Consulting Parties Disagree on How Much Historic Preservation Is Needed for the 1928 Jones Library

The Jones Library Building Committee (JLBC) convened on October 9, to fulfill the public comment component of the town’s Section 106 Review of adverse impacts of the Jones Library demolition/expansion project to the historic character of the 1928 Jones building.  The meeting was recorded and can be viewed here.

The purpose of this meeting was to receive input from consulting parties and the general public on possible interventions to address the impact of adverse effects to the historic character of the Jones library that had previously been identified by the town.  A Section 106 review is required because the Jones is listed on the National and State Registers of historic places and because the Jones demolition/expansion project is slated to receive state and federal grants that require a Section 106 review.

Section 106 consulting parties may include historical societies, preservation societies, local governments, historic neighborhood representatives, landowners, and other residents with an interest in the project or concern about the project’s effect on historic properties. Satisfactory completion of this review is required in order for the town to receive roughly $2M in grants that have been tentatively awarded to the town from the National Endowment for the Humanities (NEH) and the Department of Housing and Urban Development (HUD).  Those funds can be released only after the State Historic Preservation Officer (SHPO) has accepted a Memorandum of Agreement (MOA) with the town, specifying how the project’s adverse effects will be eliminated, minimized, or mitigated, and after that MOA has been accepted by HUD and NEH.

Twenty organizations and representatives of four First Nations were invited to participate in the review and to offer input on the town’s recent findings that the proposed demolition and renovation project had adverse effects on the historic character of the 1928 library and to give feedback from the perspective of their organizations. Each consulting organization was allowed to send two representatives to speak on their organization’s behalf.  The meeting was open to the public and time was set aside for public comment.  Fifteen representatives from 12 consulting organizations offered input (see below)

That input, along with written testimony that can be submitted until the end of October (see below) will then be used by the town, its consultant, and the State Historic Preservation Officer (SHPO) at the Massachusetts Historical Commission (MHC) to craft the aforementioned Memorandum of Agreement (MOA).

Earlier this month, the town had hired the Public Archaeology Laboratory of Pawtucket, Rhode Island to make a determination of adverse effects.  The town notified consulting parties that it had identified four adverse effects on the historic building of the proposed demolition/expansion as follows: “The Project will have an “adverse effect” on historic properties through the physical destruction of part of the Jones Library, alterations to interior circulation and historic materials, and construction of a rear addition, and changes to the visual setting of the Amherst Central Business Historic District and the Strong House.”

These adverse effects had been noted in the Massachusetts Historical Commission review of a detailed design description known as the Project Notification Form and in rejections of historic tax credit applications for the project.

The Amherst Historic Preservation Coalition, one of the consulting parties comprised of local preservationists and concerned residents, identified another five adverse effects:

1. Re-roofing with synthetic slate rather than authentic Buckingham slate – Identified by Massachusetts Historical Commission (MHC), November 22, 2023
   
   Though the Town reports the unavailability of Buckingham slate there are dealers across the country that still maintain supplies of the product. There are also other slate shingles, e.g. Vermont slate, that are commercially available and last 125 years or more.  The lifespan of synthetic slate is roughly 50 years.
   
   Prior to this project, Jones Library Boards of Trustees have diligently maintained the slate roof, using state and town CPA funds to perform the work.
   
2. Removal of 25% of historic millwork – The Jones Library Historic Structure Report states that nearly all of the irreplaceable millwork has been retained and is in very good condition considering its age.” The 1993 addition expanded the library but made only minor alterations to the original historic building according to the MHC.
   
3. Book drop hole cut into main stone façade – Jones Library trustees have said that there is no longer a plan to purchase an automatic book sorter, rendering this hole unnecessary.  The project architect justified the modification to the front facade saying that the current outdoor book drop receptacle is too small and books are sometimes left on the ground. But a second receptacle would easily solve this.
   
4. Loss of Whipple Window as an exterior window – The Historic Structure Report describes the “magnificent elliptical fanlight” Whipple Window that was reused in the north exterior wall of the 1993 addition.  It is not clear from the Project Notification Form how this window will be treated, but it does not appear to be remaining as an exterior window.
   
5. Potential vibrational damage to the Strong House – The proposed expansion will require construction activity closer to the Strong House than previous work in 1993 and the 1960s.  While the general contractor is required to carry liability insurance, it would be best to avoid damage.

Town’s Mitigation Proposal
The town has proposed to mitigate adverse effects by creating a photographic record of the building prior to demolition and construction and to create a permanent video and photographic display of the history of the building within the historic portion of the building, once the project is completed. This approach has been used as an mitigation strategy in some other Section 106 reviews and especially when the project involved substantial destruction of a historic resource.

But the town must consider the input it receives from the consulting groups and the public in adopting a strategy for addressing the adverse impacts and at least three of the consulting groups, The Amherst Historical Commission, The Amherst Historic Preservation Coalition, and the Downtown Local Historic District Commission, plus all eight members of the public who spoke during the public comment period, found the town’s proposed interventions insufficient and offered critique and alternatives.  

Consulting Parties

The participating consulting parties were:

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

Summary of Input Received
Of the 15 representatives of consulting parties who spoke, 10 limited their presentations to discussing the needs that the expanded library would fulfill, and to stating their support for the project and the mitigation as proposed. 

One speaker argued that modernization of the building needed to be prioritized over historic preservation and saw the listed adverse effects as inconsequential compared to the benefits to be derived from the expansion and argued that creating a photo record was sufficient for mitigating potential loss of historic features.

Four speakers, representing three of the six historic preservation organizations that were present, opposed the proposed mitigation and offered alternatives.

Components of the Meeting
Thirty seven people were in attendance at the start of the meeting and 48 at peak. JLBC chair Austin Sarat  informed the assembled that the town is the “responsible agent” for carrying out the 106 review and that the town has been in contact with the appropriate historic preservation organizations and has hired a consultant to assist in the process. That consultant is Virginia (Ginny) H. Adams, Senior Architectural Historian of the Public Archaeology Laboratory of Pawtucket, Rhode Island. 

Sarat also noted that the Jones Trustees had hired professional facilitators Jake Kuhn and Mara Shulman from the Collaborative Resolutions Group in Greenfield, to facilitate the collection of public input.  The facilitators established ground rules for respectful participation and informed the group that this was not a formal hearing but rather an opportunity for interested parties to provide input to the review.  Kuhn informed the meeting that he is not related to Architect John Kuhn who has been affiliated with the Jones expansion project.

Also present were Maxwell Sickler and Rachael Mangum representatives from the Advisory Council on Historic Preservation (ACHP). ACHP is the agency that wrote the federal regulations on Section 106 review. Sickler noted that he and Magnum were present as observers.

Jones Library Director Sharon Sharry reported that she had reached out to the MHC to make them aware of the meeting but said that she had not heard back from them. As the SHPO for this process, they are regarded as a consulting party to the process and will participate in negotiating the town’s MOA.

The meeting was divided into four sections.

1. Consultant Ginny Adams explained the components of the Section 106 review and reviewed the agenda for the meeting.
   
2. Facilitators Shulman and Kuhn set time limits of 5 minutes for consulting groups to offer input and gave representatives of each consulting party a chance to speak.
   
3. Shulman then led the consulting groups in a facilitated discussion focusing on adverse visual impacts of the project.
   
4. Kuhn then allocated 3 minutes to each member of the public who wished to speak during the public comment period. 

Understanding the 106 Process
Adams explained that the 106 process is conducted in four stages (see diagram below).

1. Invite interested parties and develop plans to receive public input. These plans appear to have been developed by representatives of the town in consultation with Adams in September 2024.
   
2. Identify Historic Properties
   
3. Determine possible adverse effects to the historic property.
   
4. Resolve adverse effects through the development of alternatives or modifications to the plans that will eliminate, minimize or mitigate those effects.
   

Adams pointed out that while the town had previously been denied Historic Preservation Tax Credits for this project because the plans violated five of the Secretary of the Interior’s (SOI) 10 Standards for the Rehabilitation of Historic Properties (see also here and here), those violations do not necessarily apply as regulatory standards in Section 106 reviews which may consider preservation, restoration, and reconstruction as well as rehabilitation.  The SOI’s standards may inform the MOA, but those conducting the review may apply other considerations as well, she said.

In late September, working with Adams, the town determined that the proposed demolition and expansion will have adverse effects. Consulting parties including the SHPO, were notified of these findings in a 12 page memo from the town’s Special Capital Projects Coordinator Bob Peirent on October 1.

A Brief Summary of Comments from Consulting Parties
Shulman reminded the participants that this is a forum for addressing the historic preservation implications of the project and for exploring mitigation ideas.

Comments below are summarized in the order in which they were presented.  Prior to hearing from the consulting parties,  Austin Sarat,  President of the Jones Library Trustees and Chair of the Building Committee,  claimed that avoidance and minimization have been actively pursued by the sponsors and “have been integral to the project for the last ten years.  This includes preserving the central staircase and main fireplace, scaling back the size of the addition from what was originally proposed, and replacing windows with historically appropriate replacements,” he said.

Katherine Whitcombe – Head of Special Collections, Jones Library –voiced enthusiasm for creating a digital exhibit documenting the historic changes to the library and spoke about plans to collect photos and other artifacts for the exhibit.

Sarah Barr – Director of Community Engagement at Amherst College, endorsed the renovation and expansion noting that “we need to make the library safer.” She observed that the library has gone through changes in the past and has retained its historic character during those previous changes and that it should be no different this time around. She commended the balance of the proposed mitigation which “shows respect for the history of the building while improving the building for future generations.”

Madeleine Helmer – Amherst Historical Commission, encouraged the lead agency to require changes to the design, noting that massing and size are not compatible with the historic building.  “Length and height of the building need to be reduced and there must be a setback between the addition and existing building,” she said.  “Mitigation cannot be merely a documentation effort. The impact is substantial and so the intervention must be substantial as well”, she said.

Hetty Startup: Amherst Historical Commission recommended keeping the memorial garden. She stated that the 1993 addition is structurally sound and suggested the town and JLBC consider keeping it rather than demolishing it.  She called attention to the Anna Popp report (see also here) which documented how the needs of the library could be met within its current footprint – suggesting that the addition is unnecessary. She raised a concern about the uncertain status of the Whipple Window. And she objected to cutting a hole in the front façade to create a book drop when less destructive alternatives are possible. She asked to replace if feasible – like with like – “so slate ought to be replaced with real slate. It will last much longer than synthetic slate that is also an option.” And she concurred with Helmer in objecting to the over-sized massing of the addition as an unnecessary and objectionable intrusion into the historic neighborhood.

Jeff Lee, Amherst Historic Preservation Coalition – offered several alternatives for eliminating, minimizing and mitigating adverse effects which he argued do drastic and permanent damage to the historic character of the building and the surrounding districts.  These alternatives include: 1) Avoid the Impaired Visual Setting, visual incongruity of the expansion, and potential vibrational damage to Strong House by eliminating the new addition.  This will also allow the Whipple Window to remain as a functional external window. 2) Avoid the loss of historic millwork and original circulation design by dropping plans to knock down walls in the 1928 building.  Install security cameras in spaces where line-of-sight is deemed a priority, 3) Avoid demolition of exterior walls of the 1928 building by repairing the atrium roof rather than demolishing and rebuilding the1993 addition. 4) The east entrance has a book drop, handrails, ramp and automatic door opener.  Retain it as a public entrance. 5) Replace Buckingham Slate Roof with a commercially available slate shingle such as Vermont Slate. 6) Eliminate cutting of the ashlar stone façade for book drop. Lee lamented, “we believe that protecting the historic character of the Jones Library could have been achieved if adverse impacts had been considered early in the planning process as is called for by state and federal law.  Instead, this review is being conducted after construction documents have been finished and the project already put out to bid.”

Liz Larson, Executive Director of the Amherst Historic Society (AHS) said she supports the project, and praised the new improvements to the library and the work of the library director and trustees.  She said the improved library would “make us better able to celebrate our shared history.”  She noted that the neighboring Strong House Museum, home to the AHS, had done structural engineering studies to safeguard the Strong House and the nearby trees from construction.

Anika Lopes Director of Ancestral Bridges, noted that the library will be the new home of the town’s Civil War tablets and spoke to the importance of preserving African American History and the role of the tablets in telling that history. “This is an opportunity to honor the 300 black Amherst residents who served in the union army during the civil war,” she said.  Lopes emphasized that much of African-American and indigenous history in Amherst has been hidden until quite recently.

Elisa Campbell – representing the Jones Library’s Burnett Gallery.  said the “library serves an important role for displaying of local art and we look forward to having a better and more accessible space.” 

Elizabeth Sharpe – Amherst Local Historic District Commission –prefaced her remarks stating that the other members of the commission were in agreement with what she was going to say. “We do not need to sacrifice cultural resources to meet today’s needs,” she said.  “First, the massing of the addition is out of proportion, dwarfing the Jones and the Strong House. And the destruction of most of the original floor plan is unfortunate and it erases the record of the way the building was originally meant to be enjoyed.” She recommended reducing the length and height of the addition and using an architectural hyphen (often used in pairing an old building with new architecture) to create a better distinction between old and new. She asked that the roof be replaced with real slate as this is a self-defining, eye-level feature, nothing else looks like it, and there is a supply source. (One member of the commission will accept synthetic slate). She asked that the original wooden shutters be reinstalled and that repointing of the mortar be consistent with original and variable mortar colors.  She opposed cutting a hole in the front façade for a book drop, strongly encouraged retaining the director’s office with its historical paneling, and asked that the pineapple leaves in the historic pediment on the front door be restored.  She closed by saying that details matter in historic preservation.

Jane Wald – Executive Director Emily Dickinson Museum noted that she has overseen many historic  preservation projects over last 23 years and advised that “we need to adapt the historic character of the building to modern usage and needs.“ She supported the proposed photo/video documentation as a mitigation strategy and felt that the listed adverse effects, with possibly the exception of the loss of 25% of the historic millwork, were reasonable compromises.  She supported using synthetic slate because she says “it is more sustainable because it reduces the structural load on the building”.  She spoke of compromise, concluding that the loss of historic fabric will allow the library to serve the community better.

Kent Faerber, Chair of the Jones Library Capital Campaign argued that there is no possibility at this point of making any changes to the design. He stated that no money has been raised for making any alterations to the plans. He stated that the 1928 building was not intended to be a museum but a working library and the changes that are proposed are a classic example of historical rehabilitation as defined by the National Park Service. He argued that the project makes important improvements to the building while preserving key features – preserving what is essential about the building’s history – while meeting the town’s current challenges.

Ginny Hamilton – Jones Library Capital Campaign Manager stated that the NEH grant money is specifically for the expansion portion of the project.

Sheila Murphy – Grant Director, The Literacy Project– said that lately the Literacy Project has been serving students through remote classes over Zoom.  “We started 29 years ago but since 2020 we have not had space for our classes and have been conducting our classes online over Zoom. The Jones has offered us classroom space in the expansion project.”

Michael Pill – Board of Directors, Ancestral Bridges  (note: Pill was inadvertently not recognized to speak during the consulting parties’ section but was given five minutes to speak during public comment). Pill reiterated the remarks of Anika Lopes who spoke to opening up the history of Amherst to all of its residents. Pill spoke about the exclusion and omission of the history of black residents and how this needs to be brought out of the shadows and that considerations like this must be given priority “over things like the type of slate that we use or the massing of an addition.” Rather, he wanted to raise up, rather, the long struggle to get the Civil War tablets out of storage and into the community where their story can be shared. 

Facilitated Discussion
Ginny Adams set aside 30 minutes to consider a question about addressing adverse effects, specifically about the adveerse visual impact of the addition and the mitigation strategy of visual documentation. 

Elizabeth Sharpe (Downtown Local Historic District Commission) responded that the addition is massive and overwhelms the existing structure.  Adding an architectural  hyphen is one compromise to a complete redesign and has effectively been used in other historic preservation projects. She noted that the addition to the North Amherst Library is connected to the historic building with a hyphen.

Jeff Lee {Amherst Historic Prervation Coalition] added that the addition will be visible from three different historic districts and will dominate the downtown viewscape. Asked how he might mitigate that effect he answered – don’t build the addition.

Liz Larson (Amherst Historical Society) did not see changes to the viewscape as an adverse effect, even though the town had judged them to be.  She said, “I think that the addition will better integrate the library with the Strong House.”

Library Director Sharon Sharry was unwilling to compromise on the book drop in the front façade saying, “we need a front book drop for the effective operation of the library.”

Hetty Startup {Amherst Historical Commission} said that the new addition on the back will forever change our sense of the important historical period when the Jones was built and when the Amherst Historical Society moved into the Strong House.  All along the way there have been very careful conversations between the buildings and the past and we should not cease those conversations now.

Sharry replied, “ The addition cannot be smaller or we would have made it so. The additional square footage is needed.  The addition meets setback and height requirements.” 

Kent Faerber (Friends of the Jones Library Capital Campaign)  said, “Finegold Alexander architects have reassured us that the design works and we should respect their professional judgment.”

Adams then asked for additional comments on mitigating measures that have been used in other preservation projects. She pointed out that archival documentation is a well-established mitigation strategy used by the National Park Service.

Ginny Hamilton (Friends of the Jones Library Capital Campaign)  asked – “Are there pieces of the Jones that we could put on display elsewhere in town?  Are there other possibilities for bringing the Jones to the public, especially when the jones is shut down?”

Faerber spoke in favor of photo and video documentation.

Lee said that taking photos of rooms that Amherst residents have been able to use for decades seems wholly inadequate.

Faerber said that 65% of those who voted (in a referendum in 2021) supported a project that is essentially identical to this one.  

At this point, Adams asked the consulting parties to focus on the question of addressing adverse effects.

Sarah Barr (Amherst College Community Engagement) reported that Amherst College is ready to partner with the library. “ The Jones library is apparently out of space and we can help with that,” she said.

The discussion continued with several of the participants arguing against the town’s findings of adverse effects rather than offering ways to avoid, minimize or mitigate them.  They instead emphasized that the library needs to be modernized and that needs to be the priority.

Startup disagreed saying that documentation is not a sufficient intervention at this point.  She underscored that the new addition is problematic and does not honor the architectural history or integrity of the historic building.

Public Comment
Eight members of the public, Sarah McKee, Lou Conover, Carol Gray, Rob Kusner,
Maria Kopicki, Arlie Gould, Art Keene and Hilda Greenbaum spoke during public comment, all objecting to the proposed mitigation strategy, and all suggesting that the adverse impacts to the viewscape required a substantial intervention – either a change in design of the addition or not building the addition at all.  Two of those public comments (Kopicki and McKee) can be found elsewhere in this issue.

Public Invited to Comment
The public can contribute comments to the review process until October 30 on the town web page as noted below.