Military Family Housing History

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    THE COSTOFMAINTAININGHISTORIC

    MILITARY FAMILYHOUSING

    UNITED STATESDEPARTMENTOFDEFENSE

    February 2001

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    Cover Illustration: Officers Quarters, United States Military Academy, West Point, NY

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    The Cost of Maintaining Historic

    Military Family Housing

    For the

    Office of the Deputy Under Secretary of DefenseEnvironmental Security

    3400 Defense Pentagon, Room 3E791 Washington, DC 20301-3400

    Prepared by:

    The Center of Expertise for Preservation of Historic Structures

    and Buildings, U.S. Army Corps of Engineers, Seattle District

    Under Contract No. DACA67-97-M-0697

    John Cullinane AssociatesArchitects & Preservation Planners

    Annapolis, Maryland

    February 2001

    This study was conducted for the Legacy Resources Management Programunder the auspices of the Office of the Deputy Under Secretary of Defense

    for Environmental Security. The assistance of housing staff and culturalresources managers at the surveyed installations is greatly appreciated.

    This document is a Legacy program work product and does not necessarilysuggest or reflect the policy, programs, or doctrine of the Department of

    Defense, or United States Government.

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    The Cost of Maintaining Historic Military Family Housing

    CONTENTS

    EXECUTIVE SUMMARY

    BACKGROUND

    History of Family Housing What is Historic? Marsh Report Congressional Directives

    SCOPEOFTHE STUDYAND METHODOLOGY

    QUANTITYAND AGEOF QUARTERS

    FACTORS AFFECTING OPERATIONAND MAINTENANCE COSTS

    Compliance Requirements- Cultural Resource Requirements- Environmental Requirements

    Operation and Maintenance Costs

    THE COSTOF HISTORIC HOUSINGVS. NON-HISTORIC HOUSING

    RECOMMENDATIONSFORREDUCING COSTS

    Design &Treatment Alternatives Scheduling &Coordination Procedures Maintenance &Repair Procedures Material Selection Contracting

    CONCLUSIONS

    GLOSSARY

    SOURCES

    TABLES: TABLE 1MARSH REPORTTABLE 1AUNIT QUANTITY, NOVEMBER2000TABLE 2MANAGINGORREMOVING LEAD-BASED PAINTTABLE 3HISTORIC MILITARYFAMILYHOUSING QUANTITYAND COST DATATABLE 4HISTORIC MILITARYFAMILYHOUSING GROUND TRUTH COSTS

    TABLE 5EFFECTSOF MAINTENANCE PROCEDURESTable 6REPLACEMENT COST ANALYSIS

    3

    55678

    11

    15

    17

    17

    33

    39

    41

    47

    49

    57

    1516283435

    3839

    I

    II

    III

    IV

    V

    VI

    VII

    VIII

    IX

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    United States Department of Defense

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    The Cost of Maintaining Historic Military Family Housing

    EXECUTIVESUMMARY

    The maintenance and management of themilitary housing stock has been an issue ofdebate since the formation of a formal Army.Whether or not housing should be provided, howit should be paid for and maintained, and whetherit is considered appropriate compensation for thestresses associated with military service. Thesequestions have all been the focus of seeminglyendless examinations and reports. At the conclu-sion, the results have always been the same:

    1. it is appropriate for the military toprovide housing on-base for uniformed personnel

    and their dependents to insure readiness andefficient operations;

    2. the cost of maintaining family housingis substantial and increasing;

    3. the condition of historic military familyhousing diminishes as maintenance continues to bedeferred; and,

    4. the size and cost of historic militaryfamily housing units exceeds acceptable standards.

    All of these conclusions were cited in the

    Report of the Defense Science Board Task Forceon Quality of Life, chaired by former Secretary ofthe Army, John O. Marsh, Jr., and the reports ofthe Services response to Senate Report 104-287,which concurred with the Marsh Panel Report.

    Based on field observations, interviews,and surveys, it appears that there are two primarycauses for the high cost of maintaining historicfamily housing: the size of the units, and thepresence of hazardous material (lead-based paint).The per square foot cost of operating and main-taining the units is no higher than Operation and

    Maintenance (O&M) cost for non-historic units,and, in many instances, lower. However, becausethe unit size exceeds that allowed under currentstandards, the overall cost per year is higher.Attempts have been made at some installations toclose off portions of larger homes, hoping to saveon energy costs, and, in some instances, to investi-gate converting the large single family units intoduplexes. Neither effort proved very successful.

    The cost directly associated with lead-based paint is somewhat unreliable because of tworelated factors: the lack of any basis or guidance forassessment of risk, and the resulting inconsistenttreatment of lead-based paint across the Servicesand at each installation. In almost all cases, itappears that lead-based paint is being over treated.This has resulted in excessive costs in remediationof this material.

    In addition, there are a number of conflict-ing attitudes toward historic family housing. Frominterviews with installation housing staff, it appears

    that the opinion of those assigned to installationscontaining such housing, is that the properties addsignificantly to the positive quality of life forpersonnel and their dependents. On the otherhand, for those individuals responsible for manage-ment of military real estate, the properties holdlittle value and, thus, any investment in themrepresents a burden on the overall housing budget.

    There appears to be universal acceptancethat the first impression is correctthe quality oflife is greatly improved by the existence of historic

    housing at an installation, especially for those livingin that housing. The second assumption is subjectto interpretation, especially in an environmentwhere the Services are attempting to sell offproperties to private developers and corporationsunder Base Relignment and Closure (BRAC) andprivatization programs. The reality is that thefamily housing units represent no less of a valuethan a private residence in the marketplace, andtheir resale value can be significant.

    This study looked at the current condi-tions of the historic family housing, and the factors

    affecting operational and maintenance costs,compliance with laws and regulations, and issuesraised in the Marsh Report and Congressionaldirectives. The conclusion reached is that the costper square foot for operations and maintenance ofhistoric units is the same or less than non-historicunits and that cost savings can be achieved throughimproved management and operational proceduresfor both historic and non-historic housing.

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    United States Department of Defense

    4

    Upper right: Officers Quarters, Ft. Benning, GA; middle right: Building 172, Ft. Belvoir, VA; all others: Quarters, USMA.

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    The Cost of Maintaining Historic Military Family Housing

    I BACKGROUND

    HISTORYOF MILITARYFAMILYHOUSING

    Throughout the history of the military in theUnited States there has been a need to houseand provide for uniformed personnel and theirdependents. The quality and quantity of facilitiesdesigned to meet this need have varied greatly overthe yearsfrom family housing in old stables andshanties in frontier posts to the substantial, ma-sonry, single family quarters constructed in the1930s.

    Consistently, however, two major prob-

    lems can describe military family housinginadequate quantity and inadequate maintenance.These two issues have existed from the beginningof the military, and continue to influence housingprograms and decision-making in the Departmentof Defense and throughout the Services.

    The lack of adequate numbers of familyhousing units has generally been influenced bymilitary conflict and a lack of peacetime funding.Although the housing need was identified as earlyas the Revolutionary War, expenditures on perma-

    nent quarters during military conflict has beeneclipsed by the need to direct funds to the wareffort. Housing needs during these periods havebeen satisfied through the construction of tempo-rary facilities Once the conflict is over, historically,the numbers of uniformed personnel diminish, theimmediate need for housing is temporarily abated,and legislators are anxious to reduce militaryspending. The result is that limited funds havebeen available to keep pace with family housingneeds. The other issue, inadequate maintenance, isa result of the same conflict. However, in the case

    of maintenance, deferring work results in greaterfuture expense. The condition of housing was sopoor in the early 1920s that articles titled OurHomeless Army and Army Housing: A NationalDisgrace, were appearing in national magazines.

    There have been four major developmentperiods for family housing in the United Statesmilitary. The first occurred in the last decade ofthe 19th century, and first decade of the 20th

    century. Although the military had committeditself to housing its officers earlier in the 19thcentury, it was not until 1890 that the Quartermas-ter Corps developed standardized plans andinitiated a major effort to improve the quantity andquality of family housing. The QuartermasterGeneral reported in 1903 that the preceding yearsconstruction had vastly exceeded that of anyprevious year in the history of the Army. Aquantity of these housing units remain in activeservice throughout the military, as do a number ofindividual units constructed earlier in the 19th

    century.The second major housing development

    period came after WWI during the Great Depres-sion. In response to the Stock Market collapsePresident Hoover ordered federal agencies toexpedite public works projects, triggering theQuartermaster Corps to initiate housing contracts.This effort carried on during the Roosevelt Admin-istration, up until the outbreak of WWII. Alsobased on standardized Corps plans, the familyhousing units constructed during this period

    represent the largest number of historically signifi-cant family housing units in the military inventory.The third period occurred during the

    1950s with construction of Wherry and Capeharthousing. This was the largest increase in familyhousing units, adding over 55,000 to the militaryinventory. In an effort to address a major housingshortage following WWII, and to avoid the use oftax money to build all of the units needed to meetdemand, Congress passed the Wherry Bill in 1949,providing mortgage insurance through the FederalHousing Administration to private developers

    willing to construct housing on military bases.Congressional limitations on the amount of moneywhich could be spent on Wherry housing unitsmade it difficult to construct adequate numbers ofunits in high cost areas. Military personnel paidrent on the units directly to the developers out oftheir housing allowance. In 1955 Congressestablished a variation on the program, CapehartHousing.

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    Similar to Wherry Housing, the Capehartprogram relied on private developers to constructhousing units but, instead of having personnel payrent, the government paid off the principal andinterest on the units over a 25-year period. As partof the Capehart program, all Wherry Housingunits were purchased by the government.

    During the Administration of John F.Kennedy, the Secretary of Defense asserted a newmilitary housing policy. Robert McNamara statedthat, to the extent possible, the military woulddepend on the civilian economy to provide housingfor service families.

    The fourth major family housing develop-ment period came as part of the defense spending

    increases during the Reagan Administration. It wasat this point that DoD used a variety of fundingand construction programs to accomplish its goal.Housing units were built using direct Congres-sional appropriations, Section 801 and 802programs, build-to-lease, rental guarantee, andother programs authorized under the FY84 militaryauthorization.

    Prior to the late 19th century, militaryfamily housing was generally individually designedin the style of the day. Starting in the 1870sstandardized plans for a variety of building types

    started to be used selectively across the country,including plans for family housing. After 1890most family housing units are direct copies, orvariations of standardized plans. Regional avail-ability of materials and craftsmanship influencedfinal design but, for the most part, variations wereminimal. Wherry and Capehart housing, on theother hand, relied on developers to design theunits, meeting minimum standards established bythe military. Accordingly, these units reflectregional differences.

    WHATIS HISTORIC?

    The mere fact that a property is old does notmake it historic. There has to be somereason beyond age to recognize a propertyfor itsplace in history, architectural style, association, orsome other value. For the purposes of this study,

    the designation of historic family housing refersto those properties that are: listed in the National Register of HistoricPlaces as an individual property, including NationalHistoric Landmarks; properties that have been determinedeligible for listing in the National Register; properties that meet the criteria for listingin the National Register; and, properties that are contributing elementsto a National Historic Landmark or NationalRegister historic district.

    Non-historic properties are defined asthose that do not meet the criteria for listing in the

    National Register, and properties that are notcontributing elements to a historic district.For a property to be considered historic, it

    must meet criteria that have been established bythe Department of the Interior. Under PublicLaws 74-292, and 89-665, the Department of theInterior was charged with establishing criteria foridentification of districts, sites, buildings, struc-tures, and objects significant in American history,architecture, archeology, engineering, and culture.These would be properties at the local, State, andnational level that contribute to an understanding

    of the historical and cultural foundations of theNation. All agencies are required to use thesecriteria to evaluate properties under their jurisdic-tion, and nominate those properties for recogni-tionlisting them in the National Register ofHistoric Places.

    National Register Criteria

    A property is historic if it possess integrity oflocation, design, setting, materials, workmanship,

    feeling, and association, and meets any one of thefollowing criteria:A. Association with events that have

    made a significant contribution to the broadpatterns of our history. (Examples of this would bebuildings that were constructed as part of or played arole in the settlement of the Nation, structuresassociated with the struggle for independence, WWI,WWII, and similar events.)

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    The Cost of Maintaining Historic Military Family Housing

    B. Association with the lives of persons significant in our past. (Examples includesites and buildings associated with military andpolitical leaders, engineers and architects, or greatstatesmen).

    C. Embody the distinctive character-istics of a type, period, or method of constructionor that represent the work of a master, or thatpossess high artistic values, or that represent asignificant and distinguishable entity whosecomponents may lack individual distinction.(Examples of properties that qualify under thiscriterion would include buildings that are characteris-tic of a particular period of architecture, such asColonial, Victorian, Beaux Arts, or International

    Style, properties that illustrate unique or outstandingengineering, and buildings that contain elements thatrepresent earlier periods of craftsmanship or art. Thiscriterion also encompasses buildings that contribute tohistoric districts, but would not be individuallyeligible for listing.)

    D. Have yielded, or may be likely toyield, information important in prehistory orhistory. (The best example of properties eligible undercriterion D are archeological sites, however, tradi-tional cultural properties, buildings, and engineeringsystems could also fit within this category.)

    Another level of recognition of a propertyis National Historic Landmark status. For aproperty to qualify as a NHL it must meet criteriasimilar to, but not identical to, the NationalRegister, and be of national significance. Aprevious Keeper of the National Register definedNHLs as properties whose presence is necessary totrace the history and development of the UnitedStates. All NHLs are automatically listed in theNational Register.

    There are some instances where a propertyis not ordinarily considered eligible for listing, suchas properties that have achieved significance withinthe past 50 years. However, such properties qualifyif they are integral parts of districts that do meetthe criteria, or if they are considered of exceptionalimportance at the local, State, or national level.Other exceptions to the criteria can be found inNational Register Bulletin 16A.

    Each Service has an internal system ofcategorizing buildings and structures; their classifi-cations ranging from very important to intrusions.These categories assist the Services and installationsin establishing treatment plans for the property,however, the National Register limits their recogni-tion to those properties meeting the aforemen-tioned criteria, either individually or as part of ahistoric district. National Register listing isrecognition of the importance of a property, it isnot directly related to its treatment or disposal.

    MARSH REPORT

    The Report of the Defense Science Board

    Task Force on Quality of Life, chaired by John O.Marsh, Jr., former Secretary of the Army, ad-dressed, among many other things, the cost ofmaintaining historic family housing. The report,issued in October 1995, focused on issues associ-ated with housing, personnel tempo, and commu-nity and family services, all directly related to thequality of life for uniformed personnel and theirdependents.

    As part of the Task Forces investigationsinto the status and condition of housing, questionswere raised regarding the prudence of maintaining

    historic family housing units. These questionswere generated by estimates of the funds requiredto upgrade existing housing to meet currentlivability standards, and to maintain those proper-ties to a level so that they contributed positively tothe quality of life at their installation. The TaskForces conclusion, based on cost estimates drawnfrom Service budget requests, was that mainte-nance of historic family housing was imposing anundue burden on the overall military housingaccounts, and that this burden should be decreased.

    The Task Forces investigations and itsfindings were not unique. As far back as 1870official inquiries found military housing to beinadequate and in poor condition. The studiesindicate that since its inception, family housing hasexisted in a cycle of improvement and disrepair. Asfunds are available, housing units are revitalizedand adequate maintenance is provided to insureefficient operations.

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    When funding is decreased, or diverted to moreimmediate issues, improvements to units do notoccur, and maintenance diminishes.

    The Task Force found four major prob-lems affecting the ability of the military to properlymaintain family housing:

    funding is not sufficient to produce,maintain, and operate quality housing adequately; current financial rules virtually precludeany innovative, creative methods to encourage orpromote private sector resource opportunities; housing policy is unclear, incomplete, andlacks the vision and strategy to affect change; and,

    federal laws and regulations restrict DoDsability to use its resources and the practices ofprivate industry to best advantage.

    The Task Force, when referring to the full,387,000 units of military housing, also found that... inadequate and inconsistent funding haveresulted in poor maintenance and repair, and hasdeferred revitalization and replacement of unsuit-able homes. Their estimate for correcting thesedeficiencies was more than $20 billion.

    Based on the Task Forces conclusions, the

    Marsh Report recommended that DoD, in con-junction with the Services, review current invento-ries of historic quarters and initiate actions toremove all but the most significant historic homesfrom the National Register. (The Task Force reportplaces the number of family housing propertieslisted in the National Register at 2,675, approxi-mately .69% of the military housing inventory.)The logic of this conclusion was that:

    there was inadequate funding to support

    family housing needs; the budget requests for revitalization andmaintenance of historic family housing units farexceeded requests for non-historic properties; the listing of the property on the NationalRegister was the trigger that made it historic; the fact that a property is consideredhistoric required the expenditure of the requestedfunds; and,

    because the property is historic, themilitary is required to comply with administrativereviews which add cost to the project throughdelays and enhanced treatment.

    The Report also concluded that thecondition of family housing in the military was indirect contradiction to the understood value offamily housing. In the Report, the Task Forceindicates that Housing can and should play apivotal role in mitigating some of the extraordinarystresses of military life, and that unsuitablehousing unnecessarily distracts Service membersfrom jobs that demand full attention to maintainconstant readiness .... The Task Force also found

    that The condition of family housing reflects thepriority a Service gives to quality of life in relationto other competing mission and readiness require-ments.

    CONGRESSIONAL DIRECTIVES

    In response to the Task Force recommen-dations, language in the FY97 Military Construc-tion Appropriation Bill (Report 104-287) directedthe Services to review current inventories ofhistoric quarters and provide a report to the

    appropriate committees on specific plans to removeall but the most significant historic homes (fromthe National Register.) The report should providewhat statutory impediments are being encounteredin implementing such plans.

    The Committee agreed with the TaskForces conclusion that maintenance of historicquarters was overburdening the military housingaccounts, and the language of the directive suggeststhat the Committee presupposed that the place-ment of a property in the National Register had a

    direct relation to the cost of its operation andmaintenance.Each of the military Services undertook

    the tasks under the directive, resulting in threeseparate reports: Report to Congress on Historic ArmyQuarters, March 1997; Department of the Navy Response toCongress on Historic Preservation, April, 1997;and,

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    The Cost of Maintaining Historic Military Family Housing

    United States Air Force CongressionalReport on Historic Homes, undated.

    Each of the Service reports concluded thatthe military did not have statutory authority toremove properties from the National Register, butthat there were administrative procedures whichcould be taken to relieve management cost bur-dens. The reports also concluded that the addi-tional cost to maintain these units was more aresult of their physical size than the fact that theywere historic, and listed in the National Register.

    Multi-family housing units at USMA, West Point, NY

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    United States Department of Defense

    Superintendents Quarters USNA, Annapolis, MD

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    The Cost of Maintaining Historic Military Family Housing

    II SCOPEOFTHESTUDYANDMETHODOLOGY

    The purpose of this study was to determine ifthe cost of maintaining historic familyhousing in the military was excessive, as comparedto non-historic housing units located on militarybases. To undertake this work it was necessary tofirst develop an acceptable definition of mainte-nance.

    Maintenance can be defined as the actionnecessary to keep a building in good repair andefficiency. This definition encompasses the workrequired to ensure that the building is structurallystable, and that all of the building systems, such as

    electrical, plumbing, heating, and moisture protec-tion, are operating as necessary for the functionalrequirements of the building to be met in a costeffective manner.

    For the purposes of this study, the cost ofproviding utilities to the property is consideredpart of the cost of operating it as an active housingunit.

    It was also necessary to define historicfamily housing unit. This task offers some interest-ing alternatives, but the deciding factor for federal

    property is whether it meets the criteria establishedby the Department of the Interior for listing aproperty on the National Register of HistoricPlaces.

    The factors which could affect bothoperating and maintenance cost of a property werethen identifiedunit size; condition; meetinglivability and treatment standards; hazardousmaterials; and energy conservation. Administrativeprocedures that may contribute to the cost werealso identified, such as, in-house reviews; consulta-tion required under internal or external regulations

    with interested parties; reviews and consultationwith State Historic Preservation Officers, and otherfederal agencies.

    In citing maintenance costs, the MarshReport used funding requests submitted by eachService. To ground truth the cost data, eightmilitary installations were selected among theServices to provide current information on costs to

    maintain historic and non-historic family housingunits (results shown on page 35.) The unitsrecorded were selected by the installation housingoffice, and representated a cross section of unittypes and sizes found at the installation.

    A survey was created to gather consistentinformation from these installations. The goal ofthe survey was to twofold: to identify actual, ratherthan projected maintenance costs, and to comparecosts for maintaining historic and non-historicunits (see survey questionaire, pages 13 and 14.)

    Three Department of the Army installa-

    tions were selected; two Department of the Navyfacilities, one Navy and one Marine Corps; and,three Department of the Air Force sites. Eachinstallation housing Point of Contact (POC) wascontacted, along with the cultural resource man-ager, and the goals of the survey were discussed andexplained. Survey forms were sent, and resultsreceived and tabulated.

    For the purposes of the survey, the installa-tions were given the following guidance. Historic Family Housing (question #5):

    For a property to be considered historic it musteither be: listed in the National Register of

    Historic Places; determined eligible for listing in

    the National Register; a contributing element in a

    National Register listed historic district, or aNational Historic Landmark district; or,

    meet any one of the criterion forlisting in the National register.

    New Family Housing: To qualify as newconstruction for this study a family housing unitmust be at least five years old, but no older than 20years. Major Repairs & Alterations (question#8): Work that was completed more than ten yearsagoadditions, revitalization, new roof, etc.

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    Utility Cost (question #11): Estimated ifnot metered.

    Livability vs. Historic Preservation (ques-tion #14): This question is attempting to separateout work that would normally be required tomaintain the unit in a livable condition vs. workthat is specifically required because the unit ishistoric. An example would be replacement of akitchen. It would be assigned to meeting livabilityrequirements, while the restoration of a tin ceilingin the kitchen would be appropriately assigned tohistoric preservation cost. Another example wouldbe the replacement of windows. If the replacementwindows were designed to match the historic

    windows, that cost could be attributed to historicpreservation.

    Standards (question #15): This questionrefers to any in-house design or constructionstandards, or standards such as the Secretary of theInteriors Standards for the Treatment of HistoricProperties.

    SHPO/ACHP (question #16): SHPO =State Historic Preservation Officer; ACHP =Advisory Council on Historic Preservation.

    Hazardous Materials (question #17): Leadbased paint; asbestos; radon; bird droppings; etc.

    The categories of data requested from eachinstallation were:

    - Installation Name;- Housing Unit Number;- Category Code;- Unit Configuration (single family;

    duplex; fourplex; other);

    - Historic/Non-Historic;- Construction Date;- Original Construction Cost;- Unit Size (in square feet);- Major Repair & Alterations;- Physical Condition (good; fair;

    poor);- Meets Livability Standards (yes;

    no);

    - Utilities cost per year;- Minor Repair (description);- Minor Repair Cost;- Percentage of work necessary to

    meet livability standards;- Standards or guidelines used;- Required review by the SHPO

    and/or the ACHP;- Whether reviews delayed or

    postponed the project, added cost;- Contain hazardous materials,

    what percentage of project cost;- Energy conservation component;- Accessibility requirements

    component;

    - Contracting methods;- Major Repair (description);- Major Repair Cost;

    (Same data sought on major repair as on minorrepair);

    - Estimated Maintenance Cost perYear;

    - Estimated cost to improveproperty to meetlivabilitystandards;

    - Current or Future Planned MajorImprovements; and,

    - Estimated Value of PlannedImprovements.

    In addition, discussions were held withheadquarters and other installation personnel,Corps of Engineers staff, and selected constructionmanagement professionals.

    The results of the interviews, combinedwith site visits, survey data, and anecdotal informa-tion, was used in development of a series ofconclusions on how the cost of maintaining

    historic family housing can be reduced.

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    The Cost of Maintaining Historic Military Family Housing

    1.InstallationName:

    2.HousingUnitNumber

    3.CatCode:

    4.UnitConfiguration: sing

    lefamily, duplex, fourplex,

    (circleone),other

    5.Historic: yes ;no

    6.DateofConstruction:

    6a.OriginalConst.Cost:

    7.Unitsizeinsquarefeet:

    8.MajorRepairs&Alteratio

    ns(withdate&cost):

    9.PhysicalCondition

    10.MeetsLivabilityStanda

    rds

    good ;fair ;poo

    ryes ;no

    Operation&Maintenanc

    eCosts

    11.Utilitiescostperyear(el

    ectric,gas,oil,water):

    12.MinorRepair(carriedou

    tinlastfiveyears)(painting

    ,roofpatching,windowrepa

    ir,etc.)

    13.MinorRepairCost(est)

    14.Whatpercentageofthew

    orkwasnecessarytomeetli

    vabilitystandards,codereq

    uirements,etc.,vs.

    historicpreservationrequir

    ements?%

    15.Wereanystandardsorg

    uidelinesusedwhendesigni

    ngorundertakingthework

    ,otherthanapplicable

    buildingcodes? yes

    ; no . Ifyes,what?:

    16.Didanyoftheworkrequ

    irereviewbytheSHPOand

    /ortheACHP? yes

    ;no .

    Didthesereviewsdelayor

    postponetheproject? yes

    ;no .Diditaddcost?y

    es ;no.

    17.Didthepropertycontain

    hazardousmaterialsthatre

    quiredspecialattentionund

    eranyofthe

    work? yes;no .

    Whatpercentageofproject

    cost?%

    18.Whatpercentageofthep

    roject(s),ifany,wasdesignedtomeetene

    rgyconservationgoals?

    %

    19.Whatpercentageofthe

    project(s),ifany,wasdesign

    edtomeetaccessibilityrequ

    irements?%

    20.Whatwerethecontractin

    gmethodsusedforthewor

    k?(circleallthatareapprop

    riate)

    LowBid;JOC ;

    Self-Help;DebitCard

    ; CreditCard;SABER

    ;

    OtherWouldadiffe

    rentcontractingmethodhav

    ebeenbetter?yes ;no

    .

    What?

    Why?

    DepartmentofDefenseStudy

    ontheCost

    ofMaintainingHistoricMilitaryFamilyHo

    using

    TestSiteSurvey

    Page2of4

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    21.MajorRepair(carried

    outinthelasttenyears)(revitalization,

    roofreplacement,wind

    owreplacement,etc.)

    (date&cost):

    22.TotalMajorRepairC

    ost(est):

    23.Whatperce

    ntageoftheworkwasn

    ecessarytomeetlivabil

    itystandards,coderequ

    irements,etc.,vs.

    historicpreservationrequirements?

    %

    24.Wereanystandards

    orguidelinesusedwhe

    ndesigningorundertakingthework,

    otherthanapplicable

    buildingcodes? yes

    ; no .Ifyes,what

    ?:

    25.Didanyofthework

    requirereviewbytheS

    HPOand/ortheACHP

    ? yes;no .

    Didthesereviewsdelay

    orpostponetheproject?

    yes ;no .Did

    itaddcost?yes ;

    no .

    26.Didthepropertyco

    ntainhazardousmateria

    lsthatrequiredspeciala

    ttentionunderanyofth

    e

    work? yes;no .

    Whatpercentageof

    projectcost? %

    27.Whatpercentageof

    theproject(s),ifany,wa

    sdesignedtomeetener

    gyconservationgoals?

    %

    28.Whatpercentageof

    theproject(s),ifany,wa

    sdesignedtomeetacces

    sibilityrequirements?

    %

    29.Whatweretheco

    ntractingmethodsused

    forthework?(circleall

    thatareappropriate)

    LowBid ;JOC ;Self-Help

    ;DebitCard;CreditCa

    rd ;SABER

    ;

    OtherWouldadifferentcontractin

    gmethodhavebeenbe

    tter? yes;no .

    What?

    Why?

    30.EstimatedMaintena

    nceCostperYear:

    31.Estimatedcosttoim

    provepropertytomeetl

    ivabilitystandards:

    32.CurrentorFuturePl

    annedMajorImprovem

    ents:

    33.EstimatedValueofPlann

    edImprovements

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    III Q UANITYANDAGEOFQUARTERS

    QUANTITYAND AGEOF QUARTERS

    The recorded number of historic familyhousing quarters within the military varies,depending on the types of units counted, and whois developing the list (see Table 1 below.) TheMarsh Report estimated the total number of unitsof military family housing to be 387,000. Thisnumber includes all units owned or leased by themilitary, on- and off-base. Their estimate of theaverage age of these units is 33 years. The TaskForce reported that out of that total, 2,675 units

    were listed in the National Register of HistoricPlaces, or just under 0.7% of the total.

    The military Services, in their reports toCongress, listed the number of historic familyhousing buildings under their jurisdiction. TheDepartment of the Army indicated that theirinventory of family housing listed in or eligible forthe National Register is 2,600, or approximately2% of their total family housing inventory. TheDepartment of the Air Force itemized, in theirreport, a total of 1,649 listed or eligible family

    housing buildings. The Navy reported 516 listedor eligible properties, approximately 0.6% out oftheir total 80,200 unit inventory. The average ageof Navy historic family housing is 88 years. Prop-erty age of the Army and Air Force units was notreported.

    The total number of listed and eligibleproperties reported by the Services was 4,765.Although the Task Force report appeared to countonly those family housing units listed in theNational Register, the Services listed the number ofbuildings containing family housing units thatwere either listed in or eligible for listing in theNational Register. The discrepancy in numbers is aproduct of reporting on units vs. buildings that cancontain more than one unit, and in countingnumbers of properties listed in vs. number ofproperties both listed in and eligible for listing in

    the National Register. Regardless, the total amountof historic family housing in the military inventoryis small, ranging between .5% to 2% of the familyhousing inventory.

    Out of those properties, a number havebeen identified as nationally significant. Thoseproperties have been designated by the Secretary ofthe Interior as National Historic Landmarks(NHL). The Department of the Army lists 11(eleven) such properties. There are 100 NHLslisted in the Air Force inventory, all located at F.E.

    Warren AFB. The Navy lists 172 of its historicfamily housing quarters as NHLs.Table 1 illustrates the numbere of units

    reported to Congress in response to the MarshReport questions. Table 1a, found on the nextpage, contains current inventory data.

    Table 1 Total MFH Units NR Listed NR Eligible NHL % of Inventory

    Marsh Report (Oct. 1995) 387,000 2,675 0.7

    Department of the Army Report 7861

    112

    2

    Department of the Air Force Report 943 706 100

    Department of the Navy Report 80,200 420 96 172 0.6

    1. Eligible properties are included in NR Listed number.2. Some of the NHL properties are districts containing a number of contributing family housing units.

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    A unique Navy propertyKiskiack

    16

    Table 1a Total MFH Units NR Listed NR Eligible NHL % of InventoryUnit QuantitiesNovember 2000

    Department of the Army 84,527 4,380 1 112 5.2

    Department of the Air Force 110,000 1,043 1,155 100 2

    Department of the Navy 55,5253 366 296 172 1.5

    1. Eligible properties are included in NR Listed number.2. Some of the NHL properties are districts containing a number of contributing family housing units.3. Current to close of FY99.

    Subsequent to providing housing data to theCongress in response to the Marsh Report, themilitary services have completed a full survey oftheir current housing inventory. The results of thatinventory are listed below. Housing unit totalshave been completed, and historic housing num-

    bers adjusted.

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    IV FACTORSAFFECTINGOPERATION

    ANDMAINTENANCECOSTS

    DIRECTIVES, INSTRUCTIONS, FEDERALLAWS, REGULATIONSAND STANDARDS

    COMPLIANCEWITH CULTURAL RESOURCEREQUIREMENTS

    NATIONAL REGISTEROF HISTORIC PLACES

    The Report of the Defense Science Board TaskForce on Quality of Life recommendedremoval of all but the most significant historichomes from the National Historic Register. TheTask Forces report directly associated listing in theNational Register of Historic Places with a require-ment to expend funds to maintain buildings. Thisassociation was assumed in the Congressionaldirectives responding to the Task Forces recom-mendations, and, in turn, was addressed in theServices responses to the Congressional language.

    The association of preserving and main-

    taining properties because of their listing in theNational Register is both incorrect and accurate.The listing of a property is recognition of thevalue of that property to the history, architecture,or culture of the United States. There is no directlink between listing and treatment, eitherthrough law or regulation. If a property is historic,however, federal policy, as established in theNational Historic Preservation Act of 1966 (PublicLaw 89-665; 80 Stat. 915, 16 U.S.C. 470 et seq.,as amended,) dictates that federal agencies take

    steps to avoid damage to that property.Listing in the National Register does notmake a property historic, or significant, it merelyrecognizes that status. If the National Register didnot exist, the property would still be historic, andsubject to protection under the policies establishedin the NHPA, and numerous Executive Orders,directives, instructions, and regulations. If aproperty is significant in history, design, planning,or culture, it is historic, whether or not the Keeper

    of the National Register, the State Historic Preser-vation Officer, local authorities, or an installationcommander have recognized it as such.

    On the other hand, the association oflisting in the National Register and treatment isaccurate because the military has made the assump-tion that there is a link. The assumption is that if aproperty is listed it must be maintained, and if aproperty is not listed, it need not be maintained.

    This results in the presumption that removal of aproperty from the National Register, or avoidingnominations of properties all together, will reducemaintenance costs. Whether or not a historicproperty is listed in the National Register, theagencys responsibility for management of thatproperty remains the sameit must be maintainedat a level that both supports that agencys mission,and is in the national interest.

    Listing of a property in the NationalRegister of Historic Places is not, and should notbe, a factor affecting operation and maintenancecosts. The listing of a property, however, canprovide a major benefit to the military in a periodof base closures. If a property is listed in theNational Register, certain provisions of the TaxReform Act of 1976, as amended by the RevenueAct of 1978 and the Tax Treatment Extension Actof 1980, may apply. These provisions encouragethe preservation of depreciable historic structuresby allowing favorable tax treatments for rehabilita-tion. Owners and developers of historic buildingsmay benefit from the investment tax credit provi-

    sions of the Revenue Act of 1978. The EconomicRecovery Tax Act of 1981 generally replaces therehabilitation tax incentives under these lawsbeginning January 1, 1982 with a 25% investmenttax credit for rehabilitations of historic commercial,industrial and residential buildings. This can becombined with a 15year cost recovery period forthe adjusted basis of the historic building. Historicbuildings with certified rehabilitations receiveadditional tax savings by their exemption from any

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    requirement to reduce the basis of the building bythe amount of the credit. This has proven to be amajor incentive in the privatization of historicmilitary property. Accelerating nominations ofproperties under the BRAC program to theNational Register will enhance their value todevelopers and private owners.

    The issue of appropriate authority foridentifying properties for listing in the NationalRegister was also raised in the Department ofArmys Report to Congress on Historic ArmyQuarters. That report recommends that theSecretary of Defense and the Congress examineways of providing a means for (the) Army to havefinal decision-making authority to de-list properties

    from the National Register of Historic Places andto determine what properties are eligible forlisting.

    The National Historic Preservation Act of1966 (NHPA) authorizes, and places the responsi-bility on the Secretary of the Interior to maintain aNational Register of districts, sites, buildings,structures, and objects significant in Americanhistory, architecture, archeology, engineering andculture. This listing crosses all agency lines, Statelines, and local community jurisdictions. The listis a reflection of the history and development of

    the entire country. Military history is an integralpart of that record and, appropriately, is part of thecontext in which all cultural properties are recog-nized. The absence of those properties, or the useof different criteria for listing military properties,would diminish the value of that record, and ourability to trace and understand our history.

    NATIONAL HISTORIC PRESERVATION ACTPOLICY& COMPLIANCE

    The National Historic Preservation Act, asamended (Public Law 89-665; 80 Stat 915;16 U.S.C. 470), sets forth national policy regardingthe treatment of historic properties. Section 2 (16U.S.C. 470-1) of the Act states:It shall be the policy of the Federal Government,in cooperation with other nations and in partner-ship with the States, local governments, Indian

    tribes, and private organizations and individualsto

    (1) use measures, including financialand technical assistance, to foster conditions underwhich our modern society and our prehistoric andhistoric resources can exist in productive harmonyand fulfill the social, economic, and other require-ments of present and future generations;

    (2) provide leadership in the preserva-tion of the prehistoric and historic resources of theUnited States and of the international communityof nations and in the administration of the nationalpreservation program in partnership with States,Indian tribes, Native Hawaiians, and local govern-ments;

    (3) administer federally owned,administered, or controlled prehistoric and historicresources in a spirit of stewardship for the inspira-tion and benefit of present and future generations;

    (4) contribute to the preservation ofnonfederally owned prehistoric and historicresources and give maximum encouragement toorganizations and individuals undertaking preser-vation by private means;

    (5) encourage the public and privatepreservation and utilization of all usable elementsof the Nation's historic built environment; and

    (6) assist State and local governments,Indian tribes and Native Hawaiian organizationsand the National Trust for Historic Preservation inthe United States to expand and accelerate theirhistoric preservation programs and activities.

    In addition to upholding the statedpolicies set forth by Congress, the NHPArequires federal agencies to follow specific adminis-trative processes in identifying, evaluating, andnominating properties to the National Register,

    and when any action they intend to take willadversely affect a historic resource.The Department of the Interior and other

    federal agencies have published volumes of regula-tions and directives interpreting each section ofNHPA, and detailing how to follow the adminis-trative process. As it relates to agency responsibilityfor historic properties, however, the basic premise

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    of the law is very simple. The federal governmentshould not participate in destruction or loss of ournational heritage, and government agencies shouldpractice and promote preservation within thegovernment and within the private sector.

    Section 110 (16 U.S.C. 470h-2) of the lawsets forth the goal of preservation of historicproperties which are owned or controlled by suchagency, and specific agency responsibility foridentification of resources.

    The Secretary of the Interior's Standardsand Guidelines for Federal Agency HistoricPreservation Programs Pursuant to Section 110 ofthe National Historic Preservation Act of 1966, asamended, April 24, 1998, provides advice and

    direction on development of internal agencyprograms for identifying, evaluating, and nominat-ing properties to the National Register, anddirectives to fully consider historic properties in theagency planning process.

    Section 106 (16 U.S.C. 470f) of theNHPA establishes the responsibility of the agencyto afford the Advisory Council on Historic Preser-vation an opportunity to comment on any under-taking that may have an effect on a historic prop-erty. These two sections of the law are the basis fora majority of preservation-related work undertaken

    by the military Services.The NHPA created the Advisory Council

    on Historic Preservation to advise the Presidentand Congress on preservation matters. TheAdvisory Council was structured as a peer reviewagency, to assist other federal agencies in manage-ment of historic resources. Through its regula-tions, 36 CFR Part 800, Protecting HistoricProperties the Advisory Council provides specificguidance on how to consider historic resources inagency undertakings.

    Section 110

    The cost of identifying, evaluating, andnominating properties to the National Register isan agency-wide administrative responsibility. Thisexpenditure is not related to the cost of operatingand maintaining historic family housing. Fundingfor surveys and nominations is usually through the

    planning or cultural resources management office,not through housing, and is undertaken on aprogrammed schedule not sensitive to individualprojects. The cost of a survey would impact anindividual family housing project if the survey hadnot been completed prior to project implementa-tion. Project delays resulting from completingsurvey work could increase project cost. In mostcases, however, project planning ensures that alladministrative requirements are completed beforeinitiating work.

    Section 106

    Compliance with Section 106 of the

    NHPA can be accomplished in a number of ways.The first method is on a project-by-project basis.In this case the 106 process would be initiated atthe time the project is in the initial planning stages.If the process is started at this stage the potentialfor increased project cost attributable to compli-ance is minimal. General practice at installations,however, starts the Section 106 process well intothe project planning and implementation phases.When initiated late in the planning process, orafter the project has moved into implementation,the potential for increasing cost due to delays rises

    significantly. Delaying the Section 106 processcan add cost to a project through delays in imple-mentation, resulting in increased construction cost;enforcement of requirements to consider alterna-tives to actions that would adversely affect historicproperties; and possible project redesign, resultingin lost or increased planning and design costs.

    A second way in which Section 106compliance can be accomplished is through aprogrammatic agreement (PA) among the consult-ing parties. When implemented, a PA establishes

    standards by which work will be carried out, andgenerally relieves the installation or agency of amajority of the project-by-project administrativecompliance effort and cost.

    A third alternative is development ofagency counterpart regulations. These wouldrequire the same considerations as 36 CFR Part800, but would be customized to the agencysspecific needs and operating procedures. Potential

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    cost savings would be derived through reduction inproject administrative cost, but increased staffingrequirements, or partnerships with SHPOs or otherreview agencies, could offset those savings.

    Compliance with 110 and 106 aregenerally considered to be burdensome and costlyat the installation level. This appears to be a resultof a number of factors:

    a. incomplete or inaccurate surveys,resulting in the need to undertake survey work on aproject-by-project basis, and in an atmosphere ofurgency;

    b. failure to involve cultural resourcemanagers in the initial stages of project planning;

    c. failure to agree on whether

    properties are historic, resulting in endless debateswith review agencies;d. failure to fully consider alterna-

    tives to actions that may have an adverse effect oncultural resources;

    e. initiation of the 106 reviewprocess after critical decisions have been made inproject design and development, or after theproject has been implemented;

    f. failure to be fully informed whenchoosing treatment options;

    g. failure to act in the best long-term

    interest of the Service and public when selectingtreatment; and,

    h. failure to act decisively oncetreatment and disposition choices have been made.

    There are no clear statistical data on thecost incurred as a result of these failures, althoughthere is an ample anecdotal record to suggest that asignificant number of projects have been delayed inthe review process and, at times, significant costhas been incurred as a result of failures to coordi-

    nate projects with in-house and outside agencyreviews.Evidence also suggests that, at times,

    outside review agencies have not carried out theirresponsibilities in the most effective and efficientmanner, also resulting in project delays.

    Compliance with 110 of the NHPA is anagency-wide responsibility. It should not beconsidered a responsibility of the housing office, or

    its cost be assigned to any individual project. If aninstallation survey is complete and is maintained,resource identification does not delay projectactivity.

    Compliance with 106 of the NHPA canbe streamlined in the manner detailed above, eitherthrough use of programmatic agreements, orthrough development and implementation ofcounterpart regulations. Until such mechanismsare in place, delays due to compliance can beavoided through early consultation, a commonsense approach to treatment, and decisive actiononce final choices have been made.

    SECRETARYOFTHE INTERIORS STANDARDS

    One issue regarding the cost of operatinghistoric family housing is whether themilitary services are required to maintain thatproperty to a higher standard than non-historicunits. Under policy, regulation and instruction,the Secretary of the Interiors Standards for theTreatment of Historic Properties (Standards) is thebasis by which all federally controlled historicproperties are to be treated. The Standards focuson a number of goals

    - no action will be taken that will

    damage or destroy the qualities of the historicproperty;

    - as much of the original buildingfabric will be retained as possible;

    - whenever feasible, damagedmaterial will be repaired, rather than replaced; and,

    - to the extent available, replace-ment material will match the original.

    How the Standards are interpreted andapplied is where additional cost can be found.

    Interpreting the Standards as requiring slavishreplication of missing materials or building systemsis incorrect and would result in excessive cost.Applying the Standards uniformly to all buildings,and to all portions of those buildings would,likewise, be inappropriate and costly. Applicationof the Standards must be undertaken with com-mon sense, and a clear understanding of what is

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    important to preserve, and what does not requirepreservation. This is best accomplished by havingwell trained personnel working directly on projects,and allowing those individuals to use their exper-tise. The goal is to treat historic properties in amanner that ensures they continue to support theagency mission, and preserve those aspects of ourheritage that are significant. This is nothing morethan a heads-up approach to resource management.

    Experience within the military, andthroughout the federal government, suggests thatthis can be accomplished without adding cost toO&M budgets if undertaken professionally,creatively, and in a timely manner. This can bedone by ensuring that installation staff are aware of

    the values of the historic resources to the mission,and understand the limits of treatment. A profes-sional, full-time, cultural resource manager, locatedwithin the Public Works Office, and within thedecision-making loop, is essential to developing asuccessful program. This individual should be thepoint of contact (POC) with internal and externalreview agencies, as well as assisting in interpretationof the Standards.

    Under Public Law 89-665; 80 Stat 915;(16 U.S.C. 470), as amended, the Secretary of theInterior is responsible for establishment, in consul-

    tation with the Secretaries of Agriculture andDefense, the Smithsonian Institution, and theAdministrator of the General Services Administra-tion, professional standards for the preservation ofhistoric properties in federal ownership or control.This responsibility extends to providing training in,and information concerning professional methodsand techniques for the preservation of historicproperties, and for the administration of thehistoric preservation program at the federal, State,and local level.

    The Secretary of the Interiors Standardsfor the Treatment of Historic Properties (36 CFRPart 68), along with their associated Guidelinesfor Preserving, Rehabilitating, Restoring, &Reconstructing Historic Buildings are the basis forplanning, design, and work on historic buildings,structures, landscapes, and sites under governmentjurisdiction. The Standards and Guidelines arenothing more than applying good common senseto the treatment of properties.

    The Standards and Guidelines are brokendown into four sections of workpreservation,rehabilitation, restoration, and reconstruction. Forthe most part, work done by the Services onhistoric properties will fall into the preservationand rehabilitation categories. It is unusual for theServices to undertake restoration or reconstructionof a building or structure, although all projects willusually have aspects of each treatment type. Thefollowing commonly used definitions are from theSecretarys Standards.

    Preservation is the act or process ofapplying measures necessary to sustain theexisting form, integrity, and materials of a historicproperty. Work, including preliminary measures to

    protect and stabilize the property, generally focuses onthe ongoing maintenance and repair of historicmaterials and features, rather than extensive replace-ment and new construction.

    Rehabilitation is the act or process ofmaking possible a compatible use for a propertythrough repair, alterations, and additions whilepreserving those portions of features whichconvey its historical, cultural, or architectural

    values. For military purposes, rehabilitation is thesame level of action as revitalization.

    Restoration is the act or process of

    accurately depicting the form, features, andcharacter of a property as it appeared at a particu-lar period of time by means of the removal offeatures from other periods in its history andreconstruction of missing features from therestoration period.The limited and sensitiveupgrading of mechanical, electrical, and plumbingsystems and other code-required work to makeproperties functional is appropriate within a restora-tion project.

    Reconstruction is the act or process of

    depicting, by means of new construction, theform, features, and detailing of a non-survivingsite, landscape, building, structure, or object forthe purpose of replicating its appearance at aspecific period of time and in its historic location.Reconstruction of an entire building or structure isseldom used in the military, but it may apply toelements of a property that is undergoing rehabilita-tion or restoration.

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    Each of the sets of Standards focus oncommon sense approach to treatment of buildings.Their emphasis is on repair of features wherefeasible, and replacement with compatible materi-als when necessary. The two most widely appliedstandardsPreservation and Rehabilitation, do notrequire replication of historic features, preservationof inadequate or nonfunctional elements, orretention of components or systems that do notmeet current use or code requirements.

    STANDARDSFORPRESERVATION

    Preservation may be considered as atreatment when the propertys distinctive materials,

    features, and spaces are essentially intact, and thusconvey the historic significance without extensiverepair or replacement; when depiction at a particu-lar period of time is not appropriate; and when acontinuing or new use does not require additionsor extensive alterations.

    There are eight Standards for Preservation,all of which focus on stabilizing the property toprevent deterioration, repairing the property tocontinue its useful life, and avoiding actions thatwill damage the property. The Standards are:

    1. A property will be used as it was

    historically, or be given a new use that maximizesthe retention of distinctive materials, features,spaces, and spatial relationships. Where a treat-ment and use have not been identified, a propertywill be protected and, if necessary, stabilized untiladditional work may be undertaken.

    2. The historic character of aproperty will be retained and preserved. Thereplacement of intact or repairable historic materi-als or alteration of features, spaces, and spatialrelationships that characterize a property will be

    avoided.3. Each property will be recognizedas a physical record of its time, place and use.Work needed to stabilize, consolidate, and conserveexisting historic materials and features will bephysically and visually compatible, identifiableupon close inspection, and properly documentedfor future research.

    4. Changes to a property that haveacquired historic significance in their own rightwill be retained and preserved.

    5. Distinctive materials, features,finishes, and construction techniques or examplesof craftsmanship that characterize a property willbe preserved.

    6. The existing condition of historicfeatures will be evaluated to determine the appro-priate level of intervention needed. Where theseverity of deterioration requires repair or limitedreplacement of a distinctive feature, the newmaterial will match the old in composition, design,color and texture.

    7. Chemical or physical treatments,

    if appropriate, will be undertaken using the gentlestmeans possible. Treatments that cause damage tohistoric materials will not be used.

    8. Archeological resources will beprotected and preserved in place. If such resourcesmust be disturbed, mitigation measures will beundertaken.

    STANDARDSFORREHABILITATION

    Rehabilitation (Revitalization) will be themost common level of treatment for a historic

    property. It may be considered as a treatmentwhen repair and replacement of deterioratedfeatures are necessary; when alterations or additionsto the property are planned for a new or continueduse; and when its depiction at a particular time isnot appropriate.

    There are ten Standards for Rehabilitation,all of which focus on preserving the character ofthe property, while improving its physical condi-tion and extending or changing its use. TheStandards must be applied in a rational, logical

    manner, neither placing emphasis on restoring lostcharacter nor abandoning existing fabric andsystems. The Standards and their intent are:

    1. A property will be used as it washistorically or be given a new use that requiresminimal change to its distinctive materials, fea-tures, spaces, and spatial relationships.

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    This standard simply means that if a property wasconstructed as a residence, ideally it would continue inthat use.

    2. The historic character of a property willbe retained and preserved. The removal of distinc-tive materials or alteration of features, spaces, andspatial relationships that characterize a propertywill be avoided.

    The intent of this Standard is to avoid situationswhere important portions of a property are removed inthe process of rehabilitation, and the value of theproperty diminished. An example would be where aclay tile roof was removed and replaced with a new

    composition roof. The form, color, pattern and textureof the clay tile roof would be a distinctive, characterdefining element to the building and its environment.Its replacement with any material that did not retainthose features of form, color, pattern, and texture,would diminish the value of the property.

    3. Each property will be recognized as aphysical record of its time, place, and use. Changesthat create a false sense of historical development,such as adding conjectural features or elementsfrom other historic properties, will not be under-

    taken.

    This Standard was developed to avoid situationswhere a project would basically rewrite history. Theconstruction industry has sufficient technical skills toduplicate the design and materials used on historicbuilding and structures. But the use of those skillsshould be limited to restoration and reconstructionprojects.

    4. Changes to a property that have

    acquired historic significance in their own rightwill be retained and preserved.

    Although you may not be allowed to place somethingstrange on a historic building now, if someone did itlong enough ago, there is a good possibility that itshould be saved. If changes were made in the past thatdo not detract from the character of the building, and

    that represent the design and style of the era in whichit was done, it should be retained. The exception tothis is when you are undertaking a restoration and theperiod of the change does not fall within the period ofthe restoration, or where the change does detract fromthe historic building or is not of value in itself.

    5. Distinctive materials, features, finishes,and construction techniques or examples ofcraftsmanship that characterize a property will bepreserved.

    Many historic family housing units contain materialsand features that are representative of the originaldesign, the style of architecture, or the function of the

    building which should be preserved. This Standardaddresses the issue of removal, destruction, or coveringof these features.

    6. Deteriorated historic features will berepaired rather than replaced. Where the severityof deterioration requires replacement of a distinc-tive feature, the new feature will match the old indesign, color, texture, and, where possible, materi-als. Replacement of missing features will besubstantiated by documentary and physicalevidence.

    The priority for treatment of features and materials ona historic property is a) preservation; b) repair; c)replacement in-kind; and last, d) replacement witha substitute material. Preservation of the featurewould entail keeping it in-place, repainting it orrecoating it, and basically maintaining it.

    A majority of the work at an installation involvespreservation, which is standard maintenance. Therepair option would come into use when the feature is

    broken. By repainting it you are fixing it, thatsbasically all. If the crank arm is not working on asteel window the repair action might involve itsremoval, cleaning, and possible replacing some wornor broken parts, then returning it to the originalwindow. Only if the feature is broken beyond repairis the option of replacement in-kind considered.

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    An in-kind replacement would involve removal ofthe broken feature and replacing it with the samefeature. If a steel window is broken beyond repair,in-kind replacement would mean putting back inplace another steel window of the same size, configura-tion, operation, and design. Elements of the windowthat do not affect its form and design can be modifiedin an in-kind undertaking. An example would bereplacing a single-glazed steel window with a double-glazed steel window, and an originally unfinished steelwindow with a pre-finished steel window.

    The last option is replacement with a substitutematerial. This is undertaken only if the originalmaterial, design, configuration or workmanship is no

    longer available. Given the technology currentlyavailable, there are very few features that cannot beobtained as originally designed. Great care should betaken to avoid situations where a project calls forreplacement of a feature, such as original wood or steelwindows, with a substitute material, such as alumi-num. Such an undertaking would violate theStandards and require substantial administrativeefforts, plus possibly adding time and expense to theproject.

    7. Chemical or physical treatments, if appropriate,

    will be undertaken using the gentlest meanspossible. Treatments that cause damage to historicmaterials will not be used.

    This Standard was originally written to preventabrasive cleaning of buildings, such as sandblasting.As alternative abrasive cleaning techniques havedeveloped, the Standard was expanded to include allchemical or physical treatment that could damage thehistoric fabric, including the use of acids, sand, icecrystals, corn cobs, walnut shells, high pressure water.

    Basically, any treatment that will abrade the surface ofthe material and either remove its protective surface,change its texture, or otherwise damage its integrity.It is feasible to clean a building without damaging itsfabric using the correct materials, equipment andtechniques. While abrasive cleaning of a material,such as masonry, will cause a visual change to theproperty, more significant effects are changes in thephysical characteristics of the material, shortening its

    usable life, and contributing to higher maintenancecosts, and eventual loss.

    For a majority of situations, a simplecleaning using a biodegradable soap, soft bristlebrushes, and water will clean normal dirt and grimeoff of a building. For more difficult cleaning prob-lems, such as graffiti, a number of manufacturers havesolvents that are effective and will not damage thebuilding fabric. In all cases, 2 x 2 test panels shouldbe used to assess the effectiveness of the cleaning systemand its effect on the property before proceeding.

    8. Archeological resources will be protected andpreserved in place. If such resources must bedisturbed, mitigation measures will be undertaken.

    The purpose of this Standard is to avoid damage tothe integrity of archeological sites. Unless a project isgoing to disturb the site, it should be left alone.

    If the project, as designed, would damage the site,consideration should be given to modifying the designto avoid the site. An example of this would be theinstallation of an underground utility line. Theutility line should go around the site rather thanthrough it.

    If the archeological site cannot be avoided, thenmitigation would be to conduct a professional archeo-logical excavation. This would include developmentof a research design, carrying out the research, and, ifappropriate, excavation of the site and then curationor management of artifacts recovered.

    9. New additions, exterior alterations, or relatednew construction will not destroy historic materi-als, features, and spatial relationships that charac-terize the property. The new work shall be differ-

    entiated from the old and will be compatible withthe historic materials, features, size, scale andproportion, and massing to protect the integrity ofthe property and its environment.

    The explanation of this Standard is similar toStandard #3. The intent is to preserve the designintegrity of the property. This would apply to projectsinvolving rehabilitation, new construction, planning,

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    and landscaping. Additions to a building should bedesigned in such a manner so that the historic propertyis not destroyed or overwhelmed, or that its physicalintegrity is lost. Ideally, an addition should not belarger that the original building. The connectionbetween the two should not damage materials orfeatures any more than is absolutely necessary, and thedesign of the addition should be compatible with, butnot duplicate the original.

    10. New additions and adjacent or related newconstruction will be undertaken in a such a mannerthat, if removed in the future, the essential formand integrity of the historic property and itsenvironment would be unimpaired.

    This Standard is recommending that all new work bedesigned in such a manner that it can be removed.The thought behind this is that at some time in thefuture a situation could arise where there is interest inrestoring the historic property. New construction thatremoves or destroys any portion of the property that is

    essential to defining its character would make thataction impossible.

    THEINTENTOFALLOFTHE STANDARDS,REGARDLESSOFTYPEOFTREATMENT, ISTOPRESERVEASMUCHOFTHEORIGINALFABRICANDCHARACTEROFTHEPROPERTYASISPOSSIBLE, ANDTOTREATTHEPROPERTYGENTLY. IFTHE STANDARDSAREUSEDASTHEBASISFORALLWORKONHISTORICFAMILYHOUSINGUNITS, THEPROJECTSWILLBEACCEPTABLETOALLEXTERNALREVIEWAGENCIES. SIMPLYBYCITINGANDUSINGTHESE STANDARDS, THEINDI-VIDUALINSTALLATIONSAND SERVICESCANVIRTUALLYELIMINATEADMINISTRATIVECOSTSRELATEDTOSHPO AND ACHP DELAYSINPROJECTREVIEWS.

    Restoration and reconstruction are special-ized treatments that rarely apply to militaryhousing. When either restoration or reconstruc-tion is to take place, consultants expert in thosefields will be utilized. No law or regulationrequires a federal agency to restore or reconstruct aproperty.

    Quarters 102, United States Military AcademyWest Point, New York

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    FIRE SAFETY, CODE COMPLIANCEANDHANDICAP ACCESSIBILITY

    Historically, fire safety codes were designed tominimize damage to property. Eventually

    these codes were rewritten to prevent harm tooccupants, with the value of property being asecondary concern. When addressing the issue offire safety in historic family housing, it is essentialto maintain that priorityoccupant safety first,property protection second.

    Each of the national building codes, suchas BOCA and the Uniform Building Code, as wellas the National Fire Prevention Code, providecertain exceptions for historic properties. These

    exceptions allow alternative means of providing thesame level of protection when exact adherence tothe requirements of the code would damage thehistoric integrity of the property. It is generallyassumed that many historic buildings and struc-tures, as originally designed, will fail to meetmodern code requirements in the use of materials,methods of construction, and exiting systems. Thegoal in rehabilitation: to provide an equivalent levelof protection without damaging the historiccharacter of the property, can be accomplished intwo waysthrough alternative approaches toprotection, or through application of contemporaryprotective measures in ways that avoid or minimizedamage to the property.

    An example of the first approach would bethe installation of a fire suppression system in amultifamily building, such as a sprinkler system,which would allow retention of the historic openstairways. An example of the second approachwould be placement of the sprinkler heads ininconspicuous locations.

    There are two sets of guidance available to

    apply fire safety and code compliance to historicpropertiesThe U.S. Corps of Engineers Archi-tectural and Engineering Instructions, DesignCriteria, Chapter 16, Preservation of HistoricStructures, and, although its emphasis is onnonresidential structures, the General ServicesAdministration and the Advisory Council onHistoric Preservations joint publication Fire

    Safety Retrofitting in Historic Buildings. (Avail-able through GSA Public Building Service, Wash-ington, DC or the Advisory Council on HistoricPreservation, Washington, DC.)

    The COE Design Criteria provides ageneral, policy approach to meeting life safetyrequirements, with emphasis on equivalent protec-tion without degradation of historic character. TheGSA/ACHP guidance offers detailed alternativesand examples. Both can be used when developinga fire safety plan for a family housing unit.

    Developing a fire-safety or code compli-ance plan under the assumption that the letter ofthe law and regulations must be met in a historicbuilding will result in excessive cost and possible

    damage to the resource.The first step in the design process is anassessment of the building or structure, aimed atidentifying significant spaces and character defin-ing elements that should be protected. Although abuilding may be historic, not all of its parts areequally important. Accordingly, different ap-proaches to meet fire safety requirements may beused in different parts of the building.

    The second step is evaluation of alternativemeans of providing fire safety. Selection of asystem will be based on the level of personnel risk,

    the type of occupants and uses, and the type ofmaterials to be protected. In some instances it maybe necessary to have more than one type of firesafety system in a single building. An example ofthat would be a property that housed importantmuseum pieces, such as the SuperintendentsQuarters, USMA, that is shown on page 40. Whilea majority of the building could be protected witha traditional fire suppression system, if necessary,that portion containing the museum pieces wouldbe better protected with a dry fire suppression

    system to avoid the possibility of water damage tothe collection.In addition, issues involving egress must be

    integrated into the overall system. In historicmultifamily housing units, it may not be possibleto provide the corridor or door widths required fornew construction under current code. Or, theremay be instances where open stairs are significantarchitectural elements of the building. In such

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    cases, creative solutions must be developed thatprovide the level of protection required by code,but that do not damage the property. In all cases, abalance of solutions should be developed that meetthe objectives.

    The third step in the process is review ofthe proposed systems with the authorities havingjurisdiction to ensure compliance with fire safetyrequirements, and protection of the property. Thishas to be undertaken in a timely manner to avoiddelays that will result in additional costs.

    Finally, care in the installation of thesystem is critical to protecting the building fabric.It is important that there is clear guidance given tocontractors and workmen to avoid collateral

    damage to historic fabric, and to ensure that thesystem is installed as originally designed andapproved.

    HANDICAP ACCESSIBILITY

    Although handicap accessibility can be one ofthe most difficult issues when treating historicfamily housing, it is only undertaken on an asneeded basis. Each instance of providing accom-modation for families is unique. Accordingly, thecost associated with such provisions does not have a

    significant effect on the overall housing budget,and is not a factor in maintenance costs.

    Successful accommodation, however, willrequire both imagination and effort. The goal is toprovide full access without destroying the physicalintegrity or historic character of the resource.

    As with life safety and building codeissues, handicap accessibility at historic propertiescan be accomplished through a variety of directand alternative means. It is important whenaddressing this issue not to make assumptions

    about what is required, or what can be accom-plished. Each accessibility concern must be viewedindividually, and in the context of the historicproperty that will be affected.

    Both the Uniform Federal AccessibilityStandards, Federal Standard 795 (UFAS), and theAmericans with Disabilities Act, Public Law 101-336, Accessibility Guidelines (ADAAG), provide

    the standards for making buildings and facilitiesaccessible to the disabled. In December 1993DoD issued a memorandum to all military Servicesand other offices establishing a policy to ... UseADAAG to provide equal or greater accessibilitythat would be achieved if only UFAS were ap-plied. For historic properties, however, provisionsare made to allow alternative means of providingaccess when strict compliance with UFAS orADAAG would threaten or destroy the historicsignificance or a feature of the property. Therequirement to provide access is not diminished,but the means by which it is accomplished can varyfrom that which may be required in new construc-tion.

    COMPLIANCEWITH ENVIRONMENTALREQUIREMENTS

    HAZARDOUS MATERIALS

    Some of the most critical issues to address whenworking on historic family housing center aroundhazardous substanceslead paint, asbestos, andother materials once commonly used in construc-tion, but which are now known to be hazardous.

    Concern over the presence of these substances inhomes has generated numerous studies and tests,resulting in a better understanding of the real risksinvolved when living and working with thesematerials. However, installations continue tooverreact to their presence, and tend to overremediate. This consistently results in excessivecosts and, at times, damage to a property. The levelof treatment is inconsistent across and within theServices. As an example, one Air Force installationwill treat lead-based paint through encapsulation,while another insists on the removal of all materialspreviously coated with the offending paint.

    Initially, regulations and guidance wereissued that, basically, established a zero tolerancelevel for lead-based paint and asbestos in housingunits. Research has proven that if the material isstable, and in good condition, it does not pose adanger under normal use. The problems occurwhen the level of risk increases, either due to the

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    condition of the material, its location, and who willbe exposed to the substances. Any treatment planmust take these and other issues into considerationbefore committing resources to remediation. Toooften installations attempt to use blanket solutionsfor different types of problems, often resulting inexcessive cost and damage to historic properties.Thoughtful consideration must be given to treat-ment options and alternative actions.

    LEAD-BASED PAINT

    Addressing the issues of when to removelead-based paint, how much to remove, and themost appropriate removal technique, have been

    critical in management and treatment of historicfamily housing for many years. If a building orstructure is more than 40 years old, chances arethat somewhere, it contains lead-based paint.White lead, linseed oil, and inorganic pigmentswere the basic components of almost all paint usedfrom the 18th century through the middle of the20th. Lead gave paint and other finishes, such asvarnishes, great adhesion, strength, durability, anddensity. It was the ideal ingredient when paintingeverything from metal to masonry to wood.Unfortunately, its real dangers were not fully

    recognized until 1978 when the federal govern-ment banned its use in all housing.

    The first and most obvious concerns overlead poisoning centered around poorly maintainedlow income housing. The condition of the proper-ties created situations where lead paint chips couldbe ingested by children, resulting in lead poisoning.A second, and equally dangerous problem has beenfound in self-help renovation projects, whereoccupants undertook paint removal, exposing theirchildren and themselves to lead dust. Any situa-

    tion where lead can be ingestedthrough eatingpaint chips, inhaling dust containing lead, or fromlead contaminated soilis a serious health hazard.

    The fact that this material is poisonousrequires that there be an informed, thoughtfulmanagement plan developed to address the issue ona project-by-project basis.

    There is no blanket formula that will solvethe lead-based paint problem at an installation.Each situation must be evaluated individually

    based on risk, the value of the resource, and themethods available for treatment.

    RISKASSESSMENT

    The danger of lead poisoning comes fromingesting the material, either by inhaling it oreating it. Consequently, the most critical issue toaddress is the level of risk the lead-based paintrepresents. While all lead-based paint is poisonous,not all of it poses a risk. An example would bepaint on a ship. The potential for ingesting thematerial is negligible, thus the level of risk wouldnot dictate removal of the lead-based paint. Onthe other hand, a building that is being used as a

    day care center for young children would present ahigh risk. This would require treatment of thepaint to ensure that there was no danger to thechildren.

    The National Park Service PreservationBrief #7, Appropriate Methods for Reducing LeadPaint Hazards in Historic Housing lists sevenpoints that should be examined when assessingrisk:

    the location of the lead-basedpaint (lead-based paint that is out of the reach ofchildren represents minimum risk);

    the condition of the paint (flakingor chipping paint creates a higher risk than a solidpaint surface);

    the lead content of the paint orsoil (the amount of lead used in paints variedconsiderable. A low level, .05% or less, poses norisk);

    the type of surface on which thepaint is located (surfaces that are accessible toyoung children are a high risk, as are frictionsurfaces);

    how much lead dust is currently present (this can indicate paint chalking); how the property is used and

    maintained (lead-based paint in a residentialsituation is a higher risk than the same paint in anadministrative space); and,

    the age of the occupants whomight come into contact with lead paint (youngchildren are at a higher risk of damage due to leadpoisoning than adults.)

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    Treatment

    In most cases, what are called InterimControls can be used to mitigate risk (see Table 2,page 28.) These are short term solutions, lastingless than 20 years. They include good housekeep-ing and maintenance, dust control, paint stabiliza-tion, replanting on top of contaminated soil, andoccupant education. In selective, high risk cases,Hazard Abatement may have to be undertaken.These are long-term solutions, and involve removalof the paint, selective substrate removal, encapsula-tion of the material, and, possibly, soil replacement.

    Management of lead-based paint inhistoric family housing can range from a do

    nothing approach where risk does not exist, tocomplete removal where risk is critical, with manydifferent solutions in between. Assuming thatcomplete removal is always the best solution wouldbe incorrect. The very process of removing thematerial poses a risk to workman, inhabitants, andthe environment, as well as to the integrity of thestructure. Where lead-based paint does notrepresent a risk, it should be left undisturbed.Where the risk is minimal, Interim Controlsshould be used, and where it is high, HazardAbatement should be used.

    If abatement is the appropriate option,then there is guidance in determining where tostart work, and where to use limited resources (seeTable 2.) The National Park Service has identifiedwhat paint should be removed in order of risk(with 1 being the highest health threat, and 8, theleast.)

    1. Peeling, chipping, flaking, andchewed interior lead-based paint surfaces.

    2. Lead dust on interior surfaces.3. High lead levels in soils around

    residential un