[O]pponents [of the creation of a new historic district] became increasingly vocal, warning that landmark status would … subject residents to ‘the preservation police.'”–Ellen Barry (2007)
Those of us who have worked as staff supporting historic preservation commissions have certainly had the pejorative term of “preservation police” hurled at us by members of the public. Few people seem to love us or our commission members, but why? I don’t think the answer has any basis in a claim that people don’t want places conserved; there is ample evidence that this simply is not the case. Rather, I think an important reason lies in the fact that that local governments cannot give a good answer when asked why certain processes are required.
In the US, most built heritage conservation activity is driven by the requirement for local design review via historic preservation commissions (HPCs), historic district commissions (HDCs), landmark preservation commissions (LCPs), or other similarly named bodies. Typically, a local municipality will have an historic preservation ordinance that requires certain changes to buildings, or less commonly, landscapes, to be reviewed by a commission whose members are citizens appointed by some combination of a mayor or city council. Certain buildings or areas (e.g., historic districts) of a town are required to go through a “design review” process in which these commission members review whether or not proposed changes are appropriate or not based on certain criteria. Ostensibly, the reason for design review is to preserve the historical authenticity or character of older buildings or places.
More often than not, the criteria that these commissions use to review changes to buildings or places is based on a document called the “Secretary of the Interior’s Standards for Rehabilitation“, often shortened to the “Standards”. W. Brown Morton, III wrote most of the Standards in 1976 for use by the National Park Service (NPS) in the new historic preservation tax credit program. The Standards are involved in local design review in the following two scenarios:
- The preservation ordinance requires the use of the Standards, referencing it or copying it verbatim into the ordinance, sometimes with a few, minor changes; in some cases most of the verbiage of the Standards is in the ordinance, but is not referred to by name.
- The preservation ordinance requires the use of “design guidelines”; the Standards are referenced in these guidelines, or copied verbatim, sometimes with a few, minor changes; in some cases most of the verbiage of the Standards is in the guidelines, but is not referred to by name.
As I see it, the heart of the issue with Standards-derived design guidelines, even if they are left as broad or broader than the original iteration, is that neither preservation commissioners nor many staff to HPCs can explain why they are so important to safeguarding the authenticity of an historic district. In HPCs I’ve worked in and observed, the evidence provided by staff and commission members usually resolves to arguments from authority: we can’t explain exactly why standard 9 is good, but because it’s in the Standards we need to follow it. Surely the NPS knows what’s right.
So is it so surprising that the public reacts negatively to the design review process?
When cities adopt sustainability guidelines, the public asks why and gets empirical data back: because the planet’s carbon dioxide content is increasing; because our landfills are overflowing; because reuse of buildings reduces development pressure. When a member of the public asks why the HPC uses the Standards, the answers again refer to authority or are simply tautological (i.e., self-referential or saying the same thing twice): because the NPS uses it; because our ordinance requires it; because it preserves the integrity/authenticity of buildings. If the lack of a clear answer makes staff and commission members uncomfortable, why should the public react any differently?
Keep in mind that the Standards, which spawned only a few design guidelines in the 1980s that were then copied (or perhaps more accurately described as plagiarized) en mass by HPCs across the country was never intended for local design review. HPCs uncritically adopted the Standards directly or permutations thereof mostly because there weren’t any other guidelines available. The only thing available to fall into the vacuum was the Standards, and it did so rapidly.
Backing up, the Standards was based on something called the Venice Charter, written by a small group of white, mostly European, men, in the 1960s in a meeting in Italy. Diverse perspectives were definitely not considered, nor was any empirical evidence given to back up any of the claims that doing “x” activity indeed conserves the authenticity of a building or place. It was just taken for granted that the ideas in the Venice Charter must be correct because they represented the way preservation architects thought things should be done in 1964. In essence, the authors of the Venice Charter simply thought it was the “right” thing to do because it reflected accepted practice. Salvador Muñoz Viñas (2005, p. 43) clarifies that theory contained in the Standards and the Venice Charter, “lacks a logical basis; conservation is what conservators recognize as such. Thus, it is defined as it is performed, and its use and repetition is what allows us to know and understand it.” It is worthwhile to step back and really understand what Muñoz Viñas is saying here: any assumption that the Standards are predicated on logic and scientific principles is flawed. This conclusion ought to have profound implications for practice, but the field has instead long chosen to be complacent on the ramifications of basing design review on a fundamentally unscientific platform.
Interestingly, the primary author of the Standards — W. Brown Morton, III — has publicly said that he regrets writing the Standards and believes that it has become too rigidly and widely applied outside of its original context.
Today we are still using guidelines based on 50-year old ideas without empirical evidence backing up their use. So, when commission staff and members cannot exactly explain why a specific standard is “better” using evidence, it’s because there was no evidence in the first place. Just because the Standards exists does not mean it can be justified as the best tool for a particular goal. There’s nothing wrong in critically examining the relevance of a 50-year old doctrine and its applicability in a pluralistic, multicultural twenty first century. Surely we can do better.
One would think that the NPS might be interested in acknowledging and addressing their unanticipated role in creating and perpetuating these issues, but even with repeated calls for the NPS to revisit the Standards, no actions have been taken.
Barry, Ellen. (2007). “Area of Sunnyside, Queens, Is Given Landmark Status”. NY Times, June 27.
Muñoz Viñas, Salvador. (2005). Contemporary theory of conservation. Oxford, UK: Elsevier Butterworth-Heinemann.