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Historic Resource Impact Studies Part 2

Part one of our blog about Historic Resource Impact Studies described what they are. Part two discusses what the applicant and the municipality should expect. Expectations can differ greatly. The preparer, who is usually retained by the applicant but must abide by the provisions of the ordinance, can be caught in the middle, sometimes with his or her professional reputation on the line.


Applicant Expectations: Most applicants (usually a developer) would prefer not to produce an impact study. It is one more thing they must to do in the land development process, and it can be “expensive” (actually the Impact Study cost is miniscule compared to legal and engineering costs, not to mention construction itself). Most developers would like you to draft the report and simply agree with them. The fact is that what they would like to do sometimes runs contrary to a municipality’s efforts and legal framework to preserve its historic resources.


Recommendation: Start early. Often developers bring in the preservation planner at the last moment, after tens of thousands of dollars of engineering and legal fees have already been spent. This can sometimes negate reasonable options of addressing the property’s historic resources. Sometimes the plans are “set in granite” and the developer does not want to hear about alternatives, which may require extensive (and costly) rework of the plans. Had the applicant retained the preservation consultant early in the process, thereby allowing the consultant to bring ideas to the table early on, drafting the Impact Study could have been much easier.


Here’s why: Let’s say the applicant wishes to demolish a historic building. He draws up plans and presents them to the local planning commission. The commission will make comments and may sign-off on the plan. At that point the applicant, thinking all is well, hires the preservation consultant to draft the Impact Study. The consultant may dislike the plan (particularly the demolition) and knows the historical commission will probably not recommend it.


Now we have a problem. Whereas a land use lawyer will fight for his client’s legal rights regardless of the plan (within reason, I assume), the consultant must look at design alternatives which could save the resource. Not only may the applicant not want to consider these alternatives, but may not want them included in the Impact Study.


I tell applicants: don’t expect Wise Preservation to be a “yes man”. Historical Commissions see right through that and not only will they not accept the Impact Study, but it will put “egg on the face” of both applicant and consultant. We recently witnessed a historical commission publicly chide a well-known consultant for losing his objectivity. Maintaining our professional reputation is very important for us, since historical commissions often recommend us when an applicant is looking for a consultant. Commission members should expect a fair and reasonable evaluation of the proposed plan. They are usually savvy individuals that have seen many examples of the impacts – good and bad – of development projects on historic resources. They will know if the consultant is just trying to “sell” the project for the applicant. Applicants should expect a critical and thorough analysis.


Historical Commissions need to understand that improperly drafted Impact Studies may leave many recommendations “off the table” or undervalue the resource in question. Read the study carefully, evaluate whether the resource is “significant” based on its history and architecture. Was the consultant unaware of important information? Minimizing the resource’s significance will “cheapen” the product… and an experienced Historical Commission will know and may even reject it. Are the recommendations complete and detailed? As I have told several historical commissions who may think I am biased because I am getting paid by the applicant: Unlike the developer’s architects, engineers, landscape architects, and lawyers who have a long-term vested interest (ongoing billable time) in the project, my job is complete after we make our presentation. As a preservation planner, obviously I hope my recommendations are accepted by both applicant and historical commission and I hope the historic resource is not adversely impacted.


Within reason, it is better for the applicant to openly address each recommendation. Historical Commissions should always be prepared to ask additional questions not be afraid to make additional recommendations beyond the Impact Study. I have heard many fine and creative recommendations from commission members that we, quite frankly, did not think of.  Commissions should be prepared to ask specific questions and make specific requests. For example, if the consultant recommends vegetation to buffer a historic resource from new development, the commission should ask specifically what kind of vegetation, its appearance, size (now and full-grown) and whether it’s indigenous, etc. The applicant should be prepared to provide this information. If everyone is in agreement, the municipality obviously must make sure it gets on the plan and ultimately is part of the landscape construction.


The bottom line: Both applicants and Historical Commissions should expect a professionally researched, written and presented report that fully addresses all provisions of the Historic Resource Impact Study ordinance. The report should fully analyze the significance of the resources and the potential impact of the proposed project on those resources. Its methodology should be clearly spelled out. The applicant should be expected to “defend” against unfavorable recommendations and – where possible – accept recommendations that are favorable to the resource. The consultant should not feel “pressured” by the applicant to suggest something against his or her professional judgment (let the applicant do that), but should understand the limitations of the site, zoning, neighbors, etc. Finally, back to the historical commission, don’t just take what is written, no matter how well researched or presented. Critically analyze it. Look for “opportunities” that may have been missed. And ask questions. Many questions!

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Historic Resource Impact Studies (Part 1)

One of the most exciting parts of our work is preparing Historic Resource Impact Studies. Impact Studies are required by many municipalities in Southeast Pennsylvania when a land development application is proposed for a property containing a historic resource (usually identified in a Historic Resource Survey) or within a certain number of feet of a historic resource. The general goals of impact studies are to encourage the preservation and reuse of historic resources and to foster a dialogue between the applicant and the municipality.

Impact Studies are usually prepared by qualified historic preservation professionals, such as Wise Preservation Planning. They should be written by someone who meets the federal guidelines for architectural historians (48 FR 44716 and 36 CFR 61). They are based on engineering plans and sometimes architectural renderings as presented by the developer. The process is usually overseen and reviewed by the municipality’s Historical Commission. For the developer, it is best to retain a consultant with experience dealing with all participants (applicant; the applicant’s project team – attorney, engineer, land planner and architect; adjacent land owners – if applicable; and the municipality). Wise, for example, is often recommended to a developer by the municipality; however, the developer retains Wise for the project.

Impact Studies accomplish three specific goals:

1) They document the history and significance of the historic resource. Impact Studies begin with a site survey and inspection to identify the historic resources involved. Photo documentation and measured drawings are usually prepared for any resources planned for demolition. Thereafter, the history of the property is researched. Information from the site visit and history are used to develop a statement of signficance for the historic resources.

2) They determine the level of potential adverse impact of the development on the resource and its setting. One of the main purposes of an Impact Study is to protect historic resources and their settings (sometimes called the “heritage zone”). The consultant considers the proposed plan and how it will impact the historic resource. Wise developed the scale of impact that is used by many municipalities in southeastern Pennsylvania for impact studies, which we will discuss in a later blog.

3) They recommend measures to mitigate any adverse impact. Some recommended changes may be minor, such as vegetative buffers; other mitigation recommendations may explore plan alternatives, such as road locations, building siting, and parking design.

Impact Studies go through two review stages. After completing the first draft, Wise submits the draft impact study to the applicant. Applicants need to weigh the impacts and recommendations, as on occasion a recommendation is not feasible for reasons unknown to the preparer. Often the applicant is able to amend the plan in response to the impact study and thus offer a preferable plan to the historical commission. Once the applicant has approved the text, the final, revised version of the impact study is submitted to the municipality, usually to a Historical Commission. It is very important for the municipality to carefully review each study and ensure that all bases are covered, meaning that all impacts are carefully considered and mitigation explored. For their part, applicants need to be able to “defend” their plans against Impact Study recommendations; Impact Studies are rarely “rubber stamp” approvals of plan (though many plans do create very low level impacts and thus make only minor mitigation recommendations). The Commission usually makes its recommendations to the Governing Body based on recommendations in the Impact Study or as a result of subsequent discussions.

Wise has been involved in all aspects of the impact study process. We have assisted several municipalities in drafting their historic resource protection ordinance, including language for impact studies. Wise has completed scores of Impact Studies or related plan reviews throughout Southeast Pennsylvania, virtually setting the standard for all aspects of the process. On occasion, we have been asked to consult with a historical commission in the plan review of applications drafted by other firms.

Our projects vary. We have examined the impacts of simple subdivisions, the construction of new retail plazas, to large residential developments containing several hundred units. We have consulted on the adaptive reuse and development of estate properties, and conversely the demolitions of high profile buildings such as Lower Merion Township’s historic “La Ronda” mansion.

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