Home Working with Section 106 Section 106 in Action Archive of Prominent Section 106 Cases Michigan: Demolition of Allen Park Veterans Affairs Medical Center

Agency: Department of Veterans Affairs

Criteria for ACHP Involvement:

• The proposed action will result in the demolition of a National Register-eligible historic district in its entirety (Criterion 1).

• The project raises questions regarding the timeliness of Section 106 review and the Department of Veterans Affairs’ interpretation of its responsibilities under Section 106 (Criterion 2).

In November 2001, Secretary Anthony J. Principi of the Department of Veterans Affairs (VA) responded to ACHP’s final comments on the closure, demolition, and transfer of the Allen Park Veterans Affairs Medical Center (VAMC) to the Ford Motor Land Development Corporation (Ford). His correspondence indicates that VA will follow ACHP’s recommendation to carry out the mitigation that VA originally proposed, including recordation.

Allen Park Veterans Affairs Medical Center, MI
(photo courtesy of Dept. of Veterans Affairs)

Regrettably, Secretary Principi’s letter did not address ACHP’s other recommendations regarding VA’s stewardship of historic properties. ACHP had called upon VA to enter into a dialogue with ACHP to explore the broader preservation issues highlighted by the Allen Park case. These include the need to evaluate the status of cultural resource management planning for VA facilities and the preservation opportunities offered by VA’s Enhanced Use Leasing Program, wherein VA may enter into leases with public and private entities to develop VA property for non-VA and/or VA uses.

Background

The Allen Park VAMC was constructed between 1937 and 1939 on land in Allen Park, near Detroit, which was donated to the Federal Government by Henry and Clara Ford. The complex is one of 50 VAMCs developed between 1920 and 1946 that have been determined eligible for the National Register of Historic Places as part of a thematic group. Georgian Revival in design, the eight-building complex is dominated by the main hospital building, the original central portion of which is surrounded by large additions from 1949 and 1961.

In 1986, the VA decided to construct a new VAMC in downtown Detroit. It is unclear to what extent this construction’s foreseeable impact on historic properties at Allen Park VAMC received adequate environmental review at that time. It appears that consideration of any such effects was essentially “postponed” for later review under Section 106 and was not addressed substantively during compliance with the National Environmental Policy Act.

In 1986, the long-range plan for the Allen Park VAMC site was reuse as a new long-term care facility with a primary care component. However, by the time that the new Detroit VAMC opened 10 years later, funding had never been allocated for new construction at Allen Park. Significant shifts had occurred in health care in the interim, bringing a new emphasis on outpatient care. A scaled-back nursing home was accommodated in the new downtown facility, leaving only a limited primary care facility at Allen Park, which used only about one-tenth of the complex’s square footage.

The original deed to the Federal Government stipulated that the land would revert to Ford if it ceased to be used for care of veterans. Given the underutilization of the property by VA, State and local representatives entered into discussions with VA and Congressman John D. Dingell regarding the potential for the land to revert to Ford, which would return it to the tax rolls. By the spring of 2000, VA’s preferred alternative was to demolish all buildings on the site and transfer the property to Ford. (The reversion clause does not require specifically that the site be cleared before transfer, but Ford and VA have agreed to that interpretation of its intent.)

VA did not initiate Section 106 consultation with the Michigan State Historic Preservation Office (SHPO) during the discussions regarding the fate of the complex, and it is not clear that the historic significance of the property was fully considered in decisionmaking. The facility’s Cultural Resource Management Officer played a very limited role in the discussions, and there was no Cultural Resource Management Plan for the complex, despite a VA policy directive requiring one.

Intervening congressional action then precluded the option of discussing alternatives to demolition during Section 106 review. The Veterans Benefits and Health Care Improvement Act of 2000 (P.L. 106-419) included a provision requiring VA to enter into a contract with Ford to demolish the Allen Park complex and remediate the site’s hazardous materials. The legislation authorizes VA to pay Ford up to $14 million to cover costs.

In January 2001, VA initiated consultation pursuant to Section 106. Proposed mitigation for demolition of the complex included recordation of the complex; archiving of historic records; consultation with the Michigan SHPO on a commemorative flagpole and memorial called for in the legislation; and allowing the Allen Park Historical Society to salvage architectural elements.

ACHP elected to join the consultation following a request from the Michigan SHPO. Since Ford indicated that it did not have clear plans for the site, the consulting parties questioned whether Ford might delay total demolition while exploring possible options for preservation during its planning efforts. In addition, the Michigan SHPO, the National Trust for Historic Preservation, and State and local preservation organizations requested establishment of a $2 million historic preservation fund to benefit other historic properties, patterned on several such funds that have been established as mitigation for projects in other parts of the country.

Facing a September 30, 2001, deadline for entering into a demolition contract with Ford, VA terminated consultation after the consulting parties failed to reach agreement on mitigation measures. Despite this, promising discussions continued between the Michigan SHPO, Ford, and local preservation groups regarding possible off-site mitigation at another historic property owned by Ford, the Packard Motor Car Company Proving Ground Testing Facility. Ultimately, however, such talks could not be brought to closure before VA’s deadline, and ACHP issued final comments to VA September 27, 2001.

Policy Highlights

VA controls a significant number of historic resources and must seek to balance its stewardship against changing residential and health care needs of veterans. Unfortunately, the agency has a limited number of professional cultural resource staff to meet this need.

As illustrated in this case, too frequently historic preservation is not integrated into decisionmaking. Reversing this trend is important, since aging of the infrastructure and shifts in patient care policies and expectations will doubtless result in a growing number of cases sharing the fundamental issues seen at Allen Park.

Staff contact: Druscilla Null

Updated May 6, 2003

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