Is historic preservation truly about preservation, or about design review for new and modified buildings? In DC, the historic preservation process has become a little of both. We want to avoid ugly renovations, pop-up eyesores, and awful new buildings, and historic preservation has become the forum for this review. But there is collateral damage. We’ve landmarked numerous buildings and streets that aren’t really historic, preserving some terrible anti-urbanist mistakes. Meanwhile, other less historic areas of the city, equally worthy of some design review, get no protection at all. And the preservation process, tailored for the truly historically notable, is a poor fit for design review, over-regulating architectural decisions while under-emphasizing the impact of the development on the pedestrian experience. We need minor changes—an “adaptive reuse”—of the historic preservation process, to ensure it meets our current needs.

DC’s Historic Preservation Review Board and its staff arm, the Historic Preservation Office (HPO), have been the center of much controversy in the last year. They landmarked the modern, and anti-urban, Third Church of Christ Scientist at 16th and I, over which architects and the rest of the community were deeply divided. They’ve fought high-profile legal battles on Capitol Hill and Mount Pleasant. And on projects like the proposed development at 14th and U, HPRB decisions like the one saying that an existing curb cut is historically incompatible (while allowing a similar curb cut to stay at the nearby Ellington) seem arbitrary no matter which side of the issue you agree with.

Many of these controversies emanate from two worthy yet orthogonal goals: preservation and design review. On the one hand, there are many very historically significant buildings that should not be demolished and only changed with great care. There are many neighborhoods whose historic harmony among numerous rowhouses and larger buildings need to be preserved. But there are also many non-historic buildings and areas. We want to ensure future development fits in with the character of Washington DC and each neighborhood. If you stretch a little, you could call that “historic.” And that’s how DC has developed a de facto design review process.

According to Director of Planning Harriet Tregoning at the Dupont Circle Citizens’ Association meeting last week, DC’s historic preservation law makes it much easier to “designate” buildings and neighborhoods than in other cities, but also “broad discretion” for the Mayor’s agent to allow alterations to historic structures. For those who usually agree with the decisions of HPO, HPRB, and the Mayor’s Agent, this is a good system, giving strong protections to many buildings and neighborhoods. For others, “broad discretion” is another way of saying “arbitrary power.”

Using the historic preservation process as design review both over-protects non-historic buildings in some areas while under-protecting other areas. At the same meeting, Historic Preservation Office Director David Maloney announced that a historic district is in the works for the GW campus. The campus has some beautiful buildings and some historic buildings, but also many boxy, unremarkable mid-century buildings that face the street with blank walls and garage entrances. A visitor to the area can find few stores or restaurants because most establishments are on mall-like interior areas in the centers of blocks. This was a common design pattern in the mid-20th century when streets were dangerous, but today this architecture it itself the impediment to safer and better streets. Is this “historic”? Should it be preserved inherently, with a high burden set on any change of any kind? I argue it should not. Those non-historic GW buildings deserve no protection as they are, and GW should be able to tear one down at any time. However, should they do so, we must ensure they build something better, not worse, in its place. There is a role for review, but not for preservation per se.

The Hilton on Connecticut Avenue is another example, also proposed for landmarking. This building was constructed in the 1960s when many expected a freeway to run right along Florida Avenue. As a result, the Hilton’s architecture is appropriate for a freeway-side hotel in a suburban sprawl zone, not for a townhouse neighborhood. Its edge is pedestrian-unfriendly, with two separate loop driveways and all entrances set back from the street. It’s impossible to enter without weaving among the taxis and private cars coming and going, and there are no stores on the street. The building is taller than zoning allows. What is preservation-worthy about this building? Had the preservation law existed fifty years ago, this could never have been built and whatever it replaced never destroyed. But now that this scar on the neighborhood has endured for decades, some want to erect strong procedural obstacles to any change, even improvements. As with the GW campus, it’s appropriate to ensure that changes go through a detailed review process. But a landmark designation not only ensures that changes must be reviewed, but puts the weight of the law behind the notion that this building shall not be changed more than necessary. That would be a mistake.

While many non-historic structures are over-protected, other neighborhoods receive little to no review. Historic districts are disproportionately clustered in wealthier parts of the city, where well-organized citizens have been able to win protection for their own neighborhoods, pushing development to other, poorer parts of the city without the same political clout. Thus, while every building in Capitol Hill is limited to its current height, an area like Petworth has to ensure eyesores like this. What makes Georgetown more worthy of rules ensuring that additions fit with the existing neighborhood character, other than money and perhaps the color of citizens’ skin? David Maloney has made preservation in historic Anacostia his top priority, which is laudable. But it’s taken a lot longer for Anacostia to get protection than Cleveland Park, where HPRB chairman Tersh Boasberg got his start as a historic preservation activist.

Our historic preservationists also focus on the wrong factors when wearing their design review hats. When HPRB landmarked Third Church, the discussion almost entirely focused on the architectural merit of the building: the notability of its architect, its context in the Brutalist movement, and the way the building “surprises” passerby; in the words of the Board’s architect, Anne Lewis, “Whether [architect Araldo] Cossutta did or did not succeed in larger urban design principles is not relevant.” The preservation law refers to “architectural styles, building types, or methods of construction,” not the building’s contribution to street activity. Perhaps when preserving truly great buildings, as some feel this is, that standard makes sense. But when the preservationists instead act as citywide design reviewers, it does not.

HPRB and HPO do consider the function of a building in their work. Several Board members brought up the failure of the Third Church site to create a public space. And according to Tregoning, the interplay between urbanism and preservation is “one of the liveliest debates” within the Office of Planning. Maloney added that the consensus among preservationists is that the Department of Energy’s Forrestal Building in L’Enfant Plaza, the central “gateway” building and one of DC’s biggest urbanist failures, probably should indeed be demolished. But architects agree that building is hardly notable. When discussing buildings with some architectural significance, like the I.M. Pei structures nearby, the divide between form and function is deeper. Boasberg told me that he agrees with replacing many of the urban renewal projects but, he added, some of them have significant landscaping which makes the decision more difficult. In my opinion, a little bit of interesting greenery or a historically notable parking lot should almost never prevent fixing our urban design mistakes by bringing buildings out to the sidewalk.

Of course, it’s not just modern buildings that fail to engage the streetscape; the federal buildings in the Federal Triangle are often both beautiful, historic, and completely dead along the street. Even the Old Post Office building housing the National Portrait Gallery, a historic and classic Greek Revival structure, is a dark and inert mass in the center of the Gallery Place neighborhood at night. I don’t advocate tearing these buildings down, but we should encourage building out the ground floor to the sidewalk, replacing the wrought-iron fences and shrubs with retail or restaurants that engage the street while preserving the historic old structure behind and above.

Finally, when HPRB does make decisions on urban design principles, as they often do, couching them in the language of historic preservation makes them seem arbitrary and open to attack. Advocates of a front garage entrance at 14th and U criticize HPRB for opposing the curb cut even though it already exists, while allowing an existing one to remain at the nearby Ellington. The reason to put the garage entrance in front or in back isn’t for historic reasons, it’s for reasons of traffic flow and safety for pedestrians. Fortunately, a traffic study is underway to decide just that. But HPRB can only say that it’s “incompatible with the historic character” of the neighborhood. Meanwhile, they might argue to preserve a driveway at the Hilton for the very same reason.

Historic preservationists talk about “adaptive reuse”, allowing measured changes to a building to allow it to serve contemporary needs. So, too, must we apply adaptive reuse to the historic preservation process. It’s appropriate to preserve truly historic buildings and neighborhoods. But urbanism must also factor in to the equation. One solution would be amending the law to add weight to these considerations. A proposed modification that enhances the street’s vibrancy could receive greater deference even if it destroys some historic landscaping. The bar to replacing a building with blank walls and garage entrances could be lower than that for other buildings. And representatives on the Board could include people from urbanist fields as well as architects and archaeologists. HPO staff may argue that the Board already considers these factors, but today they are almost usually secondary.

Alternately, perhaps we need a new Board within the Office of Planning alongside HPO. HPO/HPRB could focus on the truly historical, with a somewhat higher burden of proof to landmark structures. But at the same time, a Design Review Board would gain a measure of review over all non-historic development in the entire city. That board would consider the more functional aspect as well as harmony with the existing neighborhood. Existing historic districts would maintain their protections, and the rest of the city would gain new protections. But we would stop landmarking non-historic buildings willy-nilly in an attempt to impose some review. For those buildings, the historic preservation process, as implemented today, just doesn’t fit.

David Alpert created Greater Greater Washington in 2008 and was its executive director until 2020. He formerly worked in tech and has lived in the Boston, San Francisco Bay, and New York metro areas in addition to Washington, DC. He lives with his wife and two children in Dupont Circle.