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ACHP Comment Letter on Proposed Demolition of Allen Park Veterans Affairs Medical Center, Allen Park, Michigan

The Honorable Anthony J. Principi
Secretary of Veterans Affairs
Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420

Dear Mr. Secretary:

I am writing to convey to you in accordance with Section 106 of the National Historic Preservation Act (NHPA) ACHP's final comments on the proposed closure, demolition, and transfer of the Allen Park Veterans Affairs Medical Center (VAMC). ACHP regrets the pending loss of this important historic resource and community asset. We are also concerned that this case reflects broad systemic challenges and problems that the Department of Veterans Affairs (VA) must face in managing its portfolio of historic facilities. As the newly appointed Chairman of ACHP, I would like to take this opportunity to open a dialogue with you on these issues.

Findings

The Allen Park VAMC is a significant historic resource. The Allen Park VAMC is one of about 50 properties that were constructed as part of a nationwide VA hospital construction program during the 1920s through the mid 1940s. Although based on prototype campus designs and standardized building forms, the design of each complex was unique, reflecting regional architectural styles. In 1980, the Michigan State Historic Preservation Officer (SHPO) determined that the Allen Park VAMC was eligible for the National Register of Historic Places, despite it being less than 50 years old, "as a result of its exceptional importance as one of Michigan's finest and largest examples of Institutional Georgian Revival architecture." The property's eligibility was confirmed by the Keeper of the National Register in 1981.

The historic significance of the Allen Park VAMC apparently was given little consideration during decision making regarding the complex's future. The decision 15 years ago to build a new VAMC in downtown Detroit set the stage for the Allen Park complex's current fate. However, VA did not address that possibility in any detail during environmental review at that time. After the new facility opened in 1996, active discussion and analysis of alternatives commenced regarding the future of the Allen Park complex. These discussions eventually led to a statutory requirement to demolish the complex in conjunction with its reversion to the Ford Motor Land Development Corporation. The documentation of these discussions provided us by VA does not demonstrate any consideration of the facility's historic significance during the three to four years of dialogue and analysis that preceded Congressional action. During this time, neither State nor local preservation groups had an opportunity to weigh in on the importance of the facility as an historic property. Then, once the legislative mandate was in place, consideration of alternatives to demolition was precluded.

Demolition of the entire Allen Park complex represents a significant loss, and one that does not immediately appear necessary based on the structural condition of the buildings or their reuse potential. The Allen Park VAMC has served local veterans since 1939 and, due to the imposing size and architectural stature of its Main Building, has been a prominent visual landmark. Although VA determined the buildings to be inadequate to support modern health care, we understand that they are structurally sound. Frustratingly, the potential for adaptive use is present, but cannot now be further explored. The wholesale demolition of the complex will thus destroy not only an important historic property, but one that might still function as an economic asset to the community.

VA's 1996 policy directive on cultural resource management should have facilitated integrating consideration of historic preservation issues into planning for the Allen Park VAMC, but apparently did not. Section 110(a)(2) of NHPA requires that each Federal agency establish an historic preservation program, and VA Directive 7545 (and its associated handbook), issued in March 1996, sets a solid foundation in this regard. Regrettably, however, it appears to have had little or no impact on decision making for the Allen Park VAMC. The directive requires that each facility have a Cultural Resource Management Plan (CRMP) for integrating cultural resource management into facility planning and programs. Each facility is also to have a Cultural Resource Management Officer (CRMO) with effective access to budgetary, management, and decision making processes. Apparently, however, no plan for managing cultural resources was developed for the Allen Park VAMC, and the facility's CRMO played a very limited role during VA's consideration of alternatives for the complex. Thus, the process envisioned in the policy directive for integrating consideration of the facility's historic significance into master planning did not function as intended.

The closure of the Allen Park VAMC reflects significant changes nationwide in VA's delivery of health care and, as such, can serve as a cautionary tale for addressing historic preservation issues in the realignment of other VA capital assets. When construction of a new downtown Detroit facility was approved, it was envisioned that the Allen Park site could be used for a long term care facility. However, by the time that the new VAMC opened 10 years later, funding had never been allocated for new construction at Allen Park, and VA's focus had shifted from inpatient to outpatient care. This is a reflection of how, in the past decade, new technology and treatments have changed how and where VA health care is provided, with a significant shift from inpatient to outpatient services. In response to this nationwide trend, VA is taking steps to assess veteran health care needs and realign its capital assets. Initiatives such as the new Capital Asset Realignment for Enhanced Services (CARES) Program have the potential to lead to the closure, realignment, or change in mission of many of VA's historic facilities. If the historic importance of these properties is to be adequately considered in planning for their future, VA's internal cultural resources management system needs to function efficiently, and there needs to be effective outreach and coordination with the preservation community.

Recommendations

Based on these findings, ACHP hereby recommends that VA should:

Implement the mitigation measures VA proposed in a draft Memorandum of Agreement discussed at the July 19, 2001, meeting of the consulting parties. While this mitigation is not commensurate with the scope of the adverse effects that will occur, it will, among other things, ensure that an adequate record of the complex is made prior to its demolition, as required by Section 110(b) of NHPA. The VA should ensure that these measures are carried out.

Address the broader implications of the Allen Park VAMC closure by entering into discussions with ACHP and other preservation stakeholders regarding VA's historic preservation program and the challenges and opportunities faced by VA in the management of its historic resources. We believe strongly that VA's program would benefit from dialogue and cooperation between VA and ACHP.

• VA should coordinate with ACHP to take stock of the status of CRMPs and to disseminate information on historic facilities and their CRMOs to SHPOs, tribal representatives, and local concerned parties. At Allen Park, consideration of historic preservation issues presumably would have been enhanced if VA policy on preservation planning and personnel had been fully implemented.
• We ask that VA coordinate with ACHP to seek ways of maximizing use of VA's Enhanced Use Leasing Program to promote reuse of historic properties. Use of this program was not viable in the Allen Park case because of the property's reversion clause. However, VA's ability to enter into leases with public or private entities to develop VA property for non-VA and/or VA uses may be its single most important tool for addressing historic preservation as part of capital asset realignment.
• We strongly urge VA to coordinate with ACHP to discuss VA's Section 106 responsibilities for the large number of VA hospitals constructed in the late 1940s to 1950s. VA has done an admirable job of evaluating the significance of its properties that date from World War II and earlier, including Allen Park. However, many post-war facilities have recently reached or are approaching 50 years of age, the usual threshold for possible eligibility to the National Register of Historic Places. Thus, this large number of facilities already now are, or soon will be, subject to the requirements of Section 106.

In accordance with Section 106, ACHP provides these comments for your consideration as you take into account the impacts of this project. We look forward to receiving your documented decision regarding the project, pursuant to by Section 110(l) of the National Historic Preservation Act and Section 800.7(c)(4) of ACHP's regulations.

My staff will contact your office to arrange a meeting. VA's historic properties are assets that are important in the fulfillment of VA's mission and the economic vitality of communities. I look forward to discussing with you how VA and ACHP can work together to facilitate VA's management of these resources as VA charts a course for the future.

Sincerely,

John L. Nau III
Chairman

Enclosure

Updated May 1, 2002

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