Revising Preservation Brief 14

This article originally appeared in the May/June 2012 issue of The Alliance Review, a publication of the National Alliance of Preservation Commissions.

Figure 1. Reviewing a Proposed Rooftop Addition

The building as it appeared prior to the proposed rehabilitation: Originally constructed in the 19th century, it housed an undertaker’s establishment, livery stables and, most recently, a coffee warehouse.

Historic photograph.

The rehabilitation proposal is to recreate the historic appearance, while adding a two-story rooftop penthouse. This did not meet Standards 3 & 9. It would have given the building a false sense of history and adding a two-story rooftop addition to a low-rise building is generally not a compatible treatment.

The NPS conditional approval required that the rooftop addition be reduced to one story and minimally visible from the public right of way. The architect demonstrated that a one-story addition would have minimal visibility by using "animation prints" (on a CD and print outs) showing the building with the proposed rooftop addition from various locations, starting one block away and gradually moving closer until directly in front of the building. Because it is a corner building views were provided from two intersecting streets.

The revised proposal with a one-story rooftop addition that was conditionally approved by the National Park Service.

Revising Preservation Brief 14: New Exterior Additions to Historic Buildings: Preservation Concerns

By Anne Grimmer

The topic of new additions, including rooftop additions, to historic buildings comes up frequently, especially as it relates to rehabilitation projects. It is often discussed and it is the subject of concern, consternation, considerable disagreement and confusion. Accordingly, the National Park Service (NPS) published Preservation Brief 14: New Exterior Additions to Historic Building: Preservation Concerns in 1986 to address this issue. Of course, many aspects of rehabilitation have changed since then, more than thirty years after the 1976 Historic Preservation Tax Incentives program was initiated and more than twenty years after this Preservation Brief was first developed. The first years of the program were a learning experience for all preservationists, including the NPS. After all, "adaptive use", "adaptive reuse" or "rehabilitation"—regardless of what it is called, was a relatively new kind of preservation treatment and, quite different from restoration, the more familiar treatment at that time. Restoration is defined as "the act or process of accurately depicting the form, features, and character of a property as it appeared at a particular period of time by means of the removal of features from other periods in its history and reconstruction of missing features from the restoration period." Whereas rehabilitation is defined as "the act or process of making possible a compatible use for a property through repair, alterations, and additions (emphasis added) while preserving those portions or features which convey its historical, cultural, or architectural values."

Although the wording of the Secretary of the Interior’s Standards for Rehabilitation, which govern the administration of the Historic Preservation Tax Incentives program, has been revised somewhat over the years, the actual policy espoused by the Standards has remained the same. Thus, the Standards continue to be applied in the same way to all proposed rehabilitation treatments, including proposed new additions to historic buildings. Standards 9 and 10 specifically address new additions: Standard 9 states "New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property. The new work shall be differentiated from the old and shall be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment"; and Standard 10 states "New additions and adjacent or related new construction shall be undertaken in such a manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired."

The Historic Preservation Tax Incentives program has always emphasized that a new exterior addition to a historic building should be considered in a rehabilitation project only after determining that requirements for the new or adaptive use cannot be successfully met by altering non–significant interior spaces. If the new use cannot be accommodated in this way, then an exterior addition may be an acceptable alternative, but it must preserve the character of the historic building. However, what the NPS has learned from thirty years of experience, despite its best efforts to convey what an appropriate new addition to a historic building is, is that it has not always been successful in conveying this to many users of the program.

In September 2006, the Committee on the Federal Historic Rehabilitation Tax Credit Program issued a report to the National Park System Advisory Board, entitled Federal Historic Rehabilitation Tax Credit Program: Recommendations for Making a Good Program Better. The report consisted of a number of recommendations to the NPS that it take certain steps to enhance and strengthen the program. One of the recommendations was that the NPS, in consultation with its historic preservation partners, reexamine several, often problematic, issues that are commonly encountered in rehabilitation projects. Not surprisingly, new additions (and related new construction) to historic buildings was one of the issues; the others being windows, interior treatments and modern requirements and new technologies and materials.

Long aware that it was time to update Preservation Brief 14 on new additions, the need to follow up on the committee’s recommendation prompted the NPS to begin this process. Accordingly, the NPS, as directed, initiated a consultation process with its preservation partners and professionals to seek input on the topic of new additions. Based on comments and suggestions received through this process, the NPS began to work on developing expanded guidance. The resultant guidance was presented to the public in December 2007, when it was posted on the Technical Preservation Services’ website with the heading Planning Successful Rehabilitation Projects: Applying the Standards to common rehabilitation concerns as part of the information on the Historic Preservation Tax Incentives program.

The development of this expanded guidance was followed by the revision and publication of Preservation Brief 14 itself. Although more "how-to" advice has been added, such as evaluating proposed rooftop additions (Figure 1), the NPS policy on new additions presented in the original brief is essentially the same in the revised brief published in 2010. Most of the photographs in the original publication are still good examples in that the new addition is clearly distinguishable from the historic building. However, some of the new additions illustrated then may not be considered as compatible today; for instance, they may be overly large or perhaps too differentiated. Some of the illustrations in the original brief may reflect architectural styles, or other trends, such as greenhouse additions, that have now gone out of fashion but were popular twenty years ago. This is an inevitable result of changing times and tastes and the reason why most publications are updated or revised.