The Amherst Current

Keeping Up with The Jones: Historic Preservation Requirements

By Ginny Hamilton  

With the Jones Library Building Project out to bid again, rumors are rampant about project management, sustainability, and historic preservation. Even after cost saving measures, the Jones Library Renovation & Expansion:

  • Caps the Town’s share at $15.8 million and costs the Town less than basic, urgent repairs (HVAC, fire suppression, roof repairs, accessibility) by leveraging state, federal, and private funds. 
  • Eliminates the use of fossil fuels, becoming net zero ready, more efficient and sustainable than the current building, even though the carbon sequestering materials (cross-laminated timber or CLT) are beyond our budget.
  • Retains most of the original 1927 woodwork in place and preserves and repairs the historic building, opening spaces currently off limits to the public.

[TL;DR] For those for whom historic preservation regulations and funding streams provide an antidote to insomnia, scroll to the bottom for a summary.

Image by Allison McDonald

Historic Preservation Remains a Priority

With a key historic preservation review happening this Wednesday 10/9/24 at 12:30 pm on Zoom (link to agenda and Zoom info), it is worth clarifying details about historic preservation requirements and processes. 

The Jones Library is part of the Amherst Central Business Historic District, which is on the National Register of Historic Places. Therefore, any changes to the historic look and feel of the building need to be reviewed under the standards of Section 106 of the Federal Historic Preservation Act of 1966. These standards allow changes to historic features in light of the overall needs and function of the Library.

The Jones is a library, not a museum. For safety and functionality, some internal changes are necessary. The underused stairwell in the children’s area needs to be removed to make enough space for the demands of our children’s programs. Other changes to walls and doors are necessary to make the building fully accessible for people with disabilities and safer for everyone.

Project architects explored multiple options to find the most cost-effective way to renovate while preserving the historic parts of the building. Fundraising efforts involve historic preservation requirements, as well.

MA Historical Commission Parallel Processes

In 2023, once building plans were far enough along to do so, the Library initiated two distinct processes with the MA Historical Commission (MHC):

  • In April 2023, the Library began submitting applications to compete for historic rehabilitation tax credit funding.
  • In October 2023, the Library submitted a Project Notification Form (PNF) initiating the Section 106 historic preservation review required for federal grants. 

Both processes cover much of the same information about the building but are distinct from each other. [Finegold Alexander Architects produced a useful chart demonstrating this distinction. See page 18 of this presentation.

Historic Rehabilitation Tax Credits (HTC)

It is common to apply for HTCs multiple times before being approved or denied. The Library’s early applications received feedback that was addressed in subsequent attempts. In an April 2024 letter, MHC stated that they found the changes to the building to be too significant to qualify for tax credits. (Incidentally, this denial letter was sent the same day the Library received the singular high bid for the project.)

While this funding denial was disappointing, HTCs are not and were not ever counted in the $39 million secured for the project. Operating in good faith, tax credits were listed as pending prior to MHC’s April decision and have been removed from listings of potential funding sources. 

Section 106 Historic Preservation Review

In October 2023, consultants working with the Library submitted the Project Notification Form (PNF) to MHC, seeking their Section 106 determination for our federal grants, including National Endowment for the Humanities (NEH) funding awarded months earlier. 

MHC replied to the PNF in November, commenting on the project and stating that they would await a determination from NEH. Library staff resubmitted the PNF in February 2024, addressing MHC’s comments. At the same time, the Library submitted more details for the HTC application, then waited for the two MHC processes to play out in parallel time. MHC has taken no further action on the PNF, even as they decided against HTC funding.

Section 106 Consulting Process is Underway 

Given MHC’s wait and see stance on the PNF and in consultation with the appropriate federal agencies, the Town of Amherst has assumed authority to carry out the Section 106 review. Town and Library officials remain in regular contact with the federal agencies funding our project to ensure our efforts comply with their requirements. 

Following the guidance of subject matter experts from the Public Archaeology Laboratory (PAL), the Town has issued a finding of adverse effect, noting the ways in which project plans will impact the Jones Library, the Strong House, and downtown historic districts. Details of these findings are documented in the Historic Resources Assessment prepared by the PAL consultant.

Citing the decade of planning during which the Town has considered ways to avoid and/or minimize impacts to historic properties, the Town will next create a Memorandum of Agreement (MOA) detailing mitigation measures for actions that could not be avoided or minimized. Along with inviting public input, the Town has invited two dozen local organizations and institutions to participate in the MOA consulting process. Details, including the list of consulting party organizations, supporting documentation, and links for making public comment are on the Town’s Section 106 web page.

Historic Preservation Summary [TL;DR]

For those for whom historic preservation regulations and funding streams provide an antidote to insomnia, here are key points:

  • Historic preservation is a core component of the Jones Library Renovation and Expansion project and has been since the project began over a decade ago.
  • Library and Town leaders are carefully following a complex process for the necessary federal, state, and local regulations which balance program needs and historic preservation.
  • The Town has initiated the Section 106 Historic Preservation review and consultation process, hosting a key public meeting this Wednesday, 10/9/24 at 12:30 via Zoom.

Explore the substantive details here: https://www.amherstma.gov/3804/Section-106-Historic-Preservation-Review

Attend, learn & speak! The Jones Library Building Committee meets Wednesday, October 9, 2024 at 12:30 on Zoom. Please attend for:

  • A presentation by the Senior Historian from the Public Archaeology Laboratory (PAL) about the Section 106 process & findings;
  • Input by interested institutions and organizations who have opted in to consult on measures to address the adverse effects to historic properties; and 
  • Public comment relevant to the section 106 findings and mitigation options.

Currently employed by the Friends of the Jones Libraries to manage the Capital Campaign fundraising efforts, Ginny Hamilton (she/they) has worked in campaign organizing and advocacy for social change for over 30 years. Ginny lives in South Amherst with spouse and teen, two parakeets, and too many mice to count.