specific nav links
with Section 106 Section
106 in Action Archive
of Prominent Section 106 Cases Michigan: Demolition of Allen
Park Veterans Affairs Medical Center
Demolition of Allen Park
Veterans Affairs Medical Center
of Veterans Affairs
Criteria for ACHP Involvement:
- The proposed action will result in the demolition of a National
Register-eligible historic district in its entirety (Criterion 1).
- The project raises questions regarding the timeliness of Section 106 review and the Department of Veterans Affairs’ interpretation of its responsibilities under Section 106 (Criterion 2).
In November 2001, Secretary Anthony J. Principi of the Department of
Veterans Affairs (VA) responded to ACHPs final comments on
the closure, demolition, and transfer of the Allen Park Veterans Affairs
Medical Center (VAMC) to the Ford Motor Land Development Corporation (Ford).
His correspondence indicates that VA will follow ACHPs recommendation
to carry out the mitigation that VA originally proposed, including recordation.
Allen Park Veterans Affairs Medical Center, MI
(photo courtesy of Dept. of Veterans Affairs)
Regrettably, Secretary Principis letter did not address ACHPs
other recommendations regarding VAs stewardship of historic properties.
ACHP had called upon VA to enter into a dialogue with ACHP
to explore the broader preservation issues highlighted by the Allen Park
case. These include the need to evaluate the status of cultural resource
management planning for VA facilities and the preservation opportunities
offered by VAs Enhanced Use Leasing Program, wherein VA may enter
into leases with public and private entities to develop VA property for
non-VA and/or VA uses.
The Allen Park VAMC was constructed between 1937 and 1939 on land in
Allen Park, near Detroit, which was donated to the Federal Government
by Henry and Clara Ford. The complex is one of 50 VAMCs developed between
1920 and 1946 that have been determined eligible for the National Register
of Historic Places as part of a thematic group. Georgian Revival in design,
the eight-building complex is dominated by the main hospital building,
the original central portion of which is surrounded by large additions
from 1949 and 1961.
In 1986, the VA decided to construct a new VAMC in downtown Detroit.
It is unclear to what extent this constructions foreseeable impact
on historic properties at Allen Park VAMC received adequate environmental
review at that time. It appears that consideration of any such effects
was essentially postponed for later review under Section 106
and was not addressed substantively during compliance with the National
Environmental Policy Act.
In 1986, the long-range plan for the Allen Park VAMC site was reuse as
a new long-term care facility with a primary care component. However,
by the time that the new Detroit VAMC opened 10 years later, funding had
never been allocated for new construction at Allen Park. Significant shifts
had occurred in health care in the interim, bringing a new emphasis on
outpatient care. A scaled-back nursing home was accommodated in the new
downtown facility, leaving only a limited primary care facility at Allen
Park, which used only about one-tenth of the complexs square footage.
The original deed to the Federal Government stipulated that the land
would revert to Ford if it ceased to be used for care of veterans. Given
the underutilization of the property by VA, State and local representatives
entered into discussions with VA and Congressman John D. Dingell regarding
the potential for the land to revert to Ford, which would return it to
the tax rolls. By the spring of 2000, VAs preferred alternative
was to demolish all buildings on the site and transfer the property to
Ford. (The reversion clause does not require specifically that the site
be cleared before transfer, but Ford and VA have agreed to that interpretation
of its intent.)
VA did not initiate Section 106 consultation with the Michigan State
Historic Preservation Office (SHPO) during the discussions regarding the
fate of the complex, and it is not clear that the historic significance
of the property was fully considered in decisionmaking. The facilitys
Cultural Resource Management Officer played a very limited role in the
discussions, and there was no Cultural Resource Management Plan for the
complex, despite a VA policy directive requiring one.
Intervening congressional action then precluded the option of discussing
alternatives to demolition during Section 106 review. The Veterans Benefits
and Health Care Improvement Act of 2000 (P.L. 106-419) included a provision
requiring VA to enter into a contract with Ford to demolish the Allen
Park complex and remediate the sites hazardous materials. The legislation
authorizes VA to pay Ford up to $14 million to cover costs.
In January 2001, VA initiated consultation pursuant to Section 106. Proposed
mitigation for demolition of the complex included recordation of the complex;
archiving of historic records; consultation with the Michigan SHPO on
a commemorative flagpole and memorial called for in the legislation; and
allowing the Allen Park Historical Society to salvage architectural elements.
ACHP elected to join the consultation following a request from
the Michigan SHPO. Since Ford indicated that it did not have clear plans
for the site, the consulting parties questioned whether Ford might delay
total demolition while exploring possible options for preservation during
its planning efforts. In addition, the Michigan SHPO, the National Trust
for Historic Preservation, and State and local preservation organizations
requested establishment of a $2 million historic preservation fund to
benefit other historic properties, patterned on several such funds that
have been established as mitigation for projects in other parts of the
Facing a September 30, 2001, deadline for entering into a demolition
contract with Ford, VA terminated consultation after the consulting parties
failed to reach agreement on mitigation measures. Despite this, promising
discussions continued between the Michigan SHPO, Ford, and local preservation
groups regarding possible off-site mitigation at another historic property
owned by Ford, the Packard Motor Car Company Proving Ground Testing Facility.
Ultimately, however, such talks could not be brought to closure before
VAs deadline, and ACHP issued final comments to VA September
VA controls a significant number of historic resources and must seek
to balance its stewardship against changing residential and health care
needs of veterans. Unfortunately, the agency has a limited number of professional
cultural resource staff to meet this need.
As illustrated in this case, too frequently historic preservation is
not integrated into decisionmaking. Reversing this trend is important,
since aging of the infrastructure and shifts in patient care policies
and expectations will doubtless result in a growing number of cases sharing
the fundamental issues seen at Allen Park.
Staff contact: Druscilla
May 6, 2003
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