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Historic Preservation Program

Cultural Resource Management: Policy and Regulations
Section 106 Notes
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The General Services Administration’s Built Legacy

The federal government has a long history of constructing and maintaining many of our nation’s public landmarks. The primary responsibility for the design, construction, and stewardship of America’s public buildings was passed from the Department of the Treasury and individual agencies to the Public Works Administration (PWA) in 1939. By 1949, the General Services Administration (GSA) and its Public Buildings Service (PBS) was created and the stewardship responsibilities were transferred to them, By this time, the built inventory included Custom Houses, Court Houses, Post Offices, and federal agency offices all over the United States and its territories. Textbook examples of architectural styles such as: Greek Revival, Richardsonian Romanesque, Beaux Arts, Art Deco, and Neo-classical came to symbolize the permanence and stature of the federal government.  The names of those employed to design these buildings included many of America’s leading architects at that time, such as Robert Mills, Cass Gilbert, and John Russell Pope.

During the 1930’s, the expanding federal construction program was inspired by the classical esthetics of the City Beautiful movement (1893-1910), as well as by the fashionable Art Deco and industrial design trends, establishing a high standard for government buildings. Monumental entrances, highly ornamental lobbies, and elegant public spaces extended a gracious welcome to citizens visiting the federal government.  Integrated into many of these buildings were sculptural details, murals, and statuary symbolizing or representing the important civic activities taking place inside. It is a testimony to the durability of these design standards that most of these buildings remain in GSA’s inventory and continue to serve the functions for which they were constructed. 

During the mid to late 20th c, as the national preservation movement developed, GSA further expanded its real property responsibilities to its growing historic inventory, as well as new construction projects. With the passage of the National Historic Preservation Act (NHPA) in 1966 and Executive Order 11593, issued in 1971, federal agencies were now responsible for identifying their historic buildings and structures, and determine if they may be adversely affected by federal undertakings and plan accordingly to avoid, minimize or mitigate for these impacts to the historic resource.

By 1976, the Public Buildings Cooperative Use Act encouraged GSA to make public buildings more accessible to the public by locating cultural, educational, recreational, and commercial activities in federal properties. By giving GSA authority to lease space for these activities, it created a new alternative for keeping federal buildings occupied and economically viable.

In 1979, GSA Administrator, Jay Solomon formed a task force to recommend ways to improve GSA’s preservation practices. His Task Force on Historic Preservation represented a broad spectrum of professionals with experience in the preservation and urban development field. The Task Force made over 80 recommendations within ten general categories, which were published in what became known as the Solomon Report. In 1999, PBS updated the report and published Held in Public Trust: PBS Strategy for Using Historic Buildings, which reexamined GSA preservation’s goals as to reflect changes to the NHPA and the field in general. By 2003, it became apparent that further changes to the NHPA and real property economics made it necessary to revaluate the 1999 report and it was subsequently reissued as Extending the Legacy: GSA Historic Building Stewardship, which was published in 2004. 

With over 400 historic buildings providing over 50 million square feet of federal workspace GSA, and its Center for Historic Buildings, have become leaders in government stewardship. The agency has risen to the forefront of the federal preservation movement and many of its practices have been adopted by other federal land-holding agencies that look towards GSA as a model.    

Regional Historic Preservation Officers

The General Services Administration is divided into 11 Regional Offices and the Central Office which is located in Washington DC. The Regional Historic Preservation Officer (RHPO) is the GSA employee responsible for overseeing compliance of regional projects and decisions with federal preservation laws and regulations.

GSA Liaison

In August 2002, a Reimbursable Support Agreement was entered into between the GSA the ACHP to support a full time senior staff position at the ACHP to serve as the principal point of contact for handling all GSA program and project review activities. This partnership has been highly beneficial to GSA and has lead to the following accomplishments:

  • Establishing a much more efficient and timely resolution process for all GSA 106 Cases. Resulting in more cases being resolved quicker and in compliance.
  • Dedicated and expert consultation to GSA Regions on controversial and complicated GSA cases such as South East Federal Center, Washington D.C., St. Elizabeths’ West Campus Development, Washington, DC, Richmond Courthouse, Virginia, Buffalo Courthouse, New York and Cedar Rapids Courthouse, Iowa.
  • Developing a staff position in ACHP with a unique and intimate knowledge of the GSA organizational structure, which produces immediate consultation results with Regional Historic Preservation Officers (RHPO) and the Federal Preservation Officer (FPO) staff in complicated policy issues. 
  • Providing consistent communications with Project Managers on the benefits of integrating sound preservation practices with GSA’s on-time/on-budget project requirements. Providing monitoring of their progress, in such landmark cases as New Orleans Customs House, Pioneer Square Courthouse, Portland, Oregon and Armed Forces Retirement Home, Washington, D.C.
  • Developing an extremely successful Introduction to Section 106 Training specifically geared towards GSA. Close to 960 GSA employees were trained by the Liaison.
  • Developing for the first time an Executive Focused Introduction to Section 106 Training for GSA Senior Managers with approximately 150 policy officials in attendance.
  • Creating effective public outreach programs to disseminate information on GSA Programs such as assisting in the updating of GSA’s Center for Historic Buildings (PMAH) website, ACHP’s GSA agency web page and distribution of latest GSA Program information to SHPO/THPOs and NGOs through broadcast emails and periodic communications.
  • Assisting PMAH in development of disposal guidance of best practices for transferring historic buildings in a range of circumstances.

Under the supervision of the Office of Federal Agency Programs, the GSA Liaison serves as the primary policy coordinator for cultural management initiatives developed in conjunction with GSA, identifies and recommends critical cultural resource management issues for consideration and resolution by the ACHP and GSA, and serves as principal staff in the review of GSA projects under Section 106, coordinating with GSA Headquarters and appropriate regional offices. The incumbent is also responsible for coordinating such reviews with the appropriate State Historic Preservation Offices, Tribal Historic Preservation Offices, and the public. In addition he will be responsible for updating and maintaining the context of this web page. If you have any questions or comments please contact the GSA Liaison, Mr. Héctor M. Abreu-Cintrón. He can be reached at 202.606.8517 or by email at habreu@achp.gov.    

Cultural Resource Management: Policy and Regulations

General Services Administration Order ADM 1020.2, “Procedures for Historic Properties”, [issued August 20, 1982 as ADM 1020.1, amended October 19, 2003 as ADM 1020.2], GSA Center for Historic Buildings  

GSA Order ADM 1020.2 provides guidance on GSA’s procedures for complying with federal regulations for the use, protection, and enhancement of its historic properties and cultural resources. The document delineates GSA’s historic preservation program and cites laws and regulations that guide GSA’s preservation policy as well as their NHPA compliance responsibilities. It also establishes professional standards for GSA personnel responsible for their national and regional preservation programs, as well as other staff members engaged in activities that affect historic resources. Finally, it outlines the methodology for effectively integrating federal stewardship goals into GSA’s business activities.

Site Selection Guide, [March 2003], GSA Public Building Service, Office of the Chief Architect    

GSA has broad discretion in selecting sites for public buildings under 40 U.S.C. Section 3304. The Site Selection Guide provides an outline for the entire site selection process. Projects that may adversely impact historic sites, districts or individual buildings which may contribute to a districts historic significance are required under Section 106 of the NHPA to consult with the ACHP and the appropriate SHPO. The consultative process is fully described in the document. The guidance also make reference to other policies such as EO 13006 “Locating in Historic Buildings in Central Cities” which requires that federal agencies give appropriate consideration to properties within historic districts when selecting locations for their facilities.

Executive Order 13006 Fact Sheet: Locating in Historic Buildings in Central Cities, [2000], GSA Center for Historic Buildings 

The Fact Sheet includes what the order means to GSA, why it's important to the way they do business, information on outreach efforts designed to raise GSA employees' and other federal agencies' awareness of and compliance with EO 13006, and contact information for those who want to know more. 

Article: The Economics of Preservation. [Published in the National Trust for Historic Preservation "Forum Journal", Vol. 6, No. 1, Sept/Oct 1999]
Constance Ramirez, Donald R. Horn, and Bradley Wolf, of GSA  

In this article, GSA demonstrates that many older historic buildings can be more efficient and profitable than newer buildings. The Article is one of many new approaches to property management now reshaping the way GSA manages its extensive holdings of historic real estate. Issues such as operating costs, customer satisfaction and functional replacement values are discussed in making the economic argument for preserving historic resources as opposed to new construction.

U.S. Court Design Guide, [Published 1991, revised December 1997],
Securities and Facilities Committee of the Judicial Conference of the United States 

The U.S. Court Design Guide, which have been revised four times since their initial publication, describe the types of spaces associated with facilities for the U.S. Court of Appeals, U.S. Districts Courts, U.S. Magistrate Judges, and U.S. Bankruptcy Courts. The Courts Design Guide provides new and revised design criteria for renovating existing court buildings, retrofitting other types of buildings, renovating and retrofitting historic buildings, and accommodating courts in multi-tenant and leased facilities. Since new Court House constructions can have substantial impacts to historic districts and sites, the guidance provides a section dedicated to addressing these issues.

GSA Historic Building Leasing, [February 2000], GSA Center for Historic Buildings and the Arts Center of Expertise 

The GSA Historic Building Leasing Study was undertaken to determine the extent to which GSA leases space in historic buildings and the influence of the preference on leases awarded. The study also identifies obstacles to leasing historic buildings, and strategies for increasing such leases. Quantitative as well as qualitative data is presented with lists of major tenant in GSA historic properties. Data is relevant as of 2000.

Growth, Efficiency and Modernism: GSA Buildings of the 1950s, 60s and 70s, [Fall 2003], GSA Center for Historic Buildings 

On December 5, 2000, GSA brought together 75 leading private-sector architects and preservation experts to discuss how to best contend with the aesthetic and performance challenges of GSA buildings constructed between 1960 and 1979. The GSA symposium, Architecture of the Great Society was held at Yale University in New Haven, Connecticut, in partnership with the Yale School of Architecture, the ACHP, the American Architectural Foundation, and the National Trust for Historic Preservation. Results of the symposium readdressed the study period to include those buildings significant to the 1950s as well. The Modernism publication provides the context for evaluating the historic and architectural significance of GSA’s mid century modern buildings as they near the 50-year threshold for National Register eligibility. Richly illustrated with significant examples of the Modernism movement, the publication is also available as a hardbound copy by contacting GSA’s Centers for Historic Buildings at historic.buildings@gsa.gov 

Extending the Legacy: GSA Historic Building Stewardship, [Fall 2004], GSA Center for Historic Buildings  This report is a follow-up to Held in Public Trust: PBS Strategy for Using Historic Buildings, released in 1999. The Legacy report examined GSA stewardship successes and challenges within the framework of the agency’s business approach in improving and maintaining federal workspace. The current report is part of GSA’s ongoing self-assessment of its stewardship responsibilities under the current NHPA as amended in 2000. In addition, it fulfills, in part, GSA’s reporting obligations under Executive Order 13287 Preserve America, issued in 2003, to improve federal stewardship accountability and promote heritage tourism. Richly illustrated, the publication is also available as a hard copy by contacting GSA’s Centers for Historic Buildings at historic.buildings@gsa.gov 

Section 106 Notes

Case Digest of GSA Cases

Each year thousands of federal actions undergo Section 106 review. The vast majority of the cases is routine and resolved at the state or tribal level, without the ACHP’s involvement. However, a considerable number of cases, present issues or challenges that warrant the ACHP’s attention. In addition, the creation of the GSA liaison position has presented GSA with the opportunity to highlight and provide effective consultation in GSA cases which:

  • have substantial impacts on historic properties;
  • presents important questions of policy or interpretation;
  • have the potential for presenting procedural problems; and/or
  • presents issues of concern to Indian tribes or Native Hawaiian organizations.

In the past, the ACHP’s quarterly Case Digest report has highlighted a few of these case, however, since the establishment of the Liaison position there has been a more consistent presence. Click here for the PDF of the Case Digest archives. Therefore, due the expanding and unique complexities of GSA cases, the Liaison will be highlighting these and additional 106 cases than those normally presented in the Case Digest. The database will have a link, which will be posted within this section soon.       

 

GSA Memorandum of Agreement and Programmatic Agreement Database

The GSA Liaison has created an accessible database of GSA MOAs and PAs for users in pdf format. The agreements can be found under their respective GSA Region (1-11). For example, an agreement document for the state of New York would be under the Region 2 folder. The documents are available and are a useful tool in determining if your current 106 case may have similarities with other previously successful agreements scenarios. These agreement documents can be beneficial as a first step in drafting an agreement document. However, it must be stressed that each project is different and unique, and al negotiations and resolutions should always be conducted under the 106 consultative process. These documents should not be construed as boilerplate. The GSA Liaison will be managing this link and constantly updating it with the latest agreement documents, so periodic visits are recommended. The link can be found at: http://www.achp.gov/GSAagreements/     

Programmatic Agreement among Region 8 of the General Services Administration: The State Historic Preservation Office of North Dakota; [Colorado and Utah]; and the Advisory Council on Historic Preservation regarding the Preservation, Maintenance, Rehabilitation and Leasing of Historic Properties

In August 27, 2002, the GSA’s Rocky Mountain regional office (Region 8) notified the ACHP that it was interested in developing Programmatic Agreements (PA) for the management of its historic resources for those States within their jurisdiction (Montana, Utah, Colorado, Wyoming, South Dakota and North Dakota). We assisted them in the development of the first two such PAs, with the States of Utah and Colorado, which were signed by the ACHP in February 9, 2004. These individual State PAs will guide Region 8 in the preservation, maintenance, rehabilitation and leasing of their historic properties. The agreements are a direct result of GSA’s interest in avoiding future contentious preservation issues such as occurred in the State of Utah with the new U.S. Courthouse project in Salt Lake City. 

The PA for the state of North Dakota was signed in December 12, 2004. As in the Utah and Colorado PAs, this PA established GSA’s management procedures for their regional preservation and rehabilitation program, leasing program, and approval process. It will provide an opportunity for the parties to this agreement to participate in a meaningful and timely manner to assist the region in fulfilling its responsibilities to identify, evaluate and take into account the effects of its undertakings on historic properties pursuant to Section 106 of the National Historic Preservation Act (NHPA). It will also provide the North Dakota SHPO and the ACHP the opportunity to assist GSA in fulfilling its responsibilities pursuant to Section 110 of the NHPA. The ACHP is listed as the mediator if procedural disputes arise in the implementation of this PA.  In addition, the agreement contains undertakings excluded from review by the North Dakota SHPO, which will expedite the management of the identified historic resources. Finally, there are stipulated training requirements for all regional building management staff on the importance of historic preservation and correct standards for the maintenance and rehabilitation of these resources. The PA can be found in the aforementioned MOA/PA database.

African Burial Ground, New York, NY   

In 1991, the remains of more than 400, 17th and 18th century Africans were discovered during construction of the Foley Square Project Federal building in New York City. The finding deeply impacted the descendants and broader community and at the same time renewed awareness in cultural significance and historic preservation.  Since then, the GSA has been driven to complete what has become known as the African Burial Ground Project, a major effort to memorialize the legacy of those buried at the site.

Visit the web site at africanburialground.gov for more information.

Agency and Related Links 

GSA Center for Historic Buildings Web site

The General Services Administration home page is www.gsa.gov.  The Centers For Historic Buildings has an excellent web site with a wealth of technical information as well as publications and guidelines not mentioned here at www.gsa.gov/historicpreservation.

Historic Building Posters & Screensaver 

Since 2001, The Center for Historic Buildings has featured over 45 of GSA's most significant historic buildings constructed between 1834 and 1965 in a poster series. The handsome illustrations are in sepia tones and describe the name, location, date and principal architect. Architects include Cass Gilbert, Alfred B. Mullett, and Robert Mills. Available for downloading are years 2001 through 2004 PowerPoint Presentations showing the Poster Series from those years and a Screensaver for PCs. If you would like a hard copy please notify the corresponding Regional Historic Preservation Officer for your state.
Historic Federal Buildings Database: Electronic database of GSA owned historic federal buildings, which can be searched by state or architect. Includes a Statement of Significance, National Register ID number and images of the building if available.
National Register Nomination: Electronic database with pdf copies of nomination forms of GSA owned National Register Listed buildings.


Updated September 11, 2007

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