The URL can be used to link to this page

Home My WebLink AboutSubmittal - Warren Adams - EmailThe following email was submitted into the public record by Warren Adams during the October 11, 2018 City Commission Meeting in connection with the planning and zoning files listed below. PZ.1/4659 PZ.2/4657 PZ.4/4643 PZ.5/4644 PZ.6/4645 PZ.7/4660 PZ.8/4661 PZ.9/4640 PZ.10/4662 PZ.11/4641 PZ.12/4642 PZ.13/4639 PZ.14/4638 PZ.15/4637 Adams, Warren Submitted into the public record for hem(s) on 10L11L2-018, city Clerk Fnmnn: Lotane,A|ioaSlade <A|issa.Lot ne@dos.mvf|ohdazom' Sent: Monday, October l' 2018 1103 PM To: Adams, Warren Cc Acosta, Ruben &; McDonald, Megan VV,;Parsons, Timothy A.;Aldridge, Jason H. Subject: West Grove Frame Multiple Property Designation Appeals Attachments: Appea|Letter4df Warren, | meant to send this on Friday — sorry for the delay. In the objection letter You attached to your email, there appears to be an overill confLl5ion or blending of the National Register and local designation processes. As you know, these are two separate processes. In addition' the PA referenced in the letter only applies to HUD funded projects and is currently not in effect. We have atteripted to answer ah of your questions be|ow. Please don't hesitate to contact me if you have questions. \ can he reached by phone all a0z/nnun at 850.245.6357 or you are welcome to reply all with questions. AJissn Slade Lot/ne I Bureau Chief, Bureau o[Historic Preservation | [)cyu�� SiahelIistoric Preservation ()Ricer I Division ofI1istmricalKeyourcey | Florida Dcpurtoncotof State | 5V0Soo(h8zonuu�h Street | TaJiahaayee,Florida 32399 1 0S0.24,5.6357 | 1.000.8477278 1 Fax: 830.245.6439 1 &}issa.1-uiane,@D()S.N1yf�orida.coon | pvww.8be,itage.cocn 1. Inconsistent Substantive and Procedural Application Programmatic Agreement does not mean all historic resources have been identified and it is a requirement of CLG certification and the Programmatic Agreement that surveys are regularly updated? The Division has been party toa2Ol2Programmatic Agreement (PA)with the City ofMiami and the A[HP-,specifically regarding the city's responsibilities to administer their assumed federal responsibility for Section 106 (of the National Historic Preservation Act) review and consultation for U.S. Housing and Urban Development (HUD) funded projects only. As you know, that PA has expired and we are close to signing a new one for HUD projects. in the 2012 PA, specifically the text of the 4"" Whereas clause (referenced in the objection letter), should not be interpreted to mean that all historic resources were identified by the city at the time of the PA's execution and that no further identification efforts were necessary. Rather, Stipulation U,Property identification, and Stipulation U,A.Long Range Identification and Surveys within the PA requiresthecitytocontinuecffortstoidentifvhistoricresources.Thetevtofthe4mVVhereasdauseison|ynoting that the city had previously conducted some historic resource surveys and made an effort to identify historic properties as required for the assumption of Section 106 responsibilities and the streamlined review process created in the 2012 PA. In addition, the Section 106 process deals with National Register listed and eligible proper -ties, not locally designated properties. Section 106 requires the ongoing identification and evaluation of historic resources. Overall, there appears tobeafundamental misunderstanding regarding surveys nfhistoric properties inthe letter you attached, Surveys cannot identify every historic property, due to limits on the available information and what is visible smust beperiodically conducted, asthe passage ofhmeleads tonew historic �_ ~��w'r~" arr h (I .� properties that now meet historic designation criteria based upon age. For example, the National Register considers properties potentially eligible once they become 50 years of age. Currently, we are surveying and evaluating properties that were built inl968,and next year vvewill move uptoI969,and soon. Can you please confirm that thematic designation is an established process at both the local and national levels? We can only speak for the National Register designation process that we facilitate, In our office we are no longer using the term "thematic designation,"though this isawell-known historic preservation concept. instead vveare currently developing what are known as Multiple Property Submissions (also known as multiple property documents or multiple property covers), These nomination documents provide the background historic context and criteria for evaluation of properties that share similar historic significance, architectural design' or other relationships, but which are not geographically adjacent to one other, which would allow for historic district nomination. Unlike local designations, National Register Multiple Property Submissions only provide context and a means for evaluation —they do not automatically list individually identified properties in the National Register. Properties identified by Multiple Property Submissions must be each individually nominated to the National Register, The local process may differ. 2. insufficient Documentation of Historical Significance Can you please confirm Chapter 23 of the City of Miami Code meets all CLG requirements in terms of its content? Our staff has reviewed the relevant section of Chapter 23 of the City of Miami Code and it appears to meet the Florida CLG Guidelines, especially in regards to the historic designation process. The relevant section is Sec. 23-4 of the City of Miami Code. This meets Guideline 2: Enforce oppropriotostate urlocal /ogis/otion/brdesignation and protection of historic properties inthe F|orida[LG Guidelines. C an frame structures? rooriate for a Multiple Property Designation of wood Our staff has reviewed a copy of the Wood Frame Vernacular Re5idences of Coconut Grove Village West Maltiple Proper*Designution. We did not see a methodology included, however, the process you described in your email is a valid means of conducting research fora Multiple Property Submission. National Register Multiple Property Submissions often include a section specifically addressing the research methodology, tided SummaryofIdentification and Evaluation Methods. We do recommend that future local reports include a similar section, as outlined in National Register Bulletin 16b. However, your office can set whatever requirements you wish for local designation forms and documentation as long as itisconsistent with your local preservation ordinance. Further, can you please confirm that the revised suggested wording for this section in Programmatic Agreements states: The City shall ensure that any determination byCertified Staff os towhether oproperty ishistoric, for purposes of this agreement, is supported by sufficient documentation to enable any reviewing parties to understand its basis. The proposed PA addressed in itern 1. above only applies to the historic review process initiated as part of Section 106 of the National Historic Preservation Act for the commencement of a federal undertaking (eithera federally permitted, managed, or funded project). This has not yet been signed, and the PA only applies tmprojects using HUD funding provided to the City ofMiami. Local designation is separate process covered in the local ordinance (city code). Can you please confirm the City Code meets all CLG requirements? Section 23-4 (a) to (c) outlines the process for designating properties to the local historic registry, including the criteria for designation, procedures for designation, notification, preparation of designation reports the review of such designations by the historic and environmental preservation board' and the right to appeal, These sections meet the requirements found in the Florida CLG Guidelines and generally follow the National Register of Historic Places Criteria for Evaluation and the NRlisting process. Submitted into the public Z ' record for bemb\ ' PZ.1&PZ.2ond PZ.4-PZ'15 ~ ° Can you please confirm that this document provides documentation guidelines for inclusion in the HABS/HAER collections and is not a requirement for inclusion on the Local Historic Register? The Secretary ofthe Interior's Standards and Guidelinesfor Architectural and Enyineering Documentation only applies to Historic American Building Survey (HA85) and Historic American Engineering Record (HAER) documentation, HABS/HAER documentation is sometimes used as part ofthe Section I06 process for mitigation of adverse effects to historic properties' usually when a building is dated for demolition. It does not apply to local historic designation, which is guided only by the local historic preservation ordinance, namely Section 23'4 of the City [ode. HAB5/HAER is not required for inclusion in the local register, The Department o/State �scommitted tooxcaHenm/, p/eaoemxnour Submitted into the public record for item(s) PZ.1&PZ.2 and PZ.4-PZ.15 onlO/11/2O18'City Clerk