Ms. Jenifer Eggleston currently serves as Chief of Staff at National Park Service’s Cultural Resources, Partnerships, and Science Directorate. She joined National Park Service in 2007 to serve as the primary grants manager for the Hurricane Katrina and Rita Recovery Grant program, and is one of the co-authors of National Park Service’s Guidelines on Flood Adaptation for Rehabilitating Historic Buildings. First published in 2019, the Guidelines was updated into an illustrated version in 2021, and has been featured in nationwide conferences and workshops.
This interview was carried out on Dec. 20, 2022 over Zoom.
“That was the 'aha moment' for me, as I realized that the tools that we had at our disposal were not enough to bring our historic resources to resilience — especially under today’s increasing risks of natural disasters. We have to move forward, accept more change, and better regulate these changes."
An Illustration for the Wet Floodproofing of Historic Structures in National Park Service’s Guidelines on Flood Adaptation for Rehabilitating Historic Buildings.
Ziming Wang: National Park Service’s Federal-level policy-making for the flood adaptation of historic buildings parallels the emergence of State and local-level guidelines in recent years; and it’s stated in the document’s foreword that the guidelines were produced “in response to a request for technical preservation guidance specific to historic properties.” Could you tell me a bit more about the background of the project?
Jenifer Eggleston: My personal work experience with flood started in 2007, when I was appointed by National Park Service as the administrator for Hurricane Katrina recovery grant programs. In that capacity I got in contact with homeowners and business owners, and was able to learn the real-world concerns and issues in the process of disaster recovery. That was the “aha moment” for me, as I realized that the tools that we had at our disposal were not enough to bring our historic resources to resilience — especially under today’s increasing risks of natural disasters. We have to move forward, accept more change, and better regulate these changes. So we developed this national guideline over the past several years in conjunction with local partners, State Historic Preservation Offices (SHPOs), and Tribal Historic Preservation Offices (THPO), with the intention to formulate flood adaptation strategies for historic resources that are compatible with historic design, material, and characters. Federal agencies such as FEMA and HUD (Department of Housing and Urban Development) also provided assistance to this project, especially on the financial front of flood adaptation.
Ziming Wang: As you just mentioned, flood adaptation may require more significant formal and material change than normally accepted in today’s preservation standards. So, what’s the relationship between this guideline and established preservation regulations such as The Secretary of the Interior’s Standards for Rehabilitation? Is it an exception, or a reinterpretation?
Jenifer Eggleston: If you look closely at the Secretary of the Interior’s Standards for Rehabilitation, you’ll find that it uses a more broad and general language, such as requiring “minimal change to distinctive materials, features, spaces and spatial relationships.” So I would say that the hierarchy of regulations still remains; instead of a reinterpretation, we are offering a more detailed and applied explanation of the Secretary of the Interior’s Standards in the case of flood adaptation. We want to be able to say that if a project meets the recommended practices listed in our flood adaptation guidelines, then it will meet the Secretary of the Interior’s Standards. It’s good for historic property owners and architects to have a clear pathway towards regulation compliance, which gives them confidence in adaptation projects.
Ziming Wang: I found in my research that a unique challenge faced by New York City lies in the very diverse historic building types within its floodplain. I wonder what are the major types of flood-threatened historic buildings across the country? In which areas are they clustered?
Jenifer Eggleston: It would be great to have a nationwide overlay of floodplain over designated historic resources — so we could get a better idea on the number and types of historic resources under flood risk, and use this information for advocacy and decision-making. But unfortunately, because our database is organized in a manner where historic districts, designated buildings, and historic resource surveys are often listed together, it will be extremely difficult to get a precise count on nationwide scale. It’s good to see your overlay and count based on New York City.
But empirically speaking, there are indeed diverse types of historic resources — not only buildings — in areas of high flood risk. There’s an emerging attention being paid to archaeological sites within the floodplain, as coastal erosion may threaten their continued existence; there are also cultural landscapes and historic districts, in addition to historic businesses and homes.
And yes, many existing guidelines and procedures pinpoint single-family homes, as they aim to walk individual homeowners through the adaptation process and relevant flood insurance policies. Retrofitting strategies for other types of buildings — those with shared party walls, commercial buildings, duplexes, etc. — shall be explored not only in terms of new design guidelines, but also through reforms in financial and insurance standards.
Ziming Wang: I’ve noticed that you and your co-authors have been featured in multiple presentations and workshops from the East Coast to the West Coast introducing the Guidelines. So how are the guidelines received in different states? Is it influencing local policy-making, or is local policy-making influencing your work?
Jenifer Eggleston: We’re very excited and ready to see how the guidelines are working in local contexts. We fully hope that it’ll get recognition in different places, but we’re also eager to hear where the guidelines didn’t make sense — you know, real-world work always happens on the local level.
What we are seeing is that local municipalities are slowly updating their language and referencing the NPS flood guidelines. I was searching for the floodplain ordinance of the town in Virginia that I live in the other day — guess what it says? It says rehabilitation of historic buildings in the floodplain shall be carried out pursuant to the Guidelines on Flood Adaptation published by the National Park Service. I’m glad that the guidelines are being seen as a tool, and applied to different places.
Ziming Wang: And, speaking of financial grants and subsidies — I know there are established programs at National Park Service, such as the Federal Tax Credit program and the Emergency Supplemental Historic Preservation Fund programs (ESHPF; which include recovery grants for Hurricane Katrina and Hurricane Sandy). How have these grant programs facilitated the flood adaptation of historic buildings?
Jenifer Eggleston: In terms of disaster recovery, most grant funding actually comes from FEMA and HUD; in fact, we are the “little guy in the town.” FEMA’s Hazard Mitigation Grant Program (HMGP) is one of the largest funding resources in the field, which can be used to provide assistance towards the relocation, elevation and demolition of historic buildings. We often administer our own grant programs in conjunction with FEMA & HUD grants to better help bring local historic resources back after hurricane impact. For example, a repair or reconstruction project after Hurricane Katrina or Sandy may be funded by FEMA or HUD grants, and we’ll pay for specific historic materials or finishings used in the project. In HMGP applications, FEMA would be the leading agency responsible for Section 106 Review, which helps make sure that elevation or other works on historic structures don’t result in their de-listing from the National Register.
There’s a longer history for historic preservation tax credits to be used in flood adaptation. Even before Hurricane Katrina, there had been adaptation projects dealing with riverine/inland flooding risks that secured Federal tax credits. If State tax credits are also available, 20% — 25% of the construction cost of a rehabilitation project may be recouped.
Ziming Wang: There’re many partners listed in the Guidelines’ Acknowledgements section — SHPOs, THPOs, FEMA, The National Trust for Historic Preservation, etc. It really looks like a vibrant coalition between flood experts and preservationists on multiple scales — a mechanism that I believe is still lacking in New York City and many other local communities. How was that kind of collaboration organized, and what can local preservation agencies learn from your experience?
Jenifer Eggleston: Everybody has their own expertise — and yes, our partners from Federal to local level have offered us valuable insights. The key is to be as active and open as possible while still being able to make progress. We would convene with our partners and say “Help us get this right”; or ask them, “Would this help you to get your work forward?” Of course, every partner has a different opinion, and consensuses are sometimes even harder to reach on Federal level — so it can only be achieved through slow and arduous work. But hurricane and flooding are such big issues and we can’t just sit here and wait — so my advice would be to go out, find friends, and leverage their expertise, instead of sitting in the room saying “I don’t know.”
Ziming Wang: The NPS Guidelines specifically mentioned the importance of the planning and assessment process before any form of intervention is taken. How can we formalize and incentivize such process in the flood adaptation of historic properties?
Jenifer Eggleston: Early-stage planning is super critical — although it might not be a typical process in many actual projects. Sometimes people tend to jump to treatments, without fully understanding the priority of physical risks, or documenting the reasons for those treatments.
But I’m also seeing a flip side to that question — in many ways, local governments tend to be very good at planning, but not so much at doing. So it’s also important to urge local policy-makers to reach active decisions, and implement the minimum necessary interventions to deal with flood risk.
Ziming Wang: And one final question — Can you share your vision for the next steps of National Park Service’s policy-making on the flood adaptation of historic built environment?
Jenifer Eggleston: Well, first of all, we want to keep the Guidelines on Flood Adaptation for Rehabilitating Historic Buildings as a living document — we’ll be actively listening to feedback regarding what adjustments may be needed, and keep updating our policy recommendations.
In addition to the Guidelines on Flood Adaptation, I’m also envisioning potential guidelines for other forms of environmental risks. As our project has demonstrated, guidelines may be a useful tool in regulating adaptation and hazard mitigation projects, and connecting these projects with the Secretary of the Interior’s Standards.
Another thing I’ve found out is that many local municipalities have robust planning departments or preservation agencies — while the National Park Service doesn’t yet have a full-time team for guideline production (all of the Guidelines on Flood Adaptation’s authors were holding full-time office positions). So, I’m excited to see more policies and guidelines made on the local level, and I also hope that there would be a more dedicated guideline team at the National Park Service, which could help strengthen our efforts on policy-making, internal training, and public outreach.
* This interview text has been transcribed and edited based on the interviewer’s notes. For more information on National Park Service’s Guidelines on Flood Adaptation for Rehabilitating Historic Buildings, please refer to this presentation made by its authors.
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