Town Acknowledges Adverse Effects of Jones Expansion Project on Historic Character of the Building.

Meeting of Consulting Parties Will Explore Mitigation Strategies

The Town of Amherst has notified the State Historic Preservation Officer (SHPO) Brona Simon, Executive Director of the Massachusetts Historical Commission (MHC), and all consulting parties to the Town’s Section 106 Review that the town has determined that the Jones Library Demolition/Expansion Project will have adverse effects on the historic character of the Jones Library and the historic district in which it resides. The town must now devise strategies to eliminate or minimize these adverse effects if they wish to remain eligible for pending federal grants of nearly $2 million. 

The notification was sent to all participating parties in a 12 page memo dated October 1, 2024 from Bob Peirent, the town’s Special Capital Projects Coordinator, The town’s findings were based on recommendations from Section 106 consultant Virginia H. Adams, Senior Architectural Historian of the Public Archaeology Laboratory of Pawtucket, Rhode Island.

Adverse Effects
Among the adverse effects highlighted in the memo are the following:

“The demolition of portions of the original 1928 Jones Library building, interior alterations that will remove historic materials and modify circulation, and construction of a new addition that is larger in footprint than the existing 1993 addition will have an adverse effect on the Jones Library…”

Among the adverse concerns originally listed by the MHC in denial of the library’s multiple applications for historic tax credits (see also here, here. and here) were threats to the building’s historic millwork crafted from rare Philippine mahogany. Recent value engineering proposed to remove and discard all of the historic woodwork. Then, in response to widespread protest from the community, Jones Trustees President Austin Sarat reported that the woodwork would be retained and preserved.  Peirent’s memo indicated that about 25% of the historic woodwork is to be removed and discarded.

Peirent’s memo also states that the viewscape of the historic district will be adversely impacted as follows.

“The new addition will be visible within the Amherst Central Business Historic District in views from the west, south, and east. It will be minimally visible from the east along North Pleasant Street due to intervening historic and non-historic buildings and from the north due to trees lining a paved parking lot and non-historic buildings. Although the views will be similar to existing conditions, the changes in the immediate setting and the impact to the rear of a key building within the district will result in an adverse effect on the visual setting of the Amherst Central Business District.  

The new addition north and west elevations will be visible in views from the northwest and west at the Strong House property and will include views of the enlarged section of the north elevation. While there will be some screening by trees and vegetation, the proximity of the rear addition will result in an adverse effect on the visual setting of the Strong House.”

The memo also asserts that there are no adverse effects on the viewscape of the historic library as seen from Amity Street and that the proposed addition is not visible from the sidewalk facing the library. However the MHC memo argues that the new addition is inappropriately sized and dwarfs the historic building, including from the view looking toward the main entrance on Amity Street.  

Peirent’s memo also acknowledges that the Massachusetts Historical Commission (MHC) found, prior to recent “value engineering,” that the project fails to comply with five of the Secretary of the Interior’s 10 Standards for the Rehabilitation of Historic Properties but does not discuss the adverse effects of the current plan in terms of the Secretary’s standards.  

Peirent indicated that further details about the adverse effects findings would be provided soon.

The MHC was apparently not asked to respond to the final design of the library following value engineering modifications to the plans, as a new project notification form, detailing the final changes to the design, was apparently first sent to the MHC with this memo.

What Is A Section 106 Review?
Section 106 of the National Historic Preservation Act of 1966 (NHPA) requires federal agencies to consider the effects on historic properties of projects they carry out, assist, fund, permit, license, or approve throughout the country. If a federal or federally-assisted project has the potential to affect historic properties, a Section 106 review must take place. Section 106 gives the Advisory Council on Historic Preservation (ACHP), consulting parties, and the public the chance to weigh in on these matters before a final decision is made. The four-step process includes consultation to explore measures to avoid, minimize, or mitigate any adverse effects that may be identified to the historic property and reach a Memorandum of Agreement (MOA) which records the resolution measures agreed upon to resolve these adverse effects. 

Historic properties are districts, buildings, structures, objects, and sites that are listed or eligible for listing in the National Register of Historic Places (National Register). The Jones Library is listed in the National Register as a contributing building in the Amherst Central Business District, which was listed in 1991. 

The Jones Library Building Project requires a Section 106 Review because it is slated to receive a grant from the National Endowment for the Humanities (NEH), and a grant from the U.S. Department of Housing and Urban Development (HUD). Failure to satisfactorily complete a Section 106 review would put receipt of those tentatively granted funds in jeopardy. The town’s application for roughly $2M in historic tax credits was denied four times (add LINK) because of failure to address MHC concerns about the project’s violation of the Secretary of the Interior’s Standards for Rehabilitation of Historic Buildings.

Under the provisions of Section 106, the town may not sign a contract for construction until the Section 106 review and an environmental (NEPA) review have been completed.  The town put the project out to bid on September 25 and bidding for general contractors closes October 31.

Environmental Review
But the Section 106 process is not the end of it. The town must fulfill another federal requirement before HUD and NEH will release funds. It must conduct a thorough assessment of the effect the demolition and construction will have on the environment. The controlling federal regulations include public dissemination of environmental reports and mandatory public comment periods. Compliance could take several weeks and yet the town has not given any indication that the process has begun.

Mitigating Adverse Effects
The mitigation of adverse effects will be the subject of a meeting of consulting parties on October  9  from 12:30 – 3:00 p.m. on Zoom. The meeting is open to the public.

The town has recognized 15 consulting parties who have joined this process along with the town and the Jones Library Trustees and they are listed below.

Amherst Area Chamber of Commerce
Amherst Business Improvement District
Amherst College Community Engagement
Amherst Historical Commission
Amherst Historical Society
Amherst Historic Preservation Coalition
Ancestral Bridges
Burnett Art Gallery
Downtown Amherst Historic District Commission
Emily Dickinson Museum
Friends of the Jones Library System
Frost Library, Amherst College
Massachusetts Historical Commission
Literacy Project
UMass Amherst University Relations

Each consulting party will be given five  minutes to offer commentary on the town’s findings and on proposed mitigation and will subsequently participate in a facilitated discussion. Based on the input gathered at that meeting, the town intends to draft a memorandum of agreement (MOA) with a proposal on how it will mitigate adverse effects. The MOA must then be approved by the SHPO before it is forwarded to the NEH and HUD. Release of pending funds requires acceptance of the MOA by the federal agencies.

It appears from Peirent’s memo that the town is proposing to employ a photo archive strategy of mitigation – whereby the library would photograph existing conditions and  create a photo archive to document the appearance of the historic structure prior to the demolition of the 1993 addition, renovation of the historic building, and construction of a large addition.  A photo display on the building’s history will be created when the renovation is complete.

It was not evident that the consulting parties will have any final say in the form that MOA takes or have any additional opportunity to offer input once the town drafts the MOA.

The town will also contract, apparently with PAL, to conduct an archaeological survey on the property to ensure that no archaeological resources are destroyed in the demolition or construction. No timeline was offered for when this survey would take place but it appears that the project cannot move forward until it does. The archaeological survey was on the agenda for the Jones Library Trustees Meeting scheduled for Friday October 4. 

Public Input Invited
The public is invited to contribute comments to the 106 review.  There will be time set aside for public comment at the October 9 Section 106 review meeting. Comments also can be submitted to the town’s Jones Library Building project web page here: https://www.amherstma.gov/formcenter/committee-forms-3/public-comment–jones-library-building–210. Comments will be accepted until October 30.