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Preserving Historic Post Offices: a Report to Congress | 1 Acronyms and Abbreviations

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Preserving Historic Post Offices: a Report to Congress | 1 Acronyms and Abbreviations ABOUT THE ACHP The Advisory Council on Historic Preservation (ACHP) is an independent federal agency that promotes the preservation, enhancement, and sustainable use of our nation’s diverse historic resources and advises the President and Congress on national historic preservation policy. The ACHP also provides a forum for influencing federal activities, programs, and policies that affect historic properties. In addition, the ACHP has a key role in carrying out the Preserve America program. Milford Wayne Donaldson, FAIA, of Sacramento, California, is chairman of the 23-member ACHP, served by a professional staff in Washington, D.C. For more information about the ACHP, contact: Advisory Council on Historic Preservation 1100 Pennsylvania Avenue, NW, Suite 803 Washington, DC 20004 Phone: 202-606-8503 Fax: 202-606-8647 Web sites: www.achp.gov www.preserveamerica.gov Front cover: Spanish Colonial Revival, 1930s, Redlands, California, (Wikipedia); “The Fur Traders,” Elizabeth Lochrie, 1938, St. Anthony, Idaho (National Postal Museum/Smithsonian Institution); Art Deco, 1935, Milton, Pennsylvania (Evan Kalish); Colonial Revival, 1938, Lakewood, New Jersey (The Lakewood Scoop); retail counter, Bronx, New York (USPS) Back cover: postboxes at Old Post Offi ce and Courthouse, Little Rock, Arkansas (Carol M. Highsmith, Inc./ GSA); cancelled stamp (iStockphoto) WASHINGTON, D.C. OLD POST OFFICE BUILDING, ACHP HEADQUARTERS ROMANESQUE REVIVAL, 1892 TABLE OF CONTENTS 1 ACKNOWLEDGEMENTS 2 ACRONYMS AND ABBREVIATIONS 3 CHAIRMAN’S MESSAGE 5 EXECUTIVE SUMMARY 8 INTRODUCTION 13 USPS HISTORIC PROPERTIES 19 USPS HISTORIC PRESERVATION AND DISPOSAL PROGRAMS 26 USPS COMPLIANCE WITH SECTION 106 28 ISSUES IN THE SECTION 106 REVIEW OF DISPOSAL OF HISTORIC POSTAL FACILITIES 39 FINDINGS AND RECOMMENDATIONS FOR USPS PROGRAM IMPROVEMENTS 47 SOURCES ACKNOWLEDGEMENTS The Advisory Council on Historic Preservation wishes to extend its appreciation and thanks to the following individuals and organizations for their time and contributions to this report: USPS REPORT PANEL Milford Wayne Donaldson, FAIA, ACHP Chairman Teresa Isabel Leger de Fernandez, Citizen Member Stephen T. Ayers, Architect of the Capitol Beth L. Savage, General Services Administration Elizabeth Hughes, National Conference of State Historic Preservation Officers ADVISORY COUNCIL ON HISTORIC PRESERVATION John M. Fowler, Executive Director Reid J. Nelson, Director, Office of Federal Agency Programs Caroline D. Hall, Assistant Director, Office of Federal Agency Programs (report author) Najah Duvall-Gabriel, Historic Preservation Specialist Kirsten Kulis, Program Analyst, GSA Liaison Susan Glimcher, Director, Office of Communications, Education, and Outreach Shayla Shrieves, Senior Writer-Editor PRESERVING HISTORIC POST OFFICES: A REPORT TO CONGRESS | 1 ACRONYMS AND ABBREVIATIONS ACHP Advisory Council on Historic Preservation CATEX Categorical Exclusion under the National Environmental Policy Act CEQ White House Council on Environmental Quality CLG Certified Local Government CFR Code of Federal Regulations CRP Community Relations Program eFMS USPS Electronic Facilities Management System EO Executive Order FPO Federal Preservation Officer FR Federal Register FSO Facility Service Office GAO Government Accountability Office GSA General Services Administration HPC Historic Preservation Coordinator MOA Memorandum of Agreement NCSHPO National Conference of State Historic Preservation Officers NEPA National Environmental Policy Act NHPA National Historic Preservation Act of 1966 NPS National Park Service NRHP National Register of Historic Places NRIS National Register Information System NTHP National Trust for Historic Preservation OIG USPS Office of Inspector General PA Programmatic Agreement S ection 106 Section 106 of the National Historic Preservation Act of 1966 Section 110 Section 110 of the National Historic Preservation Act of 1966 Section 111 Section 111 of the National Historic Preservation Act of 1966 SHPO State Historic Preservation Officer SOI Secretary of Interior THPO Tr i bal Historic Preservation Officer USC United States Code USPS United States Postal Service WPA Works Progress Administration PRESERVING HISTORIC POST OFFICES: A REPORT TO CONGRESS | 2 CHAIRMAN’S MESSAGE The Advisory Council on Historic Preservation (ACHP) is pleased to present this report on compliance by the U.S. Postal Service (USPS) with Section 106 of the National Historic Preservation Act for the closure and disposal of its historic postal facilities. The report responds to the request by Congress in the explanatory statement of the Consolidated Appropriations Act of 2014, Division G. The USPS has disposed of post offices throughout its history. However, the rate of disposals began to increase in 2008 as declining mail volumes along with increased automation and worker productivity led to a determination by the USPS that many facilities are larger than operations require. Given the number of historic properties in the USPS real property inventory, it is inevitable that historic post offices and facilities would be among the properties considered for disposal. Section 106 consultations on a number of high profile disposals across the country have demonstrated that the preservation community and the public have significant concerns about the potential closure of these historic facilities, including the loss of public use of the buildings, the risk posed to the integrity of historic buildings and the artwork they contain, and the potential loss of public access. The limited consideration of the historic values of these iconic buildings along with the lack of transparency in Section 106 consultation further exacerbates these problems. This report makes specific findings and recommendations that would improve USPS compliance with Section 106, while building collaborative relationships with communities and historic preservation stakeholders. These recommendations are the result of thoughtful consideration of information provided to the ACHP by State Historic Preservation Officers, communities, preservation advocates, the public, and the USPS itself. Awareness of and appreciation for the value of these important community resources under federal ownership can foster better management practices that will benefit the USPS, the historic properties, and the communities in which they reside. The ACHP stands ready to work with the USPS and historic preservation partners to implement the recommendations of this report and chart a course for improved Section 106 compliancecompliance andand bbetteretter hihistoricstoric preservationpreservation outcomes for communities. Milford Wayne Donaldson, FAIA Chairman PRESERVING HISTORIC POST OFFICES: A REPORT TO CONGRESS | 3 PRESERVING HISTORIC POST OFFICES: A REPORT TO CONGRESS | 4 EXECUTIVE SUMMARY Many post offices have operated for decades as the civic core of their communities. These structures, while often functioning as community meeting places, were constructed with public funds and serve as an integral part of the governmental presence in the community, providing not only a functional role but a symbolic federal presence. Since 2008, the rate of post office disposals has increased in response to a determination by the United States Postal Service (USPS) that many facilities are larger than current operations require. Many of these disposals have targeted historic post offices. Consultations on a number of high profile disposals across the country under Section 106 of the National Historic Preservation Act (NHPA) have demonstrated that the preservation community and the public at large have significant concerns about the closure of these historic facilities and the potential loss of access to these places of such importance to local communities. In response, Congress directed the Advisory Council on Historic Preservation (ACHP) to “provide, within 90 days of enactment of this Act, a report on how the Council will ensure compliance by the USPS of Section 106 responsibilities for these historic properties.” (Explanatory Statement, Consolidated Appropriations Act of 2014, Division G). Development of this report was informed by the ACHP’s long history of working with the USPS on Section 106 compliance for a number of USPS undertakings, including rehabilitation, new construction, the sale of air rights, and demolition. With the increase in disposals, the ACHP continues to consult with the USPS encouraging proactive planning and the use of programmatic approaches to compliance for the disposal of historic postal facilities. In addition, the ACHP visited Oakland, California, to gather information and hear from stakeholders who have been directly involved in Section 106 consultations on a number of USPS disposals in California. The ACHP also solicited written comments from stakeholders and the public on the USPS disposal of historic postal facilities and its compliance with Section 106. This report provides summary information on the USPS’s historic properties, disposal procedures, and Section 106 compliance to date. It also discusses the concerns expressed by stakeholders regarding these undertakings and the USPS’s conduct of the Section 106 process. Finally, this report makes 15 specific findings and conveys related recommendations for Congress and the USPS. The report presents actions the ACHP will take, within the scope of its authorities, to ensure that the USPS more effectively considers historic preservation values in the process of evaluating postal facilities for closure and disposal,
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