Public Comment: Don’t Ignore Mass Historical Commission Guidance This Time Around

by Art and Maura Keene

The following public comment was submitted in writing to the Amherst Historical Commission for their meeting of August 28, 2024.

At your public hearing on August 22, 2024 you decided not to revisit your decision from October, 2023 about the library’s Preservation Restriction Agreement, even though critical information germane to that decision had been withheld from you.  Furthermore, one of your number testified that at that October meeting, you had taken the time to review the Secretary of the Interior’s Standards for the Rehabilitation of Historic Properties and applied them carefully to the proposed design, when the minutes and the video of the meeting indicate that you did no such thing.  This is not a good look, neither for the commission nor for the town and its commitment to historic preservation.

Furthermore, you were told that you could not revisit a decision that had previously been made and this is simply not true.  All town bodies have that right, and indeed exercise that right to revisit past decisions in light of new information. You really have an obligation – statutory and ethical – to do the same.  And you ought to be demanding an explanation for why such critical information was withheld from you.

And now you are poised to compound that error of 2023 by doing the same thing again.  The MHC has yet to weigh in on the proposed value engineering changes – indeed, we suspect that they probably have not been notified of them. The trustees apparently have not yet filed the required Project Notification Form (PNF) with the state. You know that there will be an evaluation coming from the state’s highest authority in historic preservation. Given the glaring difference between your own assessment and that of the MHC the last time around, it would be responsible of you to wait and to include that assessment in your own deliberations to make sure that you get it right. 

Of course, you are being pressured to make a decision tonight, because of deadlines faced by the architects and the trustees. But that is not a problem of your making, and you should not undercut the quality of your own work, and indeed fail to execute your ethical and statutory responsibility -which is to protect the historic character of the historic Jones building – because of assertions that the drawings must be completed in another week or so and can’t be without your vote.  Throughout this project, the trustees have been remiss and/or tardy in complying with preservation law. It is not fair for the them pressure you or rush you now. Please don’t make the same error again. This time, it would be compounded because you know that there is additional, important information coming and you have a right to see it. Indeed, given that important information has been withheld from you in the past, you ought to demand the time that you need to do a thorough evaluation.

The arguments that “we have our own standards” and that “we do not have to answer to the MHC” that were offered last week are pretty flimsy and embarrassingly self-serving. That attitude cost the town $2M in historic preservation credits because the town refused to address the MHC’s concerns. Those arguments will carry no weight among unbiased preservation authorities when the project comes up for Section 106 review and that could cost the town another $2M in HUD and NEH grants.  That hubris is kind of ironic coming from folks who seem all too willing to degrade the historic building to cut out a few costs.

Please do the right thing and wait for the MHC guidance before you offer a determination on the preservation restriction. 

Art Keene is managing editor of the Amherst Indy and Emeritus Professor of Anthropology at UMass. He directed the UMass Archaeological Field School during the 80’s and 90’s and was involved with historical preservation throughout Western Massachusetts during that time. He has lived in Amherst since 1982.

Maura Keene is a retired obstetrician-gynecologist at BayState Health Systems. Her four children are graduates of the Amherst schools. She has lived in Amherst since 1982. She is a frequent contributor to the Amherst Indy.