DC's next landmark? Image by HPO.

DC's historic preservation office continues to march forward with designating properties as historic. But is anything not historic? Recent cases, and conversations with preservationists, leaves no real clarity about whether there are any bounds to preservation.

Preservation staff have recommended designating a row of unremarkable homes on Harrison Street, near Friendship Heights, as a landmark over the objection of the property owners and the local Advisory Neighborhood Commission, ANC 3E. Eric Fidler recently explained why this landmark application is dubious at best.

The Historic Preservation Office (HPO) has also been promoting historic districts for Kingman Park and Bloomingdale over strong community opposition (and some strong community support), landmarked a Pepco substation (also on Harrison Street) over the opposition of the local ANC and criticism from Pepco, and landmarked the old Fannie Mae headquarters which the owner (and ANC) supported but which Amanda Kolson Hurley argued would “dilute historic preservation.”

I think historic preservation can play a valuable role in land use, and I live in a historic district myself. But I don't see the preservation office willing to reckon with the fundamental question about whether everything, regardless of merit, ought to be historically designated, or how to balance preservation against other needs.

A public comment period on a revision to DC's preservation plan ends March 1. That plan doesn’t address this question either. Instead, the preservation office pats itself on the back for all its work trying to find ever more historic landmarks.

Is anything not historic?

DC has more historically-designated properties than Boston, Chicago, and Philadelphia combined – three unquestionably history-infused cities.

The criteria for landmarking do not require that a structure be particularly exemplary — just that it be “associated with events that have made a significant contribution to the broad patterns of our history” or “embodies the distinctive characteristics of a type, period, or method of construction.” The mayorally-appointed volunteer Historic Preservation Review Board has to find that it is “significant,” but that, too, is a very squishy term.

It's clear that sometimes, the motivation of those seeking landmark protection is more about blocking development than honoring history. For instance, there has been a landmark application pending for years for the adjacent WMATA bus garage. There's a strong reason to believe many neighbors backed that landmark application to try to prevent redevelopment into denser housing and/or offices in this block right at the Friendship Heights Metro, and a good likelihood that was part of some landmark proponents' motivation for these Harrison Street buildings as well.

I do believe that Kent Boese, the Columbia Heights ANC (1A) chair and historian who nominated the Pepco substations, is doing so for history and not NIMBYism. At the hearing on the Harrison Street Pepco substation, he said he thought a few stations should be landmarked, but not all. In a subsequent email, he explained his thinking. “To me, there are two things that the nominations need to do. The first is to recognize that the structure, itself, is an excellent and/or unique example of what Pepco was doing with their structures at that time. The second is that each structure needs to be part of the larger narrative of Pepco's history.”

Boese does tell an interesting story about how Pepco designed various stations to blend into the surrounding architecture. But a broader concern, with so many landmark applications and especially so many in exclusionary Tenleytown, is that almost any building tells the story of something. Is every story, about everything, worth preserving? And does that mean, eventually, that almost everything in DC is preserved?

Can we tell the stories of interesting historical events without freezing the associated buildings in amber forever? Preventing change doesn't inherently educate the public about the stories behind the buildings.

Harrison Street Flats remain dubiously “significant”

In the case of the Harrison Street apartment buildings now being considered for nomination, HPO's justification for recommending the landmark is that they “give insight into how the city addressed [the] challenge” of “production of adequate housing” in the 1930s. These aren't the first or most architecturally significant example of this, though the report says they're a bit unusual in that they are “a good example of a block-long group of flats serving as a transition from commercial to residential” and located “in a prosperous section of the city developed almost entirely for single-family detached housing.”

The report says, “Its location here shows that affordable housing was needed in all sections of the city.” Ironically, landmarking these buildings likely makes it more difficult to create future affordable housing on the block, and at least some nomination supporters very much hope to exclude development with greater density, density which can help pay for more affordable housing or include it on site.

The HPO report does not seem to recognize this irony. In an op-ed on the nomination, Rebecca Miller, head of the DC Preservation League, notes that the apartments now sell for $750,000 each. She argues that new units also likely aren't so affordable, but makes no proposal about how to create housing which is and how that fits in, if at all, with her group's effort to preserve ever more (expensive) buildings.

One of the buildings in the row, in fact, was already expanded into an eight-unit building. The owners of some others would like to retain the ability to do the same. At a February 22 hearing, HPRB heard strong opposition to landmarking from the property owners, and will continue the hearing on Thursday, March 1.

Image by HPO.

The HPO says it's clarifying historicity by… just nominating more stuff

At the Pepco hearing, David Maloney, head of HPO, also said he thought several Pepco substations should be preserved, but not all. I asked him in an email if HPO has recommended against landmarking anything, and how they might draw a line between what should be historically designated and what should not be.

He didn't answer my question about whether he wouldn't landmark anything, though he did elaborate a bit on their criteria for naming something “significant.” He said, “Judgments about significance are … based on a preservation planning methodology that emphasizes the use of data and research that provides historical context for making a decision. We support HPRB with our professional expertise and access to this information. For more about this methodology, see the National Register bulletin on how to apply designation criteria.”

HPO has undertaken a number of studies to identify properties that might be eligible for designation, prepared ward heritage guides for several wards, created National Register “multiple property documentation forms” about “properties related to a historical theme” like this one on telecommuncations, reviewed DC government properties to identify historically eligible ones, and more.

Maloney pointed to the office's draft 2020 preservation plan (which is open for public comment until March 1) which, he said, describes “how we propose to expand awareness of potential historic properties and further improve the designation process.”

What's not historic, though?

The ward guides, 2020 preservation plan, and other documents all share a common theme: they talk about what is historic and do not talk about what is not. They talk about assisting communities in identifying why properties are historic and not about clarifying why some may not be.

For instance, objective A3 in the preservation plan says, “Conduct an understandable designation process with clear priorities that promote predictability for owners and communities.” But the actions it lists are all about surveying historic resources, identifying historic properties, and nominating them.

Of course, if your property is designated historic, then you do have the certainty of knowing that it’s subjec to historic preservation control. But either everything will eventually become designated, or there will be a line drawn about where to stop, and the plan is silent.

It talks about the overall quantity of historic resources (and has lots of graphs and stats about how many properties they've designated), but makes no mention of the quality of those historic resources.

I asked a high-ranking HPO staffer, “if this is your basis for making Kingman Park historic, what isn’t historic in DC?” He could not answer. Literally 10 seconds of silence. @MayorBowser @VinceGrayWard7 @charlesallen — Bob Coomber (@rcoomber) January 13, 2018

HPO can be flexible and has recommended against a few landmarks — but very few

In fairness to HPO, they’re actually fairly flexible about changes. They’ll work with property owners in reasonable ways and have been permissive about new construction. So designation isn’t a death sentence, though even if HPO is supportive of a project, HPRB in the past has tended to ask to take off a floor anytime neighbors opposed a project.

Also, HPO does sometimes recommend not designating some properties if they really are merely one example of a common type of building. Two houses at 7 Grant Circle and 16 Grant Circle got the thumbs down as not being “significant” enough on their own, though it then designated buildings all around the circle as a historic district. It also rejected designation for a deli building near the ballpark, saying landmarking “would set an unacceptably low bar for significance and thus, designation.”

I'd like HPO to better articulate how high or low this bar is, and consider setting it more than an inch off the ground.

Another common criticism of preservation is that there is no provision at all in the law to balance it against other needs like affordable housing or the value of adding housing near Metro. HPRB only determines if a property is “historic” in virtually any possible way, not whether it's historic “enough.” That should change. But in the meantime, HPRB has plenty of discretion to set a higher bar of significance or ask for more substance.

HPO will accept comments on the plan until March 1. I’m going to ask HPO to better define how much of DC ought to be designated historic, to define what shouldn’t be designated historic, and to clarify how “significance” is different from “you can just tell an interesting story of any kind about this property.”

Correction: The initial version of this article said Pepco opposed the landmark designation for its Harrison Street substation. According to the ANC 3E resolution, Pepco did not take a position but did criticize the effect that landmarking might have in the future. Also, the initial version of this article said the deadline for comment on the preservation plan was February 28. It was actually March 1.