[MassHistPres] CPC funds prevailing wage and volunteers on town owned building

[Sara Wermiel]

Jonathan, Jim, Mike et al.,

First to the main question: what is allowed under the CPA with respect to
historic preservation? 
Yes, it is strange that the act defines "community preservation" as
including the "creation" of historic resources. This seems like a drafting
error to me, but assuming it was intended -- following the guidance on the
Community Preservation Coalition website -- it could mean converting a
historic building from one use to another. The act describes the kinds of
projects that a CPC can recommend as, "the acquisition, preservation,
rehabilitation and restoration of historic resources", which makes more
sense (no creations).

The CPA defines rehabilitation, as "capital improvements, or the making of
extraordinary repairs, to historic resources, ... for the purpose of making
such historic resources ... functional for their intended uses"

To me, this language suggests substantial improvements. It's not painting as
such, but the scope of work. If a building is painted as part of a
substantial rehab project, then it's rehab. Regular painting alone, even
though it can be very expensive, doesn't seem to be what was contemplated in
the act. If work is phased, as Mike indicated, then all the phases could be
added up, and combined may qualify as rehab.

Whether the funds should be allowed for repairs that are not
"extraordinary," of course, can be debated.

Regarding Part 68 and Part 67: the rehab standards in both parts are more or
less identical, but Part 68 includes standards for three other treatments in
addition to rehabilitation: preservation, restoration, and reconstruction.
Since the act indicates that "restoration" is allowed, then it seems logical
that these standards would apply to that kind of project, while the rehab
standards would apply to rehab. You can find 36 C.F.R Part 68 online (I
don't think I can send the link).

And as Jonathan said, these standards mainly give guidance for how work is
to be done. 

Sara Wermiel
Jamaica Plain, MA