Tuesday, June 22, 2010

Cincinnati Urban Conservator asks for more time on Programmatic Agreement with OHPO

1853 Knox continues to be at the center of controversy regarding the city's compliance with Federal law and a viable Section 106 review process.


On May 27th the OHPO (Ohio Historic Preservation Office) formally advised the Urban Conservator that the city was more than 150 Days late in providing the required documentation to the state regarding implementation of its section 106 review process and further advised the city that they may consider termination of the agreement under stipulation X of the agreement. That action could result in the cut off of federal funds to the city currently used for demolition.


That letter to the city was prompted by a request from the Knox Hill Neighborhood Association to review a determination by the urban conservator that a property at 1853 Knox was not historic eligible. That review is required on any property more than 50 years old under the 1966 Historic Preservation Act.


Under the Programmatic agreement between the city and OHPO the Urban Conservator is required to make efforts to engage the public in the process:


Under the section 106 review process and under the guidelines there is what is known as “Level of Effort” . From the guidelines:

The agency official (in this case the Urban Conservator) shall make reasonable and good faith effort to carry out appropriate identification efforts, which may include background research, consultation, oral history interviews, sample field investigation and field survey.

The Review process requires the Urban Conservator to under Section 3 of 800.4: Identification of Historic Properties to:

Seek Information as appropriate from consulting parties and other individuals and organizations likely to have knowledge of, or concerns with historic properties in the area and identify issues relating to the undertaking’s potential effects on historic properties.


Knox Hill Neighborhood Association in an email request made a formal request to Mr Harris for a meeting or conference to hold formal section 106 review of that property which the neighborhood contends is a contributing structure to their upcoming federal Historic district nomination. Mr Harris failed to respond to the neighborhood request which included some information concerning the property and how it would meet the contributing structure guideline as part of a larger historic district. Because the urban conservators office failed to respond to that request, KHNA appealed the decision to OHPO and asked for a review by their office.


In a letter dated June 17th, 2010 some 20 days after the OHPO request the Urban Conservators office requested an addition 30 day extension to provide a response. That would mean it has taken the city over 200 days to respond under the original programmatic agreement and it is unknown if that response will even be satisfactory to OHPO, during which time demolitions are being conducted, using federal funds, without a proper 106 review.



Mr Harris in the letter claimed again that property has no historic value, that he has visual inspected it, and attached a project file he references as 1843 Knox Road (the actual address is 1853 Knox street) In the letter Mr. Harris asserts:


"While there may be scattered original sites in the area (not on Knox Road), there is no significant concentration, linkage , or continuity of the site, buildings,structures, or objects ,that united the area historically or aesthetically to suggest a plan or physical development that would connect the area historically."


This is in direct contrast to the Knox Hill Historic Inventory Report the neighborhood has prepared on 1853 Knox, which notes the following:


"Architecture: 1853 Knox St is a single family residence constructed circa 1880-1885. The structure is brick and features cut limestone lentils. The property is a good example of the “shotgun townhouse” layout in Cincinnati during this period. The street facade presents an intact front façade, with decorative top cornice with 6 decorative tin brackets. The home also has its original front door transom windows, and decorative limestone window cornices. The main brick structure occupies a 16x35 ft footprint. There is a later circa 1895-1900, (16x18 footprint) 2 story frame addition on the rear that is a contributing part of the Architectural history of the house we consider this property to be a contributing structure to the proposed Knox Hill Historic District.

The house is on a block of similar sized circa 1880-1890 homes on the South side of the 1800 block of Knox Street and in context with the Second Empire Townhouse. (1857 Knox), immediately west, present an intact and strong street presence and both houses have similar front historic Stone retaining walls. While the house suffers from only minor neglect and addition of a non-historic deck style front porch the house lack no significant architectural detailing and as such is a contributing historic structure. The loss of this structure due to demolition would also result in the loss of the historic retaining wall and as such would cause serious interruption of architectural continuity of the historic retaining walls that exist from 1851 Knox to 1865 Knox. Both the house and its retaining wall are restorable. As this house sits at the highest elevation (prominence) on the 1800 Block of Knox its loss would be particularly disturbing to the overall street façade."

Since that initial report was prepared it has been learned that one of past owners was Ralph Gucthlein , who was president of a decorative plaster company . The Guctheim and Sons Plaster Company was well known for their high quality decorative plaster work and plaster moldings and did work on many significant structures

Work continues on the historical ownership phase of the Knox Hill Neighborhood's registry nomination which is a slow process since this area was once part of the town of Fairmount which was annexed to the city and early records are hard to find.
1853 Knox features details like these cut decorative limestone cornice work not found on lesser examples.


The Knox Hill Neighborhood Association, has repeatedly asserted that, in the absence of a proper section 106 review process in which the public is allowed to present information, all demolitions currently planned should be placed on hold until such time as a viable review process is in place and that all properties on the demo list must be revisited and properly reviewed.


Several neighborhood groups, frustrated by the lack of detail in the cities historic building inventory reports are assembling volunteers to conduct their own surveys, using state guidelines and submit to survey to the the state for review so that they can be used in stead of the outdated "Drive by surveys ' conducted by the city. The city is hiring a consultant to "Update survey" 24 neighborhoods' this year. Contrast that to the other states which typically take 1 year just to survey some townships with high concentration of buildings over 50 years old.
Preservationists and neighborhood groups contend the Cincinnati Building Reports are incomplete, inaccurate and too old to serve as a viable source of evaluation, and that the Urban Conservators office with its limited resources and staff can not accurately inspect the 20-30 properties being submitted every couple of weeks for review from the Vacant Building Task Force which is why the 106 review process is essential to receive historical data which the Conservators office does not have time to locate that neighborhoods already have.

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