Taking a Seat at the Table: Your Involvement in the Future of Our Legacy Cities

By Charlene Dwin Vaughn, AICP

America’s Legacy Cities were once industrial powerhouses and hubs of business, retail, and services scattered across New England, the Mid-Atlantic, and the Midwest. Their factories provided jobs, and downtown areas were alive with department stores, professional offices, and financial institutions that served large regions. Since the mid-20th century, however, these cities have seen sustained loss of jobs and population, and now face daunting economic, social, physical, and operational challenges. This loss has fallen disproportionately on minority and low-income neighborhoods that have seen a greater degree of disinvestment and abandonment. But the revitalization of these neighborhoods in collaboration with, and for the benefit of, their residents is not only an imperative of equitable redevelopment but also enshrined in the Federal statutes that guide it.

Earlier this year, I attended the Historic Preservation in America’s Legacy Cities Conference which focused on public policies, programs, and planning issues associated with Legacy Cities and challenges managing shrinking populations, changing demographics, physical alterations, loss of resources, and declining tax bases. Participants agreed Legacy Cities need to revitalize their communities in the 21st century.

While many agree that change is inevitable, there are those who have not fully accepted that planning for change should be inclusive and take advantage of all available tools. Looking back over the last twenty years, the non-inclusive planning practices of the past resulted in older, minority, and low-income neighborhoods bearing the brunt of the negative impacts of dynamic physical and socio-economic changes – changes that were prompted, in part, by federal actions.

Dr. Clement Price, Vice Chair of the Advisory Council on Historic Preservation (ACHP), an independent federal agency established by Congress to advise the President and Congress and oversee the Section 106 review process, moderated a provocative panel discussion entitled Identifying, Celebrating, and Preserving African-American Landmarks. The presentation was timely as many were grappling with how to protect historic properties, particularly those in communities of color. They wanted to be clear about what qualifies African-American landmarks for the National Register of Historic Places. Is the criteria used by the National Register in evaluating historic properties appropriate for an ethnically and racially-diverse nation? Should African American or other ethnic landmarks be evaluated based on their physical characteristics or on the stories drawn from the history of these properties?

When considering how to best engage the broader public in federal planning, environmental review policies are typically applied. The two major federal environmental reviews required for major actions are the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA). NEPA requires federal agencies to integrate environmental values into their decision making processes by considering the environmental impacts of their proposed actions and reasonable alternatives to those actions. NHPA is intended to preserve historical and archaeological sites in the United States.

Before implementing federally-funded activities such as abandonment, demolition, and property alterations in Legacy Cites, agencies must comply with their NEPA obligations and with NHPA. Since many cities use federal funds to develop public-private partnerships, the scope of federal environmental reviews can be broader for compliance with Title VI of the Civil Rights Act. Notwithstanding the dictates of Title VI, the provisions in NEPA and NHPA require federal agencies to “stop, look, and listen” in project planning.

Residents and officials within communities must be better educated about NEPA and NHPA if they are to avoid a repeat of the failures of ‘Urban Renewal’ in the 1960s. These environmental reviews require the participation of the public; review of the “purpose and need” statement; consideration of alternatives, and selection of a preferred alternative or outcome. NEPA requires agencies to disclose environmental justice issues in their environmental documents, information that is vital to residents in communities that may be disproportionately affected by federal projects. While this is one of several key provisions in NEPA, it is important for the public to remember that environmental justice is equally about the built environment as it is about the natural environment.

In a similar manner, Section 106 of NHPA requires agencies to identify and evaluate historic properties within the project’s area of potential effects, in coordination with State Historic Preservation Officers (SHPO) and Tribal Historic Preservation Officers (THPO). Further, Section 106 is a consultative process in which diverse stakeholders, including civic groups, neighborhood groups, churches, anchor institutions, professional organizations, affinity groups, and the like, must discuss various options to avoid, minimize, and mitigate adverse effects on historic properties.

Dr. Price said that “to live, work, and play in Legacy Cities is an act of faith and perseverance.” Residents and other stakeholders must exercise their rights to comment on the merits of federal projects which have the potential to change their sense of their physical and social community. It is an essential part of the laws that have been in place for decades.

Information about the ACHP can be found at www.achp.gov, including the report, Managing Change: Preservation and Rightsizing in America. Information about the White House Council on Environmental Quality and NEPA can be found at CEQ website.

About the author: Charlene Dwin Vaughn, AICP, is a certified planner employed with the Advisory Council on Historic Preservation (ACHP). She received her Master’s Degree in Urban and Regional Planning from George Washington University in Washington, D.C. As an Assistant Director in the ACHP’s Office of Federal Agency Programs she manages historic preservation reviews and program improvements of federal projects that provide financial assistance; issue permits and licenses; and issue approvals.






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