rear additions would
I change the plan from a "T" shape to a
,,,,,,_ ,,,404614 deep rectangle. In order to preserve the
•
" '' �"% characteristic proportions of the Federal
.� ,M , Val_ era, circa 1809, plan, it was determined
:� 1 that the new additions read as separate
1 -- i . ; structures and not as a continuation of
{ the historic structure.
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Illustration #2. PERSPECTIVE VIEW. The revised design treated the rear addition
as a modern pavilion to clearly differentiate it from the historic structure.
83-051
,,.:,.:::.w:,,i:i::p:i:K,..;:i,„:K:i::*: ::ii:::•ts
P LA FLOOR ti TYPICAL
I i ��3
Illustration
at on
-cam
s
Anti . . infill plan (shaded) would
The proposed
-- h
:�: Q: historic ma
terials
by
leavingthe
F.. the isto c resp
ect t
_ .,..,.,:. I -�- ;«<>:~:.�.<.. wallsexposed within the new
:x.�<.. >:i`�- � • original rear
<<-' addition. The existingwindow and door
I 7 COS r>..;...
->:.. , ,x ; _ , k' I�p1 4.; openings would be left in place, as much as
M.. . �. J /
�"— « • > 0 I� : .. -- `"' possible. In addition, recessed panels would
7 be used as a connector infill between the,a I ,
c T 1 , original building and the additions in order to
i`• /it n tp - clearly differentiate the new construction
- --�. — from the historic structure.
rLH' : * I
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Li \_ ._,
_____,
• ,. • .
:•:. ...,, 771 14 -
Illustration #4. ELEVATION ....
The new 4 story addition visible from0.
the street would be compatible in -*
scale and proportion with the historic • ',: •
structure. The pattern of window and ..
•
door openings in the new addition •
would reflect the rhythm in the `——
historic facade. The use of a modern
panel system, as opposed to detailed —brickwork, would clearly separate the — 7
new construction from the historic - ---- r---- c
resource. The use of a separate ._. Il L �_� r-•,
hipped roof for the addition would � \
retain the scale of the property and • I �D
would eliminate damage to the = ,o
historic roof and cornice. • ... E_o_ 1
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards tor Rehabilitation
Number: 83-052
Applicable Standard: 2. Retention of Architectural Character (conformance)
6. Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical Evidence
(conformance)
Subject: COMPATIBLE, NON-MATCHING REPLACEMENT WINDOW SASH
Issue: Windows in historic buildings— both the openings and the actual sash that fill the
openings— can play an important role in defining historic character. Where window
openings or window sash are distinguishing features of the historic building (especially on
primary facades), building owners should strive to retain and repair them, in accordance
with Standard 6. If, after careful investigation, the window frames and sash are found to•
be so deteriorated that they must be replaced, then replacement windows should match
the historic windows as closely as possible, also in accordance with Standard 6 and the
rehabilitation guidelines. Unfortunately, owners often replace historic windows with
incompatible windows as part of a rehabilitation project, resulting in denial of
certification. In rare cases, non-matching replacement sash may be acceptable where
the historic window sash are not considered essential in defining the overall character of
the building. This usually occurs on buildings with richly ornamented facades where
there are numerous architectural features and details that add a high degree of
articulation to the building, and which are the major determinants of its historic
character. It should be emphasized, however, that this is the exception, rather than the
rule, and that violation of Standard 6 will usually result in certification denial.
Application: A 10-story, 1904 classical revival commercial building in a proposed
historic district was rehabilitated as housing for the elderly. The primary facade of
rusticated concrete and limestone was richly decorated with brackets, cartouches, and
pediments. The project work included replacement of all the historic window sash.
(Fortunately, no new window openings were made, nor was the proportion or size of the
window openings changed.) The original wooden window sash were replaced with double-
glazed metal units. The original sash were divided at midpoint by a horizontal meeting
rail; this division was repeated with the metal replacement sash, but the meeting rail was
thinner, and was placed on the lower third of the sash. On the seventh floor, a pair of
tripartite arched windows were further altered by replacement with fixed single pane
glazing in the side lights. Although a horizontal division of the sash was maintained, the
replacements altered the historic pane configuration and meeting rail dimensions. With
the concurrence of the SHPO, the NPS regional office denied certification. This
decision was explained in the denial letter to the owner:
The result of all these window alterations has had a detrimental effect on
the historic appearance of the building. When it is necessary to replace
existing historic windows in the course of rehabilitation, the "Standards"
for this program require that the replacement windows match the visual
qualities of the historic windows.
83-052
In requesting an appeal, the owners contended that the new windows "caused no
noticeable change in the building's appearance from any angle or distance." The owners
also submitted additional photographs of the primary facade taken before and after the
window installation.
After inspecting the property and reviewing the additional information submitted by the
owner, the appeals officer overruled the original decision. Central to the reversal was
the appeals officer's determination that the historic windows were not critical in defining
the historic character of this particular building, and the replacement windows were
compatible. The appeals officer stated in the notification letter:
The historic character of this building is primarily determined by its form
and by the richness and scale of the architectural features, including the
split pediments, rusticated columns and voussoirs; carved garlands,
brackets, sculptured keystones, tabernacle frames and cartouches. I do
not consider the windows to be an essential character-giving element in
this particular building. Even though the proportions of the pane openings
and rail dimensions have been altered, the relationship of solid wall to
windows openings was preserved in the rehabilitation process; in this
particular case, I feel that the replacement windows minimally meet the
Secretary's "Standards for Rehabilitation" and the overall rehabilitation is
consistent with the historic character of the building. I would not expect
to make this decision where similar window treatments were proposed on
a building less ornate than this one.
Prepared by: Jean Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
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BEFORE
Replacement sash now feature a lower meeting rail. The
Original double hung window sash featured
oo
side lights in the arched windows were also replaced with
a mid-level, horizontal meeting rail,
lz,
fixed single pane glazing. The top floor is in a shadow; it
was not altered by the project work. IV
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 84-053
Applicable Standards: 1. Compatible New Use (nonconformance)
2. Retention of Distinguishing Architectural
Character (conformance; nonconformance)
4. Retention of Significant Later
Alterations/Additions (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (conformance; nonconformance)
Subject: REHABILITATING HISTORIC STOREFRONTS FOR NON-COMMERCIAL USE
Issue: The historic character of a commercial structure is often jeopardized when a
building is rehabilitated for residential or office use. The owner, therefore, must first
consider Standard 1 of the Secretary of the Interior's "Standards for Rehabilitation",
which addresses the issue of compatible new use when determining the nature of a
rehabilitation project. If a commercial building is to be used for residential purposes,
several factors must be considered in order to preserve its historic character. Because
the open quality of most storefronts is not always compatible with the greater privacy
and security required for new uses, owners often propose designs that involve the
alteration or removal of historic materials and features. In storefronts, such features
may include large expanses of glass, transom lights, cast iron surrounds, kick plates,
elaborate cornices, and special entrance conditions. Collectively, these elements can be
important in defining the unique character of a commercial building and should thus be
retained in the process of rehabilitation.
According to Standard 2 of the Secretary of the Interior's "Standards for Rehabilitation,"
"the distinguishing original qualities or character of a building, structure, or site and its
environment shall not be destroyed. The removal or alteration of any historic material
or distinctive architectural features should be avoided when possible." In order to
comply with the Secretary's Standards, it is necessary to assess the feasibility of
residential or office use on the main floor and the need to preserve the historic
storefront character of the building. To properly address preservation issues and weigh
them against the demands of contemporary re-use, rehabilitation projects require
innovative design solutions which are sensitive to historic materials and features.
Radical alterations to the storefront of a historic commercial structure will result in
diminution of the building's historic character and ultimately in denial of certification
for tax benefits.
Application: A mid-nineteenth century corner grocery store and residence was converted
to a two-unit residential building. Located in a historic district of mixed commercial and
residential use, the building exhibited the scale, detail and simple architectural design
characteristic of the time period and area in which it was constructed (see illus. 1 and
2). In preserving the existing storefront and diagonal entrance, the owner installed new
plate glass in the existing openings and transoms, and replaced the recently constructed
brick infill below the plate glass windows with wooden panels (see illus. 3 and 4). The
cornice, often a significant architectural element in storefront design, was also repaired
and repainted. Important interior features such as a pressed tin ceiling and pine
84-053
fireplace mantel were restored. The completed design maintains the commercial
character of the building, yet, with the inserted wood panels at the base and the possible
addition of appropriate curtains or shutters behind the plate glass, it does not sacrifice
the privacy of the residents. The project is, therefore, in conformance with the
Secretary's Standards and was approved as a certified rehabilitation by the National Park
Service.
A second project involved the conversion of an early nineteenth-century brick Federal
style townhouse into law offices. Originally a residential structure, the building had been
used for commercial purposes as early as 1902 and had acquired a new entrance and wood
and glass storefront on the ground floor (see illus. 5). Because other structures along the
street had also been adapted for commercial use at an early date, this was seen as a
significant development in the evolution of the district. The area is currently comprised
of buildings which are primarily commercial at street level and residential above.
Rehabilitating the building, which had been substantially damaged by fire, involved
completely removing the existing storefront and entrance and replacing the historic
opening with brick infill and residential-scale fenestration which replicated that on the
upper floors (see illus. 6). This treatment violates numbers 2, 4 and 5 of the Secretary's
Standards. By continuing the facade treatment of the upper floors on the street level,
the commercial character of the building was lost and the continuity of the streetscape
interrupted. The impact of inserting a building with residential character was dramatic
because the structure is one of a continuous row of buildings, which, although not built
together, had acquired significance as commercial structures and read as a consistent
portion of the district. The project was denied certification on the basis that the
changes to the front facade, especially the loss of the building's storefront character,
were not in keeping with the Secretary's Standards. In an appeal of this denial new
information was presented which indicated that the date of construction of the existing
storefront was recent (approximately 1950) and that the storefront had suffered
extensive fire damage. While the denial was reversed because of new information and
because, in lieu of the damaged storefront, the owners had attempted to return the
building to its original residential appearance, the Chief Appeals Officer took this
opportunity to express his conviction that the commercial character of this part of the
district reflected changes to the area over time and, where possible, should be preserved.
A third rehabilitation of a two-story mid-nineteenth century commercial structure in an
urban residential neighborhood involved the retention of a corner entrance and projecting
display cases. To adapt the building to residential use, wood lattice in a contemporary
motif was applied to the inside of the projecting bays (see illus. 7). Although not a Tax
Act project, this unique, yet reversible, design solution increases privacy and security
from the street while preserving the historic fabric and commercial character of the
building. By respecting the building's original appearance, its compatibility with
neighboring structures is maintained.
Prepared by: Martha L. Werenfels, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
' �'rt4ie 84-053
•
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' 3 > _ Example One
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: { 1. and 2. Before rehabilitation. The
.� corner grocery store had its original
• 4,. diagonal entrance and flanking plate
' • ' `-" "- glass windows. Although the storefront
• �.� remained intact, the base had been filled
� ; • „- •- • .--' with brick and the plate glass boarded
:� . _•"4 _ over.
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84-053
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Example One.
3. and 4. After rehabilitation. In rehabilitating the original
storefront, the owner installed plate glass in the large openings
and transoms and replaced the brick infill with wooden panels.
By retaining significant architectural features, the commercial
character of the building was retained.
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84-053
1
...._ �... _ Example Two.
E _ ... . r 5. Before rehabilitation.
- : �- ._ The early 1800's rowhouse,
.- although damaged by fire,
.- 11 retained its storefront.
$ lig Mil ; ,-: I hit '° ' It is seen here as an
4•e iii L• k t- te ..! integral part of a row of
rr � nte g
l ; FtoR '• z -_ commercial structures.
:i 7 ..t 1*.•--" : i„.4-P',' •,-
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�_ .1_ t t* Example Two.
- — 6. After rehabilitation. The
- building exhibits residential scale
- windows and door openings on the
aNamss . • u�� -- - ground floor. This alteration
MO • U■ results in a loss of the building's
"'`' Waft commercial character and an interrup-
•;sus 4�it tion in the commercial row.
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84-053
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Example Three.
7. Wood lattice installed inside the display windows increases
privacy from the street without sacrificing the commercial
character of the building.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 84-054
Applicable Standards: 2. Preserving the Distinguishing Character of
a Building (nonconformance)
3. Recognition of Historic Period
(nonconformance)
4. Retention of Significant Later
Alterations/Additions (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
6. Repair/replacement of Deteriorated or
Missing Features Based on Historical
Evidence (nonconformance)
Subject: REPLACING REPAIRABLE HISTORIC INTERIOR/EXTERIOR FEATURES
AND MATERIAL
Issue: "Rehabilitation," as defined in 36 CFR 67.2 assumes that some alteration is
necessary to accommodate a new use; at the same time, the definition makes clear
the requirement that those portions or features of the property which are "significant
to its historic, architectural, and cultural values must be preserved." In order to meet
this preservation requirement and be certified for tax benefits, features and materials
of both the interior and the exterior of a building that are important—or character-
defining—should (1)be identified in the planning stage; and (2) be retained and
repaired in the work stage so that alterations necessary for the new use do not result
in their loss.
It is particularly important to note that preserving exterior features does not mean
that, as a trade-off, interior material and features can be removed; similarly,
repairing and preserving interior features does not mean that exterior materials and
features can be removed. When either interior or exterior materials and features that
are important in defining the building's historic charcter are removed, the
rehabilitation may violate Standard 2, 3, 4, 5, or 6 and, in consequence, be denied
certification for tax benefits.
Application: An 1894 townhouse located in a historic district in the midwest exhibits
on the exterior the simple architectural details characteristic of late-nineteenth
century townhouses built in the area. The three-story, three-bay residence has
modestly detailed brickwork, a recessed entrance with an ionic column supporting a
first floor entablature and decorative lintels over second floor windows (see illus. 1).
This simple detailing is also present on the interior, where a considerable amount of
historic material, including millwork, mantels, doors, and moldings contributes to the
character of the building (see illus. 2). The floor plan, with side entrance and stair
hall, also has an unusual diagonal arrangement of the mantel and partitions in the
parlor (see illus. 3).
84-054
In order to convert the residence into four modern apartment units, both exterior and
interior work was necessary. The owner's rehabilitation proposal for the townhouse
exterior included cleaning the masonry with low-pressure water; limited tuckpointing;
replacing a severely deteriorated cornice with one which would match the existing in
material and detailing; replacing a later front door with one milled to the dimensions
of the original; and replacing unrepairable window sash with new sash, reusing the
historic wood frames. All of this exterior work was considered to be in conformance
with the Secretary's Standards.
Interior demolition had already begun when the project was reviewed by the National
Park Service. This work included removal of historic material and features which the
owner assessed as "unusable." The owner's proposed floor plan for the apartments (see
illus. 4) required removal of existing partitions; subdivision of the front parlor in order
to maximize rentable bedroom space; and relocation of the living area to the former
historic entrance and stair hall space. Substantial rearrangement of rooms throughout
the building resulted in removal of additional partitions and corner fireplaces. Door
and window trim, as well as baseboards and doors, were also removed. The regional
office of the National Park Service felt that the interior materials, features, and
spaces were important in defining the historic character, and should have been
retained and repaired to the greatest extent possible. In consequence, the project was
found to be in violation of Standards 2, 5, and 6 and was denied certification for tax
benefits.
In appealing the denial, the owner stated that some of the historic materials and
features had been severely deteriorated and needed to be replaced; and that still
others were missing entirely. Based on his assessment, all existing historic materials
and features were removed and a contemporary looking interior—considered by the
owner to be a more marketable—was constructed.
Photographic documentation presented at the appeal, however, indicated that the
historic materials and features could have been repaired and only needed to be
replaced in part with new material. It was the opinion of the Chief Appeals Officer
that, together with the distinguishing spatial arrangement, interior materials and
features should have been preserved in the process of rehabilitation.
The owner then expressed a willingness to re-install portions of the historic interior
material which had not been severely damaged in the removal process and had
subsequently been stored; and to reconstruct the interior partitions and missing
historic features using all new materials. However, due to the extensive removal of
historic materials and features that should have been retained and repaired initially,
this proposal was determined to be in violation of Standard 6. Once material is
removed under such conditions, the loss is considered irretrievable; it cannot be
remedied through reconstruction. The limited re-installation proposed in this case was
determined not to constitute adequate preservation of the resource. It should also be
noted that acceptable preservation work on the exterior, in conformance with the
Standards, was not considered a mitigating factor because all work must be in
conformance with the Standards for certification purposes.
84-054
Application: A second rehabilitation in the southeast involved a three-story wood
frame house which was built ca. 1830 and displays Federal style features, including
fireplaces, trim and doors. Changes had taken place on the exterior of the house
ca. 1910, the most major of which was the addition of a large Victorian front porch
extending across the front facade and wrapping around two sides (see illus. 5). The
porch was characterized by columns resting on brick piers, turned ballusters and a
decorative central pediment. At the time of the porch construction a lean-to addition
was also built on the rear of the building and a bathroom was installed on the third
floor.
The intent of the rehabilitation work on the residence was to restore the building to
its original 1830s appearance—the rationale for such work being largely predicated on
the owner's assessment of the 1910 features. Because the porch was determined by the
owner to be severely deteriorated and thus unrepairable, he felt preservation would
require a prohibitively expensive dismantling and reconstruction of the piers, as well
as total replacement of the roof (see illus. 6). As a result of this assessment, the
porch was demolished. New front stairs and a covered stoop were then constructed on
the primary facade to its 1830's appearance (see illus. 7). Interior work—including
opening up of original fireplaces, removal of later inappropriate panelling, and repairs
and repainting of doors and door trim—was also undertaken and completed as part of
the project.
When the project was reviewed by the State Historic Preservation Office, initial
concern was expressed over potential violation of Standard 4 in the exterior
demolition work, and, in a final review by the region, the work was subsequently
denied for violation of Standards 2, 4, 5, and 6. According to a letter from the
regional office of the National Park Service, "The Victorian porch was distinctive in
terms of its large size and style...and had gained significance in its own right; thus, its
removal resulted in the loss of an important feature attesting to both the stylistic and
physical evolution of the structure."
Finally, the Region agreed with the State in the final review that the porch as it
existed at the time of the rehabilitation was deteriorated, but that its condition did
not warrant removal. Because it was a character-defining feature that should have
been retained and repaired, its removal violated Standards 2, 4, 5, and 6. A secondary
issue in the denial was that the design for the new entry was not based on either
photographic or physical evidence and was, therefore, conjectural. This treatment
violated Standard #3.
Because the owner felt that "restoration" to its 1830's appearance was an appropriate
treatment for the structure, he appealed the regional decision. In a final letter to the
owner that sustained the region's decision, the Acting Appeals Officer wrote:
The c. 1910 wrap-around porch, which was removed during the course of
rehabilitation, was significant in determining the character of the
building...Removal of the porch, with its decorative frieze, classical columns
84-054
and turned ballusters, constitutes a loss of an important character-defining
feature...While it is my understanding that work on the interior was well-
executed, it cannot compensate for loss of a major character-defining
element.
Prepared by : Kay D. Weeks and Martha L. Werenfels
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
84-054
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1. The townhouse, with its simple detailing, pictured
before rehabilitation. The owner's proposal for
exterior work was considered to be in conformance
with the Secretary's Standards.
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2. Modest interior detailing, such as window and
baseboard trim, and diagonally placed mantels
contribute to the historic character of the 1894
townhouse and thus should have been preserved to the
greatest extent possible.
84-054
i_l_iiiimimminoimmEiamiiiij
.X15TiPJG $LOoa PLAN
3. A floor plan with side entrance and stair hall, and
front parlor containing diagonally arranged partitions,
chimney and mantel were identified as important in
defining the historic character.
- LII
110 III
PROP05ED TL00R PLAN
4. Interior work involved demolition of existing
partitions as well as relocation of the living area to
the historic entrance and stair hall space (see illus.
3). The rearrangement of rooms led to removal of
corner mantels, baseboards, and door and window trim
(see illus. 2). Because the character-defining interior
spaces, features, and materials were not sufficiently
preserved, the entire project failed to meet the
Standards, despite qualifying exterior work.
84-054
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5. An 1830 structure with its large 1910 wrap-around 6. A detail of the 1910 porch shows structural
porch characterized by columns resting on brick piers, problems that need to be corrected. The owner
a highly decorative central pediment and turned assessed the 1910 front porch as unrepairable, whic'
ballusters. The porch was in a deteriorated, but still led to its removal.
repairable, condition prior to rehabilitation work.
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7. The replacement front porch—conjectural in
design—was constructed after demolition of the
historic porch. NPS concluded that because the 1910
porch was an important character-defining feature and
was repairable, it should have been retained. The
project was denied certification of rehabilitation for
tax benefits.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
( Standards for Rehabilitation
Number: 84-055
Applicable Standards: 2. Preserving the Distinguishing Character of
a Building (nonconformance)
3. Recognition of Historic Period
(nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Features Based on Historical
Evidence (nonconformance)
Subject: REPLACING HISTORIC M ATERIALS/FEATURES WITH NEW MATERIAL
TO CREATE AN "IMPROVED" APPEARANCE
Issue: As stated in 36 CFR 67.2 the treatment "rehabilitation" assumes that at least
some repair or alteration of the historic building will need to take place in order to
provide for an efficient contemporary use; however, these repairs and alterations must
not damage or destroy the materials and features—including their finishes—that are
important in defining the building's historic character. In terms of specific project
work, preservation of the building and its historic character is based on the assumption
that (1) the historic materials and features and their unique craftsmanship are of
primary importance and that (2), in consequence, they will be retained, protected, and
repaired in the process of rehabilitation to the greatest extent possible, not removed
and replaced with materials and features which appear to be historic, but which are—
in fact—new.
Sometimes an owner or developer will fail to identify character-defining materials or
features in the planning stage and, in consequence, will remove or alter them so that
the historic character of the building is compromised. More often, however,
character-defining materials and features on the exterior or the interior are
adequately identified but, in a mistaken effort to make the historic building look like
new or to have an improved or uniform appearance, they are removed and replaced
with new material. In other words, rather than retaining or repairing the historic
material and features, an owner or developer will remove them—perhaps believing
they are unrepairable or that repair costs are too high—then use new materials to
create "historic appearing " features, or, alternatively, to create a contemporary
look. In either case, the justification is often that the new product looks even better
than the historic material and will be more visually appealing for re-use purposes.
Such removal and replacement of historic materials will violate Standards 2, 3, and
6. A determination to remove and replace character-defining materials and features
must be based on severe damage or deterioration, as determined by a structural
engineer or other qualified professional. Then, even if well-defined circumstances
exist justifying replacement of individual features for visual reasons—or a loadbearing
wall for structural reasons—it is critical that so much new material is not introduced
that a historic building becomes essentially new construction.
84-055
Application: A ca. 1870 stone Gothic Revival structure (see illus. 1) was being
rehabilitated for re-use as an office building. A 1967 "modernization" of the building's
facade for retail use had involved installation of a stucco false front on the upper
level of the building. When the false front was subsequently removed as part of the
new work, the owner found that the castellated stone at the top of the building had
been removed; the historic decorative bands had been chipped away to permit
installation of the stucco work; the window sills and jambs were damaged; and several
holes had been bored into the stone to anchor the false front. Stone on the ground
level of the building had been removed as the result of a 1950s installation of an
aluminum and glass entry and merchandise and display area (see illus. 2 and 3).
Based on his evaluation of the overall damages to the stone as a result of the
combined alterations, the owner concluded that the entire facade was essentially
beyond repair and that partial replacement of the historic material would not be
possible without leaving a splotchy, uneven facade—an appearance he felt was
unacceptable. The report specifically cited the unavailability of matching limestone,
potential structural consequences of replacing only the damaged stone, and the high
cost of repair over replacement. As a result of this assessment, the owners elected to
demolish both damaged and intact historic limestone from the primary facade by
cutting it back to a depth of 5 inches, then re-build the facade with an all new stone
veneer in order to achieve an even, uniform appearance (see illus. 4).
When the Part II application was reviewed by the State, concerns were expressed
about the removal of what they assessed—as a result of a site inspection—to be a
largely intact upper level that could have been repaired; and the subsequent
demolition of the entire character-defining facade and reconstruction with all new
material. Considered a precedent-setting project by the region, application materials
were forwarded to the Associate Director, National Register Programs, for an opinion
before a final decision was reached.
In a memo to the regional office, the Associate Director stated:
It is our understanding that there are no significant features or spaces on the
interior and that the facade was the sole "character-defining" feature of the
structure. Because so little significant historic material remained, it became
all the more important to retain what had survived to the present. While the
party and rear walls and floor systems remain intact, retention of these
components does not constitute adequate preservation of the resource for
Federal tax benefits. The integrity of the individual architectural features
and spaces has been irretrievably lost, as a result of other changes over the
years and, finally, as a result of this most recent rehabilitation.
Prepared by: Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
84-055
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1. This historic photograph shows the 1870s building 2. A 1967 storefront alteration involved installation of
with intact limestone and distinguishing Gothic a stucco false front on the upper levels; stone at the
Revival detailing. ground level had been removed as the result of the
installation of an aluminum and glass entry in the
1950s.
84-055 ,
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3. When the 1967 storefront was removed, the owner 4. This photograph shows a totally reconstructed
assessed overall damages to the upper and lower levels facade using all new material. NPS recommended
and felt total replacement of the limestone facade was denial of the project for tax benefits because it was
necessary to restore the historic appearance. determined that the damaged upper level could have
been repaired. An unacceptable loss of historic
material on a significant facade was specifically cited
in the denial letter.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 84-056
Applicable Standards: 2. Preserving the distinguishing character of a
building (conformance)
3. Recognition of Historic Period
(conformance)
6. Repair/replacement of Deteriorated or
Missing Features based on Historical
Evidence (conformance)
Subject: REPLACING SEVERELY DETERIORATED HISTORIC MATERIALS
Issue: Although maximum retention of historic material is always the primary goal in
rehabilitation projects, building features may be so severely deteriorated that
replacement with new material is required, either for visual or for structural reasons—
or both. Such replacement may be limited to several bricks, wood window sash, or
brackets of a cornice; or may involve an entire loadbearing wall or walls.
In the latter situation, when extensive replacement of historic material has been
recommended by a structural engineer or other qualified professional—even if it is to
be replaced with matching new material—it is important that so much new material is
not introduced that a formerly historic building becomes essentially new
construction. In this regard, replacing a structurally unsound wall on a side or rear
elevation is usually less critical than replacing deteriorated features on a primary
elevation; similarly, replacing extensively damaged interior material and features on
upper floors may be less critical than removing and replacing significant material and
features in highly visible first-floor spaces. It should be remembered, however, that
even when features and material which are secondary in defining the character of the
building are extensively replaced, the cumulative effect may involve such a high
degree of loss that, in consequence, the project will violate Standards 2 and 3. When
extensive loss of historic material occurs—even if severe deterioration or damage is
present and seems to warrant extensive replacement—a project can be denied
certification because the"historic resource" is no longer historic.
Application: An 1860s rusticated ashlar brownstone commercial building, altered in
1880 with the addition of a flush ashlar brownstone facade on the west, was purchased
for rehabilitation, for office use (see illus. 1). The building had been derelict and
vandalized for several years—in addition to the total lack of maintenance—and, as a
result, was severely damaged and deteriorated. Within the three exterior walls (south,
west, and north), which consist of 14-inch thick loadbearing masonry of two wythes of
brick faced with brownstone, the mortar was failing between the brick and the stone.
The brownstone was spalling on both the north and south walls, with the condition
much worse on the north (see illus. 2 and 3). The building had been painted in the past,
possibly in an effort to stop water penetration. On the interior, the majority of the
distinguishing architectural detailing had been removed as a result of deterioration,
84-056
vandalism, and inappropriate earlier work. A cast iron and marble stairway between
the first and second floors and two cast-iron columns with ornate capitals on the first
floor were still in place. The floor structure and flooring were intact, but damaged,
and historic window trim and some sash remained.
An initial structural assessment led to a proposal to rebuild the north and south
walls. The structural engineer felt that the original construction technique—tying the
interior brick to the facing brownstone with iron strap anchors—was inadequate.
Further, the deficiency of the walls had been aggravated by water penetration into the
cavity between the brick and the stone, which had caused the iron anchors to rust.
The recommendation to rebuild both walls was based primarly on a few test holes
bored in the walls for investigation of the condition of the materials, particularly the
metal anchors; and on the fact that both walls were out-of-plumb by about two
inches. However, because this proposal—along with planned interior alterations for
modern office use—involved such a substantial loss of historic material, the National
Park Service determined that if the project proceeded as proposed, the resulting
building would be substantially new construction. Therefore, despite the seriously
deteriorated condition of the materials, NPS found that the work, as proposed, would
violate Standards 2, 3, and 6.
Subsequently, two structural engineers sought ways to preserve more of the historic
material. It was confirmed that the north and south walls were out-of-plumb. To
ascertain the reason for the apparent structural problems, more holes were bored so
that the condition of the walls could be thoroughly investigated. The findings were
that the north wall had lost its loadbearing capacity because of the advanced
deterioration of the stone, brick, and iron anchors; however, the engineers' solution
was to rebuild the wall only from the second floor up rather than the entire wall as
initially proposed. Since the materials were not salvageable, the replacement wall
would be all new materials. Cast-stone over concrete block was selected as a
compatible substitute material with the facing cast-stone to simulate the historic
brownstone. The re-evaluation of the structural and preservation problems of the
building led to the conclusion by the architect and engineer that the south wall could
be retained in place with the use of stainless-steel pins tying cementitious patches to
the sound brownstone beneath. The bulk of the patching would be at the beveled edges
of the ashlar blocks where the worst erosion had occurred, leaving the majority of the
historic material intact and visible.
As opposed to the initial approach, this proposal was found to preserve considerably
more historic material and was thus given preliminary approval; however, in approving
the rehabilitation proposal for Federal tax incentives, the National Park Service
expressed "serious concerns about the severe deterioration of the building." The
certification letter further stated that the positive determination was based on the
assessment "that the wooden floor and ceiling framing, the window trim on the
exterior walls, and some window sash on the west wall...as well as the first floor
columns and stair can be saved. It is possible that unforeseen problems, including
additional loss of historic fabric, may jeopardize certification."
During the rehabilitation, the building was sold. The new owner wanted to rebuild
both the south wall (facing the main street) as well as the north wall (facing a side
street) in order to avert the possibility of future structural problems and to achieve a
84-056
uniform appearance. When asked about amending the certification application to
include this new work, the National Park Service referred to its earlier approval
letter, stating that any further loss of historic material would result in denial of
certification for the entire project. The owner consequently proceeded with the
project as initially approved.
Prepared by: Susan Dynes and Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
84-056 - 1. This photograph of the west elevation shows the
1880 addition of flush ashlar brownstone above the
rough-cut brownstone of the first floor. Because the
historic brownstone on this wall was basically sound.
t .!' -! - only repainting was required.
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. 2. The brownstone of the south wall was not as
f .x 1 ' - -er."� . t •+safrOli . deteriorated and could be retained in place and
i' - ' structurally strengthened by stainless steel pins
, •� ^r ,.y _ tying cementitous patches to the sound stone
.i, db 41.1) - beneath. Limiting the patching to the beveled
,,., - -•y f;� '1 edges of the stone blocks where the greatest
�• ` 1 amount of deterioration had occurred was
'� . 1 •k. Pi'UM ri considered a sensitive preservation solution
r� ,�Y '. ;�,` : M because it left the historic material both intact
a _-_4 { �g1• 3 and visible.
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• "• _; 3. Badly spalling brownstone on the north, and less
t .; a .
�,.,. . _ visible, wall was for the most part unsalvageable.
�; ��+ ;� Replacement walls were constructed from the second:' ^,� a I� story up, a solution that assured maximum retention of
er A• .. .• ; �. historic material while making the building
�'"''�'""m= . structurally sound for the new use.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number:84-057
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (nonconformance)
Subject: INAPPROPRIATE REPLACEMENT WINDOWS
Issue: A highly decorative window with an unusual shape, or glazing pattern, or color
is most likely to be immediately identified as a character-defining feature of the
historic building. It is far more difficult, however, to assess the importance of
repeated windows on a facade, particularly if they are individually simple in design
and material, such as the single light, double-hung sash commonly found in many
vernacular late 19th and early 20th century buildings. Because rehabilitation projects
frequently include proposals to upgrade or replace window sash or even replace entire
windows, it is essential that both their contribution to the historic character and their
physical condition be evaluated before specific repair or replacement work is
undertaken.
In the latter half of the 19th century, the use of standard size sheets of clear glass;
the equal division of lights on both the top and bottom of double-hung windows; and
the lack of muntins represented a window evolution that stemmed from an interaction
of style changes and technological developments. In consequence, such simple double-
hung (1/1) windows are often a distinguishing architectural feature of the building that
should be identified, retained, and preserved in the process of upgrading or repairs
within an overall rehabilitation project. A successful preservation solution, however,
is contingent upon recognizing the design role of the windows in determining the
historic character; then prescribing sensitive repair and upgrading techniques.
If the historic windows are determined to be unrepairable, replacement windows need
to be chosen with great care. Again, it is crucial that the role of the windows in
determining the historic character be identified first--in other words, the relative
importance of the size, shape, color, and detailing of the windows to the overall
appearance of the building. After this initial assessment is made, various replacement
units available from manufacturers can be evaluated to assure an acceptable
replacement solution. Unfortunately, all too often an inappropriate approach is taken,
that is, simple double-hung (1/1) windows are replaced with aluminum units without
matching the trim detail, the width of the frames and sash, the location of the
meeting rail, the reveal or setback of the window from the wall plane, the separate
planes of the two sash, or the color or reflective qualities of the glass. In particular,
the installation of inappropriately designed replacement windows in a relatively
unornamented building can dramatically change the historic appearance of such a
building and, as a result, violate Standards 2 and 6.
84-057
Application: A six-story residential/office building located in a historic district in a
large northeastern city was recently rehabilitated. The work consisted of substantial
alterations to the interior in its conversion to modern apartments; restoration of the
front entrance; and the installation of replacement windows. Because there
apparently were few remaining historic features on the interior, the historic character
was primarly determined by its exterior—the materials, features, and finishes. For
this reason, it was particularly important to preserve the historic appearance of the
exterior to the maximum extent possible.
Due to its prominent location at the end of a row of 19th century structures, this
simple, but distinctively-detailed early 20th century building, had three highly visible
facades. On each of these facades, the traditional equally-sized double-hung sash
were important features, comprising almost half of the total wall area. Their
windows' color, proportions, spacing, and frame details also helped to relate the
building to the adjacent older properties (see illus. 1).
Because the windows were determined by the owner to be unrepairable, they were
removed and replacement units were selected and installed. The replacement windows
had flat frames devoid of molding detail, a bronze-anodized finish, and a fixed upper
and operable lower sash. Further, the location of the meeting rail was lowered—for
ease of operation of the large sash--so that the lower sash was only 1/3 rather than
1/2 the size of the historic window (see illus. 2). The owner also chose tinted glass
which she felt was justified in order to lessen the visual impact of an adjacent
elevated highway.
When the regional office reviewed the work, they determined it violated Standards 2
and 6. The denial letter stated:
...The historic windows, with clear planes in a 1/1 configuration
contributed to the restrained character of the building. "Before"
photographs show all of the 1/1 windows in place, and no
documentation was provided with the Part 2 application to show
that the exiting units could not have been repaired and retained.
Had replacement proven necessary, the appropriate treatment
would have been to use new units which matched the
configuration, color, and other visual qualities of the historic
windows. Instead, the replacement windows selected employ a
lowered meeting rail (in a 2/3 to 1/3 configuration) and tinted
glass. As a result, the replacement windows are incompatible
with and detract from the historic character (see illus. 3).
The owner appealed the region's decision on the basis that the replacement windows were
necessary and the design did not detract from the historic character of the building.
After careful consideration, the region's decision was sustained by the Chief Appeals
Officer. In sustaining that decision, he added:
Your major rehabilitation work on the facades of the building
consisted of restoring the front entrance, and the window
changes which are at issue. The lower floor with its different
masonry treatment and decorative entrance certainly is more
detailed than those above. Yet on the three intermediate floors-
-which constitute the majority of the facade--the windows
predominate, and they have now been changed through the
84-057
introduction of new metal frames and sash. Even on the top
floor, the windows are an important feature even though the
masonry has more decorative detail. You sought to justify the
change in the appearance of the windows based on the
desirability of tinted glass from an interior perspective and the
wish for an easy-to-operate sash. While I would agree with you
that the smaller sash may require less effort to operate, you
could have found commercially available windows that would
have matched the appearance of the historic sash, as required by
Standard 6, and that would have been easy to operate.
Prepared by : Charles E. Fisher and Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by
the U.S. Department of the Interior. The resulting determinations, based
on the Secretary of the Interior's Standards for Rehabilitation, are not
necessarily applicable beyond the unique facts and circumstances of each
particular case.
• , =jam''
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1. This 20th century building served as a anchor at the end of the small
historic district and had three highly visible facades. Note how the
location, design, and even the color of the wooden sash and frames matched
that of the adjacent older properties.
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2. This is a close-up view of the contemporary window units which were
installed. They had flat framing detail, bronze-anodized finish, tinted
glass, and a lowered meeting rail.
3. Below is a comparison view of "before" and "after" rehabilitation which 84-057
shows the impact of the window changes. While relocation of the meeting
rail was the most pronounced alteration, the tinted glass, lack of trim
around the frames, increased width of the anodized aluminum frames, and
loss of other detail were cited in denial of the project for preservation tax
benefits.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
rStandards for Rehabilitation
Number: 84-058
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: INAPPROPRIATE SIZE AND SCALE OF NEW EXTERIOR ADDITIONS:
LOSS OF HISTORIC CHARACTER
Issue: In the Secretary of the Interior's "Standards for Rehabilitation," the Department
of the Interior acknowledges that a new exterior addition to a historic building (such as a
fire stair, service wing, or additional story) may be essential to return the property to a
state of utility for an efficient contemporary use; however, at the same time, the
cumulative effect of the design and installation process of a new addition must not
radically change, damage, destroy, or obscure those "portions and features of the
property which are significant to its historic, architectural, or cultural values." (36 CFR
67.2).
Therefore, in evaluating the appropriateness of a new addition, it is critical that the
important character-defining materials, form, features, and detailing of the historic
building be properly identified so that they may be protected and preserved. This
identification process will also make clear those "portions and features" of the historic
property that are not important in defining the historic character and may thus be
reasonably altered or added to in the course of rehabilitating for the new use.
Because of the difficulty in designing sensitive new additions and to clarify what
constitutes a compatible new addition, the NPS has expanded its guidance in this area
(see pp. 56-57, "New Exterior Additions to Historic Buildings" in the Revised Guidelines
to the Standards for Rehabilitation (1983). The advice listed first in the guidelines is to
avoid constructing a new exterior addition altogether because of the potential for
altering and expanding the historic form and thereby diminishing the historic character.
Rather, it is recommended that services and functions required by the new use be located
in non-character-defining interior spaces. Only after it is determined that interior
spaces cannot be utilized, should a new exterior addition be considered at all. Then, the
new addition should be designed so that its size and scale are limited in proportion in
relationship to the historic building--and located on an inconspicuous side of a historic
building to further assure that there will be no radical changes to the historic form and
appearance.
The failure to recognize those qualities that comprise a building's historic character (its
materials, form, features, and detailing as well as relationship to the site and the
district) prior to designing and attaching a new exterior addition can result in overall
changes that are inconsistent with the historic character. In consequence, Standard 2, 5,
or 9 may be violated, thus jeopardizing project certification.
84-058
Application: A small late 1920s Mission Revival building of brick construction with
stucco finish is primarily distinguished on the main facade by a waved parapet cap and
symmetrically placed openings (see illus. 1). In rehabilitating the building for use as law
offices, interior and exterior work was undertaken, including replacement of damaged
plastered walls, re-stuccoing of the brick, cleaning and painting of windows, and the
construction of two new exterior additions.
The first new addition consisted of enclosing existing stairs at one end of the facade for
the clients' main entrance, as well as serving as handicapped access to a ground floor
elevator. The second new addition was a non-functional matching wing wall at the other
end of the facade which the developer felt would preserve the sense of symmetry which
was so strong in the historic building (see illus. 2 and 3).
After reviewing the Part II application, the State office recommended denial of the
project, citing violation of Standards 5 and 9; the regional office, completing its review,
concurred with the State's assessment. In a denial letter to the owner, the regional
office stated:
The new additions, consisting of the exterior stairs enclosure at one end of the
facade and the wing wall at the other end, increase the length of the facade by
at least one-third, thereby altering significantly its overall mass, scale, and
proportional relationships. Further, these additions extend and expand on the
symmetrical historic design of the facade in a way that lends to it a degree of
expansiveness...not present in the simple design character of the structure's
original design features. It is apparent that the attempt to match the color,
texture, and detail of the original design and to continue its symmetry by
extending the facade wall was motivated by a desire to preserve the historic
character of the building. In effect, however, this matching new design is
incompatible: it compounds the additions' negative visual impacts on the
original design by making contemporary and historic portions of the building
indistinguishable from one another.
When the project was subsequently appealed, the Chief Appeals Officer sustained the
regional office's decision that the new additions violated Standards 5 and 9, adding that
"they also give the building a monumentality that, historically, it never possessed, thus
changing its historic character." In consequence, the project also failed to conform to
Standard 2. As part of the appeals process, the architect forwarded three drawings
(schemes A, B, and C; see illus. 4, 5, and 6) for possible changes to the new additions to
bring the project into conformance with the Standards and thus qualify for Federal
historic preservation tax incentives. After reviewing all of the drawings, the Chief Ap-
peals Officer concluded in his final letter to the owner:
The only remedial action that can now be taken...would be to follow scheme
"C": insert a wide expansion joint between the historic building facade and the
new stair enclosure, demolish the new wing wall, lower the parapet on the stair
tower by at least one foot, and paint the new addition a different color than
the original facade. These actions would make the distinction between the old
84-058
and new construction clear; and would restore to the buildng its aspect of a
modest, simplified Spanish Colonial Revival commercial structure. Demolition
of the wing wall would allow one to view the continuous wavy cornice as it
carries around the corner. If the final revised project fails to meet any of the
above conditions, it will not meet the Standards and cannot be certified.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
84-058
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1. This drawing points out the historic form of a small-scale Spanish Colonial Revival
building with a waved parapet cap and symmetrical window and door openings.
84-058
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2. This view of the southeast corner of the primary elevation shows the new addition
that enclosed an existing stair. The addition extends from the termination of the historic
building, which is defined by the waved parapet cap.
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3. This view of the northeast corner of the primary elevation shows the added wing wall
that was built to visually balance the new addition on the southeast corner. Again, the
addition extends from the end of the historic building, as defined by the waved parapet
cap. Both additions increased the total length of the historic building by one-third and
made indistinguishable what was historic and what was new construction.
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4. Scheme "A" was proposed by the developer to make the project meet the Standards.
This change in the design would simply have provided expansion joints to show the
difference between the historic buildng and the new additions. The proposal was
rejected.
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5. Scheme "B" was also offered by the developer as a means of making the project meet
the Standards. Part of this design change was acceptable--the lowered parapet on the
stair enclosure. The total scheme was rejected, however, because the nonfunctional
northeast wing wall, even though differentiated in height, still unnecessarily expanded
the historic form of the building. It also created a symmetry at a scale that never
existed historically.
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6. Scheme "C" represents those changes to the design that would have to be made to
bring the project into conformance with the Standards. The Chief Appeals Officer
specifically listed as requirements for certification a widened expansion joint; demolition
of the northeast corner wing wall; lowering the parapet on the stair tower; and further
distinguishing the new addition from the historic facade by use of a different paint color.
Technical n Assistance
Services Interpreting
Preservation Assistance Division
U.S. DelService. the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
rStandards for Rehabilitation
Number: 84-059
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Features Based on Historical Evidence
(nonconformance)
Subject: REPLACING A SIGNIFICANT INTERIOR FEATURE TO MEET HEALTH AND
SAFETY CODE REQUIREMENTS
Issue: To comply with health and safety codes in rehabilitation projects, the Revised
Guidelines to the Secretary of the Interior's "Standards for Rehabilitation" first
recommendation to owners and developers is to work with local code officials to
investigate variances available under some codes or to devise creative and safe
alternatives so that alterations and additions to historic buildings can be avoided
completely, if possible. Because such variances or alternatives may not always be
feasible, owners and developers are next advised to identify significant spaces, features,
and finishes, so that they can be preserved in the process of successfully meeting code
requirements (such as providing barrier-free access, upgrading historic stairways or
elevators, or installing fire suppression systems).
While it is understood that owners must often undertake work necessary to meet health
and safety code, the Department of the Interior--by law—cannot approve rehabilitation
projects if significant interior spaces, features, or finishes are lost as a result of such
code-required work and, in consequence, the rehabilitation is not consistent with the
historic character of the building. In reviewing an overall project, it is thus critical that
administrators evaluate work proposals to assure that significant interior features are
properly identified so that they may be protected and preserved in the process of
meeting health and safety code requirements. Where a conflict exists between code
requirements and the Secretary of the Interior's "Standards for Rehabilitation", it should
be noted that "...The Secretary of the Interior's Standards take precedence over other
regulations and codes in determining whether the historic character of the building is
preserved in the process of rehabilitation and should be certified." 36 CFR 67.7(d).
Application: An early 20th century commercial building was being rehabilitated for use
as medical offices (see illus. 1) As the result of an inspection by a structural engineer to
assure compliance with State health and safety codes, proposed rehabilitation work
involved removal of a historic ornamental iron cage-type elevator that was manually
operated (see illus. 2) and replacement with a modern elevator (see illus. 3) featuring
automatic pushbutton operation. (The ANSI building code specifically requires an
enclosed cab and hollow metal shaft doors.) Additional proposed work included removal
of the ground floor elevator doors; removal of one set of the existing west-side elevator
doors on floors #3 through #7; and the subsequent blocking of access to the elevator on
that side due to limited passenger use after rehabilitation (see illus. 4 and 5).
84-059
When the project was initially reviewed by the S.H.P.O, recommendation for
certification was made because it was felt that loss of the elevator--although
unfortunate—did not constitute a radical change to the building's interior. However,
when the National Park Service evaluated the proposed work that principally involved
removal of the historic elevator and replacement with a modern elevator to meet code, a
final determination was made that such removal of a significant interior feature violated
Standards 2, 5, and 6. The denial letter to the owner stated:
The elevator with its highly elaborate iron grillwork and the decoratively
molded elevator doors in the lobby is a significant historic feature which
contributes to the historic character of this early twentieth century
commercial building. The features of the elevator, particularly the decorative
cab and the lobby doors are historically significant elements which should be
preserved. Your rehabilitation...will lead to the loss of a significant feature of
the building, in violation of the Standards for Rehabilitation, and the
rehabilitation will not be consistent with the historic character of the
building. For purposes of the historic preservation tax incentives, the
Standards for Rehabilitation take precedence over other regulations and codes
in determining whether the historic character of the building is preserved in
the process of rehabilitation and should be certified (36 CFR 67.7(d).
The denial was subsequently appealed and, in spite of the owner's referral to ANSI codes
requiring enclosure of the elevator, the NPS decision was sustained by the Chief Appeals
Officer, who reiterated in the letter to the owner, "...since a rehabilitation must
preserve the historic character of a property to be certified, I have determined that this
project is not consistent with the historic character of the building and does not meet the
"Standards for Rehabilitation." In the same letter—in order to achieve a certifiable
project—the owner was encouraged to pursue alternative means of preserving the
elevator by enclosing the cab itself with fire-rated glass or by constructing a fire-rated
enclosure for the elevator shaft.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
84-059
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1. Rehabilitation project work on an early 20th century building focused upon meeting
health and safety code requirements for the new use.
84-059 F
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r N" 42 ). •...1. `--^'a '; �:'� • 2. This shows a detail of the open dome,
/lf -t.' .....tr.. ..„,,..:.,.....n-�- '•a'"s'i ',k�\r_.o) f manually-operated elevator with its highly
1 . 1 .; ..;w; F. . , T ., : . decorative iron grill work. Because an
_ ; • enclosed cab was required by State law, the
f r s: historic elevator was found to be in violation
f . �._, �i;, __ 4;" k of ANSI building code standards. The
'_ �` .jt4 �� `� consulting engineer thus recommended its
fa F
t I, t: P.E4}'' � i? removal and replacement with a modern
e.Et,I; t,t. - ., 4 elevator.
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3. The replacement cab featured an enclosed
cab and hollow metal shaft doors, in
accordance with health and safety codes.
• Removal of the 1916 elevator eventually led
1
.
to project denial because the historic
elevator was deemed a significant interior
feature and, thus, its retention and
preservation were necessary to meet
minimum preservation requirements.
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84-059
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4 and 5. The decoratively detailed elevator doors in the lobby (left) were to be removed
as part of the code-required elevator replacement as well as the simpler, panelled doors
on floors 3-7 on the west side (right).
Technical Preservation Services tion Assistance v Pres Interpreting
Preservation Division
National ParkService.
U.S.
Department of Ithe Secretary of the Interior's
U.S. fthe interior
Washington, D.C.
rStandards tor Rehabilitation
Number: 84-060
Applicable Standards: 2. Retention of Distinguishing
Architectural Character
(nonconformance)
9. Compatible Design for New Additions
(nonconformance)
Subject: ROOFTOP ADDITIONS TO SMALL SCALE BUILDINGS
Issue: Rooftop additions are sometimes seen as a way of increasing the usable floor
area of historic buildings located in urban areas. When this type of new addition is
being considered, it must be designed in such a way that it is as inconspicuous as
possible when viewed from the street. Keeping a new rooftop addition inconspicuous
may be difficult on a small building of only two or three stories. Even if the new
addition is set back from the plane of the facade and screened with an existing roof
parapet, it is difficult to minimize the visual impact of an entire new floor on a
relatively low building. On buildings with a relatively small existing floor plan, the
recommended setback may not permit the creation of sufficient new space. This need
to gain valuable floor space has often led to the practice of bringing the rooftop
addition out flush with the historic facade.
The National Park Service recognizes that some alterations and additions may be
necessary to adapt the historic building to an efficient contemporary use. If a new
rooftop addition to a small scale building, however, radically changes the historic
appearance of the building so that the historic character is lost, the project will
violate Standards 2 and 9.
Application: A deteriorated three-story commercial building in a National Register
Historic District noted for late 19th century commercial buildings was rehabilitated
into mixed retail/residential use. Prominently located on a corner site flanked by
two-story structures, the building was built in 1884 as a two-story brick commercial
structure. In the 1890s a one-story addition was placed on the roof of the building
flush with the exterior walls, the exterior was stuccoed and a bracketed cornice was
added. Numerous other buildings within the historic district received similar
additional floors as the commercial district prospered during the first three decades of
the 20th century. These additions were flush with the facades and ornamented with
brackets and other victorian motifs popular in the district.
The building was severely deteriorated, had lost its ornamental projecting cornice in
the mid-twentieth century, and had suffered serious fire damage on the third floor
prior to the rehabilitation (see illus. 1). The overall rehabilitation project included a
one and a half story addition to add eight loft bedroom apartment units over the retail
and office space (see illus. 2).
84-060
As the building was relatively small ( 45')(65') and as a previous addition had been flush
with the exterior, the new addition was designed to continue the vertical expansion of
the building flush with the existing facades in order to maximize new floor space (see
illus. 2). To further blend the addition into the historic district, the owner determined
that a cornice using brackets similar to the lost cornice should be installed on the new
parapet. The spacing of the brackets, however, was modified to accommodate small
modern windows. Dates were added to the facade to differentiate the two major
periods of construction, 1890 and 1980 (see illus. 3).
The owner submitted his request for certification after the rehabilitation was
complete. The state recommended certification of the rehabilitation because it was
consistent with the historic character of the district. The regional office denied
certification because the addition was not consistent with the historic character of
the building itself. Prior to the addition, the building had a simple horizontal
character. After the height of the building had been increased by almost one-third,
the new vertical emphasis gave the building an appearance that it never had
historically. Furthermore, the historicizing of the details of the addition, including
the jack-arch windows, corbelled beltcourse, pilasters, brackets and wrought iron
cresting, eliminated any visual distinction between the new addition and the historic
building. The use of datestones as a device was not sufficient distinction to clarify
the periods of construction nor to preserve the historic character of the building.
The owner appealed the decision, stating that the addition was contemporary in design
and that it "did not destroy significant historical, architectural or cultural materials
and is compatible with the size, scale, color, material, and character of the property,
neighborhood, and environment." The Chief Appeals Officer sustained the denial of
certification, supporting the regional office's determination that the size and location
of the addition were responsible for "altering significantly its (the building's) overall
mass, scale, and proportional relationships." While the imitative nature of the design
of the addition had confused the historic character of the building by giving the
building an appearance it never had, even if the design had been purely modern in
execution, the project could not have been certified as meeting the "Standards." He
concluded that while the building still contributed in a general way to the overall
historic character of the District, that the rehabilitation of the building was not
consistent with the historic character of the individual resource as a result of the
rooftop addition and therefore, could not be certified.
Prepared by: Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of Interior. The resulting determinations, based on the Secretary of the
Interior Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
84-060
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1. The building prior to rehabilitation was a three-story structure prominently located
on a corner site in a National Register district noted for late 19th century commercial
structures. Originally built in 1884 as a two-story brick building, a third floor was
added in 1890, the building was stuccoed and an elaborate projecting cornice was
applied. The cornice was lost in the mid-twentieth century and the building suffered a
serious fire on the third floor prior to the rehabilitation.
84-060
2. The historic building received a one ;• , .
and a half story addition to accommodate '.
eight loft bedroom apartments over the . ' •,': i
retail and office space. Note the change �, ,
in scale and the dramatic vertical emphasis -
as a result of the new rooftop addition.
As the overall mass, scale andproportional
10
relationships of the buildingwere si nif i - _- #
cantly altered, the project was denied ki.p t..�_ �
t % asf f/KaM •certification. . ,; ' , 7 : . : a
ter• i.R. :5 1
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3. The new rooftop addition is not differentiated from the historic resource except by
the use of applied dates. The addition is flush with the exterior walls and has adopted
historicized features including wrought iron cresting, bracketed cornice, jack-arch
windows, pilasters and beitcourses. In this case, however, the addition so altered the
scale and massing of the building, that even if the addition had been contemporary in
design, it could not have been certified.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 84-061
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
3. Recognition of Historic Period
(nonconformance)
4. Retention of Significant Later
Alterations/Additions (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (nonconformance)
Subject: ALTERATIONS TO NON-ORIGINAL 20TH CENTURY STOREFRONTS
Issue: Storefronts on many 19th and early 20th century buildings were changed in the
1920s and 1930s, incorporating new materials and designs popular at that time and
introducing trademarks of the increasing number of commercial chains. Some of these
later storefronts today have no intrinsic value while others merit preservation as part
of the historic structure.
As guidance in evaluating non-original storefronts, those that meet one or more of the
following categories usually are worthy of retention:
1. Exhibit high quality workmanship;
2. Show evidence of being architect-designed;
3. Incorporate materials not commonly used today but are characteristic of a
particular period (e.g., curved glass, Carrara glass, bronze frames);
4. Are representative of a particular architectural style;
5. Are compatible with the rest of the building in terms of design and scale and date
to a historically significant period of the building and/or district.
Application: A two-story commercial building located in a historic district in the
Southwest was operated until recently as part of the S. H. Kress Company store chain
(see illus. 1). While the building dates to the early teens, the storefront had been
altered in the late 1930s, incorporating a distinctive design which was a trademark of
many Kress Company buildings. The band of transom windows recessed entries, metal
framing and large glass display windows sections created the visual image
characteristic of, and historically associated with, the Kress Company chain and its
buildings constructed or renovated in the 1920s and 1930s (see illus. 2 and 3). Thus,
while the 50-year age criteria of the National Register was minimally met, greater
significance was attached to the storefront because it was part of the nationwide
Kress Company effort in storefront design. While the new owners of the building
originally had intended to maintain the existing storefront, breakage of one of the
84-061
large curved glass sections posed an unforseen rehabilitation problem since such glass
was not readily available locally in the required safety glass. With the overall
rehabilitation progressing quickly, the decision was made to replace the entire
storefront with a composite design referencing features from other buildings in the
historic district (see illus. 4). Regretfully, little physical or pictorial evidence of the
original appearance of the building had survived. The completed rehabilitation was
denied certification and the decision sustained on appeal primarily because of the loss
of the intact 1930s storefront (Standard 4), but also because the new storefront was a
conjectural historic design and contained inappropriate detailing (Standards 2,3, and 6).
Regarding the problem of availability of materials--curved glass sections-cost was not
the major factor but rather time. Given time, companies could have been located
which make such custom shapes in safety glass. Unfortunately, expediency and
perhaps only mild appreciation of the historic importance of the 1930s storefront did
not facilitate the careful investigation of such alternatives.
Prepared by: Charles E. Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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1. Prior to rehabilitation, the 1930s Kress 2. Very little change to the 1930s storefrr
Company storefront had survived in place with had occurred prior to rehabilitation as evi_
nice curved entrances although the transoms by this historic photograph.
had been covered over.
tit
R�1 �.. , '� • t .,.., 84-061
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3. The entire storefront was replaced following breakage, during rehabilitation
of one of the curved sheets of glass. Expediency and difficulty in locating a
manufacturers of curved glass were cited by the owner as reasons for the change.
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4. View of storefront after rehabilitation showing conjectural appearance
of the original storefront — note inappropriate detailing of the transoms and small
size of the doors.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Paris Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
• Number: 84-062
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
4. Retention of Significant Later
Alterations/Additions (conformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (conformance)
Subject: REPLACING ALTERED FEATURES OF A HISTORIC STOREFRONT:
COMPATIBLE CONTEMPORARY DESIGN
Issue: Standards 2, 4, and 5 call for the retention of distinctive architectural
features--whether original or changes that reflect the history and development of the
building or the craftsmanship of its builders—and Standard 6 states that such
distinctive features should be repaired rather than replaced, wherever possible.
However, there may be cases where, over time, there has been a cumulative loss of
historic material comprising these features and introduction of new material that
neither exhibits a distinctive style nor special craftsmanship. (Examples of material
loss may include decorative portions of a building such as a storefront cornice; more
functional portions, such as its display windows, entrance doors, metal kick plates, or
transoms; larger portions that combine structural and design roles within the overall
storefront such as masonry, wood, or cast-iron pilasters between bays; or even the
individual storefront bays themselves.)
If individual features of a storefront have been altered and the alterations are not
"changes that have acquired significance in their own right," then the preservation and
repair requirements of Standard 6 do not apply. In these cases, the nonsignificant
later features may be removed and compatible replacement features designed and
installed as long as the new work preserves any remaining historic material, the
storefront character is preserved, and the overall rehabilitation is consistent with the
historic character of the building. The option of replacing features, such as storefront
doors or windows would, however, never extend to later, distinctive features that help
define the storefront character.
In summary, it is cautioned that a thorough professional evaluation be made prior to
removal to ascertain both the significance of individual storefront features as well as
their potential for repair. Demolition of distinctive architectural features and
craftsmanship can be the basis for denying an entire rehabilitation project.
Application A 6-story brownstone and terra-cotta structure built in the 1890s and
located in a historic district in a southeastern city was being rehabilitated for retail
and office use. Proposed exterior work included removal of nonoriginal 20th century
storefront inf ill features—transoms, double doors, glass display windows, and concrete
block kick panels (see illus. 1, 2). A contemporary replacement storefront would then
be installed within the original cast-iron columns, pilasters, and framing, thus
retaining the three-bay division of the historic storefront. The owner's primary reason
84-062
for removing much of the later storefront--those nonoriginal portions--was to
integrate an additional code-required fire exit into an overall design scheme that he
felt would successfully reflect the building's new use as an art gallery.
In its initial review, the SHPO recommended approval of the project work, but
expressed concern over whether or not the 20th storefront infill features had acquired
significance over time. In the regional review, the project was denied certification.
In a letter to the owner, the reasons for denial were explained:
We have reviewed your proposal to replace the existing storefront
with a new entrance of contemporary design that would meet the
code requirement of providing a second fire exit. Though not original
to the building, the storefront appears to be of sufficient age and
design quality to have gained significance in its own right; we feel
that its removal would violate Standards 4 and 5. Although we
recognize the need to install a fire exit through one of the side
display windows, alternative methods were suggested to the architect
by this office that would avoid damaging the significant portions of
the storefront (i.e., the gridded transom windows and double doors)
and which would not require replacement of the entire storefront...In
the absence of documentation demonstrating that the existing
storefront is not significant in terms of its age, period, style,
materials, or condition, we cannot approve its removal for the
purpose of installing a modern entrance to the building.
Because the owner felt that the existing storefront needed to be altered to accommodate
code; that the altered portions were not important historically; and that the
contemporary storefront met Standard 9, the region's decision was appealed. Prior to
appeal, the SHPO offered a final recommendation on the storefront replacement issue in
a letter to the Chief Appeals Officer, supporting the owner's contention that new
evidence seemed to indicate that most of the later alterations to the storefront had post-
dated the 1930s:
In our initial review of the project, much discussion occurred
concerning the significance of the existing storefront. While the
existing storefront, which is obviously not original, is of nice design,
it is not of sufficient quality to say that the storefront has acquired
special significance in its own right or that it is important to retain
the storefront to show the evolution of the building through history.
In addition, I have personally inspected the building and believe that
the storefront is not representative of any particular stylistic period
and is not an example of skilled craftsmanship or a good example of
design and use of material.
On appeal, the regional decision was overturned and the project subsequently certified
for preservation tax benefits. In a final letter to the owner, the Chief Appeals Officer
stated:
After carefully considering information submitted by your architect
concerning the construction detail and dating of the existing
storefront and comments provided by the State Historic Preservation
Officer, I have determined that the proposed project meets the
Secretary's Standards. I share, however, some of the concerns of the
regional office regarding proposed storefront design. While I have
concluded that the existing storefront has not acquired special
significance over time nor exhibits significant stylistic features or
craftsmanship, I would encourage you to consider a contemporary
design that provides greater visual distinction between the transom
and the display windows. I would also encourage you to revise your
design to provide for solid base panels beneath the windows and
doors. These alterations would, I feel, be more in keeping with the
historic character of the building and district yet would clearly
"read" as new construction.
After removal of the altered, nonhistoric portions of the storefront, the compatible new
inf ill was installed, thus retaining and preserving those original portions identified as
historically significant (see illus. 3,4).
Prepared by: Kay D. Weeks and Charles E. Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
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1. Overall view of the 1890s building and ca. 2. The owner removed the nonoriginal elements of the storefront, including plain
1930-1940 alterations to the original concrete block kick panels beneath the display windows, standard non-decorative
storefront. While the twentieth century woodwork and glazing in the transoms and display window sash, and the unadorned
storefront alterations were considered to be of double doors. Although the proposal was denied by the region, it was ultimately
"nice design," they were not significant overturned on appeal. The Chief Appeals Officer concluded that the later storefront
stylistically or in material and craftsmanship. elements did not display any special significance, and could thus be removed. The
original portions of the storefront--the distinctive cast-iron columns, pilasters, and
cornice--were retained, preserved, and integrated into a compatible, contemporary
storefront design.
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3 and 4. Overall and detail views, after installation of the compatible new storefront
features. Note the 1930s-1940s features have been replaced, while the new design
successfully retains the 3-bay division defined by the decorative cast-iron columns
and cornice. The original cast-iron storefront elements have been painted dark
brown as well as upper level window trim and cornice.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Paris Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 84-063
Applicable Standard: 7. Cleaning with Gentlest Method Possible
(nonconformance)
Subject: INAPPROPRIATE CHEMICAL CLEANING OF HISTORIC MASONRY
BUILDINGS
Standard 7 of the Secretary of the Interior's Standards for Rehabilitation states that
"the surface cleaning of structures shall be undertaken with the gentlest means
possible. Sandblasting and other cleaning methods that will damage the historic
building materials shall not be undertaken." While "the gentlest means possible" is
usually interpreted to mean chemical cleaning, water, or water with the addition of
detergents, it is important to realize that these methods too, can be damaging to
historic building fabric. Cleaning techniques involving water or chemicals are not
infallible, and must always be tested. If carried out improperly-- for instance, if the
chemical mixture is too strong, if chemicals are not adequately rinsed out of the
masonry, if wet cleaning methods are undertaken during cold weather or if there is
still a possibility of freezing temperatures -- such cleaning methods can physically
abrade or otherwise visually damage historic masonry. In short, chemical cleaning
may not be "the gentlest means possible." Historic masonry buildings ( and brick
buildings in particular) which have been chemically cleaned in a way that has resulted
in damage to the visual or aesthetic qualities of the masonry, may be denied
certification for tax benefits.
Application No. 1: A 1912 bank and office building constructed of brick with stone
and terra cotta trim was rehabilitated for contemporary office use after being vacant
for several years (see illus. 1). Located at a major downtown intersection, this nine
story building is a prominent and highly visible landmark throughout the city, towering
as it does above the more modestly scaled two to three story neighboring buildings.
The proposed project which was given preliminary approval by the National Park
Service, and was carried out in 1982, included refurbishing of office suites on the
interior, chemical cleaning of the exterior masonry, and replacement of the later
1940's storefront infill with more appropriately scaled window glass.
When the completed project was submitted to the National Park Service for final
review, however, it was denied certification on the basis of the cleaning techniques
which had resulted in "severe discoloration and splotching of the brick surfaces" (see
illus. 2). The region's denial letter went on to say: "The brick was apparently cleaned
with an inappropriate chemical cleaner which was not adequately tested before its
use, contrary to the recommendations contained in the Secretary's Guidelines for
Rehabilitating Historic Buildings. Although the physical damage to the brick was not
documented, the region felt that the visual change to the brick surface was sufficient
to deny the project, citing violation of Standards 7 and 2.
84-063
When the owner appealed the denial he explained that the exterior of the building had
actually been cleaned and treated with a water repellent two times. Unsatisfied with
the result after the first chemical cleaning, the owner required the cleaning
contractor to reclean the building in what turned out to be a futile attempt to improve
the appearance of the brick. During the appeal, the owner was unable to identify the
type of chemicals or the methods used in the cleaning, nor did he provide any close-up
photographs of the discolored brick. Consequently, it remained unknown whether the
chemical cleaning had also caused physical damage to the brick.
After careful review of the project, the Chief Appeals Officer sustained the region's
decision, stating that: "I concur with the regional office's finding that this treatment
(cleaning of the exterior brickwork) 'has so altered the appearance of the building as
to detract from its historic character.' Standard 7 permits only the gentlest means of
surface cleaning... Close-up photographs showing the conditions of the brick before
and after this process (the second cleaning) were not submitted, nor were technical
details of the cleaning methods and substances made available. Nevertheless, it is
convincingly evident from the extent and degree of the persistent discoloration that
the brickwork was subjected to unacceptably harsh cleaning. Accordingly, I find a
violation of Standard 7."
Application No. 2: In a second case, a mid-nineteenth century brick rowhouse was
rehabilitated for rental residential use (see illus. 3). A major aspect of the
rehabilitation of the exterior was the removal of paint covering the brick facade. The
project application stated that the building was to be chemically cleaned, generally an
acceptable paint removal technique in accordance with the Secretary of the Interior's
"Standards for Rehabilitation," and the proposal was given preliminary approval by the
National Park Service. However, when the request for final certification was
submitted, photographs showed that the "cleaned" brick appeared to have been
damaged by the cleaning method (see illus. 4). When questioned, the owner revealed
that the paint had been removed with sodium hydroxide, more commonly called
caustic soda or lye. With the knowledge that some types of chemical cleaning may be
just as damaging to historic brick as sandblasting, it was decided that an on-site
inspection of the property by the National Park Service was necessary in order to
determine if, indeed, the brick really had been damaged by this method of paint
removal. At the project site, comparison of the cleaned brick with the painted brick
of an identical row house on the same block provided evidence (see illus. 4 and 5) that
the surface of the rather soft brick had been "etched" by lye.
On that basis, the project was denied certification by the National Park Service
Regional office. The denial letter sent to the owner stated: "The National Park
Service has been cautioning property owners for some time about the dangers of paint
removal and cleaning of soft masonry. The (State Historic Preservation Office)has
been advising property owners concerning the early practice of painting
many...rowhouses for aesthetic reasons and as a protective treatment for inherently
poor quality brick. We strongly urge you to be more cautious in future projects when
you consider removing paint from historic masonry; we would encourage you not to
remove paint where historically such surface treatment has acquired significance over
time. Where paint removal is an appropriate treatment, only the gentlest means
possible, determined by careful testing, should be used. If no method can be found
which does not damage the brick or change its original visual appearance, the paint
should not be removed."
84-063
When the owner appealed this decision, the Chief Appeals Officer upheld the denial of
the regional office, explaining that "as a result of the cleaning, the surface of the
brick has been eroded, exposing additional folds and irregularities in the clay and
creating a rougher texture to the brick. These visual and physical changes to the brick
have altered the character of the masonry facade."
Prepared by: Anne E. Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
84-063
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1. Nine story bank and office building 2. Office building after chemical
before rehabilitation. Note uniformity cleaning showing splotchy and discolored
of brick color. brick.
84-063
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removal using sodium hydroxide stands
out conspicuously from its still painted
neighbors.
84-063
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4. Close-up view of uncleaned partially
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Tech
Preservation
Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 84-064
Standards for Evaluating Significance Within
Registered Historic Districts (36 CFR 67.5
(a)(2))
Subject: EXTENSIVE REPLACEMENT OF HISTORIC MATERIALS/FEATURES:
LOSS OF INTEGRITY
Issue: In'planning any rehabilitation project, it is assumed that some historic materials
masonry, wood, and metal) will be deteriorated or damaged and need repair or
replacement in preparation for the new use. While a reasonable level of replacement of
such deteriorated or damaged exterior and interior material is acceptable, at the same
time the preservation requirements outlined in 36 CFR 67 must always be met. To
receive Part 1 certification, the building,prior to rehabilitation, must convey historic
significance through its intact features, i.e., display integrity of design, materials, and
workmanship, location, feeling, and association according to the Secretary of the
Interior's "Standards for Evaluating Historic Significance Within Registered Historic
Districts;" and to receive Part 2 certification, the building, after rehabilitation, must
retain those portions and features of the building that have been identified as significant
prior to work, in accordance with the Secretary of the Interior's "Standards for
Rehabilitation."
If, after close inspection, it becomes clear that the significant portions and features of
the building cannot be retained and preserved because of the extent of physical
deterioration or damage, then the building will generally not possess sufficient integrity
of design, materials, and workmanship to be designated as a "certified historic structure"
and, in consequence, Part 1 certification should be denied. In unusual cases where Part 1
certification has already been issued and, during the course of rehabilitation, it is
discovered that the structure does not possess sufficient integrity, the Part 1
certification should be rescinded and the Part 2 application returned to the owner,
unprocessed, with a letter explaining the action.
Application: A deteriorated, three-story, three-bay wide brick structure built in 1843
was certified in the Part 1 application as contributing to the significance of the
registered historic district--a 13 block area of 19th century Federal and Greek Revival
structures (see illus. 1,2,3,4).
A Part 2 application was submitted at the same time as the Part 1 application, but a
determination on Part 2 could not be given due to a lack of information concerning the
below-grade storefront which the owner proposed removing as part of the work to return
the building to a residential appearance. The letter from NPS, WASO requesting
additional information, stated:
Although the application material indicates that the structure
was originally residential, the photographs suggest that the
storefront, including the projecting bay with side entrance
door and cornice, may have acquired historic significance over
time. For this office to make a Part 2 assessment, however,
84-064
you will have to provide information concerning the building's
conversion on the lower floor to commerical use and the
approximate date of the existing storefront. Photographs of the
storefront showing in more detail what had survived should be
submitted. When additional information and photographic
documentation is received, a determination can be made as to
whether the project meets the Standards for Rehabilitation.
In response, the owner submitted the requested information on the storefront in order
to process the Part 2 application; this particular work component was reviewed and
found to be in conformance with the Standards.
The amended application also included new photographic documentation that revealed
the severely deteriorated condition of previously blocked-up portions of the rear of
the building and the extent of damage and loss of both exterior and interior features.
This portion of the building had not been assessed in the initial application, but was
assumed to be substantially intact when Part 1 certification was issued. The newly
submitted photographic documentation called into question the integrity of design,
materials, and workmanship of the building, and it was decided to re-evaluate the
Part 1 certification (see illus. 5,6,7). Following re-assessment, a second letter was
sent to the owner, explaining the region's findings:
Based on the information submitted in the original application,
the National Park Service determined that the property
contributed to the significance of the registered historic
district in which it was located, and thus qualified (for tax
benefits) as a "certified historic structure." This certification
was based on the assumption that a majority of the structure
was still standing and that character-giving features such as
interior trim, moldings, and fireplace details would be
retained...
The new photographic documentation that you submitted shows
that barely one-third of the building was standing at the time
rehabilitation work commenced. As a result of the building's
extremely deteriorated condition, significant architectural
features are too deteriorated to be preserved on the remaining
portion of the building. In addition, nearly all interior finishes
are to be replaced and rebuilt using new materials. As a result
of the new information, we have determined that No. 2 of the
"Standards for Evaluating Significance Within Registered
Historic Districts" has been met (e.g., the structure does not
contribute to the significance of the district) and, therefore,
the building cannot qualify as a "certfied historic structure."
This decision supersedes the earlier decision...Since the
building does not qualify as a "certified historic structure," in
accordance with Department of Interior regulations, the
project is not eligible for certification of rehabilitation.
Because the owner felt preservation tax incentives should be made available and the
Part 2 processed, the project was appealed. On appeal, the region's denial of Part 1
was affirmed by the Chief Appeals Officer, who reiterated: "Similarly, I have
84-064
determined that it is not a certified historic structure because the integrity of the
original design, individual architectural features and spaces have been irretrievably
lost through physical deterioration and structural damage..."
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
84-064
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1. Although photographic documentation submitted 2. Limited demolition at the rear of
with the Part 1 application showed some deterioration the building had already occurred and
and loss on the primary elevation, NPS determined protective boards had been applied.
that the building exhibited sufficient "integrity" to
qualify as a certified historic structure.
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3, 4. The interior, with intact trim and mantels helped define
the character of this simple, mid-19th century structure.
84-064
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prior to rehabilitation, including
5. Crucial to the decertification of the structure exterior and interior features.
were additional photographs documenting the condition
7' Tr;..1
of the rear of the building prior to rehabilitation.
After removal of the boards, this new information
showed that barely 1/3 of the building remained. -
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7. The rear of the building and major portions of = -
the interior required extensive replacement of
historic material with new material. ;,,. ' ' `—r
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 85-065
Applicable Standards: 1. Compatible New Use (conformance)
2. Retention of Distinguishing Architectural
Character (nonconformance, conformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance, conformance)
6. Repair/Replacement of Deteriorated or
Missing Features (conformance)
9. Compatible Design for New Alterations/Additions
(nonconformance, conformance)
Subject: Alterations to Historic Auditorium Spaces
Issue: Changing the use of historic auditorium spaces, such as those in theatres, churches
and schools, poses difficult design problems. Some new uses cannot be accommodated in
such auditoriums without destroying character-defining spaces or features. Dividing the
space, or altering or destroying its features will result in a denial of certification for
noncompliance with Standards 2 and 5. However, there are cases where earlier
insensitive alteration to, or extensive deterioration of, the materials comprising
significant features and spaces has already resulted in loss of the historic character. In
such cases, further alterations to accommodate a new use will generally not result in
denial of rehabilitation certification. It is particularly important, however, that a
careful professional evaluation be made of altered spaces and deteriorated features to
assure that repair is, indeed, infeasible.
Applications: A small church built in 1875 in the Gothic style and located in a historic
district had been purchased by a neighboring church in 1923 for use as an educational
facility. During the 1960's it had been used as a theater and recreational center (see
illus. 1 and 2). A proposal was made to rehabilitate the structure into residential
condominiums (see illus. 3). In order to accomplish this conversion, the owner proposed
to subdivide the interior space and to insert three new floor levels into the sanctuary.
The regional office denied the project preliminary certification on the basis that the
"austere interior is of major importance" in defining the "ecclesiastical character of the
structure." It found that inserting seven residential units into the interior would
seriously impair that character. While the concept of inserting residences into the
church was not ruled out, the plans as submitted were deemed unsatisfactory because
they involved the "total loss of the original volume and space of the sanctuary."
Upon appeal the owner stressed the alterations made to the interior during the previous
20 years. The "austere" appearance resulted, he stated, from the gutting of the interior
to provide a basketball court. The interior did not, therefore, contribute to the overall
character of the building. He further stated that "the sense of volume and the
ecclesiastical character of the former church will be retained in the individual apartment
units. After the rehabilitation, this building will look like a church, as it does now."
85-065
In his decision upholding the denial of certification, the Chief Appeals Officer
determined that changes made to the interior over the years had not seriously diminished
the historic character of that space. The alterations, he said, "appear to amount to little
more than removal of church furnishings." He noted that the church retains such
features as the regularly spaced windows, the conspicuous roof structure and exposed
scissor trusses, and that the extent and form of the space remain. Overall, he concluded,
the interior still conveys a sense of the purpose for which it was designed--assembly.
The interior space, therefore, was determined to be integral to the historic character of
the building. Because that space would be destroyed by the insertion of apartments as
planned, certification was denied.
A second case involved an 1890's brownstone, Romanesque Revival church with an
octagon plan sanctuary, individually listed in the National Register, and located in a
residential section of a major northeastern city. A rehabilitation was proposed to
convert the building, which had been empty for fourteen years, to medical offices. The
new use necessitated insertion of three floors and office partitions into the sanctuary
(see illus. 4). The interior had ornate, clustered, engaged colonettes; acanthus leaf
entablatures; a wooden chair rail; four arched tripartite windows; an egg-and-dart ceiling
cornice; and a shallow dished ceiling. Plans called for enclosing most of the deteriorated
plaster detailing on the walls with furred-out walls, and removal of the lath and plaster
of the dished ceiling (see illus. 5).
The church had been converted to a synagogue in 1948, at which time the organ; organ
chamber; choir, choir gate, and railing; pulpit; stained glass windows; and pendant
lighting fixtures had been removed. Shortly afterward (early 1950's), an acoustical tile
ceiling and recessed lighting were installed. During fourteen years of disuse, the
building's attic and tower had become infested with pigeons, little maintenance had been
done, the building was without heat, and had been vandalized.
The NPS regional office denied the proposal preliminary certification, citing Standards 1,
2, 5, 6, and 9. The decision was predicated on an evaluation of the sanctuary space and
its elaborate ornamentation as essential to the historic character of the building. The
region determined that, "although parts of the historic fabric were water-damaged and
although alterations had occurred, the sanctuary had not lost its ability to convey
historical associations and the damaged features were repairable." The denial letter
stated that the installation of new floors and partitions that "leave no area for
perception of even part of the original, grand, open plan" violates Standards 1, 2, and 9.
The removal of the ceiling, enclosure of decorative detailing, and replacement of (1948)
windows violates Standards 2, 5, and 6.
In appealing the regional denial, the owners stated that the dished ceiling plaster and lath
(as well as the applied acoustical tile) would have to be removed, as they were soaked
with water from the numerous roof leaks, and had a thick layer (as much as one foot) of
pigeon excrement above. Further, due to water penetration and freeze-thaw cycles, the
decorative plaster on the sanctuary walls was severely damaged and so unstable as to be
unable to withstand even the slightest impact.
At the appeal meeting, close-up photographs of deteriorated plaster details were shown
(see illus. 6), and the condition of the plasterwork was fully discussed. The Appeals
Officer overturned the regional office denial and determined that the project was
consistent with the existing historic character of the church. In certifying the project,
he said:
85-065
The information and photographs (as well as the physical evidence) you provided
clarified for me the condition of the building...I am convinced that the
plasterwork has deteriorated to such an extent that it cannot now be repaired,
and that the interior wall and ceiling finishes have lost their physical integrity
and their historic character.
Church sanctuaries are often character-defining features of historic churches. The
importance of these spaces, however, is not dependent on the ornateness of detailing.
The first space discussed here was plain; the second was elaborate. In neither case did
evaluation of the proposed project depend on the level of ornamentation. Minor changes
had been made to the first church interior, but the materials and the sanctuary space had
remained intact. In the second case, the sanctuary had lost its character due to extreme
deterioration. Regardless of the original level of detail, if a character-defining historic
interior remains largely intact, it must be retained in a rehabilitation. Subdivision or
.other alteration that destroys the form or features of a significant space will result in
denial of certification.
Prepared by: Michael Auer and Susan Dynes, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-065
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1 and 2. Interior of the church at the time rehabilitation planning
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85-065
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Paris Service
U.S. Department of the Interior I the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 85-066
Applicable Standards: 1. Compatible New Use (Conformance)
2. Retention of Distinguishing Architectural
Character (conformance)
9. Compatible Design for New
Alterations/Additions (conformance)
10. Reversibility of New Alterations/Additions
(conformance)
Subject: INTERIOR ALTERATIONS TO CHURCH STRUCTURES TO
ACCOMMODATE NEW FUNCTIONS
Issue: Rehabilitation of any historic building should always take into consideration the
preservation of significant interior spaces, materials and features. This is particularly
important when evaluating churches because the large, open spaces frequently are
significant character-defining features. Preservation of the exterior form and shape
of a church structure is of obvious importance, but because the exterior is essentially
a reflection of this interior space, successful rehabilitation of a church structure
ultimately depends on finding a new use that respects this character-defining
feature. Generously scaled open space is characteristic of even a simple country
church and like other types of auditorium spaces, such an interior does not readily lend
itself to very many other uses. Selection of a new use that respects the character of
this space and any distinctive architectural details is a critical first step in meeting
the Secretary of the Interior's "Standards for Rehabilitation." Once a new use is
found, its functional requirements must be adapted to fit into the existing space
without damaging or adversely affecting its historic character.
Application: A small turn-of-the-century board and batten Gothic Revival church
located on a rural wooded site had stood vacant and unused for nearly thirty years (see
illus. 1-2). Built on the brick foundation of an earlier church constructed in the 1870's,
the church has a nave 5 bays in length covered by a steeply pitched gable roof. The
gabled entrance porch on the south side of the nave is distinguished by stickwork
detailing outlining the gable. Lancet windows light the nave, and the 2-bay long apse
features a tripartite stained glass window opposite a pair of stained glass windows
with a stained glass roundel above on the west end of the church. The vestry room, a
small gabled section (matching the entrance porch) projects off the north side of the
apse. A square bell tower with a shingled spire dominates the north side of the nave
opposite the entrance porch. The simple interior is highlighted by exposed oak roof
beams, arched trusses, and matchboard ceiling and wainscotting (see ills. 3-4).
Individually listed on the National Register, this building had essentially retained most
of its original fabric, as well as its form and pristine country setting, all of which
contributed to its historic character. The church did not have plumbing, electricity or
a modern heating system when the owner purchased it with the intention of converting
it into an artist's studio and residence.
85-066
The rehabilitation (already underway when the Part 2 Historic Preservation
Certification Application was submitted to the National Park Service), included the
installation of mechanical systems, insertion in the nave of 2 small pent-roofed sheds
to house a bathroom and storage, construction of a spiral staircase and a mezzanine
above the chancel to function as a sleeping loft, conversion of the vestry room into a
kitchen, and the cutting of three skylights into the north side of the roof of the nave.
When the project was reviewed by the National Park Service, the determination was
made that the cumulative effect of the rehabilitation work violated Standards 2, 9,
and 10, of the Secretary of the Interior's "Standards." Cited in the denial letter was
the installation of the large skylights into a "major roof slope," dramatically altering
the exterior appearance of the building and on the interior flooding the dark ceiling
with light, not only changing a distinctive and character-defining feature (in violation
of Standard 2), but also resulting in loss of historic roof fabric (in violation of Standard
10). The addition of a mezzanine in the chancel and a circular stair in the center of
the arch at the chancel entrance were cited as being incompatible with the character
of the building (in violation of Standards 2 and 9), as was the insertion of the bathroom
and storage sheds in the nave because their construction changed the nave space and
its visual relationship with the chancel.
The owner appealed the denial, arguing that the skylights were not highly visible on
the exterior to passers-by, as that elevation of the church faces onto an abandoned
cemetery, not a public-right-of-way. Furthermore, their installation did not result in
extensive loss of historic fabric because materials removed were used to patch
damaged areas of the roof. The owner also stated that the mezzanine and stairway
inserted in the chancel and the bathroom and storage sheds in the nave were
sensitively designed and compatible with the historic character of the church (see
illus. 5-6).
After careful review of the project and newly submitted photographic documentation
of the now completed work, the Chief Appeals Officer reversed the denial, and
certified the rehabilitation. The Chief Appeals Officer, explaining his decision in a
letter to the owner, agreed with the owner that the alterations to the interior were
not inconsistent with the historic character of the historic resource.
The skylights were introduced directly behind the bell tower in the north
slope of the roof which faces away from the principal approach to the
building; they are not obtrusive from the exterior, nor are they so numerous
as to adversely affect the character of the interior. The mezzanine,
circular stair and sheds were introduced to the interior with minimal
damage to the historic fabric. While the chancel arch was partially
enclosed in inserting the mezzanine, the windows in the east wall remain
visible through the glass panels and open circular stair. The pendant sheds
constructed in the nave similarly respect the axial lines and tunnel-like view
of the church interior from the west end towards the east. In fact the slope
of the shed roofs focuses the lines of sight toward the chancel and the
windows beyond (see illus. 6). The changes made to the interior of this
building are consistent with the historic character of this historic structure,
and I find them in conformance with the Secretary of the Interior's
"Standards for Rehabilitation."
85-066
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6. View of nave looking east. Note the
2 new sheds in front of and on either
side of spiral stairs in center of
sanctuary arch leading to mezzanine.
85-066
Finally, the Chief Appeals Officer concluded that his decision to overturn the denial
was also,
...based in large part on the sensitivity to the setting of this
structure...evident in the decisions you made regarding the use and
treatment of this building. The property surrounding it retains its rural
character and this setting contributes greatly to its historic character as a
country church. Your rehabilitation preserves the setting and appearance of
the church exterior. (see illus. 7)
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-066 •
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 85-067
Applicable Standards: 6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (conformance)
9. Compatible Contemporary Design for New
Alterations/Additions (conformance)
Subject: OPTIONS FOR REPLACING MISSING HISTORIC FEATURES
Issue: When a certified historic structure which otherwise possesses integrity is missing
a significant feature of the primary elevation, a particularly important decision has to be
made as to how to treat this portion of the building's history that has been lost.
If physical evidence and/or pictorial documentation is available and restoration of a
missing feature of the facade is desirable, the most traditional and often preferred
approach is to accurately recover it in both form and detailing so that the entire facade
appears to be "historic." Although the missing feature is actually new material, the
historic form is re-established.
If the restoration option is chosen, the replacement feature needs to be evaluated on its
accuracy of form and detailing, whether the replacement feature is made of matching
historic material (wood, masonry, or architectural metal) or a compatible substitute
material. In this regard, it should be noted that it is not acceptable to replace a missing
historic feature with a feature that conveys a false or confusing sense of history--that
glamorizes the missing historic feature; or otherwise gives the building a "historic"
appearance that never existed.
A second acceptable, but potentially difficult, approach is to replace a missing feature
with a compatible new feature. This option can be quite successful within a
rehabilitation project because, as opposed to recovering the historic configuration with
new materials, it honestly acknowledges loss of the historic feature, then gives the
replacement feature—such as a compatible, contemporary storefront--a legitimacy of its
own within the rehabilitation.
If a compatible contemporary approach to replacement is chosen, a very different
process needs to be used to evaluate the project for conformance with the Standards.
This process should begin with an assessment of the remaining historic features of the
facade. Any new work then has the dual goal of preserving and retaining those
significant aspects that have survived; and of suggesting that an important element of
the facade was missing but has now been replaced. Such a replacement feature should
approximate the form of the missing historic feature, clearly reading as new through
avoidance of historicized detailing. Modern materials may assist in conveying a
contemporary appearance, but their use is not required.
85-067
It should be recognized that once a significant feature is lost through deterioration,
alteration, or vandalism, even a thoroughly documented and carefully crafted
replacement feature is no more than an interpretive facsimile. Therefore, whether or
not physical evidence and pictorial documentation exist that could be used to restore the
missing feature such as a porch or cornice or storefront, a third option—although not
widely accepted in a historic preservation context--is to simply acknowledge the loss as
part of the evolution of the historic building.
In summary, the three options for replacing a missing feature are as follows:
1. Use pictorial documentation and/or physical evidence to re-create the historic
feature.
2. Acknowledge loss of the missing feature, then re-evaluate the features of the
existing facade to design a compatible new replacement feature that does not alter
or damage the remaining character-defining portions that convey historic
significance.
3. Accept the loss; do not replace the missing historic feature.
Applications: In the first case, a significant storefront of a "contributing" nineteenth-
century limestone building had been extensively altered; in addition, a highly decorative
and equally significant cornice was missing (see illus. 1). In the rehabilitation project,
the owners elected Option 1, above, to restore both altered and missing portions of the
building using physical evidence and pictorial documentation (see illus. 2). Overall work
included cleaning and repair of the limestone; repair of window sash and frames;
replacement of the missing cornice using fiberglass elements and, following removal of
the later, altered storefront features, an accurate duplication of the historic design was
constructed (see illus. 3). The project has received preliminary certification for the
investment tax credit.
In the second case, a former theatre building located in a midwest historic district was
determined to be a contributing element, in spite of the fact that it had been extensively
altered in the 1960s for use as offices. The original glazed wooden double doors, (see
illus. 4), had been removed and the openings filled in with glass block as part of the 1960s
renovation (see illus. 5). Also, in order to level the sloped theatre entrance floor,
concrete had been poured in the front 15 feet of the building to a thickness of 22 inches
at the facade.
The recent rehabilitation project for which certification was requested included
substantial interior office renovation; removal of small areas of the later paint to
determine the original brick colors and painting over the gray paint to approximate them;
replacement of the deteriorated second-floor casement windows with matching sash; and
replacement of the 1960's glass block in the first floor openings with large steel-framed
windows and transoms (see illus. 6). The owner felt that the new windows were
compatible with the remaining character-defining features of the historic facade, as
outlined in Option 2.
After review, the regional office denied the project certification based on an assessment
that the new first floor windows violated Standards 6 and 9. The denial letter stated:
Although there is no question that the block infill...was not significant, the
rehabilitation of the building should have either left the existing conditions
85-067
in place, been based on a significant documented period of the building, or
reflected a predictable treatment to the age, style, use and detail of the
building. The windows installed in place of later inappropriate glass block
infill followed none of these approaches.
Because the owner felt that the new design was compatible, in accordance with Standard
9, and that the installation of doors was not possible because of the poured concrete and
the use of the building, the denial was appealed.
After carefully evaluating the facts, the Chief Appeals Officer reversed the regional
decision, finding that the overall rehabilitation was consistent with the historic character
of the former theatre building. An assessment of the building's facade, without the
distinctive wooden double doors, revealed that the historic character of the facade now
consisted of the prominent projecting central pavilion, together with the pattern of
narrow vertical openings on the second floor, the freestanding piers, and the patterned
brick. One option was to accurately restore the form and detailing of the missing
doors. But an equally acceptable option was to acknowledge their loss and select a
compatible contemporary solution. Since the doors were now gone, retention of the
significant openings in the rehabilitation was a key preservation objective. Whether
these openings were used as doors or as fixed windows was not an issue in the appeal.
However, if the existing openings had been altered, changing the historic proportions, or
the piers or patterned brickwork changed, the historic character would clearly have been
diminished. This project, however, retained and preserved the remaining character-
defining features of the facade.
In approving the project, the Chief Appeals Officer held that the owner had met the
requirements of Option 2, to design a replacement feature that did not alter or damage
the existing masonry openings, or did not have a negative visual impact on the facade. In
fact, the new work successfully borrowed elements from the documented historic doors
in the compatible contemporary approach, as stated in a final letter reversing the
region's denial:
The restrained design of the new windows repeats proportions from the
original doors, which are known from a historic photograph. The stone
panels recall the major horizontal division established by the large kick-
plates on the doors, the vertical mullions indicate the original division
of each bay into two doors; and the new transom approximates the
proportion of the original transom. Replication of the original doors,
based on the historic photograph you have, would have been an
acceptable preservation treatment as well...
Prepared by: Kay D. Weeks and Susan Dynes, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
85-067
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1. At the outset of rehabilitation, an 1866 limestone '�' `1 "'S -ii- t! ri-J'''
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building was missing its ornamental cornice; and the -- `�
ground level storefront had been extensively ----�---64)
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,, 3. In addition to restoration of the
T „I,., storefront using matching materials, this
sr- ._ r ,�=;, _ photograph of finished work shows an
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2. Based on the availability of this and other
photographic documentation, the owners were able
to accurately restore both the cornice and the
storefront to their historic configuration.
85-067
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4. Historic photograph of the theatre's facade as it appeared in 1913. Note the glazed wooden
double doors, repetitive features that, together with the distinctive rectangular openings
themselves and the patterned brickwork, define the architectural character of the building.
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IITheatre building as it appeared at the commencement of rehabilitation. The wooden doors had
been removed in an earlier "renovation" and the openings filled-in with glass block. In addition,
the masonry was painted a uniform gray. The stone sills cover a 22-inch-thick concrete floor
inside.
6. Rehabilitated facade. After removing the nonsignificant glass block inf ill, the owners elected
not to restore the wooden double doors, but instead, to install new, simply detailed steel windows
that respect the regularized openings. The brick has been painted to approximate the original
colors so that the patterning is again evident.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department
D.C.
of the Interior the Secretary of the Interior's
Wash [Standards for Rehabilitation
Number: 85-068
Applicable Standard: 2. Retention of Distinguishing Character of
Building and Environment (nonconformance)
Subject: REMOVAL OR ALTERATION OF HISTORIC SITE FEATURES
Issue: Standard 2 requires that the original qualities or character of a building and its
environment shall not be destroyed. The landscape and landscape features around a
building are often important aspects of its character or that of the historic district in
which it is located. It is incumbent upon an owner to ascertain the historic
significance of all elements of an historic building and its site before making decisions
about destroying or altering historic material.
Even when development pressures within a neighborhood are intense, site features that
help define a building's historic character must be retained as part of a certified
rehabilitation. Those elements might include gardens, walls, fountains, pools, paths,
site lighting, benches, or grading.
Application: An early twentieth-century Mediterranean villa style house, individually
listed in the National Register, had a formal garden, apparently conceived as an
integral part of the total design (see illus. 1). The house had been vacant for over ten
years and although the garden's architectural features were deteriorated and the
planted areas were severely overgrown, much of the historic fabric remained. There
were terraces at the front and rear of the building. The rear terrace had a simply-
detailed pergola and steps down to a small walled garden with a fountain and an
ornamental wall topped by an iron fence (see illus. 2). Symmetrical steps led from
there to a long, narrow lawn (overgrown at the commencement of rehabilitation), at
the base of which was a fountain against a masonry wall.
In a recent rehabilitation that involved reuse of the house for rental apartments and
development of the site with new low-rise apartment structures, the landscape
features, both plant materials and architectural elements, were destroyed. In its
denial of the project, the regional office, while commending the owner on his proposal
for the rehabilitation of the house, stated:
The walled garden, albeit in a neglected condition, was one of only a
handful of formally designed gardens in the city that survive to the
present day. The neighborhood was, in the last decade of the 19th
century and the first decades of the 20th, a coherent and contiguous
collection of medium to large scale urban mansions on small lots. Typical
to these was a small, formally designed, often walled, garden either to
the rear or to the side of the house. Today, few have survived. The
imperative to save this significant feature was all the more important
given this context.
85-068
The owner appealed, citing the following four points:
1) The deteriorated condition of the garden structures and the overgrown site.
2) The fact that the nomination to the National Register for the house did not
mention the garden; therefore, it cannot be considered significant.
3) The garden to the rear of the house was never visible from the public way, nor
would it be after project completion.
4) Certain elements of the garden — the basic configuration of a portion of the
small walled garden, the urns, the balusters and some iron work will be reused.
The owner also brought a photograph of the rear of the house after the garden area had
been cleared as part of the rehabilitation effort, but before the new construction had
begun. It was evident that nothing remained of the rear garden below the terrace; and
that, in fact, most of the terrace had been demolished in preparation for construction of
the new apartment structures (see illus. 3).
The Chief Appeals Officer upheld the region's denial of the project, stating:
Although the garden is not described in the documentation that was
submitted to justify inclusion of the house in the National Register, as
you pointed out during the appeal meeting, it was nonetheless a
constituent element of the whole property that was nominated and
accepted. The house and garden together constituted the complete
resource.
Furthermore, it is evident that the garden was conceived as an integral
part of the total design for the house and was constructed at the same
time as an appropriate setting to complement and enhance the imposing,
romantically eclectic building. Although some of the features were
deteriorated and the site was overgrown, the integrity of the original
garden design had survived intact.
The rehabilitation project, already well underway, will destroy all sense
of the original garden design. No longer will the long vista exist from
the terrace outside the house to the lower end of the site. Nor will one
be able to step down through a small, enclosed garden, past a simply-
detailed pergola, to a long, open lawn. The scale and design of retaining
walls and balustrades, some topped with iron fences, will be lost.
Prepared by: Susan Dynes, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-068
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2. View of the rear of the house before rehabilitation began. There is a rear terrace
with a pergola and a small walled garden with ornamental walls and an iron fence.
85-068
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3. Rear of the house after garden was cleared but
before construction began.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. 20240 [Standards for Rehabilitation
Number: 85-069
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance; nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (conformance;
nonconformance)
Subject: FACTORS TO WEIGH IN EVALUATING DAMAGED/DETERIORATED
BUILDINGS
Issue: If a historic building is certified as "contributing to the significance of the historic
district;' this means that its physical characteristics are still able to convey historic,
architectural, or cultural significance prior to rehabilitation and in spite of deterioration,
damage, or loss as demonstrated by existing condition photographs. Part 1 certification
of significance does not imply that historic building materials will be fully intact at the
outset of rehabilitation; in fact, Part 2 work may involve repair or even total
replacement of some particularly vulnerable historic material such as roofing, exterior
wood cladding, wood window frames and sash, or interior plaster. On the other hand, if
historic material that could have been repaired is unnecessarily replaced, Standards 2 and
6 will not be met.
An important factor to consider in evaluating the Part 2 work is the significance and
integrity of the interior. The preservation of a significant interior that may include
historic materials, features, finishes, spaces, or structural framing system may, in
limited instances, serve to offset the documented need for extensive replacement of
exterior material. In these select cases, the building can still make a positive
contribution to the historic significance of the district and be certified for preservation
tax incentives.
Application: The first case is a two-story frame house with lap siding built ca. 1865-
1870. Photographs of the exterior prior to rehabilitation revealed a combination of
damage, deterioration, and previous alterations (see illus. 1). Specifically, lap siding had
been inappropriately covered with stucco. A later front porch, nonsignificant front and
rear additions, and an exterior metal staircase leading to the second floor had all been
removed. Finally, the building's interior had lost the majority of its historic features due
to earlier insensitive renovations. In spite of exterior and interior losses and change, the
building had been certified as meeting Part 1 integrity requirements because the
essential form and detailing was sufficiently intact to convey historic significance within
the district.
When the Part 2 application was submitted, rehabilitation work had already been
completed. Before and after photographs of the exterior were limited to front, side, and
rear elevations, with no detailed documentation evidence of deteriorated materials. The
application stated that after removal of the nonhistoric stucco, the historic clapboarding
was found to be deteriorated beyond repair due to moisture and termites. In
consequence, all clapboarding was removed as well as the sheathing underneath.
85-069
At the same time, other historic wood features were removed and replaced, including
roofing, window sash, sills, lintels, shutters, and wood trim (see illus. 2,3). Again,
justification for replacement was based on extreme deterioration. When the State office
reviewed the project, it recommended denial primarily based on undocumented
replacement of exterior wood. Also, some of the replacement features were felt to be
inappropriate, such as the heavy roof shakes. The region concurred with the State
evaluation and the project was subsequently denied for nonconformance with Standards 2
and 6. The denial letter from the Regional Director strongly emphasized the unnecessary
introduction of new material:
...replacing all weatherboards, all trim, shutters, all windows, all
roofing materials, and adding new framing pieces for doors and
windows, new brick stoops, new sills and thresholds, and new
hardware have the cumulative effect of making this building appear
to be a new house with some Colonial-style details...
Because the owner felt that replacement of extensively deteriorated exterior wood
cladding was justified, affadavits were submitted as the basis for a Part 2 appeal.
These consisted of individual, signed statements from the project architect and a
licensed structural engineer attesting to the severely deteriorated condition of the
property prior to rehabilitation. No new photographs documenting deterioration were
included. After careful review of the new information, the Chief Appeals Officer
affirmed the Region's denial:
...the affadavits...contain insufficient evidence to support your
contention that the extent of the deterioration caused by moisture
trapped behind the stucco and its subsequent removal was so
widespread as to require complete replacement of the siding, window
sash and frames, and the exterior wood trim...
...I also find that the written record and the documentation clearly
demonstrate that (the building) was a certified historic structure
prior to rehabilitation. However, in consequence of your
rehabilitation, everything now seen on the exterior of the building is
new. Because of the inordinate amount of replacement material now
visible...the structure has fallen below the acceptable level of
integrity of materials and workmanship that were required for it to
be designated a certified historic structure for purposes of the
Federal tax incentives. Therefore...it is my determination that (the
building) is no longer a certified historic structure...and that this
decertification is not considered retroactive.
In a second case, another "contributing" wood frame building, built ca. 1769, was
rehabilitated by the present owner as a single family rental home. The building had
been used historically for a variety of purposes, including a warehouse, residence,
store, and post office. In the Part 2 application, the owner provided both general
elevation photographs as well as detailed photographs of existing conditions, and
ongoing and completed work (see illus. 4 , 5). Both exterior and interior work was
photographically documented and submitted with a narrative explaining what was
original, what was added later, what could reasonably be preserved, and what needed
to be replaced. Because the owner's architect believed that exterior wood features
were not repairable, extensive replacement of exterior work was already underway as
85-069
part of the rehabilitation. After review of the application, the State recommended
approval; the Region, however, disagreed.
Reviewing the same photographs of the exterior and interior, the Region felt that the
building--although having had a long history of material replacement and alteration—
still possessed a number of early features. The significant wood features cited were
"rafters, joists, and other structural members, some sash, window and door frames,
doors, and much early wall sheathing and clapboarding." In denying the project for
nonconformance with Standards 2, 5, and 6, the Region stated:
While in some instances replacement of materials may have been
warranted due to the degree of deterioration, such wholesale
replacement appears unjustifiable on the basis of submitted
documentation and constitutes an irretrievable loss of original
historic fabric...Photographs submitted indicated that many original
features could have been spliced, patched, treated with consolidants,
or in other ways retained, thus preserving original and distinguishing
features. As the building presently stands, there is almost no historic
material in place.
The owner felt that his rehabilitation met the Standards and the denial was
subsequently appealed. On appeal, the Chief Appeals Officer agreed that there had
indeed been extensive loss of exterior wood features in the rehabilitation, but
disagreed as to their relative historical significance, particularly when weighed
against unusual existing structural components and interior materials and features
dating from the early 19th century. This included original ceiling rafters, cupboards,
paneling, and fireplaces. Of importance in the appeal were photographs documenting
the fact that the highly significant interior was preserved in the rehabilitation (see
illus. 6, 7). Most important, although replacement of historic exterior wood was
extensive, the clapboarding was found to be machine-sawn from the early 20th century
and therefore not as significant as the Region had believed.
I agree with the Regional Director's assessment of the historic and
architectural significance prior to rehabilitation. Despite its deteriorated
and altered condition, its character as an 18th century structure was
evident in its location and setting on the Meeting House Green, in its
form, and in such particulars as its post-and-beam construction...
Careful examination of the photographs of the completed work submitted
for this appeal reveals that considerably more of the historic building
remains than was thought by the regional office. Virtually all of the 18th
century framing that survived the earlier fire has been preserved intact;
this framing gives the building its form and is an important component of
its architectural significance. Inside the building are exposed posts, joists
85-069
and summer beams, and early 19th century mantels, panelling and
cupboards on the chimney walls of four rooms, door and window frames,
and several doors that are all original elements or later additions that
have acquired significance. The further documentation of the completed
work demonstrates high retention of interior features.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-069
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6. An early pegged-braced structural system, fireplace with bee-hive oven, and cupboards are shown.
If the extant, significant interior had not been factored into the evaluation to offset extensive loss of
exterior materials, overall preservation requirements for Part 2 would not have been satisfied.
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7. The same room shown above after completion of the work. On appeal, it was concluded that the
building's highly significant interior, including materials, features, spaces, and an early structural
system had been identified prior to rehabilitation, then carefully retained and preserved.
85-069
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"' ; =eye aa ' . - 1. Front and side elevations of a ca. 1865-
• �•� i 1870 wood frame building prior to
- , �- rehabilitation. Stucco had been applied over
-- -• -c"f 1- • ^ '"" - -- the exterior wood at a later date and had
-_�--:••;= `- ''=-�• s r,4. �� - caused rotting and termite infestation of
r-- " ' :" historic wood. The building was certified as
- meeting Part 1 integrity requirements in its
~� deteriorated and damaged condition.
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2, 3. The same building shown after rehabilitation is essentially new construction. Rather than
targeted replacement of deteriorated materials, the owner replaced all of the siding, roofing, windows,
sills, shutters, and trim. Some of the replacement features, such as the use of thick, cedar shakes on
the roof and side porch were considered inappropriate. The owner was denied Part 2 certification on
appeal. As a result of material loss during rehabilitation and the earlier loss of interior features and
spaces, the Part 1 certification was also withdrawn because the building could no longer meet integrity
requirements.
85-069 �' : r: •
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4. A ca. 1769 building was certified in the Part 1 application in its existing condition, which involved
extensively deteriorated exterior wood clapboarding, sheathing and window sash. On the interior, some
original framing members were intact, while others were repaired or replaced.
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5. Completed exterior work shows the extent of replacement of deteriorated exterior wood
materials and features. All siding and sheathing was replaced with new wood. Window sash and
frames are also new. The applicant documented areas that needed to be replaced because of
extensive deterioration as well as those portions, such as the cornice molding, that could be
retained and preserved.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. 20240 [Standards for Rehabilitation
Number: 85-070
Applicable Standards: Standards for Evaluating Significance With
Registered Historic Districts (36 CFR 67.5 (2)(e)
Subject: REMOVING FALSE FRONTS OR NONHISTORIC SURFACE COVERINGS
PRIOR TO REHABILITATION
Issue: As part of the 1950's drive to clean-up, or "modernize" shopping and residential
areas, metal false fronts were often attached, or nonhistoric surface coverings
directly applied to historic building facades. When a Part 1 evaluation of significance
is requested prior to rehabilitation and a false front or nonhistoric surface covering is
in place, the need for removal will differ depending upon the type and extent of the
obscuring covering. Two basic types of covering exist:
(1) A false front or screen covers up a historic building's facade, concealing the form,
materials, design, workmanship, and historic relationship to other buildings in the
district. In past administrative practice, removing a false front was considered to be
part of the rehabilitation work itself and thus assessed in the Part 2 evaluation for
conformance with the Secretary of the Interior's "Standards for Rehabilitation,"
particularly Standards 2 and 6. Now, in accordance with the revised regulations (36
CFR 67 - March 12, 1984) at least a portion of the false front or screen must be
removed prior to rehabilitation in order to evaluate the integrity of the historic
building. After the historic integrity is established through evaluation, the false front
or screen will generally need to be removed totally in order to receive final Part 1
certification.
(2) On the other hand, when a nonhistoric surface covering (such as aluminum or vinyl
siding, permastone, or asbestos siding) has been directly applied over historic wall
surfaces, removal of that material may not always be necessary for Part 1
evaluation. A nonhistoric surface material, unlike a false front, usually does not
totally obscure a building's significant form, features, and detailing. When a building's
historical significance is conveyed through other surviving characteristics of the
exterior of the building (such as its roof, cornice, unusual windows, chimneys,
ornamentation, etc.), then a Part 1 certification of significance may be given with the
nonhistoric surface covering left in place. The covering may simply be retained in
rehabilitation; alternatively, it may be removed by the owner.
In summary, for both types of covering, Part 1 certification will be issued only when
enough of the historic building is visible to classify the building as contributing to the
historic district even if the proposed rehabilitation were not completed for some
reason.
Application: Part 1 certification was requested for a two-story masonry building in a
historic district. A photograph of the 1908 department store (see illus. 1) was
submitted together with photographs of the existing appearance. In its current
condition, however, it did not convey historic, architectural, or cultural
85-070
significance because an aluminum false front had been attached in the 1950s, hiding
the facade as well as wrapping around both sides of the building. Enamelized metal
squares had also been affixed to the side elevations. The rear of the building was both
visible and apparently intact, but had no particularly distinguishing features (see illus.
2,3,4)
Even though the storefront had been altered in an earlier renovation prior to
attachment of the false front, there was some evidence that the second story of the
department store remained relatively intact underneath. Because a 16" gap had been
left between the metal screen and the store's facade it was possible to look out the
original window and see some of the masonry detailing behind the screen. This
suggested that the building might retain enough integrity to meet overall requirements
for Part 1 certification.
Consequently, the owner was notified by the Region that at least a portion of the false
front would need to be removed in order to evaluate the historic facade to see if it
possessed sufficient integrity for Part 1 certification. In response, the owner
informed the Region that the scope of rehabilitation would be limited to interior work,
and the building's exterior would remain "as is," in its covered condition. As a result,
the building was not issued "certified historic structure" status; however, if ownership
were to change, a new owner could reapply for Part 1 certification of significance.
In a second case, an owner submitted a Part 1 and Part 2 application with photographs
of a 2 1/2 story, hip-roofed, frame and masonry building in a tree-lined district of
similarly scaled residences. Photographs and a narrative explained that the building
had been covered with a concrete veneered covering, and that the wood window sash
and shutters had also been replaced with new aluminum "features" (see illus. 5). It was
acknowledged in the application that these changes to the building did not contribute
to its overall architectural appearance and historic integrity. Documentation also
included several photographs of the interior showing raised paneling, parquet floors,
tiled fireplaces, and intricate plaster cornice moldings and, in fact, the application
emphasized the interior's significance.
In the Part 1 evaluation, the reviewer initially expressed some concern over the
concrete veneer covering historic materials, but concluded that other surviving
exterior features such as building's form, its roof--roofing materials, dormers,
chimneys and cornice--and an elaborately detailed portico satisfactorily conveyed the
building's architectural significance in relationship to the district (see illus. 6).
Removal of the nonhistoric surface covering was thus not required for Part 1
certification to be issued. This decision would have been made even if interior
materials, features, and spaces had not been significant and intact.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U. S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
_ .. __ 85-070
1"7.4::11:4 )111 "d.' 2�_ •
^ + ' • i1 y. 1. Early 1900s photograph of
the Ochs Building shows the
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- , __ �\� prior to a series of renovations,
• I - W r 4' ' "' the last of which totall
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- T` � :, - ,,' 2, 3, 4. The department store shown as
submitted for Part 1 evaluation, with a
y --- .,._� false front obscuring the primary
■
...A.- ,,-1. $ `-`_ elevation and enamelized metal squares
_ .+R. covering the secondary elevation. A
Y ;° photograph of the rear elevation showed
AN.. j r,/.. .• ; , , 3 a portion of the building's historic
't R" "mow"``° °— material that had not been obscured.
° r This elevation, however, was not of any
u_ � •; . . `• particular architectural or historic
significance.
85-070 1.
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5. A photograph of a portion of the _ _ t
primary facade reveals a highly
decorative porch, but also shows the
nonhistoric concrete veneer, and
aluminum sash and shutters.
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6. The building is shown here on the right in relationship to another building in the district.
Although the historic wood sheathing has been obscured with formstone that is heavy and gray
in appearance, the surviving physical characteristics of the rest of the building were sufficient
to convey historic and architectural significance. This includes the roof shape and materials,
and a decorative cornice and portico. Part 1 was issued. In the rehabilitation, the concrete
veneer was simply patched and retained as part of overall work.
Technical Preservation Services interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
i
Washington, D.C. 20240
rStandards for Rehabilitation
Number: 85-071
Applicable Standards 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Design for New Additions
(nonconformance)
Subject: PROPOSED ROOFTOP ADDITION ON BUILDING WITH A DISTINCTIVE
CORNICE
Issue: Rooftop additions can meet the Secretary of the Interior's "Standards for
Rehabilitation" if they are inconspicuous within the district or neighborhood and do
not alter the historic character of the building. If a building has a distinctive profile
against the skyline, a profile created by turrets, ornamental cornices or other
character-defining roof features, it may be very difficult to design a rooftop addition
without either destroying significant material or radically altering the appearance of
the building.
Application: A nine-story commercial office structure, built in 1910-11, determined
to be eligible for individual listing in the National Register, was to be renovated for
continued use as offices and commercial space (see illus. 1 and 2). Situated on a
highly visible corner property, the building is distinguished by its U-shaped plan,
distinctive storefronts, elegant brick and terra-cotta detailing and most particularly
by an elaborate projecting terra-cotta cornice and parapet.
The owner's proposal to construct two additional stories atop the building (see illus. 3)
was denied certification by the regional office, which cited the "negative impact on
the historic character of the building" of such an addition. The design of the rooftop
addition, the denial letter further stated, "will compromise the historic character of
the building by appearing as a historic component; the building's original scale will be
altered, and the prominent cornice will be compromised, all violating Standards 2 and 9."
Upon appeal by the owner, the denial was affirmed by the Chief Appeals Officer, who
noted that "the two-story addition... would extend to the plane of the wall, thereby
drastically reducing and weakening the prominence of the cornice." The "marked
appearance of the cornice against the sky," he continued, is "virtually unique" in the
city, and is the "overriding character-defining feature of the building."
In reaching his decision, the Chief Appeals Officer noted the extensive research into
the history of the building undertaken by the owner and presented at the appeal
meeting. This information included the original structural steel drawings, which
depicted an eleven-story building rather than a nine-story structure. These drawings
indicated that the top two floors of the structure would have been constructed out to
the facade line, much in the manner of the proposed addition. No elevation drawings
were found, but surviving physical evidence, original promotional material, and
testimony taken in a lawsuit involving the original owners also supported the claim
that the building was originally designed for eleven rather than nine stories.
85-071
The Chief Appeals Officer acknowledged the evidence presented by the owner as
satisfactorily establishing "that the original builders contemplated an eleven-story
edifice rather than the nine-story building that was constructed and exists essentially
unaltered today." He noted further that "the additional two stories, had they been
built, would have been constructed above the cornice." He concluded, however, that
the information, while very interesting, had "little relevance to the matter under
consideration; what concerns us here is that which was built and embodies historic
identity.... The fact is that the building was built as it was and its historic character
for seventy-five years has been largely determined by the appearance of its cornice
unencumbered against the sky." Because the proposed addition would have diminished
that appearance, it would not have preserved the historic character of the building,
and was consequently denied certification.
Prepared by: Sharon C. Park, AIA, and Michael J. Auer, Ph.D.
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-071
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3. The proposed rooftop addition, like other designs submitted, would have
obscured the appearance of the character-defining cornice against the sky.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. 20240
[Standards for Rehabilitation
Number: 85-072
Applicable Standards: 6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
Subject: PRESERVING DISTINCTIVE SIDE AND REAR ELEVATIONS
Issue: Attaching a new exterior addition usually involves some degree of loss to an
external wall or walls. For this reason, it is generally recommended that an addition
be constructed on a secondary side or rear elevation—as opposed to a primary
elevation--where'significant materials and features are less apt to be present.
There are cases, however, where side or rear elevations are architecturally detailed;
where they display either a distinctive individual plan or a plan characteristic of
buildings in the neighborhood; where they were traditionally highly visible within the
block; or where they are of special historical significance. In these instances, the
distinctive features on a side or rear elevation also need to be retained and preserved
in rehabilitation, i.e., not damaged, destroyed, or hidden. If materials or features
judged to possess significance are damaged or destroyed in the process of
rehabilitation the intent of Standards 6 and 9 will not have been met.
Application: A late 19th c. 3-story, 3-bay brick rowhouse was determined to
contribute to the historical significance of a small-town-historic district. The building
was typical of other Victorian-era brick townhouses in the district with its Italianate
doorway, brackets, dentil work, and stone steps. Also characteristic of many buildings
in the district, there was a brick two-story kitchen wing with a small second-story
porch that featured a decorative balustrade on the rear of the building (see illus. 1,
2). The interior was both significant and intact; photographs documented features
such as a mahogany balustrade, marble fireplace, plaster ceiling trim, and original
doors and trim.
Rehabilitation of the building essentially involved work to convert the residence into a
dress shop. The owner felt that the existing interior space was inadequate for the
retail operation, and, as a result demolished the historic rear ell and two-story porch
preparatory to building a much larger addition in its place (see illus. 3).
When the Part 2 application was reviewed by the State, denial was recommended.
Several work areas were questioned, but loss of the rear addition and porch in order to
construct a new, large scale commercial wing was the primary reason for denial.
Standards 2, 9, and 10 were cited. The regional office agreed with the State's
assessment, and also cited Standard 6. The denial letter, emphasizing the loss of
fabric on a distinctive rear elevation, stated in part:
85-072
...demolition of the rear wing and second-story porch has resulted in loss of
historic fabric. In the case of the porch, there was a loss of skilled
craftsmanship as well. In the case of both the porch and wing, the historic
rowhouse configuration (designed to supply more light, air, and space than
was available from the main block alone) has been destroyed. The
replacement design has a non-residential scale and appearance. No
evidence of deteriorated conditions has been given to justify the
demolition...
In the appeal, the owner explained that in order for the residence to function as a
shop, certain changes had been necessary. The interior needed to be expanded and, to
do so, an extensively deteriorated, and essentially nonsignificant porch had been
removed. To substantiate their claim, a letter was submitted by the architect
certifying that the rear brick kitchen wing and two-story porch could not be
preserved; however, no photographs of deterioration and structural failure were
provided.
After carefully evaluating the facts of the case, the regional office's denial was
sustained by the Chief Appeals Officer. Citing loss of historic material as well as a
permanent change to the rear of the building, the decision was further explained in a
final letter to the owner:
The historic rear wing and second-story porch were demolished due to
alleged severe structural deterioration; the extent of deterioration,
however, was not substantiated in the course of the meeting. Furthermore,
the design of the new rear wing is not compatible with the building or the
district. In mass, proportion, and scale it differs drastically from what was
there before and stands as an intrusion in the texture of the neighborhood,
the character of which can be appreciated from the rear parking lots as well
as from the street. The addition of this wing also resulted in significant
change in the spatial arrangement of the first floor interiors. Accordingly,
despite some exemplary preservation of interior details, I have found that
the work does not satisfy the "Standards for Rehabilitation."
Prepared by: Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-072
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1, 2. The 3-story brick rowhouse, front and rear elevations, prior to conversion
into a dress shop. Although many rear elevations are not particularly distinctive,
this one featured a second story gallery and brick kitchen wing that were
characteristic of the rear elevations of other residences in the district.
Demolition of the wing and gallery preceded construction of a massive new
addition that interrupted the former visual unity of the neighborhood.
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3. Completed work, rear elevation. The project was denied, largely based on
demolition of the rear wing and porch and construction of a large addition that
changed both the exterior form and interior plan.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. 20240 rStandards for Rehabilitation
Number: 85-073
Applicable Standards: 2. Retention of Distinguishing
Architectural Character (conformance)
4. Removal of Later Non-Significant
Alterations/Additions (conformance)
5. Sensitive Treatment of Distinctive
Features and Craftsmanship (conformance)
6. Repair/Replacement of Deteriorated,
or Missing Architectural Features
Based on Historical Evidence (conformance)
Subject: ALTERNATIVE REHABILITATION TREATMENTS FOR LATER
NON-SIGNIFICANT ADDITIONS
Issue: The Standards generally encourage the retention of later additions to historic
buildings. Such additions often have acquired significance in their own right because
they provide evidence of the historical evolution of the building or because they are
important examples of an architectural style.
Circumstances under which a later addition may not contribute to the significance of a
historic structure include: 1) a later addition that is less than fifty years old; 2) a later
addition that is not a fine example of an architectural style, or does not exhibit
significant character or fine workmanship; 3) a later addition that does not contribute
measurably to the National Register-determined period of significance of the building
or district; 4) a later addition that is so badly deteriorated that its replacement would
constitute a level of "reconstruction" not required in a rehabilitation; and 5) a later
addition that obscures earlier significant features.
Additions to historic structures that meet any of these conditions may be treated in a
variety of ways. Rehabilitation options include retention of the later addition, removal
of the addition to reveal restorable features underneath, replacement with new features
of a compatible new design, or, if adequate historical documentation exists,
replacement with an accurate duplication of original features.
Assessing the significance of later additions requires careful professional review, and
must always be done on a case-by-case basis. Removal of significant later features can
result in denial of certification of a project.
Application No. 1: A six-story structure, individually listed on the National Register as
well as in a National Register historic district, and erected in 1906 as a private
residence and hotel, was rehabilitated for use as an office building (see illus. 1). The
facade, exhibiting stylistic elements derived from the French Renaissance, was faced
with a high quality brick veneer trimmed with brownstone, and the building was topped
with a graceful "mansard" roof. Over the years, however, the building had undergone
some stylistic changes and additions, the most notable being the construction of an Art
Moderne carrara glass storefront on the first floor to accommodate a bar, as well as the
85-073
addition of a copper marquee (c. 1928 according to the application) over the hotel
entrance, and extensive remodeling of the interior. The rehabilitation proposal called
for the removal of the Art Moderne storefront, the bar interior, and the marquee, and
reconstruction in their place of the original 1906 first-floor facade (see illus. 2). The
regional office of the National Park Service denied certification because the
cumulative effect of the proposed work would result in a rehabilitation that did not
conform to Standards 2, 4, 5 and 6 of the Secretary of the Interior's "Standards for
Rehabilitation." This decision was based largely on the proposed removal of the bar
storefront and its interior which the region judged to date from the 1930's, and removal
of the copper marquee (although other issues including interior fabric removal and its
reconfiguration were cited in the denial letter). The regional office had assessed all of
these additions to be character-defining features of the structure, and as such should be
retained in the rehabilitation.
Upon appeal, the denial of the regional office was overturned, in part because of the
availability of new information at the appeal meeting, including photographs that
clearly showed earlier unsympathetic remodelings had destroyed all of the bar interior,
documentary evidence that the Art Moderne storefront had been constructed in the
1940's, and assurance that the rehabilitation would retain all historic fabric still extant
on the interior. The project, now already in progress, was given preliminary
certification, and in a letter explaining his decision, the Chief Appeals Officer
emphasized that he strongly concurred with the policy espoused by Standard 4 that
encourages retention of those later additions that have acquired significance over
time. But in this case, the owner had 2 valid options—either to retain the existing
storefront or because of the existence of detailed drawings of the original facade, to
restore that facade:
...each instance has to be judged on its own merits, and I find that this
Art Moderne storefront is not of exceptional architectural or historical
significance; it is less than 50 years old, is not mentioned in the National
Register documentation as possessing exceptional importance...and is not
architect-designed. Furthermore, because of the existence of the original
drawings, restoration of the 1906 facade was also an acceptable approach
in accordance with Standard 6. The unusually accurate substantiation of
the original design was a major consideration on this point.
The fact that nothing remained of the bar interior provided further
argument favoring restoration of the original facade. I feel that the
copper marquee, like the storefront, is also not of exceptional
significance and may be retained or removed at your discretion.
Application No. 2: Another project involved rehabilitation of two residential
properties for apartment use. Originally constructed in the early part of the
nineteenth century as multi-family housing for mill workers, these buildings had been
certified as contributing to the significance of the historic district in which they
were located. The houses were situated side-by-side, and nearly identical in design
85-073
and floor plan. They were of frame construction, two and a half stories, and six bays
wide with a gabled roof (see illus. 3-4). Each house had a later addition of a wooden
porch that stretched across the length of its facade. Rehabilitation work on the
properties was extensive as the houses had fallen into disrepair through lack of
maintenance.
Although the State Historic Preservation Office had recommended approval of the
rehabilitation project, the regional office of the National Park Service denied
certification on the basis that the completed project violated Standards 2, 4, 5 and
6. As in the example discussed above, the region felt this rehabilitation did not
conform to the Standards due in part to removal of the later additions — in this case,
the porches (see illus. 5-6). The region's denial letter stated "these front porches
were significant to each house as a later addition (estimated to be from 1900 or
earlier) and were significant collectively as a phenomenon within the district."
The owners appealed the regional decision, because they felt the rehabilitation met
the Standards. At the appeal meeting the owners defended removal of the porches
on the basis that the porches were poorly constructed of inappropriate materials
which at the time of the rehabilitation were found to be too deteriorated to repair,
and not of sufficient quality or workmanship to retain. Most importantly, however,
research had revealed the fact that the porches in question were first depicted on
the Sanborn insurance map of 1926, but did not yet appear on the map of 1914. Thus,
the maps clearly showed that the porches had been built in the twentieth century,
outside the period of significance of the district.
After reviewing all the facts of the case, the Chief Appeals Officer agreed with the
owners that the rehabilitation met the Secretary of the Interior's "Standards," and
overturned the denial issued by the regional office. In doing so, he stated that the
primary significance of these properties lay in their exterior form and details, and
that these character-defining features had been preserved and restored in the
rehabilitation. Had the porches been in a better state of repair, their retention
would also have been an option. He further explained his decision to the owner,
saying:
In its denial letter the regional office stated that removal of the front
porches was in violation of the Secretary of the Interior's Standards,
because these porches had not only acquired significance as later
additions but also were significant collectively as a phenomenon within
the historic district. However, from information you presented at the
appeal meeting, we can now date the porches between 1914 and 1926, a
period outside the significance of the historic district as a nineteenth-
century mill community.
Thus, for both of these projects featuring later additions that did not contribute to
the significance of the historic structure or the district, there were the four
alternative rehabilitation treatments outlined in the introduction from which to
choose. One option, in both cases, might have been to retain the later addition. But
85-073
another option in accordance with the Standards, and the one selected for both
projects, was restoration. In the first example, restoration of the 1906 facade was
made possible because of the discovery of the existence of the original architect's
drawings. In the second project, restoration was made possible because discovery of
two Sanborn maps proved that the porches had not been constructed until the
twentieth century, and therefore did not contribute to the nineteenth century period
of significance of the historic district in which the houses were located, and as such,
could be removed.
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-073
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85-073
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 85-074
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (non-conformance).
9. Compatible Design for New Additions
(non-conformance).
Subject: ROOFTOP ADDITIONS
Issue: Rooftop additions proposed for larger urban buildings raise certain preservation
issues. First, there is the concern over material loss -- to what extent significant
historic features such as cornices will be altered and how much of the roof system and
the building's structural framework will be altered, damaged, or destroyed. A second
preservation issue is the visual impact of the addition on the historic character of the
building. The size, scale, material, color and detailing of the proposed addition may
individually or collectively impact other distinctive historic qualities of the building.
Finally, an addition is often designed so as to appear to be an important and integral
part of the historic design -- a treatment which can compromise the historic character
of the structure and as a result preclude the project from obtaining certification of
rehabilitation.
Application: A former City Hall was recently rehabilitated for use as private offices
(see illus. 1). The building is located in a downtown historic district that includes
many financial and institutional buildings of the early 20th century, typically 4 to 10
stories in height. Early in the history of the building, a rooftop addition had been
constructed, set off to one side. Though set back from the facade, it was clearly
visible diagonally from across the intersection as well as from down the street. The
poorer quality workmanship and material and the fact that the electrical, mechanical
and plumbing systems were independently designed led to the National Park Service
determination to approve its planned removal.
The owners proposed construction of a new one-story addition running the full depth of
the building yet set back along the side elevations from the historic roof balustrade
(see illus. 2). On the front, however, the proposed addition would create a highly
visible 3 bay penthouse, set along the same plane as the front of the building and
detailed to match. When the plans were reviewed by the National Park Service a
determination was made that the addition precluded the project from meeting
Standards 2 and 9.
Problems with the proposed addition included its prominent location on a major facade
and the detailing, which made the addition read as an integral part of the historic
structure. The detailing emulated the original and along with its form and location
resulted in the addition becoming a strong new design element on a significant facade
-- an element which also took on an instant "historic" look. While it was restrained in
size and scale in proportion to the historic building, it altered the building's historic
character. The building had a distinct form which would be changed by the addition of
85-074
such a prominent penthouse. Furthermore, the historic cornice no longer would be the
termination of the historic building in design, now having to share that role with the
proposed addition.
In the end, the financial infeasibility of any rooftop addition precluded its
construction.
Prepared by: Charles E. Fisher, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-074
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1. This former City Hall, shown here in a 1925 photograph, has changed little over
the years on the exterior with the exception of an old rooftop addition off to the
left. The building has a prominent corner location and is highly visible not only at
the intersection of two busy thoroughfares but also from down the streets as well.
85-074
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2. The proposed penthouse addition with the three bay portion across the front was
determined not to meet the Standards for Rehabilitation. The change in the form
of the building; the conscious attempt to tie the addition to the historic building
through use of replicative detailing; and the alterations to the historic roof
balustrade, were all factors cited by the National Park Service.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service the Secretary of the Interior's
U.S. Department of the Interior
Washington, D.C.
[Standards for Rehabilitation
Number: 85-075
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance).
9. Compatible Design for New Alterations/
Additions (nonconformance).
Subject: ELEVATED PEDESTRIAN BRIDGE AS PART OF A REHABILITATION
Issue: Elevated pedestrian bridges have become popular urban features in downtown
developments. Networks of pedestrian bridges, often referred to as "skywalks" or
"pedways," may be found in numerous cities to protect pedestrians from inclement
weather and ease safe movement between buildings.
Pedestrian bridges, however, pose particular problems for historic buildings; they are
difficult to integrate into a rehabilitation without altering the character of the
historic resource. Standards 2 and 9 address the issues of retaining character-defining
features and materials as part of an overall rehabilitation. When a primary elevation
is partially obscured by a large, horizontal new element that penetrates the historic
resource or complex, it is generally the case that the historic character of that
resource is severely impacted.
In the following two examples denial of certification resulted from the proposal to
incorporate a "pedway" into the overall rehabilitation. These elevated bridges had a
negative impact on the individual buildings as well as the district in which they were
located.
Applications : A rehabilitation proposal called for the conversion of a group of eight
historic row warehouses into an interconnected mixed-use complex of shops and
offices. The buildings are located in a downtown urban area that has experienced
substantial demolition and subsequent new office construction. The warehouses
comprise the entire historic district located on two blocks and divided by a road (see
illus. 1 and 2). Across from the historic district is a modern office complex and public
plaza. The road between the two is a major traffic artery and the city has proposed a
pedestrian bridge over this road as part of a network of downtown bridges. The
developer wished to incorporate this bridge into the new complex to provide a
convenient, safe entry for office workers and shoppers. The developer determined
that the bridge would help ensure the financial success of this project.
This two-block historic district is characterized by large, solid, five-story brick
warehouses that follow a major transportation artery. In fact, one of the historic
buildings is angled at its midpoint to follow this road, thus creating a vista that is an
important aspect of this grouping of buildings. The formation of two distinct block of
buildings separated by a road is also a character-defining feature of this unique
grouping of row warehouses. The bold scale, the articulated warehouse detailing, and
the continuous panoramic vista of the two separate groupings of buildings are all
important aspects in establishing the character of this historic district.
85-075
The developer, sensitive to the exterior character of the warehouse buildings,
proposed to leave the existing exteriors unaltered except for the replacement of lost
features such as storefronts. As such, his proposal for the elevated "pedway" would
not penetrate the original warehouses, but would enter the complex through a
proposed new infill structure located over the site of the road which divided the
district (see illus. 3). The design for the new "pedway" would be a thin steel box-
frame truss and open on the sides.
The State and the regional office, however, determined that both the pedestrian
bridge and the new inf ill construction would so alter the character of the historic
resource that the overall project should be denied. On the issue of the proposed
"pedway," the region's denial letter stated the following:
The proposed changes would impact the character of the row as a
series of structures which are significant for their cohesive
appearance.... The angle at which the buildings and the street
bend midway through the row already serves to distinguish the
row into a series of two sequential experiences. Interposing the
pedway addition would destroy the way this row of buildings is
experienced. The pedway is therefore incompatible with the
existing row which violates Standard 9 and it would destroy the
distinguishing qualities of the site and the environment in which
these buildings are located thus violating Standard 2.
The owner appealed the regional decision stating that the bridge was of lightweight
construction, that it would not intrude visually, and that the industrial character of
the bridge was in keeping with the industrial character of the buildings. The Chief
Appeals Officer, however, agreed with the State and the region that the presence of
this bridge, or any bridge, along this primary elevation would severely impair the
historic character of the buildings and the district. In his letter which sustained the
region, the Chief Appeals Officer concluded that:
The bridge would bisect the district, and even though the
structural members would not be glazed on the sides, this bridge,
or any bridge, would be a major intrusion; for it would interfere
with the distinguishing character of the cohesive groupings of
row warehouses, the significance of which qualified the district
for entry in the National Register of Historic Places.
In a second case, a 20-story office building, both individually listed in the National
Register as well as being within a registered historic district, was scheduled for
conversion into shops and 155 apartments. The design of this early 20th century
building followed the classic approach of a formal limestone base three stories high, a
block or body of brick constructions with regularized window openings for 12 floors
and finally a capping of several floors in a lighter brick under an elegant copper
dormered "mansard" roof (see illus. 4). Located on a corner across from a large open
park, the two street elevations were primary facades of equal detail and articulation.
As part of the rehabilitation, the owner wished to provide parking for his tenants. The
building had no surface parking on its own site, but the developer owned a new building
a block away where secured parking and a health club would be available for use by
the tenants. As the neighborhood was still in transition after a period of decline, the
85-075
owner felt that the only way to market his apartment building sucessfully was to
guarantee his tenants 24 hour security, not only in the building, but from the parking
garage via a pedestrian bridge. As the lower two floors of the building were to house
offices and shops, the entrance of the proposed pedestrian bridge at the third floor
provided a convenient lobby and entry point for tenants as well as serving as one of
several required fire exits from the complex. The owner had made arrangements with
the city to lease the airspace on an annual basis.
The owner's architect detailed the proposed pedestrian bridge to fit inside the arched
fanlight at the third floor in order to reduce the loss of historic materials (see illus.
5). Any sash, framing or transom panels removed would be stored in the building for
reinstallation at a later date if the pedestrian bridge were ever removed.
The State and regional offices, however, were extremely concerned that the
pedestrian bridge, located on a formal elevation of the building and only one bay away
from the front entrance would drastically alter the appearance of the historic
resource (see illus. 6). The project was denied certification and the owner appealed
the decision. The Chief Appeals Officer agreed with the denial, further stating:
The proposed pedestrian bridge is an inappropriate and
incompatible attachment to the primary facade of this
architecturally significant building To interfere with the view
of the building and adjacent structures by floating a bridge above
other historic buildings and the street and insert it into a
nomumentally organized and carefully detailed facade would
damage the architectural concept and diminish the historic
character of the resource and adjacent buildings. The new
feature would be dramatic and conspicuous, not subordinate to
the historic structure; and the traditional views of the
streetscape and the building would be distorted.
Although I appreciate the desire for functional and service
amenities for your tenants, I am still unable, in view of the
whole, to see this proposed bridge as consistent with the historic
character of this important building. Therefore, it is my
judgement that the bridge will have to be deleted if the desired
certification is to be gained.
In each of these cases, the pedestrian bridge was considered by the owners as a
critical marketing device. In both cases, however, the pedestrian bridge as a major
new design element on a primary facade. Regardless of other issues raised as part of
the denial, the "pedway" alone would have resulted in denial of certification.
Prepared by: Sharon C. Park, AIA, TPS
These bulletins are issued to explain preservation project decisions made by the U.S
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
85-075
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1. Case No.1: This view is looking south along the major street. Note the bend in the
warehouse row as the buildings follow this road. This two block row of eight buildings
is the last remaining row of industrial warehouses in the city.
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2. This view of a portion of the historic district is looking north. Note the road which
divides the district into two blocks. This is the site of the proposed new addition and
"pedway."
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3. This artist's rendering, looking south, shows the proposed "pedway" connecting a
public plaza across the street to the renovated warehouses. This new horizontal
element, visually intrudes on the historic panoramic vista of the warehouses and was a
cause for denial of certification. The glass enclosure over a historic street was a
separate cause for denial.
85-075
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listed as well as being located within a registered , , 1tr l;
historic district. The proposed "pedway" would enter . •• , •.1 j ` '; ; ,,i,..1!A. `r lar»'
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to reduce the loss of historic materials. The project, however, was denied
certification as a result of the drastic change this elevated bridge would have on the
formal facade of this significant architectural resource.
85-075
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CUMULATIVE
INDEX
Volume 1: 001-043
Volume 2: 044-075
Abrasive Cleaning
009, 039
Additions to Buildings
See Also: Greenhouses
Storefronts
Demolition of Additions
016, 018, 045
New Designs
010, 022, 026, 027, 028, 034, 037, 045, 051, 058, 072, 075
Rooftop Additions
034, 048, 051, 060, 071, 074
Administrative Issues
See: Previous Owner
Air Conditioning
014
Aluminum Siding
See: Artificial Siding
Arcades
030
Artificial Siding
005, 006, 070
Atrium
048
Balconies
See Also: Porches, Galleries
048
Brick
Mitigating damage of abrasively cleaned masonry
009
Painting previously unpainted brick
011, 029
Removing interior plaster to expose brick
013
Brownstone
See: Sandstone
Building Codes
Elevator
059
Fire safety
037
Handicapped access
032
Ceilings
See: Interior Spaces, Alterations
Chemical Cleaning
063
Cleaning, Damaging Methods
See: Abrasive Cleaning
Chemical Cleaning
Complexes
See: Demolition, Buildings within Complexes
Courtyards
See: Atrium
Demolition
See Also: Interior Spaces and Features, Alteration
Buildings within complexes
012, 041, 043
Demolition/alteration of non-original features that have achieved significance
016, 018, 027, 041, 073
Significant fabric and features
032, 039, 048, 072
Deteriorated Buildings, Features and Materials, Repair versus Replacement
029, 031, 038, 040, 042, 043, 054, 055, 056, 064, 067, 069
Doors and Entranceways
See Also: Interior Spaces and Features, Alteration
New openings
029, 047, 049, 050
Removal or replacement of entrance
004, 015, 025, 032, 045, 049, 050, 061, 067
Entrances
See: Doors and Entranceways
Environment
See: Setting
Exterior Surfaces
See: Artificial Siding
Brick
Paint, Removal of
Replacement Materials
Sandstone
Wood
Fireplaces
See: Interior Spaces and Features, Alteration
Floor Plans, Changes to
019, 020, 026, 051, 054, 065
Galleries
See Also: Porches
New construction
008
Gardens
See: Setting
Greenhouse Additions
007, 022, 045
Historically Inappropriate Alterations and Additions, Construction of
See Also: Brick, Removing interior plaster to expose brick
004, 005, 008, 018, 024, 029
Insulation, Urea-formaldehyde Foam
023
Interior Spaces and Features, Alteration
See Also: Floor Plans
017, 019, 020, 024, 047, 054, 059, 065, 066
Limestone, Replacement
055
New Construction
See: Additions to Buildings
Environmental/Setting, Alterations
Greenhouses
Historically Inappropriate Alterations
Inf ill Construction
Porches
Roof Alterations
Storefronts
Paint
See Also: Abrasive Cleaning
Mitigating damage to exterior by painting
009, 042
Painting previously unpainted surfaces
011, 029
Retention of unpainted surfaces after paint removal
036, 039
Pedestrian Bridges
075
Plan, changes to
See: Floor Plans
Plaster, Removal of
See Also: Interior Spaces and Features, Alteration
013
Porches
See Also: Galleries
Alteration/Demolition
006, 018, 033, 039, 044, 054, 072, 073
Enclosures
001, 033
Previous Owner, Project Work Undertaken by Previous Owner Which Does Not
Meet the Standards
001
Regulations, Project Work Undertaken Prior to Issuance of
018, 028
Replacement Materials
See: Artificial Siding
Brownstone
Doors
Limestone
Roofing
Sandstone, Replacement of
Windows
Wood
Roof Alterations
See Also: Additions, Rooftop
031, 038, 051
Sandblasting
See: Abrasive Cleaning
Sandstone, Replacement
040, 056
Setting
002, 068
Siding
See: Artificial Siding
Wood, Replacing clapboarding with shingles
Site
See: Setting
Skywalks
See: Pedestrian Bridges
Stairtower
037
Standards for Evaluating Significance Within Registered Historic Districts
064, 070
Standards for Rehabilitation, Secretary of the Interior's
Standard 1 (Compatible New Use)
020, 028, 033, 047, 053, 065, 066
Standard 2 (Retention of Distinguishing Architectural Character)
001, 002, 003, 006, 011, 012, 013, 014, 015, 017, 019, 020, 021, 022, 023, 025, 026,
028, 029, 030, 032, 033, 036, 039, 041, 043, 044, 045, 047, 048, 049, 050, 051, 052,
053, 054, 055, 056, 057, 058, 059, 060, 061, 062, 065, 066, 069, 071, 073, 074, 075
Standard 3 (Recognition of Historic Period)
004, 005, 006, 008, 010, 024, 029, 046, 054, 055 ,056, 061
Standard 4 (Retention of Significant Later Alterations/Additions)
012, 016, 018, 025, 027, 031, 041, 043, 053, 054, 061, 062, 073
Standard 5 (Sensitive Treatment of Distinctive Features and Craftsmanship)
011, 014, 017, 020, 025, 029, 032, 033, 047, 048, 053, 054, 058, 059, 062, 065, 073
Standard 6 (Repair/Replacement of Deteriorated or Missing
Architectural Features Based on Historical Evidence)
013, 015, 029, 031, 032, 035, 038, 040, 042, 046, 049, 052, 054, 055, 056, 057, 059,
061, 065, 067, 069, 072, 073
Standard 7 (Cleaning with Gentlest Method Possible)
009, 039, 063
Standard 8 (Protection/Preservation of Archeological Resources)
Standard 9 (Compatible Contemporary Design for New Alterations/Additions)
001, 003, 007, 010, 014, 022, 028, 030, 031, 034, 037, 045, 046, 048, 049, 050, 051,
058, 060, 065, 066, 067, 071, 072, 074, 075
Standard 10 (Reversibility of New Alterations/Additions)
026, 037, 047, 048, 051, 066
Storefronts
003, 004, 027, 030, 049, 050, 053, 061, 062, 067, 070, 073
Streetscape
075
Stucco
040
Surface Material, Nonhistoric
005, 070
Timing
See: Project Work Undertaken Prior to Issuance of Regulations
Vinyl Siding
See: Artificial Siding
Windows
See Also: Storefronts
Alteration/Demolition
015, 031, 032, 046, 048, 075
New Openings
050
Replacement
021, 029, 035, 046, 052, 057
Wood
Abrasive cleaning
039
Removing interior woodwork
017
Removing paint from previously painted wood
036, 039
Replacing clapboarding with shingles
042
U. S. GOVERNMENT PRINTING OFFICE 1985 486-032/32920
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
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Volume III
Cover illustration: Yokohama Specie Bank (1908-10), Honolulu, Hawaii. Rehabilitated
under the historic preservation tax incentives program. Drawing by Michel A. Van
Ackere for the Historic American Buildings Survey. 1987.
INTRODUCTION
"Interpreting the Standards" ("ITS") bulletins were initiated in 1980 by the Preservation
Assistance Division to explain rehabilitation project decisions made by the National Park
Service, U.S. Department of the Interior, in its administration of the historic
preservation tax incentives program. Issued at intervals to program administrators in
National Park Service regional offices and State historic preservation offices, the first
43 "ITS" bulletins were collected in 1982. Volume II of "Interpreting the Standards"
appeared in 1985, and included another 32 bulletins. The present volume adds another 32
bulletins, bringing the total to 107.
Designed primarily for State and Federal program administrators, these bulletins have
proved useful to architects, developers, historians, and others involved in the
rehabilitation of historic buildings. Consequently, with this volume, "ITS" bulletins are
offered for sale to the general public for the first time.
Decisions presented in these bulletins are specific to the circumstances of the
rehabilitations involved. They do not accumulate as precedent in the legal sense. The
procedures for obtaining certifications of rehabilitation are explained in Title 36 of the
Code of Federal Regulations, Part 67. These regulations control in the event of any
inconsistency with these bulletins.
The following ten Standards for Rehabilitation are used by the Secretary of the Interior
to determine if a rehabilitation project qualifies as a "certified rehabilitation" pursuant
to relevant sections of the Internal Revenue Code. The Standards comprise the sole
regulatory basis for determining whether or not a rehabilitation is consistent with the
historic character of the structure and where applicable the district in which it is
located. (The Standards for Rehabilitation, first published in 1977, are undergoing
revision as this volume goes to press. The revised text, however, will differ in relatively
minor aspects only from the Standards that governed review of the projects discussed in
this volume. These Standards are given below.)
1. Every reasonable effort shall be made to provide a compatible use for
a property which requires minimal alteration of the building, structure, or
site and its environment, or to use a property for its originally intended
purpose.
2. The distinguishing original qualities or character of a building,
structure, or site and its environment shall not be destroyed. The removal
or alteration of any historic material or distinctive architectural features
should be avoided when possible.
3. All buildings, structures, and site shall be recognized as products of
their own time. Alterations that have no historical basis and which seek
to create an earlier appearance shall be discouraged.
4. Changes which may have taken place in the course of time are
evidence of the history and development of a building, structure, or site
and its environment. These changes may have acquired significance in
their own right, and this significance shall be recognized and respected.
5. Distinctive stylistic features or examples of skilled craftsmanship
which characterize a building, structure, or site shall be treated with
sensitivity.
6. Deteriorated architectural features shall be repaired rather than
replaced, wherever possible. In the event replacement is necessary, the
new material should match the material being replaced in composition,
design, color, texture, and other visual qualities. Repair or replacement
of missing architectural features should be based on accurate duplications
of features, substantiated by historic, physical, or pictorial evidence
rather than on conjectural designs or the availability of different
architectural elements from other buildings or structures.
7. The surface cleaning of structures shall be undertaken with the
gentlest means possible. Sandblasting and other cleaning methods that
will damage the historic building materials shall not be undertaken.
8. Every reasonable effort shall be made to protect and preserve
archeological resources affected by, or adjacent to any project.
9. Contemporary design for alteraions and additions to existing properties
shall not be discouraged when such alterations and additions do not
destroy significant historical, architectural or cultural material, and such
design is compatible with the size, scale, color, material, and character of
the property, neighborhood or environment.
10. Wherever possible, new additions or alterations to structures shall be
done in such a manner that if such additions or alterations were to be
removed in the future, the essential form and integrity of the structure
would be unimpaired.
Bulletins appear in order of issuance. The number assigned to each is composed of the
fiscal year in which the bulletin appeared and an overall cumulative number. The index
at the end of this volume references all bulletins in the series. (Unfortunately Volumes 1
and 2 are no longer in print.)
This material is not copyrighted and can be reproduced without penalty. However,
normal procedures for credit to the authors and the National Park Service are
appreciated. Additional information and guidance on technical preservation and
rehabilitation techniques for historic buildings may be found in the Preservation Briefs,
Technical Reports and other publications developed by the Preservation Assistance
Division. For a complete list of titles including prices and GPO stock numbers, write:
Preservation Assistance Division (424), National Park Service, P.O. Box 37127,
Washington, D.C. 20013-7127.
•
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards tor Rehabilitation
Number: 86-076
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: ASSESSING "PROBLEM USE" HISTORIC STRUCTURES
Issue: While some historic buildings reveal their character immediately through a
particular style, through the use of rich materials such as marble and bronze, or
through a repetition of ornamental features and decorative detailing, many others do
not. The character of utilitarian structures, such as warehouses and jails, may be
conveyed through the very simplicity of their form and materials, or through features
associated with the historic use of the building.
The contemporary uses some utilitarian structures can serve while preserving their
historic character are limited. Historic utilitarian structures have been rehabilitated
within the framework of the Secretary's Standards, but the potential limitations for
adaptive re-use should be recognized early in project planning. It is important to be
aware of the functions they have served over time in order to meet the Standards. As
a result of an incomplete assessment of the significance of a structure's historic
function to its character, an owner may make changes that compromise its identity.
Application: A jail built in 1887 was proposed for rehabilitation into residential
apartments. Located in a historic district, the structure consisted of a warden's house
and a cell block (see illus. 1). The exterior of the four-story, 124' x 44' cell block
contrasted sharply with the warden's residence, a three-story, late Victorian structure
topped by an elongated arched dome that had long been a landmark in the historic
district. The stark interior of the cell block reflected the strictly utilitarian
character of the structure. The cells, 5' x 8', were separated by 18" load-bearing
masonry walls (see illus. 2 and 3). The internal structural system was therefore
independent of the exterior walls. To accommodate the insertion of 32 apartments,
plans called for the nearly total demolition of the historic floor plan (see illus. 4).
In denying the project certification, the regional office noted that the design proposal
would remove:
all signs of the historic plan and structural system along with all
interior historic fabric, i.e., stairs, balustrade and newel posts,
lattice strap cell doors and riveted steel jambs, etc.
Consequently, this proposal would erase all evidence of the
essential form, integrity and sole intent of the building's historic
appearance and purpose.
In his appeal, the owner stressed the immense difficulties encountered in converting the
building into housing. He stated that only by removing all of the interior fabric could the
conversion be accomplished. In the meeting, he also noted that much of this work had
already been undertaken, including the removal of the roof (made necessary by the
decision to remove the load-bearing cell walls). At the time of the appeal meeting,
therefore, the cell block stood roofless with only its perimeter walls in place.
86-076
The Chief Appeals Officer agreed with the determination of the regional office that the
rehabilitation destroyed all traces of the jail's character as a jail--and thus in large part
its very history. The historic function of the cell block was very specific. "Its sole
purpose," he wrote, "was embodied in the interior arrangement of the structure." This
arrangement "was more than a mere adjunct to the historic resource. It was the most
essential component of it. The interior arrangement largely determined the fundamental
historic character of this building... and it had survived into the present essentially
unaltered." As a consequence of the work undertaken, however, "practically all internal
vestiges of the defining historic character have been obliterated." The rehabilitation,
therefore, failed the basic statutory test required of every project undertaken on historic
buildings for purposes of the Federal historic preservation tax incentives program--that
the rehabilitation work must preserve the essential portions and features of the property
significant to its historic, architectural and cultural values.
In determining that the rehabilitation did not meet the Standards, the Chief Appeals
Officer addressed the underlying question of whether the proposed new use—housing--
violated Standard I (compatible use). In doing so, he rejected the claim that the con-
version of this special-use building to apartments entailed removal of all interior fabric:
Considering whether this specialized building could be converted
to housing, admittedly a difficult question, I have come to the
opinion that it could have been reasonably successful with
imaginative exploration of alternatives to total clearance of the
interior of the cell block.
While a design proposal for housing that was more sympathetic to the historic structure
would have been approved, the Chief Appeals Officer took the occasion to note that the
building would more easily have accommodated other uses, and concluded:
It seems unfortunate that a historic public building of such
particular character could not have been retained for an
appropriate public use, such as library or archives, that could
have been fitted into it with minimal disturbance of its historic
arrangement. A creative, affirmative search for alternatives to
disposal can sometimes lead to the useful retention of a
seemingly redundant historic public building.
Nevertheless, in this case, the denial resulted from the loss of historic character involved
in the specific method of inserting residential units into the building rather than from the
choice of housing as the use per se.
Prepared by: Michael Auer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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2. Interior of the cell block. Cells were 5' x 8', separated by 18" load-bearing walls.
86-076
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4. Floor plan showing proposed insertion of apartments and removal of nearly all
interior fabric.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. _
[Standards for Rehabilitation
Number: 86-077
Applicable Standards: 1. Compatible New Use (nonconformance)
2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: ASSESSING UTILITARIAN STRUCTURES TO DETERMINE AN
APPROPRIATE RE-USE
Issue: While some historic buildings reveal their character immediately through a
particular style, a variety of crafted materials, a striking design, or through a
repetition of ornamental features and decorative detailing, many others do not. The
character of certain utilitarian structures such as warehouses, ice houses, barns, and
jails may, rather, be conveyed through a simplicity of materials, form, features, and
detailing which reflects a specific historic use. While architecturally simple, these
structures may have played vital roles in a town's commercial, social, or cultural
history.
The contemporary uses that some utilitarian structures can serve while preserving
their historic character are limited; thus, the potential limitations of re-use should be
recognized early in the planning stage. To meet Standards 1 and 2, it is particularly
important to be aware of and respect the building's significance as identified in the
National Register nomination, one aspect of which is understanding the historical uses
and functions it has served over time. Without a complete assessment of a structure's
history and character, an owner may inadvertently make changes that compromise its
unique identity.
Application: An ice service company determined eligible for National Register
listing was being rehabilitated for multi-unit residential use. The property consisted
of a one-story rectangular structure built in 1920 that served as offices, an engine
room, and coolers; and a 50 foot high windowless, ice storage house added in 1924 (see
illus. 1 and 2). The firm manufactured, stored, and supplied "pure" artificial ice made
from artesian well water until that service was rendered obsolete by the invention of
electric coil refrigeration. The ice storage house had been used since the the 1950s as
a lumber warehouse. It is important to note that in spite of changes in use from 1920
to the 1980s the ice storage structure remained "virtually unaltered and stood as rare
material evidence of a time in American history when household and commercial
operations depended on the delivery of blocks of ice for preservation of foodstuffs."
The Part 2 application outlined a series of changes required to provide light and
ventilation for the "problem use" structure, and to make the exterior generally more
compatible with newly conferred residential zoning. Specifically, windows and doors
were to be cut on two side elevations on four levels and balconies added (see illus. 3).
Stair towers would also be constructed to meet fire code requirements. When the
State reviewed the application, some concern was expressed about the new windows,
but it was felt that overall preservation concerns had been met in the rehabilitation of
an unusual structure that might otherwise have been demolished by the city.
86-077
Retention of the structural pilasters and interior cork wall sheathing were cited as
positive aspects of work, as well as passive energy conservation through solar retrofit.
Disagreeing with the State's recommendation for approval, the regional office denied
the project, citing violation of Standards 1 and 2. A letter to the owner stated in part:
Conversion of an ice-storage building...which will probably be
listed in the National Register as a rare example of its type...to
use as an apartment building is a drastic change in use and
requires too many significant changes to the fabric of the
building. The distinguishing character of the main part of the
building is inherent in the tall, solid brick walls, unrelieved
except by pilasters, without window openings. Cutting window
and door openings and adding balconies on four levels on the two
long sides of the structure significantly alters the original
character...The appended stair towers add to the changes...
Because the property had not been formally listed and was therefore ineligible for
appeal, the owner requested an administrative review that would provide guidance on
possible final certification. In his letter of concurrence with the Region, the Chief of
the Technical Preservation Services Division wrote:
After carefully reviewing the documentation provided, I
concur...that the proposed rehabilitation does not appear to meet
the Secretary of the Interior's "Standards for Rehabilitation."
The new window openings would dramatically alter the character
of this monolothic structure. Furthermore...I have serious
reservations about the building's continued eligibility for the
National Register if the proposed rehabilitation is carried out.
Prepared by: Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
86-077
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1. The historically important 1920s ice company firm consisted of a low
rectangular structure together with a 50 foot high, ice storage house. Neither
structure may seem to be of particular architectural "attraction." The simplicity
of construction and lack of decorative detailing, however, parallel a specific use
for that period of our commercial history.
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2. Ice storage house prior to rehabilitation. The massive brick structure was
historically designed and constructed to be windowless on all four sides in order to
enhance thermal efficiency. (The one opening seen near the top of the building is
a small attic vent).
86-077
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3. The rehabilitation proposal involved cutting windows on two highly visible side
elevations and adding balconies. The National Park Service determined that the
degree of change to accommodate this particular re-use proposal was not
consistent with the historic character of the building; thus, approval was denied.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
teVashington, D.C.
II rStandards for Rehabilitation
Number: 86-079
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
9. Compatible Design for New Alterations/
Additions (nonconformance)
10. Reversibility of New Alterations/Additions
(conformance)
Subject: COMPATIBILITY VERSUS REVERSIBILITY IN NEW ADDITIONS TO
HISTORIC BUILDINGS
Issue: Standards 2, 9, and 10 of the Secretary of the Interior's "Standards for
Rehabilitation" are used in the evaluation of new additions to historic buildings. It is
important that a new addition be designed and constructed so that the character-
defining features of the historic building are not radically changed, obscured,
damaged, or destroyed in the process of increasing the building's size. This means that
the new addition should be compatible with the historic building in terms of mass,
materials, relationship of solids to voids, and color. The size and scale of the addition
should also respect the historic building, and be attached if possible to the rear or an
inconspicuous side. Further, new additions to structures should be reversible so that if
removed in the future, the essential form and integrity of the structure would be
unimpaired.
Occasionally architects and owners will propose an addition to a historic building
which they argue could be removed at a future date without damaging the basic form
and integrity of the structure. Often the materials used in these additions, such as
glass, canvas and clear plastic, are cited as proof that the additions are temporary.
The issue, however, is not the permanence or impermanence of the materials used to
construct the addition. If an addition adversely alters the character of the historic
building, regardless of its presumed reversibility or temporary nature, the project will
be denied certification. Rehabilitations must meet all applicable Standards to receive
certification.
Application: A small, circa 1900 railroad depot which is individually listed on the
National Register was rehabilitated as a restaurant. The character and picturesque
quality of this depot prior to rehabilitation (see illus. 1) was largely defined by the
conspicuous, slate-covered, hipped roof that projected broadly beyond the exterior
walls to shelter the station's platform. The exterior walls on four sides of the building
were decoratively treated with a quarry-faced limestone foundation, smooth red brick,
and limestone stringcourses and window moldings. The use of these multi-colored
materials and architectural features such as arched windows, leaded glass transoms,
and wood brackets on stone corbels served to link the visually rich exterior walls with
the prominent roof.
86-079
In order to make the project economically feasible, a new addition to the depot was
built to increase the seating capacity of the restaurant. An addition with large plastic
windows with striped plastic walls and roof was constructed around almost half of the
depot's exterior walls and was attached along the eaves of the building. Awnings were
hung from the eaves around the remaining half of the building (see illus. 2).
The project was denied certification by the NPS regional office on the basis that the
rehabilitation violated Standards 2 and 9. In the letter of denial to the owner, the
Regional Director stated that the addition and awnings obscured exterior, decorative
architectural features and had altered the building's historic form.
The owners appealed the denial, stating that the addition did not destroy nor obscure
historic fabric. The owners contended that the architectural features were visible
inside the new addition, and that the addition and awnings were carefully designed to
result in little or no damage to the historic fabric of the building, therefore meeting
Standard 10.
The Chief Appeals Officer agreed with the owner that the addition and awnings
resulted in no damage to significant historic fabric, and was therefore technically
reversible. However, the regional office's denial of certification was affirmed. The
Appeals Officer agreed that the rehabilitation did not meet Standard 9, which
specifically states that alterations and additions "shall not be discouraged when the
design is compatible with the size, scale, color, material and character of the
property . . . ." Although the architectural features and building materials of the wide
overhang and the historic exterior walls were visible inside the new addition and
behind the awnings, their relationship to the design and form of the overall building
had resulted in the loss of the historic character of the exterior of the depot. As the
Appeals Officer stated in his letter to the owner:
Whether it is a temporary, reversible addition or a more permanent
addition to the building, it is fundamentally incompatible in size,
form, and detail with historic character of the historic depot. Since
the addition obscures and alters such a substantial portion of the
historic building's significant exterior, I have to conclude that the
rehabilitation is not consistent with the historic character of the
building.
Prepared by: Jean E. Travers
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
86-079
•
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1. Pre-rehabilitation view of building from railroad tracks: Note brackets,
stone corbels and stringcourses. These features occur on all sides of the
building.
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2. Post-rehabilitation view of the new addition and awnings from street. The
addition and awnings obscure a substantial portion of the exterior.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
1Vashington, D.C.
II [Standards for Rehabilitation
Number: 87-080
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
9. Compatible Contemporary Design for New
Alterations/Additions (nonconformance)
10. Reversibility of New Alterations/Additions
(nonconformance)
Subject: INCOMPATIBLE ALTERATIONS TO HISTORIC RESIDENTIAL INTERIOR
SPACES
Issue: Historic residential interiors often contain highly decorative architectural
features such as mantels, woodwork, ceiling medallions and crown moldings that are
readily recognized by owners and architects as significant and therefore worthy of
preservation. However, when assessing the historic character of interiors prior to
rehabilitation, the spaces themselves are often overlooked. Important spatial qualities
can include a room's proportions, defined by ceiling and wall dimensions, the size and
number of openings between rooms, and the arrangement of rooms that link spaces on
a particular floor. Just as any alteration to a historic interior needs to preserve
important architectural features, such an alteration needs to be compatible with
significant spatial qualities. Alterations which adversely alter or destroy important
interior spaces with new partitions, or floor and ceiling cuts--while perhaps not
destroying decorative features such as mantels--may still result in loss of the
interior's historic character. Projects in which this occurs will not meet Standards 2,
5, 9, and 10 and may therefore result in denial of rehabilitation certification.
Application: A four-story duplex townhouse, originally designed as a single family
dwelling, was rehabilitated into five apartments (see illus. 1). This townhouse
possessed a high degree of integrity and architectural distinction prior to
rehabiliation. Although the building had been used as a roominghouse since 1930, and
vacant for four years prior to acquisition by the present owner, the significant interior
spaces, finishes and features were remarkably intact. Of particular significance was
the second floor with its three parlor rooms which retained crown moldings, pocket
doors and mantels. Of equal importance in defining the historic character of the
interior were the interior spatial qualities. These three parlor rooms were designed as
a sequence of large square rooms divided by pocket doors.
The project work on the building's exterior was sensitively done. The exterior of the
building was gently cleaned and selectively repointed. The historic windows were
repaired. However, several incompatible alterations occurred to the interior of the
townhouse to accommodate the five apartments. The basement was subdivided, and
the staircase was removed to permit the introduction of two units and the bedroom of
87-080
a third duplex unit, the main living spaces of which are on the second floor. The
second floor, the most architecturally significant portion of the interior, sustained
substantial amounts of new construction (see illus 2-7). A freestanding closet was
installed in the first parlor. A large stair and kitchen were constructed in the center
parlor, and a bath, utility and storage room were placed in the rear parlor. Although
the third and fourth floor rooms, originally serving as bedrooms, were more simple in
their architectural detailing, substantial alterations and removal of historic fabric
nevertheless occurred (see illus 8-11). Entrance doors from the hallways to these
rooms were removed and new entrances created. The closets and interior walls
separating the bedrooms were removed to allow for a new interior plan dividing this
space on the third and fourth floors into two, two-story (duplex) apartments. Two new
staircases were also constructed in this space. The historic staircase and stairhall
were maintained on the third floor, but removed on the fourth to accommodate new
bathrooms. In reviewing the rehabilitation application, it was the Regional Director's
finding that these interior alterations resulted in substantial loss of historic fabric and
incompatible alterations to the building. The project was denied rehabilitation
certification on the basis of Standards 2, 5, 9, and 10.
The owner appealed the region's decision, emphasizing the retention of significant
historic fabric on the exterior and interior. Crown moldings, mantels and pocket doors
were repaired and retained. New construction was placed away from historic walls
and ceilings in almost all cases so that new partitions would not abut crown moldings
and baseboards. The owner insisted that the majority of historic interior walls and
spaces had been retained and all distinguishing architectural features preserved to the
extent that if the new construction were to be removed in the future, the historic
character of the interior would remain.
The Chief Appeals Officer agreed with the Regional Office and affirmed the denial of
rehabilitation certification. In his letter to the owner, the Chief Appeals Officer
described the significant spaces of the interior and how they had been changed by the
rehabilitation.
Although it is evident that efforts were made in the rehabilitation to avoid
destroying ornamental features such as crown moldings and pocket doors, I
find that the alterations have in fact damaged the overall historic character
of this building's significant spaces. Although historic interior walls remain
on the second floor and in the third and fourth floor hallway, large amounts
of historic fabric nevertheless were sacrificed to allow for the new room
plan on the third and fourth floors and for the intrusion of three new
staircases in the building. I find the alterations to the parlor floor the most
destructive. The three formal rooms, historically of approximately equal
size, have been significantly altered by new construction. The new
construction in the center room, effecting the most severe intervention in
terms of the amount of new building and loss of historic fabric, has further
altered the original spatial qualities of the second floor overall. Although
the rear room is still partially visible from the front room, I find the new
kitchen wall and stair balustrade in the center room so invasive as to
destroy the sequence of space that this series of rooms was consciously
designed to envelope. The alteration to the parlor floor is sufficently
87-080
damaging to the character of this building that I would have upheld the
regional office on that change alone. Therefore, it is my determination that
the rehabilitation is not consistent with the historic character of the
building and that it fails to meet Standards 2, 5, 9, 10.
Prepared by: Jean Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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formal series of 3 parlor rooms on the 2nd floor.
87-080
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2. 2nd floor plan: Originally a side hall plan with 3 parlor rooms all of
similar dimensions. Note extensive new construction in these rooms, especially stair
and kitchen in center parlor room, and new wall for bathroom in rear parlor.
87-080
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Note view through 3 parlor rooms divided by pocket doors.
Center parlor room below now houses a staircase and kitchen.
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5. Post-rehabilitation: 2nd floor. Note
new staircase and partition in center parlor room,
new freestanding partition to the right of parlor - �
door in front room. ,
41
6. Work in progress: Center parlor. New
partition wall for kitchen designed not to abut
historic ceiling, yet is centrally located in room*
87-080
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New partition divides previously square room.
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3 :, .xd u . _ _ in-progress (above). Note the
FTM { .� insertion of the new staircase
_ into the original bedroom in
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10. Work in progress on third floor showing -"Ili:" ; _' ' -- ,
penetration of wall between historic bedrooms, } ', i �.
new staircase inserted in room and view to 14,- i '` 4
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fourth floor above. iY• { _1- .' ,: �� -•
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11. Post-rehabilitation view of original staircase
maintained as a part of rehabilitation, but fourt
floor is fllored above, preventing access.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 87-081
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (conformance)
Subject: INTERIOR ALTERATIONS RESULTING IN LOSS OF AIR/LIGHT SHAFT
Issue: Standard 2 of the Secretary of the Interior's "Standards for Rehabilitation"
states that "the distinguishing original qualities or character of a building, structure or
site and its environment shall not be destroyed." The interior of a historic building
contains many different features that may be character-defining, including obviously
decorative features or examples of fine craftsmanship such as doors, moldings,
stairways, mantles and plasterwork, but equally important to the historic character of
a building may be its layout, which includes the floor plans and the way in which rooms
and other interior features are arranged. In many cases, it may be as important to
preserve the general building layout as it is to preserve the historic shape of the
building, including voids or spaces which may contribute to this shape. However, there
are some instances when openings (voids or spaces) in historic building may not be
character-defining. In such instances, and particularly if these spaces no longer serve
the purpose for which they were originally designed, it may sometimes be acceptable
and in conformance with the Standards to eliminate them in the rehabilitation.
Application: A modest two-story, turn-of-the-century rowhouse which was built in
1902 originally as working-class housing, contained four "railroad" flats, two on each
floor separated by a center vestibule and stair, and a lightshaft in the rear (see illus.
1). Rehabilitation plans appropriately called for the retention of the four units.
However, although the basic "railroad" plans were retained for each flat (despite some
relatively minor changes), rehabilitation did result in the elimination of a narrow
(approximately three feet) enclosed light shaft which separated the two sets of flats
(see illus. 2). The National Park Service acknowledged that the narrow light shaft had
lost its function and did not meet minimum standards for light and air, but noted that
this alone did not justify its removal since Department of the Interior regulations
state that "the Standards take precedence over other regulations and codes in
determining whether the historic character of the building is preserved in the process
of rehabilitation. . ." Thus, the necessity of meeting health and safety code
requirements is not a factor taken into consideration by the National Park Service in
its review of a rehabilitation project. More importantly, the National Park Service
determined that obliteration of the lightshaft did not result in significant changes to
the floor plan, nor did it alter the character-defining features of the exterior. The
"exterior continues to contribute to the significance of the historic district in which it
is located, and the interior still preserves its original center-entrance plan." In short,
the rehabilitation was determined to be in conformance with the Standards because
"those components that are important in defining its character have been retained."
87-081
In a second, very similar project, lightshafts in two identical turn-of-the-century
apartment buildings were also determined not to be character-defining (see illus. 3).
Although originally utilitarian (primarily as ventilating shafts for the bathrooms),
when the buildings were constructed about 1900, these shafts had never been very
effective at providing light to the stairs or bathrooms in these three-story buildings
because of their narrowness. Over the years the six original apartments had been sub-
divided, and the rehabilitation plans called for the creation of additional units which
would result in completely eliminating the airshafts. The National Park Service
determined that the airshafts or lightwells were not significant character-defining
features. "Because the proposed changes in apartment layout eliminated the original
need for these lightwells they were rendered useless. Of course, the fact that an
existing element of a building is suddenly without purpose is generally not sufficient
reason to dispense with it, if it is significant. However, in the case of these buildings,
the lightwells were not particularly significant or character-defining features, since
they lacked notable distinction in design, workmanship and materials."
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-081
1. Original floor plan showing the two first floor "flats" separated by center staircase
and lightshaft. Note that lightshaft was completely enclosed, and not visible from the
rear of the building.
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2. New floor plan after rehabilitation shows that although lightshaft has been
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87-081
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3. This original floor plan shows the lightshaft (shaded) that was determined
not to be a character-defining feature and therefore eliminated in the
rehabilitation of these two identical apartment buildings.
Technical n Preservation ServicesInterpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 87-082
Applicable Standards: 2. Retention of Distinguishing Architectural
Character
5. Sensitive Treatment of Distinctive Features
and Craftsmanship
6. Repair/Replacement of Deteriorated or
Missing Features
Subject: ALTERATIONS TO INTERIOR LAYOUTS
Issue: Floor plans are often of prime importance in defining the historic character of
historic buildings. Indeed, in some cases, the floor plan defines the building type.
Such is the case with "shotgun" cottages, marked by the linear arrangement of rooms
that gives the form its name. Although alterations to the plan of such structures
undergoing rehabilitation are possible within the framework of the Secretary of the
Interior's "Standards for Rehabilitation," the basic interior layouts of these modest
structures must be respected, particularly when they have survived intact.
Applications: Both projects discussed here are double "shotgun" cottages whose
characteristic room arrangement remained intact despite some deterioration of
features and finishes (see illus. 1 and 2). The first was built ca. 1900; the second dates
from ca. 1890. The original plan of each building is a rectangle having a dividing party
wall down the middle with four rooms arranged in linear fashion on each side. Sheds
containing bathrooms had been added onto the rear of each building (see illus. 3 and
4). Each building was rehabilitated for continued use as residential apartments.
In the first case, the "shotgun" plan was generally retained in the rehabilitation with
some modifications (see illus. 5). Kitchens were inserted into the second room of each
half of the duplex; a bathroom and laundry were inserted into the third room. The
fourth room in each half of the building was enlarged by moving the partition forward
a few feet. Despite these alterations, the division of the building into two equal units
was respected in the rehabilitation. Within each half of the double cottage, the
interior arrangement of small rooms, one behind the other, was also maintained. Thus,
on both the exterior and the interior, the building appears as it appeared historically,
as a modest double cottage in the "shotgun" style. This plan largely determined its
historic character, which remains following the rehabilitaiton. The project meets the
"Standards for Rehabilitation."
In the second case, radical changes made during the rehabilitation obliterated the
characteristic interior plan (see illus. 6). The separation between the two front rooms
was destroyed to create one larger room in place of the double parlor arrangement. In
87-082
order to enlarge the apartments, the plan was further altered by incorporating almost
the entire rear half of the right unit into the left unit. The floor space lost to the
right unit was regained through the addition of a stair to the attic, into which two
bedrooms were added. In this project the damage done to the historic character of
this modest building is extreme. The units no longer convey a sense of the original
"shotgun" plan. Construction of the stair in the right unit has further drastically
altered the structure by introducing a vertical element missing from the historic
plan. Finally, the division between the halves of the building was effectively
destroyed in the rear half of the building. Accordingly, the project fails to meet the
Secretary of the Interior's "Standards for Rehabilitation."
Prepared by: Michael J. Auer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-082
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87-082
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extends across the full width of the building in the rear half. To regain the floor space
thus lost in the right unit, a stair was added, further altering the plan of this simple
structure.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the interior s
t
—rashington, D.C.
II [Standards tor Rehabilitation
Number: 87-083
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
9. Compatible Design for New Additions
(conformance)
Subject: ROOFTOP ADDITIONS
Issue: Rooftop additions are often proposed when there is a need for additional space
in a historic building which is located in an urban area where ground floor expansion is
not a possibility. There is no specific "formula" for determining when a roof-top
addition may be appropriate; because each historic building and its setting/context is
unique, each proposal must be reviewed individually. While it is generally true that
smaller buildings, three stories or less, are least suitable for new additions, and that
taller buildings may be more likely to lend themselves to a new rooftop addition, there
are still notable exceptions. And, it is important to realize that some historic
buildings cannot accept rooftop additions at all. A building with a very distinctive
cornice, for example, even though eight or nine stories tall, may be just as unsuitable
as a smaller building for a rooftop addition, if such an addition would be likely to
obscure that character-defining feature. Standard 9 does not discourage rooftop
additions if they do not destroy significant historic or architectural fabric, and if their
design is compatible in size, scale, color, material and character of the property and
the neighborhood. The guidelines recommend that all new additions to historic
buildings be designed so it is clear what is new and what is historic, and that rooftop
additions in particular be as inconspicuous as possible when viewed from the street,
and that generally they be set back from the wall plane.
Application: A rooftop addition was proposed for a four story apartment building that
was being rehabilitated for continued residential use. The building (actually two
buildings either built together or designed and built to complement each other) was
constructed in 1914 in a rather plain, vaguely classical revival style of brick with a
slightly raised limestone base, beltcourses and some decoratively carved keystones on
the first floor. It is capped by a simple but fairly prominent dentilled cornice (see
illus. 1). This building is one of several larger scale apartment buildings located in a
primarily small scale, single family residential neighborhood. The building itself is
surrounded on both sides and across the street by two to two and one half story
rowhouses, and therefore is highly visible within the district. For this reason alone, it
might appear that the addition of any more height to this building would not meet the
Standards.
87-083
However, using a setback design concept linked to the cornice by a sharply slanted
pent roof, another floor was added that is only minimally visible on the non-significant
side elevations, and cannot be seen from the other side of the street directly across
from the building (see illus. 1). The new rooftop addition and stairtower (see illus. 2-3)
is visible only on the non-significant and non-character-defining north and south
elevations of the building. The fact that there are skylights inserted into the new pent
roof is also unknown to passersby. From the public wayfare the new addition is visible
only on the non-significant side elevations in the new brickwork rising above the
original roofline, and the stairtower. This rooftop addition thus preserves the historic
character of this building, and is in conformance with the Standards.
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-083
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buildings of harmonious but slightly different design.
87-083
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 87-084
Applicable Standards: 2. Retention of Distinguishing Architectural
Character
5. Sensitive Treatment of Distinctive Features
and Craftsmanship
6. Repair/Replacement of Deteriorated or
Missing Features
Subject: SUBDIVISION OF SIGNIFICANT SPACES
Issue: The imposing lobbies, auditoriums and other grand spaces associated with
hotels, churches, theaters and other public buildings are typically character-defining
features of such structures. These major spaces, however, are often part of a spatial
sequence that has been consciously designed as part of the overall plan of the
building. Other, adjacent spaces, either leading up to the building's "centerpiece" or
flowing from it, may thus be essential components of the overall character of the
structure. Any rehabilitation of such structures must respect the procession of these
congruent spaces. Isolating them from their context within the overall organization of
the building may cause a project to violate the Secretary of the Interior's "Standards
for Rehabilitation."
Application: A large building constructed in 1925 as a social and residential club for a
fraternal organization, and subsequently converted to a hotel, a drug rehabilitation
center and other uses, was rehabilitated as residential apartments. The primary
entrance to the building was a three-story lobby that was the most prominent and
most highly ornamented interior space (see illus. 1). At one end of the lobby was a
monumental split stair leading to a gallery and to two other large public spaces, a
lounge area known as the "palm room" and a dining room (see illus. 2, 3 and 4).
Photographs of the lobby demonstrate that the palm room was continuous with that
space. The palm room was clearly visible through the reredos, and shared the lobby's
deeply coffered ceiling. The large pendant light fixture in the lobby was balanced by
an identical element in the palm room. The palm room and the lobby, and to a lesser
extent the dining room (which opened onto the palm room) were thus perceived as
components of one large space.
In the rehabilitation, both the palm room and the dining room were subdivided and
incorporated into apartments. The palm room was stripped of its decorative features
and an additional floor was introduced into the space. In the dining room the ceiling
beams and brackets, panelled wall with niche, hooded fireplace, and other features
were retained, but incorporated into individual apartments (see illus. 5). To enclose
the new apartment spaces, a floor-to-ceiling partition was constructed behind the
ornamental screen between the lobby and the palm room (see illus. 6).
87-084
The project was determined not to meet the "Standards for Rehabilitation" on a
number of grounds. In the palm room both the decorative finishes and the space itself
were destroyed in the process of inserting two levels of residential space. In the
dining room, individual features were retained, but in the finished work they appear as
individual artifacts only, out of architectural context. The sense of the room as a
coherently organized space is lost. These modifications to the two spaces had adverse
effects on the historic character of the building, and alone would preclude the project
from meeting the Secretary's Standards. When these spaces are viewed in relation to
the overall layout of the building, however, the consequences caused by their
subdivision appear even more serious.
The insertion of a solid partition behind the open screen effectively cut off the lobby
from the palm room. The damage wrought by the rehabilitation to the individual
spaces thus exceeded the demolition of individual features or their incorporation into
smaller rooms. The rehabilitation destroyed the formal organization of the spaces
themselves. The progression from the grand, three-story lobby, up the elaborate split
stair into the palm room and adjoining dining room was lost, and the historic character
of the building irreparably harmed.
Prepared by: Michael Auer, TPS
These bulletiins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
'7 / 87-084
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room is reflected in mirrored wall at the left of the fireplace. All features were
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6. Lobby after rehabilitation. Partition behind screen closes off palm room and dining
room from the lobby.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 87-085
Applicable Standards: 3. Recognition of Historic Period
(nonconformance)
9. Compatible Contemporary Design for new
Alterations/Additions (nonconformance)
Subject: INCOMPATIBLE NEW ADDITIONS
Issue: Entrances and porches are often the focus of historic buildings, particularly if
they occur on primary elevations. When rehabilitating historic buildings, if an
entrance or porch is not original and has not acquired significance, property owners
and architects are free to remove these features and/or replace them. Design and
construction of new entrances or porch additions, however, must be compatible in
size, scale, color, material, and character with the historic building, neighborhood, or
environment. The new construction should not dominate, but be clearly differentiated
from, the historic building; and according to Standard 3, it should not seek to create a
false historic appearance.
Application: An 1880 manufacturing facility at the edge of a registered historic
district was rehabilitated into a retail store (see illus. 1). The original brick building
was a simply detailed, two-storied, gabled structure, with a large one-story section to
the rear. It displayed characteristics typical of its function as an industrial building,
with large door openings, numerous windows, and a covered loading dock.
The rehabilitation called for the removal of a ca. 1950 corrugated metal roof covering
the loading dock, and the construction of a new porch or portico in its place on the
south side of the building. While the existing roof was a simple addition to the original
building, it was generally consistent with the industrial character of the building, and
could have been retained (see illus. 2). However, in the rehabilitation, a decision was
made to construct a new porch on this highly visible side elevation, making it the new
primary entrance from a parking lot. The new construction was determined not to
meet Standards 3 and 9.
The new porch, which retained and boxed in the surviving pipe columns from the old
roof, is located in the same general location as that roof (see illus. 3). However, it
differs from the old in design and scale. It has larger columns and is three feet taller,
thereby dominating the south side and front of the building. The new portico fails to
meet Standard 9, in that its size and scale are out of proportion to the historic
building. The new portico also departs from the industrial character of the building.
With its deep entablature and massive formal columns, the new portico creates more
monumental, classical architecture than is consistent with the function and historic
character of this modest industrial building. The new portico hints of the Greek
Revival, an architectural phenomenon much earlier than the date when this building
was constructed.
87-085
The rehabilitation could have met the Standards if one of the following options had
been chosen: 1) retention of the existing side roof, 2) removal of the roof, leaving the
south wall as it was originally, or 3) construction of a simple new roof, following the
size and pitch of the old roof.
Prepared by: Camille M. Marton, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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prior to the rehabilitation.
87-085
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portico.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
—rashington, D.C.
rStandards for Rehabilitation
Number: 87-086
Applicable Standards: 6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence
Subject: MATCHING THE HISTORIC WINDOW DESIGN AND DETAIL WHEN
REPLACEMENT IS NECESSARY
Issue: A window survey can be a valuable component of rehabilitation project
planning, particularly for buildings of institutional scale. An objective window survey
by an experienced person will establish the condition, and repair or replacement needs
of the existing windows. A critical aspect of the survey--often overlooked--is using it
to help identify the visual role that the historic window design and its detailing or
craftsmanship plays in defining the character of the structure. Such an evaluation
should include the size and number of historic windows in relationship to the wall
surface, the pattern of repetition, overall design and detail, proximity to the ground
level and key entrances, and their visibility, particularly on primary elevations--both
from a distance and up close. It should also consider whether significant interior
spaces exist in which the windows are distinctive features. If extensive deterioration
makes it necessary to replace the historic windows--especially those that have
distinctive muntin patterns or decorative detailing--the replacement windows should
provide a close visual match of the design, detail, and finish. Using the same type of
material is.always a preferred preservation recommendation to achieve a visual match
particularly when the windows are seen at close range and when they are important in
defining the building's historic character. If the replacement windows selected do not
adequately match the historic configuration and result in changing the appearance of
the resource, Standard 6 will be violated.
Application: A school building that remained as a single component of a previous
multi-structure complex for the handicapped was being rehabilitated for office use.
When viewed from a distance across the former campus (see illus. 1 ), the masonry
school building is identified by its twin entrance towers, steeply pitched gable and hip
roof, and round-arched entrances on its primary facade. When viewed closer, as one
would see the primary south elevation when approaching either of the entrances, the
windows become distinctive features of the building because of their size, number,
pane configuration, and high visibility in proximity to the walkway and main entrance
(see illus. 2 and 3). Finally, from the inside (see illus. 4), the historic windows have
distinctive muntin detailing, shadow lines, and finishes.
An important aspect of the application was inclusion of a comprehensive window
survey. Based on the survey, the applicant contended that total window replacement
was necessary. NPS agreed that the windows were deteriorated to the point that total
replacement was appropriate. Once that issue was resolved, the main question
remaining in review was to determine whether the owner had selected a replacement
87-086
window that was consistent with the building's historic character. The owner's first
option was a wood replacement unit, but an aluminum replacement unit with
sandwiched muntins was instead selected based on a combination of factors such as
faster delivery time, meeting energy code requirements without having to install
storm windows or interior energy panels, and the lower cost of the window units
themselves. In making an overall decision as to whether the project could be
certified, NPS concluded that the design of the replacement units was not consistent
with the building's historic character. As part of the denial letter, NPS wrote:
Regarding the windows, on the basis of the window survey, I
accept that replacement of the twelve-over-one is warranted;
however, I find that aluminum replacement windows with
sandwiched muntins are quite inconsistent with the character of
this structure. The twelve-over-one windows are an integral
component of the external architectural design of the building,
and preservation of their visual qualities is not dispensable.
Although you have attempted to match the pane configuration,
the muntins themselves are flat; the change in appearance of the
windows as a result of these sandwiched muntins between double
glazing fails Standard 6, which requires "in the event
replacement is necessary, the new material should match the
material being replaced in composition, design, color, texture,
and other visual qualities."
In rejecting the design of the proposed replacement units, NPS gave the owner an
alternate course of action to bring this aspect of the project into conformance with the
Standards. This was to select a commercially available wood replacement window that
would match the historic design and have true divided single-glazed panes rather than
applied exterior muntins. Finally, if an energy panel was desired, this commercially-
available feature could be applied inside the sash or, alternatively, a standard interior
storm window could be used. Such a window system would preserve the detailing of the
historic windows and the historic appearance of the windows would be retained not only
from a distance--but equally important in this case--from up close.
Prepared by: Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
87-086
46
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1. The former school building is characterized by its distinctive form--massive yet only
three stories in height--its twin towers, unusual arch-shaped entrance and series of large-
scale, twelve-over one windows that were designed to provide maximum daylight in the
classrooms.
87-086 i
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entrance establish the importance of their design and detail.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 87-087
Applicable Standard: 6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (nonconformance)
Subject: INAPPROPRIATE REPLACEMENT WINDOWS
Issue: Inappropriate replacement windows can easily detract from the historic
appearance of an entire building and change its historic character. The National Park
Service requires an applicant to show that repair cannot be accomplished and that
replacement is necessary due to an extensive level of deterioration. Once this
determination has been made through proper planning, any replacement window needs
to match the historic sash, the pane size and configuration, the glazing, the muntin
detailing and profile, and the historic color and trim. This is true whether the window
is a simple one-over-one, double-hung unit, or a double-hung sash with multi-light
division. Also, whether the replacement is made of wood or aluminum, special custom
work is nearly always required to achieve a satisfactory match. If the principal design
features differ from the historic window, it is likely the new windows will violate
Standard 6 and, in consequence, project certification will be jeopardized.
Application: One of the larger commercial buildings in a district of intact 19th
century structures was being rehabilitated for office use. Built in three sections and
unified with a handsome Italianate facade in about 1875, the entire structure occupies
the intersection of two major streets on the front, and extends the length of one city
block at the rear. As part of the application process, a request was made by the
owner to install replacement windows because of the deteriorated condition of the
original windows. NPS responded affirmatively by letter stating that replacement in
kind of the historic sash was acceptable. NPS would further permit the owner to use
aluminum window units but, in this case, imposed a set of special conditions that had
to be met for approval. The NPS letter to the owner said:
...On any-facade where wholesale replacement is necessary,
aluminum double-glazed replacements will be acceptable
provided: 1. they are custom built to match the size and shape
of the existing window; 2. all glazing is clear; 3. the pane sizes
and configuration exactly match the originals; 4. all false
muntins are exterior applied and closely match the originals in
profile; and 5. all interior and exterior wood window trim is
repaired or replaced to match...
After work was completed by the owner on the building, the project application was
reviewed again by NPS for conformance to the special conditions. NPS denied final
certification, in large measure, for the inappropriately designed replacement units
installed. The different material (aluminum rather than wood) was not an issue in this
particular case. NPS wrote: "After lengthy negotiations over the issue of window
87-087
replacement, we approved the removal of the historic windows and established
parameters for the design of the new windows. These parameters were not met, and
the new windows detract from the historic character of all three public facades of the
structure...This is particularly unfortunate in light of your arguments that they would
preserve the historic appearance better than storm sash over the existing units."
Before and after photographs revealed several design deficiencies in the new window.
Where one over one double-hung windows had existed historically on the building's
primary facade, the replacement windows were a "fixed" design with both upper and
lower sash on the same plane; the horizontal piece applied as a meeting rail is actually
flat, and consequently unable to cast the familiar shadow line of the historic window.
Finally, there was a dramatic difference in color, from a light cream color to dark
brown (see illus. 1 and 2). On another key facade, where there had been historic four-
over-f our double-hung windows, fixed sash were installed, the light divisions were
altered, wider muntins were used, and the color of the windows was changed (see illus.
3 ,4 and 5).
After NPS denial, the applicant sought to bring the replacement windows into
conformance by a series of cosmetic changes, including relocating the horizontal
muntin at the top of the four-over-four window, and applying wood trim to the
aluminum muntins in an attempt to create a thinner appearance (see illus. 6 and 7).
This proposal was also rejected by NPS on appeal. In a final letter to the owner, the
Chief Appeals Officer explained:
In view of the prominence of these windows, I do not
believe that any superficial, cosmetic changes to the
muntins--instead of replacing the existing sash and
installing accurate replicas of the originals--can be
made that would bring the project into compliance.
Prepared by: Kay D. Weeks, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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1. Before rehabilitation, the front elevation of the
1875 commercial building is shown with its distinctive
"eyebrow" ornamentation framing the one-over-one, 2. After rehabilitation and installation of the new
circle-top, double hung windows. Because the sash and windows, the"eyebrows" seem to float--disconnected--
eyebrows are all painted a light color, they are
perceived •
historically as a unified design component. above the dark brown fixed sash. v
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3. Before rehabilitation, the windows on another street
elevation were four-over-four units that feature delicate,
attenuated muntins. The historic window is a double-hung
design; the shadow line that the meeting rail casts at the
center of the two-part window is a distinctive quality.
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4 and 5. After rehabilitation, there is a striking change in the "7 ,
appearance of the entire facade due to the installation of
a
inappropriate replacement windows. In addition to the R- .. -- . .., : `� •
obvious color disparity, the unit is noticeably on one plane �`,,. h "
rather than double-hung. The muntins are also much heavier " .r"
and there is no meeting rail. '
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6. In an attempt to bring the inappropriate four-over-four replacement units (see 4 and
5.) into conformance with the Standards, two alternatives were proposed. In proposal A,
the horizontal muntin at the top would be relocated so that all eight lights would be o
equal size like the original. A 3 1/2" wide aluminum strip would be applied in an attempt
to recapture some aspects of the meeting rail. Even after these adjustments, however,
the upper and lower sash would read as a single, fixed unit; the muntins are also too wide
and too flat.
87-087
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7. In alternative B, proposed changes included installation of a wood brick molding. In
an attempt to make the muntin appear thinner and visually recessed, the wide aluminum
muntins would be painted a charcoal gray; trapezoidal shaped wood strips would also be
applied to the existing flat muntin and painted to match the existing window color. Even
making these modifications, the replacement window did not match the detailing of the
historic window--the depth of the frame and muntin was still far too shallow, and the
muntin profile and width was still inappropriate. This proposal was also rejected.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior s
i
Washington, D.C.
[-Standards for Rehabilitation
Number: 87-088
Applicable Standard: 6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (conformance)
Subject: RESIDENTIAL AND OTHER SMALL-SCALE BUILDINGS - REPLACEMENT
WINDOWS
Issue: If a determination has been made that the historic windows cannot reasonably
be repaired due to an extensive level of deterioration, a replacement window needs to
be selected with care in order to preserve the historic character of the building. Any
replacement window should match the historic sash, pane size and configuration,
glazing, muntin detailing and profile, and historic color and trim. This is particularly
important where small, residential buildings are concerned and the windows are highly
visible due to their proximity to the sidewalks and streets. Using the same material is
always the preferred preservation option to achieve a satisfactory match; and in some
cases with small buildings it may be the only possible way. Special custom work is
frequently required. If an inappropriate window is selected, it is usually difficult to
make post-installation design and detailing adjustments to the new window in an effort
to bring the window into conformance with the Standards.
Application: Three workers' rowhouses were rehabilitated into subsidized family
housing (see illus. 1). The buildings are simple in character and distinguished only by a
corbelled cornice on the facades and large wood windows with 2/2 sash on all
elevations (see illus. 2). The historic structures are situated in particularly close
proximity to the street, and consequently their facades are highly visible.
In the course of the rehabilitation, all the historic wood window sash, which were
deteriorated and not salvageable, were replaced. The replacement windows installed
consisted of a single-hung aluminum window with fixed upper sash and a screen panel
placed directly below the upper sash in the same plane, a meeting rail considerably
wider than the original, muntins sandwiched between the glass, and a bronze colored
finish (see illus. 3). These windows were determined not to meet Standard 6 in that
they did not match the existing windows in design, color, profile, and muntin
configuration.
The 2/2 wood windows, with truly divided window lights, were an integral part of the
design of these small and simple buildings. The new aluminum windows fail to respect
the character and the visual qualities of the original windows. The screen panel
directly below the upper sash altered the double-hung appearance of the original
windows, and the stile and rail profiles along with the sandwiched muntins did not
adequately duplicate the size and form of the original windows.
A new proposal to modify the appearance of the aluminum windows was subsequently
submitted in an attempt to more closely approximate the visual qualities of the
original windows. A specially shaped exterior frame with a thin muntin would be
87-088
milled of wood and applied over the existing flush metal sections of the new aluminum
windows (see illus. 4). However, it was determined that this modification did not
capture the historic apearance of the existing wood windows. Wood frames fabricated
with central dividing muntins and applied to each window would not faithfully
duplicate the configuration of the old windows and would read as a temporary
treatment, rather than an integral component of the sash. In view of the proximity
and visibility of these windows to the street, any superficial or cosmetic change to the
existing replacement sash, regardless of material, would not be consistent with the
historic character of this building.
To bring this rehabilitation into conformance with the Standards, the owner decided to
replace the new aluminum windows, which were clearly visible from the street, with
new wood sash duplicating the originals in size, profile, muntin configuration, and
composition (see illus. 5 and 6). With the new wooden sash in place, the project was
subsequently certified.
Prepared by: Camille M. Martone, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particluar case.
87-088
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1. Pre-rehabilitation photograph of workers' rowhouses (front
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windows that had ai thin vertical muntin and wooden moldingdo(brickble-hun
molding)
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87-088
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3. Post-rehabilitation photograph of 4. Aluminum replacement window with a
aluminum replacement window. The vertical wood mock-up of an applied unglazed sash
muntin was sandwiched within the insulating frame and muntin placed over the upper
glass and the double-hung appearance changed aluminum sash. The applied frame and
since the screen panel was ins
glass muntin look like temporary add-ons, rather
below the fixed upper sash. than matching the historic sash.
87-088
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5. New wood replacement window as 6. Post-rehabilitation photograph of historic
approved. If possible further refinement rowhouses with matching wood windows.
(although not required in this case) would
have been to install the half screen on the
inside rather than on the front of the upper
and lower sash.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
—Washington, D.C.
rStandards for Rehabilitation
Number: 87-089
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (nonconformance)
Subject: INCOMPATIBLE REPLACEMENT WINDOWS: CHANGES IN SHAPE AND
DIMENSIONS OF WINDOW SASH AND MUNTINS.
Issue: The selection of replacement windows that successfully match the visual
qualities of historic windows involves a thorough understanding of the importance of
the individual elements of the historic windows themselves. The shape and dimensions
of muntins and sash can be particularly important in large, multi-pane sash that are
repeated across a simple, architecturally unadorned facade. In many historic
industrial, institutional and multi-story commerical buildings, the rhythm created by
the rows of windows across the facade becomes a strong design feature and as such,
important in defining the historic character of the building. Seemingly small
differences between the replacement window and the historic window, such as the
muntin shape or size, cumulatively can change the overall appearance of the building,
and result in failure of the rehabilitation to meet the Secretary of the Interior's
Standards for Rehabilitation.
A late-nineteenth-century mill building located in a registered historic district was
distinguished by its strong horizontal form, low gabled roof, and large, multi-pane
windows. The historic windows were wood, 16-over-16 double-hung, arch-headed sash,
and unfortunately very deteriorated (see illus. 1-2). The repetitive spacing, design and
detail of the sash, and planar qualities of the double-hung windows created a strong
visual pattern on the otherwise unornamented facade. These windows, therefore, were
the dominant architectural feature of the building. As such, preservation of their
visual qualities was critical to preserving the historic character of the building.
The replacement windows, however, did not adequately duplicate the visual qualities
of the historic windows, specifically in appearance, shadow lines, muntin detail and
planar qualities. In addition to the change from an arch-headed to a square-headed
sash, a number of other distinct changes have occurred to the historic appearance of
these windows. The double-hung, historic wood windows have been replaced by fixed
metal units with much narrower sash dimensions, noticeably changing the planar
relationship of the upper and lower sash. The resultant effect is that at certain angles
the replacement windows have the appearance of the upper and lower sash being in the
same plane, rather than duplicating the appearance of the historic, double-hung sash
(see illus. 3-5).
87-089
The thickness of the meeting rail so evident in the historic sash has been reduced in
depth creating a weaker shadow line (see illus. 5). The use of an applied aluminum
muntin grid rather than true 16-over-16 wood muntin divisions has caused significant
changes to the appearance of the windows (see illus. 6). The muntin grid clearly does
not match the original, since the new muntins have a rectangular rather than
trapezoidal profile, it has a ribbed surface, and it extends beyond the plane of the rails
and stiles. The projecting grid, furthermore, creates additional shadow lines that did
not exist on the historic windows. The historic muntins were flush to the surface of
the sash, integral to the sash frame construction and trapezoidal in shape after
puttying.
These numerous deficiencies give an awkward and incompatible appearance to the
windows and the overall building that is especially noticeable given the large size and
number of the openings. As a result, the window replacements were determined to be
inconsistent with the historic character of the building and therefore do not meet
Standards 2 and 6.
Prepared by: Jean E. Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-089
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windows. Note previous owner's effort to duplicate arch-headed sash with sample
unit on 2nd floor. In the view below, note how the upper and lower sash are set on
different planes, a characteristic feature of double-hung windows.
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3-5. Post-rehabilitation view of the building showing replacement windows. In 5, note
how the reduction in depth of the meeting rail has produced a flat appearance to the
window. The appearance of a historic double-hung window with sash on different
planes and a heavy shadow line created by the meeting rail has been lost.
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Vertical Section of Replacement Window
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Aluminum muntin grid
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6. Shop drawing showing applied muntin grid projecting beyond the exterior surface of
the sash. Also note rectangular shape and the two grooves on the interior and exterior
muntin grids which produce the ribbed appearance and additional shadow lines that did
not exist on the historic windows.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington. D.C.
rStandards tor Rehabilitation
Number: 87-090
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
S. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historic Evidence (nonconformance)
Subject: INCOMPATIBLE REPLACEMENT WINDOWS: CHANGES IN COLOR, SIZE,
AND CONFIGURATION OF SASH AND FRAMES
Issue: The selection of replacement windows that successfully match the visual
qualities of historic windows involves a thorough understanding of the importance of
the individual elements of the historic window themselves. Some of the important
elements that must be considered are the size and shape of the frames and sash,
muntin and mullion profiles and configuration, the configuration of the window itself,
the reveal of the window (depth of the window within the opening) and trim detailing
around the frames. In some cases, the historic color of the window, if known, can also
be important in defining its historic character. Failure to specify and install
replacement windows that adequately match the visual qualities of historic windows
will result in failure of the overall rehabilitation to meet the Secretary of the
Interior's Standards for Rehabilitation.
Application: Window replacements were planned as part of the rehabilitation of three
revival-style commercial buildings located in a registered historic district and built
between 1920 and 1930 (see illus. 1-3). The historic windows above the storefronts
were wood, residential in scale, double-hung, multi-pane sash typical of the early-
twentieth-century revival styles (see illus. 4-5). The windows were characterized in
part by narrow muntins, meeting rails, and sash. The attenuated proportions of the
wood members created a delicate appearance of the historic frames and sash that was
a character-defining feature of the historic windows and the building. In addition,
groupings of double-hung windows were common; heavy mullions separated the window
units and featured a raised vertical edge. The frames and sash were painted dark
green. Historical photographs of the buildings also indicated the frames and sash were
painted a dark color, a traditional color treatment for red brick, Colonial-revival style
and stucco, European-revival style buildings.
Aluminum, double-hung windows with attached metal grids on the exterior and interior
to simulate muntins were chosen to replace the originals (see illus. 6-7). Several of
these windows were installed to evaluate their effectiveness in matching the adjacent
historic windows. These windows were, however, determined not to adequately
duplicate the visual qualities of the historic windows in their color, proportion, size,
and installation detail of the originals. A light ivory color was chosen, rather than the
dark green of the historic sash, causing the windows to stand out against the facade
rather than to recede as the dark-colored historic sash had done (see illus. 8). The new
87-090
sash and frames were not properly sized to custom-fit the openings in the manner of
the originals. As a result, the amount of glass area was reduced and the delicately-
designed appearance of the historic frames and sash was replaced by a much heavier
appearing unit. The meeting rails of the replacement unit were almost twice the
thickness of the historic ones, and the grids, although trapezoidal-shaped, were
significantly wider than the historic muntins. The blocking of the opening reduced the
sash area while significantly increasing the exposure of the frame with its attached
aluminum subframe and metal panning. The flat metal panning bore no relationship in
size or profile to the historic wood molding detail found around the frames of many of
the historic windows in the buildings. It also was proposed that the mullions in the
multiple window bays be covered in metal in a manner that would eliminate the
decorative edge detailing. Finally, the appropriateness of the metal grids on
residential scale windows of this type on low-rise buildings was a questionable
treatment. These numerous deficiencies resulted in denial of certification for tax
benefits.
Although this window unit was manufactured by a company that had produced
compatible replacement windows for historic buildings, the company typically designs
windows for larger openings. This particular window unit was unsuitable as a
replacement for the small-scale, residential style windows of these three buildings.
On a larger window opening, the dimensions of the meeting rail and grid might have
been acceptable. But no reduction in the dimensions of the members was made when
the sash size was reduced to fit these small windows, and the sash were not made to
custom-fit each opening or the size of the historic sash.
The owner asked if an alternative panning shape more similar to the profile of the
historic frame and brick molding would sufficiently replicate the historic appearance
of the windows. Close examination of the shop drawings (see illus. 9) identified that
the problem could not be rectified by a different panning shape, since the
inappropriate color, size and configuration of the members and installation detailing
would not be affected. Nothing short of a different window unit, correctly sized and
detailed and in an appropriate dark color, would resolve these difficulties and bring
the project into conformance with the Secretary's Standards.
Prepared by: Jean E. Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-090
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1-3 Pre-rehabiliation views demonstrate the residential scale of the second and third
floor windows. Note how the dark color of the window sash and frames makes the
windows less prominent on the upper floors of buildings 2 and 3.
87-090
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historic windows. Note beaded mullion above,
thin muntins, meeting rails and sash on paired
windows and the simple double-hung window below.
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6. Proposed replacement window, exterior.
Note rectangular panning, extensive subframe 7. Proposed replacement window, interior.
creating additional shadow lines. Compare the Note the three layers of metal comprising the
meeting rail and muntin dimensions with the subframe, and the decreased size of the sash
historic sash in 4-5. and glazed surface within the opening.
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8. Proposed replacement windows on third floor and original windows below. Note
how dark sash and frames are unobtrusive, light sash and frames create a striking
pattern on the red brick facade.
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9. Drawing of proposed window and original window and frame location. Note how
new sash and frame are set closer to the exterior and within the window opening. The
owner's alternative panning identified above will not correct the deficiencies of the
sash.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 87-091
Applicable Standards: 9. Compatible Design for New Alterations/
Additions (nonconformance)
Subject: ADDING TO FREESTANDING HISTORIC BUILDINGS
Issue: The first consideration in planning a new addition is the potential physical
impact on significant historic materials and features. Probably of equal importance,
however, is the potential visual impact on the building's historic appearance or
"character." Because freestanding historic structures are often visible from all four
sides, they tend to be particularly vulnerable to exterior change. For this reason, if
the factors of size and high visibility are not carefully weighed prior to construction
of the new addition, a distinctive historic form and profile can easily be expanded into
a building with a completely different character. When a new addition is simply too
large in relationship to the freestanding historic building, then placing it on a
secondary elevation, using a reveal, using compatible materials, and making a clear
differentiation between old and new may still not offset the addition's impact on the
historic character. When it is determined that a new addition violates Standard 9,
project certification will be denied.
Application: In three rehabilitation projects under review by the National Park
Service, the size of the new addition was the major cause for denial. In each case, the
historic structure was a freestanding building (a residence, a school, and a bank) with a
distinctive form or shape.
First, a two-story vernacular brick residence dating from 1915 recently underwent
rehabilitation for use as a dormitory. When a new, large-scale addition was attached
on a secondary, but highly visible, elevation as part of the project, NPS denied the
project for preservation tax incentives. While recognizing the success of the architect
in differentiating the new construction from the historic building (including wall
reveals, roofing material, face brick with a soldier course, and windows and cornice
details), NPS determined "the addition overwhelmed the historic structure in mass and
was too prominently sited." Before rehabilitation, the historic building was
asymmetrical in shape, consisting of a main block and several subsidiary--but
proportionally similar--components and highlighted by a prominent wraparound wooden
porch. After rehabilitation, the form was still asymmetrical, but the new brick
addition became the most prominent architectural feature of the building from several
elevations, its distinctive angular form dwarfing the historic porch in size and scale.
In summary, the addition drastically changed the form of a residence that was typical
of its time, and, in changing the form, compromised the historic character (see illus. 1
and 2).
In the second case, a 1926 classically-styled freestanding bank building with large
round-arched window openings was rehabilitated to extend its historic commercial
function. When new bank offices were added along one side of the historic building,
essentially doubling the size of the historic structure, the project was denied for tax
benefits: NPS explained, "The new addition gives the building a radically different
87-091
size, shape, and appearance from what it had been for sixty years since its
construction... In effect, it obliterates the character of the structure as a
freestanding building, nearly obscuring an entire flank." Before rehabilitation, the
building was easily identifiable in the district by its symmetrically rectangular mass
and balanced formal windows; after rehabilitation, the form of the building became a
decisively asymmetrical wedge shape with a prominent new entrance replacing the
historic tripartite windows (see illus. 3, 4, 5). The materials and architectural
detailing of the new addition were not issues. Finally, NPS stated in the denial letter
that a smaller addition could have been certified.
In a third case, a ca. 1839 two story brick structure, three bays wide, with distinctive
stepped gables had been expanded in 1912 by a two-story ell when its use as a school
for women was changed to use as a private residence. In 1985, the structure was
added to again for use as a restaurant, then submitted to NPS for the investment tax
credit. Project work included construction of a kitchen and greenhouse addition and
construction of a storage building on the site. After review, NPS denied the
rehabilitation, primarily citing the impact of the new addition both on the building and
the district. In NPS' denial letter, it was stated that "prior to rehabilitation, the
structure was a simple, freestanding, L-shaped structure readily identifiable in
character." The NPS letter further explained to the owner that after rehabilitation
"the historic form of the structure is no longer clearly distinguishable; the kitchen-
bakery addition of approximately 2,000 square feet has vastly increased the size of the
building, turning the former L-shaped plan into a U-shaped plan and thus obscuring the
essential form of the historic structure...the addition overwhelms and competes with
the historic structure rather than being subordinate to it." It was noted in the NPS
denial letter that making the school into a restaurant would have been a compatible
use if the addition had been smaller in relationship to the historic structure; also, the
greenhouse addition in itself would not have precluded certification (see illus. 6).
Prepared by: Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-091
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1. The c. 1915 freestanding residential structure is visible
from all four sides; an unadorned brick side wall is a foil for
the most distinguishing feature of the house--the wood
wraparound porch.
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NEW ADnITION
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2. A new dormitory wing has been constructed on the side
elevation shown in illustration 1. Because of its height,
degree of projection, distinctive shape, and high visibility, the
new addition has become the dominant feature of the house
and has changed the historic character.
87-091
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3. This freestanding bank 1
structure, located at a major �. ( ��l r I:-- — "•-•�`'` i�! - ^—
intersection in the district, was' 1 7. ��' L .R' R :{ *
readily identifiable before _ '°` ; -.ti' " ,- - -
rehabilitation by its simple _ ^
rectangular form and its large,
arched openings. _ - ...m.o.lam--..._
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4. The historic bank and new bank addition are
AFT ------- shown in relationship to the surrounding streets
in the district. The previously rectangular form
of the freestanding bank has been dramatically
altered by both the size and shape of the
addition.
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.x...k: ,<. . - appropriate height, compatible
j - - - materials, and clear
fir — / -� - differentiation between new and_
i" old, the new work now dominates
-' — the resource and the setting. The
historic bank can no longer be
_ _ , seen from a major side street.
87-091
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NEW ADDITIONS _ _ )a -
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- 1
6. The side and rear elevation of the 1839 brick school building are shown
here on the far right (the later ell is not visible) together with three new
components added as part of the rehabilitation project--a greenhouse, a
kitchen building with stepped gables matching the historic building, and a
storage building. Because the new addition has changed the historic
character to a dramatic degree, the project was denied tax incentives. A
smaller kitchen wing--planned and sited differently--could have been in
conformance with the Standards. The greenhouse itself was not an issue.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number:87-092
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Design for New Alterations/
Additions (nonconformance)
Subject: REHABILITATING HISTORIC VERNACULAR STRUCTURES FOR
CONTINUED RESIDENTIAL USE
Issue: The most important part of planning an interior rehabilitation is correctly
identifying the structure's distinctive materials and its historic spatial character so
that they may be satisfactorily preserved within the framework of making changes
necessary for either a continued or new use. Vernacular buildings which are
characterized by simple rectangular spaces and plain detailing should have their
spaces and detailing respected when the overall rehabilitation is being conceived.
Some enlargement of rooms laterally by removing partitions could be an acceptable
approach if a sense of the historic space, plan, and simplicity of detailing were
retained in the process. On the other hand, cutting through floors or ceilings to create
dramatic new spaces (and plans) can drastically alter the character of these unadorned
vernacular structures. While some loss and change are anticipated in the process of
rehabilitation, major modification of character-defining spaces will violate Standards
2 and 9.
Application: A row of 19th century industrial housing--considered the most extensive
intact examples of this type of housing in the country—was being rehabilitated for
continued residential use. Originally, the 3 1/2 story brick units had served as boarding
houses for unmarried textile workers; later in the 19th century, the houses were
converted for tenement use. During the 130-year history of the structures, their
historic character as mill workers' housing remained. Although some interior
modification had taken place with attendant destruction of historic fabric and
features, the floor plans and historic interior room arrangements had generally
survived. The modest rooms, characteristic of the period of their construction and
reflecting the functional simplicity of their historic use, were detailed in a uniform
manner throughout the buildings. The floor to ceiling height had been similarly
uniform.
The rehabilitation was determined not to meet the Standards owing to the removal of
large portions of the first floor in order to create two-story spaces that would permit
additional light to rooms newly inserted in the basement. The change radically altered
the historic spatial definition of these rooms as well altering the historic relationship
of the first and primary floors to other floors in the buildings. This work was totally
incongruous with the simple, but distinct historic character of the 19th century
residential structures. In a denial letter to the owner, NPS explained further that the
continued residential use of these buildings should not have posed any major problem
or need for extensive changes to the building's overall historic design:
87-092
The character of the historic interior spaces appears to have been
easily adaptable for modern residential use. Unfortunately, during the
course of your rehabilitation work on these units, large portions of the
first floors were removed in order to create two-story spaces. The
creation of those two-story spaces required the destruction of both
historic material and the distinguishing spatial concept of the most
significant areas of each house, in violation of Standard 2.
Furthermore, the design character of the new space is incompatible
with the vernacular character of the building, thus violating Standard 9.
An alternative to removing portions of the floor would have been to regrade at the
rear to perm it more light to enter the basement through enlarged windows. It was
further noted by NPS that the incompatible spatial changes were all the more
regrettable because they were not essential to a viable reuse scheme for the buildings
or to extending their useful life.
Prepared by: Kay D. Weeks
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
;,,,� , 87-092
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1. The historic character of the structures as mill workers' housing
remained; that character, as NPS noted, was still forcefully
conveyed by both the exterior and the interior.
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2. The plan shows room size and arrangement; units converted to two-story
spaces by cutting through the first floor are denoted by shadowing.
87-092
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' �Yr' 3. A typical room,
::, ,� - �;y �,-•--` prior to
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r '` �; * defined by its low
e :
L �"° � ceiling, rectangular
rr.+ k !-• •
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,-. � -.. • simplicity of
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4. As part of the :,. ..
rehabilitation, the `k
historic space was r ' �
dramatically redefined �' I,"�'','.
by removing the first .. r0-- 144P `: ''!
story floor, revealing •:. ? ;
the basement level. f �
Two separate 'r •
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rectangular spaces were �•
then made into one �+� :-
rehabilitated living
unit. This inappropriate =-�
treatment violated bothieg •
9tanrlarric anti 9_
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
r
ashington, D.C.
[Standards for Rehabilitation
Number: 87-093
Applicable Standard: 5. Sensitive Treatment of Distinctive Features
and Craftsmanship(nonconformance)
Subject: ALTERATION OF INTERIOR LAYOUTS
Issue: Standard 5 of the Secretary of the Interior's "Standards for Rehabilitation"
requires that "distinctive stylistic features" characterizing a building be treated with
sensitivity. Such features may include the interior floor plan or arrangement of
spaces important in defining the historic character of the building. Radically changing
a floor plan may result in a loss of historic character.
Application: A three-story, commercial structure built in 1890 was marked by
commercial space on the ground floor and office or residential space above (see illus.
1). As a result of many changes over the years, the commercial portion of the building
retained little historic fabric; the space behind the storefronts was otherwise
undistinguished (see illus. 2). Consequently, the ground floor offered the owner
considerable latitude in making changes during the course of the rehabilitation.
The upper floors were distinguished by an oversized atrium extending through the
second and third stories. Arranged around this atrium were two distinct rings of
rooms, the inner ring fitted with windows intended to borrow light from the atrium,
and the outside ring lit by exterior windows (see illus. 3, and 4). Over the years many
of the window sash facing the atrium had been filled in, although their location was
clearly evident from the surrounding trim. The open third floor hallway overlooking
the atrium had been enclosed (see illus. 5). Nevertheless, despite these changes and
some deterioration of fabric and finishes, the distinctive historic floor plan and the
unusual sequence of spaces made up by the atrium and double ring of rooms had
largely survived (see illus. 6 and 7). The rehabilitation plans for the upper stories
called for retention of the atrium but the removal of all historic fabric behind the
perimeter walls of the atrium in order to create open plan offices. In addition the
perimeter walls of the atrium would be rebuilt in a different configuration, with doors
and windows suggestive of the historic ones, but narrower and arranged in different
locations.
Despite later alterations, the historic plan and the interior spaces of the building on
the upper floors are quite distinctive, even though carried out in relatively simple
materials. The arrangement of two rings of rooms around the atrium is unusual for a
building of this period and construction and needed to be retained in any project. The
proposed rehabilitation would all but obliterate this distinctive configuration, thereby
greatly impairing the historic character of the structure, and violating the "Standards
for Rehabilitation."
Prepared by: Michael Auer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitations, are not necessarily applicable beynd the
unique facts and circumstances of each particular case.
87-093
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1. 1890 commercial building prior to rehabilitation.
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2. Typical ground floor space before rehabilitation.
87-093
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3. View of central space showing atrium extending
through the second and third floors, with skylight
above. The second floor doors shown lead to rooms
beyond. Windows have been blocked in, but their
configuration is still apparent from the surrounding trim.
On the third floor the open hallway had been partitioned.
87-093
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4. Interior rooms were fitted with windows and �i `' ,
doors with transoms to borrow light from both the '
exterior window walls and the rooms facing the `'
lighted atrium. '=*' jI
_. y Ii•.,
. ' •iir
5. On the third floor, the historic hallway,
originally open, had been fitted with a solid
partition; the offices behind it, however, were
relatively unaltered.
87-093
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6 and 7. Historic second floor plan of atrium, hallway and inner and outer
rings of rooms (left). In the proposed rehabilitation (right), this distinctive
arrangement would be destroyed.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
irshington. D.C.
rStandards for Rehabilitation
Number: 87-094
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: INCOMPATIBLE ALTERATIONS TO SIGNIFICANT REAR ELEVATIONS
Issue: Before initiating a rehabilitation project it is important to first identify those
features which are character-defining and which must be preserved. While there may
not be much doubt whether the primary or front elevation is significant, it is not
always as easy to determine when the sides and rear, or secondary, elevations are also
character-defining. However, when a secondary elevation exhibits fine stylistic
detailing, shape or form unique to the building type or use, when it is highly visible or
of special historical or social significance to the historic district or neighborhood, it is
likely to be worthy of preservation. If such a character-defining elevation is not
preserved in the rehabilitation, the project will not be in conformance with the
Standards and will be denied certification.
Application: A vacant and derelict armory building individually listed on the National
Register was rehabilitated for use as residential apartments. Built in 1912 of red
brick, the armory was designed in an appropriately militaristic style featuring an
arched entranceway flanked on either side by a projecting three-sided corbelled bay,
and a three-story tower. The armory is comprised of two sections: a two-story, L-
shaped, flat-roofed head house provides the primary elevation facing the street, and
adjoins a one-and-one-half story, gabled-roof drill shed which spans across the rear of
the head house, and extends four bays past the edge of the head house (see illus. 1).
The drill shed parallels the river (which the rear of the shed faces) and is visible from
the town across the river (see illus. 2-3).
Despite several alterations made in the 1950s and some deterioration and vandalism
which occurred during the nearly 15 years the buildings had been vacant, the armory
had survived in a remarkably intact state prior to rehabilitation. The interior of the
head house, including a large entrance hall, company parlor, and numerous small rooms
on both floors, easily accommodated the apartment conversion which was
accomplished with a minimal loss of historic fabric and character. The interior of the
75 x 300 feet drill shed was a completely open space with exposed steel trusses and a
suspended gallery at one end (see illus. 4). During the rehabilitation this large open
space was converted into twenty apartments by creating two floor levels. To provide
light into these apartments, skylights were added to the rear of the roof of the drill
shed, and the rear wall was reconfigured by removing the original paired nine-over-
nine wood sash windows along with a substantial amount of brick between the piers
(see illus. 5-6). Nine prefabricated, panelled units which incorporated walls, windows
and doors were inserted in these newly made openings along the entire length of the
rear elevation. Wooden decks with privacy screens and steps to the parking lot were
added for the first floor apartments (see illus. 7).
If the open space within the drill shed had been a significant, highly detailed space,
the insertion of twenty apartments on two levels would very likely have been in
87-094
violation of the Standards. In this particular case, however, while the concept of
introducing multiple units into the very plain, open space of the drill shed was in
conformance with the Standards, the specific treatment of the rear elevation was not,
and the project was denied certification.
The drastic changes to the fenestration of the rear elevation were cited as cause for
denial. The existing historic window openings could have been altered in a manner
that would have provided light and access to the rear apartments while still leaving
enough brick to maintain the character of the rear wall. Instead, as the project was
carried out, the wholesale removal of the sash and most of the brick between the piers
added up to a significant loss of historic fabric. However, it is the change in
character of the rear elevation that is most damaging. Installation of the
prefabricated panels resulted in unacceptable changes in: color and texture (brick red
to stark white, smooth panels); materials (brick and wooden window sash to
prefabricated panels and aluminum windows); composition (distinctly vertical to
distinctly horizontal); and design (industrial to residential). Addition of the wooden
decks further obscured what remained of the brick, and emphasized the incongruous
domestic appearance of the rear elevation. Furthermore, the elevation now is highly
visible to those entering the apartments from the parking lot, and to neighboring
houses.
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-094
i
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1. The facade of the armory before rehabilitation. The gable-roofed drill
shed extends four bays beyond the head house with its three-story tower and
three-sided corbelled bay.
2. The rear elevation of the drill shed. Note the paired, nine-over-nine wood
sash windows and the high sills which provide much of the character.
is
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87-094
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3. View from the rear of the property behind the drill shed looking through
the trees to the town across the river.
4. The interior of the drill shed before rehabilitation, showing the exposed
steel trusses and the suspended gallery at one end.
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87-094
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5-6. The rear elevation of the drill shed during rehabilitation. Note the
extensive loss of brick, and how the character has changed with the removal of
the multi-paned wood sash and the creation of large openings.
87-094
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7. The rear of the drill shed showing the completed rehabilitation with the new
skylights in the roof, the prefabricated panels filling the former bricked areas,
and the new wood decks and privacy fences facing onto a parking lot at the rear of
the property.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service Wthe Secretary of the Interior's
S. Department of the Interior
ashington, D.C.
rStandards for Rehabilitation
Number: 87-095
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance).
9. Compatible Design for New Alterations/
Additions (nonconformance).
Subject: NEW CONSTRUCTION IN HISTORIC DISTRICTS: INCOMPATIBLE
ALTERATIONS TO HISTORIC SETTING
Issue: The setting of a historic building can be an important element in defining its
character. Setting is defined as the relationship of the historic building to adjacent
buildings and the surrounding site or environment: it is the arrangment of man-made
features, such as buildings and structures and their relationship to each other and to
their natural environment, such as open spaces, topographic features, and vegetation.
The Secretary's Standards address the importance of preserving the historic setting of
a building or district in Standards 2 and 9. Standard 2 emphasizes the need to protect
distinguishing original qualities or character of a building or site and its environment.
Standard 9 addresses the necessity of designing alterations and additions that are
compatible with the character of the property and its environment. The setting of a
historic resource is often quite fragile, particularly in rural areas where buildings and
structures are surrounded by large expanses of open space, and in industrial complexes
where buildings were constructed in specific locations for functional reasons. New
construction on, or adjacent to, historic buildings, if not carefully planned and
executed, can dramatically alter the historic setting of adjacent buildings or the
district. Such work may not meet the Secretary of the Interior's Standards.
Application: A historic district significant as an early-nineteenth century textile
manufacturing center was rehabilitated as a rental housing community. The district
was significant in part for its founder's early attempt to group buildings by their
functions (such as housing and milling) to take advantage of the natural terrain.
Historically, milling functions were placed adjacent to the river where a waterway
system was constructed. Buildings for housing and community activities were grouped
separately across fields (see illus. 1). Although industrial functions had ceased years
before, and the buildings were deteriorated at the time rehabilitation began, the
historic setting of the district, in particular the portion of the district where milling
functions occurred, remained intact. The industrial portion of the district included a
large mill spanning the river, a machine shop, ruins of another associated mill building,
an early twentieth century frame structure used as an office, and waterway system
linking the buildings to the pond and river. These buildings and structures were
situated across a field and visible from the main street running through the district
(see illus. 2-3).
The rehabilitation included the conversion of several of the historic buildings in the
district into apartments. In the area where milling functions occurred, the machine
shop and an adjacent frame building were rehabilitated for housing, and a free-
87-095
standing, two-story apartment block was constructed (see illus. 4). (Two additional
apartment blocks were constructed outside the district boundaries.) The frame
building was substantially altered during rehabilitation and is now linked by a new
addition to the machine shop (see illus. 5). Illus. 6 and 7 also show the new apartment
building constructed in the field directly in front of the machine shop and frame
building.
The large addition to the frame building and new construction has produced a more
densely developed environment in the area in front of the machine shop than that
which existed prior to rehabilitation or historically. It has elim inated the visual
separateness of the mill buildings from the historic residential buildings in the district,
and obstructs the visibility of the machine shop from the street which is a main
vantage point in the district. In addition, the new construction is incompatible in
design with the historic buildings. The historic mill buildings, in particular the
machine shop, were simple, unadorned elevations with ordered rows of windows on
each floor. The new construction, including the alterations and addition to the frame
building, are characterized by their asymmetrically massed roof forms, porches,
projecting bays, and have prominent features such as window shutters and palladian
windows. This new construction is not compatible with the historic setting and design
of the mill buildings and is inconsistent with the historic character of the district.
The project work, therefore, does not meet Standards 2 and 9.
Prepared by: Jean E. Travers, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
87-095
PRE-REHAB SITE PLAN
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Machine shop
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Housing, community buildings,
min owner's residence
1. Site plan of the district prior to rehabilitation. Note location of the mill and mill-
related buildings in the SW corner of the district.
87-095
,c i, .f..,..,, 1.� �1I•ars 1 it, r ice.: .. 4
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2-3. Pre-rehabilitation views of the machine shop, frame building, and the mill. The
National Register record states "the mills are set across a wide meadow at the end of
a formal system of waterways; their isolation points to the mills as a distinct unit."
Note the unadorned, simple quality of these industrial buildings.
t
Hill .
Machine shop Frame building - N . '
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87-095
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4. Post-rehabilitation view of machine shop and frame building. Note alterations to
the frame building and new construction in the previous open space. The new
construction introduces a variety of architectural forms and features not found on the
historic buildings in the district.
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5. Note how close the frame building's new addition is located to the machine shop. A
wood deck links the two structures. The new addition has created a more densely
developed environment than existed prior to rehabilitation, obstructs the visibility of
the machine shop, and has introduced architectural forms and features not found on
historic buildings in the district. The new construction, therefore, has changed the
visual qualities characteristic of the setting of this district.
87-095
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6. Aerial view of this portion of the district showing the alterations to the frame
building, and a portion of the free-standing new construction on the left. The machine
shop is in the center right of the picture, and the mill is located in the upper left
corner. Note the more densely developed environment immediately in front of the
machine shop.
ri' 7"`, 1+C+-�..-� 'fi w .. .--. c .
i " ' -t s. ��`� ,am. a:rr
xip . : \lachine shop . _� Y.
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7. Aerial view showing blocks of new construction identified as 1, 2, and 3. White
line is the approximate boundary of this part of the district.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service 4S.
Department of the Interior
the Secretary of the Interior's
ashington, D.C.
rStandards for Rehabilitation
Number: 88-096
Applicable Standards: 3. Recognition of Historic Period
(nonconformance)
4. Retention of Significant Later
Alterations/Additions (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Features Based on Historical Evidence
(nonconformance)
Subject: UNDOCUMENTED "RESTORATION" OF MISSING ARCHITECTURAL
ELEMENTS
Issue: When rehabilitating historic buildings, the repair or replacement of missing
architectural elements must be based on solid physical or documentary evidence. For
example, old photographs of the building may show a missing element clearly enough
to replicate it. Original architectural drawings may also provide this information.
Sometimes the outline of the missing feature may be clearly discernible on the facade
or elevation of the building, or may be revealed after removal of a later covering such
as asbestos or aluminum siding. An accurate reconstruction of the feature such as a
porch or a rear ell may be based, in part, on excavations made to determine its size
and depth by the location of buried footings. Finally, key elements may be found such
as balusters or porch railings that were stored in attics or basements when they were
removed in an earlier remodeling.
Any of these situations can provide useful clues necessary to carry out an accurate
reconstruction of the lost element. However, reconstructions that are not based on
such physical or documentary evidence, but merely on hearsay or a theoretical design,
cannot be verified historically, and generally are not in accordance with the
Secretary's Standards. If, during rehabilitation, some indication of a missing feature is
encountered, unless adequate documentary evidence exists to guide an accurate
reconstruction, it is better not to attempt such a treatment, but instead to design a
replacement that is new but also compatible with the historic building. It is also
important to remember that later additions or replacements for the earlier feature
may have acquired significance over time; if so, they should be retained.
Furthermore, if missing architectural elements are restored on a selective basis, the
completed building may take on an appearance it never had historically.
Application: A circa 1872 Italianate brick house, part of a farm complex individually
listed on the National Register, was rehabilitated for use as a bed and breakfast
establishment. The impressive, two-story house (see illus. 1), features segmental
arched door and window openings, a bracketed wood cornice, a lozenge-patterned
colored slate hipped roof and cast iron roof cresting. When first constructed, the
house had four porches—on the front, both sides and the rear. Over time, these
porches had been removed, and only their "ghost" outlines on the brick walls (and the
88-096
fact that exterior doors remained on the second story that had apparently opened out
onto porch roofs) provided clues to the fact that porches had ever existed. Although
the original porches were gone, a later, elliptical terrace surrounded by a low,
rusticated cast-stone wall, probably constructed around the turn of the century,
existed on the primary facade of the house at the start of the rehabilitation.
As part of the rehabilitation, the owner removed this elliptical terrace and wall from
the front of the house and decided to "reconstruct" the original porches. Instead of
using the very distinct "ghost" outlines (which had been removed by the owner during
cleaning of the exterior brick), the owner used pieces of wood brackets found on the
property as models to construct new porches. These bracket fragments, the owner
speculated, came from the "original" porches that had been described by area
residents as preceding those porches which had left their physical profile on the brick
(see illus. 2-3).
The rehabilitation project was determined not to meet the Standards because the
design of the new porches was not based on conclusive pictorial or physical evidence.
The new designs did not match the outlines on the masonry, nor were they based on
historic photographs or architectural drawings of the house. The porches give the
house an appearance that is not verifiable, yet appears to be historic. This violates
Standard 3. Although the intention of the owner was to restore the house to what he
believed to be its original 1872 appearance, in the absence of clear and indisputable
documentation as to what this was, two appropriate approaches would have been to
have left the porches off the house or to have based the porch reconstruction on the
physical evidence (outlines) of the former porches that still remained on the brick
when the property was first acquired.
The surviving bracket outlines could have provided ample guidance for quite closely
replicating these porches. Excavation in front of the doorways might have revealed
evidence of the location of footings that supported the porches, to document the depth
of the porches.
The owner, of course, had the option to retain the elliptical cast-stone wall. Although
clearly of a later period, this wall did not detract from the Italianate character of the
house. Its retention would have been in accordance with Standard 4, and
reconstructed porches based on the "ghost" outline would also have been compatible
with the wall.
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
facts and circumstances of each case.
ii;;*'''es . .. ' -• _I. ' ., P•A
f
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,.t�" 88-096
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1. The house as it appeared when acquired by the current owner. Note the "ghost"
outline of a porch on the front, the second floor exterior doors, and the elliptical cast
stone terrace. �� / _ _• �,� ������•���
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2-3. The reconstructed front porch (left) and the side porch (right). Their designs
were based on bracket fragments found on the property combined with area residents'
descriptions of the porches as they remembered them, but did not match the "ghost"
outlines that had existed on the brick prior to cleaning.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards for Rehabilitation
Number: 88-097
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Design for New
Alterations/Additions (nonconformance)
Subject: INCOMPATIBLE SITE WORK
Issue: Vacant lots adjacent to historic buildings often provide convenient locations for
stairtowers, parking lots and other work undertaken as part of an overall rehabilitation
project. Department of the Interior regulations state that a rehabilitation undertaken
for purposes of the investment tax incentives "encompasses all work on the significant
interior and exterior features of the certified historic structure and its setting and
environment." Development on adjacent lots may result in denial of certification if
the site work radically affects the "historic qualities, integrity or setting of the
certified historic structure." (36 CFR 67.6(b)).
Application: A four-story, three-bay brick structure built about 1869 and located in a
historic district noted for its brick warehouse and commercial structures was
rehabilitated for use as residential apartments. The rehabilitation of this structure
was undertaken as part of a larger project involving three other buildings (see illus. 1
and 2).
In order to provide access to this structure and to the neighboring buildings, an
entrance courtyard was created on the vacant lot bordering all four structures (see
illus. 3). Principal elements of the new construction included a wall at the property
line, an entrance pavilion, a three-story steel exterior stairto.wer, a wall at the mid-
point of the lot and a covered "walkway highlighting the entrance to the building at the
rear (see illus. 4 and 5). Additionally, the lot was excavated to provide light and
access to new below-grade apartments (see illus. 6).
The new construction contrasts radically with the historic character of the nineteenth
century warehouse, with the other structures it serves, and with the historic district
as a whole. The forms and colors of the new work introduce an appearance
incompatible with the commercial and industrial texture of the district. The entrance
walls and pavilion, constructed at the edge of the property line, are highly visible at
street level and do not relate to the scale and texture of the enveloping district. The
excavation at the rear of the courtyard introduces a level one story below the street,
which adds a further incongruous note.
88-097
In addition, the prominence of the new work serves to diminish the prominence of the
principal historic structure to which it is attached. The effect is that the historic
building seems an appendage to the new entrance pavilion and stairtower rather than
the reverse (see illus. 7). As a result, the project fails to meet the Secretary of the
Interior's Standards for Rehabilitation.
Prepared by: Michael Auer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
facts and circumstances of each case.
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1 and 2. Four-story commercial structure before rehabilitation. Vacant lot and
buildings at the right and to the rear were also part of the overall project.
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88-097
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 88-098
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: CHANGE TO HISTORIC SETTING
Issue: The setting of a historic building can be an important element in defining its
historic character. Setting is defined as the relationship of the historic building to
adjacent buildings and the surrounding site or environment. Standard 2 of the
Standards for Rehabilitation calls for retention of the distinguishing "original qualities
or character of a building, structure, or site and its environment," while the Guidelines
for Rehabilitating Historic Buildings stress the need to retain "the historic relationship
between buildings, landscape features, and open space." This relationship between a
building and its setting can be altered drastically by moving other buildings onto the
site of a historic structure and by the addition of extensive parking lots and other
landscape changes.
Application: A large, finely detailed Neo-Classical mansion, built in 1900 and
representing the wealth of prosperous mill managers and the specific contributions of
its locally significant owner to the community, was listed individually in the National
Register of Historic Places. Although the large lot on which the building stood had
been overgrown in recent years, the character of the house as an imposing suburban
residence on a spacious site had survived (see illus. 1).
In the process of converting the site into an office condominium complex, another
large house, originally located on the adjacent lot with a similar setback and
orientation, was moved to what had been the front yard of the individually listed
building (see illus. 2, 3 and 4 ). The moved building was turned to face the 1900
structure. A parking lot with much enlarged street access, including the addition of
gateposts from the neighboring property, was constructed between the two buildings
(see illus. 5). A second and much smaller building was also moved from the adjacent
property and sited at the rear of the listed building.
Although both of the moved buildings were saved from demolition, their relocation in
the manner shown here has nearly obliterated the historic setting of the 1900
building. That building appears as a subordinate element in a new composition bearing
little relationship to the historic appearance of the property. The central parking lot,
furthermore, has become the dominant feature of the site (see illus. 6). The project
does not meet the Standards for Rehabilitation.
Prepared by: Michael Auer, TPS, and Amy Schlagel, National Register
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
facts and circumstances of each case.
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1. Although the site was overgrown, the character of this 1900 house
as a large suburban residence had survived.
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2. Site plan before rehabilitation began. The 1900 house (A) stood alone on its lot.
On the adjoining property stood another large house (B1) and a dependent cottage (C1).
88-098
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4. Site plan after relocation of buildings. The neighboring house was moved and
turned around (B2) to face the 1900 building (A) across a paved parking lot. The
cottage associated with the moved house was relocated (C2) behind the 1900 building.
88-098
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
—Jashington, D.C.
[-Standards for Rehabilitation
Number: 88-099
Applicable Standards: 2. Retention of Distinguishing Architectural
character (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Architectural Features Based on
Historical Evidence (nonconformance)
Subject: SELECTIVE RESTORATION IN HISTORIC INTERIORS
Issue: When rehabilitating historic buildings, changes that have taken place in the
course of the history and development of a building and that have acquired
significance should be respected. If, however, an earlier period in the history of the
building is clearly identified (in the National Register nomination, for example) as
being the primary period of historical significance, property owners have the option to
restore the building to that period if the restoration can be substantiated by historic,
physical or pictorial evidence. The Secretary of the Interior's Standards for Historic
Preservation Projects defines restoration as "the act or process of accurately
recovering the form and details of a property and its setting as it appeared at a
particular period of time by means of the removal of later work or by the replacement
of missing earlier work." Sometimes a decision is made by an owner to restore
portions of the building to a particular historical period and to rehabilitate the rest of
the structure. As a result, a new appearance may be created that never existed
historically and does not accurately reflect the history and evolution of the building.
Application: A two-story brick structure, constructed in 1839 as an academy was
substantially altered in 1870 and again in 1912 when the building was converted to a
residence (see illus. 1). Prior to rehabilitation as a restaurant, the interior of this
structure reflected its function as a residence of the early 20th century rather than its
original use as a school, with a center stair hall plan, six-panel doors, and bullseye
molding around doors and windows. A one-story hipped roof porch supported by cast-
iron columns dating from 1870 extended the breadth of the facade, and a two-story
brick ell, constructed in 1912 when the academy became a residence, extended from
the southeast corner of the main block. The National Register documentation for the
historic district in which this building is located cited the academy as being important
in the history of education in the town. A decision was made to restore the main
block of the building to its appearance as an academy in the 1870's. While this was
considered an acceptable approach given the building's significance during that period,
the restoration was determined not successful for several reasons.
Features in the main block of the building such as partitions, windows, doors,
fireplaces and trimwork dating from ca. 1912 were removed and replaced with
replications of the ca. 1839-1870 features in their original locations. The twentieth
century center stair (see illus. 2), was removed and replaced with a new stair in an
attempt to further match the original configuration of the academy floor plan. Also
included in this rehabilitation was the replacement of the front door, and the change
in location of the front door and windows to reflect the facade as it appeared between
88-099
1839 and 1870. The ca. 1870 porch, however, was retained and preserved, as was the
ca. 1912 rear ell addition. Although the new stair was based on scattered ghost marks
and fragments of the original stair, there was no evidence of what the original
bannister and newel post looked like, and as a result the new appearance is conjectural
(see illus. 3). Also conjectural is the design of the new front door which was installed
to replace two ca. 1912 doors. The only evidence existing for the front door was three
hinges found near the suspected location of the original door.
Other interior features in the main block of the building were not returned to the
academy period of the structure. A ca. 1912 door with bullseye molding on the first
floor and a ca. 1912 arched opening on the second floor, were retained amidst 1839-
1870 details. In addition, all of the 1839 windows were not reinstalled. On the
interior, window trim applied over recessed plaster panels was installed in the location
of two 1839 windows (one on each floor) to represent their original locations (see illus.
4). Lastly, partitions that had existed on the second floor of the main block from
1839-1912 were not reinstalled, in order to accommodate one large seating area for
the restaurant (see illus. 5 & 6). Because only portions of the main block were
restored, the work was inconsistent, and the rehabilitation failed to return the
signficant main block of the building to its historic appearance as an academy.
Selective restoration in this rehabilitation would have been appropriate if the entire
1839-1870 main block of the building, the significant academy structure, had been
restored, with the rear ell addition (ca. 1912) being retained and preserved as a
representative example of the building's change of use. If evidence did not exist to
accurately restore the building to its academy period, retention and preservation of
the entire structure as a twentieth century residence would have been acceptable.
Prepared by : Camille M. Martone, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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4. Main dining room in first floor of restaurant after rehabilitation. Note ca. 1912 door and molding remain, and ca. 1839 window
hal not peen reinstalled.
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards tor Rehabilitation
Number: 88-100
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
Subject: ALTERATIONS OF FLOOR PLANS AND INTERIOR FEATURES
Issue: In an historic interior, the floor plan, the sequence of spaces, features, and
finishes can be important in defining the overall historic character of the building.
Their identification, retention, and protection should remain a high priority in a
rehabilitation project. Radically changing such elements may result in a loss of
historic character.
Application: A three-story school building, with a four-story central bell tower
constructed in 1886 as the main school for the town (see illus.1), was rehabilitated as
residential apartments. Around 1938 the building had been converted to pocketbook
factory and after 1970 a storage facility. Despite these new uses, the building
retained a high degree of integrity, both on the exterior and interior, and was declared
a certified historic structure for its contribution to a historic district. The original
interior configuration had survived, consisting of a central corridor with a central
freestanding stair (see illus. 2), with four classrooms off the hall on each floor. Two
end towers also contained stairs and provided separate entrances for boys and girls to
the classrooms. Interior trim and detailing that remained intact included beaded
board wainscotting in classrooms and halls, and Eastlake-style window and door
surrounds. (see illus. 3).
In the rehabilitation of the building to accommodate seventeen apartments, the
central-hall plan was obliterated; the central staircase was removed and bathrooms
and apartment units were inserted in the space (see illus. 4 & 5). A new east-west
corridor perpendicular to the original central hall was installed. Further work
included subdivision of classrooms with permanent partitions, furring out the interior
face of the exterior walls, and the subsequent covering of significant amounts of
wainscotting.
The existing floor plan of this building was part of the building's character with the
primary public access to the building through doors in the central tower into a
spacious center hall, which in turn provided direct access to the classrooms. In the
completed rehabilitation, circulation through the interior spaces has been drastically
changed. While the central entrance remains in the same location, access to the
building is now through a narrow corridor rather than a spacious hall. The central
stair leading to second and third floor classrooms has been removed, and the original
four classrooms on each floor have been subdivided. The sense of time and place
associated with the school building and how it functioned historically has been
diminished. There is no trace of the distinctive floor plan or spacious hallway that
once helped define the function and character of this building type.
88-100
Another distinctive feature that was characteristic to this building type was the
panelled wainscotting found throughout the interior. However in the rehabilitation,
the interior face of the exterior walls was furred out and significant amounts of
wainscotting were subsequently covered (see illus. 6). This treatment has caused the
wainscotting to appear fragmented and dis-continuous. The remaining wainscotting
appears to be randomly placed, and together with the significant subdivision of the
classrooms prevents a clear understanding of the original classrooms' design and space.
The rehabilitation could have been successful if the original floor plan had been
retained and incorporated into apartments without extensive alterations. This floor
plan could have lent itself to adaptation to apartments if it had been limited to one
apartment per classroom with the retention of the hallway as a shared lobby among
residents. However, because of the drastic change to the floor plan, the historic
character of the building has diminished, and the important progression or sequence of
spaces through the building, as well as distinctive architectural features were lost.
Prepared by: Camille M. Martone, TPS
These bulletins are issued to explain preservation project decisions made by the U.S
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
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6. Third floor classroom as modified for apartments in rehabilitation.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
liVashington, D.C.
[Standards for Rehabilitation
Number: 88-101
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features
and Craftsmanship (nonconformance)
Subject: REMOVAL OF DISTINCTIVE ARCHITECTURAL FEATURES AND
REPLACEMENT WITH INAPPROPRIATE NEW FEATURES
Issue: Interior features in a historic building that are significant in defining the
historic character and function of a building need to be retained in the process of
rehabilitation. If the interior has been greatly altered over time and documentation
indicates that surviving features are severely damaged or deteriorated, flexibility is
afforded the owner in making further alterations. New features introduced to the
building, however, must be compatible with the scale, design, materials, color, and
texture of the surviving interior features. If on the other hand, original interior
features have remained relatively intact and are important evidence of the building's
history, they should be retained and preserved in situ.
Application: A one-story long and narrow railroad depot with a deeply overhanging hip
roof and double-hung wood windows on all sides, built in 1870 in the Queen Anne-Stick
style, was rehabilitated into a restaurant (see illus. 1). The depot, which was
individually listed in the National Register of Historic Places, had been extensively
remodeled in 1891 and retained a high degree of integrity and architectural character
of that period prior to rehabilitation. Of significance was the structurally and
architecturally intact interior of the depot. Prior to rehabilitation, this modest
structure retained virtually all of its historic fabric, including interior spaces,
features, and finishes. The waiting room, including the original 5-sided ticket booth, a
wooden ceiling with a wide cove cornice throughout, and tongue-and-groove panelling
had survived (see illus. 2 & 3).
The majority of the project work on the building's exterior, including window and roof
repair, was sensitively accomplished; one exception was the construction of an
awkward-looking exterior ramp and fence at the south end. Work on the interior
however, involved incompatible alterations to accommodate seating for the
restaurant. The ticket booth, a distinctive element that contributed to the definition
of the historic function of this train station, was removed and the original ticket
window relocated (see illus. 4). Approximately two-thirds of the plank ceiling and
cornice, features characteristic of the Stick style, were also removed (see illus. 5), to
permit full utilization of the second floor. The Secretary of the Interior's Standards
for Rehabilitation require that distinctive features which characterize a building,
structure, or site be treated with sensitivity. They also require that the removal or
alteration of ary historic material or distinctive architectural features be avoided
when possible. The removal of these intact features and insertion of new
architectural elements greatly impairs the historic character of the structure and
violates the Standards.
88-101
The ceiling of the depot which was removed to install a functional second floor above,
was replaced with new ceiling joists dropped below the original first floor ceiling (see
illus. 5 dt 6). The new unfinished and exposed wood joists are not in keeping with the
character of the previously finished waiting room. Further compromising the room
was the insertion of restrooms and a staircase at one end of the waiting room; two end
windows were obliterated and the distinctive waiting room was reduced by
approximately 1/4 to 1/3. Although some detailing was retained on the interior, it was
extensively reconfigured, and the new features added were incompatible to the
building. As a result, the existing 19th century interior lost its integrity and historic
character.
Prepared by: Camille M. Martone, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of
the Interior's Standards for Rehabilitation, are not necessarily applicable beyond the
unique facts and circumstances of each particular case.
88-101
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2. Interior view of waiting room prior to rehabilitation. Note
wooden ceiling and wide coved cornice.
88-101
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3. Interior view of ticket booth prior to rehabilitation. This
historic feature was removed in the process of rehabilitation.
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4. Post-rehabilitation view of waiting room after the removal of ticket
booth. Note ticket booth window relocated in new stair wall.
88-101
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5. Post-rehabilitation view of waiting room. Note the removal of
existing ceiling, and the addition of exposed ceiling joists above.
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6. Post-rehabilitation view of second floor. Original attic space
converted to restaurant space by lowering the ceiling below.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C. 20240 rStandards for Rehabilitation
Number: 88-102
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (conformance)
6. Repair/Replacement of Deteriorated or
Missing/Features (conformance)
Subject: REHABILITATING PREVIOUSLY ALTERED INTERIORS
Issue: Rehabilitating a historic building in accordance with the Secretary of the Interior's
Standards requires not only that exterior work be carried out with sensitivity, but that
interior treatments also be undertaken with equal respect for those significant character-
defining features which make it distinctive. Generally this means that the rehabilitation
should retain and preserve as much as possible of the original floor plan and spatial
configuration, as well as those interior features and finishes that are important in defining the
overall historic character of the building.
Some interiors are of such significance that they must be retained almost in their entirety if
the building's historic character is to be preserved. However, other buildings, because of
unsympathetic uses or other changes over the years, have been reconfigured on the interior
and no longer contain notable interior features or finishes that must be preserved. When
rehabilitating buildings where rooms have been greatly reconfigured, walls torn out, and doors
and trim removed, the owner is generally afforded some flexibility in making further
alterations.
Application: A three-story, brick rowhouse built in 1893 was rehabilitated for residential use
into three apartments (see illus. 1). Originally constructed as a single-family house, and later
altered for office use, the building was vacant and had already been partially gutted by the
time the new owner purchased it for rehabilitation. The previous owner had removed wall
partitions and, leaving wall studding on the first floor only, stripped the plaster from the
ceiling joists and removed the one remaining mantel, and most of the decorative door, window
and floor trim (see illus. 2-3). The staircase, running from the 1st to 3rd floors along one
wall survived; most of the woodwork which had been removed, had not been thrown away but
was found later by the new owner piled on the third floor. The second and third floors had
been stripped of their wall studding and were essentially open spaces. Although the walls
were gone on the first floor, the studding still remained between what was originally the
front and the rear parlor, and between the front parlor and the stairhall.
The spaces and basic configuration of the stairhall and front and back parlors, were retained
in the rehabilitation, although some of the rooms were converted to new uses necessitated by
the rearrangement of the first floor into a two-bedroom apartment unit (see illus. 4). As part
of the rehabilitation, the double-door-sized opening between the front and rear parlors was
permanently walled-off to provide a bathroom and closets for the apartment. Although this is
88-102
generally not a recommended rehabilitation treatment, in this case it was minimally acceptable
because it did not destroy an original or historic spatial sequence. That had already been lost
when the previous owner removed the walls which had traditionally defined these spaces.
Despite the existing shell-like condition of most of the interior, the new owner restored the
historic staircase (although code compliance necessitated several changes) and repaired and
reused the woodwork and trim that had been removed by the previous owner. Because the
rehabilitation also included a careful restoration of the exterior, which was the major
remaining character-defining aspect of the building through which it contributed to the
significance of the historic district, the rehabilitation was certified.
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the facts and
circumstances of each case.
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I. The exterior of this 1893 brick
rowhouse is its primary character-
defining feature through which it
contributes to the historic district.
FIFftr FLooF, — ' \�` . ..__
_ - .4z 88-102
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2. The interior of the house •�' - --: •..� — i -�� , -, ' "� ,,,
after it had been "gutted" by w`�' z,, ,,1 'k jh "` `' , ` �x '
the previous owner. The ? ? <�� "x -- - '�,; { � • `.'
k r, is fir. '`- v4-. - � ; Fp
photographs of all 3 floors are ' ' — • -, --'- `- - � ^�"' xk.*
taken from the same location on -t`: t` -`�`., .
each floor, and show views �g #' 3 ':' fi
toward the front of the house. .. . � �'''
i t ? aE� '
The new owner was able to °r } t ; . -„e.
repair and reuse wood trim ' _ d ,
(here, shown piled behind the _ '`r
stairs on the third floor), that I L. �== i �
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had been removed by the • :
previous owner. t 1 , a _
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88-102
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FIRST FLOOR
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SECOND FLOOR
3. Floor plans of the interior I+ I'
prior to rehabilitation. The I
fireplaces had been removed II
during previous renovations.
Dashed lines represent open !i II
stud walls. r_
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THIRD FLOOR
4. The redesigned first floor after rehabilitation �I�■
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showing retention of the I �—�
basic spaces and stair-hall M 1� II
configuration. Q
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0 I . OEM aliillui • :21 FIRST FLOOR REHABILITATION
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Intenor's
Washington, D.C. 20240 [Standards for Rehabilitation
Number: 88-103
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Design for New Alterations/
Additions (nonconformance)
Subiect: ADJACENT NEW CONSTRUCTION
Issue: The Secretary of the Interior's Standards for Rehabilitation govern new additions to
historic structures undergoing rehabilitation work. They also apply to new construction
ad iacent to historic structures when the new construction is placed on the same property on
which the historic structures stand. Furthermore, the Guidelines for Rehabilitating
Historic Buildings recommend "designing... adjacent new construction which is compatible
with the historic character of the site and which preserve[s] the historic relationship
between a building or buildings, landscape features, and open space." Adjacent
construction that impairs the historic character of a historic building may render the
rehabilitation project ineligible for historic preservation tax incentives even if the work
completed on the historic structure itself is otherwise acceptable.
Application: A college campus that formerly functioned as a Roman Catholic seminary
was rehabilitated into an extended-care retirement community. Historically the main
structures of the educational complex were aligned across a formal, terraced platform,
overlooking the expansive lawns and playing fields that separated the institution from the
surrounding community. This linear arrangement of the principal campus buildings
conveyed the impression of an institution proclaiming its presence to the world, while
retaining a certain detachment from it (see illus. 1). The overall project included the
conversion of several historic classroom buildings and dormitories into apartment
buildings. As part of the overall, massive project, three new apartment buildings were
constructed, grouped in front of an existing structure (see illus. 2 and 3).
The rehabilitations of all of the historic structures met the Standards for Rehabilitation,
with the exception of a dormitory constructed at one end of the line of principal buildings.
(This building, although constructed in the mid-twentieth century, was determined to
contribute to the significance of the historic district as a physical expression of the
profound changes undergone by the institution in its last decades.) Both by its location and
its shape, the structure serves as a terminus to the row of buildings to which it was added.
The grouping of three newly built structures around the dormitory overwhelms the latter,
severing its visual connection to the row of historic buildings. As a result, the end building
is no longer visible from the main entrance to the campus, from what remains of the lawn,
or from any other principal vantage point in front of the buildings.
88-103
Although the new construction is generally sympathetic to the neighboring historic
buildings in size, scale, color, materials, and design, it fails to meet Standards 2 and 9 of
the Standards for Rehabilitation because of its impact on the site and environment of the
building it obscures.
Prepared by: Michael Auer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
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I. The alignment of the principal structures overlooking a formal terrace, expansive lawns
and playing fields was a principal feature of the historic campus.
88-103
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2. Aerial view of campus. The three new buildings at right visually sever the end building
from the rest of the row, thereby drastically diminishing its historic character.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 88-104
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
5. Sensitive Treatment of Distinctive Features and
Craftsmanship (nonconformance)
Subiect: INAPPROPRIATE EXTERIOR PAINTED FINISHES
Issue: Paint or paint color can be an important factor in defining the character of a historic
building. Painting a building that has never been painted, or removing paint from a building that
has traditionally been painted is never a recommended rehabilitation treatment, because either of
these treatments can change a building's appearance to one that is at odds with its historic
character. Likewise, when repainting a historic building that is already painted, the new color
should generally be close to the original, as well as historically appropriate to the building, and
the historic district in which it is located.
Application: A derelict, two-story, reinforced concrete, stucco apartment building built in 1941
was rehabilitated for apartment use. It is a U-shaped structure entered through a deep central
courtyard, and although quite plain, the building is a characteristic example of the Moderne style
(see illus. 1). The exterior is accented by rather simple architectural details, which include bulls-
eye windows, "eyebrow" window canopies, geometric raised panels, and like many other buildings
in the historic district, features decorative panels of local stone (see illus. 2).
As part of the rehabilitation, the exterior stucco, which had been repaired and patched as
necessary, was painted as the owner himself stated, in a "fanciful and sportive manner." Prior to
rehabilitation, the building had been painted beige with a few of its decorative features
highlighted in a darker brown. After rehabilitation, the wall surfaces of this building had been
transformed by the application of numerous colors and decorative painted and patterned surfaces
(see illus. 3-5). Wall surfaces were painted in alternating horizontal bands of aqua, yellow and
pink, and projecting horizontal overhangs and the raised geometric panels were boldly outlined in
black. Most notable was the use of paint to create contemporary stylized patterning, exaggerated
illusionistic stone textures on door surrounds and above door panels, and a "cracked-tile" pattern
above second-story stairwells and on planters surrounding the base of the building.
This apartment building is typical of the Moderne style, and as such is characterized by simplicity
of materials, flat roofs, horizontal unbroken lines, use of pure colors and honesty of materials. It
is the building's plain, monochromatic wall surfaces combined with only a few simple geometric
decorative features that define its character. The application of these exuberant painted finishes
during the rehabilitation distorted these features so characteristic of the style, thus confusing the
historic stylistic identity of the building.
Consequently, as no evidence was presented to indicate that this type of exterior decorative
painting had ever existed on this particular building, nor indeed on any building located in the
historic district, it was determined that the decorative painted abstract patterns and faux finishes
applied during the rehabilitation were inconsistent with the historic character of the building, and
the historic district. The plain, unpatterned aqua, yellow, and pink colors on the walls were not
considered objectionable, or in violation of the Standards, although it is most unlikely that they
would have existed historically either in such a combination, or in such intense colors.
88-104
In order to receive the tax credits, the owner agreed to paint over the patterned finishes on the
walls in solid white and the planters in solid black, thereby bringing the rehabilitation into
conformance with the Standards and making it consistent with the historic character of the
property and the historic district.
Prepared by: Anne E. Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S. Department
of the Interior. The resulting determinations, based on the Secretary of the Interior's Standards
for Rehabilitation, are not necessarily applicable beyond the unique facts and circumstances of
each particular case.
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1. The primary entrances to this early 1940s Moderne apartment building are
located in the courtyard of the U-shaped structure. Note the overall
plainness of the building before rehabilitation, which is highlighted
only by horizontal banding and raised geometric panels.
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2. The street elevation of the building where patch repair work has already
begun shows the decorative panels of local stone under the second story
windows at either end of the building.
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3-5. After rehabilitation the character of the building has been greatly changed by the
application of a variety of decorative painted finishes, in particular the "faux" stone
surfaces around doors, the contemporary patterned design used above doors and on
balconies, and the "cracked tile" pattern on the planters that surround the building.
n
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Technical Preservation Services interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
[Standards tor Rehabilitation
Number: 88-105
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
4. Retention of Changes Which Have
Acquired Significance (nonconformance)
6. Repair/Replacement of Deteriorated or
Missing Evidence (nonconformance)
Subiect: REMOVAL OF EXTERIOR FEATURES WHICH DEFINE HISTORIC USE
Issue: Even when it is not possible to establish the original appearance of an architectural
feature which has been replaced during the life of a building, the very presence of the
feature in an altered form may be important in understanding the historic function or
historical evolution of a building. According to the Secretary's Standards, if the feature is
deteriorated or does not comply with building codes, all attempts should be made to repair
the feature that exists. Attempts to reconstruct such a feature without physical or
photographic evidence may raise concerns about the appropriateness of a replacement;
however, when the feature has served in the same location throughout the building's
history, and is important to an understanding of the building's historic use, retention or
suitable replacement of the existing feature should occur. Complete removal of the
replacement feature with no effort toward retention would place the project in violation of
Standards 2, 4 and 6.
Aoolication: In the conversion of an 1889 two story, balloon frame building to professional
office space, a highly visible exterior wood staircase which had formerly accessed the
second floor was removed (see illus 1 and 2). The building, located in a district of
residential and small commercial structures, had served as a store on the ground floor with
separate living quarters above. The staircase had originally allowed separate entry to the
second floor, and thus reinforced the functional independence of the two floors.
The existing staircase was constructed within the last fifteen years; no remnant of the
original feature had survived to guide replication and photographic documentation was
unavailable. In view of the Standard's cautions against reproductions which are purely
conjectural, the owner maintained that any attempt to reconstruct a staircase would
misrepresent the original type. Because the narrow width and deteriorated condition of the
staircase made it undesirable to retain, the decision was made to remove the staircase
entirely with no attempt at reconstruction.
The project was determined not to meet the Secretary's Standards for Rehabilitation
because some form of staircase had always served the second floor of the ell and it was felt
that the staircase should have been retained or rebuilt. Furthermore, the staircase had been
cited as a character-defining element representative of commercial vernacular architecture
in the district. Without a staircase to access the second floor of the ell, the historic
independence of the living quarters is no longer evidenced and the ell is represented as a
single unit.
The project would meet the Standards if the staircase were reinstated, thus recapturing the
historic division between the first and second floor living quarters.
Preeared by: Lauren McCroskey, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
88-105
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1. This view shows the exterior staircase in place before rehabilitation. Although this
staircase was a replacement of the original, the feature was significant because it had
remained in the same location and because it announced a separate use and function for
the second floor of the ell.
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2. With the removal of the staircase there is no longer an indication of the second floor's
independence from the first. The two floors of the ell addition appear to be functionally
integrated.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
thington, D.C.
[Standards for Rehabilitation
Number: 88-106
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
9. Compatible Design for New Alterations/
Additions (nonconformance)
Subject: INCOMPATIBLE ROOFTOP ADDITIONS
Issue: When rehabilitating a historic building for a new or continued use, it may be
necessary to expand the historic building somewhat to meet new functional requirements or
to make the project economically viable. New additions to historic buildings located in
urban areas frequently take the form of rooftop additions because of higher property costs
or limited availability of land on which to expand. While it is always preferable to choose
the new use to fit the size of the existing historic building, the Standards allow the
construction of new additions if they do not destroy significant historic or architectural
fabric, and if their design is compatible with the size, scale, color, material and character
of the property and the neighborhood. Compatible rooftop additions should be subordinate
to, and clearly differentiated from, the historic building; not all historic buildings can be
enlarged in a manner that is consistent with the Standards, whether for reason of size,
siting or location within a historic district. The Guidelines for Rehabilitating Historic
Buildings recommend that new rooftop additions be designed so that they are
inconspicuous from the public right-of-way, are set back from the front wall plane of the
building, and do not damage character-defining features of the historic building. A
proposed rooftop addition that violates any of these principles generally would not meet
the Standards.
Application: A small, two-story commercial building originally constructed in 1891 as a
law office was rehabilitated for residential use. Located on a hill in the business district
of a small rural town, this semi-detached brownstone structure almost completely covered
its building lot, and its unattached side wall abutted a steep hill, with space for only a
narrow service walkway providing access to the rear of the building (see illus. 1). Despite
the fact that the entire two floors of the building were utilized for its conversion into a
single-family residence, the owner felt that the existing space was inadequate, and
accordingly engaged the project architect to design a new rooftop addition. The new one-
story addition, approximately 10' x 16', was clad in wood and featured a large brick
chimney on the primary elevation. Although set back more than halfway from the front of
the historic building in an attempt to minimize it, the new addition is still highly visible
within the historic district (see illus. 2-3). This is due in part to its size which is almost
one-half the size of the historic building, as well as to the fact that the building itself is
highly visible within the town and historic district because of its location on a hillside.
88-106
Because the rooftop addition is too large, and its proportions too heavy for such a modest-
sized building, the rehabilitation was denied certification. (The new awning over the front
door was also cited as violating the Standards because its size and proportions intrude on
the simple classicism of the facade.) While the rooftop addition is not particularly
noticeable from many points within the historic district, it is very visible from the main
intersection nearby. It is also extremely visible from the historic district boundary up the
street from the building. This is the first impression one receives of the historic district
when entering the town from this point, and it includes an important scenic view which
encompasses much of the district as well as the river and hills beyond.
Prepared by: Anne Grimmer, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
88-106
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separates the building from the steep hill that abuts it
on the right.
88-106
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Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
7Washington, D.C.
rStandards for Rehabilitation
Number: 88-107
Applicable Standards: 2. Retention of Distinguishing Architectural
Character (nonconformance)
3. Recognition of Historic Period (nonconformance)
6. Repair/Replacement of Deteriorated or Missing
Features Based on Historic Evidence
(nonconformance)
Subject: ADDING DETAILS WHICH MISREPRESENT A BUILDING'S HISTORIC
APPEARANCE
Issue: Owners are often tempted to embellish simple, unadorned facades with high style
details, or features borrowed from a different building epoch. If architectural details are
added to a facade it is necessary to establish that the features existed together historically
on the facade. Undocumented and conjectural changes create a false sense of historical
development and are contrary to the Secretary's Standards for Rehabilitation.
Application: In a historic district of vernacular wood frame dwellings, the main facade of
a small, single story, simply detailed 1900 building was elaborated with details suggesting
the Greek Revival style (see illus 1.) Triangular pediments were added to the window
heads, and simple turned posts were replaced with square, Doric posts (see illus 2.) The
resultant changes undermined the vernacular simplicity of the Victorian structure.
Although buildings within the historic district built about the same time were fitted with
Greek Revival details, they were without exception larger, more imposing structures. No
other authentic examples of modest, similarly adorned structures could be found. However,
even if such examples could be cited, the evidence would not prove that this building ever
had these particular features.
The use of unprecedented details on this small facade is also historically and visually
improper because the proportions of the new features create awkward junctures with the
existing cornice. For example, the capitals of the posts are improperly scaled and project
beyond the gable soffit (see illus 3.) The building's new presentation as a Greek temple is
also unsuccessful due to the lack of entablature and requisite Classical cornices and
moldings that would normally be found in the overlying gable of a true Greek Revival
building.
It is not advisable to impose a new stylistic identity onto a facade since attempts will most
likely confuse the historic appearance of the building. Although an exterior of any size
may lack elaborate detailing and texture, it is important to retain the simplicity which
defines the building, realizing that historic character may be expressed only by the few
modest details that exist. In this example, violation of the Interior's Standards occurred
because the added decorative features caused the removal of historic materials and because
the building was given an appearance conflicting with its historic one. By removing the
added features and reinstalling the original posts, the visual appearance of the porch and
windows can be readily retrieved.
Prepared by: Lauren McCroskey, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, arc not necessarily applicable beyond the unique
facts and circumstances of each particular case.
88-107
Wk. •, �i' 1. Simple turned posts and plain windows
� Y • A a . were the only expressive details of
1� . . , :,•. _ ,`;�'; the vernacular frame building.
ort
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2. The dramatic shift in appearance from a vernacular
structure to a higher style building is achieved
with Greek Revival posts and triangular window
pediments. The building was not originally fitted
with these details, nor is there any occurrence of
these features on a facade of this size within the
district.
88-107
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3. Not only have the added features created a
non-historic appearance for the facade, but
the size of the new capitals does not conform
to the narrower dimensions of the overlying
gable and causes an awkward overlap of the
cornice. Compare with the photograph taken
before rehabilitation which reveals the
compatible proportions of the turned posts and
the gable it supports.
Technical Preservation Services Interpreting
Preservation Assistance Division
National Park Service
U.S. Department of the Interior the Secretary of the Interior's
Washington, D.C.
rStandards for Rehabilitation
Number: 88-108
Applicable Standard: 2. Retention of Distinguishing Architectural
Character (nonconformance)
Subject: INAPPROPRIATE DROPPED CEILINGS
Issue: Dropped ceilings are often installed in historic buildings to cover up materials in
need of repair, to reduce energy costs, and to provide an enclosure for HVAC ducts and
lighting. However, they are generally not appropriate for historic buildings.
Contemporary dropped ceilings can diminish the architectural character of a building in a
number of ways. First, they often destroy or obscure architectural ornamentation.
Decorative details such as plaster cornices, ceiling medallions, and picture molds are
frequently removed or damaged during installation of dropped ceilings, while other
historic features such as exposed beams are simply concealed. Lowered ceilings can also
have the effect of altering and, in many cases, radically changing room proportions. After
a dropped ceiling is inserted, doorways, windows, and other openings can appear to "crowd
the ceiling." Finally, since dropped ceilings are often visible from the outside, they can
also adversely affect the exterior of the building as well as the interior.
In some cases, however, lowered ceilings may be acceptable: where distinguishing historic
features and details would not be lost, where altering room proportions does not change the
building's overall historic character, and where the new ceilings do not extend so close to
windows as to be prominent from the exterior.
Annlication: The subject building is a ca. 1890 two-story brick residence located in a turn-
of-the-century residential and commercial historic district. In converting the residence
into three floors of offices, the owner introduced dropped ceilings in the all primary spaces
on the first floor with the exception of the central hall.
Originally, the house featured generous 12' unornamented plaster ceilings on the main floor
(see illus. 1), an important characteristic of its age and style. To conceal a new HVAC
system, dropped ceilings were installed at a height of 10'. (Typically, the HVAC would be
installed in the basement of this building type, but the owner elected to use it for office
space, and existing headroom was already limited.)
The contemporary ceiling installed drastically diminishes the historic appearance of the
primary rooms (see illus. 2). The fluorescent lighting, dark grid lines and uneven texture
of the acoustical tile are not consistent with the building's historic character. It assumes a
visual prominence lacking in the original.
88-108
The project did not retain the architectural character and therefore failed to meet the
Standards for Rehabilitation. In this particular case, there was no permanent damage to
the historic materials, so the rehabilitation could potentially meet the Standards if the
owner were to install a plasterboard ceiling more consistent with the original room
proportions, preferably at the minimum required clearance for the HVAC system. One
method to better integrate HVAC systems is the use of wall and ceiling chases. Failure to
minimize the impact of the HVAC system and dropped ceiling may violate Standard 2.
Prepared by: Michael Auer and Neal A. Vogel, TPS
These bulletins are issued to explain preservation project decisions made by the U.S.
Department of the Interior. The resulting determinations, based on the Secretary of the
Interior's Standards for Rehabilitation, are not necessarily applicable beyond the unique
facts and circumstances of each particular case.
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1. The only primary space on the first floor left 2. This view shows the distracting metal grid and
unaffected after rehabilitation was the central ceiling illumination of the new dropped ceiling.
hall, shown here with its original ceiling height
and column divider.
CUMULATIVE INDEX
Volume 1: 001-043
Volume 2: 044-075
Volume 3: 076-108
Abrasive Cleaning
009, 039
Additions to Buildings
See Also: Greenhouses
New Construction, Adjacent
Storefronts
Demolition of Additions
016, 018, 045
New Additions
010, 022, 026, 027, 028, 034, 037, 045, 051, 058, 072, 075, 079, 085, 091, 095, 097
Rooftop Additions
034, 048, 051, 060, 071, 074, 083, 106
Administrative Issues
See: Previous Owner
Air Conditioning
014
Aluminum Siding
See: Artificial Siding
Arcades
030
Artificial Siding
005, 006, 070
Atrium
048, 093
Awnings
079, 106
Balconies
See Also: Porches, Galleries
048, 077
Brick
Mitigating damage of abrasively cleaned masonry
009
Painting previously unpainted brick
011, 029
Removing interior plaster to expose brick
013
Brownstone
See: Sandstone
Building Codes
032, 037, 059, 081
Ceilings
See: Interior Spaces, Alterations
Chemical Cleaning
063
Cleaning, Damaging Methods
See: Abrasive Cleaning
Chemical Cleaning
Codes
See: Building Codes
Complexes
Sec: Demolition, Buildings within complexes
Courtyards
097
See Also: Atrium
Cupola
078
Decks
See: Porches
Demolition
See Also: Interior Spaces and Features, Alteration
Buildings within complexes
012, 041, 043
Demolition/alteration of non-original features that have achieved significance
016, 018, 027, 041, 073
Significant fabric and features
032, 039, 048, 072, 076, 082, 084, 093, 100, 101, 105, 107
Deteriorated Buildings, Features and Materials, Repair versus Replacement
029, 031, 038, 040, 042, 043, 054, 055, 056, 064, 067, 069, 086, 087, 088, 089, 090
Doors and Entrances
See Also: Interior Spaces and Features, Alteration
New
029, 047, 049, 050, 077, 094, 097
Removal or replacement of entrance
004, 015, 025, 032, 045, 049, 050, 061, 067, 085, 105
Elevator
059
Entrances
See: Doors and Entrances
Environment
See: Setting
Exterior Surfaces
See: Artificial Siding
Brick
Paint, Removal of
Replacement Materials
Sandstone
Wood
False Fronts
See: Surface Material, Nonhistoric
Fireplaces
See: Interior Spaces and Features, Alteration
Floor Plans, Changes
019, 020, 026, 051, 054, 065, 076, 080, 081, 082, 084, 092, 093, 100, 102
Galleries
See Also: Porches
New construction
008, 078
Gardens
See: Setting
Greenhouse Additions
007, 022, 045, 091
Historically Inappropriate Alterations and Additions, Construction of
See Also: Brick, Removing interior plaster to expose brick
004, 005, 008, 018, 024, 029, 078, 085, 107
Insulation, Urea-formaldehyde Foam
023
Interior Spaces and Features, Alteration
See Also: Floor Plans, Changes
017, 019, 020, 024, 047, 054, 059, 065, 066, 076, 080, 081, 082, 084, 093, 099, 100, 101, 102,
108
Light Shaft
081
Limestone, Replacement
055
Moved Building
098
New Construction, Adjacent
See Also: Additions to Buildings
Greenhouses
Historically Inappropriate Alterations
Infill Construction
Porches
Roof Alterations
Setting
Storefronts
002, 095, 103
Paint
See Also: Abrasive Cleaning
Inappropriate Decorative Schemes
104
Mitigating damage to exterior by painting
009, 042
Painting previously unpainted surfaces
011, 029
Retention of unpainted surfaces after paint removal
036, 039
Pedestrian Bridges
075
Plan, Changes to
See: Floor Plans, Changes
Plaster, Removal of
See Also: Interior Spaces and Features, Alteration
013
Porches
See Also: Galleries
Addition of decks and porches
094, 096
Alteration/Demolition
006, 018, 033, 039, 044, 054, 072, 073, 078, 085, 107
Enclosures
001, 033
Previous Owner, Project Work Undertaken by Previous Owner
001, 102
Rear Elevations
See: Secondary and Rear Elevations
Regulations, Project Work Undertaken Prior to Issuance of
018, 028
Replacement Materials
See: Artifical Siding
Brownstone
Doors
Limestone
Roofing
Sandstone, Replacement of
Windows
Wood
Reversibility
079
Roof Alterations
See Also: Additions, Rooftop
031, 038, 051, 078, 079
Sandblasting
See: Abrasive Cleaning
Sandstone, Replacement
040, 056
Secondary and Rear Elevations, Changes to
033, 049, 050, 072, 085, 091, 094
Selective Restoration
078, 096, 099
Setting
002, 068, 095, 097, 098, 103
Siding
See: Artificial Siding
Wood, Replacing clapboarding with shingles
Site
See: Setting
Skywalks
See: Pedestrian Bridges
Stairs and Stairtowers, Exterior
037, 083, 097, 105
Standards for Evaluating Significance Within Registered Historic Districts
064, 070
Standards for Rehabilitation, Secretary of the Interior's
Standard 1 (Compatible New Use)
020, 028, 033, 047, 053, 065, 066, 077
Standard 2 (Retention of Distinguishing Architectural Character)
001, 002, 003, 006, 011, 012, 013, 014, 015, 017, 019, 020, 021, 022, 023, 025, 026, 028,
029, 030, 032, 033, 036, 039, 041, 043, 044, 045, 047, 048, 049, 050, 051, 052, 053, 054,
055, 056, 057, 058, 059, 060, 061, 062, 065, 066, 069, 071, 073, 074, 075, 076, 077, 079,
080, 081, 082, 083, 084, 089, 090, 092, 094, 095, 097, 098, 099, 100, 101, 102, 103, 104,
105, 106, 107, 108
Standard 3 (Recognition of Historic Period)
004, 005, 006, 008, 010, 024, 029, 046, 054, 055, 056, 061, 085, 096, 107
Standard 4 (Retention of Significant Later Alterations/Additions)
012, 016, 018, 025, 027, 031, 041, 043, 053, 054, 061, 062, 073, 078, 096, 105
Standard 5 (Sensitive Treatment of Distinctive Features and Craftsmanship)
011, 014, 017, 020, 025, 029, 032, 033, 047, 048, 053, 054, 058, 059, 062, 065, 073, 080,
082, 084, 089, 090, 093, 100, 101, 104
Standard 6 (Repair/Replacement of Deteriorated or Missing Architectural
Features Based on Historic Evidence)
013, 015, 029, 031, 032, 035, 038, 040, 042, 046, 049, 052, 054, 055, 056, 057, 059, 061,
065, 067, 069, 072, 073, 078, 082, 084, 086, 087, 088, 089, 090, 096, 099, 102, 105, 107
Standard 7 (Cleaning with Gentlest Method Possible)
009, 039, 063
Standard 8 (Protection/Preservation of Archeological Resources)
Standard 9 (Compatible Contemporary Design for New Alterations/Additions)
001, 003, 007, 010, 014, 022, 028, 030, 031, 034, 037, 045, 046, 048, 049, 050, 051, 058,
060, 065, 066, 067, 071, 072, 074, 075, 079, 080, 083, 085, 091, 092, 095, 097, 103, 106
Standard 10 (Reversibility of New Alterations/Additions)
026, 037, 047, 048, 051, 066, 079, 080
Storefronts
003, 004, 027, 030, 049, 050, 053, 061, 062, 067, 070, 073
Streetscape
075, 097, 098
Stucco
040
Surface Material, Nonhistoric
005, 070
Timing
See: Project Work Undertaken Prior to Issuance of Regulations
Vinyl Siding
See: Artificial Siding
Windows
See Also: Storefronts
Alteration/Demolition
015, 031, 032, 046, 048, 075, 107
New openings
050, 077, 094
Replacement
021, 029, 035, 046, 052, 057, 086, 087, 088, 089, 090
Wood
Abrasive cleaning
039
Removing interior woodwork
017
Removing paint from previously painted wood
036, 039
Replacing clapboarding with shingles
042