Preservation work plan misses most important job: clarity
Historic preservation does a lot of good for DC, but property owners need more clarity about what will and won't get approved. The preservation office's latest work plan sadly continues to omit this component, which should instead be one of its top priorities.
DC's historic preservation office has published its annual work plan. It includes many worthwhile endeavors, such as putting more data about historic sites online, helping affordable housing developers qualify for existing federal tax credits, and doing more to preserve and repair the boundary stones.
However, the plan doesn't do anything to address preservation's biggest problem. Right now, there are very few written standards for what is and is not "historically compatible." As a result, the Historic Preservation Review Board makes decisions arbitrarily, mostly built upon individual members' personal aesthetic decisions rather than any rules or precedent.
Most other boards that make decisions follow a much more legalistic format. They have a set of regulations which they are bound to uphold. When considering each case, they look to the relevant regulations, and try to figure out how to fill in gaps when the regulations don't directly address a situation. If a regulation isn't working well, the agency (or legislature) changes it.
In preservation, the law basically only charges HPRB with deciding whether something is "compatible." The only definition of "compatible" comes from historic district standards which describe the nature of a historic district but don't give much detail about many types of potential changes. As a consequence, preservation decisions are fueled by more emotion and less law than other areas.
Preservation staff don't analyze the rules and precedents as thoroughly as they could, or as much as many other boards do. When claiming there is a rule limiting the heights of buildings on 16th Street, the staff report made no mention of the recent Hay-Adams case which set a different standard. When recommending against solar panels on a Cleveland Park home, staff falsely claimed that the current guideline prohibits all solar panels visible from any street.
This isn't impossible to change. The preservation office simply needs to spend more of its time setting up clearer guidelines. They are already doing this in a few areas, such as a new set of rules for utility meters in public space. More of this will help property owners know with more confidence ahead of time what they can and can't do.
When HPRB rejects a project or insists upon changes, it could also publish a written decision explaining what elements of a proposal were not "compatible," which can help clarify for similar cases in the future. Staff reports can be clearer about which guidelines they refer to and point to those guidelines, when such exist, or note that there is no written guideline when there is none.
Instead of doing this, too much of the work plan seems to focus on simply expanding preservation's jurisdiction and bringing more and more of the city under its control. One of the categories, "defining historic significance," mostly focuses on ways to find more historic significance among buildings and educate people more about historic significance. This can be valuable, but is "evangelizing," not "defining."
It may indeed be worthwhile to bring at least some level of preservation protection to significant buildings and neighborhoods which lack it today. But as long as the process remains mysterious and revolves mostly around the aesthetic whims of a few people which shift like the wind, the public won't, and shouldn't, support increasing its reach. The office needs to make it a top priority to get its own house in order, and soon.
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