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National Register: Integrity and Evaluation Issues

Tax Act Workshop, Philadelphia, PA, October 10, 2000


Hahan-Richardson Building, Columbus, MS

Front View

Interior Front

Does not contribute to the significance of the Columbus Central Commercial Historic District because of loss of historic integrity

When the district was listed in the National Register the c.1870 brick, two-story, three-bay wide commercial building was classified as a contributing resource in the National Register documentation. Subsequent to the listing of the district, an owner gutted the property. A new owner purchased the property and sought a Part I certification, which was denied for a loss of integrity. The decision was appealed and upheld: the building characterized as essentially a gutted shell in ruinous condition. The building had lost its roof, the original brick cornice, the original storefront, all window sash, and all of the internal structural system, including the upper and lower floors. What remained from its original construction was a portion of the second story facade, the two side party walls, and the rear wall of the one-story section. The building did not retain sufficient historic fabric to add to the district’s sense of time and place and historical development. This denial decision was subsequently upheld in court.

B & D Mills, Grapevine, TX

Aerial view of the complex within the district after the fire.

Historic view of significant 1950s additions to the complex.

Contributes to the significance of the district despite loss of fabric from 1995 fire

The B&D Mills at 213 West Hudgins Street in Grapevine, Texas, has retained its ability to contribute to the historic character of the Cotton Belt Railroad Industrial Historic District, which was listed on the National Register of Historic Places on September 4, 1997.

The historic identity of the B&D Mills, as it existed at the end of the district’s period of significance, remains intact. Although the 1995 fire destroyed the original mill structures (1902) and a number of warehouses and other additions, the remaining industrial features are sufficiently intact to reflect the conversion of the mill to a processing facility for poultry feed in the 1930s and its evolution in subsequent decades as an important supplier and manufacturer for the region’s growing poultry industry. Furthermore, many of the key component features, including the manufacturing tower, concrete bulk warehouse, and office building, which directly related to technological innovations in the 1950s remain intact. These innovations were the basis for justifying the district’s period of significance to 1956, and their importance is well documented in the National Register nomination and the material presented for the appeal. For these reasons, the B&D Mills retains sufficient historic fabric to add to the district’s sense of time and place and historical development.

Rendering, B&D Mills, 1956 condition
Rendering, B&D Mills, post fire condition


Daphne Funeral Home, San Francisco, CA

NOT Eligible because of loss of integrity

A nomination appeal was submitted to the NPS because of the State’s decision not to nominate the Daphne Funeral Home to the National Register of Historic Places. It was determined that due to the loss of historic integrity, the Daphne Funeral Home does not meet the National Register Criteria for Evaluation and thus is not eligible for listing in the National Register.

Historic view, 1953

The Daphne Funeral Home was constructed between 1950 and 1954 by the California architect A. Quincy Jones. The nomination form claims that the building is exceptionally significant under National Register Criterion A as the first Modernist mortuary in the United States, and Criterion C as an early and notable example of the work of A. Quincy Jones, an important Modernist architect from Los Angeles, California. The nomination also notes the association between the funeral home’s owner, Nicholas Daphne, and the writing of Jessica Mitford’s expose of the funeral industry in her 1963 book The American Way of Death, and Mr. Daphne’s efforts to reform the industry.

Recent view, Daphne Funeral Home

When constructed, the Daphne Funeral Home was an early example in San Francisco of a small commercial building designed in a modernistic style. Unfortunately, the building suffered a major fire in 1967 which resulted in a substantial loss of original materials and alterations which have destroyed the character of the building from its period of construction. The nomination does not establish that the substantial alterations to the building dating from the 1967 fire have achieved significance over time. Finally, the owner’s activities to reform the funeral industry and his association with the writing of The American Way of Death would not qualify the Daphne Funeral Home for the National Register, because these associations are linked to the building’s earlier appearance.

Following the fire the highly visible horizontal redwood exterior siding was altered to vertical wood battens; the long horizontal band of windows on the major south-facing elevation was covered with the new vertical wood battens; the original steel windows were replaced with aluminum sliders; the distinctive interior redwood wall coverings were replaced with gypsum board; the caretaker’s residence in the administration building was altered to office space; the large, original neon signage on the roof was not replaced; the slumber rooms were enlarged and their relationship to the outside gardens altered; and the roof overhang on the north side of the administration building was radically cut back even with the edge of the walls. In addition, the landscaping of the grounds is quite different from its appearance when the building was constructed. The cumulative effect of these alterations is that the property no longer can recall its original sense of time and place as an example of early 1950s modernist architecture, and the building, as altered only 32 years ago, does not appear to be exceptionally significant in its own right.

Building at 465 10th Street, San Francisco, CA

Pre-rehab condition

Same view with rooftop addition

Eligible despite alterations incurred during conversion into housing

Constructed in 1924 by Herbert L. Rothschild Entertainment, Inc., this reinforced concrete early 20th-century Classical Revival style building was listed under Criterion A in the area of Entertainment/Recreation. The distinctive industrial building with its characteristic scenery painting tower and decorative exterior detailing served as a complimentary site associated with San Francisco’s well established theater/entertainment operations.

While the integrity of the property has been compromised by recent rehabilitation work, particularly the sizable roof top addition on the northern section of the building and the insertion of new windows in the south wall of the tower, sufficient character-defining features remain to convey a sense of historic use and function.


Scenery painting tower before rehab
Scenery painting tower after rehab


City Garage Yard and Fire Drill Tower (Durham MRA), Durham, NC

Overall view of the complex

Eligible despite unfortunate alterations

Historically significant as the only surviving early to mid-20th-century municipal service complex in the city and architecturally important for its Romanesque Revival styling and its distinctive free-standing Fire Drill Tower, the property was listed individually in the National Register under Criteria A and C.

Overall view of main garage building

The impact of the construction of the "elevated handicap walkway" with retaining wall across the length of the distinctive arched bay garage openings originally designed for direct, ramped vehicular access into the building and the glazing of the garage openings caused concern for State and NR staff. Although there was consensus that the alterations were character altering and unfortunate, the majority of NR staff was of the opinion that the overall integrity of the complex as a rare survivor if its type met the criteria.



Above: Section through garage

Left: Plan of the complex


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