ACHP Calls for More Protection of Historic Jones Library

Recent letters from two agencies involved in oversight of the architectural changes proposed for the Jones Library challenge a memorandum of agreement (MOA) proposed last month by the town.

In an attempt to resolve ongoing issues related to preservation of historic aspects of the Jones Library building, the town offered a draft Memorandum of Agreement (MOA) to Consulting Parties on January 30, 2025. According to the Section 106 Review process, the town and the State Historic Preservation Officer (SHPO), in this case the Massachusetts Historical Commission (MHC), must come to an agreement about how to address adverse effects (see also here and here) of the proposed demolition and expansion on the historic Jones Library before federal funding can be released. 

In a letter of February 5, 2025, the MHC found that the proposed MOA by the town was not sufficient and recommended several additional actions, including preservation of all original mahogany millwork and retention in either the existing building or any addition. Among other items, it also specified that the existing slate roof tiles be salvaged as possible and, as necessary, replaced with genuine slate of similar quality.

In a February 13, 2025 letter, Rachel Mangum, Assistant Director, Office of Federal Agency Programs of the Advisory Council on Historic Preservation (ACHP), declined to participate in consultation for the time being but noted that they would re-engage if the SHPO and town fail to reach agreement. The ACHP is the federal agency charged with promoting the “preservation, enhancement, and sustainable use of our nation’s diverse historic resources”. Representatives from the ACHP have attended the Section 106 meetings and were invited to participate in current negotiations on the MOA, as is common practice. They offered the following advisory comments “in consideration of the strong interest in and concern about this undertaking demonstrated by consulting parties and members of the public”:

Clarification of Preservation Restriction Agreement
In 2022, a Preservation Restriction Agreement (PRA) for the Jones Library property was executed by the Jones Library Trustees and the town that calls for adherence to the Secretary of the Interior’s Standards for the Treatment of Historic Properties. However, the town has interpreted the PRA to allow for more substantial changes, provided they are reviewed and assessed by the Amherst Historical Commission. The ACHP encouraged the town “to provide information to the consulting parties regarding the applicability of the PRA to the undertaking as proposed, and how the town has met or intends to meet the terms of the PRA for this Section 106 review and undertaking.”

Retention of Historic Fabric (Specifically, Original Millwork)
Like the MHC, the ACHP noted the concerns expressed about the loss of a significant portion of the original handcrafted mahogany millwork throughout the 1928 building. It encouraged the town to “continue to consider alternatives that avoid or minimize adverse effects on these contributing features, including potential salvage or reuse if preservation in place is not feasible.”

Wider Public Involvement in Continued Design Review
Although the draft MOA includes a process for continued design review by the Amherst Historical Commission, “the ACHP suggests that any continued refinements to the undertaking design also be shared with the consulting parties and made available for public review through a process defined in the MOA.” This was in recognition of the strong interest expressed by members of the public and by consulting parties.

No response Yet from Town
The town has not offered any public response to the letters from either the MHC or the ACHP. The Section 106 process must be resolved before any construction contracts can be signed. The town has also not indicated whether bids received from contractors in October 2024 are still valid and no new bid documents have been posted online for the changes to keep the roof as genuine slate. As of this writing, the Jones Library Building Committee has not met to discuss these issues and no meeting is currently scheduled.