Saturday, August 1, 2009

SHPO's comments on Beale Street Landing

Any project that uses Federal money, and that might have an adverse effect on a historic property, must undergo a review under Section 106 of the National Historic Preservation Act of 1966 (NHPA). Under the current Sec. 106 regulations, the job of making an assessment of the adverse effect is delegated to the State Historic Preservation Office (SHPO), which in Tennessee is the Tennessee Historical Commission under the Department of Environment and Conservation (TDEC).

Below is the complete text of the SHPO report on Beale Street Landing (omitting one generic informational flowchart), dated two days before the Consulting Parties Meeting in October, 2007. These reports are generally prepared using a template that outlines the Section 106 regulations, and SHPO's comments are inserted under the appropriate regulation section. I have highlighted SHPO's comments in bold.


22 October 2007

SHPO Comments:

1. Step Four Consultation

36 CFR Part 800.6 conditions:

• continuing consultation to explore project alternatives or modifications to the proposed Beale Street Landing project that would avoid or minimize project effect

• notifying the Advisory Council on Historic Preservation and determining Council participation

• involving consulting parties to participate in further consultation

• providing all consulting parties with appropriate project documentation

• making project related information available to the public.

II. Review of Criteria of Adverse Effect

A. Physical destruction of or damage to all or part of the property;

Beale Street Landing as currently proposed takes a portion of the Cobblestones Area that is a contributing element within the National Register of Historic Places listed Cotton Row Historic District. This taking, combined with the current design of Beale Street Landing, constitutes an adverse effect.

B. Alteration of a property, including restoration, rehabilitation, repair, maintenance, stabilization, hazardous material remediation, and provision of handicapped access, that is not consistent with the Secretary's Standards For the Treatment of Historic Properties (36 CFR part 68) and applicable guidelines;

The Secretary of the Interior's Standards for Rehabilitation state that:

1. A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.

Beale Street Landing as currently proposed contains significant elements that dramatically change the historical use of the property from that of a working riverfront to that of a recreational park and promenade. The various design features of this new use, particularly the cluster of very large vertical islands, the prominent stair step terraces, and the imposing helical transit ramp, are not minimal changes but rather are significant and impactful changes to the Cotton Row Historic District's historic materials, features, spaces and spatial relationships.

2. The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.

Beale Street Landing as currently proposed does not preserve the historic character of the Cobblestones Area and the riverfront of which it is a part, which is gradually sloping, primarily horizontal, and commercial in nature. Rather, it alters those features by substituting a series of bold stair step terraces combined with a primarily vertical treatment reflected in the design of the four river overlook islands whose use is primarily recreational and the helical transit ramp whose design is out of character with the historic appearance of the area. The design as currently proposed also takes a portion of a contributing element within the Cotton Row Historic District.

3. Each property will be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken. (Not Applicable)

4. Changes to a property that have acquired historic significance in their own right will be retained and preserved. (Not Applicable)

5. Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.

Beale Street Landing as currently proposed does not preserve the construction materials, techniques, or craftsmanship of the Cobblestones Area upon which a portion of the project is located. Instead, it substitutes new construction materials and treatments that are out of character with the Cobblestones Area rather than replacing cobblestones that had been removed by an earlier project, thereby restoring the original features of the area.

6. Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.

Beale Street Landing as currently proposed does not replace missing cobblestone features nor does it substitute new features that match the old ones in design, color, or texture. Instead, it covers up a portion of the Cotton Row Historic District's Cobblestones Area with new features that do not match the old ones in design, color, or texture.

7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used. (Not Applicable)

8. Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.

Beale Street Landing as currently proposed will only require on¬site archaeological monitoring during any ground disturbance associated with the project. However, if the project changes or expands to include ground-disturbance in areas that have not been previously reviewed, we will need to consult further on those specific changes. In particular, any proposed removal or disturbance of the Cobblestones may affect significant archaeological resources.

9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.

Beale Street Landing as currently proposed is not compatible with the historic materials, features, size, scale, and massing of the Cobblestones Area. Instead, it proposes new construction materials, and design features that do not reflect the size, scale, proportions, and massing of the Cobblestones Area. The size, scale, proportions, and massing of the proposed design are in fact significantly more massive than the existing historical features associated with the Cobblestones Area.

10. New additions and adjacent or related new construction will be undertaken in a such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired. (Not Applicable)

These alterations that are inconsistent with the Secretary's standards for the treatment of historic properties constitute an adverse effect.

C. Removal of the property from its historic location; (Not Applicable)

D. Change in the character of the property's use or of physical features within the property's setting that contribute to its historic significance;

Beale Street Landing as currently proposed dramatically changes the character of the historic property's use and the physical features within the historic property's setting that contribute to its historic significance. In the National Register of Historic Places nomination, Cotton Row Historic District is classified as a commercial historic district. Yet Beale Street Landing as currently proposed would change the use of the area from a commercial use to one that is primarily recreational through the creation of terraced promenades and overlook islands. While the riverfront was historically a steamboat landing, its use was primarily for the transshipment of freight from riverboats up the riverbank to warehouses at the top of the embankment. Beale Street Landing does reflect the historic use as a riverboat landing, but the current design reflects a primarily recreational use of boarding and disembarking pleasure boat and cruise ship passengers. In doing so, the design overwhelms any sense of the historic commercial use of the riverfront. This change in the character of the historic property's use constitutes an adverse effect.

E. Introduction of visual, atmospheric or audible elements that diminish the integrity of the property's significant historic features;

Beale Street Landing as currently proposed introduces strong visual elements that diminish the integrity of the Cobblestones Area of the Cotton Row Historic District. The Cobblestones Area is a gradually sloping shoreline covered in cobblestones that provided a solid and smooth transition from the water's edge to Riverside Drive. The Cobblestones Area is generally horizontal and measured in its incline from the waterline to the embankment. Contrariwise, Beale Street Landing as currently proposed is a cluster of four high, vertical islands connected to each other by a series of stair step terraces that proceed from the embankment down to the waterline. There is nothing gradual, horizontal, or gently sloping in the current design of Beale Street Landing. Installing it as currently proposed would therefore dramatically alter the feeling, character, and association of the Cobblestones Area. The introduction of out of character visual elements within the viewshed of the historic property constitutes an adverse effect.

F. Neglect of a property which causes its deterioration, except where such neglect and deterioration are recognized qualities of a property of religious and cultural significance to an Indian tribe or Native Hawaiian organization; (Not Applicable)

G. Transfer, lease, or sale of property out of Federal ownership or control without adequate and legally enforceable restrictions or conditions to ensure long-term preservation of the property's historic significance. (Not Applicable)

III. Exploration of project alternatives or modifications to the proposed Beale Street Landing project that would avoid or minimize project effect .

(The section was left blank.)

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