Do Simpler Local Documentations Really Save Time, Money and Resources?
The Pitch: The three programs administered by the Heritage Documentation Programs (HDP) department of the National Park Service (NPS), called the Historic American Buildings Survey (HABS), the Historic American Engineering Record (HAER), and the Historic American Landscapes Survey (HALS), are the gold-standard of documentation policies. The data created for HABS/HAER/HALS requires a Life Expectancy of over 500 years (LE500). Basically, as close to "FOREVER" as we are likely to get. This is accomplished by keeping the photographic negatives in “state-of-the-art curatorial facilities” at Fort Meade in Maryland which are humidity- and temperature-controlled. After donation to HABS, the Library of Congress (LoC) accessions the data, but that's not the end of the story; the Prints & Photographs Division also carries out a series of steps including text-scanning all the documents, scanning the drawings and film-scanning all the original negatives in high resolution. That's where the accessibility comes in; all the keyword-searchable data, medium resolution Jpegs and high resolution Tiff files of the drawings and photographs are uploaded to the LoC HABS WEBSITE available on the Internet for public viewing 24/7/365 worldwide. Can your local historical society do that?
The data created for HABS/HAER/HALS
requires a Life Expectancy of over 500 years…
Can your local historical society do that?
Documentation of historic resources is one way to mitigate impacts to significant properties and photographic documentation is one facet of a comprehensive CEQA mitigation strategy. There are many ways to document resources with digital photography, video, illustration, virtual reality, point-clouds, drone photography and activities that haven’t even been invented yet. These innovative mitigations are a great way to make mitigations more meaningful, but they need to supplement the required HABS documentation because HABS is the only way to guarantee perpetual access and storage. While these other documentation activities can be used to help share the memory of a site, only documentation for HABS/HAER/HALS meets the Secretary of the Interior’s Standards for Architectural and Engineering Documentation (SISAED); because it follows three basic requirements:
- Photography & measuring to capture maximum data.
- Archival document production and archival materials.
- Perpetual storage with perpetual public access.
Not just one or two of the basic tenets are required, but all three. The archival film, drawings and reports are placed in climate controlled cold storage and the keyword-searchable documentations are made available worldwide on the LoC website: http://www.loc.gov/pictures/collection/hh/ While it may appear that doing a partial HABS, HABS-Like, or Diet-HABS documentation using digital photography and/or distributing the artifacts locally would be sufficient, in order for the mitigation to be a public benefit for future generations and meet the SISAED, the entire HABS procedure must be followed.
The Good News: Better is Cheaper: Counterintuitively, making only one copy of a HABS/HAER/HALS documentation for the Library of Congress and donating it to Heritage Documentation Programs in Washington DC through their informal donation policy is less expensive than distributing multiple archival copies locally. Note that what we call the "direct donation" procedure to HDP is different than the required "mitigation review" procedure for federal undertakings administered at the NPS Western Regional Office (more on that later). If a lead agency oversees mitigations for a historic resource under CEQA, then the mitigation should actually result in a public benefit when completed. The ACT of documentation does not have a mitigating effect on the resource. The data recorded and its distribution to the public into the future is the mitigating effect; the more widespread and long term the data distribution, the more meaningful the mitigation.
It is the three tenets above: Maximum Data Documentation/Archival Data/Perpetual Accessibility that make a HABS/HAER/HALS survey work, but local documentations usually fall apart on number 3: Accessibility. In our experience CEQA mitigations usually require large format photography and measured drawings "follow HABS/HAER/HALS guidelines*" they often expressly require large format film photographs by an experienced photographer and measured drawings by an experienced architect. These mitigations go on to require document production on archival materials "to HABS/HAER/HALS guidelines*." Then things go haywire, in an attempt to avoid the perceived delay associated with NPS review and perhaps the perceived expense of the getting the data into the LoC, the mitigations spell out the multitude of local historical societies, libraries, archives, info centers and museums that will get copies of the archival prints and sometimes additional sets of master negatives as well. This last rewriting of the guidelines, can be the costliest and yet it often reduces the public benefit of the mitigation, because once those negatives are in typical storage, their life expectancy starts to fade. Local archives cannot afford to keyword scan and upload the high-resolution photos and do not have LE500 state-of-the-art curatorial facilities that keep the negatives at a temperature of 35ºF and 30% relative humidity.
The concept of "HABS-Like" is a failure: There, I said it. All of the "HABS-Like" large format documentations we produce in California as CEQA mitigations could be repackaged into HABS archival negative envelopes ($1.00 each) and mailed to HDP in Washington DC for inclusion in the LoC without any further effort on our part; the majority of CEQA mitigations already require HABS guideline* conformance and they are thus ready for donation to the LoC (which will never happen, because the negatives have been delivered and accessioned and no archive would give them back). These local documentations will stay local, most won't ever be scanned, none are keyword-searchable, most won't be available on the internet and often just sit on a shelf in the basement of the planning department or local library because three-ring binders of archival prints and negatives don't mix well on the shelves of books upstairs. All this means they don't rise to the Secretary of the Interior's Standards; close, but no cigar.
There are some solid archives out there, like the SF Public Library and the LA Public Library, and these are a good place for "second copies" if you want a local set after sending the SISAED compliant negatives to LoC. These large public libraries do have good facilities, and good search and access procedures, but they are not "forever" and not available online 27/7/365 to anyone, even if they don't have a library card. We have experienced cases where seven sets of prints and drawings and two sets of negatives were requested in a mitigation. Often one of those sets of negatives is destined for HABS anyway, making the printing six times more expensive without any actual accessibility benefit to the public, the LoC set is going to be more accessible, more searchable and better stored (more foreverable) than any local set.
A recent seven-print mitigation: The HABS documentation shall be submitted to NPS for transmittal to the Library of Congress (1), and archival copies shall be sent to the City Landmark Committee (2). In addition, one original copy shall be sent to each of the following entities:
3. Southern California Coastal Information Center (SCCIC).
4. The archives of the City of X Conservancy.
5. The archives of the City of X Historical Society.
6. The archives of the City Public Library.
7. The archives of The Huntington Library.
Print sets that will last a lifetime, for city planning, local historical conservancies and landmarks commissioners, can be produced as acid-free paper laser prints from a color copier for less than $1.00 each and regular 11×17" paper plans can be printed for a fraction of full-sized archival vellum drawings that met the HABS spec. Or better yet, add on some DVD's with PDF reports, maps, historic photos and scans all ready for easy access and sharing, or Print-On-Demand books for the local library. The creative, innovative, video documentations, virtual-reality walk-thrus, drone photography, coloring books, ghost stories and 3-D renderings should go to the local groups for dissemination on everyone's websites and Facebook and Instagram pages. Once the master set of archival prints, negatives, drawings and report are donated to HDP and accessioned by LoC, there is no need for the city or local groups to store, protect, insure or backup the core data from a HABS survey. If a local citizen wants to access the high resolution files, just type the name of the city into the Library of Congress HABS search box, here, and voila, instant access. The high resolution photographic and drawing files alone take up hundreds of megabytes of space and creating a website to disseminate those images would perpetually need updating, maintenance, and a backup strategy in case of server crashes or viruses. The negatives need to be kept cool and dry and the prints should be available to historians, students and the public. Can your local library archive negatives forever? Most local libraries and museums lack the ability to archivally store film negatives for even a generation, and definitely can't compete with Library of Congress life expectancy of over 500 years.
In the end,
why not let the Library of Congress
deal with it for the next 20+ generations?
What's Stopping You? (Probably NPS review) We want to dispel a couple of myths that have made HABS-Like documentations popular.
Myth #1: NPS Heritage Documentation Programs is only interested in National Historic Landmarks and properties on the National Register of Historic Places.
Heritage Documentation Programs staff want documentations, if it's historic they want it. From the beginning the HABS mandate was to document "A complete resume of the builder's art." The formal 1933 proposal for HABS intended that it cover " … structures of all types, from the smallest utilitarian structures to the largest and most monumental." A 1997 memo was circulated by the ACHP that stated that federal documentation will only be carried out on National Historic Landmarks and Nationally significant sites to the detriment of the HABS/HAER collections, but a recent memo has replaced that limiting policy with an inclusive policy that federal documentations will include ALL historic properties. HDP has also been very keen on accepting documentations of resources that are not on the National Register but have local historic significance, buildings as small as a hot dog stand that would not usually require a federally reviewed mitigation.
Myth #2: HABS/HAER/HALS "direct donations" are reviewed for adequacy and require approval by the NPS regional office.
Heritage Documentation Programs "direct donations" are not reviewed like federal mitigations. For mitigations under Section 106, the portion of the National Historic Preservation Act, draft HABS mitigations must be reviewed by the NPS Western Regional Office historian in Seattle to assure adequacy of mitigations and recommend changes, edits and sometimes additional documentation. In contrast, "direct donations" to HDP involve a phone call with the HDP collections manager in Washington DC to discuss if the resource is historic, and communication to determine the catalog number and title for the documentation. Most CEQA documentations meet HABS/HAER/HALS formatting and archival guidelines*, and HDP would like to have them in the formal LoC collection, even if it's just one or two photos of a local historical building, this requires one copy of master negatives and one set of archival prints, one copy of any drawings on vellum, and one copy of the report.
Myth #3: HABS/HAER/HALS documentation needs to be undertaken with "official" involvement.
Heritage Documentation Programs will accept direct donations from anyone willing to follow the stringent guidelines. This can be done by photographers, historians, or developers trying to get a jump on documentation mitigations that they know will be required on a future project. Since there is no better documentation program than HABS/HAER/HALS, having an architectural historian develop a scope and write a report, and having an architect and large format photographer begin the documentation fieldwork can save time, and time is money. If no historian is available to do a full HABS report, a HABS history-short-form can be filled out by anyone with access to basic historic information about the resource. The best time to document a historic resource is when it was built, the second best time is today; waiting for a moment sometime in the unknown future when the documentation is a contractually required mitigation, is tied to milestones in the project approval process, and needs to be signed off by the city will not produce a better archival document. We have done a number of documentations where "getting-it-over-with" was our client's main goal, but it saved time and money and made for a better documentation nonetheless. Win-Win.
We'll write more about unofficial donation documentations in a future blog post: HABS Mitigation for CEQA (Part 2: Can Sooner Also Be Better?)
We have created an EXAMPLE OF MITIGATION text to generally meet the documentation requirement of some CEQA environmental documents like MNDs and EIRs. These mitigations can also be used as a basis for creating NEPA and Section 106 mitigations to federal undertakings, but consultation with the State Historic Preservation Officer (SHPO) will be required to determine the exact deliverables and required scope.
*Preparing HABS/HAER/HALS Transmittal Guidelines available at:
https://www.nps.gov/hdp/standards/Transmittal.pdf
Take a look at the Frequently Asked Questions section of our website if you’d like more information about HABS/HAER/HALS photography.