HomeMy WebLinkAboutSubmittal - 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
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Submitted into the public
record for item(s)
PZ.1&PZ.2 and PZ.4-PZ.15
Adams, Warren on 10 11 2018 City Clerk
From: Lotane, Alissa Slade <Alissa.Lotane@dos.myflorida.com>
Sent: Monday, October 1, 2018 1:03 PM
To: Adams, Warren
Cc: Acosta, Ruben A.; McDonald, Megan W.; Parsons, Timothy A.; Aldridge, Jason H.
Subject: West Grove Frame Multiple Property Designation Appeals
Attachments: Appeal Letter.pdf
Warren,
I meant to send this on Friday — sorry for the delay. In the objection letter you attached to your email, there appears to
be an overall confusion 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 attempted to answer all of your questions below. Please don't hesitate to contact me if you have
questions. I can be reached by phone all afternoon at 850.245.6357 or you are welcome to reply all with questions.
Alissa Slade Lotane I Bureau Chief, Bureau of Historic Preservation I Deputy State Historic Preservation
Officer I Division of Historical Resources I Florida Department of State 1 500 South Bronough
Street I Tallahassee, Florida 32399 1 830.245.6357 1 1.800.847.7278 1 Fax:
850.245.6439 1 Alissa.Lotane,c DOS.NfyFlorida.com , www.flheritage.com
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 to a 2012 Programmatic Agreement (PA) with the City of Miami and the ACHP; 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 4th 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 II. Property Identification, and Stipulation II, A. long Range Identification and Surveys within the PA
requires the city to continue efforts to identify historic resources. The text of the 4th Whereas clause is only noting 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 properties, not locally designated
properties. Section 106 requires the ongoing identification and evaluation of historic resources.
Overall, there appears to be a fundamental misunderstanding regarding surveys of historic properties in the letter you
attached. Surveys cannot identify every historic property, due to limits on the available information and what is visible
from the public right i f w� Also, surveys must be periodically conducted, as the passage of time leads to new historic
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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 in 1968, and next year we will move up to 1969, and so on.
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 is a well-known historic preservation concept. Instead we are 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 1: Enforce appropriate state or local legislation for designation and protection of
historic properties in the Florida CLG Guidelines.
Can you please confirm that the method used by Staff is appropriate for a Multiple Property Designation of wood
frame structures?
Our staff has reviewed a copy of the Wood Frame Vernacular Residences of Coconut Grove Village West Multiple
Property Designation. We did not see a methodology included, however, the process you described in your email is a
valid means of conducting research for a Multiple Property Submission. National Register Multiple Property Submissions
often include a section specifically addressing the research methodology, titled Summary of Identification 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 it is consistent 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 by Certified Staff as to whether a property is historic, for purposes
of this agreement, is supported by sufficient documentation to enable any reviewing parties to understand its basis.
The proposed PA addressed in item 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 (either a federally permitted,
managed, or funded project). This has not yet been signed, and the PA only applies to projects using HUD funding
provided to the City of Miami. Local designation is a 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 NR listing process.
Submitted into the public
record for item(s)
PZ.1&PZ.2 and PZ.4-PZ.15
on 10/11/2.018, City Clerk
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 of the Interior's Standards and Guidelines for Architectural and Engineering Documentation only applies to
Historic American Building Survey (HABS) and Historic American Engineering Record (HAER) documentation. HABS/HAER
documentation is sometimes used as part of the Section 106 process for mitigation of adverse effects to historic
properties, usually when a building is slated 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 Code. HABS/HAER is not
required for inclusion in the local register.
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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