Preservation problems: predictability and pellucidity

The latest historic preservation plan essentially concludes that people don’t trust historic preservation in DC because they don’t know enough about it, and recommends that staff and advocates push harder to persuade people of preservation’s positive effects.

As I argued yesterday, that’s not preservation’s primary problem. Rather, it awkwardly absorbed many resident desires to shape development, from laudatory ones like wanting buildings to engage the street and eschew vinyl pop-ups to the too-common impulse to simply block any buildings that are even slightly tall.

Preservation needs to confront these questions of what it should and shouldn’t restrict and what kinds of outcomes it’s looking for. Meanwhile, it can take some immediate steps to define much clearer rules, make preservation decisions more predictable, and let people to see how projects have evolved through the process.

We need pictures!

The Historic Preservation Office (HPO) is right that people aren’t aware of all of the positive effects of their review on development. One big step they could take to improve transparency (or, after using a thesaurus to find a word starting with ‘p,’ pellucidity) is to put images of the proposed buildings online.

Right now, you can access staff reports online, which go into ornate detail about the building. Take this paragraph about the project at 13th and U:

The composition has been organized with three vertically-oriented towers so that it doesn’t look squat or horizontal; the corner balconies and paired windows help reinforce the vertical emphasis. The rhythm and proportions of fenestration on the residential floors is consistent with historic apartment buildings, while the first floor is designed and articulated to reinforce the street’s pedestrian scale and retail character.

That’s great, but can you really picture the building based on that description? As they say, a picture is worth a thousand words, and in the case of architecture, maybe many thousands. It’s really almost impossible to understand what they’re talking about without a picture:

I was able to post that picture because this developer put renderings online when they presented them to ANC 1B, but many don’t. The preservation office isn’t making their decisions based on prose, but on sketches.

Historic Preservation Review Board (HPRB) members get many pages of drawings before their meetings. These are almost always, if not always, just print-outs from the architect’s computers. It shouldn’t be hard to have the architect submit electronic files and put them online.

The DC Office of Zoning recently deployed a nice system that lets you search for a zoning case and see all of the submissions, both textual and graphical, as PDFs. Why not the same for historic preservation, or even work with OZ and use the same system?

Often, I hear about buildings where the board seemed to make the right decision, or where a project improved based on staff review. It would be great to run posts about those. With pictures, it would become far more feasible.

This should be a top priority for the office. I didn’t see it in the plan.

We need information earlier!

When a project appears on the HPRB agenda, it’s actually fairly late in the design review process. The property owner has usually shown the design to the staff and gotten considerable feedback already.

Often the staff makes designs better through this consultation. (Sometimes they make it worse.) If they want people to see the positive effects of preservation review, the next step should be to peel back the curtain on this somewhat.

It starts with a property owner submitting a permit application. Post those online, and then post the designs at each step along the way. Residents could see a slideshow of how a project has evolved, hopefully for the better, through the process from start to finish.

Maybe property owners don’t want people to know about their plans until they are farther along, though it’s not clear the government should be in the business of catering to that desire for secrecy. If there is a reason to maintain some silence, then perhaps the office can post all of the original and intermediate renderings once a project reaches the point of becoming public, such as going on the HPRB agenda or having a zoning hearing.

Create clear guidelines to define “compatibility”

The other major direction for the preservation office to pursue is making its decisions less apparently subjective. Right now, staff reports seem to pull aesthetic judgments out of thin air, and then the board either agrees or disagrees.

Since it’s made up of architects, historians, and archaeologists rather than lawyers, most of the comments on the board involve statements like “I like the detailing” or “I think it’s too tall.”

Preservation should not be about what people “like.” It’s technically about what is “compatible,” and an important, yet mostly absent, step is to define, ahead of time and clearly, what “compatible” means.

DC has some design guidelines. They are extremely vague and quite out of date. For instance, the document on additions to historic buildings says:

a contrasting rear addition may be acceptable if it is not visible from a public street or alley and when it does not destroy existing character-defining details, ornamentation and materials of a rear elevation. A new rear addition that can be seen from a public street or alley should be compatible with the design of the rear elevation of the existing building. If the new addition is not visible from the street or alley, a less compatibly designed addition may be acceptable.

That’s fairly clear, but isn’t the preservation office’s practice in much of the city. I live in the Dupont Circle historic district and am a member of the Dupont Circle Conservancy. We discuss many rear additions, and at least in Dupont, the Conservancy’s policy, and HPO’s policy, has been that rear additions of any type are fine as long as they’re not visible directly from the street. You wouldn’t know that from reading the guidelines.

If the rules are different among historic districts, then the guidelines need to say so.

The guidelines on new construction in historic districts say:

Typically, if a new building is more than one story higher or lower than existing buildings that are all the same height, it will be out of character. On the other hand, a new building built in a street of existing buildings of varied heights may be more than one story higher or lower than its immediate neighbors and still be compatible.

Sounds like on a street like U Street, a building like that 8-story apartment building should have been a no-brainer. Anyone on the board saying it was too tall was clearly ignoring the written guidelines — except that the guidelines are widely ignored and out of date.

The answer is simple. Write newer, much clearer guidelines. That would let property owners figure out for themselves fairly well what is likely to get approved or rejected. What you can build on your property shouldn’t depend on the whims of the preservation official, but rather have a firm basis in the code with officials only interpreting the guidelines and applying them to the specifics of a case.

Guidelines would also give residents and leaders a chance to actually debate what kinds of restrictions there should be. Each historic restriction also has a consequent impact on the city’s ability to house more people, economic growth, the tax base and more.

We need a balance, but right now that balancing happens almost entirely behind the scenes, in the minds of HPO staff, who then crank out a report that recommends for or against a project purely on historical grounds. Let people debate whether or not a historic guideline is a good idea, not just on the basis of “compatibility” but on its total effect on the city.

Cite the guidelines in reports and decisions

Then, when crafting staff reports on projects, cite each recommendation to a guideline. Say that the building needs to have more of a setback? Then refer to a guideline that says this. If there’s no guideline to that effect, then it’s not incompatible. Write a new guideline that defines the incompatibility, and use it for future cases.

Likewise, if HPRB goes against the staff recommendation, it should have to quote guidelines that form the basis for that decision. Don’t simply declare that a building ought to look different; point to a written document that other people besides the board would likely interpret as meaning the same thing.

This would make decisions seem less arbitrary. Instead of reading like an aesthetic judgment, a staff report would be interpreting the guidelines in a clear way. Others might disagree with the interpretations at times, but it’s not just coming from nowhere.

The Mayor’s Agent can also hold HPRB to a more rigorous standard. When the Board of Zoning Adjustment grants a variance or a special exception, it writes a detailed, legalistic set of factual findings and conclusions of law based on the regulations.

HPRB doesn’t need to be quite so meticulous, but nor does it get carte blanche to make any judgment unquestioned. In the law, it’s actually technically only an advisory body. But it’s usually not treated as an advisory body; the staff follows HPRB’s rulings as if it’s the official arbiter of “compatibility.”

In the law, the mayor, who acts through an official known as the Mayor’s Agent, can override any HPRB decision. The Mayor’s Agent could declare that if HPRB votes to deny a permit, they need to point to some guidelines that justify it, or not have its “advice” given much weight.

A few steps can make a difference

Preservation has many beneficial effects on our built environment. However, it’s too opaque and decisions often seem capricious. The preservation office can work to repair preservation’s reputation by tackling two problem areas:

First, make sure that people can see what property owners propose and what changes came out of the preservation process. Post online renderings of projects when they first come to HPO, as they evolve through consultation with staff, when they go to HPRB, and the final outcomes.

Second, make sure people can see why those changes came about. Develop detailed and specific guidelines that any property owner could read and understand generally what would and wouldn’t go forward. When a case is controversial and goes to the board, make sure staff reports and board decisions then cite these guidelines to ground the decisions in something other than flighty opinion.