HomeMy WebLinkAboutSubmittal - Christine Rupp - Letter regarding Wood Frame HomesThe following email was submitted into the public record by Christine Rupp during
the October 11, 2018 City Commission Meeting in connection with the planning
and zoning files listed below.
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record for item(s)
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on 10/11/2018, City Clerk
ERICA
MOLLON
' CONSULTING
October 10, 2018
City of Miami
City Commission
3500 Pan American Drive
Miami, FL 33133
RE: Appeal of HEPB Resolution R-18-050
Local Designation of the "Wood Frame Vernacular Residences of Coconut Grove Village
West Multiple Property Designation"
Dear Members of the Miami City Commission,
I am writing in defense of the landmark designation of the properties included in the "Wood
Frame Vernacular Residences of Coconut Grove Village West Multiple Property Designation."
The proposed historic district contains vernacular -style houses associated with the area's historic
and continued settlement by black Bahamians, Southern African-Americans, and their decedents.
The structures included within the district form a cohesive unit and represent a shared history as
well as representing a distinct building typology unlike other buildings developed within the
greater Miami -Dade County context. The Multiple Property Designation format is based on the
national standard set forth by U.S. Department of the Interior and regulated by the National Park
Service, and the buildings contained within the boundaries of the proposed district meet the
national criteria for inclusion. Decades of prior precedent have established the legal standing for
historic preservation ordinances, including the designation of properties within a historic district
or a multiple property designation at the local level. Further, more recent research supports the
economic benefits of historic designation.
The local City of Miami Multiple Property Designation process reflects the standards established
under the Secretary of the Interior for inclusion on the National Register of Historic Places. The
nationally -recognized Multiple Property Documentation Form (NPS 10-900-b) nominates groups
of related significant properties based on the themes, trends, and patterns of history shared by the
properties.' Multiple property listings may arise from historic contexts identified in the Federal,
U.S. Department of the Interior, "How to Complete the National Register Multiple Property Documentation
Form," National Register Bulletin (Washington, D.C.: National Park Service, 1999), 2.
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Submitted into the public
record for item(s)
PZ.1&PZ.2 and PZ.4-PZ.15
on 10/11/2018, City Clerk
State, or local planning process? Multiple Property Documentation is used to nominate and
register thematically -related historic properties simultaneously or to establish the registration
requirements for properties that may be nominated in the future.3 As a management tool, the
thematic approach can furnish essential information for historic preservation planning because it
evaluates properties on a comparative basis within a given geographical area and can be used to
establish preservation priorities based on historical significance.4
The Multiple Property Designation often establishes historic districts. A historic district is
defined by the by the U.S. Department of Interior, National Park Service as an area that
"possesses a significant concentration, linkage, or continuity of sites, buildings, structures, or
objects united historically or aesthetically by plan or physical development.115 A district derives
its importance from being a unified entity, despite containing a wide variety of
resources. Districts can reflect one principal activity, or can encompass several interrelated
activities. Buildings within a district can lack individual distinction or architectural significance,
but as a group still retain enough integrity to qualify for designation. A district must be a
definable geographic area; however, a district can also be composed of two or more definable
significant areas separated by nonsignificant areas.6 As with individual resources, a historic
district can be found to have significance in at least one of four areas: are associated with events
that made a significant contribution to the broad patterns of our history; are associated with the
lives of significant persons in our past; embody the distinctive characteristics of a type, period, or
method of construction, or that represent the work of a master, or that possess high artistic
values, or that represent a significant and distinguishable entity whose components may lack
individual distinction; or have yielded or may be likely to yield, information important in history
or prehistory.? These national regulations are then incorporated into the local ordinances
established at the county and city level and while local historic district regulations vary
throughout the United States, most incorporate the regulation of alterations, demolitions, and
new construction permits within the official boundaries of the district.$
Since the establishment of the Historic Sites Act of 1935, a legal precedent to designate and
protect sites and buildings of significance was set. With the National Register of Historic Places,
created as part of the National Historical Preservation Act of 1966, a nationally -recognized
system was set in place. This system establishes a framework for state and local agencies to
2 ibid, 6.
3 ibid, 2.
4 ibid, 2.
5 Patrick W. Andrus and the Staff of the National Register of Historic Place, "How to Define Categories for Historic
Properties," National Register Bulletin, ed Rebecca H. Shrimpton (Washington, D.C.: U.S. Department of the
Interior, National Park Service, revised 2002) Part IV.
6 ibid, Part IV.
7 ibid, Part H.
8 Dianne Pierce O'Brien, "Measuring the Full Economic Impacts of Local Historic District Designations," (master's
thesis, Columbia University, 2013), 1.
v--4 EAICA MOLLON CONSULTING 1904.651-1447 1 EMMOLLON@CMAIL.COM 0---v
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record for item(s)
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on 10/11/2018, City Clerk
designate and set policies to protect sites of significance within their own municipalities. Within
the first decade, the legality of both the national and local preservation ordinances were tested.
Overwhelmingly, the courts sided with the preservation agencies finding that preservation, like
other zoning measures, do not constitute a taking and that laws and policies for historic
preservation reflect the priorities of a democratic society. They restrict things deemed harmful
and seek to promote actions that are viewed as beneficial. Historic preservation laws reflect a
decision by policy makers that our heritage, whether national or local, is significant and should
be preserved for future generations.9
The non-profit charity that owned and managed Sailors' Snug Harbor, a New York City
Landmarks Historic District, wanted the landmark status revoked claiming it was a hardship and
an unconstitutional taking. The Board of Trustees became one of the first entities to oppose
landmark designation and publicly question the legality of the property's regulation by the New
York City Landmarks Preservation Commission, citing that designation would interfere with the
profitability of the designated property. At first, the New York State Supreme Court ruled in
March of 1967 that designation of the buildings constituted an "unlawful taking of property
without just compensation" (Trustees of Sailors' Snug Harbor v. Platt, New York Supreme Court,
53 Misc. 2d 933, 280 N.Y.S.2d 75 (1967)). However, the court of appeals reversed the previous
year's original decision finding that the designation of the property was not considered a taking
(Sailors' Snug Harbor v. Platt, 29 App. Div. 2d 376, 288 N.Y.S.2d,314 (1st Dep't 1968)).10 The
appeals court determined that landmark preservation laws closely resemble zoning ordinances in
that they constitutionally regulate real property and are to protect the general welfare of
communities.I I Following the ruling, an editorial in The New York Times stated: "There is no
longer any doubt that the concept of preservation is not only in the public interest but is a
decisive factor in the quality of the environment."12
Additionally, denying the highest and best use of a property for the owner does not result in a
taking so long as the property owner retains viable use of the property, as determined by U.S.
Supreme Court Case Penn Central Transportation Co. v. New York City, 438 U.S. 104 (1978). In
this case, it was determined that the designation of Grand Central Terminal as a New York City
Landmark did not interfere with the building continuing to operate as a train terminal and was
therefore still a profitable business, despite the owner's desire to construct a new tower on the
site. The building, which was in poor condition at the time of designation, could still retain its
intended use, and while the construction of a new tower may have resulted in higher returns for
9 Timothy McLendon, et al, "Contributions of Historic Preservation to the Quality of Life in Florida," (Gainesville:
University of Florida, November 2006), 7.
10 "Sailors' Snug Harbor," New York Preservation Archive Project, Last modified 2016. http://www.nypap.org/
preservation-history/sailors-snug-harbor/
11 Mary Spearing, "Landmark Preservation: The Problem of the Tax -Exempt Owner," Fordham Urban Law Journal,
Vol. 3 no. I article 6 (1974): 125-126
12 "Sailors' Snug Harbor," New York Preservation Archive Project, Last modified 2016. http://www.nypap.org/
preservation-history/sailors-snug-harbor/
v ---O ERICA MOLLON CONSULTING 1904.651.1447 1 EMMOLLON@CMAIL.COM 0---v
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on 10/11/2018, City Clerk
the owner, they offered no evidence that they were incapable of making a profit off of the
existing, landmarked, structure. The transfer of development rights from the air space above
Grand Central Terminal continues to provide additional profits for the building forty years later,
and the rehabilitated building draws thousands of commuters and tourists to the site daily.
Recent research aimed at determining the economic impacts of preservation have found that
historic preservation is good for local economies and property owners. 13 From this large and
growing body of research, the positive impact of historic preservation on the economy has been
documented in six broad areas: 1) jobs, 2) property values, 3) heritage tourism, 4) environmental
impact, 5) social impact, and 6) downtown revitalization. 14 Historic preservation is one of the
highest job -generating economic development options available and across the country a one -
million -dollar investment in preservation generates more jobs than the same investment in
leading industries or new construction. 15 For property owners, a key factor for designation is the
documented property value increase for residential properties after they become part of a local
historic district. In Philadelphia, houses in local historic districts command a premium of 22.5%
over comparable properties not in historic districts. 16 In a small historic district in North Little
Rock, Arkansas, houses are worth on average $31,000 more than comparable houses not in the
district; resulting in annual additional revenues for the county of $40,000, for the city of $50,000,
and $200,000 for the school district. 17
Beyond increasing home values, creating jobs, and increasing tax revenues, historic preservation
drives heritage tourism. Historic preservation provides the setting, the history, the persona, and
the traditions for heritage tourism; heritage tourism provides the opportunity to educate, enjoy,
and appreciate historic preservation. 18 In 2007, heritage tourists in Florida spent an estimated
$4.13 billion and 46.7% of all U.S. visitors to Florida reported visiting a historic site during their
stay. 19 In 2004, nearly 80 million tourists visited Florida and brought more than $57 billion to the
Florida economy. Of those, 9.2% identified visiting historic sites and museums as the primary
purpose for their visit, with another 3% identifying local cultural events and festivals as their
major activities 20 Within the United States, international heritage visitors stay longer, visit more
13 P1aceEconomics, "Measuring the Economics of Preservation: Recent Findings," (Washington DC: Advisory
Council for Historic Preservation, June 2011), 1.
14 ibid, 1.
15 Donovan D. Rypkema, "Economics and Historic Preservation," Forum Journal and Forum Focus (Washington.
D.C.: National Trust for Historic Preservation, December 2015). https:Hforum.savingplaces.org/connect/community-
home/librarydocuments/vi ewdocument?
DocumentKey=01472cec-22ab-4ffe-90a2-8577c1 al5d6b&CommunityKey=00000000-0000-0000-0000-000000000
000&tab=librarydocuments
16 P1aceEconomics, 3.
17 ibid, 3.
18 Timothy McLendon, et al, 7.
19 PlaceEconomics, 4.
20 Timothy McLendon, et al, 21.
v-0ERICA MOLLON CONSULTING 1904.651.1447 1 EMMOLLON@CMAIL.COM 0}-
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places, and spend more per day than other tourists. 2.6 million more international tourists visited
a historic place than went to an amusement park; 4.1 million more than went to the beach; four
times as many than went to a casino. For every international visitor who played golf, 14 visited a
historic place 21 In Fernandina Beach, FL, the city realized that the historic resources represented
a basis on which to build a tourism industry and the basis for desirable economic development
outcomes. With a total of over 330 buildings in two key historic districts, the town has become a
tourist destination leading to a rapid rise in property values and increase tax revenue 22
According to Florida Statues, "the rich and unique heritage of historic properties in this state,
representing more than 10,000 years of human presence, is an important legacy to be valued and
conserved for present and future generations. The destruction of these nonrenewable historical
resources will engender a significant loss to the state's quality of life, economy, and cultural
environment.1123 The landmark designation of the properties included in the "Wood Frame
Vernacular Residences of Coconut Grove Village West Multiple Property Designation"
represents a cohesive historic district that is consistent with the regulations outlined by the
Secretary of the Interior and national best practices. The thematically -cohesive nomination
would create a historic district that would protect the rare typology found in Coconut Grove
Village West. Further, the multiple property format and landmark designation in general have
been upheld in all levels of courts across the United States, including the U.S. Supreme Court.
And ultimately, landmark designation is economically beneficial for both the property owner and
the local municipalities. As the research cited here demonstrates, those contributions are
measurable, positive, and significant to a local economy.24
Thank you for your consideration,
Erica Mollon
Preservation and Urban Planning Consultant
21 PlaceEconomics, 5.
22 Timothy McLendon, et al, 12.
23 2018 Florida Statues, Title XVIII Public Lands and Property, Chapter 267 Historical Resources, 267.061 Historic
properties; state policy, responsibilities, la.
24 PlaceEconomics, 9.
v-- *ERICA MOLLON CONSULTING 1904.651.1447 1 EMMOLLON@CMAIL.COM 0--v
zi ERICA
MOLLON
CONSULTING
WORK EXPERIENCE
Erica Mollon Consulting
Preservation and Urban Planning Consultant
Submitted into the public
record for item(s)
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on 10/11/2018, City Clerk
QUALIFICATIONS
October 2017 -present
• Provides preservation and urban planning services including cultural resource surveys, historic
properties documentation, archival research, significance assessments, cultural landscape reports, and
Local, State, and National Register nominations.
• Combines experience working on preservation and urban planning projects in New York City, Albania,
Myanmar, and Trinidad and Tobago to provide a global approach to cultural heritage challenges.
AKRF July 2015 -present
Architectural Historian and Planner
• Led three -borough survey for the New York State Office of Parks, Recreation, and Historic
Preservation (OPRHP) to identify and document historic resources. Responsibilities included
budgeting; coordinating and managing a team of internal employees, seasonal interns, and external
consultants; establishing a workflow; and building and maintaining databases.
• Managed urban design and historic and cultural resource project tasks related to Environmental Impact
Statements (EIS) and Environmental Assessment Statements (EAS).
• Analyzed and identified potential impacts to historic resources pursuant to Section 106 of the National
Historic Preservation Act reviews and section 14.09 of the New York State Parks, Recreation, and
Historic Preservation Law.
• Collaborated with graphic designers and GIS specialists to develop a process for the visual
communication of large-scale projects on urban design.
• Established a process for standardized documentation for New York State Department of
Transportation (DOT) and New York City Department of Design and Construction (DDC) Section
106 projects.
Cultural Heritage without Borders Albania June 2014 -August 2014
Harriman Pepsico Research Fellow
• Recipient of competitive fellowship from the Harriman Institute at Columbia University to work with
an international non-profit whose work uses preservation to build collaborative relationships,
understanding, and work toward reconciliation following conflict.
• Led a team of five people in conducting an onsite survey of the prison site, geolocating key buildings
and work sites, and documenting current conditions through photographs and measured drawings.
• Developed a strategic plan for the preservation and adaptive reuse of a work camp prison site including
precedent research and formal site documentation.
Columbia University in the City of New York August 2013 -May 2015
Teaching Assistant
• Served as the teaching assistant to the Preservation and Planning Studios.
• Aided 15-20 students in surveying and identifying architectural resources in the Yorkville neighborhood
of Manhattan and in identifying key community gathering spaces surrounding a potential development
site in Brooklyn.
• Assisted the head of the department and professors in creating presentations and organizing lectures.
Greenwich Village Society of Historic Preservation June 2013 -August 2013
Research Intern
• Researched and authored building descriptions with current condition assessments in the East Village
neighborhood of Manhattan.
• Attended community board meetings and Landmark Preservation Commission hearings on behalf of
the Director of Preservation. Authored statements and provided testimony at Landmark Preservation
Commission hearings.
ERICA
�01a MOLLON
CONSULTING
Submitted into the public
record for item(s)
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on 10/11/2018, City Clerk
QUALIFICATIONS
EDUCATION
M.S., Historic Preservation and M.S. Urban Planning, Columbia University, New York, NY, 2015
M.B.A., University of North Florida, Jacksonville, FL, 2011
B.A., Fine Art, Agnes Scott College, Decatur, GA, 2002
PAPERS AND PUBLICATIONS
Columbia University
"Guiding Sustainable Development in East Port of Spain." Joint report with Inter -American Development
Bank, 2014.
"Yangoon, Myanmar at a Turning Point" Joint report with World Monument Fund, 2015.
"Measuring the Impacts of Preservation on Disadvantaged Communities." Master's Thesis, 2015.
Cultural Heritage without Borders, Spa_( Dialog
"Spay in Context." October 3, 2014.
"Building Conservation: Reconstruct, Rehabilitate, or Ruination?" October 7, 2014.
"Great Visitor Experiences Make Great Museums." October 10, 2014.
"Education and Outreach: The Heart of the Museum." October 16, 2014.
"Museums: Fundraising and Organizational Structures." October 29, 2014.
Docomomo US
"Mid -Century Modern Schools in Manhattan." Sept. 17, 2013.
Greenwich Village Society for Historic Preservation, Off j`' The Grid
"From Swill Milk to Swell Milk; One Building That Shouldn't be Put Out to `Pasteur."' June 28, 2013.
"No Need for a Mock UN at One East Village Elementary School." July 5, 2013.
"Lost Theaters of the East Village: Loew's Avenue B." Aug. 16, 2013.
PRESENTATIONS
Presenter, "New Voices in Preservation: The Next 50 Years," New York State Preservation Conference, May
5-7, 2016, Albany and Troy, NY.
CERTIFICATIONS AND MEMBERSHIPS
Meets Secretary of Interior's Professional Qualification Standards for Architectural Historians (36 CFR Part
61, Appendix A)
American Planning Association (APA)
Preservation Alumni
ERICA
k�'�, MOLLON
21CONSULTING
Submitted into the public
record for item(s)
PZ.1&PZ.2 and PZ.4-PZ.15
on 10/11/2018, City Clerk
Erica Mollon is a preservation and urban planning consultant with five years experience in
working in the industry. Ms. Mollon holds an M.S. in Historic Preservation and an M.S. in Urban
Planning from Columbia University. She has experience preparing Environmental Impact
Statements (EIS) and Environmental Assessment Statements (EAS) and in performing analyses
pursuant to Section 106 of the National Historic Preservation Act to identify and assess potential
impacts to historic resources. She specializes in historic properties, urban design and aesthetics,
and land use analysis, with experience in cultural resource field surveys, archival research, and
significance assessments. Before beginning her own consulting business, Ms. Mollon worked for
a New York City -based environmental planning firm and participated in preservation planning
projects in Myanmar, Albania, and Trinidad and Tobago.