Mr. Gillian D. Brown, Esq
Buffalo Municipal Housing Authority
300 Perry Street
Buffalo, NY 14204-2299
Re: Invitation to Comment – Alternative Analysis Supplemental Update Materials
June 22, 2020
Dear Mr. Brown,
I received the Invitation to Comment – Alternative Analysis Supplemental Update Materials on Tuesday, June 16th. Please accept the comments below as our official response to that correspondence.
Thank you for providing the supplementary materials. Preservation Buffalo Niagara continues to oppose Alternative No. 3 as an acceptable solution. As you know, Willert Park has been determined to be eligible for the National Register of Historic Places under Criteria A and C. Alternative 3, which destroys all of the buildings except for the Administration Building and saves the bas relief sculptures devoid of their building contexts completely destroys the historic integrity of this site, and represents a major erasure of history, and has an especially profound and irreversible impact on black history in Buffalo.
Willert Park/A.D. Price Courts is one of the single most historic places in the City of Buffalo. Its existence is critical to understanding the shape of our City, but it is also a critical site in the history of the United States. Perhaps no other site locally is capable of encapsulating the stories of how government sanctioned racism and segregation shaped the current reality of our City and of race relations in the United States. It is a story of one community’s fight for dignity and fairness against a range of forces determined to keep them down. It is a story of self-determination, and of organizing together to build political power. It is the story of what it means to be at home in the place where you live. Layer on top of that a high style design by a recognized architect, beautiful aesthetic embellishments by a famous artist, and a site plan that is specifically representative of its time and you have a space that should be protected and invested in, not destroyed.
Were Willert Park to be saved and invested in, not only could it serve its intended purpose as housing for those in need, but it could also be another important part of Buffalo’s cultural renaissance. A cultural renaissance that could finally be expanded to include more parts of our community: as architecturally important as the Darwin Martin House, but with a much more profound story to tell, connected not just to design or to a person of local importance, but connected to larger truths about our national identity and the lives of many people of local and national significance.
PBN wholly rejects the BMHA’s consultant’s argument that Alternative No. 3 is in any way consistent with Criterion A. By destroying every single building at the site except for one, the site would no longer be significant and would lack any and all integrity as defined by both the National Register of Historic Places (NR) criteria and the Secretary of the Interior’s (SOI) Standards. Trying to argue that the new units to be built would also be affordable and so would be consistent with Criteria A would be like tearing down Buffalo City Hall and building a new municipal building and trying to argue that the new building contributed to historic significance because it had a similar function as the old building. National Register criteria cannot be applied to non-existent or demolished or new buildings. It is only in relation to evaluating historic (existing) buildings (unless you’re reviewing archaeological sites). These arguments indicate a complete lack of understanding on the appropriate application of both the National Register of Historic Places (NR) criteria and the Secretary of the Interior’s standards. The only Alternative that meets Criterion A is Alternative No. 1.
Alternative 3 is wholly insufficient as a preservation alternative under Criterion C, and Alternative 1 is the best Alternative to preserve the site’s integrity under the Secretary of the Interior’s Standards. While we understand the argument that the BMHA’s consultant is making when they say that changes to some of the interior layouts or changes proposed under Alternative 1 may be problematic from the SOI’s standpoint, we strongly disagree. Nowhere in the National Register Nomination are interior finishes or room layouts identified as significant components of the design. We understand that the BMHA’s consultant has not been able to design solutions that would both preserve the integrity of the site and also result in safe, livable homes for residents. Preservation Buffalo Niagara has worked with other architectural consultants who have been able to create designs which are able to accommodate both HCR standards as well as SOI standards. If the BMHA were to work with PBN to grant us designated developer status, we are confident that we can produce designs that are able to honor both the historic nature of the site, as well as the lives of the people who will live there in the future.
Section 106 Process
PBN would like to request additional information about the Section 106 process. Who is the lead Federal agency on this Section 106 Review? Please also supply a list of other recognized Consulting Parties, and the process used for soliciting those parties. Please supply information about any public or community meetings undertaken as part of the Section 106 process, and any plans for future public meetings. Finally, please supply us with a timeline for the Section 106 process, including any formal public comment periods and the process that will be used for collecting public comment.
We understand that the Buffalo Municipal Housing Agency does not prioritize historic preservation and placemaking in its work, but is focused on housing provision and in this instance, is focused on providing large multi-bedroom units. PBN would certainly not presume to know more than the BMHA about its need for these larger units. However, PBN does reject the BMHA’s assertion that the only answer to filling this community-wide need is the continued erasure of black history in Buffalo. Within a one mile radius of Willert Park are over 2,500 vacant lots, totaling nearly 300 acres of vacant land. Additionally, the BMHA has current site control of Perry Projects and its nearly 1,000 vacant units. There are many alternatives for providing new larger housing. Demolishing an important historic site is not the only way for the BMHA to meet its goals.
With this alternatives analysis, the BMHA continues to offer us a false choice: provide large five bedroom homes for people who need them, or save one of the most historic sites in the City of Buffalo. PBN rejects this false choice. We know from decades of scholarly research that living in places with strong connections to history and culture are an important part of people’s mental and physical well being. We know that building an anti-racist society means investing in the places important to telling a full and complete story of our entire community. We know that Buffalo’s future is tied up in investing in the places that make us special, not in more disposable architecture that further differentiates between the parts of Buffalo that have been able to save their history and culture and the parts of Buffalo that have been systematically denied that opportunity.
Again, thank you for the opportunity to submit these comments. We would be more than happy to sit down with you at any time to discuss these matters further.