Diagram for Lower Manhattan Coastal Resiliency (LMCR), a collection of neighborhood-scaled infrastructural adaptation projects launched by New York City that will form a continuous landscaped flood barrier surrounding Lower Manhattan. Source: NYCEDC; NYC Mayor’s Office of Climate Resiliency; ARCADIS. 2021. Financial District and Seaport Climate Resilience Master Plan.
As New York State’s governmental historic preservation agency, the New York State Historic Preservation Office (SHPO) administers Federal and State-level preservation programs including Statewide Historic Resources Survey, New York State and National Registers of Historic Places, Federal Historic Rehabilitation Tax Credit, Certified Local Government program, the State Historic Preservation Tax Credit & Grant programs, State and Federal Environmental review, and a wide range of technical assistance.
After Hurricane Sandy, New York SHPO became one of the 12 SHPOs and 2 THPOs (Tribal Historic Preservation Offices) in Northeast and Mid-Atlantic regions that received National Park Service’s Hurricane Sandy Disaster Recovery Grants, which helped it to carry out a five-year initiative to survey historic resources within flood-threatened communities, as well as fund brick-and-mortar rehabilitation projects on several flood-damaged sites including the Saugerties Lighthouse on the Hudson River. New York SHPO has also administered Section 106 Reviews or State Historic Preservation Act (Section 14.09) Reviews for a number of Lower Manhattan’s neighborhood-scaled resiliency plans.
In this interview, New York SHPO staff share information on how heritage resilience relates to their scope of work and recent project reviews. A Zoom interview with Ms. Olivia Brazee, New York SHPO’s Historic Site Restoration Coordinator for New York City, was carried out on Jan. 31, 2023; Ms. Chelsea Towers, New York SHPO’s Survey & National Register Coordinator, answered questions about SHPO’s Hurricane Sandy Survey via email. Ms. Kathy Howe, Director of New York SHPO’s Community Preservation Services Bureau, also contributed to the interview.
“It’ll be a worthy challenge to put information in one place, and to consolidate available resources for the public."
Ziming Wang: What impacts did Hurricane Sandy cause to New York State’s historic resources? What are some major projects that were launched under National Park Service’s Hurricane Sandy Disaster Recovery Grants, and which geographic locations did these projects focus on?
Chelsea Towers: After Hurricane Sandy hit the Eastern seaboard in 2012, New York SHPO realized the need to evaluate damages and flooding risks faced by the State’s historic properties; however, our ability to assess damages was hampered by a lack of consistent and up-to-date information on resources within affected areas. So under National Park Service’s Hurricane Sandy Disaster Recovery Grants, we launched Hurricane Sandy Historic Resource Survey of Select Waterfront Communities — a five-year initiative to document historic resources within communities vulnerable to flooding. Communities surveyed in this initiative were selected based on aggregated data from FEMA’s “Hurricane Sandy Storm Surge Extents” and NOAA’s “NY Preliminary Coastal Inundation Risk Assessment,” and included study areas affected by Hurricane Sandy, as well as locations that were designated at extreme, high or moderate risk for future flooding.
In general, the survey looked at waterfront areas of Suffolk and Nassau Counties, select communities within Orange, Rockland and Westchester Counties, and New York City’s Five Boroughs; for each of the study areas, our consultants produced a context statement about the history of the community, and made recommendations for National Register eligible individual resources and historic districts. In total, 14,293 properties were surveyed; 28 historic districts were identified or updated; and approximately 11,000 properties were added to, or updated in, the New York State Cultural Resource Information System (CRIS).
In addition to the Hurricane Sandy Survey, the National Park Service grants also funded several brick-and-mortar rehabilitation projects for historic resources affected by the hurricane.
Ziming Wang: How did Hurricane Sandy change New York City’s flood adaptation and historic preservation policy-making? During the Section 106 Review process, has New York SHPO identified any challenge to the heritage values of historic properties brought by flood adaptation projects?
Olivia Brazee: After Hurricane Irene and Hurricane Sandy, we really started to see some changes in citywide resilience policy thinking. We’ve seen the development of planning regulations and studies that seek to proactively protect communities and properties from future flood events; and the city has launched a number of community-scaled infrastructural adaptation plans under the Lower Manhattan Coastal Resiliency (LMCR) initiative. It’s exciting to see these ambitiously scaled proposals, which are to some extent informed by the huge financial losses caused by past flood events.
In New York City, the SHPO was involved in the review of several community-scaled resilience infrastructure plans — such as the East Side Coastal Resiliency Plan which envisions a series of floodwalls, floodgates and raised landscapes designed at 16.5 feet above sea level, the Battery Coastal Resilience Plan that will raise the Battery Wharf by 5 feet, and the Battery City Coastal Resilience Projects that features a landscaped barrier system that cuts through Wagner Park. We have evaluated potential impacts on local historic resources and important viewsheds (e.g. the viewshed between the Battery and the Statue of Liberty) brought by these projects, and voiced our considerations when adverse impacts are identified. If all these projects do get built, Lower Manhattan’s waterfront will be significantly transformed, in a way that provides a new context for adjacent historic districts and landmarks.
Speaking of building and site-level interventions, many appropriately designed flood adaptation solutions — such as the installation of flood vents, flip-up flood barriers, relocation of mechanical and electric equipment, and basement fill — typically don’t interfere with a building’s historic character, and are therefore deemed as not causing adverse effects by SHPO. But in the case for historic districts, the considerations must be made for more than just a number of individual buildings — so I guess we have to really wait and see some of the more nuanced impacts brought by large and small-scaled adaptation interventions on our historic districts. One interesting neighborhood to observe would be Red Hook: it’s an officially undesignated but obviously historic neighborhood, and the city has proposed above-grade floodwalls there.
Ziming Wang: Flood adaptation and historic preservation are both complicated and professional fields — and sometimes it may be hard for historic homeowners and property owners to get information on available design, policy, and financial resources from different governmental agencies. How do you think preservation standards and public information-sharing mechanisms should involve to better serve flood adaptation projects?
Olivia Brazee: Yes, it may be difficult and challenging for home and property owners to know where to go for information — and ultimately they may have to deal with multiple agencies and get information in a piecemeal manner. We know it’s important to put information in one place, and to consolidate available resources for the public — but so far, we can only do so for programs and resources under our purview. It might be a worthy challenge for researchers like you to create an integrated, interdisciplinary information platform on heritage resilience.
Our review work at SHPO only deals with projects that are funded, approved, or licensed by State or Federal agencies — so we don’t often serve as a direct interface to homeowners. However, when projects come to us for review, we’ll try to convey information and procedures as clearly as possible. At SHPO, we actually administer three different kinds of project review: the Federal Section 106 Review, State-level historic preservation review under New York State Historic Preservation Act, and additionally, environmental review pursuant to the State Environmental Quality Review Act (SEQRA). There are overlaps between these reviews, and the procedures may seem overwhelming to applicants; but we constantly try to streamline the process for applicants or direct them to the right agency to consult, very often through email correspondence and phone calls. On the flood resilience front, we are regularly in contact with preservation officers at FEMA, who carry out Section 106 Reviews for flood mitigation grant applications filed to them that may involve designated historic properties.
Another program closely associated with project applications is Federal and State-level tax credits and grants — they are the ambassadors of historic preservation in the real world. We’ve done quite some public education on tax credits: we used to conduct in-person tax credit workshops, which turned virtual during Covid.
Ziming Wang: Speaking of these historic preservation financial incentives — as the ambassadors of historic preservation, have they facilitated flood adaptation projects on New York State or New York City’s historic properties?
Olivia Brazee: I’ve seen project applications for tax credits and preservation grant programs where flood resilience is part of the project design — however, for projects applying for historic preservation incentives, flood adaptation is often a secondary goal within the whole scheme. A rule in Federal and State tax credit programs relevant to flood adaptation is the definition of Qualified Rehabilitation Expenditures (QREs) — which covers interventions on the building, but not necessarily site works (such as levees and barriers) related to flood resilience.
Ziming Wang: I noticed that in New York State’s latest Historic Preservation Plan (2021-2026), “Disaster Planning and Resilience” was identified as one of the key topics. What are some of the next steps that New York SHPO is taking to address heritage resilience?
Olivia Brazee: Yes, we incorporated Resilience as a key goal in our current State-level preservation plan, which means that we’ll take more resilience considerations into account when we review the projects that come to us.
At SHPO’s Technical Assistance and Compliance Unit, our role may be pretty reactive or advisory; however, after Hurricane Irene which wiped across some historic towns in New York State, the SHPO provided direct technical support in the post-disaster recovery process, and helped to make sure that works happening on-site were compliant with Secretary of the Interior’s Standards for Rehabilitation.
The National Park Service has recently published Guidelines on Flood Adaptation for Rehabilitating Historic Buildings; looking forward to the future, I would hope to see more standards to be developed to help delineate agreed-upon flood resilience design treatments that are compatible with the unique character of historic buildings and sites, as well as potential reforms in tax credit programs so they may better work for flood adaptation and flood resilience projects.
* This interview text has been transcribed and edited based on the interviewer’s notes.
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