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with Section 106 Section
106 in Action Archive
of Prominent Section 106 Cases Michigan: Demolition of Allen
Park VA Medical Center
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).
Recent Developments
On September 27, 2001, ACHP issued final
comments to the Department of Veterans Affairs (VA) on the closure,
demolition, and transfer of the Allen Park Veterans Affairs Medical Center
(VAMC) to the Ford Motor Land Development Corporation (Ford). Facing a
September 30 deadline for entering into a demolition contract with Ford,
VA terminated consultation after the consulting parties failed to reach
agreement on mitigation measures under consideration, including establishment
of a broad-based preservation fund and phasing of demolition to permit
further exploration of preservation
alternatives.
Despite this, promising discussions continued between the Michigan State
Historic Preservation Office (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
VAs deadline.
In its comments, ACHP recommended that VA carry out the mitigation
that it originally proposed, including recordation. These measures exhaust
the possible on-site mitigation, but the circumstances of the case highlight
broader issues regarding VAs stewardship of historic properties.
Thus, the comment letter also calls on VA to enter into a dialogue with
ACHP to explore these issues, including the status of cultural
resource management planning for VA facilities and the preservation opportunities
offered by VAs 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. Chairman Nau has requested a meeting with VA Secretary
Anthony Principi to discuss these and other issues.
Allen Park Veterans Affairs Medical Center, Michigan (photo courtesy of Dept. of Veterans Affairs)
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 constructions 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 for
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 rather than inpatient 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 complexs
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, VAs 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 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 facilitys 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 sites 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.
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
June 6, 2002
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