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

[Roughan, Michael]

I would like to suggest that perhaps we could solicit the services of the Community Preservation Coalition and Christopher Skelly, either individually or as a group to assist in developing a "standard of practice" regarding the use of CPA funds. While our email dialogue is beneficial to the recipients, there is no good way (that I am aware of) to retrieve our comments for others later.

Perhaps, this topic could be an agenda item for one of the historic conferences sponsored by one of the historic preservation groups regionally?

Anyways, I am fine continuing the dialogue as you all are a tremendous resource and I value your input.

Regards,

....Mike

Michael Roughan, AIA, EDAC, LEED AP

D +1.617.357.7725 M +1.617.784.6463



-----Original Message-----
From: masshistpres-bounces at cs.umb.edu [mailto:masshistpres-bounces at cs.umb.edu] On Behalf Of Sara Wermiel
Sent: Thursday, April 21, 2016 10:39 PM
To: 'MA Historic Preservation'
Subject: Re: [MassHistPres] CPC funds prevailing wage and volunteers on town owned building

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

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