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'>jniv6RS,t*HEARING

BEFORE TH E

SS 1

T h

KANSA

SI 5 1ITTEE ON BUILDINGS AND GROUNDS

OF TH E

[MITTEE ON PUBLIC WORKS 

UNITED STATES SENATE

NIN ETY-F OURTH CONGRESS

FIR ST SESSION

ON

S . 86 5

A BILL TO PROMOTE MORE EFFIC IEN T USE OF THE 

NATION’S CONSTRUCTION RESOURCES, TO FOSTER THE 

PRESERVATION OF BUILDINGS OF HISTORIC OR ARCHITECTURAL SIGNIFICANCE, AND TO ENHANCE THE SOCIAL 

AND ECONOMIC ENVIRONMENT W ITHIN AND SURROUNDING FEDERAL OFF ICE BUILDINGS

MAY 19, 1975

SERIAL NO. S-H 17

Printe d for the use of the Committee on Public Works

64-188 0

U.S. GOVERNMENT PRIN TING OFFICE 

WASHINGTON : 1975
•t*

COMMITTEE ON PUBLIC WORKS

JEN NIN GS RANDOLPH, West Virginia, Chairman

*

EDMUND S. MUSKIE, Maine 

JO SE PH M. MONTOYA, New Mexico 

MIKE GRAVEL, Alaska

LLOYD M. BENTSEN , Texas 

QUE NTIN N. BURDICK, North Dakota 

JOH N C. CULVER, Iowa

ROBERT MORGAN, North Carolina 

GARY HART, Colorado

HOWARD H. BAKER , Ja „ Tennessee 

JAMES L. BUCKLEY, New York 

ROBERT T. STAFFORD, Verm ont 

JAMES A. MCCLURE, Idaho 

PETE V. DOMENICI, New Mexico

M. Barry Meyer, Chief Counsel and Chief Clerk

Bailey Guard, Minority Staff Director

Leon G. Bill ing s and Richard D. Grundy, Senior Pro fessional St aff Members

Richard A. Hellman, Minority Counsel

J ohn W. Yaoo, Jr ., As sistan t Chief Clerk; P h il ip T. Cummin gs, Assista nt Chief Counsel

Harold H. Brayman, Senio r Professional Staff Member (m ino rity) Pro fessional and research staf f: Karl R. Braith wa ite, J ames W. Case (A ssist an t Counsel), P aul Chim es, Trenton Crow, Katherin e Y. Cudlip p, P aul F. Ebeltoft, Jr., George F. F enton, Jr., Randolph G. F lood, Kathaleen R. E. Forcum, Ann Garrakrant, Richard T. Greer, Richard M. Harris (A ssist an t Counsel), Wesley F. Hayden, Richard E. Herod (A ssista nt Counsel, Mino rity), Veronica A. Holland, Ronald L. Katz, J ohn D. Kwa pisz, Mich ael McFarland, Larry D. Meyers, J udy F. Parente, J ohn B. P urinton, Jr., Margaret E. Shannon, Charlene A. Sturbitt s, E. Stevens Swa in, J r., Sally W. Walker

SUBCOMMITTEE ON BUILD INGS AND GROUNDS 

ROB ERT MORGAN, Chairman

MIKE GRAVEL, Alaska JAMES L. BUCKLEY, New York

JOHN C. CULVER, Iowa JAMES A. McCLURE, Idaho

(II)
C O N T E N T S

a _______

Page

Buckley, Hon. James L., U.S. Senator from the State of New York, opening 

state ment of__________________________________________________ 1

LIST OF WITN ESSES

Barn ett, Jon athan, director, graduate program in urba n design, the City

College of New York___________________________________________ 50

Prepared statem ent___________________________________________ 69

Burley, Robert, the American Institut e of Architec ts__________________ 42

Prepared statem ent___________________________________________ 42

Hanks, Nancy, Chairman, Natio nal Endowment for the Arts, accompanied 

by Bill Lacy, Director of Architecture and Environmental Arts for the 

National Endowment for the Arts and Executive Director of th e Federal

Architectu re Task Force________________________________________ 10

Prepared statem ent___________________________________________ 12

Knott, Lawson B., Jr., executive vice presiden t of the Natio nal Trust for 

Historic Pre servation , accompanied by Joseph Moody, director, Legal and

Legislative Services------------------------------------------------------------------- 33

Prepared statem ent___________________________________________ 37

Lawrence, Peter G., program director, New Life for Old Buildings_______ 46

Prepared statem ent___________________________________________ 84

Meisen, W alte r A., Acting Commissioner, Public Buildings Service, General

Services Adm inistratio n_________________________________________ 86

Prepared statem ent___________________________________________ 86

Newman, Anthony J., executive director, New York Landmarks Conservancy _____________________________________________________ 48

Shipley, Nancy K., Vice Chairman, Advisory Council on Historic Preserv ation ---------------------------------------------------------------------------------------- 22

Wiedersum Fred eric G., Wiedersum Associates_______________________ 51

Prepared statement___________________________________________ 74

** ADDITIONAL MATERIAL

Appendix : Responses to Senator Buckley’s request for comments on S. 865:

AIA Research Corp___________________________________________ 116

Architectu re Plu s____________________________________________ 117

• Architectural Record_________________________________________ 118

Bank of America_____________________________________________ 120

California, University of______________________________________ 123

Carr, the Oliver T. Co________________________________________ 124

Chloethiel Woodward Smith & Associated Architects______________ 126

Canada. Public Works of_____________________________________ 128

Center for Visual Environment_________________________________ 131

Downtown Brooklyn Development Association____________________ 134

Downtown Progress__________________________________________ 136

Dubin, Mindell, Bloome Associates_____________________________ 138

First National Bank in St. Louis_______________________________ 141

Gutheim, Fre derick___________________ 142

Mitchell/Giurgola Associates____________________ ______________ 143

Illinois, University o f__________________ i_____________________ 146

Johnson/Burgee Architects____________________________________ 148

Landmarks Association of Central New York_____________________ 149

Landmarks Preservation Service_______________________________ 150

<ni)
IV

Appendix: Responses to Senator Buckley’s request for comment on S.

865—Continued

Page Massachusetts, the Commonwealth of___________________________ 153

National Urban League, Inc___________________________________ 154

National Tru st for Historic Preserva tion________________________ 155

National Varsity Club________________________________________ 156

New York Landmarks Conservancy_____________________________ 157

Anderson/No tter Associates, Inc_______________________________ 100

Pei, I. M., & Partn ers ________________________________________ 102

Progressive Arch itecture______________________________________ 165

Seattle, city of______________________________________________ 107

Department of Community Development____________________ 168

State University Construction Fun d____________________________ 171

Washington, State of________________________________________ 174

Adaptive-use projects, examples of_________________________________ 30

Advisory Council on Historic Preservation, proposed amendments_______ 25

General Services Administration:

Recommended changes to S. 865________________________________ 99

Responses to additional written questions________________________ 101

S. 865, reprint of________________________________________________ 3

Sta tem ents:

Lawrence, Peter G., program director, New Life for Old Buildings___ 84

Council on Environmental Quality______________________________ 110

ft

t

»-
PUBLIC BUILDINGS COOPERATIVE USE ACT OF 1975

MONDAY, MAY 19, 1975

f U.S . Senate,

Committee on P ublic Works, 

Subcommittee on Buildings and Grounds,

W as ki ng to nD .G .

Th e subcomm ittee met at 10 a.m., pu rsua nt to call, in room 4200, 

Dirksen Senat e Office Bu ild ing . Hon. Jame s L. Buc kley pre sid ing ,

Pre se nt: S enato rs Buc kley and Gra vel.

OPENING STAT EMENT OF HON. JAMES L. BUCKLEY, U.S. SENATOR 

FROM TH E STATE OF NEW YORK

Se nator Buckley. Will th e he aring come to order.

As we h ave a ra th er larg e witness list , I suggest that we begin with 

a p anel of Miss Nancy Ha nks, Ch air ma n of the N ational Endow ment 

for the Ar ts, and Mrs. Nancy Shipley, V ice C hairm an o f th e Advisory 

Council on Histo ric Prese rvation.

Th e legislation before us toda y >;eeks to make the Fe de ral Gover nment a b etter n eighbor in the cities of our Na tion . It is legi slation t ha t 

seeks to conserve energy and na tu ra l resources, while pro ducin g new 

jobs.

I believe we can achieve these goals by ad ding flexibility t o t he wa y 

the Fe deral Gov ernment acquire s and uses its office bui ldings. Specifically, our bill authorizes two new op tions. It would en courage renovat ion —“recy clin g” mi gh t be be tte r word—of existing b uildin gs into 

new F ed eral offices, where t hat is a pp ropriat e.

Th is appro ach, I believe, w ould help us rec aptur e some of the beauty 

of our h eritag e, ma kin g o ur cities more livable by foste rin g contin uit y 

and prog ress.

Th is app roa ch would save ene rgy, using the designs of old er 

building s th at are less extra va ge nt in energy use than most presen t 

buildin gs. And it would usu ally prove che aper than replacem ent construct ion . Fi na lly , it is oft en work th at can be acco mplished more 

expeditiou sly than wholesale dem olition and replacem ent.

It is not my inte nt to argue the m erits or deme rits of a tax str uc ture 

th at seems to enco urage the destruction of the old, wi th its rep lac ement by eit he r a new build ing or a pa rk in g lot. Rathe r, I believe the 

Fe deral G ove rnm ent m ust set an ex amp le, an example th at oth er units 

of gov ern me nt may follow and seek to encourage.

Th is is not an effort to select an occasional historic bu ild ing a nd the n 

reno vate it. I would antic ipa te th at the Federal Gover nm ent would 

find op po rtu nitie s for ren ovation in man y older, rundow n office 

(1)
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buildin gs, warehouses, railway station s, theater s, and so on, and t urn 

them into p rod uctive office space.

I am convinced t hat this app roa ch would encourage the sp end ing of 

the taxpa ye rs’ money in a wise and fru ga l way. But I might add , any 

effo rt to utilize old er building s would also have the salutary effect of 

slow ing the push tow ard th e consolidation of all Fe deral offices in one 

tow eri ng monolith per city.

We must question wh eth er the public is best served by locating th e 

local Secret Service office across th e hall from the local Fo rest Service 

office, or whether th ei r plac ement in smaller buil din gs around the city 

isn't a w iser course.

Ou r bill would also a llow, for the firs t tim e, th e co operative, priva tepub lic use of space in Fe de ral office bu ildings . Th is bill seeks to bring 

th e public back into our pub lic buildin gs. I t seeks to breat he new life 

into F edera l buildings.

I am convinced th at we must open up ou r F ed eral building s, enco urag ing public use of wh at the y have paid for. The recent sta ff repo rt to 

the Fe deral arc hitec tur al tas k force sought to encourage a more lively 

pedestrian sett ing in and aro und these building s.

Section 4 of the bill, b y amend ing section 210 of the Fe deral Pro perty and Ad ministrat ive Services Act of 1949, would gr an t GS A au ­

thor ity to lease gro und floorspace of Federal office buildings fo r commercial, cultu ral , edu cational, or rec rea tional uses.

W he the r with sign s or designs, we plac e “No Tresp assin g” at the 

entran ces to most F ed eral office buildings . It is sad to note th at no one 

visits a Federal office build ing except on business. Tha t must be 

changed .

An a rticle in th e Ch ris tia n Sciei^e Mo nitor expressed it w el l:

The Public Buildings Cooperative Use Act may seem somewhat peripheral to 

many Americans during these perilous days, but it embodies the essence of the 

relationship between people and government. Bj’ engaging a wider spectrum of 

activity, not for just eight hours a day but into our evenings too, and by making 

good use of the buildings we already have, this bill would have a beau tiful b earing on the way our downtowns look from now on, and on the way we think about 

and use the resources of government.

Such coopera tive use of gro und floorspace would, of course, serve 

th e employees of the bui lding. It would serve t he visting public. Most 

significantly , I believe, the y would br ing new life , new act ivity, and 

new vitalit y to the blocks aro und th at F ed eral office build ing.

I am pleased to say th at t his bill has the c osponso rship of both t he 

chairma n and the rank in g minority mem ber of the full committee, 

and the chairma n of the Bu ild ing s Subcommittee.

[The bill, S. 865, fo llows:]
3

94tii CONGRESS 

1st Session S. 865

1

i IN TH E SE NA TE OF TIIE UN ITED STA TES

F ebruary 27 (legislative day, February 21), 1975

Mr. Buckley (for himself, Mr. Baker, Mr. Morgan, and Mr. Randolph) introduced the following b ill ; which was read twice and, by unanimous consent, 

referred to the Committee on Public Works

BILL

To promote more efficient use of the Nation’s construction resources, to foster the preservation of buildings of historic or 

architectural significance, and to enhance the social and economic environment within and surrounding Federal office 

buildings.

1 Be it enacted b<J the Senate and House of Jleprcsenta2 lives of the Un ited Sta tes o f Am erica in Congress assembled,

3 Tha t this Act may he cited as the “Public Buildings C'oopera4 tive Use Act of 1975”.

5 Sec. 2. (a) In order to carry out his duties under this

6 Act and under any other authority with respect to operating,

7 maintaining, altering, and otherwise managing or acquiring

8 space to meet the office needs of the Federal Government

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and to accomplish the purposes of this Act, the Administrator shall—

(1) acquire and utilize space in suitable buildings 

of historic or architectural significance, unless use of such 

space would not prove feasible and prudent compared 

with available alternatives;

(2) give preference, after first complying with 

paragrap h (1) of this subsection, to the purchase and 

use of space in other existing buildings unless use of such 

space would not prove feasible and prudent compared 

with available alternatives;

(3) encourage the location of commercial, cultural, 

educational, and recreational facilities and activities 

within or near public buildings;

(4) provide and maintain space, facilities, and activities, to the extent practicable, that encourages public 

access to and stimulate public pedestrian traffic around, 

into, and through public buildings, complementing and 

supplementing commercial, cultural, educational, and recreational resources in the neighborhood of public buildings; and

(5) encourage the public use of public buildings, 

including commercial, cultural, educational, and recreational use of such buildings outside of regular Federal 

working hours.

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(3) l»v redesignating section 12(c) and section

12(d) as section 12(d) and section 12 (e ), inserting 

the following new section 12 (c) :

“ (c) Whenever the Administrator undertakes a survey 

of the public buildings needs of the Federal Government 

within a geographical area, he shall contract with the Chairman of the National Trust for Histo ric Preservation to 

identify any existing buildings within such geographical areas 

which are of architectural or historical interest and which 

would be suitable, whether or not in need of repair, alteration, 

or addition, for acquisition or purchase to meet the public 

buildings needs of the Federal Governmen t.” .

Sec. 4. (a) The Federal Property and Administrative 

Services Act of 1949 is amended—

(1) by striking the word “and” at the end of 

section 21 0( a) (1 4) , and adding the following paragraphs following section 21 0( a) (15) :

“ (16) to enter into leases of space on the ground 

floor of any public building with persons, firms, or 

organizations engaged in commercial, cultural, educational, or recreational activities. The Administrator shall 

establish a rental rate for such leased space equivalent to 

the prevailing commercial rate for comparable space 

devoted to a similar purpose in the vicinity of the public 

building. Such leases may be negotiated without com-
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petitivc bids, but shall contain such terms and conditions 

as the Administrator deems necessary to protect the 

public interest;

“ (17) to make available, on occasion, or to lease 

at such rates and on such other terms and conditions as 

the Administrator deems to be in the public interest, 

auditoriums, meeting rooms, courtyards, rooftops, and 

lobbies of public buildings to persons, firms, or organizations engaged in commercial, cultural, educational, or 

recreational activities that will not disrupt the operation 

of the building;

“ (18) to deposit into the fund established by subsection (f) of this section all sums received under leases 

or rentals executed pursu ant to paragrap hs (16) and 

(17) of this subsection;

“ (1 9) to pay sums in lieu of real property taxes to 

States and units of local go vernment on any space leased 

pursuant to paragra ph (16) or (17) of this subsection, 

to persons, firms, or organizations otherwise subject to 

taxation; and

“ (2 0) to furnish utilities, maintenance, repair, and 

other services to persons, firms, or organizations leasing 

space pursu ant to paragrap hs (16) and (17) of this 

subsection. Such services may be provided during and 

outside of regular working hours of Federal agencies.” .
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(b) The Federal Property and Administrative Services 

Act of 1949 is amended by adding at the end of section 210 

(e) the following: “The Administrator shall, where practicable, give priority in the assignment of ground floor space 

not leased under the terms of subsection (a) (16) or (a) 

(17) of this section in such buildings to Fede ral activities 

requiring regular contact with members of the public. To 

the extent ground floor space is unavailable, the Administrator shall provide space with maximum case of access to 

building entrances.” .

Sec. 5. As used in this Act—

(1) The term “Administrator” means the Administrator of General Services.

(2) The terms “public building” and “ Federal agency” 

bear the same meaning as the Public Buildings Act of 1959.

(3) The term “ unit of local gove rnment” means any 

city, county, town, parish, village, or other general purpose 

political subdivision of a State.

(4) The term “historical or architectural significance” 

includes, but is not limited to, buildings listed or eligible to 

be listed on the National Register.

(5) The term “commercial activities” includes, but is 

not limited to, restaurants, food stores, craft stores, dry goods 

stores, financial institutions, and display facilities.

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1 ((») The term “cultural activities” includes, but is not

2 limited to, film, dramatic, dance and musical presentations,

3 fine art exhibits, studios, and public meeting places, whether

4 or not used by persons, firms, or organizations intending to

5 make a profit.

G (7) The term “educational activities” includes, but is not

7 limited to, libraries, schools, laboratories, and lecture and

8 demonstration facilities.

9 (8) The term “recreational activities” includes, but is 

10 not limited to, gymnasiums and day care centers.
10

Senator Buckley. Tha t concludes my opening statement. Would 

the witnesses like to proceed?

STATEMENTS OF NANCY HANKS. CHAIRMAN. NATIONAL ENDOWMENT FOR THE ARTS, ACCOMPANIED BY BILL LACY, DIRECTOR

OF ARCHITECTURE AND ENVIRONMENTAL ARTS FOR THE NATIONAL ENDOWMENT FOR THE ARTS AND EXECUTIVE DIRECTOR

OF THE FEDERAL ARCHITECTURE TASK FORCE; LOIS CRAIG,

STAFF DIRECTOR OF THE FEDERAL ARCHITECTURE PROJECT,

AND NANCY SHIPLEY, VICE CHAIRMAN. ADVISORY COUNCIL

ON HISTORIC PRESERVATION; AND ROBERT R. GARVEY, JR.,

EXECUTIVE DIRECTOR OF THE COUNCIL

Miss Hanks. Senator Buckley, I believe you said you would prefer 

our answering questions rather than making statements. We have submitted, or at least I have submitted, a statement for the record. I 

would like, if I might, to make two or three very brief comments 

in connection with the legislation th at we are hearing today.

Senator Buckley. Your statement will be printed in the record.

Miss Hanks. Thank you very much.

[The statement appears at p. 12.]

Miss Hanks. The National Endowment for the Arts and also the 

architecture task force, on which Senator Baker and Congressman 

Thompson incidentally sat, would strongly support this legislation.

I think, sir, not only are those very important points that you raise 

in your own remarks about the economic factors, about the livability 

of our cities, and about putting our Government more in touch with 

our people, I would like to say it is not only the details of the legislation that you are presenting today but, sir, it is also an attitude th at 

is very important—of government toward its people and toward its 

environment in a city.

I would like to make two points. In connection with multiple use, 

that would make our government buildings more a part of the lives 

not only of the government workers but of the people in the cities. In 

connection with adaptive use, it would make the government join with 

private citizens all over this country who want to preserve their cities.

It is a positive attitude by the Federal Government toward the people, toward the cities. I strongly commend you and your associates 

for this piece of legislation.

We have only actually three comments to make, if I might, on the 

legislation itself, other than very strong applause. We would like the 

committee to consider in connection with the adaptive use section of 

the bill, the possibility tha t the GSA Administrator be authorized to 

lease space in old buildings as well as just to purchase them.

Second, we believe tha t it would be helpful if there were more specifically articulated guidelines and limitations on the policy of consolidating Federal offices, a point you strongly make in your opening 

statement. We think the legislation could help very much in tha t 

regard.
11

In connection with the multiple-u se provisions, we wou ld like the 

committee, if possible, to se riou sly consider rem oving the lim ita tio n on 

gro und floorspace.

We believe there might be instances, indeed ma ny, in which the 

mezzanine or second floors, pe rhap s roo ftops of the building s, migh t 

be used for m ultiple use.

Tho se are t hree technical changes we would like to see in th e legislation. Other th an th at , sir, and wi th my wr itten testim ony, I th an k 

you very much.

Se nator B uckley. Thank you, Miss Hanks.

Do you have any specific thou gh ts on where to draw the line ? W ould 

you recommend language th at expli citly allow s leasing of the mezzanine or roo fto p area ?

Miss H anks. No. I would just open it up. I would thi nk th e marke tplace in effect would say wh at space was needed. Ev ery town and city 

will be differen t. I think , there fore, if you just open it up, GS A's 

neg otiatio ns in th e cities a nd Stat es would work it o ut.

Se nator B uckley. Some people ha ve suggested that GS A s hould n ot 

be required to lim it bids to com petitive bid ding. Do you have any 

thou gh ts on that?

Miss H anks. No. Bill Lacy, who is d ire cto r o f o ur arch ite ctu re progra m and is here with me tod ay, migh t answer the question bette r 

than I.

I would have no comm ent on com petitive bid din g. I don ’t know’ if 

you wish to have any oth er staff comments at the pre sen t time.

Se nator B uckley. Mr. Lacy, w ould you come up and join the group ?

Miss H anks. Mr. Lacy is D ire cto r of the Ar chite ctu re and E nv iro nmental Arts for the National Endowm ent fo r the Arts and executive 

dir ector of the Federal task force on a rch itectu re.

Mr. Lacy. Mr. Ch airma n, I can’t shed a great deal of lig ht on the 

question. We are really more int ere ste d in the int ent of the bill than 

the specific w ay in w hich it would be a dministered .

My feeling on the matt er is th at we should follow’ pro cedures al ­

ready operative in the ma rke tplace wh eth er th at deals with the compet itiv e or noncompetitive. I think th at is pro perly t he jur isd iction of 

the G SA Ad minist rator in worki ng out the specific detai ls of how this 

bill should be a dminis tere d.

In the same tone, I agre e with Miss Ha nks, th at we should not fix 

rig idl y the requirements for openi ng up Federal build ing s to nonFederal uses; but, rather, test the idea and see how it is most easily 

accommo dated in existing real estate accepted pro ced ures th at now’ 

exist.

Se nator Buckley. Than k you very much.

[Miss Ha nk s’ statem ent foll ows:]
12

Sta te m en t o f

Nancy Hanks

Cha irm an , N a ti o n a l Endowment fo r th e A rt s

I

on

S. 86 5, th e P u b li c B u il d in g s 

C oopera ti ve Use Ac t of 1975

b e fo re th e

Su bc om mittee on B u il d in g s and Grounds 

Co mm ittee on P u b li c Works o f th e U. S. Sen at e

May 19 , 1975
13

Mr. Cha t-m an , i t i s a s p e c ia l p le a su re fo r me to be h e re to t e s t i f y 

on S. 86 5, th e "P u b li c P u il d in g s C oopera ti ve Use Ac t o f 1975." In doin g 

so , I am w ea ri ng two h.,c-i to d ay , one as Ch air man o f th e N a ti o n a l Endowment fo r th e A rt s an d a n o th e r as th e p ers on char ged by th e P re sid e n t 

w it h r e s p o n s ib ility fo r th e F e d e ra l D es ig n Improvem ent Pr og ram.

As yo u know, in 19 72 , th e P re sid e n t as ked th e N a ti o n a l Endowment 

fo r th e A rt s to ta ke-. char ge o f a pr og ram to im pr ov e th e F e d e ra l Go ve rnm e n t' s d esig n a c t i v i t i e s . One fa c e t of th a t pr og ram was to be a r e v is io n 

and expan si on of th e G uid in g P r in c ip le s fo r F e d e ra l A rc h ite c tu r e , is su e d 

in 19 62 . To c a rry o u t t h i s a sp e c t of th e d e sig n pro gr am , we appoin te d 

a t th e P r e s id e n t's re q u e s t a ta s k fo rc e com posed of em in en t p r iv a te de ­

sig n p ro fe s s io n a ls and two conce rn ed members of C ongre ss , on e o f whom 

was S en ato r Bak er , th e o th e r wa s R e p re se n ta ti v e Fra nk Thompson. We a ls o 

as se m bl ed a gr ou p o f a r c h i te c ts fro m 20 F e d e ra l a g en c ie s w it h m aj or co ns tr u c tio n r e s p o n s i b i li t ie s to draw on t h e i r s p e c ia l kn ow ledg e a s we co nd u cte d our re se a rc h . I w i l l d is c u s s th e e x c e ll e n t wo rk of th e F ed era l 

A rc h it e c tu re Ta sk Forc e in a l i t t l e w h il e; b u t I wo uld lik e to sa y now 

th a t th e in te r-a g e n c y gr ou p has pro ve n to be an in v a lu a b le so u rc e of 

in fo rm a ti o n , id e a s , and en th u sia sm . The se F e d e ra l d e sig n e rs a re p ro ­

f e s s io n a ls in th e b e s t sen se of th e wo rd: They a re e x p e rt an d im ag in at iv e and th ey p la c e th e p u b li c i n te r e s t in th e f o r e f r o n t of t h e ir 

th in k in g . The ag en cy r e p r e s e n ta tiv e s t e l l us th a t we in tu rn per fo rm 

a v a lu a b le s e rv ic e to the m and t h e i r a g en c ie s by p ro v id in g a forum fo r 

th e ex ch an ge o f in fo rm a ti o n and th e c ro ssb re e d in g o f id e a s .

S ta f f su p p o rt to th e F e d e ra l A rc h it e c tu re Ta sk Forc e and i n t e r ­

ag en cy gr ou p i s pro vid ed by th e F e d e ra l A rc h ite c tu re P r o je c t. With me 

h e re t h i s mor ning a re Mr. B ill Lac y, D ir e c to r of th e A rc h it e c tu re + Env ir o n m e n ta l A rt s Prog ram o f th e N a ti o n a l Endowment fo r th e A rts and 

E x ecu ti v e D ir e c to r o f th e F e d e ra l A rc h it e c tu re P r o je c t, and M rs. L ois 

C ra ig , S ta f f D ir e c to r of th e P r o je c t.

The F e d e ra l A rc h it e c tu re Tas k F o rc e, l ik e th e gr ou p co nv en ed te n 

y e a rs b e fo re th a t pr od uc ed th e G uid in g P r in c ip le s , made no a tt e m p t to 

d e fin e an a p p ro p ria te s t y l e fo r F e d e ra l a r c h ite c tu r e . We ha ve lo ng 

s in c e p ass ed th e tim e when i t was th ought n e c e ssa ry fo r ever y p u b li c 

b u ild in g to r e c a l l th e g lo r ie s of a n c ie n t Gre ec e and Rome, a lt h o u g h we 

r i g h tl y c h e ris h th e a r c h i te c tu r a l le g acy th o se ti m es ha ve beq uea th ed u s. 

In s te a d , th e Ta sk Forc e bro ad en ed th e fo cus of i t s work be yond th e 

b u ild in g i t s e l f to in c lu d e th e p ro c e sse s th a t pro duce th e b u ild in g and 

i t s im pa ct on u s e r s , v i s i t o r s , and i t s p h y sic a l and so ci oec onom ic 

en v ir o n m en t.

In A p ril 19 74 , th e Tas k Forc e Is su ed an in te rim r e p o r t, e n ti t le d 

F e d e ra l A rc h ite c tu re : A Fra me wo rk fo r D ebate , c o n ta in in g i t s fin d in g s 

and a s e r ie s of re co m m en da tio ns f o r im pr ov in g F e d e ra l a r c h ite c tu r e .

Sin ce th a t ti m e, a t th e d ir e c tio n of th e Ta sk F orc e, th e s t a f f of th e 

F e d e ra l A rc h it e c tu re P ro je c t has p re p are d su pple m enta ry r e p o rts on two 

o f th e mos t im p o rt an t re co m m en dat io ns, reco m m en da tio ns which S. 865 

would im pl em en t: c o o p e ra ti v e — o r m u lt ip le — u se , an d re c y c li n g of 

b u ild in g s — o r a d a p ti v e u se . I wo uld lik e to su bm it th o se two r e p o rts

54-188 0 - 75 — 2
14

e n ti t le d F e d e ra l A rc h it e c tu re : M ult ip le -U se F a c i l i t i e s and F ed era l 

A rc h it e c tu re : A dap tive- U se F a c i l i t i e s fo r th e re c o rd . Along w it h 

S enato r B u ck le y 's su c c in c t flo o r sta te m en t ac co mpa ny ing h is in tr o d u c ­

tio n of S. 86 5, th ey s t a te th e case fo r c o o p e ra ti v e us e and re c y c li n g 

as f o r c e f u lly as p o ss ib le and d e sc ri b e our re aso n s fo r str o n g ly su pp o rti n g th e b i l l .

»

I would lik e to h ig h li g h t only a few p o in ts made in th o se do cu ­

men ts and to add some comments on th e p r a c t ic a l im p li c a ti o n s of t h i s 

b i l l . As to some of i t s te c h n ic a l a s p e c ts , I d e fe r to th e e x p e rts a t 

th e G en er al S e rv ic e s A d m in is tr a ti o n , th e A dvis ory C ounci l on H is to ric 

P re se rv a ti o n , th e N ati o n al T ru st fo r H is to ric P re s e rv a tio n , and th e *

o th e rs te s ti f y i n g to day.

S enato r Buc kley n ote d th a t th e b a s ic pr ob lem in F ed era l a r c h ite c ­

tu re was summed up by P ro fe sso r J . B. Ja ckso n o f Har va rd in a quote 

used to in tr o d u c e th e m u lt ip le use r e p o rt: "No one in h is r ig h t mind 

now go es in to a p u b li c b u il d in g ex cep t on b u s in e s s ." The pr ob lem is 

one of both v is u a l ima ge and p h y sic a l a c c e s s.

W ri ti ng l a s t y ear about new b u il d in g s on th e M al l and th e FBI 

b u il d in g , R u sse ll Ba ker o f th e New York Tim es com me nted, "Man is out 

of p la c e in th e se p o n d e ro s iti e s . They a re desi gned to make man f e e l 

n e g l i g i b l e . . . . " The p o in t i s , ou r "p u b li c " b u il d in g s a re lik e s ig n s , 

a d v e rtis in g th e kin d of people and go ve rnmen t we a r e . In t h is c a s e , 

th ey a re f a ls e a d v e r tis in g : Our go ve rnmen t i s n o t d is ta n t and a lo o f; 

i t i s an open go ve rn m en t, s e n s itiv e to th e nee ds and d e s ire s of i t s 

p eo p le . But our b u ild in g s , th o se per m an en t, a tte n tio n - g e ttin g symbo ls 

of th e F e d e ra l p re se n c e , do not al w ay s show t h a t .

Some p eople sa y th a t as im p en etr ab le a s some of ou r b u il d in g s 

ap p ear, most o f th e p u b li c has l i t t l e ne ed to v i s i t in s id e the m. Unf o r tu n a te ly , ev en wh ere our ag en cie s co nduct a c t i v i t i e s th a t re q u ir e 

fre q u e n t c o n ta c t w it h th e g e n era l p u b lic , th ey a re o fte n so in co nven ­

ie n tly lo c a te d th a t i t i s har d to b e li e v e th a t th e p u b li c i s we lco me . I 

ha ve be en to ld , fo r in s ta n c e , th a t th e Go vernm ent P rin tin g O ff ic e books to r e s in F e d e ra l b u il d in g s in Bo sto n and C in c in n a ti a re lo ca te d in 

su b-b as em en ts and th a t ev en th e b u il d in g guar ds ha ve tr o u b le g iv in g 

d ir e c tio n s to v i s i t o r s seek in g the m. And I was s t a r tl e d to re ad in th e 

A p ril is su e o f th e E a ste rn A irlin e s i n f li g h t mag az in e an a r t i c l e about 

b a rg a in -h u n ti n g in W as hing ton wh ich c o n ta in ed th e fo ll o w in g com ments:

With few e x c e p ti o n s, W ash in gto n's b e s t bu ys a re found in th e •

n o n p ro fit g i f t sh ops o p era te d by th e F e d e ra l Go vernme nt.

L o cati n g them i s th e har d p a r t.

Tak e th e Commerce D ep ar tm en t, fo r ex am pl e. Fo r b a rg a in s, 

n o th in g ca n match th e Government B ookst ore ho us ed h e re . But p la n 

to ask a t l e a s t th re e guar ds fo r d ir e c tio n s . I t ha s to be th e 

m o s t- d if f ic u lt- to - lo c a te bo o k st o re in th e w or ld !
15

At th e L ib ra ry of C on gr es s you’l l fin d a s e le c tio n o f Am eri ­

ca na p o s t e r s . . . . The L ib ra ry is a sn ap to lo c a te , but th e g i f t 

shop — ag ain — see ms to ha ve bee n p u rp o se ly hid den.

The r e a l b a rg ain a t th e L ib ra ry of Con gr es s i s i t s c o lle c tio n 

of re c o rd in g s. F in din g th e g i f t sh op w o n 't h elp you h ere bec ause 

re c o rd in g s a re so ld th ro ugh th e R ec ord in g L abora to ry ho us ed — you 

gues se d i t — in an o u t- o f-th e -w a y o f f ic e tu ck ed in to a ba se men t 

c o rn e r.

In d ia n c r a f t s a re to be foun d a t th e Dep artm en t o f th e In -

• t e r i o r , a n o th e r o u t- o f- th e -w a y b u ild in g w it h both a g i f t sh op and 

museum b u rie d in i t s b u re a u c ra ti c c o r r id o r s .

I am d e li g h te d to se e th a t S ecti o n 4(b ) of S. 865 would c o r re c t t h is 

s it u a t i o n .

I f you re ad th e re co m men da tio ns of th e Ta sk Forc e as a w hole , you 

w ill se e th e s e is s u e s o f p u b li c ima ge and p u b li c a cc ess we re v ery much on 

th e minds o f th e ta s k fo rc e memb ers. They concl uded th a t th e F e d e ra l 

Gover nm ent h as an o b lig a tio n to p ro v id e b u il d in g s wh ich dem onstr ate th a t 

go ve rn men t i s n o t a re m ot e c o n tr o l sy st em ru n fro m W as hing ton and wh ich 

em ph as ize th e F e d e ra l G ov er nm en t's a c c o u n ta b ility to i t s lo c a l c o n s titu e n c ie s by c o n tr ib u tin g to th e im prov em ent o f t h e i r envir onm ent, s o c ia lly , 

eco n o m ic all y , and v is u a lly . And th ey f u r th e r co ncl uded th a t a d a p ti v e 

use and m u lt ip le use ca n be ke ys to h e lp in g th e Governm ent me et th a t 

o b lig a tio n . I w i l l t r y t h is morning to e x p la in why.

Mr. Cha irm an , th e re a re o th e rs h e re who a re much more kn ow le dgea ble 

th an I in th e c o m p le x it ie s of tu rn in g o ld b u il d in g s in to co nte m pora ry 

u se s. I w ill only make a few g e n era l o b se rv a ti o n s.

Old b u il d in g s a re lik e o ld f r ie n d s . The y connec t us to our p a s t.

Ye t a t th e same ti m e, th ey a re a v i t a l p a rt o f our p re se n t beca use th ey 

a ssu re us o f a c e r ta in s t a b i l i t y and c o n ti n u ity in ti m es of ra p id ch an ge.

I t i s fo r j u s t t h i s re aso n th a t th ey sh ould ho us e th e F ed era l G over nm en t's 

a c t i v i t i e s . They v ery o fte n p e r f e c tly f i t th e 1962 G uid in g P r in c ip le s 

d e s c rip tio n o f an a p p ro p ria te F e d e ra l a r c h ite c tu r e s ty le as on e " . . . which

• i s d is ti n g u is h e d an d which w ill r e f l e c t th e d ig n ity , e n te r p r is e , v ig o r, 

and s t a b i l i t y of th e Am erica n n a ti o n a l gover nm en t."

Re use o f o ld b u ild in g s a ls o a cco rd s w it h a lo s t Am erica n e th n ic 

w whi ch we a re try in g to re c a p tu re , on e ex p re ss ed in th e New En glan d

p ro v e rb , "Use i t up, wea r i t o u t, make i t do, or do w it h o u t. " In h is 

a d d re ss to s t a t e h i s t o r ic p re s e rv a ti o n o f f ic e r s in F eb ru ary , th e S ecre ­

ta r y of th e I n t e r i o r sa id th a t i t i s now an accep te d fa c t th a t a d ap ti v e 

use i s f a r more ec onom ic al in i t s use o f en er gy and n a tu r a l re so u rc e s 

th an new c o n s tru c tio n . Th ese com para ti ve re so u rc e and ener gy sav in g s 

ha ve n o t y e t be en a c c u ra te ly m ea su re d, ho wev er, and th ey a re o fte n 

overl o o k ed . The Endowment ho pe s to c o n tr ib u te to an in te r-a g e n c y e f f o r t 

to u n d ert ak e su ch m ea su re men ts in th e n e ar f u tu r e .
Bec au se b u il d in g s re p re se n t in v estm en ts and th e ir s i t e s econom ic 

o p p o rtu n it y , many o ld e r b u il d in g s ha ve f a lle n v ic ti m to f a u lt y econ om ic 

reaso n in g th a t c o n sid e rs only some obvio us c o s ts of re n o v ati o n w it h o u t 

c o n sid e rin g some n o t- so -o b v io u s sa v in g s. Compared to new c o n s tru c tio n , 

ad ap ti v e use p r o je c ts pro vid e more jo b s , re q u ir e no d em o li ti o n and s i t e 

c le a ra n c e , and use l e s s s tr u c tu r a l and o th e r c o n s tru c tio n m a te ria ls .

They a re , m or eo ve r, co m pl et ed f a s t e r , r e s u ltin g in lo wer bo rrow in g c o s ts 

and le s s tim e th a t th e s i t e re m ai ns eco nom ic all y id le . Th es e eco nomi c 

advan ta ges ne ed to be q u a n ti fie d and p u b li c iz e d .

In a d d it io n , th e re a re some in d ir e c t b e n e f its a tt r i b u ta b le to r e ­

us e p r o je c ts which we may nev er be a b le to m ea su re q u a n tita tiv e ly . Th es e 

in clu d e r e v it a l i z a t io n o f su rr oundin g neig hborh oods and th us in c re a se d 

re ven ues fo r lo c a l gov er nm en ts , as w e ll as heig h te n ed c iv ic p rid e .

I am very p le a se d to se e th a t t h is b i l l enco ura ges re c y c li n g of 

th o se b u il d in g s which we do n o t norm al ly th in k o f as a r c h ite c tu r a l 

la ndm ar ks. .The y to o , s ig n ify c o n tin u ity , and more im p o rta n tl y , a re 

re so u rc e s to be conse rv ed i f a t a l l p o s s ib le . In S a lt Lak e C it y , 

t r o ll e y b arn s ha ve be en tu rn ed in to a su c c e s s fu l sh op pi ng c e n te r; in 

Ak ron, g ra in s i l o s , o f a l l th in g s , a re bein g tu rn ed in to ap art m en ts 

and o f f ic e s .

I t may be h e lp f u l to c la r if y two it em s in th e b i l l as i t i s w r itte n 

in o rd e r to all o w th e F ed era l Gover nm ent to ta k e maximum ad van ta ge of 

ad ap ti v e u se. F i r s t , i t is n o t c le a r w het her th e A d m in is tr ato r i s to 

giv e th e same p r i o r it y to o ld e r b u il d in g s in le a s in g sp ac e fo r th e 

F e d e ra l Governm ent a s he i s in d ir e c t a c q u is itio n of sp ace. The 

G ov er nm en t's r e n t pa ym en ts ca n h elp a p r iv a te owner to m ain ta in an 

old b u il d in g c u r re n tly in good c o n d it io n , w hil e th e Gov er nm en t's 

com mitment to e n te r in to a le a s e ca n p ro v id e th e owner of a rundow n 

b u il d in g w it h th e le v e ra g e to o b ta in p r iv a te r e h a b i li t a t i o n fin a n c in g . 

M or eo ve r, p r iv a te r e s to r a tio n lo o k in g fo rw ar d to a F ed era l Governm ent 

te nancy w ill ha ve to p ro v id e fo r e li m in a ti o n of a r c h ite c tu r a l b a r r ie r s 

to th e handic ap ped.

Secon d — and S en ato r B u ck le y 's sta te m en t in d ic a te d he i s a lr e a d y 

aw are o f t h is f a c to r — th e G ov er nm en t's p o li c y of o f f ic e c o n so li d a ti o n 

mu st be re -e xam in ed so we ca n make th e mo st use of th e many sm a ll e r, 

o ld e r b u il d in g s th a t e s ta b lis h a hu m an -s iz ed s c a le in our c i t i e s . The 

tr e n d in re c e n t y e a rs has been to ro un d up a l l th e F e d e ra l w ork er s in 

a m e tr o p o li ta n a re a in to one la rg e c e n tr a l o f f ic e co mplex . The re is 

undoubte dly a p o in t beyond wh ich th e p r o l if e r a t i o n of se p a ra te o f f ic e 

b u il d in g s cau ses an in c re a s e in m ai nte nance, co mm un ication and p ro te c ­

tio n c o s ts . On th e o th e r ha nd , p la c in g F e d e ra l o f f ic e sp ac e in one 

s tr u c tu r e must so m etim es ta k e us beyond th e p o in t wh ere eco nom is ts would 

sa y we a re a c h ie v in g a re tu rn to s c a le . In o th e r wor ds , we may be a b le 

to o p e ra te th re e or fo u r med iu m -sized o f f ic e s tr u c tu r e s in a m e tr o p o li ta n 

a re a as ch eap ly as a s in g le g ia n t- s iz e d on e. The o n e -b u il d in g conce pt 

may a ls o o v e r-c o n so li d a te in te rm s of co nven ie nce to th e p u b li c and th e
ne ed fo r i n t e r - o r in tr a -a g e n c y co m m un ic at io n. Peo ple w it h b u sin e ss a t 

Envir onm en ta l P ro te c ti o n Agency o f f ic e s seldom need to se e o f f i c i a l s 

o f th e Bur ea u o f La bo r S t a t i s t i c s — a t l e a s t n o t on th e same day. Nor 

do th e o f f i c i a l s o f th ese two a g en c ie s need to be in co n ti n u o u s c o n ta c t.

T his i s n o t a new is s u e . As e a r ly as 18 60 , th e e n g in eer in char ge 

o f th e T re asu ry D ep ar tm en t’ s C o n str u c ti o n Bureau (a fo re ru n n e r o f GSA), 

p o in te d out " th e im poli cy o f co m bi ni ng a co u rt h o u se and p o st o f f ic e 

un de r th e same ro o f in a la rg e c i t y ," sin c e th e c o u rts re q u ir e d a q u ie t 

lo c a tio n and th e p o st o f f ic e a lo c a tio n in th e no is y b u sin e ss d i s t r i c t .

In 19 05 , th e S e c re ta ry o f th e T re a su ry ’ s annual re p o rt wa rned th a t 

p la c in g a la rg e c it y p o st o f f ic e in th e same b u il d in g w it h a comb ine d 

co u rt house an d cu stom ho us e in volv ed " d is p ro p o rtio n a te a p p r o p ria ti o n s ."

As c u r re n tly w r itte n , S. 865 wo uld n o t p r o h ib it us e o f se v e ra l 

o ld e r b u il d in g s to s a t is f y F e d e ra l sp ace nee ds in an a re a . However, 

i t may be advan ta geous to add a p ro v is io n in d ic a ti n g when c o n s o li d a ti o n 

of F ed era l o f f ic e s in a m e tr o p o li ta n a re a wo uld not be d e s ir a b le .

The F e d e ra l A rc h it e c tu re Ta sk Forc e was th oro ughly convin ce d th a t 

a d a p ti v e use o f f ic e b u il d in g s would im prov e th e p u b li c ima ge of th e 

F ed era l Governme nt in co m m un iti es a c ro ss th e N ati on. The Ta sk Forc e 

co ncl uded t h a t m u lt ip le use h o ld s ev en g r e a te r p o te n tia l fo r demons t r a ti n g a com mitment to op en and a c c e s s ib le go ve rn m en t, lo c a l ec onom ic w e lf a re and so un d ur ba n la n d -u se p r in c ip le s .

Un der th e p ro v is io n s o f S. 86 5, m u lt ip le us e co uld be acc ommodated 

th ro ughout th e p u b li c b u il d in g in v e n to ry . A daptive use p r o je c ts , e x is tin g 

o f f ic e and c o u rt co m ple xes , and new c o n s tru c tio n u n d ert ak in g s could a l l 

be o u t f it t e d w it h f a c i l i t i e s to hou se co m m er ci al , c u lt u r a l , e d u c a ti o n a l, 

and r e c r e a tio n a l a c t i v i t i e s . N eedle ss to say , n o t ev er y F e d e ra l b u il d in g 

ca n su p p o rt th e e n t i r e ra nge of u se s; som e, bec ause o f lo c a tio n or p u rp o se , may be a b le to acc ommodate o n ly r e g u la r o f f ic e a c t i v i t i e s . Eac h 

s itu a tio n i s uniq ue an d w ill ha ve to be e v alu ate d in th e c o n te x t o f i t s 

s e t ti n g .

M u lt ip le use i s n o t a new id e a , o f c o u rse . I t i s si m pl y a new 

name fo r a f a m ilia r p r in c ip le o f urb an la nd u se. As an e d i t o r i a l in 

A r c h ite c tu ra l Record mag az in e r e c e n tl y ask ed, "Why s h o u ld n 't th e 

Government l iv e over th e s to re ? " Fo r c e n tu r ie s , c i t i e s fe a tu re d a 

ju m bl e o f h o u sin g , sh ops, w ork pla ce s and s o c ia l c e n te rs in c lo s e pro xim it y . Many peo p le a re now convin ce d th a t t h is m ix tu re of use s was 

re sp o n sib le f o r th e ch arm, v i t a l i t y , and a ttr a c tiv e n e s s of c ity l i f e .

The y a re p ro b ab ly r i g h t . We sh ould reme mb er, ho wev er, th a t t h is mixtu re came a b o u t, n o t from any co n scio u s a tt e m p t to make c i t i e s "c ha rm ­

in g ," b u t r a th e r a s a s o lu tio n to th e pr ob lem of p ro v id in g th e n e c e s s i t i e s 

o f l i f e w it h a slo w-m ov in g tr a n s p o r ta tio n sy st em . The tra n s p o r ta tio n 

pr ob lem ought to s t r i k e a ch or d w it h us ag ain to day . We ha ve j u s t r e ­

c e n tl y re co g n iz ed th e tr a n s p o r ta tio n and ener gy c o s ts of our p a tte r n 

o f ur ba n sp ra w l and se g re g ate d la nd u se s. I don’ t th in k an y of us 

doubt th a t th e F e d e ra l Gov ernment must do w hat ev er i t ca n to c o n tr ib u te 

to re d u cin g th o se c o s ts .
Mor eo ve r, m u lt ip le -u se b u il d in g s a re o fte n us ed more in te n s iv e ly , 

and th a t conse rv es ur ban la n d . In no rm al p r a c tic e , ou r F ed era l o f f ic e 

b u il d in g s sta n d emp ty a f t e r wor ki ng hours and on wee ke nd s. N ig h tli fe 

and weekend a c t i v i t i e s go on in o th e r b u il d in g s . I f th e o f f ic e and 

a f te r - h o u r s a c t i v i t i e s a re accommodated in th e same s tr u c tu r e , ho wev er, 

th e p re ssu re on ur ba n la n d and con se q u en tl y on th e op en la n d su rr oundin g our c i t i e s i s le sse n e d .

S ecti o n 2 (a )( 5 ) o f S. 865 wo uld en co ur ag e su ch in te n s iv e us e of 

F e d e ra l b u ild in g s . I t could be one of th e mo st s ig n if ic a n t p ro v is io n s 

in th e b i l l , i f im plem en ted v ig o ro u sly . I t ca n tu rn F e d e ra l b u il d in g s 

in to a c tiv e c e n te rs o f com munity l i f e . As Ch air ma n of th e N ati o n al 

Endowment fo r th e A rts , I ha ve to p o in t o u t th e p o te n tia l t h is p ro v isio n p a r ti c u l a r ly h o ld s o u t fo r th e a r t s . Many o f our F e d e ra l b u il d in g s 

c o n ta in a u d it o ri u m s and o th e r p u b li c rooms whi ch , w it h minor a lt e r a t io n s 

could fu rn is h sp ac e fo r perf orm in g a r t s p ro d u c ti o n s. F il m s, c o n c e rts , 

and, w it h more s u b s ta n tia l m o d if ic a ti o n s , th e a tre and da nc e per fo rm an ce s 

ca n be p re sen te d in room s which du ri n g th e workd ay a re dev ote d to t r a i n ­

in g s e s s io n s , m eeti n g s, and h e a rin g s. Of co u rs e, when n o t bein g us ed 

fo r c u lt u r a l a c t i v i t i e s , th ese same rooms ca n be us ed a f t e r hours fo r 

m eeti ngs o f lo c a l c iv ic o rg a n iz a ti o n s or gover nm en ta l b o d ie s.

As w it h a d ap ti v e u se , th e re so u rc e and en er gy sa v in g s th a t ca n be 

a tt r i b u te d to m u lt ip le use a re n o t as ap p are n t as th e str a ig h tf o rw a rd 

co m m er ci al ar gu m en ts in i t s fa v o r. We know of on e in sta n c e in wh ich 

a M id wes te rn town ple aded w it h th e F ed era l Gover nm ent to pro v id e sp ac e 

fo r co m m er ci al a c t i v i t i e s in i t s new o f f ic e b u il d in g . The b u il d in g 

was in th e m id dle o f a re dev el opm en t t r a c t wh ich had be en c a r e f u lly 

pla nned as a p e d e s tr ia n sh oppin g a re a . A ll o th e r new b u il d in g s in th e 

a re a wer e re q u ir e d to in c lu d e lo wer flo o r sh op pi ng sp ace. The town 

was v ery co nce rn ed th a t th e F e d e ra l b u il d in g , wh ich occu pie d a la rg e 

and s t r a te g i c s i t e , would d is r u p t th e flow of sh o p p ers . F e d e ra l o f f i ­

c i a l s had to sa d ly in fo rm town p la n n e rs th a t no a u th o rity e x is te d to 

a ll o w s to r e s in th e b u il d in g and i t st an d s to da y as an is o la te d , f o r ­

b id d in g p re se n ce in an o th erw is e liv e ly s t r e e t . T his is n o t an 

a e s th e tic pro bl em ; i t i s an a b d ic a ti o n of th e G ov er nm en t's c le a r 

ec on om ic and s o c ia l r e s p o n s i b i li t ie s .

I t was to j u s t su ch c o m p la in ts fro m bu si ne ss m en th a t th e Can ad ian 

Governme nt re sp onded w it h an am b it io u s m u lt ip le -u se pr og ram . To ld by 

m erc hants th a t i t s s in g le -u s e o f f ic e b u il d in g s we re "d ea d sp aces" in 

th e s w ir l o f c i t y a c t i v i t y and wer e dama ging to b u sin e ss in th e ir 

n eig hborh oods, th e Dep ar tm en t o f P u b li c Works be ga n d e sig n in g new 

b u ild in g s w it h b u i l t - i n sp ace fo r s to r e s and r e s ta u r a n ts and e sta b ­

lis h e d an o f f ic e to a c tiv e ly m ar ke t th e sp ace. The Dep artm en t t e l l s 

us th a t i t has had no co m p la in ts about i t s e n tr y in to th e co mmercial 

r e n ta l m ark et. Dep artm en t re p re s e n ta tiv e s ev en p a r ti c i p a te in th e act i v i t i e s o f lo c a l m er ch an ts a s s o c ia tio n s .

U n fo rtu n a te ly , le a s in g out sp ace fo r co m m er ci al , c u lt u r a l , ed uc at io n a l , and r e c r e a tio n a l a c t i v i t i e s i s not si m ply a m att e r o f ha ng in g
o u t a sig n sa y in g , "s p ace to l e t " and a ssig n in g le a s e s on a f i r s t - 

com e, f i r s t - s e r v e d b a s is . C are fu l p la n n in g is re q u ir e d to make su re 

th a t th e m u lt ip le -u s e pr og ram acc om pli sh es i t s goal o f en ha nc in g th e 

urb an envir onm en t. F o rtu n a te ly , ex p eri en ce in th e p r iv a te s e c to r ca n 

be r e li e d on to gu ar d a g a in s t mo st p i t f a l l s .

The C an ad ia ns ad m it q u it e c a n d id ly , f o r ex am pl e, th a t th e ir f i r s t 

m u lt ip le -u se p r o je c t g o t in to d i f f i c u l t y a t f i r s t . I t was a new b u ild ­

in g in a d ep re ss ed a re a w it h l i t t l e e x is tin g da yt im e o f f ic e or commerc i a l a c t i v i t y . Co mm erc ial te n a n ts we re moved in to th e new b u il d in g 

b e fo re th e G over nm en t's o f f ic e w ork ers . With no a v a ila b le c li e n t e l e , 

many o f th e sm all sh op s had to v a c a te . The Dep artm en t of P u b li c Works 

now pa ys c a r e f u l a tte n tio n to th e pr ob lem o f phasi ng in i t s te n a n ts .

I t i s a ls o im p o rt an t to ensu re an a p p ro p ria te mix o f a c t i v i t i e s . 

C e rta in ty p es o f r e t a i l a c t i v i t i e s and r e s ta u r a n ts a c t a s dr aw in g card s 

to p a sse rs b y to th e b e n e f it of o th e r, le s s in s ta n tly te m pting f a c i l i t i e s . 

The se dr aw in g c a rd s ha ve to be in clu d ed in any s u b s ta n tia l co mm erci al 

sche me . On th e o th e r ha nd , some a c t i v i t i e s , thou gh le g a l, m ight d e tr a c t 

fro m th e d ig n it y o f th e F ed era l Gover nm ent and o ff en d a p a r t o f th e 

p u b lic . They sh ould be excl uded .

O th er a c t i v i t i e s , l ik e ba nk s and tr a v e l a g e n c ie s, a re norm al ly 

open only d u ri n g o f f ic e hours and sh ould n o t be al lo w ed to ta k e up to o 

g re a t a p o rti o n o f th e a v a ila b le sp ace.

The su pply o f and demand fo r co m m er ci al , c u lt u r a l , e d u c a ti o n a l, 

and r e c r e a tio n a l a c t i v i t i e s ha ve to be stu d ie d in ea ch s i tu a tio n . P r i ­

v a te ow ne rs do n o t ex ecu te le a s e s w it h s to r e s or o th e r f a c i l i t i e s th a t 

ha ve l i t t l e ch an ce o f econom ic s u r v iv a l, sin c e fre q u e n t tu rn o v ers r a is e 

a d m in is tra tiv e expen se s and d is co u ra g e cu st o m ers . A c tiv itie s in th e 

le a se d sp ac e in F ed era l b u il d in g s w ill ha ve to be ke yed to th e dem ands 

of two gro ups: th e g e n e ra l p u b li c and F ed era l o f f ic e w ork ers . Some 

f a c i l i t i e s th a t m ig ht n o t o th erw is e be en co ura ged to le a se ba se d on 

a s t r i c t l y e x te r n a l m ar ket a n a ly s is , sh ould n e v e rth e le s s be so ught fo r 

th e b e n e f it o f our c i v i l se rv ic e em pl oy ee s. A th le tic and r e c r e a tio n a l 

f a c i l i t i e s , fo r ex am pl e, a re to o seldom pro vid ed in ou r o f f ic e b u ild ­

in g s, d e s p ite t h e i r p o te n tia l c o n tr ib u tio n to em ploy ee h e a lth , m ora le , 

and e f f e c tiv e n e s s . A tt e n ti o n mu st be p a id , of c o u rs e, to th e r a te s 

char ged by p r iv a te h e a lth f a c i l i t i e s . They may be to o h ig h to all o w 

th e b u lk o f th e em pl oy ee s to en jo y t h e i r use . On th e o th e r ha nd , some 

c a re w ill ha ve to be ta ken to ensu re th e co m m erci al so un dn es s of th e 

R an do lp h- She pp ar d Act prog ram. Perh aps th e ven din g sta n d s co uld be 

pro vid ed lo w er f lo o r sp ace in acc ord an ce w it h S e c ti o n 4(b ) of th e b i l l .

Making p u b li c b u il d in g s in v itin g to th e p u b li c in v o lv es more th an 

j u s t p ro v id in g a mix o f a c t i v i t i e s in s id e them. I f p e d e s tr ia n s a re to 

be a tt r a c t e d to them , a s S. 865 enco u ra g es, and as p ro fit- s e e k in g te n a n ts 

dem and, th e b u ild in g s th em se lv es ha ve to be d esi gned to a c t as m ag net s. 

F o u n ta in s, p la z a s th a t d ir e c t movement toward th e b u il d in g , pr om in en t 

e n tr a n c e s , in fo rm a ti o n k io sk s, s ig n s , and ban n ers ca n c ap tu re th e a t ­

te n tio n o f p eo p le p a ssin g by .
20

B u il d in g man ag ers ca n in c re a s e th is ma gnetic, e f f e c t by pro gram mi ng 

f r e e a c t i v i t i e s in in door and outd oor p u b li c sp aces. B ost on’ s C it y 

H all — which do es not in c o rp o ra te m u lt ip le use s o f th e s o r t we a re 

ta lk in g ab o u t, but wh ich i s a good exam ple of a p u b li c b u ild in g th a t 

a c tu a lly welco me s th e p u b li c — i s th e s e ttin g fo r a y ear- ro u n d f e s t i ­

v a l. D ur in g th e summ er, i t s o utd oor p la z a , wh ich was desi gned as a 

sm all a m p h it h ea tr e , i s th e sc ene o f o rc h e str a and ja z z c o n c e rts , fo lk 

da nc e and b a ll e t pr og ra m s, s c u lp tu re e x h ib its , and an a u al Fourt h of 

Ju ly c e le b r a tio n . In doors a t C it y H a ll , th e re a re p a in t ng, photo gra phy, 

s c u lp tu re , and ta p e s tr y e x h ib its , fa sh io n sho ws, r e c e p ti o n s , a C hri st m as 

T re e f e s t i v a l , and c o u n tl e s s c h o ra l, ban d and org an c o n c e rts . I know 

you a l l und ers ta n d how su ch ev en ts ca n e n li v e n a b u il d in g ; I 'v e o fte n 

st opped to l i s t e n to th e c h o ra l c o n c e rts th a t yo ur c o n s titu e n ts p re se n t 

in th e lo b b ie s o f th e Senate O ffic e B u il d in g s, not to m en tion th e 

nu me rous e v en ts on th e s te p s of th e C a p it o l.

None o f us wa nt to make F e d e ra l b u il d in g s in v itin g to th o se who 

wo uld d is r u p t th e a c t i v i t i e s o f t h e i r o f f ic e s . Some people ha ve ex ­

p re sse d th e fe a r th a t m u lt ip le -u s e F ed era l b u il d in g s w ill be more 

s u s c e p tib le to d is ru p tio n o r bo mbing , sin c e more people w ill be p assin g 

th ro ugh the m. Tha t i s a gen iu ne conce rn . C are fu l a tte n tio n to d e sig n , 

ho wev er, ca n a lla y th ese f e a r s . The new J . Edgar Hoove r B u il d in g , which 

has be en c r it i c i z e d by some a s an exam ple of a F ed era l b u il d in g th a t de ­

t r a c t s fro m th e co m m er ci al an d s t r e e t en vi ro nm en t ar ou nd i t , does, in 

f a c t , in c o rp o ra te a c ir c u la tio n sy st em fo r i t s v i s i t o r s th a t p re v en ts 

the m fro m w an de ring in to s e c u r ity - s e n s itiv e a re a s of th e b u ild in g . I f 

t h is s e c u r ity pr ob lem ca n be so lv ed in th e h e a d q u a rte rs of th e FBI, I 

d a re sa y i t ca n be so lv ed in most o th e r F ed era l b u ild in g s .

F in a lly , w hil e i t i s n o t a pri m ary re aso n fo r a d v o cati n g emplo yme nt in F e d e ra l b u ild in g s , m u lt ip le use sh ou ld r e s u l t in a n e t f in a n c ia l 

re tu rn to th e F ed era l B u il d in g Fund. S. 865 re q u ir e s th a t r e n ta l r a te s 

be e q u iv a le n t to p re v a ili n g co m m erci al r a te s , wh ich norm al ly y ie ld a 

p r o f i t a f t e r overh ea d, u t i l i t i e s and th e lik e a re s u b tra c te d . At th o se 

r a t e s , i t i s e sti m a te d th a t th e 39 ,0 00 sq uare f e e t of r e s tr a u r a n t and 

r e t a i l sp ace in th e F ed era l Home Loan Bank Board h e a d q u a rte rs now un de r 

c o n s tru c tio n w ill command a g ro ss r e n ta l of $5 29 ,000 per y e a r. A lo c a l 

W as hing to n r e a l e s ta te d ev elo p er in fo rm s me th a t co m m erci al r e n ta ls 

v ary a cc o rd in g to d if f e r e n t u se s o f th e le ase d sp ace. Some i n s t i t u ­

tio n a l u s e rs c a rry a r e la ti v e ly h ig h -fix e d charg e, w hil e many r e t a i l 

u s e rs pa y a p erc en ta g e o f g ro ss s a le s in a d d it io n to a r e l a ti v e ly lowfix e d r e n t. The f o rtu n a te a sp e c t o f th is re n t s tr u c tu r e i s th a t i t 

am ou nts to a b u i l t - i n su b sid y . By le a s in g a sm all p o rti o n o f sp ac e to 

a h ig h -re n t u se, on e ca n re n t o th e r sp ac e to ach ie v e an in te r e s tin g mixtu re of a c t i v i t i e s and s t i l l more th an co ver m ai nte nan ce and u t i l i t y 

ex pen se s on th e e n tir e sp ace.

I wo uld lik e to su g g est only on e sm all , but im p o rt a n t, re v is io n in 

th e m u lt ip le -u se p ro v is io n s o f th e b i l l . As p re s e n tly w r itte n , only 

gr ou nd f lo o r sp ac e ca n be le a se d on a se m i-pe rm an en t b a s is . T his pro ­

v is io n wo uld p re c lu d e , fo r ex am pl e, le a s in g ro o ft o p sp ace to a re s ta u r a n t
21

o r ba se men t sp ace fo r a t h l e t i c f a c i l i t i e s . I t would a ls o p re clu d e a 

tw o -le v e l sh oppin g a re a lik e th e m ez za ni ne pro pose d fo r th e new F e d e ra l 

Home Loa n Bank Board b u ild in g . Sin ce th e se no n- gr ou nd le v e l fe a tu r e s 

ha ve be en su c c e ss fu l els ew h ere , I th in k i t would be a m is ta k e to lim it 

desi g n and r e n ta l o p ti o n s to gr ou nd flo o r sp ace on ly .

« A lthough I ha ve sp ok en of them s e p a ra te ly , a d ap ti v e use and m u lt ip le

us e a re b e s t co mbine d, w it h m u tu all y b e n e f ic ia l r e s u l ts . Many r e h a b i li ­

ta tio n p r o je c ts a re made eco nom ic all y f e a s ib le by in c lu d in g m u lt ip le 

u se s in th e ad apte d b u il d in g s . M u lt ip le -u se f a c i l i t i e s g ain p atr o n ag e 

by b ein g lo c a te d in adapte d old b u il d in g s wh ich a re both f a m ilia r and

* in tr ig u in g to th e p u b li c .

Mr. Cha irm an , we a re deep ly g r a ti f i e d th a t th e work of th e F e d e ra l 

A rc h it e c tu re Ta sk Fo rc e has born e t h is f r u i t . The N a ti o n a l Endowment 

fo r th e A rt s s tr o n g ly su p p o rts S. 86 5. We b e li e v e i t w ill r e f l e c t in 

our p u b li c a r c h ite c tu r e th e same im puls e to more op en co m m un icatio n be ­

tw een th e Governm ent and th e gover ned th a t we se e in so many o th e r a re a s 

o f co nte m pora ry p u b li c a f f a i r s . Thank you fo r g iv in g me th e o p p o rtu n it y 

to sp eak to you in b e h a lf o f S. 86 5.
22

Se na tor Buckley. Mrs. Shiple y, would you care to give us you r 

views on th is legisla tion t

STATEMENT OF NANCY K. SHIPLEY, VICE CHAIRMAN, ADVISORY 

COUNCIL ON HISTORIC PRESERVATION

Mrs. Ship ley. I am N ancy Shipley, Vice Ch airma n of the Adv isory 

Council on H istoric Prese rva tion. With me to day is Rober t R. Garvey, 

Jr ., Execu tive Directo r of the Council.

You are hea ring, of course, tod ay from Miss Ha nk s and others on 

the relationship of thi s bill t o t he p ar t played by the F edera l Government, and I would just like to address t oday some specific sections of 

the prop osed bill th at a re of most concern to our Council.

A t its recent mee ting on May 7 and 8, the Advisory Council reviewed the proposed bill and voted unanim ously to endorse its ear ly 

enactment. The Council finds th at the bill is con sistent with the congres sion al dec laration in the intr oduction to the National Hi sto ric 

Pre ser vatio n A ct of 1966 th at , “The hist orical an d cult ural fou ndations 

of the Nation should be preserv ed as a living pa rt of our com munity 

life and development in orde r to give a sense of ori entation to the 

Americ an peop le.”

In testimo ny befo re you today, you have heard , or will hea r, commen ts concern ing the relationship of this bill to a “good neigh bor” 

policy of the Federal Gov ernm ent, to rev ita liz ati on of urb an areas, 

to energy and resource conserv ation, and to lab or intensive emp loyment.

Th e Council support s these positions and ra th er than restate them 

fo r you, I would like to add ress specific sections of the prop osed bill of 

most concern to the Council.

Of critica l imp ortanc e to effective imple me ntation of the bill is the 

determination by the Ad minist rator of wh eth er it is feasible and 

pr ud en t to utilize ex isting bu ilding s o f historical, arc hitectur al or cul ­

tu ra l significance.

Simi lar languag e exists in section 4(f ) of the De partm ent of Tra ns ­

po rta tio n Act and has been the subje ct of extensive judicia l scrutiny.

The Council believes th at it is most im po rta nt th at the legislative 

his tor y of this bill reflect that determina tion un der section 2(a )( 1) be 

ade qua tely docu mented and take into account fac tors which are difficu lt to qu an tif y; specifically, the historical, arc hitec tur al, o r cultu ral 

imp ortanc e of existing building s and th eir contribu tion to the 

commun ity.

A pure cost-benefit ana lysis, based on cost per square foot, may in ­

deed not a ccurate ly reflect the t rue costs and benefits to o ur society of 

uti liz ing or n ot utilizing an existin g str ucture.

In this re gard, it should be noted th at p ursuant to the National H istor ic Prese rva tion Act of 1966, th e Advisory Council is charged with 

the respon sibility of advis ing Federal agencies on the public intere st 

involved in their activitie s affecting historic resources.

There fore, it seems ap prop ria te th at the comm ents of the Council 

be ob tain ed by the Ad minist rator of the General Serv ices A dm inist ration in o rder to assist him in making determinations as to the fea sib ility and pruden ce of uti liz ing e xisting his tor ica lly , arc hit ectur all y, or 

cu ltu rally sign ific ant structu res .
23

The Council also notes that the present national historic preservation program is essentially a partnership between the Federal Government and the States. Pursuant to the National Historic Preservation 

Act, and at the request of the Secretary of the Interior, the Governor 

of each State has appointed an official to serve as State reservation 

officer.

In furtherance of this partnership, the Council suggests tha t the 

State historic preservation officers be named in the list of officers to 

be consulted by the Administrator.

The next element of the bill of concern to the Council is the requirement that the Administrator identify existing structures of historical, 

architectural or cultural significance.

The bill as proposed limits the Administrator to contracting with 

the chairman of the national trust for all identification activities. 

The Council is concerned t hat limiting identification activities to the 

national trus t exclusively fails to take advantage of a very real opportunity to initiate State and local involvement at the earliest stages 

of planning for a Federal building.

The involvement and support of the local community, as suggested 

by Miss Hanks, is a basic objective of this bill and it appears th at every 

effort should be made to gain this support at the earliest time, at the 

beginning of the project.

The Council recommends tha t the bill be amended to provide that 

the Administrator has the responsibility to identify buildings of historical, architectural, and cultural significance in a geographical area, 

and that he be given maximum latitude in working with organizations 

to accomplish his identification responsibilities.

Within this framework, the Council suggests tha t it would be appropriate for the Administrator to consult with such organizations as 

the Department of the Interior, the National Endowment for the Arts, 

the national trust, the Council on Environmental Quality, and the 

Advisory Council on developing the means to identify historical, architectural, and cultural properties.

The Council would also like to suggest, as Miss Hanks and you suggested, that further consideration be given to giving the Administrator 

discretion in leasing space, and not restricting leasing to ground floors 

only. The use of other areas of buildings, such as rooftops for restaurants, could be regulated administratively rather than by statute.

In this regard, the Council also suggests tha t the bill allow the Administrator to lease space to Government corporations, and units of 

State and local governments as appropriate.

Finally, you may have noted that I have consistently used the terms 

“historical, architectural, or cultural” in referring to the significance 

of existing buildings.

The term “cultural” might appropriately be added to the present 

bill. In reviewing Federal projects throughout the country, the Council has found important resources exist which derive their significance 

more from a cultural association than from architecture or history.

For example, the Beale Street Historic District in Memphis, Tenn., 

and the Chinatown Historic District in Honolulu, Hawaii, are areas 

which are most strongly associated with cultural characteristics that 

have contributed to our heritage, rather than history or architecture.
24

I he Council suggests that, consistent with the National Historic 

1 reservation Act, the bill utilize the term “historical, architectural, or 

cultural in referring to the significance of existing buildings.

I hank you tor the opportunity to appear before you today. I would 

bke to submit a copy of my remarks for the record which we believe 

would attect the improvements which I have outlined.

Again, the Advisory Council unanimously supports the proposed 

ill and looks forward to working with the General Services Administration through this legislation to work toward revitalization of our 

older urban areas.

Senator Buckley. I hank you. Your proposed amendments will be 

entered into the record. I thank you. They sound very constructive.

Airs. Shipley. Thank you.

[The proposed amendments follow:]
Advisory Council 

On Historic Preservation

1 522 K Street N.W . Suite 430 

Washington D.C. 20005

May 19, 1975

Hon. Robert Morgan 

Chairman, Subcommittee 

on Buildings and Grounds 

Committee on Public Works 

Unit ed States Senate 

Washington, D. C. 20510

Dear Senator Morgan:

As indicated in ray remarks before you today, the Council proposes 

the following amendments to S.865 for your consideration:

1. The introduction should be amended to read as follows:

"To promote more efficent use of the N at io n’s 

construction resources, to foster the preservation of buildings of h istorical, architectural, 

or cultural significance, and to enhance the 

social and economic environment within and 

surrounding Federal office buildings."

2. Section 2(a)(1) should be amended to read as follows:

"(1) acquire and u tilize space in suitable 

buildings of hi storical, architectural, or 

cultural significance, unless use of such 

space would not prove feasible and prudent 

compared with available alternatives;"

3. Subsection 2(a)(3) should be amended to read as follows:

"(3) encourage the location of commercial, 

cultural, educational, and recreat ional 

facilities and activities, and of units 

of government corporations and State and 

local governmen ts, within or near public 

bui ldi ngs ;
26

4. Subsection 2(b) should be amended to read as follows:

"(b) In carrying out his duties under subsection 

(a) of this section, the Administ rator shall 

consult with Gov ern ors , areawide agencies 

established pursuant to title II of the 

Demonstration Cities and Met ropolitan Development Act of 1966 and title IV of the Intergovernmental Cooperation Act of 1968, the Advisory 

Council on Historic Prese rva tio n, the appropriate 

State Historic Preservation Officer designated 

pursuant to the National Historic Preservation 

Act of 1966, and chief executive officers of those 

units of local government in each area served 

by an existing or proposed public building, and 

shall solicit the comments of such other community 

leaders and members of the general public as he 

deems appropriate."

5. Subsection 3(2) should be amended to read as follows:

"(5) whenever a project proposed in the prospectus 

does not provide for acquisition or purchase of 

the building or buildings identified to the 

Administrator pursuant to section 12(c), a statement , Including the comments of the Advisory Council 

on Hi storic P res erv ati on, documenting and substantiating the economic and other justifications 

for not acquiring or purchasing such building or 

buildings; and";

6. Subsection 3(3) should be amended to read as follows:

"(c) Whenever the Administrator undertakes a 

survey of the public buildings needs of the 

Federal Government wi thin a geographical area, 

he shall (contract with the Chairm an of the 

National Trust for Histor ic Preservation to) 

identify any existing buildin gs withi n such 

geographical areas whi ch are of historical, 

architectural, or cultural interest and which 

woul d be suitable, whether or not in need of 

repair, alteration, or addition, for acquisition 

or purchas e to meet the public buildings needs of 

the Federal Government. In carryin g out this 

identification res ponsibility, the Administrator 

shall develop an appropriate Identification process,

in consultation with the Department of the I nte rio r,
the National Trust on Historic Preservation, 

the National Endowment for the Ar ts , the 

Council on Environmental Quality and the 

Advisory Council on Historic Preservat ion ."

7. Subsection 4(a)(1) should be amended to read as follows:

"16) to enter into leases of space (on the ground 

floor) of any public building with persons, firms, 

or organizations engaged in commercial, cultural, 

educational, or recreational activities, or with 

units of government corporations or State or local 

governments. The Administrator shall establish a 

rental rate for such leased space equivalent to 

the prevailing commercial rate for c omparable space 

devoted to a similar purpose in the vicinity of the 

public building. Such leases may be negotiated 

withou t competitive bids, but shall contain such 

terms and conditions as the Admi nistrator deems 

necessary to protect the public interest;"

8. Subsection 5(4) should be amended to read as follows:

"(4) The term "hi sto ric al,or architectural, or 

cultural signi ficance" includes, but is not 

limited to, buildings listed or eligible to be 

listed on the Nation al Register."

The Adviso ry Council appreciates the opportunity to comment 

on S.865.

Sincerely yours,

Nancy Shipley 

Vice Chairman
28

Sena tor B uckley. You spoke at the outse t, Mrs. Shipley, about th e 

need to tak e some fac tors int o account oth er th an dolla rs and cents.

I ga ther yo ur counsel has been at work ma kin g such assessments. How 

has t his worked o ut in prac tice ?

Mrs. Ship ley . With a va rying degree of success, of course. It is 

easy to talk about fai lur e more and more. The Federal establishment 

think s in terms of the cu ltu ral value s as leaders as yours elf em phasize 

them. So it filters th roug h to the dep artments. W e find all th e tim e that 

the historical values are considered more and earlier, which is so 

important.

Senator B uckley. May I ask th is : Have you wor ked w ith t he GSA #

in the pas t?

Mrs. S hip ley . Y es; of course.

Se nator Buckley. I s the GS A sufficiently imagi nat ive to ta ke these 

oth er values into acc ount ?

Mrs. Ship ley . Yes. Comm issioner S amp son has been a ch amp ion, as 

you know, of pre servation within his own considerable numb er of 

building s th at he has to acco unt for. He does his best. It is not always 

possible, b ut more and more. A gain, as we like to emphasize, th e e arl ier 

these thi ng s are considered, and thi s bill would go fa r in allo win g an 

ea rlier consid eration and req uirin g an e arlie r consid eration , the e arl ier 

it is considered, the easier it is for Com missioner Sampson to take them 

int o account.

Senator Buckley. You are s ugg esting we prov ide t ha t kin d of la ti ­

tud e to GSA to take these into f ull account.

Mrs. Ship ley . Yes.

Se nator Buckley. Miss Hanks, your testim ony mentions the task 

force repo rts. I w onder i f we could have some copies of those.

Miss H anks. I would be happy to su bm it them.

[The rep ort s ref err ed to have been retain ed in t he comm ittee files.]

Se nator B uckley. It has been suggested t he re will soon lie a number 

of U .S. post offices th at are about to be abandoned. Ho any one of you 

happen to know wh at opportu nit ies m igh t exist to use these building s 

fo r Federal offices? •

Mrs. Ship ley . Senator. I think Mr. Garve y, our Execu tive Direc ­

tor, has been heavily involved in that. Pe rh ap s he could comment for 

you.

Senator Buckley. Please come forw ard , M r. G arvey. •

Mr. Garvey. Th ere are indeed a num ber of facilities th at have 

forme rly been in service as postal facilities, or where the removal of 

postal services is anticipa ted .

The P ostal Serv ice has the cap abi lity to dispose of or sell such pr op ­

erty. One of the discouragements , I think , in this kin d of tran sf er o r 

use for office space un der thes e circumstances is embodied in the very 

difficult financial circ ums tanc es that the Posta l Service continually 

faces because of increased costs; and the efforts to secure maximum 

retu rn on the disposal of. sale, or tran sfer of such prop erty places a 

detrime nt in the way of reuse of postal build ing s fo r other such 

purposes.

There are a good many situ ations thr ou gh ou t the country — well,

I say a good many. T know of two or three at th is very mom ent—in 

which the histo ric ity of a postal build ing is und er conside ration, or the
29

reuse of a for me r postal bu ild ing is under con sideration and the cost 

fac tors get to be a very large element in such reuse p lans.

Se nator Buckley. Th ank you.

Are you fam ili ar w ith the old post office here in Wash ing ton ?

Mrs. Ship ley . There is a bill in the House, H.R. 1501, which has 

not yet been intr oduce d in the Senate which, I think , would allow the 

leasing of th at post office. I t is a specific bill t ha t does for one b uildi ng 

what the bill before you would do for every b uildin g, basic ally , I think . 

It allows a n exception to be made fo r the post office.

Is t ha t rig ht, Miss H ank s?

Miss H anks. Yes ; the old post office, we are quite fa m ili ar w ith it. 

So is (ISA, a s you know, sir, and I would be h ap py to give you a copy 

of our fea sib ility stu dy for the use of the old post office on Pe nn sy lvania Avenue.

The sit uatio n at the presen t tim e, and I think the questio n mi gh t 

be posed to the General Services Adm inistratio n, is th at the y are work ­

ing out the pro spe ctu s on the renovation and adaptiv e use of th at 

buildin g.

It is a very difficult situation, and I feel ra th er inco mpetent to comment on it, but I will. Th at is, I think the citizens of th is c ommunity 

have determ ine d the y want to save th at o ld post office b uildin g.

Local citizens, g overn me nt officials, both Fe deral and fro m the Di stri ct of C olum bia, made a decision to save the bui lding, an d th ere it sits.

It is b eing used now by some Fe de ral offices, some D ist ric t offices. It 

is an eyesore on Pennsylva nia Avenue a t the present time. I know th e 

General Service s Ad ministratio n hopes to at leas t restore t he o utside, 

which shouldn ’t be too difficult, so t hat it a t least looks good from the 

outside.

A deter mination will have to be made by the Congress and by the 

executive as to wh eth er to go forw ard with the a dapti ve and mu ltiple 

use of the buildin g.

The Na tio nal Coun cil on the Arts has discussed this on many occasions. It feels th at the Federal Government, in a cooperativ e effo rt 

of both Congres s and the executive, c an make a dete rm ina tion th at th e 

Governme nt of the U nit ed Sta tes would be m aking a statem ent, and a 

very s tro ng one, a bou t the imp ortanc e of a b uilding t hat was b rin ging 

life as well as beau ty to downtown W ash ing ton .

Se na tor Buckley. Did you find a gr ea t intere st among community 

leaders in this program ?

Miss H ank s. Community leaders, t here is no question abo ut it. Th e 

Pennsylva nia Av enue dev elopment p lan , while it addresses i tse lf to the 

no rth side of the avenue, has commented specifically th at it believes 

the old post office on the south side should be preserv ed.

Th ere are many gro ups, “ Don’t T ea r It Dow n,” and o the r grou ps in 

the community t ha t are very a nxio us to have th at b uil din g m ade usable 

by peop le in th at area. I would hope th at some day there wou ld be 

money enough to do it.

Senator Buckley. What about the W ill ar d H ote l ?

Miss Hank s. We were asked if we would tak e an inter est in the 

W illard Hotel. I happ en to have a per son al inter est in the W ill ar d 

Hotel. Wh en my mo the r first came to W ashing ton at age 3, she s tay ed 

there.

54 -18 8 0 - 75 — 3
30

On the other hand, I said to Mr. Lacy and to our associates that if we 

could work on one building, perhaps that was enough for this year.

Senator Buckley. I hope we can handle more than one at a time.

Miss Hanks. Sir, if you want us to work on the Willard Hotel, we 

will work on the Willard Hotel.

Senator Buckley. I think it would be helpful for the record if the 

four of you could give us examples of adaptive-use projects that you 

believe would set an example or pattern that might be of guidance in *

carrying out the bill, as well'as examples of multiple-use projects.

Miss Hanks. We would be happy to do so.

[The information requested follows:]

1 . Some Exam ples of Adaptive-Use P rojects

SALT LA KE CIT Y, UTAH

The use of thousands of square feet of abandoned trolley barns as an enclosed 

shopping mall has brough t about the reclam ation of one of the c ity’s dereli ct districts. The 67-year- old barn s cover a ten-acreblock known as Trolley Square. It 

houses almost 100 commercial tenan ts, including an open air ma rket, shops, offices, 

a gas statio n, and a movie theate r, all for an estim ated cost of $7 million.

BOSTON, MAS S.

Under the Massachusetts Housing Finan ce Agency, the block-long Chickering 

Piano Factory, buil t in 1853, was adap ted in 1974 to provide 174 uni ts of mixed 

income housing for ar tis ts and craftspeople with studio, gallery, and reh earsal 

space. By using exposed wood columns, brick walls, and electrical conduits along 

with othe r money-saving design features , conversion costs were kept down to 

$12.5 0/square foot—less than half the projected cost of sim ilar new construction.

CONCORD, N .H .

Based on alt ern ative feasibility studi es—one for new construction, one for 

adap tive reuse—the New Hampshire Sta te legisla ture decided to ada pt Concord’s 

Old Post Office building (18 84 ) for offices for legislato rs. Scheduled for completion 

in August, 1975, the ada ptation of th e French Renaissance stru ctu re will cost the 

State aroun d $4 million, compared with .$10 million for a new building providing 

comparable squa re footage.

BALTIMOR E, MD.

•

The renova tion of Baltimor e’s Old City Hall, scheduled for completion in the 

Summer of 1976, is projected to cost arou nd $30,0 00 per gross squa re foot. Compara ble city hall s built elsewhere recently have cost over twice as much. The 

adaptat ion of the 100-yea r old building will provide 85% more space for offices 

and ceremonial functions than ha s been afforded by the building in the past. •

2. Some Examples of Mixed-use Projects

NA SH VI LL E, TENN.

The first five floors of an $18 million sta te office building will house separat e 

music and dram a thea ters, a multi-purpose rehe arsal studio suita ble for aren a 

productions, and a sta te museum. Above will be 10 stories of offices for sta te 

agencies. Planne rs of the building, which is now under construction, were motivated not only by economy, but also by the belief th at multiple-use planning 

would generate nigh ttim e activity in th e capitol a rea.

WAS HI NG TO N, D.C.

The new Federal Home Loan Bank Board building will have store s on its 

first floor and mezzanine, providing 39,000 squa re feet in available public commerical space, and earn ing $529,000 per yea r in ren t payments.
31

NE W YOR K CI TY

The Acorn School, a pre-school, was built in “found” space on the ground floor 

of a New York City high-rise apartment building. The New York Education 

Construction Fund is planning a 5-story public grade school in an apa rtm ent 

tower on E. 87th St., as well as a commercial high school in a P ark Ave. and 34th 

St. high-rise.

Through special zoning variances for neighborhood needs, developers and the 

NYC Planning Commission came up with a mixed-use plan involving the aters in 

new office buildings. The Joseph E. Levine Theatre, the Uris Theatre, and the 

Paramount are all housed in new office buildings.

City/developer zoning negotiations also provided incentives for the soon-to-beopened Olympic Towers, 5th Ave. at 57th. Olympic Tower will provide groundfloor commercial, mid-section condominium apartments, and upper-level office 

space.

Senator Buckley. If you have any examples that come readily to 

mind, you might want to discuss them now.

Mr. L acy. Senator, the list is very long. I would pre fer to submit 

that for the record, if possible. We have numbers of examples listed 

in the “Federal Architectural Report” which you asked for copies of 

earlier. It is replete with examples that range from railroad stations 

to Federal court buildings to county courthouses.

It would be a simple matter to provide those for you. The San 

Francisco Mint is one example that GSA is very proud of.

Not all of these are Federal buildings that I am speaking of. They 

do provide an example of this entire movement of try ing to save what 

is best of this country’s architectural heritage.

Senator Buckley. Is it fair to say that a wide variety of structures 

exist that are soundly built and can be adopted for new Federal offices?

Mr. Lacy. Yes, sir, in this town alone, you only have to look at— 

which is perhaps the easiest example—Union Station, whether or not 

you agree with the purpose to which it is being put in addition to 

rail passenger service.

The old Executive Office Building, the Pension Building, the. 

Customhouse in New York City—there are any number of examples 

around the country. I think it is a very strong movement in this 

country at the present time.

We hear talk in the architectural profession, maybe wishful thinking, that by the end of the century, we will build an equivalent of 

another United States. I suppose our interest is in seeing that it won’t 

be at the expense of the first one.

Senator Buckley. Mr. Lacy, as an architect, have you thought of 

these in terms of energy savings?

Mr. Lacy. Yes, we have. We are a little frustrated, I suppose, at the 

lack of accurate information that would let us assess in a quantifiable 

way the exact cost savings in energy or dollars.

One of our next projects which we hope to undertake in cooperation 

with the National Bureau of Standards and other Federal agencies 

that have construction responsibilities is some way of measuring, so we 

do have an idea.

Prices fluctuate so quickly in terms of construction it is very difficult 

to say with assurance that, by reusing an old building, you really 

accrue great benefits in energy or money.
32

We believe i t is true and we th ink we have enough figures now th at 

we can make a case for that point of view.

Senator B uckley. O ut of curiosity, why is t her e a lack o f inform ation? Have the y not been concerned about ene rgy in the past?

Mr. Lacy. No; t his is a relativ ely new id ea, I believe, w hich accounts 

for the lack of inf orm ation. It is a very new notion, savi ng old bu ild ­

ings for new purposes. There has always been a certain am ount of 

activity ad ap tin g building s for new purp oses . The y normally have to 

be very substan tial buildings.

The pressure we experience in this time of progress, and of the 

hig her land costs and grea ter user exp ectatio ns is also new.

Senator Buckley. I wonder i f S enato r Grav el would proceed. I must 

step out to catch a phone call.

Senator Gravel [pres idi ng]. Let me pose one que stio n: W ha t kind 

of crite ria are you going to use f or leasing on the gro und floor ? Ob viously th at space is more valuable than other space in the b uil din g, so 

you are natur ally g oin g into the m arketplace. How would you proceed 

to do this?

Miss H ank s. Senator, I would like to mentio n a couple. It would 

seem to me t he National End owment for t he Arts would have in mind. 

Of course, this decision would defin itely be up to th e Gen eral Services 

Ad mi nis tration. I believe they have procedures t hat they w ould follow 

in th at connection.

We would assume th at the marke tplace would ope rate in t his regard. 

We would assume th at the lower floors wou ld be a t a h igher cost th an 

the up per floors. We would also assume, Senator , th at certain crite ria 

as to the appro pri ate ness of the typ es of commercial fac ilities in the 

building would be considered.

If the pur pose in a building were to make it more alive, in oth er 

words so it would n’t be a dead spot in town, it is en tire ly possible t hat 

some comm ercial enterp rises, like banks, as good as they might be, 

basically open at 9 a.m. and close at 4 p.m., the sam e as th e governm ent, 

might be res tric ted in the amount of space they ’re allowed to lease.

I can also think of oth er types of comm ercial enterp rise s th at have 

some success th at would not be ap prop ria te to the dignity of the 

gov ernment bui lding.

Senator Gravel. I wou ldn’t w orry so mu ch about the dign ity. I think 

we can add a lot of dignification bv allowing m ultiple use.

Miss Hanks. I do, too. But I was think in g of such thi ng s as some of 

the bookstores.

Senator Gravel. I would hope we would not have any ad ult 

bookstores.

Miss H anks. Yes.

Mrs. Ship ley. Before we close, I would like to mention the New 

T ork Customshouse which, as you know, has been a gre at example 

of the Federal Governmen t moving out o f a perfectly marvelous b ui lding in New York, which is perha ps an exam ple, as Mr. Lacy could 

tes tify, of a waste o f space, and g oin g into th e Boa rd of Trade Cen ter.

I his building , I believe, the New Yor k State Histo rical Com mission moved into it. It is being salvaged. But legislation such as S. 865 

would requ ire Commissioner Sam pson to br ing to the a ttention of the 

Customs people to try to work it out instead of m ovin g into the g reat 

new sky scra per.
33

Senator Buckley [presiding]. Someone had a lot of space and is 

tryin g to fiddle with it.

Miss Hanks. I think the point that the lady makes is very important. 

A our bill would encourage the Federal Government to be imaginative 

about adaptive use and multiple use. This is the important thing about 

it.

At the moment it can be done in some ways by hook and crook, by 

shifting property to States or local communities. But this would be the 

Federal Government making a statement about the importance of the 

adaptive use and reuse of our buildings that are important to our 

community and making them more useful to all our citizens.

That is again why I think it is the attitude you are proposing th at is 

so important.

Senator Buckley. That, of course, is the objective.

I thank you for your contribution to this hearing.

Before you leave, there is one other problem we would like to ask 

about. We will have testimony today that mentions possible problems 

with fire safety and facilities for the handicapped in older buildings. 

Do you believe these issues can be resolved in most of the buildings 

that might be adapted ?

Miss Hanks. I am absolutely certain they can. In some instances it 

will be difficult. Buildings with long steps leading up to them make it 

monumental. On the other hand, the National Endowment for the Arts 

feels very strongly that engineers and architects can make our buildings accessible to the handicapped.

I might mention, Senator, th at the National Council on the Arts felt 

so strongly about the importance of this some 2 years ago that it passed 

a resolution about making cultural facilities more accessible to the 

handicapped, and we have been working very hard on this.

As a matter of fact, among other things, we have programs that 

provide matching funds for engineering surveys to institutions that 

have difficulties in this regard.

Second, the council felt that perhaps the endowment was not moving 

as fast as it might in the total use of cultural activities and accessibility 

for handicapped people, and therefore they established a council committee, which is chaired by Jamie Wyeth, and the members are Charles 

Fames and Rosalind Russell.

Mr. Wyeth, who is chairman, felt the subject was so important that 

he asked his wife, Phyllis Wyeth, to work on this question for 2 or 3 

days a week, and she has been with us for the last 2 months and will 

have a report in, in June.

So it is something we feel strongly about. We feel it can be accommodated. It is a very important part of the legislation.

Senator Buckley. Thank you very much.

Is Mr. James Biddle here ?

STATEMENT OF LAWSON B. KNOTT, JR., EXECUTIVE VICE PRESIDENT OF THE NATIONAL TRUST FOR HISTORIC PRESERVATION,

ACCOMPANIED BY JOSEPH MOODY, DIRECTOR, LEGAL AND

LEGISLATIVE SERVICES

Mr. Knott. I am Lawson B. Knott, Jr., the executive vice president 

of the national trust. Mr. Biddle is away and I so informed the committee, I believe, earlier that he would not be able to be here.
34

I have with me Mr. Joe Moody who is direc tor of our legal and 

legisla tive services. We are pleased to be here on behalf of both our 

chair ma n and president and the 75,000 members o f t he nat ion al tru st, 

nationwid e, which includes some 1,500 member organiz ations w ith over 

600,000 members.

We feel very pleased to be here to s upport wholehearted ly this legislation. We so informe d Ch air ma n Randolp h on M arch 25 in a response 

for hi s request for a re po rt o f the bill.

We have filed with the comm ittee a brief statem ent . I will say th at 

we s up po rt each and every prov ision of the bill, inc lud ing those th at 

relate to the leas ing of space in governm ent building s for commercial 

purposes. Also those provisions tha t relate to the pr io r exam ina tion of 

the pote ntial of Feder al building s for con tinu ed use or f or other buildings of nationa l significance befor e bu ild ing new buildin gs.

I would like to comment parti cu larly on th at portion which relates 

dir ectly to the nat ion al tru st, and to say th at our endorsement o f section 3 of the bill relates to its fun dam ent al purp oses. We would be no 

less enthusiastic i f it should be amended to pro vide th at identif ication 

of existing buildin gs useful as Fed eral office space sh ould be m ade by 

othe r entities.

Se nator B uckley. Mr. Kn ott, would you app rov e o f the bro ade nin g 

recommended by Mrs. Shi ple y?

Mr. Knott. We would have no objection to that. We believe we are 

pa rti cu larly well qualified to do thi s work o bjectively for the Federal 

Governm ent. To do so would be a pub lic service th at we would be 

proud to provide and one which we believe in its bro ader con text was 

con tem plated when the Congress c hartered the national trus t in 1949.

But our su pp ort fo r the general concept would not be less if the 

Congress should seek to pro vide for its acco mplishm ent throu gh o the r 

qualified org ani zation s working indepe ndently of or in cooperation 

with nation al tru st.

Th at, Mr. Ch airma n, is the sum and substance of our position. I 

wou ld be h ap py to resp ond to any questions or observations.

Senator Buckley. T ha nk you very much. Yo ur full statem ent will 

be inc orp ora ted into th e re cord [see p. 37].

I would like to ask you, do you cu rre ntl y have the staff th at would 

enable you to underta ke t he kind of responsibility cited in section 3?

Mr. K nott. No; indeed, Mr. Chairm an. We do not have th at staff. 

Th e national trus t, essentially, in its early days, did acquire some 

muse um pro pertie s which it operates and continu es on a selective 

basis to acqu ire museum pro per ties, such as Ly nd hu rst in yo ur S tate.

Today , the na tio nal trus t is placing gr ea t empha sis on its c ata lytic 

role, assisting local org aniza tions and entities where the grassroots 

streng th of the p res erv ation movement lies.

We are aid ing those org ani zation s in moving forw ard , and in so 

doing, we have ope rated fo r several y ear s a c onsultant gr an t prog ram 

in which small amoun ts of money—$500, $1,000, $5,000—hav e been 

mad e available to local gro ups to employ arc hit ects and oth er spe ­

cia lists in th eir histo ric d istri ct p rog ram .

In t his and other pro gra ms , we hav e cre ated ove r a period o f y ears 

a gr ea t reserv oir of constan t manpower and exp ertise th at we know
35

is ava ilab le and c ould be b roug ht to b ear nat ion wide in a prog ram o f 

this type.

So while we do not main tai n a lar ge staff we are a str on g or ga ­

nizatio n, and have headquart ers staff o f some 120 peop le and an oth er 

150 nationwid e.

We are expanding , however, I might add. We h ave three reg ion al 

offices, begin nin g first on the west coas t, 5 years ago, then Chicago, 

then in New En gla nd. We e xpe ct two more in the South and So uthwest this yea r. So our staff outreach in the local areas is ga ining 

strength .

Senator Buckley. There for e, you would be able to do the job.

Mr. K nott. W e th in k we c ould ha nd le th e job.

Senator Buckley. Do you agree on the desirability of bro adening 

the defi nition to incl ude cu ltu ral as well as his tor ica l an d arc hit ectu ra l im po rta nt bu ilding s?

Mr. K nott. Yes.

Se nator Buckley. Ha ve you pa rti cipa ted in any prog ram s th at 

hav e involve d mu ltip le use or ad ap tiv e use ? Do you have any direct 

experien ce along these lin es ?

Mr. K nott. H ere aga in, Mr. Ch air man, in a catal ytic role. We are 

now worki ng wi th a pro jec t th at because of the lon g str ug gle and 

the pers iste nce of th e local peop le in S t. Louis, and with th e a id of the 

Gen eral Services Ad ministratio n, has gai ned a certa in amount of 

notoriety nationwid e. For more th an 10 yea rs, local int ere sts have 

been attempting to save the old pos t office b uilding; an d to pro vide 

for mult ipl e uses of th is old bu ild ing whi ch was designe d by the same 

arc hit ect who designe d the old Ex ecutive Office Bui lding he re in Wa shing ton. I t is a ve ry distinctive bui lding.

We have rec ently come to the aid of th e local people by pro vid ing 

for a gr an t of $15,000 to help the m up da te th ei r cost da ta so they can 

pro vid e the kind of inf orma tio n th at private lenders req uire in ord er 

to h elp finance the project.

In other words, quite often we are able to come in at a tim e when 

local intere sts have exh austed th ei r resources, and we have been able 

to help t hem move forw ard .

We p erf orme d such a role in the W ainw rig ht B uilding in St. Louis, 

and the W illard Ho tel in Wash ing ton . An d the Pr ud en tia l Bu ild ing 

in B uffalo, we hope to do the same thing.

Th is is an ind irect answer. Bu t t hrou gh our wo rk with local or ga nizations and con sultan ts, we have experienced th e joy and pride the y 

feel in prov idi ng for ad aptive uses t hat ha ve been m ade of some o f th e 

old buildings.

Senator Buckley. You are satisfied about the fea sib ility of the 

concept ?

Mr. K nott. Yes; indeed.

Senator B uckley. An d t he projec ts with which you hav e been associated met fire hazards a nd se curity stan da rds?

Mr. K nott. Yes. You would be intere sted to know th at we feel th at 

the case h isto ries t hat a re dev eloping in the field o f pre ser vation, both 

priva te enterpri se and , since th e 1966 H ist oric Pr eserva tio n Act, with 

the aid of the Federal Government, are very im po rta nt from an economic point of view—that we a re br inging tog eth er a grou p with the
36

cosponsorship of the U rban Lan d In sti tute, the Am eric an In stitu te of 

Archi tects, and several other organi zation s who are directly invo lved 

in the development of pro perties .

We are bringing them tog eth er in late Ju ly in Sea ttle. Ma yor 

Ulhm an of Sea ttle, working w ith private enterpri se, has been able to 

do a great deal in p ion eer ing the way for sa vin g w orthwhile building s.

It is for tui tou s th at I used the word “ pionee r” because it is Pio neer 

Square in Seattle t hat is such an exam ple of a da ptive use th at has been 

made, with the majo r and with local len din g ins titution s wo rki ng 

together.

So we have a conference scheduled and we will have publicity ou t 

on it a few days. We expect 300 or 400 peop le aro und the country to 

come to Seattle to discuss not only success sto ries, but some exa mples of 

fai lur es and w hy did the y fail .

In oth er words, we hope for a clin ical analy sis of some very ou tsta nd ing exam ples of pre ser vat ion by private enter pri se and by th e 

pub lic sector, too.

Senator Buckley. Th an k you. Tha t should be a very interesting 

conference. I am sure it will prove tremendo usly helpf ul to the Government. Th an k you very much.

Mr. Knott. Than k you.

[Mr. Kno tt’s statem ent follo ws :]
37

STATEMENT OF NATIONAL TRUST FOR HISTOR IC PRESERVATI ON 

IN SUPPORT OF S. 865 BEFORE THE SUBCOMMITTEE ON BUI LDINGS AND GROUNDS, COMMITTEE ON PUBLIC WORKS, UNITED 

STATES SENATE

MAY 19, 1975

Mr. Chairman and members of the Subcommittee, my name is 

Lawson B. Knott, Jr. I am the Execu tive Vice Presid ent of

the National Trust for Historic Preservation.

Created by act of Congress in 1949, the National Trust is 

responsible, among other specific things, for fostering 

public participa tion in historic preservation.

In behalf of our Board of Trustees, our officers, and our 

more than 74,000 members throughout the United States, I 

wish to express my appreciation for this opportunit y to 

appear in support of the pu rposes and objectives of S. 865.

We believe that the Con gressional mandate to the Adm ini ­

strator of General Services set forth in Section 2 of the bill

provides needed legislative policy d irect ion to assure accomplishment of the Congressional intent as to the purposes of

the bill.

The National Trust endorses the amendments which would be

made, by Section 4 of the bill, to Section 210 of the Federal 

Property and Administra tive Services Act of 1949, as amended. 

Consistent with the recent staff report of the Federal
38

Architecture Task Force established by the National Endowm ent 

for the Arts, these amendments would provide for the commercial, cultural, educational or recreational uses of the ground 

floor space in Federal office buildings where such uses will 

not disrupt the operation of the buildings. The many benefi ts 

flowing from the implementation of such a "good neighbor" 

policy by the Federal government are amply demonstrated by the 

experience of Canada and at the state and local levels of 

government in this country, as explained in the Task Force 

report and by Senators Buckley and Baker upon introduction of

the bill.

However, our more direct concern wit h the bill relates to 

the amendments which would be made to the Public Buildings 

Act of 1959, as amended, by Section 3 of the bill. Under this 

Section, the Administrator of General Services, when und ertaking a survey of public building needs within a geographic 

area, would be required to contract with the National Trust 

in order to identify existing build ings within such areas, 

including, but not limited to, those of architectural or 

historical interest suitable, whether or not in need of 

repair, alteration, or addition, for acquisition*to meet the 

public buildings needs of the Federal government. In addition, where such buildings are identified, but a public 

building project proposed by the Ad ministrator of General 

Services does not propose their acquisition, the prospectus
39

must include a statement of the economic and other justifi cations for not acquiring such buildings.

Senator Buckley said, in introducing the bill, that it would 

encourage the renovation and recycling of existing buildings 

for Federal office use, where appropriate, and that recycling 

what is worthy and well built in our archi tectural heritage, 

for use as Federal office space would produce many benefits.

We certainly subscribe to those views. As the Senator also 

pointed out, recapturing some of the beauty of the past would 

make our cities more livable by fostering continuit y and pro gress. By participating in Federal space need surveys in the 

manner provided by Section 3(3) of the bill, the National 

Trust should be able to identify many historic office and 

other buildings of the kind me ntion ed by Senator Buckley. 

Conversion of the interior of such buildings to meet current 

Federal space needs accompanied by restoration and preser ­

vation of their exteriors, should provide viable and economic 

alternatives to new construction.

While we have not made a study of the labor -intensity 

relationship between new co nstru ctio n and renovation and 

restoration, it is our information and belief thht restoration 

and renovation work produces considera bly more jobs per dollar 

expended than new construction.
40

Conversion, restoration and preservat ion of buildings, in 

addition to providing needed job opportunities, would salvage 

the energy initially expended in constructi ng the structures 

and, at the same time, conserve energy resources which might 

otherwise be dissipated in their demolition. The conservation of energy resources which would result from recycling 

the worthy elements of our man-ma de environmen t would, we 

believe, be significant.

We believe, further, that Federal leadership in a program 

of utilizing recycled historic structures for its own space 

needs, also would significantly stimulate state and local 

governments to pursue the same course of action in providing 

for their office space needs.

National Trust historic preservat ion activities are funded 

in part by Federal grants-in-aid provid ed by the National 

Park Service, Department of the Interior, on a 50-50 matching 

fund basis. The Trust's matching share is provided by memb ership fees and private donations of money or other property.

New subsection (c), which would be added to Section 7 of 

the Public Buildings Act by Section 3(3) of S. 865, is under ­

stood by us to intend that National Trust costs incurred in 

identifying structures suitable for government use wo uld be 

reimbursable under the terms of the contracts to be entered 

into with the General Services Administra tion and, thus,
41

would not constitute a drain on other funding avai lable to 

the National Trust which has never been adequa te to carry out 

all worthy preservation opportunities. I wish to emphasize 

that our general endorsement of Section 3 of the bill goes to 

its fundamental purposes and would be no less enthus iasti c if 

it should be amended to provide that identification of existing buildings useful as Federal office space was to be made 

by other entities. We believe that we are parti cularly well 

qualified to do this work objectiv ely for the Federal govern ­

ment and to do so would be a public service that we would be 

proud to provide. But our support for the general concept 

would not be dampened if the Congress should see fit to pro ­

vide for its accomplishment through other quali fied entities 

working independently of or in cooperati on w ith Nation al Trust 

There appear to be minor technical deficienci es in the bill 

which we have called to the attention of the Committee in our 

report of March 25, 1975, to Public Works Committe e Chairman 

Randolph.

We urge Subcommittee approval and C ongressional enactment 

of the measure which undou bted ly would favorably impact the 

prese rvation of buildings significant to America n history 

and culture throughout the Nation.
42

Senator Buckley. We will now call up the architectural pan el: Mr. 

Robert Burley of the American Institute of Architects; Mr. Peter 

Lawrence, program coordinator, Harv ard Graduate School of Design; Mr. Anthony Newman, executive director, New York Landmarks Conservancy; Mr. Jonathan Barnett, director, Urban Design, 

City University of New York; and Mr. Frederic P. Wiedersum, Fred ­

eric P. Wiedersum Associates, New York.

We seem to have, by some odd coincidence, a number of witnesses 

from New York.

Before you begin your presentations, I would note that I wrote to 

a number of architects, planners, local officials, and other, asking them 

to comment on S. 865. We received a number of answers, all of them 

positive. I would like to take this opportunity to place them in the 

record.

[The material referred to may be found in the appendix, p. 113.]

Senator B uckley. Shall we start with Mr. Burley ?

Gentlemen, you may either read your statement or put it in the 

record and comment on it informally. It is up to you. In any event, 

they will be incorporated in full in the record.

STATEMENTS OF ROBERT BURLEY, THE AMERICAN INSTITUTE OF

ARCHITECTS; PETER LAWRENCE, PROGRAM COORDINATOR,

HARVARD GRADUATE SCHOOL OF DESIGN; ANTHONY NEWMAN,

EXECUTIVE DIRECTOR, NEW YORK LANDMARKS CONSERVANCY;

JONATHAN BARNETT, DIRECTOR, URBAN DESIGN, CITY UNIVERSITY OF NEW YORK; AND, FREDERIC P. WIEDERSUM, FREDERIC

P. WIEDERSUM ASSOCIATES, NEW YORK

Mr. Burley. I am representing the American Institute of Architects. We do have a written statement which I would like to submit for 

the record. You will find that our testimony does in fact support the 

bill very strongly. I will not read our testimony but instead I have a 

series of slides which show actual case histories involving adaptive use 

and multiple public use of Government buildings. I would like to present the slides rather than going through our detailed statement.

Senator Buckley. Excellent.

[The statement appears a t p. 57.]

Mr. Burley. As you know, the Federal Government is not new to 

the area of historic preservation. We have already had mention of the 

Pioneer Courthouse in Portland, Oreg., which is a current example of 

Federal adaptive use. Also, the old U.S. Mint Building in San 

Francisco.

But in earlier years the Federal Government worked on adaptiveuse projects in Philadelphia and on a courthouse in St. Louis and other 

places around the country. Adaptive use is not a new experience for 

the Federal Government.

Multiple use within buildings is also not new. In 1939 Rockefeller 

Center was built in New York City, a classic example of office space 

on the upper floors and then public use at the lower or ground level, 

shops and restaurants, ice skating, theater, the kind of public activity 

which complements office use above. This was 1939.
43

Bu t it seems t ha t since th at time, pa rti cu larly a fter the war, we tore 

down large portio ns of our cities ’ existing structures. We discarded 

arc hitectur e and ait which we di dn ’t think were so attrac tiv e at the 

time, and we b uil t sometimes in th eir place trem end ously monotonous 

projects.

In man y cases these were pure housing or pur e shoppin g pro jec ts

• We seemed to forget th e m ultiple use concept. Th is slide shows fore ign 

exam ple and I won’t tell where it is in the interest of f ore ign relation s. 

Bu t it shows you how dull some rec ent pro jects can be.

In the seventies th ere seems t o be a resu rgen ce o f inte res t, n ot ju st in

• historic preservation but in adaptiv e use of buildings. We wou ld like 

to keep a b uildi ng like th is, which you are ce rta inl y not goin g to bu ild 

again. You have to find a good use fo r it so you can su pp ort it 

economically.

In th is case it is the Je fferson M ark et Cou rtho use in New York City. 

It was adapted for use as a lib rary. Cle ani ng up the brick work, 

carpeti ng the floors, ad din g good lig hting, and moving the lib rary 

equipment inside created an ad ap tiv e use th at was very reasonable in 

cost.

Prob ably the best known ada ptive-use pro ject which sta rte d in the 

late sixties is G hir adell i Square in San Fra ncisco , where m an uf ac turing and fac tory building s were turned into shops and othe r uses.

The c onstruction costs were pro bably $30 per square foot. C ert ain ly 

you could build retail space fo r the same pric e per squ are foot. I 

wouldn’t say there was a gr ea t cost sav ing in these bui ldings. Bu t in 

Gh ira delli Squar e, the excitement and space is so me thing which could 

never be duplicate d at a com parable cost per square foot.

I think a h ighe r qua lity , in fac t, has been achieved here by utilizing 

existing arc hit ectur al resources.

Next is the Cannery , also in San Fra ncisco , ano the r wareh ouse, commercial bu ild ing converted to office space, shops, and prov idi ng for 

hum an uses.

In tro du cing good fire stai rs, openin g the bu ilding s up, and m ultiple

• use are eviden t in thi s case. It mak es a very ple asa nt kin d of hum an 

env ironment.

An othe r very good example in San F ran cisco is the Showplace. T his 

is an ex isting warehouse building . It is the kind of a bu ild ing th at 

only a mo the r could love, I guess, when you look at the outside.

You might ask why more people don’t ad ap t these kin ds of bu ild ­

ings if it is economical ?

If you look at the Sho wplace before it was converted, it is a very 

dis coura gin g kin d of space.

Yet, on exa mination of the str uc ture, it is sound; it supp orts 100 to 

200 pou nds per squ are foot. It has a sp rin kler system in place. An 

arc hitecture, plannin g, and engin eering team with im agina tion took 

this kin d of space , sandblasted the existing str uc tur e, cleaned up the 

brickw ork and colum ns, and introd uced good lig hting, ca rpeti ng , and 

made it into a v ery ex citing cente r for fu rnish ing s and o ther uses.

Th is is adaptiv e use at a very low cost. I would guess between oneth ird and one -ha lf the cost of a new bu ild ing prov iding com parable 

facilities.

In Vermont, I can speak from very close experience because th is is 

my own office building , purch ase d 10 years ago for $8,500. We did
$15,000 worth of improve ments. Eve ryone in Ve rmont thou gh t we 

were crazy. W e ended up w ith 3,000 square feet a t $6.67 cost pe r square 

foot, one -ha lf or on e-thir d of w hat the cost would be------

Se nator B uckley. I s it fire proof?

Mr. Burley. It is not fireproof. It does n ot have a s prinkler system. 

It is v ery close to a tro ut stream so we can pu sh it in.

Bu t the space inside is very comfortable. We hav e ha d clie nts in 

from New 1 ork and Boston. The y would ra th er do business here than 

in a new commercial office building.

Also in Vermont we did a master pla n for the St ate of Vermon t. 

V e recommended th at th e St ate purchase the b uildi ng that you see on 

the rig ht, which is the old Pavil ion Hotel, bu ilt in 1875.

A ft er a feasibility stu dy, everyone tho ught it was a white elepha nt. 

We recommended they deve lop it into a museum. We showed how it 

could be pres erve d and the land scape imp roved aro und it ; an au ditor ium for public use.

Tbe build ing was actua lly reb uilt entire ly, b ut it was done at a cost 

of $27 a squa re foot at a time when totall y new’ bu ild ing constru ctio n 

cost between $30 and $35 a squa re foot.

I think in this proje ct and oth er pro jects th at the sav ing is usually 

in t he area between 20 to 30 percent over new’ constru ctio n. In some of 

the cases I showed, it wen t as high as a 60- or 70-percen t savings. I 

think, more realistically, it is between a 10- an d 3 0-percen t savings.

Th is State office bu ild ing in Ver mont has a veran da on it. It has 

rockin g cha irs outside. State employees eat lun ch the re. I think it is 

the o nly State office buildi ng in the country with a veranda.

Also, in Montpelie r, this slide illustra tes an old ap artm en t block 

with stores which used to be on the lower floor that ar e poorly pai nte d 

and poorly maintain ed. Th e o wners wanted to tear thi s down and pu t 

in its place a two-story office b uilding, at a cost of between $150,000 

and $200,000.

But the faca de was cleaned up, san dblasted, the cast iron pa rts exposed, the rig ht pa int colors app lied . The cost fo r adaptiv e pre ser vatio n work was about $80,000, certa inly less than half th e cost of p uttin g 

a sma ller new’ buildi ng in its place.

The space on the gro und floor was air- con dition ed. The basement 

space was u tilized. It had nev er before been used. It gave the owners 

offices f or an insurance com pany with very economical space.

One more example in Vermo nt, and th at is the Wind sor House, an 

old home. W ith the help of H U I) funds, a ma tch ing gr an t of $92,000, 

this bu ild ing was purcha sed by Historic Wind sor, tu rn ed over to the 

city of W ind sor , d raw ing s were done of how the building s ori gin all y 

looked, with a supermark et, chim ney, shutt ers , and every thing else, 

and a second sketch which showed what it could be when it was 

restored .

In fac t, the res tor ation has been completed. The bu ild ing looks, if 

anyth ing, bette r than the sketches did, and the cost, with elevato rs in 

place and first-class office space inside, will be about $25 or $26 per 

square foot. Again , definitely less than the cost of new’ constr uction.

The State bicentennial office is in th is build ing now. and th ere is also 

a resta uran t on the lower floor. So it is both ad ap tiv e and mu ltip le 

public use, really, within the building.
45

The n umber of projects of th is ty pe is i ncr eas ing in the priva te secto r across the c oun try. Th is is Brookfield Comm unity College. It is a 

barn which was con verted into a library .

Th is is a dep artme nt store in Dallas, Tex., ad ap ted fo r use as El 

Centro J unio r College. It m akes a very h andsome bui lding.

Sa lt Lak e City : some tro lley barns. Ag ain , t his is the kind o f space 

th at, when someone first looks at it, he wond ers wh at in the heck an yone could do with i t ; who could ev er like it ?

Yet, when you see thi s p roject in its completed form, agai n, it is very 

exciting. It has dozens o f huma n uses inside. It is very good use of a n 

existing s tru ctu re. I t certa inly perfo rm s a fun ction for the people in 

Sa lt Lak e City.

The Br ad bu ry Office B uilding in Los Ange les, ret urne d to office use 

and sho ps on th e lower levels.

The W ainw rig ht Bu ild ing , which has been m entioned, in St. Louis, 

Mo., cu rre ntly being re stored fo r State office use. Ag ain , the basic concep t is shops.

In A lbany, N.Y., the old Delaw are & Hudso n Ra ilr oa d Co. b uildin g 

now being adapted for the use of the St ate unive rsity comp ute r cente r an d other office centers.

Here in Wash ing ton , D.C., the Can al Square pro jec t just off M 

Street. Th is is a com binatio n of res torin g existing b uil din gs a nd combin ing them with new office str uc tures and shops. Basically , it does 

have offices on the upp er floors, shops, resta urants, an d pub lic activ ities 

on the low er levels. But it has a very good h um an scale, well execu ted in 

this case.

Of course, in Eu rope th e idea o f ada ptiv e-use pre ser vation has gone 

on fo r gen era tions and cen turies. In Am sterdam, where 90 percen t of 

the centr al busin ess di strict is on the National Hi sto ric R egi ster, so to 

spea k, it becomes pe rha ps a bit of a prob lem.

Yet, in Eu rope you see excellent examples of new building s, old 

building s, side by side, and it usu ally ma int ain s exciting p ublic in terest. These are real live co mm unities th at we see in Europ e.

In the Un ite d States, the tre nd is also stron gly in this direction .

Th is is Fou ntain Square in Cincinn ati, Ohio. Fo un tain Square has a 

series of p edest rian walkwa ys above th e street level, so you h ave a separa tio n of p ede strial traffic a nd auto mobiles.

Cro wn Cente r in Kansa s City, a new bu ild ing pro jec t for mu ltip le 

use.

I think at thi s time the re is a new excitement com ing int o arch itecture in citie s in the U nited States. It is a form of rediscov ery. You 

can see it in th e pub lic spaces. T hey are much more huma n, mucn more 

intere sting.

Th is has even gone as fa r as Fe de ral Po st Office signs. Th is is the 

most adv enturous one.

Se nator B uckley. Where is th at ?

Mr. B urley. I d on’t know where it is; unless it is in T rolle y Squ are, 

I would guess, in Sa lt La ke City. We have a numb er of ex perts he re 

and I think the y could pro bab ly iden tif y where the sign is.

Bu t we h ave accomplished some very handsome Fe de ral buildings. 

Th is is a Federal Reserve Bank in Mic higan. Bu t in th is case there is 

no p ublic use at the gro und level. We hav e restore d, v ery economically , 

existing bu ild ing s to new uses, as in t he case of the Show plac e.

5 4 -1 88 0 - 7 5 — 4
46

We have achieved e xci ting p ublic spaces in new b uildin gs. I th ink it 

is v ery logical to com bine adaptive use of new Fe de ral buildings, pu blic use of new hum an scales, and blend the m togeth er.

We, at the Am erican In stitu te of Archi tects, would like to see the 

Fe de ral Gov ernm ent dem onstra te the p ote ntial of th is process. Th ank 

you, Senator Buckley.

Senator Buckley. Th an k you, Mr. Bu rley. Tha t was extremely 

intere stin g.

Mr. Lawrenc e?

STATEMENT OF PETER G. LAWRENCE, PROGRAM DIRECTOR, 

NEW LIF E FOR OLD BUILDINGS

Mr. Lawrence. Senator, I am Pe ter Law rence, pro gra m dir ector 

fo r new life for old building s at the H ar va rd Gradu ate School of 

Design. I would like to ask th at my testimo ny be entered into the 

record, and I would like to offer a few rem arks .

Senator B uckley. Your state ment will, of course, be printed in full. 

(See p. 84.)

Mr. Lawrence. I t is a priv ileg e for me to be here in su pp ort of 

S. 865. I strongly e ndorse the purpo ses and intent of th is bill.

I also think there is very broad-bas ed su pp ort fo r the inten t o f t his 

legisla tion . My pr im ary interest is th e enc ouragement of con serv ation 

an d th e effective use o f the manmade environ men t.

I think th at the purposes of the legisla tion very strongly add ress 

this.

There are tw o poin ts here. The in ten t o f th e le gislation is to promote 

more efficient use of the N ation’s construction resources, wi thin a bro ad 

con tex t th at is not lim ited to the pre ser vation of few lan dm ark 

buildings.

Th e oth er is to fos ter the pre servation of building s of historic or 

arc hitec tur al significance. The point here is that building s of sign ificance should be given the first con sideration , bu t then very active 

con sideration should be given to oth er existing buildin gs, such as 

those which would no t fall in the assigned cate gory.

One o f my reco mmendations would be to str ength en the legislation 

to insu re th at this process would be follo wed—th at is, that oth er 

existing building s would be considered af te r first reviewing arch itec turally significant b uild ings.

Senator Buckley. Wo uld the word “cultu ral” be broad enough or 

not?

Mr. Lawrence. Senator , rather than attempt to do it th at way, 

the way I app roa che d it was to brea k it into two sections. After considera tion of wha t was deemed to be historically, arc hit ectur all y, and 

cultu rally sign ificant buildin gs, perha ps an addition could be mad e 

fo r a consideratio n of oth er existin g building s in the area that would 

prove prudent and feasible to pursue as office space.

I would like to discuss two examples in more d eta il, in terms of the 

economics. One is the W inthrop Squar e Bu ild ing , the old Record 

Am eric an Bu ild ing in Bosto n, which, I believe, provides an exam ple 

of the economic via bil ity o f m ixed use in a recycled structur e.

Th is building has been c onverted into office space with about 10 p er ­

cen t of th e tot al floorspace bein g commercial on the gro und floor.
The total cost for this work is $40 a squ are foot, inc ludin g acq uisitio n cost. Th e cost of new con stru ctio n on th at site du ring the same 

period of tim e would range from abo ut $70 to $80 a square foot.

One of the adv ant age s of the recycling process th at is pointed out 

in this proje ct is when the bu ild ing was completed, it w as alr eady 20 

percent rented. Today , i t is 60 p erc ent occ upied and 90 pe rcent rented.

I think this rapid ren t-u p proce ss pro vides an ad dit ion al advanta ge 

in the recycling process th at o fte n does not exist in new con stru ctio n. 

By being able to reno vate a sma ll portion of the building , one can 

show a pote nti al clie nt tha t he will be able to ren t ea rlier in t he process.

An oth er example is the proposed renovation of Union Stati on in 

New London, Conn ., a National Re gis ter p roperty . Th is will be renovated into 22,000 square feet of space and will retain its fun ction as 

an Am tra k Stati on , g iving Amtra k 5,000 square feet, at a total renovation cost of $28 pe r squ are foot.

The alternate proposal that, was considered for the site of the 

sta tion would have produced a 5,000-squa re-foot bu ild ing at a ra th er 

high cost of $100 per square foot. Th is would have given Am tra k 

less space fo r a high er rent. Amtra k would have gotten 3,000 square 

feet. The rent would have been hig her because they wou ld have been 

supp ortin g a larg er percen tage of the total space of the bui lding.

So wi th th is sta tio n you hav e an example of mixed use—a resta urant , railr oa d sta tion, two floors of office space, and a much high er 

quali ty spac e fo r a lower cost. You also hav e more spac e fo r Amtra k 

at a lower ren t.

I would also like to com ment th at I think the re is ex trem ely broadbased su pp or t fo r the conservation an d reuse of buildings. I think 

th at the re is a lar ge gro up of people th at view the conservation of 

build ing s as conserv ing valuab le resources of energy, tim e, capit al, 

and cra fts ma nship . Such peop le consider the destru ction of an y b uilding to be a waste.

I fou nd throug h the program new life for old build ing s and severa l other program s I am cu rre ntly doing at the School of Design 

th at the re is th is sup port. New life fo r old building s is attended by 

appro xim ate ly 200 city and tow n pla nners , architects, an d contract ors 

every T uesda y evening f or abo ut 3 to St y hours.

Th is is a series th at normally, as a conti nuing edu cation pro gra m, 

migh t draw 40 people. An othe r indicator of the inc rea sin g int ere st 

is at the Rhode Island School of Design where the gr ad ua ting class 

of arc hitec tur e s tud ents select th e proje cts on which the y work du ring 

the final 5 mo nth s o f the ir pr ogram .

Th is wou ld be a proje ct they are pa rti cu larly intere ste d in pu rs uing. Th is year, 75 percen t of the gr ad ua tin g stu dents chose t he preserv ation an d/o r reuse of existing buildings. La st year I th in k th at 

percen tage was pro bab ly aro un d 10.

I wo uld lik e to briefly comment on a couple of my p rop osals. I th ink , 

as I hav e said, in order to reflect more stron gly the in tent of going 

beyond the issue of his tor ica lly s ignific ant bui ldings, I recommended, 

with rega rd to section 12(c) of the Pu blic Bu ild ing Ac t, th at th is be 

addressed as two areas so th at the significant bu ild ing s were con sidered first and all oth ers were the n conside red. I also wou ld lik e to 

recom mend, as oth ers have, th at the mixed-u se con cept pos sibly be 

broadened to include space beyo nd the ground floor of the building .
48

To accomplish this, perha ps an amoun t of space equ iva len t to the 

gro und floor are a could be considered and , thu s, allow one to go vertic all y and use other floors. I think the sec urity problem could be 

covered in doing th is.

I w ould like to than k you very much f or givin g m e the opp ortun ity 

to comment on the bill and offer you these suggestio ns.

Se nator B uckley. T ha nk you, Mr. Lawrence.

I shall address some questions to the panel as a whole a fter we complete the ind ividual presen tations, as I wou ld like to follow up on 

several of t he matt ers you touched upon.

Our next witness is Mr. Newman. *

STATEMENT OF ANTHONY J. NEWMAN, EXECUTIVE DIREC TOR,

NEW YORK LANDMARKS CONSERVANCY

Mr. Newman. T ha nk you, Mr. Chairma n. My nam e is An tho ny J.

Newm an. I am executive direc tor o f the New Yo rk La nd marks Con ­

servancy, which is wo rki ng fo r preser vat ion and reuse of significant 

arc hit ectur al, histor ical, and cultu ral build ing s in New Yo rk City.

The bill curre ntl y under conside ration, S. 865, is in man y ways a 

model response to the challenges ent ailed by the need to integrate 

im po rta nt exam ples of our arc hit ectur al he rit ag e int o the lif e of to ­

da y’s com munities.

It presents an op po rtu nity for the Fe deral Government to s har e in, 

and to give leader ship to, the g row ing m ovement to recycle s tru ctu res 

which are of great importance to the com mun ities in which the y are 

located.

Th ere is increasing evidence t ha t th is recycling makes sense, n ot only 

esthet ically a nd env ironm entally , b ut also econom ically. T ha t is to say, 

we can conserve and reuse archite ctu ral ly significant buildin gs, make 

the most judicious use of dw ind lin g resources and energy supplies, a nd 

obtain att ractive and fun ctional space at costs which are gen erally 

significantly lower than the costs of dem olition and new constru ctio n.

With ou t the c onsideration of site a cquisition, which wou ld apply in ■

eit he r the case of rehabilitati on or new con struct ion , the cost of constru cting new office space in New York City will average $50 a square 

foot.

Broad ly spe aking, in the same ma rke t, assum ing basic str uc tural •

soundness, the cost per square foot of reh ab ilitated office space can be 

as low as $30 p er square foot, a difference of up to 40 percent.

Some reasons are imm edia tely evid ent. In reh abilitat ion work one 

is usually dea ling with existing fou ndatio ns, e xte rio r walls, a nd roof.

It must be remembered, tho ugh, th at th e reh ab ilitat ion of well-chosen 

build ing s will preserve , fo r th e general benefit, priceless and irre pla ceable exam ples of workm ans hip a nd ch aracter th at are ofte n contained 

in bui ldings th at the Government would be concerned with under the 

terms of t his bill.

The cost of reha bilitati on will na turally vary acc ord ing to the comple xity of the bu ild ing th at is under con sideration . But the cost can 

va ry in eit he r dire ction. It can be a hig h cost, as some of the examples 

shown th is morning demonstra ted, or the y can also be low costs.

The May issue of Fo rtu ne had an article on the Bu tle r Square in 

Minneapolis, a work house str uctur e th at was converted to mixed uses.
49

Office use was a sign ific ant par t of the new life for the building . The 

bu ild ing is bein g completed at the cost of $20 pe r s quare foot. I think 

it is rema rka bly low in to da y’s world.

A pa rti cu larly comm endable aspect of the bill is its rec ogn ition of 

the very str on g adv ant age s to be realize d from ma kin g fed erall y contro lled space availab le for commercial, cultu ral , edu cational, and recrea tional uses.

Not only would governm ent fac ilities become good and lively neigh ­

bors, b ut the inclusion of such activities could , indeed, be a dete rm ining 

fac tor in the via bil ity of the Gover nm ent ’s acquisition and opera tion 

of a p artic ul ar bu ilding.

In man y cases, older b uil din gs have within them g round floorspaces 

which are of ou tstan din g ch aracter but do not lend th emselves rea dily 

to office functio ns. The y would be ap prop ria te, however, fo r uses such 

as shops, pe rfo rm ing art s, gro ups librar ies , and othe r revenue-generating activities that could indeed enhance the viability of Fe de ral 

opera tion of the bu ilding.

A fu rthe r cons ideration th at T think ou ght to be included in the ultimate form of the bill is t he fac t th at many of the building s th at will 

come into consideration under the ter ms of the bill will be build ing s in 

heavily developed downtow n are as of the cities. A lot of these older 

building s will have unu sed develop ment rights.

Th is will be a great asset fo r the Federal Government in acquiring 

any such building s and will repres ent an im po rta nt tool fo r influencin g 

the f utur e developm ent of such dow ntown areas.

Se na tor Buckley. Could you expla in to me, in a lay ma n’s term , 

what th at means?

Mr. Newm an. Yes. If the bu ild ing which is chosen for its a rch ite ctural, cu ltu ral, or historic al me rit is 10 stories tall in an are a th at is 

generally chara cterized by build ing s of 35 to 40 stories, very simply 

spe aking, there are 25 unb uil t floors on tha t site.

Th e righ t to build those floors does belong to the own er of the site. 

In a pla n pu t forw ard by Jo hn Costonis, in a wor k entitl ed “Space 

A dri ft,” it was proposed those develop ment rig hts be detach ed from 

the site once it is determ ined the bu ild ing is worth prese rving and be 

mad e available to oth er are as of the city in a con trolled fashion so 

th at the pre ser vat ion of the bu ild ing from which the develop ment 

rig hts hav e been removed is fa irly certa inl y assured and the develop ­

ment righ ts can be applied in othe r are as where the local jurisd iction 

has d ecided th at th ey will no t comprom ise or destroy the cha racter of 

the othe r are a.

It is a concept which is r at he r recent and which has been applied in 

New Yo rk City and, to some ext ent , in o the r areas. T he most ou tst an ding example of its appli catio n in New Yo rk City is the South Stree t 

Seaport Museum, and. sep ara tel y, the New York City La nd mark s 

Prese rvati on Law allow s the lim ited tran sfer of dev elopment rig hts 

from a des ignated lan dm ark bu ild ing to an ad joining site.

I would suggest th at und er the bill being con sidered grea t considera ­

tion be given to the implication s of such unused dev elopment rig hts 

th at may accrue to the Government in its acquisition of significant 

pro pertie s, a nd th at the Go ver nment , wi th local jur isd iction s, w ork out 

imagina tive and effective way s of dea ling with those develop men t 

rig hts t hat will enhance the fu ture of the city in question.
50

I than k yon for th is o pp ortunity to comment on yo ur bill. On beh alf 

of the directors of the New Y ork La nd mark s Conserv ancy , I stat e o ur 

str on g support for the bill and congratula te you fo r the foresight 

which is evident in its concept and la nguage.

Se na tor Buckley. Thank you v ery much.

Mr. B arne tt, we have yo ur handiw ork here.

STATEMENT OF JONATHAN BARNETT, DIRECTOR, GRADUATE 

PROGRAM IN URBAN DESIGN, THE CITY COLLEGE OF NEW YORK

Mr. Barnett. I appre cia te the op ortun ity to come here and tes tify 

on S. 865, the Public Bu ild ing s Coopera tive Use Ac t of 1975. I am 

going to em ulate m y colleagues and ask th at the full text of t he statement I have prepare d for you be made a p ar t of the record. I will confine myself to a few comm ents drawn from th at. (See p. 69.)

I do think this is a sensible piece of legisla tion . I think it would 

work. I t represents an oth er very useful o pp ortunity for ad mi nis tra tors 

to work in a flexible way with complete urban problems.

I agre e with you, Senator Buckley, when you said in your in tro du ctory statement t ha t you di dn ’t see this bill as m irac le wor king. I think 

th at statement reflects a very just appre cia tion of the natur e of urban 

problems.

Th ere is no one solu tion th at anyone is g oin g to propose th at is go ing 

to work seemingly m irac ulous results. This bill is clear ly a u sefu l step 

and is some thin g th at will be helpful.

To my m ind, it is m ost useful because it promo tes tw o charac teristics 

of the city which are best described by the words “co mplexity” and 

“co nti nu ity .”

Com plexity is the essence of what cities have to offer, a l ot o f thin gs 

going on in small spaces. Wh en you introd uce a single-use building 

int o a complex fab ric, you are probably dim ini shing bo th its str ength 

an d its life.

Also, we h ave learned from experience, pa rti cu larly t hrou gh urb an 

rene wal, th at cities are com plex, living organisms. If you go in to a city 

an d remove large portio ns of its physical str uc ture, you cause a shock 

to the economic and social structu re of th e city.

Co nti nuity is the oth er general chara cte ristic. The effect of thi s 

leg isla tion is to promote continuity of activ ity between old and new 

par ts of th e city.

Th is bill’s grea t str en gth is tha t it rep res ent s a tool to F edera l and 

local adm ini str ato rs. I t will, however, require a dm inistrativ e i ma gin ation . I don’t know how you wr ite the need to exercise imagi nat ion into 

a b ill, and of course, there a re always imp edim ents to new procedures.

I would like to talk about two pa rti cu la r cate gories of buildin gs. 

One of them is old post offices. Wh en you look at the old building s 

which ought to be reused, many of them h ave tu rn ed out to be Fe deral 

build ing s in t he first place.

The Posta l Service, because it is phasi ng out centr al post offices in 

fav or of warehouse str uc tures on the ou tsk irts of cities, is going to 

hav e a lot of surpl us building s of high architec tur al qu ality.

Ju st as an exam ple, the Central Post Office in Buf falo o r the p osta l 

warehouse in Greenwich Village or to cite anoth er kind of Fe deral 

Bu ild ing , the customhouse in New York Cit y. I am not sure wh eth er
51

you sho uld do it th roug h this legi slation or not, bu t vou should perha ps 

con sider ad din g lan guage to thi s bill which would ask the Federal 

Adm inist rator to give priorit y to Federal building s of hig h arch itectural quality which are in the process o f bein g phased out o f their 

prese nt Federal use.

The oth er poin t 1 wan ted to make is abou t new Federal b uild ings. I 

th in k th at th e ollice bu ild ing as an a rch ite ctu ral f orm is no t ne cessarily 

the correct shape for a lot of Federal servic es because many Federal 

offices require a degree of public use, people using the buliding , which 

is much g reater th an you would experienc e in a norm al office building .

As a consequence, I think thi s bill should encourage the arc hitect 

as well as the Adm inist rator to rethin k the whole n atu re o f the space 

in which Federa l offices are located.

If you just t hink o f the resu lt of thi s b ill as, p erh aps, a su perm ark et 

at the grou nd floor o f a conventional F edera l buil din g, I think it w ould 

not be ap prop ria te.

If you look upon Governmen t services as som ething offered in a 

very accessible set ting, perha ps a sho pping mall, in which some of the 

othe r less accessible oflices m ay be off’ to the side, you may be talking 

about a very new a nd use ful sort of building.

I think a commendable effect of t his bill will be the opp ortunity f or 

th e professiona l to rethin k the whole na ture of wh at Federal space 

should be. I hope it is used t ha t way.

I am makin g a copy of my book, Ur ba n Des ign as Publi c Policy, 

ava ilable to you. I am no t ask ing you to make the entire book a par t 

of th e record. Pe rh ap s your staff m igh t w ant to look at the th ird chapte r which deals with the tra ns fe r question th at Mr. Newm an pointed 

out, and also ch ap ter two on Designing Cit ies W ith ou t De signin g 

Bu ilding s, which ta lks a bout m ixed use.

I would like to comm ent on a couple of queries you made th is mo rning. On the question of c ompetitive bids, you may not be able to sub ­

stitu te a new procedure fo r com petitive b ids, but it might be possible 

to add oth er admi nis tra tiv e crite ria besides cost: Strategic location, 

qu ali ty of the buil din g, the valu e of the space itself. Such c riteria can 

be pu t down on p aper, they can be used admi nis tra tiv ely .

Th e question of ene rgy saving, old build ings were designed when 

ene rgy was not as ava ilab le as it is today. If you use the old bu ild ing 

in the way it is origi na lly designed, if you close t he inter ior doors in 

the win ter, use the high ceilings and open the do ors in the summ er, i t is 

possible to say th at old building s are more environme nta lly sensible, 

and make bette r use of energy. It is conceivable th at an old building 

would be energy sav ing just by vir tue of its origi nal design.

I appre cia te the op po rtu nity to speak to th is bill. I commend it. I 

am very happ y to see it was introduced. I hope it goes forward.

Se nator B uckley. T ha nk you, Mr. B arne tt.

Mr. Wieders um.

STATEMENT OF FREDERIC G. WIEDERSUM, WIEDERSUM 

ASSOCIATES

Mr. Wiedersum. Th an k you, Mr. Chairma n. I hav e sub mitted my 

repo rt for the record and I would likewise, with everybo dy else, like 

to mak e just a few comments. (See p. 74.)
52

We are definitely in fav or of the bill. We feel th at historical and 

arc hitec tur al significant building s are wo rth y of the e ffort fo r arch itec tur al eng ine ering studies to determ ine their fu ture usefuln ess as 

Fed eral buildings.

I would like to make a statement th at I do not believe th at all b uildings studied are goin g to prove to be usefu l buildin gs. I do not believe 

th at every bu ild ing study is going to res ult into lower con stru ctio n 

cost. Bu t I do feel it is very im po rta nt to the arc hitectur al and engi- *

neering profession to be given the op po rtu nity to make these fea sibil ity studies. The professiona ls should stu dy t he space utilizatio n of 

the building , make a str uc tur al ana lysis, mechanical and elec trical 

stud ies of exis tin g systems. *

Many of the mechanical system s may prove to be obsolete and may 

have to be completely removed or rejuvenate d. How ever, if these s tu dies pro ve th at th e u ltim ate saving s in to tal d ollars spent f or ren ova tion 

rath er than new constru ctio n, and the re are these savings, then a decision for p res erv ation should prevail.

Ev ery effort should be made to recycle existing str uctur es throug h 

these detaile d valu e and life cycle analyse s by the profess ionals.

Pr ivate investo rs have found it prud en t to renova te existing stru ctures rath er th an to demolish them . W e have d em onstrate d in hospital 

design the economic adv antage s of rec onstr uctin g existing fac ilities.

Mu nicipalities have emb arke d on resto rat ion pro jec ts which have 

prov en to be successful. Some of them have been mentioned alr eady 

today. The Bo ard of Trade bu ild ing in Chicago is an exam ple.

Jefferson Ma rke t Cou rtho use in New Yo rk City, which was men ­

tion ed, was converted into a pub lic lib rary. Fort Sch uyler in the 

Bronx was co nverted in to a mariti me cente r.

T support the concept of prov idi ng commercial, cu ltu ral , edu cational , and rec reation al facilities in Fe deral building s for the follow ­

ing reasons: The fac ility can become revenu e-p rod ucing for the mu ­

nic ipa lity . The building s, through use. should gen era te an awareness 

of the value of our Federal office building s and the refore encourage 

the fac ility to become a focal poin t of th at com mu nity’s a ctiv ities. «

Th is concept has c ertain ly been successful and completed by priva te 

investors. Sh op ping ce nters have been related to office build ings. Th is 

has been done over and over aga in, not only in new building s but in 

renovated bui ldings. *

And the concept which GSA has now emb arked on a pro gra m of 

lease-back, whereby Federal agencies are leasing back from priva te 

investo rs space, I believe the inclu sion of commercial esta blis hments 

on the first or second or wha tever floors will encourage the priva te 

investor to go into a lease-back sit ua tio n with the Fe deral 

Governm ent.

Tn closing, I would like to compliment the co mmittee on introducin g 

this bill which T feel has such a significance on our arc hitec tur al 

heritag e.

Th ank you.

Senator B uckley. I would like to direct this question to the panel 

as a whole. Plea se ans wer as you wish. Mv question is abou t the lim itatio n in the bill on the rig ht to lease only on the bottom floor, the 

first floor. It has been suggested th at pe rhap s leasin g should be ex-
53

tended to the mezzanine or to the top floor. One witness suggested 

th at the equivalent of the first floor space be ren tab le at the discretion 

of th e G SA.

Do any of you care to comment on the need fo r gr ea ter flex ibility? 

If so, what sort of sta nd ards sh ould be app lied to pre vent GS A goin g 

into com petition with the com mercial office building s?

* Mr. Burley. I feel you should be in a position where you can lease 

space along what I would call a pr incipa l pedes tria n-w ay. Whethe r 

this occurs at the stre et level or basement level, or pe rhaps a level 

above the street, that would be the essential crite ria .

• If the space can also go throug h more th an one lay er vertically it 

permits a better, more fun ctional flow of people throug h the space. 

If it is accompanied by th is kin d of lease space, I th in k it will encourage this use.

Mr. Newman. I think there is anoth er con sidera tion which may 

go into arg um ents on beha lf of spaces of the build ing s being made 

availab le on oth er th an ground floors.

The bill men tions ma kin g space ava ilab le fo r commercial, cu ltu ral, 

educa tional , and recr eational facilities. M any of the organiza tio ns who 

would use space under those rubrics would be n ot-fo r-p rofit o rganizations who dep end on a great ma ny othe r sources for th ei r income and 

op erating expenses.

Groun d floor space is usu ally the most des irab le and is gen era lly 

the most expensive. If the organiz ati ons who would benefit fro m thi s 

provision in the bill could use othe r spaces in the build ing s which 

would be rentab le to them at less th an the hig h rat es for the gro und 

floor, I think th at would be a very beneficial aspect of the bill.

The crite ria for deter mi nin g which org aniza tions sho uld pe rhaps 

benefit from such less -expen sive-th an-ground floorspaces could be 

worked out by the nation al endowm ent, by State councils, or oth er 

associations which are famili ar with bu dge ts a nd ar ts and civic g roups.

Se na tor Buckley. Should space be m ade ava ilab le t o such gro ups a t 

less th an commercial costs?

Mr. Newman. I f th at is at all possible, I think th at wou ld be desira ­

ble. The offset could pe rhaps be fou nd in high er rents gen era ted by 

oth er spaces in the building.

# Mr. L awrence. Senator , I think, to continue with th is issue of 

space being adjace nt to majo r pedestrian access, this actua lly enables 

one to cha rge h igher ren ts because th is is the are a where the com mercial activ itie s would most pr efer to be located. Tn tu rn , thi s would compensate fo r the nom inal rents ch arg ed for the oth er spaces.

Bu t it w ould be in the best int ere sts o f the a dm inist rator to be re nt ­

ing ra th er t ha n locked into the gro un d floor, to be able to rent where 

the traffic is and the ref ore ch arg e th e rents.

Se na tor Buckley. Do you see any prob lems with the op era tors of 

priva te build ing s who might see the Government com pet ing un fa irly 

in th e r ental m ark et ?

Mr. Burley. I don ’t. I see no problem , ha ving done con side rable 

work with sho pping centers and retail spaces. A bre ak in conti nu ity 

rea lly hu rts all of the commercial space. It is esse ntia l to keep this 

pedestrian -way active and aliv e f or its full length.
54

If the Federal Gov ernment keeps space inac tive , i t is really a d et ri ­

ment to the economic viab ility of the comm unity.

Senator B uckley. Tha nk you.

Mr. Barnett. I would concur in the form ula tio n of the pedes tria n 

path. On the questio n of competition, I really d o think th ere are some 

differences between cities, the ren tal marke ts in cities.

Really, the purpose of th is bill is to give an option to the Federal *

admi nis tra tor . I ima gine t here will be situati on s it wouldn ’t be a pp ro ­

pr iate to do it. I would hope the re would be ma ny situations where it 

would be ap pro priat e.

Mr. Wiedersum. I have nothing to add . sir. »

Senator Buckley. I recall some y ears ago I was in a town meetin g 

in a very small town. Th e great bu rning issue was whether or not a 

majo r route should be rou ted throu gh the tow n or around it. Somebody got up and suggested th at traffic should not be confused with 

prog ress.

Is the re a me nta lity , you might say, of civic pride and so on th at 

would cause mayors and oth er city officials to resist the idea of recycling because i t would perpe tua te old building s instead of en coura ging new b uildin gs ? Is th ere such a phenomenon ?

Mr. Barneht. I think actually arc hitects have to tak e a certain 

amount of th e blame for this because each gen era tion of arch ite cts refuses tak ing f or gran ted concepts of th e p revious generation.

The previous gen era tion of arc hitects were pro mo ting the concept 

th at all new building s were sup erior to old buildings. Th e presen t 

gen eration of arc hitects doesn’t agree with this. The public accepts 

the formu lation of the previous gen eration and has to be talked out 

of it. I think the m odern arc hitecture started ou t as a concept of revolution th at would sweep away the past, but the profession to an exten t has g rown out of th is idea. I think it has an obligation to ed ucate 

the public. I have a feeling the public has never gone along with the 

profession. I have an uneasy feeling as an arc hitect th at any new 

bu ild ing is c onsidered by members of the pub lic to be a step backw ards 

from the old one. I wish th at weren't the case. In many cases it is an «

ina ccu rate descrip tion .

Senator B uckley. I g athe r from what Mr. Bar ne tt said e arl ier th at 

there may be som ething to the energy con servation aspects of thi s 

proposal but no t a large amount. Wo uld this lie the normal •

presum ption ?

Mr. Burley. I feel there is, in addition to the conservation poten ­

tia l of tra ditio na l forms o f b uild ings, which I think is fairl y obvious, 

the energy poten tial, in the c onservation of la lxir, materi als, e t cetera.

I think th at has been pointed out in some of the othe r s tate ments tha t 

have been placed in the record.

Senator Buckley. Now aday s any leg isla tion th at is proposed with 

the word “en erg y” in it is assured of much faste r atte ntion.

Mr. Wie ders um, you do some work in the are a of sm alle r cities and 

towns. Do you see a ny special prob lems or adv ant age s of th is general 

app roa ch in sm aller localities?

Mr. Wiedersum. No, I do n ot; excep t we do a g rea t deal of our work 

on Long Island. I do n't believe you are goi ng to find the num ber of
55

buildings—I know you are n ot—t hat you are talki ng about as you are 

going to find in th e cities.

One other thing that might be a lit tle more difficult. Th ere is some 

talk of a Federal office bu ild ing at Mitchell Field . I wonde r if the 

inclu sion of rentable space in a lar ge build ing on Long Isl an d would 

be as successful as it m igh t be in a city .

I think these are studie s th at the GSA and oth ers have to make to 

see i f all of the contents of this pro posal are a da pta ble to outside the 

cities.

Senator Buckley. I appre cia te that. The object, of course, is to expand th e options av aila ble to GSA bu t also requ ire them to go throug h 

the tho ug ht process of examinin g wh at is available .

In th at general context, most people th in k of build ing s in ter ms of 

th eir exterio rs. Ce rta inl y the charm a nd varie tv an d his tor ica l aspects 

ten d to be visual. Sho uld any specia l em phasis be placed on prese rving 

int eri ors for ada pta ble use ?

Mr. Newma n. I think , Se na tor Buc kley , t hat the q uestion certainly 

should be a p art of t he exam ining of any building , b ut that t he d ete rmination rea lly would res t on th e ind ivi du al qu ali ty of the buildin g.

Th ere are man y build ing s whose exteriors wou ld be significant in 

terms of development of a style of arc hit ectur e or in terms of bein g 

an im po rta nt component of a neighb orhood bu t wThose interio r is 

utterly irrele va nt to eit he r of those two fun ctions the bu ild ing might 

pla y. *

The best answer would be d ependent on th e m erits o f a building , the 

Custom House at Bowling Green in New Yo rk is a bu ild ing in 

which every possible e ffort sh ould be m ade to preserve significa nt p arts 

of the inte rio r. The y are as im po rta nt as a ny pa rt of th e exte rio r of the 

bui lding.

On the othe r ha nd, the F ed eral Office B uilding in Greenwich V illage 

is a ra th er str iking , com pelling bu ild ing from th e exterior , bu t the 

interio r is comple tely fun ctional, a nd w ith ou t any en ormous appeal a t 

all, an d I think t hat the re the concept of dev eloping a pro ductive reuse 

for the b uil din g should override any concern for the existing inte rior.

Se na tor B uckley. I f th is legislation is enacted, th e lan guage sh ould 

in effect emphasize the de sir ab ility of case-by-case ap praisal?

Mr. Newma n. Yes.

Se na tor B uckley. May I ask you gentlem en th is q ue sti on : Who do 

you believe would be the best agen cy or gro up to advise the GS A on 

poten tia l sites fo r adaptiv e use, or should we go to a bro ad ran ge of 

agencies and grou ps ?

Mr. B urley. Senator , I m ade th e recommen dation th at possibly this 

could be b road ened t o also in clude the A dvisory C ouncil i n its c apa city 

with State hi storic p res erv ation officers an d t he ir, in tur n, rela tio nship 

to local histor ica l commissions, a nd that perh aps a j oint ad visory relationship between the natio nal tr ust and the Ad vis ory Council migh t 

be explored.

Mr. Barnett. T would str on gly sug gest th at the GS A should consult in the localities involved with the staff of the pl an ning comm ission, and if there is a land mark pre ser vation comm ission with it as 

well. Th e expert know ledg e of wh at build ing s to save is likely to be 

cen tralized in those two kinds o f agencies.
56

Mr. Burley. I think the national trust as mentioned in the bill is a 

very good route to go for advice. But I would like to add tha t the 

American Institute of Architects has State preservation coordinators 

throughout the United States.

For this kind of information you need local or regional advice. I 

think architects would be very happy to work in some cooperative way 

to give information to the national trust or whatever route might be 

established to supply this kind of information to the Government.

Senator Buckley. Thank you.

Some people have suggested that adaptive and multiple use might 

invite problems with security, or problems with fire prevention, access 

for the handicapped, and so on. Do you see any partic ular problems in 

any of these areas ?

Mr. Barnett. I think there are problems. I think that as an architect, 

architects know how to solve these problems. I think there may well 

be administrative reluctance to any new procedure that may make a 

lot of trouble. I think local administrators are going to have to change 

procedures and have to do things they are not used to doing. The 

problem of wheelchairs and problems of fire safety can be solved if 

people will sit down and try to solve them.

Senator Buckley. What about security ?

Mr. Barnett. Again, there is so much variety in buildings tha t it 

is hard for me at least to generalize about it. I think tha t kind of 

problem can be solved also. It may mean rather unpleasant changes in 

the building, restricting access and so forth, but it can be done if it 

has to be.

Mr. Burley. As a very practical security matter, I think our experience has been that some of these adaptive use buildings—which are 

liked by the public, they really like to use these buildings—have less 

vandalism than in new buildings which the public dislikes.

Senator Buckley. Gentlemen, thank you very much. I appreciate 

your testimony very much.

Mr. Burley. Thank you.

[Mr. Burley’s, Mr. Newman’s, Mr. Ba rnett’s, Mr. Wiedersum’s and 

NIr. Lawrence’s prepared statements follow:]
57

THE AMERICAN INSTITUTE OF ARCHITECTS

PUBLIC BUILD ING S COOPERATIVE USE ACT OF 1975

*

A STATEMENT BY

ROBERT A . BURLEY, AIA

THE AMERICAN INST ITUTE OF ARCHITECTS

TO

SUB COM MITTEE ON PUBLIC BUILD ING S AND GROUNDS

COMM ITT EE ON PUB LIC WORKS

UNITED STATES SENATE

WA SHINGT ON , D .C .

»

M ay 19, 1975

♦

1735 NEW YORK AVENUE, N.W. WASHING TON, D. C. 20006 (202) 785-7300
58

Mr. Cha irm an , I am Robert A. Bur ley, AIA, member of th e Am eri can In st it u te

of A rc hi te ct s Board of D irec to rs an d a pra ct ic in g arc h it ect in Ve rm ont. To day

th e Am erican In st it u te of A rc hit ect s, the nat io nal so cie ty for th e arc hit ectu ra l

pro fe ssi o n , w is hes to expre ss it s str on g and e n th u sia sti c su pport for S . 86 5,

th e Pu bl ic Bu ild ings C ooper at iv e Use Ac t. We com mend the Com mittee for

Its consi dera ti on of th is Im po rta nt le g is la ti o n . »

The Pu bl ic Buildings C oo pe ra tive Use Act pr ov id es for conse rv ati on of the

n a ti o n 's bu ild in g re so urc es In a se n si b le m an ne r. The le g is la ti o n enco ura ges

th e w is e us e of fe der al arc h it ectu ra l and his to ri c re so urc es in or de r to In cr ea se

the a cti v e, dail y use of fe der al buildin gs on th e par t of th e p u b li c. No t on ly

does S. 865 e sta b li sh a br oa d fo un da tion for a more v it a l re la ti onship bet w ee n

the fe der al go ve rn men t and th e p eople , bu t it enco ura ges the adap ta ti on of

fe der al buildin gs so th ey w il l fu nc tion as in te gra l part s of th e urba n en vi ro nm en t.

Th is ex cell en t le g is la ti o n w ill a ls o co nse rv e our in cre asin g ly sc arc e en er gy

and m at er ia l re so u rc es.

Per hap s no on e wo uld dis agre e th at the obje cti ves of S. 865 ar e worth st ri vin g

to a tt a in . But ar e th ey re all y a tt a in a b le ? We beli eve th ey a re . We beli eve th at

the goals of th is le g is la ti o n ar e vali d and th at the m etho ds se t fo rth to att ain *

th ese goals ar e re ali sti c and p ra c ti c a l. We will do cu men t ou r su pp or t for S. 865

with a se ri es of sli d es and se le c te d , actu al c ase h is to ri es of m ult ip le - and a d ap ti v e- ♦

u se pro je cts which have-s ig n if ic an tl y co nt ribu te d to th ei r co m m unitie s.
59

WISE USE OF THE NATION'S BU ILD ING RESOURCES

The In stitu te ad vo ca tes the pre se rv atio n of sound st ru cture s In active use

wh en ev er po ssib le . Museum s and museum v illa g e s have a le gitim ate and

pro per ro le In ou r socie ty , bu t the bulk of arc hitectu ra l pre se rv atio n In the

United States sh ou ld consis t of buildin gs w hic h co ntin ue to f u lf ill the d a ily

needs of ou r co m m unities. G h lra d e lll Square in San Fra ncisc o Is perha ps

the be st kn ow n exam ple of adaptive -u se In the United Sta te s, ye t pre serv ationin -u se has been pra cticed bo th p u b licly and p ri va te ly fo r many years . European

c it ie s and town s offer co untle ss exam ples of h is to ri c pre se rv atio n throug h

a ctive -u se . The a ctive-u se co nc ep t sh ou ld be a fir s t p ri o rit y fo r obta in in g

fe der al work in g sp ac e, ra th er than ju s t an occasio nal a lt e rn a tive . S.86 5

wo uld giv e p re se rv a tio n-l n -u se , adaptive-u se, and m ultip le -u se the consid eration they deserv e.

CONSERVATION OF ENERGY AN D MATERIALS

The u ti li z a ti o n of buildin g m at erials w hic h have alrea dy been man ufac tured and

In sta lle d In e xis tin g stru cture s pro du ces an obvious sa ving s in m ate ri als , manufa ctu ring, and construction en erg y. Man y build in gs of sto ne and bri ck ma sonry

co nst ru ct ed gene ra tio ns ago are often more dura ble and of consid era bly

* better q u a lity than th at which we can af fo rd to build to day. Build in gs which 

repr es en t a le ss extra va ga nt te chnolo gic al ag e, w ith reas on ab le pro portio ns of

* windo ws to solid w a ll s , have de mon strated th e ir ec on om ic soundness In term s

of he ating and coolin g co sts . A single th ic kness of glass in a mo dem buildin g

allo w s tw enty tim es as much he at to be lo s t from the buildin g than an in sula te d
GO

ma sonry w a ll . Even w ith in su la te d gla ss, the ra tio is ten to on e.

PRESERVATION OF OUR NATIONAL HERITAGE

We tear down and bu ild an ew . We trade ou r herit age fo r new d ri v e -in fa c il it ie s ,

ta lle r b u ild in g s, or more parking sp ac es . We move from plac e to plac e w ith

incr ea sing ea se , bu t perha ps w ith In creasing lo ss of id e n ti ty . Yet many of our

c itie s s till pro udly dis p la y th e ir h is to ric de ve lopm en t as ev iden ce of the pe op le *

who crea ted them . Because our c it ie s are rich fa brics wo ven from many fr agile

th re ads, h is to ric build in gs co ntrib ute to the te xt ure of the co ntem po rary urban fa b ri c.

A GOVERNMENT FOR THE PEOPLE

T ra d itio n a lly, go vernment build in gs have been gia nt m onolit hic monum ents w hic h

shelter the bu re au crac y and e ff e ctive ly pr ev en t a v it a l and ne ce ss ary in te ra ction

be twee n governm ent and the pe op le. People appro ach government build in gs

only when they mu st; more of te n th ey sim ply tru dg e past.

S. 865 encoura ges fe dera l build in gs to remain ope n longer and we lco me pe op le for

a wid er va ri ety of pur po se s. As su ch , the le g is la ti o n encoura ges an increa se d

dialogu e be tween pe ople and go ve rnmen t. Build in gs w ith d a ily co mmer cial and

public a c ti v it y at the sidew alk le vel become v it a l pa rts of the urb an en vir on men t

rather than s te ri le , un approa chable fa ca des. *

COST SAVINGS

*

It is of te n im ag ined th at re st ora tion or re h a b ilita tio n of an olde r build in g in volv es

en dles s re pair and ex pe ns e. Th is has some tim es been the ca se , bu t only when

old er buildin gs we re restor ed piec em ea l or wh en som eone has trie d to co nv ert

them to an unsuitable use or to an appeara nce which wa s ne ver In tend ed .
61

Pra ctica l re sto ra tion and adaptive -u se have ga ined substa n tia lly in popula rity

du rin g the la st ten ye ars , both in terms of ow ner attitudes and pro fe ssio nal tr a in ­

ing and ex pe rie nc e fo r arc h ite cts , engin eers , contracto rs , and othe rs in vo lv ed

- in the re sto ra tion pro ce ss. Con side ra ble cre d it fo r the increa se in public

ac ce ptan ce of pre serv ation pro je ct s sh ou ld be given to the de mon stra tio n pro je ct s

au thor ized by the N ational H is to ri c Pre se rvat ion Act of 1966 or ass is te d by the

De partm ent of Hou sing and Urb an Dev elop men t.

Actua l case his to ries of adaptive- and m ultip le -u se docume nt the c o st- b e n e fit

ra tio of pr ese rv in g old st ru cture s as com pared w ith equiv ale nt new construction

costs . W hile the avera ge sa ving is from ten to th ir ty per cent, fin a n cia l sa ving s

of up to se ve nty pe r ce nt have been re co rd ed. In v ir tu a ll y ev er y ca se where an

old build in g has been preserved fo r a cti v e , co ntem po rary use , the pub lic respon se

has been overw helm in gly enth usia stic.

G hirard elli Square , an adaptive -u se of fa cto ry b u ild in g s , is one of the most

po pu lar attra ctions in San Fra ncis co. Cost sa vings we re no t sig n if ic a n t fo r the

pro je ct when com pared to the avera ge co st fo r construct in g new re ta il space at

the same tim e. But there is no qu estio n th at new construction in the same pr ice

range wou ld be un able to ac hiev e the same high q u a lity of urban sp ac e.

A daptive- and m ultip le -u se pro je cts need no t be la rg e to be econom ic ally adva nta -

« ge ou s. A private Vermont off ic e b u ild in g , o ri g in a lly a 1900 sc ho ol ho use , was

pu rch ased fo r appro xim ate ly $8,0 00, In cl udin g one acre of land and a trout stre am . 

$15,000 of im provem ents produced 3,0 00 square fe et of co m fo rtable , fr ie n d ly 

offic e sp ac e. A llow in g fo r the va lu e of the la nd, the ne t

54-188 0 - 75 — 5
off ic e build in g co sts to ta le d ap pro xim ately $6.6 7 per square fo o t, ab ou t

s ix ty pe rcen t le ss than the co st of co mpa rable constr uction.

An oth er excelle nt exam ple of ad ap tiv e use is a st ate offic e build in g in

M ontp elie r, Ve rm on t, re co ns truc ted from an old hote l structu re . The cost fo r

re build in g th is exis tin g hote l was $27 pe r square fo o t, at a tim e when new

offic e build in g construct io n was av erag ing $3 0-$3 5 per square fo o t. It is

perhaps the only state off ic e build in g in the country w ith a veran da and ro ck in g

chairs. Space is pr ov ided fo r state em ployee s to enjo y summer lunc he s al

fr esco. U nfo rtunate ly , the old shops at the st re et le ve l we re elim in ate d in

the re build in g. S til l, the pro je ct illu s tr a te s th at a governm ent buildin g can

preserve a very human ch ar ac te r and at the same tim e save construction money

and fu nction e ffi c ie n tl y .

The Show pla ce in San Fra nc isco is ye t an othe r excelle nt exam ple of adaptiveuse. The wa reho use stru ctur e wa s adapted fo r co ntem po rary use as an in te rio r

fu rn is hin gs showroom cente r. Sand-b la sting the exis tin g m ill- con str u ctio n

heavy tim be rs to a cle an, textured fi n is h and ex po sing mec ha nica l system s in

a st ra ig htforw ard manner has pro duced substa ntial adaptive -u se co st savin gs.

The pro je ct wa s completed at ab out one-t hird the co st fo r co mp arable new co nstr uction. The new lig h tin g comb ine d w ith the b o ld , wooden ch ar ac te r of the

origin al st ru ct ure has pro duced exceptionally a tt ra c ti v e , use fu l sp ac e.

We belie ve th at the Public Buildings Coope ra tiv e Use Ac t is a co mmon -sen se ,
63

pra ctica l piece of le g is la tio n w hic h cle a rl y ad dres se s the pote ntial fo r the

fe der al go vernment to de ve lop a more humane im ag e.

We wo uld recommend only one additio n to the le g is la ti o n . The re la tionship

be twee n fe der al pr op er tie s and the co mmun ity wou ld be fu rther streng then ed

if co oper ativ e impro vements and us es in cluded are as be twee n buildin gs and

str eets . Thinking h o ri zo n ta lly, as w e ll as v e rti c a ll y , gro und flo o r le vels might

be expanded to in clude pedes trian tr a ff ic le v e ls . C in cin n a ti , fo r exam ple , tes

do wn town w a lk s, sh op s, and o ff ic e en tra nc es at a le ve l above vehic ula r stre et

tr a ffic . Exam ples of majo r pedes tria n cir cu la tio n be low gro und are nu merou s.

In conclu sio n, we shou ld lik e to add th at arc hitects wou ld ap pear to benefit

more d ir e c tl y from pu sh ing aside the wor k of th e ir pred ec es so rs and en co urag ing

co mmission s fo r entire ly new fe dera l o ff ic e pro je cts . In a sh ort term se ns e,

th at may be tr ue. Ho wev er, we sh ou ld a ll re co gn ize th at Am erica has pro duced

man y gre at a rc h ite cts , pla nners , and b u ild e rs . To ge ther th ey have pro duced c it y

fa brics that are often sound and re usable , althou gh ofte n misun de rstood and unappre cia te d. Fe de ral governm ent de mon stra tio ns th at these cu lt u ra l and physic al

reso ur ce s can be w is e ly u ti liz e d w il l pla y a major ro le in the re v it a li z a ti o n of

our so cie ty . We encoura ge the fe dera l go vernment to un de rta ke th is leadership

ro le .

Thank you fo r the opportunity to ex pres s our vie w s.
G4

My name is Anthony J. Newman and I am executive director of the 

New York Landmarks Conservancy, a not-for-profit, tax-exempt 

orga nization working for the conservation and r e-use of buildings 

of architectural, historic or cultural merit.

Because of shortages in mone y and materials and because of the 

inflated costs of energy and labor, the past several years have 

seen a significant shift in the traditional development patterns 

in many of our cities. There has been a co ncurrent shift in the 

broad goals of those closely concerned with historic preservation.

A prime factor in this latter change has been the awakening of a 

general realization that the wholesale destruction of older bu ild ­

ings was consigning important parts of our history to the rubble 

heaps. Preservation, therefore, has evolved into a m ajor con sid ­

erati on in planning the future of our cities and to wn s.

Our perceptions of histor ic preservation have, indeed, become 

broader and more comprehensive. We no longer see valuab le arc hitectural expressions as buildings in isolation. We perceive them 

as important facets of a larger environment, as resources that make 

unique, essential and irreplaceable cont ributions — both visually 

and psych ologically -- to the hu manity and livability of our 

developed areas.

These changes in what has been called historic prese rvation are 

so great and the r ealization of the need for the qualities that it
G5

Anthony J. Newman 

Page Two

can bring to our lives is so strong that I would suggest it fitting 

that we cease speaking in terms of historic pres ervation and begin

to consider these activities under the rubric of architectural co nservation. Over the years, conservation has acquired a connotat ion 

of representing something that is needed and beneficial while p re ­

servation has about it an aura of the optional, desirable but not 

essential. Additionally, conservation implies keeping something 

alive and flourishing while pres ervation has the implication of 

keeping something from change.

Today's challenge wi th valuable olde r buildings is not to preserve 

them, intact, as they were 75 or 100 years ago. Rather, it is to 

keep those buildings, with all that is valuable about them, as vital 

and functioning components in a world of c hanging demands and tec hnologies. Briefly, old buildings must be made to serve new purposes

There is increasing evidence that this makes sense not only aes the tically and environmentally but also economically. That is to say 

we can conserve and re-use architecturally significant buildings, 

make the most judicious use of dwindling resources and energ y sup ­

plies, and o btain attractive and functional space at costs which 

are, generally, significantly lower than the costs of demolition

and new construction.

Without the consideration of site acquisition, which would apply in 

either the case of rehab ilitation or new construction, the cost of
Anthony J. Newman 

Page Three

constructing new office space in New York City will average $50.00 

per square foot. Broadly speaking, in the same market, assuming 

basic structural soundness, the cost per square foot of reh abi lit ated office space can be as low as $30.00 per square foot -- a d if ­

ference of up to 40 per cent.

Some of the reasons for this dramatic difference are immediately 

evident: in rehabilitation work one is usually dealing with existing 

foundations, exterior walls and roof. These savings are partially 

offse t by the premi um that is paid for doing work within the c on ­

straints of existing conditions. It must be remembered, though, that 

the rehabilitation of well-chosen buildings will preserve, for the 

general benefit, priceless examples of w orkmanship and character that 

are impossible to replace.

The costs of rehabilitation will, of course, vary according to the 

complexity of the buildi ng involved and the new use for which it is 

intended. These costs will vary in either direction. Butler Square 

in Minneapolis, the C onversion of a warehouse into a mixed-use building of which office space is a significant part, is being completed 

at a cost of only $20.00 per square foot.

The bill currently under consideration is, in Riany ways, a model 

response to the ch allenges entailed by the need to integrate imp ortant examples of our architectural heritage into the life of today's 

communities. It presen ts an opportunity for the federal government
67

Anthony J. Newm an 

Page Four

to share in and to give leadership to the growing m ovement to r ecycle structures which are important parts of the communities in 

which they are located.

A particularly commendable aspect of the bill is its recognition 

of the ver y strong advantages to be realized from making federally 

controlled space available for commercial, cultural, educational 

and recreational uses. Not only would government facilities beco me 

good and lively neighbors, creating feelings of accessibility about 

government properties, but the inclusion of such activities could 

be a determining factor in deciding, unde r the terms of this same 

bill, whet her or not federal acqu isition and utilization o f space 

in landmark buildings is practicable. In man y cases, older buildings 

have within them ground floor spaces which are of o utst anding ch ar ac ­

ter but are no t functional as office space. The ability to rent such 

spaces to revenue producing tenants such as restaurants, shops or 

performing arts groups will greatly enhance the viability o f governmental ownership.

Undoubtedly, man y o f the buildings that will be considered for 

acquisition under the terms o f the bill will be located in already 

developed downtown sections of large cities. Most older buildi ngs 

of a rchitectural distinction in such areas have unuse d development 

rights which will represent a valuabl e asset to the government upon 

acquisition o f such properties as well as an important tool for 

influencing future development in dow ntown areas. The disp osition
68

Anthony J. Newman 

Page Five

of such development rights is a matter to which great thought should 

be given. Here, too, is an additional opp ortu nity for the federal 

government to work with local jurisdictions to create ways of dealing 

with such unused development rights that will produce patterns of 

development responsive to the continuing need for the elements of 

humanity and livability in our urban areas.

The sponsors of the bill under cons ideration are to be congr atulated 

for the foresightedness which is evident in its conception. Speaking 

for the New York Landmarks Conservancy I respe ctfully urge your 

positive action.

Thank you.
69

Sta te m ent by Jo n ath an B a rn e tt , AIA, ATP

P ro fe ss o r and D ir e c to r o f th e G ra duat e Pr og ram in Ur ba n D esi gn, 

The C it y C o ll eg e o f Mew Yo rk

on

S. 86 5, th e P u b li c B u il d in g s C o o p e ra ti v e Use Act of 1975

b e fo re th e

Su bc om mitt ee on B u il d in g s and Gr ounds

Co mm ittee on P u b li c Works

of th e U nit ed S ta te s S en at e

May 19 , 1975
70

Mr. C hair m an, I a p p r e c ia te th e o p p o r tu n ity to come h e re to d a y 

to t e s t i f y on S. 865, th e P u b lic B u il d in g s C o o p e ra ti v e Us e A ct

o f 19 75 .

I b e lie v e t h a t th e l e g i s l a t i o n b e f o r e you i s so und an d 

w o rk a b le . I t w i l l p ro v id e a u s e f u l to o l f o r th e p r e s e r v a tio n

an d en hancem ent o f o u r c i t i e s .

S e n a to r B u ck le y s a i d , in h i s s ta te m e n t in tr o d u c in g t h i s 

B i l l , t h a t he d id n o t se e i t a s m ira c le w o rk in g . T h is re m ark 

r e f l e c t s a j u s t a p p r e c ia tio n o f th e n a tu r e o f o u r u rb a n p ro b le m s. 

Th ey a re co m ple x, t h e i r i n t e r - r e l a t i o n s h i p s a re ev en mor e co m ple x - 

an d by no mea ns f u l l y u n d e rs to o d . T h e ir s o l u ti o n i s u n li k e ly 

to b e fo und in a s i n g l e , se e m in g ly m ir a c u lo u s a c ti o n . I n s te a d , 

we have to t r y to s o lv e u rb a n pro ble m s by a s e r i e s o f s t e p s , 

o f te n r e l a t i v e l y sm a ll in th e m s e lv e s , w hic h o v e r a p e rio d o f ti m e 

ad d up to p r o g r e s s .

T h is b i l l se em s to me to r e p r e s e n t t h i s k in d o f u s e f u l s t e p .

The p e o p le who p la n an d a d m in is te r o u r c i t i e s h av e a g r e a t 

need to pro m ote c e r t a i n q u a l i t i e s o f u rb a n l i f e w hic h a re b e s t 

d e s c r ib e d by th e w o rd s ’c o m p le x it y 1

 a nd ‘c o n t i n u i t y ! C o m p le x it y i s 

th e e s s e n c e o f w hat c i t i e s h ave to o f f e r : th e c o n c e n tr a tio n o f 

a m u ltitu d e o f a c t i v i t i e s an d p o s s i b i l i t i e s w ith in a r e l a t i v e l y 

sm a ll sp a c e . At th e p o in t wh en a c i t y be co m es a c o l l e c t i o n o f 

o f f i c e to w e rs su rro u n d e d by p a rk in g l o t s , i t h a s l o s t many o f 

i t s v i t a l a t t r i b u t e s . I am n o t t a l k i n g a b o u t c i t i e s v e rs u s 

s u b u rb s , a lt h o u g h I am a p a r t i s a n o f c i t i e s an d I f e e l i t w ou ld
71

be f o o l is h to w r ite o f f o u r e x i s t i n g u rb a n in v e s tm e n t, ev en 

i f i t w ere p r a c t i c a b l e to do s o . As su b u rb s ta k e on u rb a n 

f u n c t io n s , th e y to o h av e to p ro v id e f o r a co m ple x v a r i e t y o f 

u s e s , th e y in e f f e c t be co me c i t i e s , w it h a l l th e p ro b le m s as 

w e ll a s th e p o s s i b i l i t i e s o f u rb a n l i f e .

We h ave le a r n e d th ro u g h h a rd e x p e rie n c e t h a t c i t i e s a re 

d e l i c a t e , v i t a l o rg a n is m s , an d t h a t d r a s t i c s u r g i c a l ch an g es 

can da mag e th e w hole u rb a n ec on om y, an d s o c i e t y . C o n tin u ity 

betw een p a s t an d p r e s e n t i s an im p o rta n t mea ns o f p r e s e r v in g 

c i t i e s , n o t j u s t b e c a u se o f s e n tim e n ta l a s s o c ia ti o n s - a lt h o u g h 

th e s e a re im p o rta n t - b u t b e c a u se change in c i t i e s sh o u ld be 

e v o lu tio n a r y .

Th e b i l l b e fo r e yo u w i l l h e lp l o c a l p la n n e r s an d a d m i n is tr a t o r s 

pro m ote b o th d e s i r a b l e u rb a n c o m p le x it y an d c o n t i n u i t y .

C o m p le x it y , by a ll o w in g F e d e ra l b u il d in g s to c o n ta in a g r e a t e r 

v a r i e t y o f u s e s an d th u s a s tr o n g e r web o f r e l a t i o n s h i p s to 

su rro u n d in g a r e a s . C o n tin u ity , by o p e n in g up new p o s s i b i l i t i e s 

f o r th e a d a p tiv e r e - u s e o f o ld b u il d in g s .

I s t r e s s t h a t t h i s b i l l ’ s g r e a t s t r e n g th i s t h a t i t r e p r e s e n ts 

a to o l to b e p u t in t o th e h an d s o f F e d e ra l o f f i c i a l s an d lo c a l

I

a d m i n is tr a t o r s , n o t a d i r e c t p r e s c r i p t i o n f o r a p a r t i c u l a r s e t

o f a c t i o n s .

I know fr om my own e x p e rie n c e a s d i r e c t o r o f u rb a n d e s ig n 

f o r New Yor k C ity , an d fr om my w or k a s a c o n s u lta n t in o th e r 

c i t i e s , t h a t s i g n i f i c a n t o p p o r t u n it ie s h av e b een m is se d in th e
72

p a s t f o r wan t of su ch le g i s l a t i o n , and i t w ill be u s e fu l in

th e f u tu re .

I sh ould lik e to c i t e two p a r ti c u la r c a te g o rie s of 

F ed era l b u il d in g s : o ld p o st o f f ic e s and new F ed era l o f f ic e 

b u il d in g s .

Downtown p o st o f f ic e s , many o f g re a t a r c h ite c tu r a l 

d i s t i n c t i o n , a re b ein g ph as ed out by th e P o s ta l S e rv ic e as 

i t m ov es; o p e ra ti o n s to w ar e- ho us e b u il d in g s in o u t- ly in g 

a re a s . To th e e x te n t th a t th is B i ll en coura ges o th e r 

F ed era l ag e n cie s to ta k e ove r th e se p o st o f f ic e b u ild in g s , 

i t i s perf orm in g an im p o rt an t fu n c ti o n . I f th e is s u e i s 

n o t a lr e a d y co vere d in o th e r l e g i s l a t i o n , I th in k th e Subco m m itt ee sh ould c o n sid e r ad din g la nguag e th a t wo uld en coura ge 

F ed era l a d m in is tra to rs to ta k e s te p s to in s u re co n ti n u ed us e 

o f im p o rt an t e x is tin g F ed era l b u il d in g s .

New F ed era l o f f ic e b u il d in g s sh ould be more th an o f f ic e 

b u ild in g s , as th ey ho use many s e rv ic e s whi ch re q u ir e g r e a te r 

p u b li c a c ce ss th an th e no rm al o f f ic e f lo o r . The p ro v is io n s 

o f th is B i ll sh ould en coura ge a r c h ite c ts and p la n n e rs to 

r e - th in k th e n a tu re o f th e se b u il d in g s . A su perm ark et on th e 

gr ou nd f lo o r o f a c o n v e n ti o n a l F ed era l b u il d in g wo uld pro bably 

be in a p p ro p r ia te . In c lu d in g some F ed era l s e rv ic e s in a b u ild in g , 

per haps li k e a sh op pin g m a ll , th a t c o n ta in s o th e r s e r v ic e s , 

wo uld p ro b ab ly make v e ry good se n se .
73

Fo r some more g e n e ra l o b se rv a ti o n s on p re s e rv a ti o n of 

old b u il d in g s and th e pr om ot io n o f mi xe d us e in c i t y c e n te r s ,

I sh ould lik e to r e f e r yo u to a bo ok th a t I ha ve r e c e n tly w r i tte n , 

e n t i t l e d : "U rban D es ig n As P u b li c P o lic y ." I am mak ing a co py 

of t h is bo ok a v a ila b le to th e Su b- Com mitt ee .

I g r e a tly a p p re c ia te th e o p p o rtu n it y to sp ea k in 

b e h a lf o f S. 86 5, whi ch r e p r e s e n ts an im p o rt a n t s te p fo rw ard , 

b oth s u b s ta n tiv e ly and in th e ap pro ach to urb an pr ob lem s

th a t i t r e p r e s e n ts .

Thank yo u v ery much.
74

ST ATEM ENT IN SU PP ORT O F

B IL L S . 865

PU BLIC BU ILDING S CO OPE RA TI VE USE AC T OF 19 75 "

BY

FR EDERIC G. WIED ER SU M, P. E. , PA RTN ER

WIEDE RS UM AS SOCIAT ES 

A rc h it e c ts -E n g in e e rs -P la n n e rs

V all ey S tr e am , Ne w Yor k
75

T h e fo llow in g s ta te m e n t in su p p o rt o f B il l S. 865 , " P u b lic B u il d in g s 

C o o p e ra tiv e U se A ct of 19 75" is b ein g r e s p e c tf u lly su b m it te d fo r th e r e c o r d 

M onday, M ay 19 , 19 75 by F r e d e r i c G . W ie d e rs u m , P . E . , P a r t n e r , W ie d e rs u m

• A s s o c ia te s , A r c h ite c ts , E n g in e e r s , P la n n e r s , V a ll e y S tr e a m , N ew Y o rk .

T h e le g is la tio n p ro p o s e d b y S e n a to r B u c k le y , B ill S. 86 5 w ou ld f u rth e r 

th e e ffo rt to p r e s e r v e c o u n tle s s b u il d in g s w h ic h , b e c a u s e o f th e ir h is to r ic a l 

an d a r c h i t e c t u r a l s ig n ific a n c e , c o n trib u te to o u r e n v ir o n m e n t an d e n r ic h o u r 

c u ltu r e . E q u a lly im p o rta n t, th e y m e r it c o n s id e ra tio n b e c a u s e th e ir r e h a b ilita tio n to s e r v e u s e fu l c o n te m p o r a ry p u r p o s e s is fre q u e n tl y e c o n o m ic a lly fe a s ib le .

T h e in te n t o f t h is B ill is n o t to c r e a t e 'm u s e u m p i e c e s ', bu t to r e ta in

a s e n s e of c o n ti n u it y in o u r li v e s by m a k in g th e b e s t u s e o f e x is ti n g s t r u c tu r e s

o f an h i s t o r i c a l n a tu r e . It is n o t so m u c h a c o n c e rn w it h th e s e s p e c ific m o n u ­

m e n ts o r b u il d in g s , but r a t h e r w it h th e li v in g c h a r a c te r o f u rb a n a r e a s , v il la g e s 

an d to w n s , w h ic h th e p r e s e n c e o f th e s e s t r u c t u r e s s e r v e s to im p ro v e an d r e i n ­

f o rc e . U rb a n d e s ig n , w h ic h t i e s in new an d old s t r u c t u r e s , ad d s in g r e a t

• m e a s u r e to an y e n v ir o n m e n t.

N a tu r a l la n d m a rk s , o fte n im p o rta n t d e s ig n e le m e n ts in c itie s , p re s e n t

* u r g e n t d e s ig n p ro b le m s in s c a le and c h a r a c te r fo r any ne w d e v e lo p m e n t n e a rb y .
W he n th e s e p ro b le m s a r e u n d e rsto o d an d s e n s itiv e ly h a n d le d , g ro w th an d 

ch an g e a r e a c c e p ta b le e v e n ts in u rb a n li fe .

W e a r e b eg in n in g to s e e th a t in th e d e s ig n of new b u il d in g s , w e ca n n o t

c o n ti n u e to ig n o re e x is ti n g co n te x t - th a t no t o n ly m u s t any new b u il d in g o r

c o m p le x r e s p e c t its s u rro u n d in g s but it o ft en m a k e s s e n s e to m a k e f re s h an d

in v e n ti v e u s e of f a m ilia r im a g e s fro m th e p a s t in th e d e s ig n of ne w b u il d in g s,

th u s e n la rg in g th e sc o p e of w h at an a r c h ite c t can a c c o m p li s h .

T h e c o n c e p ts of M r. B u c k le y 's B ill a r e b ein g s u c c e s s fu lly e m u la te d

th ro u g h o u t th e U n it ed S ta te s am ong both p r iv a te d e v e lo p e rs an d lo c a l g o v e r n ­

m e n ts . N ot only a r e t h e r e e c o n o m ic a l a d v a n ta g e s in th e re n o v a ti o n o f so und

h is t o r i c a l b u il d in g s , but w it h to d a y 's s p a c e p la n n in g an d d e s ig n te c h n o lo g y , 

th e a m o u n t o f u s a b le i n te r io r s p a c e can b e in c r e a s e d c o n s id e ra b ly w it h o u t

in te r f e r in g w it h th e a r c h i t e c t u r a l fa c a d e .

O ne su c h e x a m p le o f a c it y g o v e rn m e n t re ta in in g its h is to r ic a l an d 

a r c h i t e c t u r a l h e r ita g e is c u r r e n tly u n d e r c o n s tru c tio n dow nt ow n in th e C it y 

o f New Y o rk w h e re th e 2 4 - s to r y M u n ic ip a l B u il d in g is u n d e rg o in g e x te n s iv e 

i n t e r io r r e n o v a tio n s . T h e 6 l - y e a r old lim e s to n e e x te r io r w it h its r e c e s s e d 

p illa r s an d o r n a te d e ta ils w il l be re ta in e d u n to u c h e d . T h e 6 5 ,0 0 0 s q u a re fe et 

o f i n te r io r s p a c e c a lls fo r th e e li m in a ti o n of m a n y s m a ll o ffic e s an d th e 

re d u c ti o n of o v e r s iz e d c o r r id o r s in fa v o r o f la r g e o p en s p a c e s . T h e in te r io r 

w il l a ls o be c e n tr a lly a i r c o n d it io n e d , th e c e il in g s y s te m w il l b e a c o u s tic a lly 

tr e a te d an d new li g h ti n g an d plu m b in g s y s te m s in s ta lle d . W he n c o m p le te d , 

th e s t r u c t u r e w ill h o u s e an a d d it io n a l 1, 50 0 c ity e m p lo y e e s .
Z z

It has bee n pro ven in m an y in sta n c e s th at th e c o n str u cti o n co st of 

com p le te ly re novati ng an ex is ti n g , s tr u c tu ra ll y so un d buildin g p ro v es to be 

le s s expensi ve p e r sq u a re foot th an th e co st of n ew co n str u cti o n . Man y

• ow ners of exis ti ng off ic e buildin gs and h o te ls in our n a ti o n 's la rg e r c it ie s 

to o quic kly d e te rm in e th e ir buildin gs o b so le te . As co n st an tl y updat ed zo ni ng 

la w s al lo w fo r ta lle r an d la rg e r s tr u c tu r e s , th e s e ow ners se e on ly th e p o ss i-

«

b il it y of g re a te r p ro fit s th ro ugh ne w c o n str u c ti o n . T h u s, th e old s tr u c tu r e 

is te rm e d ex pen dable , th e re b y ad ding to th e sa d fa ct th at th e way to lo se a 

h e rit a g e c o m p le te ly is on e bu ildin g at a ti m e .

T he m a jo r fa cto r sh ou ld be to giv e e v e ry c o n sid era ti o n to exped ie ncy 

in dec id in g w hat to do w ith recy cli n g o ld e r buil d in g s, p a rti c u la rly if th ey a re 

unocc upie d fo r an y le ngth of ti m e . T he m ain enem y of re cy cli n g is ab an donm en t, 

fo r it is duri n g th e peri o d wh en m ain te n an ce is re la ti v e ly ab se n t th at old s tru c tu re s

m ay su ff er a p h y sic al deca y du e to w a te r dam age or w eath eri ng of u n p ro te cte d

su rfa c e s w hi ch , if left to d e te rio ra te fu rth e r co ul d re n d e r th e buildin g to o c o stl y

to re c y c le back in to th e m a in str e a m of our a rc h ite c tu ra l h e rit a g e .

T he k ey t o S en ato r B u ck le y 's L eg is la ti o n w it h re fe re n c e to th e p r e s e r ­

vat io n of h is to ric an d a rc h ite c tu ra l buil din gs wou ld be th e d eta il ed valu e and li fe

• cycle a n aly sis of th e s tr u c tu re in q u est io n by t h e A rc h it e c ts and E n g in e e rs.

T h ese su rv e y s o r a n aly se s w il l giv e th e G e n e ra l S e rv ic e s A d m in is tr a ti o n a

• d eta il ed d e sc ri p ti o n of t h e s tr u c tu r e 's li fe sp an as w ell as th e conditio n and 

adap ta ti on of t h e b u il d in g 's exis ti ng sy s te m s. T h ro u g h in novat iv e desi gn 

te ch n iq u es and th e devel opm en t of m o re so p h is ti ca te d eq uip m en t th ro ugh 

te chnolo gy, th e u se of ex is ti n g m ec h an ic al and s tr u c tu r a l sy ste m s co uld be 

re ta in e d , th e re b y re duci ng th e cost of re n ovati on and pro vid in g a m o re v ia b le 

p ro je c t.

54-188 0 - 75 — 6
78

W he n in c r e a s in g th e o c c u p a n c y of an e x is ti n g b u il d in g by re n o v a ti o n ,

A r c h ite c ts an d E n g in e e rs m a y b e c o m e in v o lv ed w it h co d e r e s tr ic tio n s a s w e ll 

a s s t r u c t u r a l re in fo r c e m e n t of fo u n d a ti o n s. T h e s e c o n d it io n s im p o s e a r e a l 

n e c e s s ity fo r r e s e a r c h an d fi eld te s ti n g o f e x is ti n g c o n d it io n s d u rin g th e *

p ro g ra m m in g an d p r e - d e s ig n p h a s e .

T h e re a r e m a n y te c h n iq u e s w h ic h p r o fe s s io n a ls can r e s o r t to in

r e s to r in g b u il d in g s w h ic h m a y a p p e a r to b e in a d v a n c e s ta g e s of d e te r io r a tio n .

F o r e x a m p le , th e u s e o f th e p o st- te n sio n c a b le s y s te m can e lim in a te c o lu m n s 

an d c r e a te m o r e u n b ro k e n in te r io r s p a c e .

O ld e r b u il d in g s w h ic h tr a d itio n a lly h a v e h ad h ig h c e il in g s a r e id e a l 

c a n d id a te s fo r th e u s e of d ro p p e d c e il in g s w h ic h , in a d d it io n to b ein g a r c h i ­

t e c t u r a l f e a tu re s , a r e h ig h ly p r a c tic a l to s e r v e a s a i r p le n u m s an d to c o n c e a l 

d u c tw o rk an d o th e r m e c h a n ic a l s y s te m s . T h e n a g a in , if a p p r o p r ia te , th e 

A rc h ite c t m a y d e c id e to le a v e th e s e s y s te m s ex p o sed to c r e a te an in te r e s tin g 

v is u a l a r c h i t e c t u r a l f e a tu re and at th e s a m e tim e r e d u c e th e c o s t of r e n o ­

v a ti o n . F ro m th e s e s u r v e y s o r a n a ly s e s , GSA o r th e A r c h ite c t w il l be a b le 

to a c c u r a te ly e s tim a te th e c o s t of c o n v e rti n g th e o b s o le te s t r u c t u r e in to a 

m o d e rn an d u s a b le F e d e r a l an d p u b li c f a c ility . D e m o li ti o n sh o u ld be th e

la s t r e s o r t . *

A ty p ic a l e x a m p le of a p ro je c t w h e re p r e s e r v a tio n an d re m o d e li n g 

o c c u r r e d jo in tly w as th e B o a rd of T ra d e B u il d in g in C h ic a g o , c o m p le te d «

s e v e r a l y e a r s ag o . M o d e rn iz a ti o n of th e 4 5 - y e a r - o ld s t r u c t u r e 's i n te r io r

s p a c e in c lu d e d th e re p la c e m e n t of e x is ti n g m e c h a n ic a l s y s te m s an d c o n v e rs io n
to an a ll - e le c tr ic e n erg y sy ste m . By dem o li sh in g in te rio r w all s an d in c o rp o rat in g m o d ern off ic e pla nnin g, th e ow ners w e re ab le to co n v ert an ad d it io n al 

18 0,0 00 sq u a re fe et in to ne w re n ta b le sp a c e. M o re im p o rt a n t, th e b u il d in g 's

e x te rn a l c h a ra c te r and b a sic s tru c tu re w e re p re se rv e d .

D em oli ti on of ol d fa c il it ie s of te n p ro c ee d s witho ut an y sin c e re a n aly sis

by ow ners of ex is ti n g s tru c tu re s . T he re a so n s fo r dem oli ti on a re oft en d e s ­

cri b ed as s tr u c tu r a l w eak n ess witho ut a s tr u c tu r a l a n aly sis ha vi ng been p e r ­

fo rm ed; th e hi gh c o st of re novati ng w ithout assem b li n g a c a re fu l e sti m a te ;

li m it ed li fe sp an of th e bu ildi ng d e sp it e th e fa ct th at c are fu ll y m ain ta in ed

s tr u c tu ra l im p ro v em en ts wo uld la st m any y e a rs ; and th e in ab il it y to adap t th e

b u il d in g 's in te rio r sp a c e to c u rre n t c r ite r ia , w hic h ca n fr eq u en tl y be o v e rco m e by a deta il ed sp ace a n aly sis .

P u b li cly ow ned buildin gs p re se n t a c le a r oppo rt u n it y fo r p re se rv in g

lo cal c h a ra c te r, an d whe n c are fu ll y an d c re a ti v e ly an al yze d th ey ca n off er

eco n o m ic al an d v alu able sp ace r e s o u rc e s . T h is re cy cli n g of a n eig h b o rh o o d 's 

h is to ric a l back gro und by p re se rv in g a vin ta ge buildin g no t on ly sa v e s th e 

li fe of th at p a rti c u la r s tr u c tu re , bu t m o re si g n if ic a n tl y it p re s e rv e s and 

enhan ces th e sta b il it y , unit y and id en ti ty of th e su rr o u n d in g com m unity.

An in te re s ti n g c ase in po in t is th e Je ffe rs o n M ark et C o u rt h o u se p ro je c t,

a New Y or k C it y la n d m ark on th e c o rn e r of S ix th Ave nu e and T enth S tr e e t in 

M an hat ta n, w hic h w as co n v ert ed in to a publi c lib r a r y in 19 67 . T he m o st

im p o rt an t ach ie v em en t w as th e b u il d in g 's fa v o ra b le im p act on th e im m e d ia te

su rr o u n d in g com m unity.
so

A G o th ic s t r u c t u r e , b u il t w it h V ic to ria n sty le d b r ic k in 18 75 , th e 

2 4 ,0 0 0 s q u a re fo ot b u il d in g , e m p ty an d n e g le c te d fo r fi v e y e a r s , w as 

to be d e m o li sh e d u n til a n e ig h b o rh o o d la n d m a rk -c o n s c io u s a s s o c ia tio n s u c c e s s ­

fu ll y c a m p a ig n e d fo r its p r e s e r v a tio n . I n iti a lly , th e c ru m b li n g co n d it io n of 

#

s o m e of its b ric k w o rk an d in t e r io r p la s te r , p lu s an e x tr e m e ly d e te r io r a te d 

ro o f co n d it io n w oul d h av e se e m e d an im p r a c tic a l a r c h i t e c t u r a l c h a ll e n g e .

«

H o w e v e r, d e ta il e d a n a ly s is d e te rm in e d th a t its b a s ic s tr u c tu r e , w it h 

a p p r o p ria te r e p a i r s , w ould p e r m it th e b u il d in g to m e e t a l l n e c e s s a r y s ta n d a rd s 

and code r e q u ir e m e n ts . I n te r io r s p a c e s , w it h c a r e f u lly p la n n ed a r c h i t e c t u r a l

an d m e c h a n ic a l d e ta ilin g , w e r e h ig h ly s u ita b le fo r l i b r a r y p u r p o s e s , an d

th e c o s t w as n o t c o n s id e re d e x c e s s iv e .

T h e w o rk w as p e r fo r m e d , in clu d in g r e p a i r o f b ric k w o rk an d in t e r io r

s t r u c t u r a l r e in fo r c e m e n t to m e e t th e d iffe re n t lo ad r e q u ir e m e n ts in a lib r a r y .

In a d d it io n , new m e c h a n ic a l, e le c tr ic a l an d f ir e p ro te c tio n s y s te m s w e r e

in s ta lle d in u n o b tru s iv e a r e a s , w it h cooli ng to w e r s p la c e d in t r u s s e s in s id e

th e p it c h e d ro o f an d a i r d is tr ib u te d th ro u g h c o n c e a le d g r i ll s . C onfi ned i n t e r io r

s p a c e s w e r e r e d e s ig n e d and ex p an d ed . F o r e x a m p le , p a r titio n s re m o v e d fro m

th r e e a d ja c e n t c o u r tro o m s c r e a te d th e la r g e m a in re a d in g ro o m .

T h e r e s u lt o f th is re c y c lin g h a s b een v e ry s u c c e s s fu l, n o t o n ly «

b e c a u s e th e d is ti n g u is h e d h is t o r i c a l n a tu r e of th e b u il d in g w as p r e s e r v e d ,

b u t b e c a u s e it h a s a ttr a c te d an in fl u x of d e s ir e a b le new c o m m e r c ia l sh o p s

and o th e r e n t e r p r i s e s w h ic h g iv e th e a r e a th e c h a r a c te r o f an u rb a n c e n te r .
81

M an y oth er s tru c tu re s in Ne w Yor k C ity ha ve ta k en th is re cy cli n g 

path . F o rt Schuyle r in th e B ro nx w as co nvert ed to th e M a rit im e C oll ege fo r 

th e S ta te U n iv ers it y of New Y or k ; th e fo rm e r O ff ic ers Club of F o rt T ott en

• h as bee n a Jo b C ore C en te r fo r th e p a st th re e y e a rs; th e old C unar d B ui ld in g 

at Bow lin g G re en in lo w er M anhattan , w ith it s G re at H al l, hav in g stoo d id le 

fo r so m e ti m e , w as le ase d to th e G overn m en t fo r u se as a P o st O ff ic e Sta tion

fo r so rt in g and m ail in g; th e old Q uee ns R e g is te r Bui ld in g is no w use d as th e 

G re a te r Ja m a ic a R edev elo pm ent off ic e in vo lv in g c u lt u ra l and o th er a ffa ir s;

and n u m ero u s o th er s tru c tu re s hav e been re cy c le d in cl udin g th e fo rm e r

B ro okly n F ire D ep art m en t H e a d q u a rte rs Bui ld in g w ith it s op en sp a c e s,

c u rre n tl y desi gned to b ecom e an ed u cati o n al fa cil it y , acco rd in g to pla ns

devel oped by Poly te chnic In sti tu te of N ew Y or k.

On e of th e m o st im p o rt a n t s tru c tu re s in th e ra c e a g ain st dim in is hin g

our a rc h ite c tu ra l h e rit a g e is th e re now ned W ai nw right Buildin g in St. L ouis ,

th e f ir s t m o d ern ste e l fra m e sk y s c ra p e r in th e w orl d, desi gned by L ouis

Sull iv an in 1890. A ft e r c o n sid eri n g v ari o u s a lt e rn a ti v e s, a desi g n com petiti on

w as he ld w hic h re su lt e d in th e d ecis io n to hopefu lly p re s e rv e an d re s to r e

th e 1 0 -sto ry s tru c tu re fo r S ta te off ic es.

T h e re a re vac an t m u lt i-s to ry buil din gs in m an y co m m u n it ie s th ro ugh

ou t our nati on whi ch w ere o rig in a ll y desi gned fo r m anufa ctu ri n g u sa g e. T h ese

• fa c il it ie s u su a ll y in co rp o ra te d la rg e op en a re a s th at wo uld be com pati ble

w ith th e off ic e sp ace u sa g e of to day . T he u ti li zati o n of th e lo w er fl o o rs co uld

e a s il y be co n v ert ed in to a sh op pi ng a rc a d e , re s ta u ra n t, re c re a tio n fa c il it y 

o r o th er c o m m e rc ia l sp ace.
U n ti l v e r y r e c e n tly , o ld e r in d u s tr ia l b u il d in g s did not a tt r a c t d e v e lo p e rs 

o f new c o m m e r c ia l a r e a s , y et th e s e old b u il d in g s h a v e g r e a t p o te n tia l fo r 

n e w b u s in e s s n e ig h b o rh o o d s , o ft en w it h a b u ilt- in p ic tu r e s q u e n e s s th a t is h a rd 

to a c h ie v e . T h e ir i n tr in s ic v a lu e s oft en a r e b o th a e s th e tic an d p r a c tic a l, fo r 

th e w a re h o u s e s o f th e la te 19 th C e n tu ry w e r e h a n d s o m e b u il d in g s o f a r c h i t e c t u r a l 

s tr e n g th a s w e ll a s s tu r d y c o n s tru c tio n , an d ev en t h e i r la te r c o u n te r p a r ts of th e 

e a r ly 20th C e n tu ry h a v e v ir tu e s th a t th e im a g in a tiv e ey e can fi nd.

F u r th e r m o r e , th e s e ol d b u il d in g s e n c lo s e a v o lu m e of s p a c e th a t can n o t

b e e c o n o m ic a ll y eq u a le d to d a y . T h e y a r e u n iq u e o p p o rtu n it ie s fo r c o n v e rs io n

to new and c o n te m p o r a ry u s e s . B old c o lo r an d g r a p h ic s , e ffe c ti v e la n d s c a p in g

and p la z a s can r e v ita liz e a n eig h b o rh o o d .

A ne w o ffi c e s t r u c t u r e p r e s e n tly u n d e r c o n s tru c tio n in lo w e r M a n h a tt a n in

N ew Y o rk C it y c o n ta in s th e f i r s t c o v e re d p e d e s tria n s p a c e to b e c o m p le te d

u n d e r new zonin g d e v e lo p e d b y th e U rb an D e s ig n G ro u p of th e D e p a rtm e n t of

C it y P la n n in g an d th e M a y o r's D e v e lo p m e n t O ff ic e . T h e s e s p e c ia l r e g u la tio n s

all o w th e d e v e lo p e r to in c r e a s e th e flo o r a r e a o f b u il d in g s in r e tu r n fo r p r iv a te

p u b li c a m e n itie s s u c h a s u n d e rg ro u n d c o n c o u r s e s , a r c a d e s an d p la z a s .

• W hen c o n tra c tin g a new F e d e r a l o ffi c e b u il d in g in th e fu tu re , th e in itia l

d e s ig n c r i t e r i a sh o u ld in c lu d e s p a c e a llo c a tio n s fo r p u b li c an d c o m m e r c ia l 

u s a g e , s u c h a s th e 2 3 - s to r y T is h m a n T o w e r B u il d in g in L o s A n g e le s w h e re th e 

f ir s t flo o rs o f th e o ffic e to w e r an d p a rk in g s t r u c t u r e a r e d ev o te d to c o m m e r c ia l 

an d sh o p p in g f a c ilitie s . T h is sa m e c o n c e p t, if u se d in a F e d e r a l o ffi c e b u il d in g , 

w ould p ro v id e add ed re v e n u e w h e re u n d e r th e p r e s e n t s y s te m no re v e n u e is 

a v a ila b le to c o u n ti e s o r s t a te s in w h ic h th e fa c ility is lo c a te d .
Gro und fl oor le v els sh ou ld be so desi gned th at th ey ca n be e a sil y 

ad ap te d to a te n a n t' s re q u ir e m e n ts . D esi gn fle x ib il it y in th e se a r e a s w il l 

al lo w th e ow ner to m ak e te nant ch an ges w ithout m ajo r co n str u cti o n a lt e ra ti o n s . 

T h is co nce pt of sp ace coord in ati on by th e ow ner wou ld , in th e w r ite r 's opin io n, 

be id ea l fo r u se by re ta il , ed u cati o n al o r c u lt u ra ll y -o rie n te d te n a n ts . By 

ad ap ti ng a re n ta l poli cy th at w il l be eco n o m ic all y a cc ep ta b le to th e su rr o u n d in g 

com m unity, a F e d e ra l fa cil it y w il l tru ly beco m e a fo cal po in t of t h at co m m u n it y 's

a c ti v it ie s.

It w as th e w r ite r 's p ri v il e g e to s e rv e fo r s e v e ra l y e a rs on th e R egio nal

2 Publi c A d v is o ry P a n e l on A rc h it e c tu ra l S e rv ic e s fo r G e n e ra l S e rv ic e s

A d m in is tr a ti o n duri ng w hi ch peri od he ha d th e o p p ort unit y fo r d is c u ssio n s

w it h panel m em b e rs an d GSA p e rs o n n el. T h is pro vid ed fi rs th an d in sig h ts in to

c u rre n t an d fu tu re n eed s in th e desi gn and co n str u cti o n of bo th ne w an d re novate d

F e d e ra l b u il din gs.

It m ay be a se n ti m e n ta l th ought, bu t o ur n a ti o n 's fu tu re p h y sic al

gro w th w il l be a re fl e cti o n of t h e p a st, gro w n m o re so p h is ti cate d only b e ca u se

o u r co m ple x so c ie ty dem ands ch an ge in a co n ti n u all y ch an gi ng w o rl d . As

a ll of u s, bo th th o se w hose a c ti v it ie s re q u ir e ne w sp ace, and th e A rc h it e c ts 

wh o tr a n s la te th at ne ed in to ta ng ib le s tr u c tu r e s , we sh ou ld o c ca sio n all y p au se 

an d a s s e s s th e in h ere n t valu es of wha t we a re do in g.

As su re ly as o u r need s w il l en d u re fo r a lon g ti m e to co m e, th e 

n ew est s tru c tu re co nta in in g th e b e st of m o d ern te chnolo gy w il l on e da y be th e 

su b je ct of d ecis io n by a fu tu re g e n era ti o n as to it s co ntinuin g val ue to so cie ty . 

W ith th at in m in d, we sh ou ld co n sid er bo th th e old an d th e ne w as equal ly 

e s s e n ti a l to o u r h e rit a g e .
84

Statem ent of P eter G. Lawr ence, Program D irector, New Lif e for Old

B uild ings, Harvard Graduate School of Desig n

It is a dist inct privilege for me to be here in supp ort of Bill S-865, the 

Public Buildings Cooperative Use Act of 1975. I stron gly endorse the purposes 

and inte nt of this bill and also believe the re is broad-based supp ort for such 

legislation. A stre ngt h of the bill th at goes beyond its stat ed purpose s is that 

it is based on the extens ive background work prepared by the Fede ral Architectur e Task Force of which Senator Howard H. Baker , Jr. is a member. The 

two task force staff reports, Federal Arch itectu re, Multiple Use Fac ilit ies and 

Fed eral Architecture , Adaptive-Use Fac iliti es provide detai led documentation 

of the case for enacting this legislation.

The purpose and int ent of this legislation is “to promo te more efficient use 

of the Nation’s con struction resources” w ithin a broad conte xt th at is not limited 

to the preservation of a few landm ark buildings, “to fos ter the pres erva tion of 

buildings of histo ric or arc hitectura l significance” by giving such buildings 

first conside ration when planning for the office needs of the Fede ral Government, 

and “to enhance the social and economic environment within and surro unding 

Fede ral office buildings” prim arily by encouraging the use of Fede ral office 

buildings for othe r uses, includ ing commercial, cul tur al, educational and recr eational purposes.

Passa ge of the bill will achieve many anc illary beneficial results. Several of 

these key points deserve review A mixed use approach in Federal office buildings 

will result in a lower tota l cost to the Federal Government due to the prop ortio nally higher r ents t ha t may be charged for prime commercial space, such as ground 

floor locations. Mixed use will also gene rate increased revenue for the city in 

which the building is located in the form of payments in lieu of taxes. Fina lly, 

by encouraging commercial activ ities and increa sing pede stria n traffic these areas 

will become safer.

My prim ary intere st is to encourage the conservation and effective use of the 

man-made environment. America has a large and valuable inventory of older 

existing stru ctur es, many of which are of arc hit ect ura l or histo rical significance, 

while othe rs are quite commonplace. The loss of any of these buildings serves to 

destroy a quality of ma terial and labor craf tsm anship which can never be 

replaced. The reuse of older buildings, whene ver possible, preserve s a rich and 

varied arc hitect ura l her itag e and conserves scarce resou rces of materials, energy 

and ca pi ta l: we are living in a tightly constrained economic and ecological environment, and we must eliminate senseless consumption, and being co nservative 

of our existing resources.

While introd ucing S-86 5 on Februar y 27, 1975, Senator Buckley stated that 

the inte nt of the bill is “not an effort to pick an occasional historic building and 

then renovate it.” He anticipa tes th at opportunities will be found for the renov ation of many older, run-down buildings for Federal use, and I strong ly agree. 

Adoption of a Fede ral buildin g policy which encourages the reuse of existing 

buildings will spu r Americans to protect, preserve and mai ntain the man-made 

environment, and help us main tain a sense of continu ity with histo ry and scale 

in our urba n areas.

The reuse of exis ting buildings for office space and the development of mixed 

use buildings are concepts that have recen tly been gaining wider acceptance. 

There are many excellent examples which at test to the gre at potential of this 

approach. I would like to describe several partic ula rly significa nt examples of 

the applica tion of these concepts.

One Winthrop Square, the old Record American Building, in Boston is an 

excellent example of the economic viability of mixed use in a recycled stru cture. 

The arc hite cture firm of Childs, Bertman, Tseckares converted the buildi ng into 

modem commercial and office space l ast year. An extremely successful underta king, t his project shows th at reused buildings can provide economic advantages to 

developers and be highly marketable.

The cost of the renova tion work was $32 per squa re foot. The tota l cost of 

the project, including the acquisit ion price, was $40 per square foot. The cost 

of new construction of compa rable quality performed durin g the same time period 

plus the acquisition price of the site would have been about $70- $80 per square 

foot. One half of the ground floor, about 10% of the tota l space, is commercial 

and rents for about $11 per square foot. The arch itec t, Charles Tseckares, points 

out that if the building were located in the cent ral commercial area, the ground 

floor rent s would be higher. The remaining 90% of th e gross space of this building 

is utilized for offices and rents at about $9 per squa re foot.
85

When completed in October, 1974, the building was already 20% rented. Today 

it is 60% occupied and 90% rented as ten ant s complete the finishing of inte rior 

spaces. Such recycled space enjoys strong acceptance in the marketplace. Rapid 

rent-up allows the developer to achieve a quick return on invested capit al. Typically, rent-up in this project is more rapi d tha n is normally experienc ed with new 

constru ction. Furth ermore, the mixed use concept benefits the ten ant s and 

the visiting public. New life and vita lity has been brought to an are a where litt le 

commercial activity existed previously.

The proposal for the renovation of Union Station (New London, Connecticut) 

by the Boston arch itec ture firm of Anderson Notter is an excitin g example o f the 

conversion of National Register prop erty into office and commercial space. This 

22,000 squa re foot building, designed in 1895 by H. II. Richard son, will retain 

its function as an AMTRAK station and will also provide several floors of office 

space and a restau ran t. The cost of this renovation proje ct will amo unt to about 

$32 per squa re foot, there being no a cquis ition cost for the pr operty .

The alt ern ate proposal to the City Development Authority for the site of Union 

Stati on would have cost about $100 per squa re foot to construct a concrete block 

structur e. Of the 5,000 square feet proposed for the new building, abou t 3,000 

square feet would have been utilized bj’ AMTRAK. The current reuse proposal, 

however, will provide AMTRAK wit h 5,000 squa re feet of hi gher q uali ty space at 

less rent. Lower ren t is possible because AMTRAK will utilize a smal ler percentage of the tota l space in the building.

While this reuse proposal creat es more space for less cost per squ are foot, it 

also involves a gre ate r total proje ct cost. The larger t ota l inves tmen t will infuse 

more c apit al into the New London area. Gre ate r tax revenues will also be cre ated 

for the city because of the fa r gre ate r volume of commercial space in the reuse 

proposal. New London will benefit from an expand ed tax base. The investment 

will provide jobs for the construction indu stry while the visiting public and 

employees will bring life to the rem nan ts of an importa nt tra nsp ort ation n etwork, 

perha ps encouraging gre ate r use of AMTRAK services.

Many small business owners pref er to locate in existing buildings because the 

aestheti c and nostalgic value of older buildings enhances the ir ability to create 

customer appeal. Increasingly, small busines s owners are seeking locatio ns in 

older buildings realiz ing tha t these buildings possess unique qualitie s and 

amenities which are extremely expensive or impossible to duplicate in new 

struc tures.

One such company is the Boston confectionery firm of Baile y’s which has 

always estab lished its reta il stores in older buildings. Fra nkl in Wyman, Jr., the 

prese nt owner of Bailey’s, has stated, “I believe . . . strong ly in leasin g older 

Boston buildings and those in the subur bs th at have escaped urba n renew al.” A 

recent arti cle in the Christian Science Monito r described Mr. Wyma n’s reasons 

for wanting to utiliz e older buildings. These stru ctures, he said, exhibit a “touch 

of hist ory” and engender respect for both the buildings and the pas t accomplishments of the city.

I would like to reinforce something many of us here realize, but which many 

othe rs do not—the re is extremely broad-bas ed suppo rt for conservation and 

continued use of exis ting buildings. Reuse is not merely a passing fad or the 

cause of a vocal few. Many people realiz e th at these buildings were often constru cted in a unique fashion, making the struct ure s irrepla ceable repr esen tatives 

of our past. People appreciate the qualitie s of scale and harmony with the su rroundin g env ironment th at old buildings provide. This suppo rt is con sidera ble an d 

growing as is evidenced by the increase d membership in the Natio nal Tru st for 

Histo ric Preservation.

In addition, more and more people are beginning to view older buildings as a 

valuable resource of energy, time, capi tal and craftsma nship . Such people consider the destr uctio n of any buildin g to be a waste. To them reus ing these 

resources ju st makes sense.

Robert Campbell, an associate of the Cambridge architect ure firm of Sert 

Jackso n and arc hitectura l critic for the Boston Globe, stat ed recent ly at Ha rva rd 

that almos t all the mail he receives from read ers is overwhelmingly negative 

about new development projects, especially the large scale projects. Conversely, 

readers respond quite positively to the arti cles he has wri tten abou t renovation 

projects.

Sentim ent in supp ort of building reuse is a lso growing among p rofessionals. T he 

seventeen week course, New Life for Old Buildings, which I am cur ren tly directing through Continu ing Educatio n at the Ha rva rd Gra dua te School of Design, is
86

being attend ed by two h undre d city and town planners, co ntra ctor s and architects. 

Normally a Continuing Educa tion program might draw’ only forty people. The 

New Life for Old Buildings program has received requests from unive rsitie s 

throu ghout the country th at also wish to establish similar programs.

At the Rhode Islan d School of Design, the gra dua ting class of arch itec ture 

stud ents select projects on which they work during the final five month s of the ir 

program. Over 75% of the studen ts in this year’s gradu atin g class chose proje cts 

rela ting to preservation and reuse of old buildings.

In order to reflect more effectively the purposes and int ent of this legislation, 

I respectfully propose th at the Committee consider the changes listed below.

Insert the words in parentheses and strike what has been omitted so th at 

Section 12 (c ) of the Public Buildings Act of 1959 page, Lines 4-12 of thi s bill is 

amended to read as follow s:

“ (c ) Whenever the Adm inis trator undertake s a survey of the public buildin g 

needs of the Federal Government within a geograph ical area , he shall (seek 

recommendations from the Advisory Council on Historic Pres ervatio n and the 

National Tru st for Histo ric Pres erva tion to identify any exis ting buildings within 

such geographic are as which are of archite ctural or hist oric al intere st which 

would be suitable wheth er or not in need of repair, alte rati on, or addition, for 

acquisition or purcha se to meet the public buildings needs of t he Fede ral Government. (Should such significa nt buildings not prove feasible the Adm inist rator 

will actively consider othe r exist ing buildings whet her or not in need of repair, 

alte ration, or addition, for acquisition or purch ase to meet the public buildin gs 

needs of the Federal Govern ment.) ”

The duties of the Advisory Council include commenting on Federal und ertakings havin g effects upon properties listed in the National Register of Historic 

Pl ac es ; coordinating Federal, State, local and priv ate preservation eff orts; disseminating inf orm ation; and, generally, advising the Pres iden t and the Congress 

on historic preservation. In these capacities the involveme nt of the Advisory 

Council here seems to be q uite appro priate.

As presently written, it appe ars tha t the bill does not explicitly go beyond 

land mar k preserv ation. The wording of the last section has been strengthene d to 

insu re that the s pirit and intent of the law can be achieved.

Tha nk you f or giving me t his opportunity to express my support for S-865 and 

to offer you these suggestions.

Senator Buckley. Our conclud ing witness this morning is Mr. 

Meisen of th e G ener al Services A dm inistration.

Air. Meisen, you may read your statem ent or introd uce it for the 

record.

STATEMENT OF WALTER A. MEISEN, ACTING COMMISSIONER,

PUBLIC BUILDINGS SERVICE, GENERAL SERVICES ADMINISTRATION

Air. AIeisen. T hank you, Senator. I would like t o have it placed in 

the record in total and just synopsize it quickly , if I might, so t hat we 

mi gh t answer you r questions.

Se nator B uckley. Fi ne. [See p. 92.]

Air. AIeisen. I am W alter A. AIeisen, Ac tin g Coi missioner of the 

Gen eral Services Adm inist ratio n’s Pu blic Bu ild ing Service and 

De puty Ad minist rator for Special Pro jects.

It is my pleasure to ap pe ar before you on behalf of A rthu r F. 

Sam pson, GS A’s Adm inist rator, to discuss this bill, S. 865, which 

prop oses t o :

Promote more efficient use of the Nation’s constru ction resources, to foster the 

preservation of buildings of historic o r arc hitectura l significance, and to enhance 

the social and economic environm ent within and surr ound ing Fede ral office 

buildings.
87

As the princ ipa l ma nager, builder, owner, and lessor of Federal 

building s in the Un ited Sta tes , the Gen eral Serv ices Ad ministratio n 

has a fun dame nta l com mitmen t t o the betterm ent o f the to tal environment o f A me rica’s cities and towns.

We feel a special sense of responsibility fo r prom oting th e integr ation of the human elem ent into the pla nning , con struction , use and 

e mainte nan ce of buildin gs.

Mr. C hairm an, I would like to m ention th at ou r concern fo r the bu ilt 

env ironm ent is not new. You will be intere sted to know t hat in Ap ril 

1972, at Mr. Sam pson’s request, we sponsored an In tern ationa l Env ironmental Conference on B uilding Constru ctio n a nd Use.

* Repre sen tati ves from the Un ite d Sta tes, Ca nada, Ja pan , Mexico, 

and Franc e pr oduced ideas a nd mad e va luable recom mendation s examining the impac t of con struct ion on our env ironm ent. Two majo r 

reco mmendations of th at conferen ce concern the mult ipl e use of Fe deral building s and the reno vation and reuse of exis tin g b uildin gs.

We, in the General Services Ad ministratio n, str on gly su pp ort the 

concepts introd uce d in S. 865. A s men tioned, we have long promoted 

the concepts of historic pre servation and the mu ltiple use of F ed era l 

structures. We, the ref ore , feel th at such a com binatio n of activity 

would be well worth pursu ing .

Mr. C hairm an, it is im po rta nt to note th at while we hav e es tablishe d 

commercial operation s such as g’ftshops, bookstores, dry cleaners, florists, barbers, home fur nis hin g stores, and so on, in many of o ur b uildings throug h the Small Business A dm inist ratio n’s 8( a) pro gra ms an d 

handica p enterprises as set f or th by the dis tin guish ed ch air ma n in the 

Ra nd olph -Shepard Act, we have not significantly contr ibu ted to the 

mix of act ivities th at combine to enh ance ex ter nal v ita lit y and give life 

and excitem ent to the neig hborh ood environment. On the contr ary , 

these businesses prim arily serv e occ upa nts of the building , and Fe deral 

building s have reinfo rced the image of a dow ntown, w hich is lackin g 

in vi tality, with streets th at become deserte d af te r wo rking hours.

Th ere are many benefits to be gain ed from the m ult ipl e use of Fed-

* eral building s and espe cially older, or seem ingly obsolete, structures. 

Beyond the obvious adv antag es which have alr eady been mentio ned, 

we must recognize oth er im po rta nt factors. Fir st is the issue of resource s carcity .

* For years we have gone on the assumption th at we hav e ha d limitless 

sup plie s of lan d, energy, and money, but recent events hav e made it 

clear t ha t this is no longer a v alid assu mption.

Th e renova tion o f o lder b uildin gs, for the purposes s tat ed in S. 865, 

will produce fac ilities t ha t can p lay a ma jor role in the effor t to make 

more intensive use of ava ilab le resources.

An other advanta ge of these concepts is that of energ y use. If people 

were able to walk to work or shopp ing areas con veniently, u ltima tel y 

there would be less traffic congestion , less dem and fo r roads, and less 

fuel consumption.

In addit ion , the renovation of existing str uc tur es will pro vid e a 

lower consum ption of ene rgy pe r con stru ctio n do lla r and low er consum ption of na tural resources per con struction do lla r th an new 

con stru ctio n.
88

When comp aring renovation to new con stru ctio n, the for me r w ould 

gen erally result in less noise pollution, less traffic disrup tion, and less 

imp act on san itation and oth er e nvironm ental systems.

These are im po rta nt issues, but there are oth ers th at we can not 

ignore. Because res toration and renova tion usu ally require a hig her 

level of ha nd craft trades, these p rojects will nu rtur e tra des and craf ts 

which are fas t becoming nonexistent in the Un ite d States. Th roug h 

0

S. 865, we could augment Fed eral efforts to preserve and rejuvenate 

historic buildings while helping to preserve the valuable cu ltu ral 

resource.

Mr. Chairma n, multiple-use Federal building s, and the attempt to 

e

preserve cu ltu rally sign ificant buildings, places the emp hasis of the *

Federal b uildin g program on serving the total pub lic intere st, and n ot 

merely servin g the past objective of sim ply prov idi ng Federal agency 

space.

Th rough S. 865’s arc hitectur al pre ser vation prov isions, where the 

situation is w arr anted , PB S would be ab le to h elp preserve the importa nt arc hit ectur al heritage of our culture. Th is act will, the ref ore , 

enable the Governm ent to become a p ar tn er w ith the community in an 

attempt to meet pub lic needs and goals, w hich are th e very reasons for 

any governm ent pro gra m. However, the success of its applicat ion , we 

believe, will depend on cha nging Government assu mption s about 

building p urpo ses so th at m ultiple use is n ot just allowed bu t actively 

prom oted.

It has proven successful for the governments of Ja pa n, Canad a, 

and Sw eden and it can be successful for o ur F edera l Governm ent. Fo r 

all of these reasons, the GSA support s the concept of S. 865 and we 

welcome the o pp ortun ity to meet its requirem ent s and challenges.

Before closing, I would like to submit for the record several comments t ha t GS A has to offer the members of the subcommittee, or the 

subcommittee staff, fo r th eir info rmation an d use. These will be su bm itted with the tota l text of my pre sentation.

Th ank you.

Senator B uckley. T ha nk you, Mr. Meisen. They will be printed in «

the rec ord. [See p. 99.]

You spoke a m inute ago about the desirability of actively p rom oting 

mu ltip le use. Do you have any tho ug hts as to how GSA would go 

about doing this ? •

Mr. Meisen. O ne of my concerns is th at we probab ly will tie inu ndated initially with requ ests for use of space. I think , as mentioned 

earlier by a num ber of speakers, we are talk in g abou t a question of 

attitu de.

There is no d oubt t he re will be pro blem s involved in both th e a dm inistrat ion and design of facilities. Unless an attit ud e is tak en on the 

pa rt of our Agency, and others th at are involved in the pro gra ms, 

reg ardin g poten tial cost problems, we could find many reasons for not 

havin g as much comm ercial activ ity or as much multip urp ose use as 

might be possible if we took a positive app roach.

I want to assure you. Sena tor, th at we propose to do all in our power 

to generate as positive an approac h throug ho ut all GSA regions and 

our headquarters office.
89

I think our response to an initial effort to make viab le comm ercial 

facilities in Federal building s is p rob abl y the bigges t impet us to fu rtherin g the idea.

We have to take a p ositive attit ud e and do all we can in this leg islation to make sure it is viable and do all we can to facilitate its 

operation.

Se nator Buckley. You men tioned th at the statutor y changes th at 

you are recom mending are technica l in na ture.

Mr. Meise x. Yes. One of them, fo r e xample, was to change th e contact poin t to say tha t we feel it sho uld be the A dvisory Council on H istoric Prese rvati on and the St ate histor ic preser vat ion officers.

* We feel wre have been using them with an ear ly warning system in

thi s cap acity in the past. It is o nly a recent develop ment, and is about 

1 year old. It has worked very, very well. We have gotten prom pt responses in all the pa rti cu la r ar eas we con tracted on.

Senator B uckley. W ould it cause any problems to broa den th e n um ­

ber of co ntac t points, to bro ade n it even fu rthe r th an th at ?

Mr. Meisex. If it would not pre sen t a prob lem to the Advisory 

Council. We would, o f course, p refe r to ha ve them as the con tact poi nt 

for t he AIA , the State pre ser vation officers, an d all of the o th er in terest grou ps which m igh t exist locally.

They have a very good system of main tai ning those kin ds of contac ts in local areas. If we could work throug h one co ordin ati ng body, 

it would be extrem ely h elp ful.

Se nator B uckley. It was suggested t ha t some of th e space m igh t be 

made available for cer tain typ es of activities at less th an commercial 

rates. If you were given the a utho rit y to do this , would this create any 

special prob lems, adminis tra tiv ely ?

Mr. Meisex. 1 think if we w ere talk ing abo ut commercial activities 

it migh t give us some difficulties. I am also concerned abo ut the rent. 

I think the comment was made in rel ation to. I tho ug ht, of office use of 

oth er c ult ural groups.

Se nator B uckley. Th at is ri gh t.

« Mr. Meisex. I don ’t know wh eth er this would create any problems. Once wre st ar t going into th at area and s tart renting space at less 

than commercial rates, which is basically wha t we sh ould be charg ing 

our F edera l agencies as well, I don’t know.

» I would have to look into th at a lot more serio usly. Clear ly, if it is

surplus, if it was surpl us space to our needs, I don’t th ink we would 

have much difficulty w ith th at.

Se nator B uckley. I f you have any second thoughts or a fte rth ou gh ts, 

I would appre cia te your sen din g them in. We will keep the record 

open fo r a week for th at purpose.

Mr. Meisex. Certain ly.

Se nator Buckley. Sev eral people have suggested th at we bro ade n 

the lim ita tio n to inclu de mezzanine or possibly the roo fto p areas. Do 

you have any tho ughts on th at ?

Mr. Meise x. Yes. One of the o ther comments th at I am also subm ittin g recommended a change in the w ork ing, where we ju st say i t sh ould 

be ch ang ed from “on the gro und floor” to “on t he public access level.” 

Bas ical ly, it is any levels th at have direct public access. I don’t know
90

if the roof would be a viable area. Tha t migh t create problem s of 

throug h traffic th at might be more expensive to solve. We certa inl y 

think it shou ld be broaden ed to say all public access levels of the 

buildin g.

Senator Buckley. I n your experience, is one of my prem ises of t his 

legislation correct th at reno vation gives more jobs per dollars spe nt 

than an y o the r k ind ?

Mr. Meisen. Yes. I th ink th is is tru e. C lea rly, if you are ta lking abou t 

any given time frame , you see, if a $10 million bu ild ing str etches over 

4 years, you migh t hav e 200 o r 300 people employed du rin g those 4 

years. Bu t if you had 10 $1 million ren ova tion jobs, the y would all be 

wor king a t t he same time because you would have m ore jobs si mu lta neously and you can pu t more people into a renova tion job because the 

floors are there. In oth er words, you can work on seven floors in the 

building at a tim e; while in new con struction you are wa iting for 

fou ndatio ns to be finished, then for t he steel to go up. It takes a while 

to cycle in.

While our origin al estimates ind ica ted five times as man y, we now 

think , gen erally, abo ut three time s the numb er of people are employed in reno vation work tha n are in new con stru ctio n for an equal 

amoun t of dollars. I t is certainly tr ue if you count th e tim e period.

Senator Buckley. Un de r the bill as introd uce d, GS A is required, 

first of all, to assess the via bility of an existing s tru cture and t he n to 

make an assessment of the feasibility, the cost-benefit tradeoffs, a nd so 

on. I th ink i t was M rs. Shipley who spoke o f th e d esi rab ility of loosening tha t somewhat, so tha t a value could be place d on intangib le benefits. Do you believe t he pla nning needs to be broaden ed in any way to 

give you g reater latit ud e in making those jud gm ents?

Mr. Meisen. I t hink in the case of b uildin gs th at are a rch ite ctu rally 

significant, or his tor ica lly significant, th at decision becomes mucn 

easier.

In a registere d building , for example, o r one t ha t is eligib le fo r the 

“N atio nal Histo ric Re gis ter,” we would have a lit tle less difficulty as 

opposed to just an old er building th at someone wan ted to offer us. 

De terminin g what its significance is m igh t be a lot more difficult.

Of course, our whole recommendation is based on the prem ise th at 

it might cost more and, therefore , some type of a value must be pu t 

on th at unless you are going to just let economics dict ate it.

Wh ile I agree th at you can do renova tion more economically, you 

can also have to experience con side rabl y more money. If , in fac t, it 

was trul y economically viable, stri ctly on economics, I think we would 

have seen m uch more ren ova tion th an is go ing on.

I think some of the pre ssure you see, you asked before why would a 

city like ly not care for this. There a re a numb er of d riv ing fac tors in 

this. One is tax income. If i t is a 6-sto ry bu ild ing t ha t mi gh t sustain a 

40-story office building , the tax income from a 40-story office build ing 

is significantly greater th an the 6-sto ry building . There is incentive 

then to drive the valu e of th at pr op erty up. Th e city sometimes is 

anxious to ge t that tax income.

In oth er cases, mud an d smut tear down every bu ild ing i n its way. 

They are looking fo r a new Federal bu ild ing in a new urban renewal 

are a to tr y to be a catal yst fo r developm ent of priv ate office build ings.
91

So they might pr efer you to go int o an urban renewal are a ra th er 

than buy somewhere else. So I th in k there are drives w ith in cities.

1 am conc erned more about the best cost of a prop ert y. I think ren ­

ovation is ma rgi nal and borde rlin e cost effectively when you own the 

pro perty .

Fo r ex amp le, a go vern men t-ow ned bu ild ing that we want to convert, 

we find the costs come out very close. Som etim e the difference is the 

ratio of how much usable space you g et com pared to the gross amount 

of space. Usual ly it is estimated in gross cost. If you ca n only use h alf 

the space because of big, wide corridors, yo ur relative efficiency goes 

down.

Tak e the same Federal build ing , we don’t own it, it is a priva te 

building , if we have to add on those ren ovation costs, we hav e to buy 

th at p ro pe rty from a curre nt owner, and he is looking a t the b uil din g 

potent ial of th at site fo r a 40-story office building , his value of th at 

piece of lan d migh t be quite hig h, espe cially if the city is enco uraging 

the use of th at prop erty fo r a 40-story bui lding.

You can see we m igh t not be able to affo rd buyin g t hat prop erty a t 

its hig hest and best price and the n sti ll do wh ate ver ren ovation is 

necessary.

I see this cle arly as a concern as it affects P ostal Serv ice buildin gs, 

and th at came up, I believe, with Mr. Garvey. They are curre ntl y 

finishin g a lar ge n um ber of centr al bu lk-m ail -ha ndlin g systems.

Wh en those are completed, there will be many, m any old post offices 

th at w ill be surplus to th ei r needs. We have a first o ption to buy them 

back from the Po st Office. T hey , in th ei r legisla tion , have t he right to 

expect the current m ark et value .

If th at c urrent ma rke t value ha s to be paid bv G SA , or else th ey will 

sell them and demo lish them fo r othe r bu ild ing sites, we migh t have 

a difficult tim e, economically, because we wo uld have to ad d t hat a gain 

to th e cost o f ren ovation.

Small pos t offices are difficult ren ovation problem s as fa r as cost is 

concerned. We find it very m arg ina l even when we own t he pos t offices. 

If we have to buy it and the n reno vate , I th in k we will hav e much 

more of a problem.

I would like to see some kind of leg isla tion t hat would requ ire the m, 

if it is a his tor ic post office, to give it back to the Government. But I 

know we are talking abo ut an a rea th at is n ot within th is co mmittee ’s 

jur isd iction , perhap s. But it is a serious problem. We are going to 

lose many post offices t hrou gh ou t the cou ntry unless som eth ing like 

th at cun be developed.

Se na tor B uckley. T ha nk you very much. I think, M r. Meisen, th at 

the subcomm ittee will sub mit a numb er of add ition al questions to you 

for the record.

Also, we wa nt to inse rt three newspaper articles in the reco rd.

[Mr. Meisen’s pr epare d s tatem ent, respo nses to ad dit ion al questions, 

and the new spa per article s follow :]
S ta te m e n t o f W alt er A. M else n 

A c ti n g C om m is si one r 

P u b li c B u il d in g s S e rv ic e 

U .S . G e n era l S e rv ic e s A d m ln ln s tr a tl o n

b e fo re th e

Subc om m itte e on B u il d in g s And Groun ds 

U n it ed S ta te s S e n a te 

May 19, 1975

Mr. Cha irm an an d Membe rs o f th e Subcom m itte e:

I am W alt er A. M els e n , A c ti n g Com m is sion er o f th e G e n e ra l S e rv ic e s 

A d m in is tra tio n ’ s P u b li c B u il d in g s S e rv ic e an d D ep uty A d m in is tr a to r 

f o r S p e c ia l P r o j e c t s . I t i s a p le a s u re to a p p e a r b e f o r e yo u in b e h a lf 

o f A rt h u r F. Samp son GSA A d m in is tr a to r to d is c u s s a b i l l , S. 8 6 5 , w hi ch 

p ro p o se s to "p ro m ote mo re e f f i c i e n t u se o f th e N a tio n 's c o n s tr u c tio n 

r e s o u r c e s , to f o s t e r th e p r e s e r v a tio n o f b u ild in g s o f h i s t o r i c o r 

a r c h i t e c t u r a l s i g n i f i c a n c e , an d to en han ce th e s o c i a l an d ec on om ic 

e n v ir o n m en t w ith in an d s u rro u n d in g F e d e ra l o f f i c e b u i l d i n g s ."

In th e p a s t , F e d e ra l b u ild in g s have been vie w ed a s c o ld , c o n c r e te e d i f i c e s 

e n te re d o n ly by th o s e who e i t h e r wo rk In th e s e s t e r i l e e n v ir o n s o r in d iv id u a ls 

who had b u s in e s s w it h th e F e d e ra l G ove rn m en t. R ecent In n o v a ti o n s in a r c h i t e c t u r a l 

s t y l e an d d e sig n o f F e d e ra l b u ild in g s h as h e lp e d to e ro d e th e n e g a tiv e a t t i t u d e 

to w ard su ch m o n o li th ic s t r u c t u r e s . The c o n c e p ts em bo di ed in S. 865 w i l l mak e 

th e F e d e ra l b u ild in g an d i t s o c cu p a n ts mo re a p a r t o f th e co mmun ity i t s e r v e s by 

o p en in g th e d o o rs to th e p u b lic . T his l e g i s l a t i o n can a ls o become a v e h ic le

f o r th e r e v i t a l i z a t i o n o f dow nto wn a re a s o f o u r c i t i e s .

As th e p r i n c i p a l m an ag er, b u i l d e r , ow ne r an d l e s s o r o f F e d e ra l b u ild in g s in 

th e U n it ed S t a t e s , th e G e n e ra l S e rv ic e s A d m in is tr a ti o n h a s a fu n d am en ta l

commitm en t to th e b e tt e rm e n t o f th e t o t a l en v ir o n m e n t o f A m e ri c a 's c i t i e s
93

and to wns . We f e e l a s p e c ia l se nse of r e s p o n s ib ility fo r pr om ot in g th e 

In te g ra ti o n of th e human el em en t In to th e p la n n in g , c o n s tru c tio n , us e and 

m ai nt en an ce of b u il d in g s .

O bvio usl y, we of GSA ha ve a la rg e sta k e in and an eno rmous r e s p o n s ib ility 

fo r th e impro veme nt of our en vir onm en t. Our P u b li c B uil d in g s S erv ic es is 

* re sp o n sib le fo r 10 ,000 f e d e ra lly owned or le a se d b u il d in g s ; 1700 c o n s tr u c ti o n

p ro je c ts un de rw ay ; a b i llio n d o lla r an nua l b udget; 22 ,0 00 em pl oy ee s, and 

an in v en to ry o f a q u a rte r of a b i l l i o n sq uare fe e t of b u il d in g sp ace ac ro ss th e

countr y.

Mr. Ch airm an , I wo uld lik e to men tion th a t ou r co nc er n fo r th e b u i l t 

en vi ro nm en t i s n o t new. You w ill be in te r e s te d to know th a t in A p ri l 

1972, a t Mr. Sa mps on 's re q u e s t, we sp on so re d an In te rn a tio n a l Env iron m en ta l 

Con fe re nc e on B uil din g C o n str u cti o n and Us e. R e p re se n ta ti v e s from th e 

Uni te d S ta te s , Ca na da , Ja pan . Mexico and Fra nc e pr od uc ed id eas and made 

v alu ab le reco mmen da tio ns ex am ining th e im pa ct of c o n s tr u c ti o n on ou r

en vir onm en t.

1 m en tio n our in te r n a tio n a l co nfe re nce be ca use i t s pu rp os e i s f u lly su p p o rt iv e 

of th e co ncepts pr op os ed by th e d is ti n g u is h e d Chairman and ra nkin g m in o ri ty 

, member of t h i s su bc om mitt ee as w ell as Chairman Randolp h and Sen at or Bak er.

F i r s t , th e b i l l S. 865 would al lo w a c o o p e ra ti v e , p riv a te /p u b li c use to 

sp ac e in F ed era l b u ild in g s . The GSA co nfe re nce re p o rt s ta te d in 1972 

th a t "th e id e a of m u lt ip le -u s e b u il d in g s i s gr ow in g, and in th e c o n s id e ra ti o n 

of th e c ity as a 'ho me' ra th e r th an a 'm a rk e tp la c e ' , th e re i s good re as on

54-188 0 - 75 — 7
94

to consider the use of the lower floors of Federa l bui ldings for me rcant ile 

purposes."

Second, S. 865 would encourage, where practical, the ren ovat ion of older

buildings, thereby converting them to usef ul Federal space. In this 

regard, our conference report recommended "that GSA should use its Influence 

to maintain and create v ari ety In terms of archite ctur e and use. This 

would Include consider ation of preservation of h isto ric b uild ings and 

areas for community-oriented, multi-pu rpos e public buil dings. "

We in the General Services Administration stro ngl y support the concepts

Introduced in S. 865. As mentioned, we have long promote d the concep ts

of histor ic pres ervation and the multiple use of F ede ral structures, 

and therefore feel that such a combination of acti vity woul d be wel l

worth pursuing.

Cities have always had multi ple-us e planning. In ma ny older neighbo rhood s,

apartments typically were built above stores that lined the street level.

And recent examples of v erti cal mixing, that is some comb inat ion of retail, 

parking, office, recreatio nal and resident ial use In a single structure,

can be found In Marina Towers and the John Hanc ock C ente r in Chicago

and In the United Nations Plaza in Manhattan. City p lann ers have acclaimed 

these b uildings for their potential In rev ital izin g core areas.

Frequently, however, neithe r private nor public office bui ldings are

designed to contribute to the active move men t of people amid diverse

settings, or to provi de opportunities for pl anned or chanc e encounters,

or to en courage the int erplay of varied acti vitie s, or to promote the 

compatibility of b uil din g facades at a scale easily used b y
95

p e d e s tr ia n s . When th e em plo yees go home In th e evenin g, th e su rr oundin g 

s t r e e t s a re l e f t emp ty and a fte r-h o u rs a c tiv ity is d is coura ged.

T hi s dim in is hed human v i t a l i t y of many downtown a re as is a se ri o u s 

prob lem and Sen at e b i l l 865 pro vid es an ap pr oa ch fo r th e s o lu tio n .

Mr. Ch airm an , i t is im port ant to n o te th a t w hil e we ha ve e s ta b li s h e d 

co mmercia l o p e ra ti o n s such as g i f t sh o p s, boo k s to r e s , dr y c le a n e rs , 

f l o r i s t s , b a rb e rs , home fu rn is h in g s to r e s , and so on , in many of ou r b u il d in g s 

th ro ug h th e Sm all B usi nes s A d m in is tr a ti o n 's 8 (a ) prog rams and ha nd ic ap 

e n te rp ris e s as s e t fo rth by th e d is ti n g u is h e d Chairman in The Ra nd olph - 

Sh ep ard A ct , we ha ve n o t s ig n if ic a n tly c o n tr ib u te d to th e mix of a c t i v i t i e s 

th a t com bine to en ha nc e e x te rn a l v i t a l i t y and giv e l i f e and exci te m en t to 

th e ne ig hb or ho od en vi ro nm en t. On th e c o n tra ry , th ese b u sin e sse s p rim a ri ly 

se rv e occ upan ts of th e b u ild in g , and F ed era l R u ll d ln g s ha ve re in fo rc e d th e 

image of a downtown wh ich i s la ck in g in v i t a l i t y , w it h s t r e e t s th a t become 

d esert ed a f t e r wor king h ours .

The re are many b e n e f its to be ga in ed fro m th e m u lt ip le -u s e of F edera l 

b u il d in g s and e s p e c ia lly o ld e r, o r se em in gl y o b s o le te , s tr u c tu r e s . Beyond 

th e ob vi ou s ad van ta ges wh ich ha ve a lr e a d y be en m en tioned , we must re cogniz e 

o th e r im p o rt an t f a c to r s . F ir s t is th e is s u e o f re so u rc e s c a rc ity . For 

y e a rs , we ha ve gone on th e as su m pt io n th a t we ha ve had lim itle s s su p p li e s 

o f la n d , en er gy and money, bu t re c e n t ev en ts ha ve made i t c le a r th a t t h is 

i s no lo nger a v a lid as su m ption. The re n o v ati o n o f o ld e r b u il d in g s fo r 

th e purp ose s s ta te d in S. 865 w ill pr od uc e f a c i l i t i e s th a t can pla y a 

major ro le in th e e f f o r t to make more in te n s iv e us e of a v a il a b le re so u rc e s .
Another advantage of these concepts is that of energy use. If people 

were able to walk to work or shopping areas conve nien tly, the ultimately 

there w ould be less traffic congestion, less deman d for roads and 

less fuel consumption. In addition, the renov atio n of existing s tructures 

will provide a lower consumption of energ y per cons truc tion dollar 

and lower consumpt ion of natural resources per cons truc tion dolla r than 

new construction. When comparing renovatio n to new constr uctio n, the 

former would generally result in less noise poll ution , less traffi c 

disruption, and less Impact on sanitation and other envir onme ntal systems. 

These are important Issues, but there are other s that we cannot ignore:

Because rest oration and renovation usually requir es a higher level of ha nd ­

craft trades, these projects will nurture trades and crafts which are fast 

becoming non-existent in the United States. Through S. 865 we could augmen t 

Federal efforts to pr eserve and rejuvenate hi sto ric buildings wh ile he lpi ng 

to preserve the val uable cultural resource.

Since renovation also tends to be more labor orien ted -- per const ruct ion

dollar than n ew con str uct ion -- it would m ean more jobs. Mr. Chairman, I

would like to point out to the members of the Subcomm itte e that a $1 

million investment in repair and alte rati on w ork pr oduces five times as 

many new jobs as $1 mil lio n in new construc tion activity. This compa riso n 

cannot, of course, be taken literally in all cases, but it does illu strat e 

that possibilities exist through this legis lati on for subs tanti al and 

effective payoffs is worthw hil e employment.

I would mentio n briefl y that there are other b ene fit s or advantages to various 

provisions of this bill which In clude:
97

-Provides additional convenie nces for Gover nmen t employees. 

-Augments further the aims and intent of the Int ergover nmen tal

Cooperation Act.

-Establishes a viable par tner ship betwe en the F ede ral Governmen t

and various sectors of t he community.

-Creates Job and business oppor tuni ties for the local community. 

-Relieves some of the b urd en borne b y local commu niti es in

pres erving older structures.

We would, of course, be naive to think that there would not be problems 

or adjustments to be made. Security must be cons idere d, but the question 

is not multiple- use vs. security, and we are conf iden t that through 

quality design and p lann ing this pro ble m will be resolved. Espe cial ly 

when we have multiple-us e ground fl oo rs .

Other Issues such as p aym ent -in -li eu of real prop erty taxes; policy 

deviations such as max imu m space util izat ion, fire safety , hand icappe d 

facilities and budgetary adju stments wo uld of cours e n eed to be addressed. 

But as I mentioned at the begi nni ng of my statement, we have faced the 

issue of multiple-use of space for several years and are well along in 

our planning for such a program.

The impact of the Federal G ove rnment---through legis lati on, regulation,

taxation---is already felt in v irt ual ly every secto r of our economy.

When it is justified as being in the public interest, the Federal 

Government competes with private ente rpr ise on a mam mot h scale. But 

the significant public benef its to be derived from mult iple-u se 

Federal bu ildings are ample justi fic ati on for the rel atively minor
98

F e d e ra l in te r v e n tio n in th e m ark et econom y th a t wou ld be re q u ire d to 

im ple m en t S .8 6 5 .

Mr. C hai rm an, m u ltip le - u s e F e d e ra l b u ild in g s , an d th e a tt e m p t to p r e s e r v e

*

c u l t u r a l l y s i g n i f i c a n t b u ild in g s , p la c e s th e em phasi s o f th e F e d e ra l b u ild in g 

pr og ra m on s e r v in g th e t o t a l p u b li c i n t e r e s t , an d n o t m e re ly s e r v in g th e 

p a s t o b je c tiv e of sim ply p ro v id in g F e d e ra l ag en cy s p a c e . Th ro ug h S .8 6 5 's 

a r c h i t e c t u r a l p r e s e r v a tio n p r o v is io n s , whe re th e s i t u a t i o n i s w a rra n te d ,

PBS wou ld be a b le to h e lp p re s e r v e th e im p o rta n t a r c h i t e c t u r a l h e r ita g e 

of our c u l t u r e . T h is a c t w i l l th e r e f o r e e n a b le th e Gov er nm en t to becom e 

a p a r tn e r w it h th e co mmun ity i n an a tt e m p t to m ee t p u b lic n eed s an d g o a ls , 

whi ch a r e th e v e ry re a s o n s f o r an y Gov ernm en t pro gra m . H ow ev er , th e 

s u c c e s s o f i t s a p p l i c a t i o n , we b e l i e v e , w i l l dep en d on ch an g in g Gov ernm en t 

a ssu m p ti o n s ab o u t b u ild in g p u rp o s e s so th a t m u ltip le - u s e i s n o t j u s t a ll o w ed 

b u t a c t i v e l y pro m ote d.

I t h a s been pro ven s u c c e s s f u l f o r th e go ver nm en t o f J a p a n , Can ad a an d Swede n 

an d i t ca n be s u c c e s s f u l f o r our F e d e ra l G over nm en t. For a l l o f th e s e 

r e a s o n s , th e GSA s u p p o rts th e c o n c e p t o f S.8 65 and we we lco me th e o p p o rtu n ity 

to m eet i t s re q u ir e m e n ts an d c h a lle n g e s .

B efo re c lo s i n g , I wou ld l i k e to s u b m it , f o r th e r e c o r d , s e v e r a l comm en ts ’

th a t GSA has to o f f e r th e me mb ers o f th e Subcom m it te e, o r th e Su bco m m itte e 

s t a f f , f o r t h e i r in fo r m a ti o n an d u s e .

THANK YOU,

ATTACHMENT

P B S :5 /1 5/7 5
«_ S ta ttlt Departm ent ot Community Development, 306 Cherry Street. Se attle, Weshington 96104 (206) 563-2936

RECOMMENDED CHANGES TO LANGUAGE OF S. 865

1. On pag e 1, lin e 6, b efo re th e word " o p e ra ti n g " , add " c o n s tr u c ti n g " .

2. Sin ce GSA p ro v id es v a rio u s ty pes of sp ace fo r th e F ed era l Go ve rnment,

pag e 1, lin e 8 sh ould be re v is e d to re ad "S pa ce necess ary fo r th e accomm odation 

of F ed era l a g e n c ie s ..."

3. To a ssu re th a t th e A d m in is tr ato r of GSA is n o t li m it e d to a s in g le method 

fo r s a tis f y in g Gover nm ent sp ac e need s, we recommend th a t on pa ge 2, lin e 2, 

a f te r th e word " s h a ll" th e phra se "up on h is d e te rm in a ti o n th a t i t is in th e 

b e st in te r e s t of th e Go vernme nt— " , be in s e r te d .

4. On page 2, lin e 14 , a f te r th e word " b u ild in g " , in s e r t "u n le ss in ­

c o n s is te n t w it h lo c a l zo ni ng re g u la ti o n s or p la n n in g o b je c tiv e s ."

5. Page 3, lin e s 12 th ro ugh 15 . We recommend d e le tio n of th is su b sec ti o n 

b ecau se , in su b m it ti n g p ro sp ectu ses in acc ord an ce w it h o th e r s e c ti o n s of th e 

b i l l , th is conce rn w ill be f u lly a d d re ssed .

6. Page 4, lin e s 4 th ro ugh 12, sh ou ld be re v is e d to re ad as fo ll o w s:

" (c ) Whenever th e A d m in is tr ato r un d ert ak es a su rv ey of th e p u b li c 

b u il d in g ne ed s of th e F ed era l Government w it h in a g eo g ra p h ic al a re a , he

s h a ll co n su lt w it h th e S ta te H is to ric P re se rv a ti o n O ffic e r and th e Ch airma n 

of th e Adv isor y C ounci l on H is to ric P re se rv a ti o n to id e n tif y w it h in 30 da ys 

any e x is ti n g b u il d in g s w it h in su ch g eo g ra p h ic al a re a wh ich a re of

a r c h ite c tu r a l o r h i s t o r ic in te r e s t and which may be s u ita b le , w he th er or
100

n o t in ne ed of r e p a i r , a l t e r a t i o n , o r a d d itio n , f o r a c q u i s i ti o n o r p u rc h a se 

to ne ed th e p u b lic b u ild in g s n eeds o f th e F e d e ra l G overn m ent. " T h is , we 

b e l i e v e , is a more p r a c t i c a b l e m et ho d f o r i d e n tif y in g p o t e n t i a l a d a p tiv e - u s e 

b u i l d i n g s .

7. Pag e 4 , l i n e s 18 an d 19, th e p h ra se "o n th e gro und f l o o r " sh o u ld be 

r e p la c e d w it h "o n th e p u b lic a c c e s s l e v e l ," s in c e in some b u ild in g s gr ou nd 

f lo o r sp a ce i s be lo w g ra d e an d n o t s u i t a b l e f o r com m er ci al a c t i v i t i e s o r 

p u b lic a c c e s s .

«
101

Resp onses F rom Genera l Services Adm inist ra tio n

1. How does one determin e when an old building should be saved?

The decision to save an old building would be base d upon an ana lysi s to det ermine if the facili ty can be economically adap ted to suita bly house Federal agencies when compared with other available alte rnative s. Fac tors such as efficiency 

in space utilizatio n, safety stan dards, energy consumption, etc. would be included 

in the analy sis. If the analysis should indic ate th at a par tic ula r old buildin g was 

the best alte rna tive for satis fying the Governm ent’s need, then it would be retained (i f Government-owned) or acquired. It is importa nt to note that thi s type 

of analysis is currently used in all our Pro ject Development Reports.

2. Who will make decisions as to wh at histo rical or architect ura lly significant

buildings w ill be converted to mu ltiple use?

The Adm inis trator of General Services, based on the recomme ndations of the 

Commissioner of the Public Buildings Service (o r by delegating autho rity the reto ), will have the final resi»onsibility in determin ing whe ther a pa rti cu lar building of historic or arc hitectura l significance should be converted to multiple use. 

Obviously, this would be done only after care ful analysis of community needs, 

commercial feasibility of multi-use facilitie s in the building, and the intend ed 

use of th e building by the Government. Consulta tions w ith local planning officials, 

business leaders , community associa tions, and oth er inte rest ed partie s would also 

be required as pa rt of the analysis.

3. W hat kinds of buildings might not be suitab le f

There would not seem to be any class of building (except perha ps those housing 

a high propor tion of high secur ity agencies) which would be exclude d from 

consideration for multip le use. Otherwise, decisions would be m ade on a case-bycase basis, with appropriate consideration of economic f actors, community needs, 

etc. There would not necessarily be any gre at difference in the natur e of the 

analy sis of arc hite cturally or histo rically significa nt buildings, as distin guish ed 

from merely old buildings, although policies may be developed to perm it some 

premiums for the form er categories.

4- Could the term “archite ctu rally significant'’ ap ply to a modem buildingf

We see no reason why certain modern buildings could not be considered arc hitectural ly significant.

5. Do you advocate tha t the Government purc hase historic buildings outright,

or tha t it lease them ? And, question 13. Is leasing of such str uc tur es pra ctical? Doesn’t tha t denote a sort of tempora ry arrangem ent, leaving the ult imate fat e of a landmark building undec ided?

We believe th at the most desirable method of preserving buildings of histo ric 

value would be o utrigh t purchase. A leasing arrang eme nt is only temporary, and 

at the end of the lease term we would be faced with the alte rna tives of eith er 

letti ng the lease expire or enter ing into a new lease arrangem ent.

6. Is building res tor ation to original app earance desired?

We believe th at in most cases, restoration to the original exterio r appearance 

would be most desira ble, since the tota l chara cte r of the structur e could only 

be exhibited if the buildi ng were retu rned to the original sta te specified by the 

architect . However, this may not alwa ys be prac ticab le and in such instances 

restoration should only echo the original app earance through the retentio n of 

its significant arc hitect ura l characterist ics. Generally speaking, building int eriors would have to be converted to cur ren t sta nd ard s to satisfy the operatin g 

needs of occupying agencies, and to comply with hea lth and safety requirements.

7. Couldn't the reh abi lita tion cost equal tha t of new cons truction?

Generally, reh abilitation would cost less tha n new construction. However, in

some cases it would cost more if the scope of work were very exten sive and 

required expensive materi als and workmanship.

8. As a nation al policy, do you thin k tha t money can actu ally be saved by converti ng old buildings into modem office and oth er mixed-use space, instead

of building new ones? Does GSA have figures to subst antiate this?

GSA does not have sufficient experience, pa rtic ula rly with regard to multip le 

use facilities, to supp ort a policy stateme nt of this natu re. Development of such
102

a policy would, of course, involve analysis of complete life-cycle costs, including 

occupant agency operating costs and revenues from commercial tenan ts.

9. Can life-cycle costing of rehabilitated buildings and new buildings be fav orably compa red! Can a cost-benefit rat io be establis hed, or has it been, tha t

shows a definite oost advantage, of one over the other, to the governme nt!

See answer to Question No. 8.

10. Wouldn't the proje cted life-expectancy of a restored old building sti ll be a

ma tter of conject ure, as compared to that of a modem new building!

Wouldn't it actu ally be much less!

Generally speaking, the projected life-expectancy of a restored building is 

more conje ctural tha n in the case with a new building. The degree of conje cture 

with respect to older buildings would depend on the ext ent of inves tigations of 

structur al integ rity, adequac y of mechanical systems, etc. Actual reten tion per iods would vary according to investm ents for restoration (or modernizatio n) and 

general maintenance during the period of occupancy.

11. Do you think tha t old buildings can be su itabl y converted to meet fire safe ty

requir ements and oth er code stip ula tions! Can fac iliti es for the physically

handicapp ed be prov ided ! What are the ma jor construction problems tha t

will confront GSA with respect to reh abilitat ion !

Most older buildings usually have some inheren t limi tations with rega rd to 

the lates t code and accessibility requirem ents. However, many can be successfully adapted to comply with current sta nda rds with out serious violation of 

the ir historic or achitec tura l integrity. Each buildin g has to be assessed individually and some of the areas of concern would be:

1. Does the building have or can it be renov ated to provide fire containment ma terials/faci liti es?

2. Can a system be developed within the buildin g to detect fire and notify 

the occupants for evacuat ion?

3. Can systems be insta lled in the building th at will extinguish a fire?

4. Can evacuation route s be established that would ensure safe exit from 

the building in case of fire?

5. Is the buildin g stru ctu rally sound to with stan d normal na tur al forces 

such as wind, snow loads, ear th tremors, etc?

6. Can minimum facilit ies for the handic apped and elderly be provided?

12. Are landm ark buildings now insure d agai nst fire or other dam age! What

would the ir sta tus be in this respect if the Government bought them or, in

some instances, leased the m!

We have no way of knowing, of course, which “lan dm ark ” buildings, owned 

by priv ate parties are insured agai nst fire or othe r damage. We assume th at the 

owners have such insuran ce. With respect to land mar k buildings which are 

owned by the Feder al Government, the General Accounting Office has consistently 

held th at as a ma tter of policy the Federal Government, as a self-insurer, should 

not expend public fund s to insu re Government-owned property. In the event the 

Government leased a privat e “lan dmark” building, any insu ranc e necessary for 

the protection of the owner’s in vestme nt will be a ma tte r for the owner to decide.

IS. Is leasing of such struct ure s pra ctical ! Doesn't tha t denote a sort of tempora ry arran gem ent, leaving the ultimate fate of a landmark building

undec ided!

See Question No. 5.

14. What prio rity would be given to leasing old buildings, as against leasing

new ones! Which is the p resent policy!

Currently , in acqui ring lease space, the Adm inist rator has the aut hor ity to 

select, from a number of responsive offers, the one proposal which in his det ermination repres ents the best intere st of the Government, price and other fact ors 

considered such as the suscep tibili ty of the space to efficient layout and the 

availab ility of adequate housing, public tran spo rtat ion , eati ng facilities, etc. 

Under S. 865, as now writ ten, the re appe ars to be a priorit y establis hed, first, 

to acquire space in historic and/o r architectually signific ant buildings; second, 

older bui ldings ; and, finally, constru ction or leasing of new buildings. We believe 

th at the objectives of the bill can be readily achieved with out this prio rity and 

have recommended th at the langu age of the bill be modified so th at the Ad-
103

min istr ato r has adequ ate flexibility in determining the means of satis fying 

agency space needs in given s ituat ions.

15. In rehabil itation of old buildings a good investm ent fo r the Government,

from the standpoint of economic feasibility, as compared to new

const ruct ion t

The economic feasib ility of restorin g older buildings can only be discussed 

in general terms, as each case must be decided on its own merits. When applied 

to the restorat ion of histo ric buildings, and from a stri ctly economic viewpoint, an economic analy sis will usua lly indic ate “no”. However, consid eration 

must be given to the exte nt to which the Government finds it desirable to pay 

a premium for the histo rical and cultu ral contributions which thes e buildings 

provide to the communities in which they are located. As previou sly mentioned, 

reha bilitation of older buildings in our inventory is one of the alte rna tive s 

considered in connection with all proposed construction projects.

16. In your opinion arc reconstru cted old buildings conducive to energy conser vat ion ! And question 20. Do you feel energy savings will be s ub sta nti al!

Older buildings can be reconstru cted to be generally conducive to energy 

conservation if special atte ntion is given to such ma tter s as the rma l insulation, openings, refitting of fenestr atio n to reduce infiltration, etc. However, it 

should be noted tha t they may not compare favor ably in term s of energy conservation with those researc h buildin gs now on the drawing boards. Obviously, 

the degree of energy efficiency in older buildings will depend on the investment 

to be made in energy conserving fea tur es and mater ials.

17. Do you feel tha t a sub sta ntial percentage of GSA's public buildings program should be diverted to the acquisition and rehabi lita tion of old building s! How about leasi ng!

We believe th at our progra m should continue to be devoted to housing

Fede ral agencies in first class space. If this can be economically achieved 

throu gh the reha bilitation of older buildings, we would have no objection. We 

do not believe, however, that a prio rity should be established for resto ring 

buildings th at ar e merely old a s implied in S. 865.

18. Would there be any oonflict in juri sdic tion over buildings already in national

tru st and those to be acquired by GSA !

In the event GSA acquire s a building eligible for listing on the National

Register, GSA will take the app rop riate steps to nominate the buildin g for the 

register. With respect to buildings which are on the regi ster and ar e acquired 

by GSA, the National Histo ric Pres ervatio n Act requ ires th at before any alter ations are made, GSA consult with the Advisory Council on Historic Pres ­

ervation. This consu ltation proced ure does not create any conflict in juris dicti on 

over the building.

19. How can enactm ent of S. 865 promote more efficient use of the nati on's constru ctio n resource s!

If enacted, S. 865 would promote a more efficient use of our na tur al resources 

because many of the existing components, such as the steel and masonry mate ­

rials, w’ould be utilized to the gre atest extent practic able. This, of course, would 

be in con trast with new construction which would involve the manufactu re of 

new materi als on the one hand, and even tual destr uctio n of many of them in 

the older buildings on the other.

20. Do you feel t ha t energy savings will be sub sta nti al!

See Que stion No. 16.

21. What effect ivould enactment have upon GSA's public buildings program

gen erally!

The enac tmen t of S. 865 would have a significant impact on our buildings 

program. Both the multi-use and historic al preservation sections would significantly affect the planning and construction area s. Our planning stud ies and the 

scope of our consultations with local aut horiti es would have to be broadened 

to include local retail and service markets and community needs in term s of 

commercial, cultura l, recre ational, and education al facilities. The acquisition 

of arc hite cturally and histo rically significant buildings could possibly result 

in the estab lishm ent of “localized” Federal complexes where agencies havin g 

similar acti vities could be collocated. This would be in con trast to our cur ren t
104

practice of consolidating agencies to the gre atest exten t practicable in a single 

building or a complex of buildings within a one or two block radius.

Providing non-governmental space in Fede ral buildings will also affect building design. Considerations, such as circulation , visibility, and flexibility, would 

call for more “openness,” while secur ity and safe ty considerations would probably requi re additional (but not necessa rily more apparen t) restr ictions. Design will also be affected by the need for, and the desir abili ty of, providing 

different kinds of gra phics and other a ppur tena nces a t ground level, both inte rnal 

and exte rnal. Design beyond the immediate envelope of the buildin g will be *

affected by the same needs, plus community involvement in developing impinging urba n design elements.

Fur ther, the mixed use of public buildings as proposed will result in the need 

for increas ed security. This will neces sitate the use of F eder al Prot ectiv e Officers 

in these buildings during the evening hours and on weekends. In lieu of the ’

use of Fede ral Prote ctive Officers, it may be necessary to utiliz e con trac t guar d 

service. In eith er case, additional costs will be involved.

22. What design and constru ction problems will be encountered, ada ptin g old

buildings to modern office and other usage proposed?

Our pas t experience indicates th at the re are three basic design challenges in 

reh abil itating older buildings to provide modern office space. They a re : space 

utiliza tion, energy conservation, and adeq uate fire protection and safe ty improvements. It must be recognized that the re will be occasions where it will be s tru cturally and/o r economically infeasible to convert certain older buildings to 

meet our cur ren t minimum stan dard s, and we do not inten d to inves t our constructio n funds into those types of buildings. Our decisions will be q uite difficult 

in this regard when the building in question has been found to be of histo rical 

or archite ctural significance. In such cases, we would have to deter mine th at 

the benefits to be derived in preserving an historic str uctur e would outweigh 

any margina l disadvanta ges concerning space utili zati on and perh aps energy 

conservation.

However, if the building cannot be converted to provide a safe and hea lthful 

environ ment for employees and visitors , it should not be acquired by GSA for 

use by Federal agencies.

23. Who do you anticip ate would do most of the design and supervision associated with restored old buildings . . . arch itects in priv ate practice or

government? Should there be design com petition?

Qualified A-E firms in priv ate prac tice selected on a competitive basis would 

do most of the design and supervision of the restoration projects. However, GSA 

staff archite cts will have to manage the proj ect program s for the Government.

As a general rule, design competi tions would be impracticable, as well as 

expensive.

24. On what basis arc A-E co ntracts gener ally awar ded for reh abilitation of old

buildings?

All A-E contrac ts are awarded thro ugh essen tially the same procedural proct

ess. The basic requi rements of the procedure are: public announcement of the 

project in the Commerce Busines s Daily, evaluati on of qualific ations and past 

performance of those firms responding to the announcement, interviewing and 

rank ordering in term s of qualification of at leas t three, usual ly five to eight, of 

the firms with rega rd to the specific project, and finally, negotiatin g with the 

firm best qualified to perform the job unti l an acceptable offer is received or, 

if unsuccessful, proceeding in rank order with the other firms u ntil an acceptable 

agreem ent is reached. This is the process prescribed by the A-E Selection Act 

(P L 92 -582 ), commonly refer red to as the Brooks Bill. The basic difference in 

the selection of design professio nals for new con struction as compared to reha bilitati on work is the emphasis given in the evalu ation process to experience in the 

alteration and restoration field. This is in keeping with our policy of selecting 

the best profess ional firm for the pa rticular projec t in question.

25. In your opinion, which provides more jobs, new construction or altera tions?

The alte rati on project provides more jobs, per dolla r of cost, tha n new construction. The dollar ratio depends on the overall dollar cost, but normally varies 

from 1V6 to 2 times in favor of a lter ation type work. If the rep air and alteration 

proj ect dolla rs are spent in 1 year, versus a 3-year construction cycle, then the
105

dolla rs are fur the r intensified by a rati o of 1 to 3 in favo r of alte rati on type 

work.

26. Do the same OSHA requ irem ents apply to construction as the new work?

Do you h ave any comments on thi s?

Our inte rpre tation of the OSHA regulations is th at they apply equally to 

reconstruction, as well as new work. The law requires that each employer provide a safe a nd healthfu l work place for his employees. It m akes litt le difference 

if the work place is old or new. Deviations from the OSHA regulations ar e only 

" perm itted when they equal or exceed the level of safe ty intended by the specific

regulations.

27. Would such use conflict with local building oodes or zoning restrictions if

mixed use were conte mpla ted?

* GSA Public Building Proj ects are not subjec t to local buildin g codes. T he legal 

foundation s for noncompliance are rooted in the supremacy claus e of the Constitutio n (Art. VI, 2nd pa rag rap h) which provides th at the C onstitution and the 

laws of the United States made in pursuance there of shal l be supreme law of the 

land. Enforcement of local or sta te building regulations would be in conflict with 

Federal policy, since section 10 (c ) of the Public Buildings Act of 1959, as 

amended, requires tha t the Ad min istrator of General Services shall be responsible 

for all construction authorized by the Act.

With respect to zoning rest rictions, Title V III of the Inte rgov ernm enta l Cooperation Act of 1968 requires the Adm inistrator, to the extent practicable , to comply 

with and conform to regu latio ns of the unit of local government having jurisdiction rela ting to planning and development before makin g a commitme nt to acquire prope rty and building s or to change the use of such prop erty in an urban 

area. No such requir ement exists, however, with respec t to prop erty located outside an urba n area. It should be noted, nonetheless, that section 2 (b ) of S. 865 

requires the Adm inistrator to consult with and solicit comments from local and 

sta te governments in carryin g out his duties under section 2 of the proposed bill.

28. How would park ing problems be resol ved?

In the acquisition of an hist orical structur e to sat isfy our progra m needs, 

park ing will be as much of a progr am requir ement as in any other acquisition of 

space. The distinct ion lies in the fa ct th at onsite pa rking, e ithe r w ithin or adjacent 

to the principal stru ctur e, may not alway s be available. In those instances, the 

required park ing will have to be provided by .some other means, i.e., additional 

land acquisition and /or leasing. Obviously, the cost of this p ark ing will have to be 

included in the economic a naly sis of the available a lterna tives to satisfy our program needs.

29. Does your resea rch indi cate any reluc tance on the pa rt of local officials to

• accept reha bilitation in lieu of new cons truction?

Although ’’revital izat ion” in the pas t has mean razin g a n are a and constructing 

new buildings, this concept app ears to be changing, and plan ners are becoming 

more a nd more concerned a bout integr atin g existing str uctur es and new c onstru ction. It must be recognized th at a furth er educationa l process may be necessary 

in this regard with respect to many local officials. Although we concede there will 

be instances when the Gover nment’s plans to reh abi lita te buildings will be 

con trar y to local plannin g objectives, we do not anticip ate any unive rsal reluctance on the par t of the local officials to accept rehabili tatio n. Certainly, in our 

consu ltatio n with them, we will emphasize tha t we do not propose to mai ntain 

buildings as senseless intr usio ns in the community. On the con trar y, we would 

present them as rejuve nated par tic ipa nts in the growth acti vity arou nd them.

30. Do you feel tha t various agencies, to whom you now r ent space, will be co ntent

in a reh abi lita ted building tchen competit ively priced space i s available elsewhere in new buildings, more convenie ntly located?

Improv ing the quality of space which they occupy h as been a ma jor objective 

of most Fede ral agencies over a period of many yea rs and, in the minds of 

most agency officials, “quality ” is virtua lly synonymous with a relativel y new 

building which is in an area convenient to their clientele.

Ther e certainl y will be a reluctance on the pa rt of some agency officials to 

accept old buildings which they consider will fall shor t of optimizing the ir ope rating effectiveness. It is also likely th at such reluctance will be fo rtified by th e f act
106

that the Standa rd Level User Charge they will be req uired to pay may be subs tantially the same at th e two a lte rna tive locations.

It will be incumbent on GSA, therefore, to assure that th e older fa cilities offered 

have sufficient appeal to overcome agency objections in the majori ty of cases.

31. Is this bill compatible with the inte nt of Executive Orde r 115121

A reading of both documents could? lead to the conclusion tha t the re are majo r 

conflicts between the bill and the Executive Order. For example, gre ate r d isper sal 

of agencies may occur by v irtue of the emphasis the bill places on the acquisition 

of historic buildings. Since histo ric buildings general ly are not on the scale of 

modern first class office buildings, the opportunity for consolidation of entir e agencies or groups of agencies in these older buildings would be subs tant ially 

lessened. In addition, the historic buildings could be located outside the downtown are a of a city. Thus, governmental operations would be dispersed which 

could hampe r the efficient performance of the missions and programs of some 

executive agencies contrary to the inte nt of section 2 of Execu tive Order 11512.

However, these disad vanta ges might be minimized through the acquisition 

of a group of archite cturally or historically significant buildings, thereby esta blishing “localized” Federal complexes where agencies having similar activ ities 

could be collocated. This would, to a large degree, sati sfy the general intent of 

Executi ve Order 11512.

32. What impact would enactment of S. 865 have upon urba n planning in large

cities ! Isn't the idea generally to renew and revitaliz e depressed inner-c ity

area s, as directed by E.O. 115121 What if the buildings selected for reha bilitati on were not in these ar ea s!

The impact of S. 865 could be very favora ble upon urba n planning in large 

cities. In the 1960’s planning was based on the tota l cleara nce—bulldozing—of 

inner-c ity areas, followed by construction of new homes and businesses. City 

planners are now modifying the ir thinki ng in this respect. Such plannin g now 

seeks to preserve existing struct ure s where renovation is feasible. Reha bilita tion 

alleviates the tota l displace ment and aliena tion th at resulted from the urban 

“remova l” projects of the 1960’s.

E.O. 11512 does not dictate new construction, but is directed to all types of 

Fed eral acquisit ion of space. The heart of 11512 is t ha t the Fede ral Government, 

in its facility acquisiti ons, becomes a par tne r with the host community and seeks 

locations where the community feels the maximum socio-economic impact can 

be achieved.

Reflecting today’s planning techniques, where reha bilitation is a key element 

in revitaliz ation , S. 865 will give the Federal Government the option to p artic ipate 

in revitaliz ation of inner-city are as when city plans and other conditions indicate 

rehabilitation is the p refe rred course of action.

S3. What effect would popu lation distribution have! Unemployment! Moderateprice housing ava ilab ilit y!

In determi ning when and where to acquire Fede ral buildings, the local population distributio n, the avai labi lity of low- and moderate-income housing, and 

the socio-economic benefits of the proposed action are given full consideration 

along with the program needs of the Government. In considering whether to 

acquir e an historic structur e to satis fy our progra m needs, these facto rs would 

be e valua ted as with any other alter nativ e. In this connection, it should be noted 

th at conversion and altera tion have a gre ater impact on unemployment per 

doll ar cost than new construction.

Slf. Who will make decisions regarding the selection of occupants in converted

buildings scheduled for mixed o r multiple use !

The Adm inist rator in consultation with the Public Buildings Service will

determ ine the type of commercial, cultu ral, educati onal, and recrea tiona l act ivities that will occupy buildings scheduled for multiple use. These determinations 

will be made aft er an anal ysis of local desires and plann ing goals ; zoning require ­

ments; the nat ure of the Fede ral activities to be housed in the building; the 

natur e of the businesses, if any, in the general a re a ; and the environmental 

impact of a multi-use operatio n.

35. Would prefere nce necessarily be given to non-profit or minor ity groups!

Otherwise, why c an't cont racts fo r space be competitive !

Prefer ence will be given to non-profit or minority groups only to the extent

require d under the Randolph -Sheppard Act and the Executive Orders 11458 and
107

11625. It is recommended tha t the Committee repo rts or the bill should make it 

specifically clear the bill’s inten tion with respect to the aforementioned Act and 

Exec utive Orders.

Competition in awa rding con trac ts will be used to t he g rea test extent pra ctic able to insur e that the Government obtai n the maximum rental possible. However, 

to insure tha t ther e is a proper mix of commercial, cultura l, and recre ation al 

uses of space, or to give prefe rence to businesses th at formerly occupied the 

site on which the building was constructed, it may be necessary at times to 

contrac t for space on a negotiated basis w ithou t competition.

36. Would space used for art, educati on, and recr eatio nal activitie s be supported

entir ely by revenue from ren t charged other occu pant sf How could businesses

then compete with others not burdened with such arrang em entsf

Under section 4 of S. 865, it would be o ur intent ion to insu re th at the Fede ral 

agency or other sponsoring orga niza tion responsible for the cul tur al or educational activ ity would pay for the space such an activity occupied in a Fede ral 

building.

37. Ho you think tha t the local business sector would rese nt the idea of the

Goverment encouragin g competition by providing space in a Fed eral

building?

Although it is likely th at some objections will result initi ally , we believe th at 

it will soon become app aren t th at the effect of leasing space to non-Federal 

activities can be a positive ra th er tha n a negative fact or. Before deciding on 

which types of activities would be most suitable fo r occupancy in a Federal building, an anal ysis of the local commercial marke t would be made to determ ine 

what is needed, what businesses have the b est potentia l to succeed, an d wh at will 

have the most beneficial impact on the community. Obviously, firms th at would 

drive other concerns out of business would not meet thi s crit eria . It should also 

be n oted in this connection th at a degree of competition is needed to insure the 

success of individual concerns. For example, it is a well-establishe d principle in 

the planning of shopping malls that most business have some form o f competition 

eith er from competing stores or othe rs mar keti ng sim ilar products. Thus, there 

are near ly alway s two or more store s of the same business in such malls.

38. What tax advantages will accrue to local governments as a res ult of commercial establishm ents in mixed-use buildings? What are some of the

problems GSA could have resu lting from mixed use?

Section 4 of S. 865 provides tha t sta te and local governments would receive

Fede ral payment- in-lieu of taxe s on any space in Fed eral faciliti es leased to 

commercial activi ties. These payments would, most likely, be based on the fa ir 

market value of the space as determ ined by GSA staff, or contract, appraisal.

Making such paym ents could be a ma jor bookkeeping workload for GSA. The 

actu al disbu rsem ent of payments, the account in the Tre asu ry from which they 

should be draw n, and to whom specifically they should be made, is not clearl y 

defined in the bill. Proced ures will have to be establis hed, in conjunction with 

OMB and the Tre asu ry Departmen t, th at will adequ ately provide for disbursements.

39. Ho you know of any legislation tha t might be in conflict or laws th at should

be revised to achieve the objectives of 8. 865?

No. S. 865, if enacted, would not be in conflict with any other provision of law.

1/0. Are there any revisio ns tha t should be made, in addi tion to suggestions

alrea dy given?

No.

[From Preserv ation News, May 1975]

P resid ent’s Colum n—F ederal Arch itectu re

(By James Biddle)

In another repo rt for its c ontinu ing study Fed eral Arch itectu re: A Framewo rk

for Debate, the Fede ral Arch itect ure Task Force of the Natio nal Endowment for 

the A rts said las t November, “No one in his righ t mind goes into a public building 

except on business.” Further mor e, the repo rt continued, since business is usually 

conducted only between the hours of 9 and 5, public building s ar e dead the 

rema inder of the time and add a death pall to those other buildings around 

them.
108

I was pleased to note recently an initial legislative atte mpt to remedy this 

situation. The U.S. Senate now has before it a bill to permit not only the 

mixed use of federal buildings, but also the adaptive use of old buildings as 

federal office space.

Sen. James L. Buckley (R/Cons.-N.Y.) introduced S. 865, the Public Buildings 

Cooj>erative Use Act of 1975, on February 27 and said, “I see this bill as a way 

to enhance the environment of our cities while saving money.” lie went on to 

explain tha t the proposed legislation was not “miracle working,” but rather 

an attem pt to make existing federal law more flexible.

Senator Buckley’s bill was cosponsored by Sen. Howard II. Baker, Jr. 

(R-Tenn.), Sen. Jennings Randolph (D-W. Va.) and Sen. Robert Morgan (DN.C.). Senator Baker, who has displayed an interest in historic preservation, 

is one of two Congressional members of the Federal Architecture Task Force 

and Senator Randolph is chairm an of the Committee on Public Works, to which 

the bill was referred.

The legislation has two basic parts. It would amend two existing laws to 

permit the federal government to lease street floor space in its buildings for 

commercial, cultural, educational and recr eational purposes, a technique that 

has been used successfully in Canada. It would also, and this part is of particu lar 

interest to the National Trust, encourage the federal government, through the 

General Services Administration, to buy old buildings and convert them into 

offices.

“Such an approach—an effort to recycle what is worthy and well built in our 

architectural heritage—would produce many benefits,” said Senator Buckley. 

He listed some of them as saving energy, reducing construction costs and being 

more labor-intensive for employment. The sena tor added tha t such a plan, “may 

also have the salutary effect of slowing the push toward consolidation of ail 

federal offices in one g iant concrete monolith per city. We can reasonably question 

whether or not the local Secret Service office must be across the hall from the 

local Forest Service office.”

The General Services Administration is directed by the legislation to contract 

with the National Tru st for an inventory of possible local renovation alternatives 

when it makes a space survey in an area. Said Senator Buckley, “I would 

antic ipate that the Tru st and GSA would find opportunities for renovation in 

many older, rundown office buildings, warehouses, railway stations, theaters 

and so on.”

I was pleased to note that the legislation does not say that only properties 

listed in the National Register of Historic Places should be considered for reuse. 

As important as the National Register is, there are many buildings of archite ctural or historical inte rest tha t are simply th at ; they are interesting and add 

to the overall ensemble of a city or community but do not meet the criteria 

needed for National Register status. These are some of the buildings most 

frequently being demolished and are the ones we must also try to save.

In response to requests by Senators Buckley and Randolph, the National Tru st 

has indicated it supports this legislation. The concepts of multiple use and 

adaptive use are ones th at will benefit all—from those who work in the buildings 

to those who shop there and live in the neighborhood. And everyone benefits too 

when a p art of our past is saved and reused.

[From The Christian Science Monitor, April 25, 1975]

Uncle Sam’s General Store

(By William Marlin)

Washington.—Uncle Sam has built thousands of public buildings. At least 

they are called public buildings—post offices, picnic shelters in the natio nal 

parks, court houses, the regional headquarters for myriad agencies, m ilita ry barracks, mints, w eath er stations.

The thing is, most public buildings, especially those plonked down in the center 

of our cities, are stand-offish in physical scale and downright unneighborly in 

relation to the ongoing life of the communities around them.

With all the cha racter of a shoulder-high banking counter, except for the 

assemblyline symbolism of bald eagles, flags and agency emblems, the entrance 

areas of these buildings convey a cold-shoulder message; Stay away unless you 

have business here.
109

hn Jpa » l s IKJ )v a y *° h o u se the services of a government which is supposed to 

?

v a i u l fo

,

r

 the people. Perhaps, as E. M. Forster, the English write r, once

' ’ W e s h<’Uhl yell out at least two cheers for democracy—and insist on at least two uses for the public buildings which we pay for.

Early next month, the Senate Committee on Public Works begins hearings 

on the Public Buildings Cooperative Use Act of 1975 (S. 865), introduced in 

late February by Jam es Buckley (R) of New York with the cosponsorship of 

Jennings Randolph (D) of West Virginia, Howard Bak er (R) of Tennessee 

and Robert Morgan (D) of North Carolina. This is called, in capital parlanc e’ 

bipa rtisa n support, and here is why S. 865 deserves it.

This bill would conserve money, conserve jobs, and conserve the salutary scale 

and identity of imp ortant urba n districts. Why else, it might be asked, would a 

conservative like Mr. Buckley come out for it?

For the first time, multiple uses, meshing of public and priv ate functions, 

would be encouraged so tha t, in groun -fl oo r area s, commercial, cultural, educational and recreational activities could add a vital dimension, for employees 

and visitors alike, to the presence of government on our streets.

If a court room and an IRS office can co-exist in the same building, why 

can’t a court room and concert hall? If a post office and a Secret Service headquarters can function within a couple hundred feet of each other, why can’t a 

nost office and a shopping concourse? Why should the only evidence of life and 

laughter around a public building be the splashing of a fountain, or the palaver 

of people brown-bagging lunch, or some lonely sculpture abstrac ting the isolation of the buildings it is meant to enhance? Mr. Buckley’s bill would unbend 

existing law so t ha t the needs of government can be accommodated along with 

the public’s.

A second provision of S. 865 would encourage the adaptation and reuse of 

worthy, well-built existing buildings which, dove-tailed with the multiple-use 

measure, would bring the public into closer proximity, on a daily basis, with 

the evidence of America’s incredibly rich architectural heritage.

The bill thus gives cultural values a chance to break even with economic ones. 

Older buildings, for example, use considerably less energy than do many new 

ones and, don’t forget, it takes a whopping lot of energy to tear down an old 

building and then replace it.

Another dividend per tains to America’s unemployment lines. In case you were 

wondering what prese rving old stru ctures has to do with putting bread and 

butter on the table, it might be useful to point out, as the General Services 

Administration did in February, that a million dollars for repa iring and improving an existing fede ral building produces five times as many jobs as does the 

construction of some spanking new slab.

The Public Buildings Cooperative Use Act may seem somewhat peripheral 

to many Americans during these perilous days, but it embodies the essence of 

the relationship between people and government. By engaging a wider spectrum 

of activity, not for just eight hours a day but into our evenings too. and by 

making good use of the buildings we already have, this bill would have a beautiful bearing on the way our downtowns look from now on, and on the way we 

thin k about and use the resources of government.

Given this enlightened legislation. Uncle Sam’s public buildings should have 

a lot in store—the kind of store which many would welcome the chance to mind.

[From the New York Times, June 17, 1975]

Deolaciattnq th e F eds

The image of the Federal Government is monolithic, glacial and du ll; it is an 

image created by Federal buildings, which are monolithic, glacial and dull. In 

and out of Washington, most of the stru ctures put up by the Federal Government 

are temples to 9-to-5 bureaucracies, usually devoid of any sign of extra -government life. Their distinguishin g characteristics are lack of style and soul.

A bill in Congress now would change all that. It would not only revolutionize 

Federal architecture, but profoundly alter its impact on cities and neighborhoods.

First, this legislation, introduced by Senator Buckley of New York and backed 

by the General Services Administration, would encourage the Government to 

utilize the country’s existing architectural resources. Instead of automatically 

producing those still-born monuments, the G.S A. would be required to explore 

the use of older buildings and existing spaces, where suitable, including land54-188 0 - 75 — 8
inark-quality properties. Pa rt of the process would be cons ultat ion with the 

National Tru st for Historic Pres erva tion on the local ava ilab ility of such structures. This is a long way from earlie r Federa l pract ice of decla ring its own 

histo ric buildings Government surp lus and knocking them down to the highest 

parkin g-lot bidder.

Second, and ju st as revolutionary, the restr ictio ns th at have guarant eed the 

ste rili ty of Government buildings—th e probition of all non-Government uses— 

would be lifted. The rental of space to commercial ente rprises would be permitted, with an eye to reinforcing the area ’s functions. Cultural, educa tional and 

recr eatio nal uses of a buildin g’s faci lities would be trea ted as desirable. This 

would not be restr icte d just to the ground floor where Government construction 

hab itually assa ssina tes the street, but would take place in auditoriums , courtyards, rooftops and lobbies as well.

The impact would be fa r more tha n archite ctur al. Ins tea d of an afte r-5 

o’clock su rrea l landscap e of locked doors a nd empty, echoing spaces, Fede ral constru ctio n would promote the hea lth and vitality—and even the safe ty—of a city. 

Design dedicated to the social and economic improvement of the enviro nment 

would be a fine sub stit ute for ins tan t Federal wastela nds. We are delighted th at 

the approa ch of the Bicent ennial is bringing out the revolutionary in Senator 

Buckley.

Senator Buckley. Thank you very much.

A statement from the Council on Environmental Quality will, without objection, be made a part of the record.

[The statement referred to follows:]

E xecutiv e Office of th e Presid ent,

Coun cil on E nviron menta l Qua lit y,

Washington, D.C., June 10,1975. Hon. R obert Morgan,

Chairman, Subcommittee on Buildings and Grounds,

U.S. Senate, Washington, D.C.

Dear Senator Morgan : It is my pleasure to submit for the record these 

comments on S. 865, the “Public Buildings Cooperative Use Act of 1975.” As 

Chairman of the Council on Environmental Quality, I am reminded daily of 

the enormous impact Federal action s can have on the man made environment. 

Federal investm ents and supp ort in housing, tran spo rtat ion , sewers, defense 

facili ties, energy development, parks , health cente rs and educat ional facilit ies 

exert an importa nt influence on the form and functio n of the cities we live in. 

It is also clear th at the location and design of Fede ral office buildings, cour thouses, veter ans hospitals, and other stru ctur es in cities, an investm ent of 83 

billion dollars, can have imp orta nt effects on the surro undi ng environment.

Each yea r about a billion dolla rs is spent to construct new Federal buildings 

across this country and about ha lf that much is spen t to lease prope rty for 

Fede ral use. With so much money being spent on some 2.5 billion square feet 

of office space, it makes good sense to examine the impact of the investment.

In this regard, S. 865 appears to be a very useful piece of legislation. It 

recognizes and encourages the positive contrib utions th at Federal buildings can 

make to the ir surround ing environm ent. It places special emphasis on making 

use of existin g buildings of histo ric or arc hite ctur al significance, both by encouraging thei r reten tion and rehabilitation when already in Federal hands, 

and by encouraging the ir purchase or lease to meet Federal space needs. In 

addition, S. 865 encourages the location of commercial, cult ural, educational, 

and recre ation al facilities and activ ities within or nea r public buildings in ways 

that add to urban vitality and encourage use both durin g and outside of regular 

hours.

The Federal Government has a responsibility to assure th at its action contrib ute to humane and enriching public purposes—partic ula rly when to do so 

also conserves energy, na tur al resources and costs. While we would not recommend th at our cities become museums of the past, the past 's fine arch itec ture 

preserv ed and complemented by cr eativ e and compatible new co nstruc tion, where 

appropr iate, can contribute to an environm ent which is divers e and rich in 

memory, activ ity, and design.

There is a precedent for adaptive use of historic buildings by the Federal 

Government right here in Washington. Across the stre et from the Whit e House, 

Laf aye tte Square Par k is edged on two sides with red brick row houses in scale
Ill

with the Park, the White House aud the 18th Centu ry St. Joh n’s Church nearby 

Some twenty years ago when more courtrooms and office space were found 

necessary, the houses were to be torn down and replaced with large aud unwelcoming buildings. Fortuna tely, because of Pre side ntia l concern, there was 

a stay of execution and the houses were remodeled into handsome offices. As 

one of the ten ant s in those townhouses, 1 thin k it is the most civilized Federal 

space in twon. Ample new buildings of related materi als aud deta il were added 

behind the old ones connected by planted courtyards, and the space needs were 

satisfie d by retai ning th e old a nd blending th e new.

Also in Washington the Old Executive Office Buildin g was saved from the 

bulldozer and stan ds today as gracefu l and useful space next door to the White 

House. Across the stre et, the Renwick Museum has been restored and put to 

public use, and the Federal Home Loan Bank Board Building is under cons truction, carefully designed to include mixed uses which serve the surro undi ng 

area. In other cities, GSA has restor ed and put to good use older court houses 

and Federal buildings. In San Francisco, the Old Mint, abandoned and cobwebbed, was resto red with care by the U.S. Tre asu ry Depa rtme nt to become a 

museum of coins an d of San Francisc o's lively and g rand past.

Too often in the past, however, ther e has been an atte mp t to centr alize 

Federal office space in cities by putting all agencies, related or not, und er one 

roof in a new building of litt le architect ura l distinction . Visually the building 

has been set off from the othe rs aroun d it and is locked up and left at the end 

of the day. S. 865 gives us the tools and the man date to change this picture.

There is an imp orta nt and growing effort on the pa rt of state s, citie s and 

priv ate groups to save and use fine older arc hitect ure for office space. This 

month's Fortune magazine has an excellent arti cle with photos on how to recycle 

buildings for office space. But perha ps the most rele van t example comes from 

the State of Missouri. In St. Louis, the 9-story Wainwright Building, built 

in 1890-91 by Dankmar Adler and Louis H. Sullivan , and famed for its brick / 

ter ra cotto facade, was saved from demolition when the State of Missouri 

decided to resto re the building as part of a sta te office buildin g complex.

Local governments have also begun to act. In Seattle, the City is using some 

of the old tur n of the century granite buildings in and aroun d the restor ed 

Pioneer Square for city offices, thus contribu ting to the resto ratio n, stabili ty 

and liveliness of that area. The old City Hall in Boston has been modernized 

into beautiful and elegant priv ate offices. All over the country where old buildings have been renewed, life around them has also been renewed and a pedestri an scale and dive rsity that gives the city a special chara cte r and excitem ent 

has been restored. My frank opinion is th at if our older cities are saved, they 

will be saved more by this kind of thou ghtful use of exis ting resource s than 

by demolition and sweeping changes.

S. 865 not only recognizes the opportunity the Federal Government has to 

contribut e to architect ura l and histo ric pre servati on ; ano ther section of the 

bill calls for enriching the spaces in and aroun d the public buildings by a 

design that encourages pedestrians to move freely in, around and throu gh the 

buildings, by providing courtyard s, res tau ran ts, food stores, shops, banks, 

thea ters , lectu re halls, meeting rooms and recre ation facilit ies, not only for 

those who work in the building but for the convenience and enrichmen t of the 

general public, who after all pay the bill for the construction and mainte nance 

of these stru ctur es. I might add there is also no reason why these functions 

and older buildings cann ot be adapted to be accessible to the handicapp ed, 

whet her employees or visitors.

Mixed use in office buildings is not a new idea, but it is an idea that requ ires 

the suppo rt of this legisla tion to encourage its widespread application in Federal buidings. In Canada and Sweden, the national governments have take n 

steps to include a variety of activi ties in the ir government buildings. In Nash ­

ville. Tennessee, the first five floors of a sta te office building now unde r construc tion will house sep ara te music and dram a the aters, a multipurpose rehears al 

studio and a sta te museum—all open to the public. Above will be ten stories 

of offices for sta te agencies. This multi-use building will not only be economical 

to contruct and maintai n but it will tend to keep people in the cur ren tly unde r 

utilized downtown are a af ter working hours. I believe the Federal Government 

can do much to eneen der the same sense of vit ality by allowing a vari ety of 

uses in its own buildings. The legisla tion before you today would be a great 

help in star tin g us towa rd th at goal.
112

With respect to the specific language of S. 865, we have two suggested 

changes which we believe the Committee should co nsi der :

First, Section 2 of the bill should be revised to apply to leased space as well 

as purchased or federally constructed space. This would increase considerably 

the o pportu nity for ad apti ve use of older st ruc tures in cities.

Second, we believe t he bill should encourage the consid eration of altern ativ es 

using more tha n one older building or a mix of old and new, especially where 

the buildings are in close proximity. It should not be necessary to limit the 

survey to only buildings tha t can accommodate the ent ire Federal esta blish ­

ment in the city. Often creative use of groups of smaller buildings can accomplish the same purpose of consolidating agencies from scattered offices to a 

cent ral location.

In closing, we suppor t S. 865 and urge that it be enacted into law. The Office 

of Management and Budget has advised us th at it has no objection to the 

submission of this report from the standpoint of the Adm inist ratio n’s program. 

Sincerely,

Russell W. Peterson,

Chairman.

Senator Buckley. The he aring is adjourn ed.

[Wh ereupo n, at 12 :10 p.m., the subcomm ittee recessed, to reconvene 

subject to the call of the C hair.]
AP PEND IX

RESPON SES TO SENATOR BUCKLEY ’S REQ UES T FOR 

COMMENTS ON S. 865

E S L . B U C K L E Y

NEW . YO RK

C O M M IT T E E S

' S C r u f o b x 5 s > f a ( ® : 5 ^ te n a ia

W AS HIN G TO N , D-C . >0 310

. Il arc h 1 9 , 1975

D ea r

On F e b ru a ry 27, 19 75 I in tr o d u c e d th e "P u b li c B u il d in g s . C o o p e ra ti v e 

U se A ct o f 19 75 "* This ' i s l e g i s l a t i o n t o enco ura ge b o th " c o o p e ra tiv e u s e " 

a n d " a d a p tiv e u s e " i n 't h e F e d e ra l o f f i c e b u ild in g p ro g ra m . I am e n c lo s in g 

a co py o f t h e b i l l , as w e ll as a co py o f ny f l o o r s ta te m e n t e x p la in in g t h e 

i n t e n t o f t h e l e g i s l a t i o n . ' - • .

I t v o u ld be a o s t h e lp f u l to ne t o hav e y o u r th o u g h ts a n d s u g g e s ti o n s 

on t h e b i l l . Do you b e lie v e t h a t th e id e a i s a so und a n d w o rk a b le on e?

Do you have an y s u g g e s ti o n s f o r ch an ges i n th e b i l l ? Do you h a v e ’any 

•' s u g g e s ti o n s on b u il d in g s o r c i t i e s w her e th e s e c o n c e p ts e i g h t b e a o s t 

■ e f f e c t i v e l y tr i e d ? Do y o u ha ve an y e s ti m a te s on th e s a v in g s , e i t h e r i n 

c a p i t a l c o s t o r en er gy u s e , from su ch 'a pr og ram?

I tin h o p e fu l th a t th e S e n a te Com mitt ee on P u b li c Work s w i l l h o ld a 

h e a r in g on t h i s b i l l w ith in th e n e x t s e v e r a l w eek s. W it h y o u r p e rm is s io n , 

I s h a l l a sk t h a t an y re s p o n se you a re k in d en ou gh t o p r o v id e b e

in c lu d e d as p a r t o f t h a t h e a rin g re c o rd , 

th a n k s f o r y o u r c o o p e ra ti o n .

«\ S in c e r e ly ,

Ja m es L . B uck le y
116

AIA RESEARCH 

CORPORATION 

17 35 NEW YORK AVE, N W 

WASHINGTON, D C. 200 06 

(2 02 )7 85 -8 77 8

April 4, 1975

Senator James L . Bu ckley 

Unite d States Senate 

W ash ington, D. C . 20510

Dear Senator Bu ck ley:

Thank you fo r giv in g me an opportunity to com ment on the "P ublic Build in gs Co op erative Use Act of 1975. " I am fa m ilia r w ith the repo rt of the Fe de ral Arc hitect ual Task 

Force, est ablis hed under the N ational Endowment fo r the Arts, and I belie ve the 

idea of m ultip le use of Fede ral B uild in gs, as ad vo ca ted in the re port, to be a sound 

and wor ka ble one.

We w il l have to de vo te much more of our concerns at a na tio n to the re de sign and 

re build in g of our urb an are as in the next few ye ars . Fe de ral Build in gs and fe der al 

ag en cies ten d to be lo ca te d in the m id st of our major urb an ar eas. The Act can 

poin t the wa y to renewed use of ou r exis ting stoc k of b u ild in g s. We belie ve th at 

30 pe rcen t of the en ergy used in ou r exis ting build in g co uld be saved by re de sign 

and care fu l m odific ation of energy sy stems. A substa ntial part of th is sa ving s in 

la rg er build in gs co uld come from more in te nsiv e u ti li z a ti o n , ca re fu lly pla nn ed by 

a rc h ite cts . The dolla rs sav ed in re vis in g build in gs sh ou ld also be substa ntial, bu t 

I ca nn ot give any estim at es th at can be genera liz ed.

'- -_ & *e sid e n t

JPE/mc

cc : Prima, Gara
Architecture plus

117

The International Magazine of Architecture 1345 Sixth Avenur: New York N> 10019 Pr.one 212 489 8697

Peter Blake faia / editor m chief

A p ri l 3, 1975

Sen at or James L. Bu ck ley 

U ni te d S ta te s Sen at e 

W as hing ton, D.C . 20510

Dear Sen at or Buc kley :

Thank you ver y much fo r yo ur l e t t e r of March 19 . I ’m so rr y 

i t has ta ken so lo ng fo r me to re sp on d to i t .

I th ought yo ur p ro p o sa l fo r th e co o p era ti v e us e and ad ap ti v e 

us e of o f fic e b u il d in g s i s e x c e lle n t and I only w ish th a t i t 

wou ld become th e model fo r fu rth e r prog rams to prom ote th e 

mixed us e of b u ild in g s . As you know, i t is q u it e common fo r 

o ld e r b u il d in g s in Eu rope and el se w her e to co n ta in ap art m en ts , 

o f f ic e s , s to re s and co mmercial f a c i l i t i e s a l l un de r th e same 

ro of and i t i s su ch a m ix tu re o f use s th a t makes so many 

b u il d in g s in Eu ropean c i t i e s both liv e ly and s a fe .

I'm se nd in g you a copy of ou r M ar ch /A pr il is s u e (197 4) wh ich 

was de vo te d al m os t e n tir e ly to th e "re c y c li n g " o f o ld b u il d ­

in g s . I t might come in ha nd y. P le ase l e t me know what 

p ro g re ss you make w it h yo ur b i l l and t e l l me i f th e re is 

anyth in g I can do to be of h e lp .

P .S . Our new ad d re ss i s 130 E as t 59 th S tr e e t, New York 

New York 10022 .
11$

ARCHITECTURAL RECORD

1221 Avenue of the Americas

New York, New York 10020

Telephone 212/997-45 65

WALTER F WAGNER, JR . A.I.A.,

Editor

Marc h 27, 1975

S enato r James L . B uckle y

U nite d S ta te s Se na te

W ashin gto n, 0C 20510

Dear S enato r B u c k le y :

I have be en aware fo r about te n days th a t you ha d in tro d u c e d th e P u b li c 

B u il d in g C o rp o ra ti v e Use A ct w it h S enato rs B a ke r, M or ga n, and R andolp h. 

B efo re co mmen tin g I s h o u ld " d is q u a lif y " m y s e lf by tellriq you th a t I was a 

member o f Nancy H anks' F edera l Ta sk Fo rc e on G u id in g P r in c ip le s f o r 

Federa l A r c h it e c tu r e . I t s r e p o r t, I am su re you kn ow , s tr o n g ly endors es 

th e concept o f m ixed use in Federa l b u ild in g s . I e n c lo s e a co py o f a re c e n t 

e d i t o r i a l, G u id in g P r in c ip le s fo r Federa l a r c h ite c t u r e ; P a rt 2 . O r, why 

s h o u ld n 't th e go ve rn m ent liv e over th e s to re ? I t d e t a ils my e n th u s ia s tic 

b e lie f in th e concept develo ped in your b i l l ( I a ls o e n c lo s e an e a r lie r 

e d it o r ia l on th e Ta sk Fo rc e re p o rt o u t lin in g o th e r Ta sk Fo rc e id e a s w hic h 

I th in k are im p o rt a n t) .

S o .. .Y e s in deed I b e li e v e th e id ea is so un d and w o rk a b le . My o n ly sugg est io n fo r ch an ge s in th e b i l l r e la te to th e r e s t r ic t io n in S e c ti o n U, p ara ­

gra ph 16 e nco u ra gin g le ase o f sp ace on th e gro und f lo o r o n ly . I can 

e n v is io n a num ber o f d e s ir a b le p r iv a te uses w hic h m ig h t wan t sp ac e on two 

f lo o r s — fo r in s ta n c e a s to re o r re s ta u ra n t w it h m ez za nin e o r p ro fe s s io n a l 

o ffic e s w hic h m ig h t wan t s e m i- p u b li c space fu r t h e r up in th e b u ild in g . I 

can ev en e n v is io n th e p o s s ib ilit y o f a re s ta u ra n t on th e to p flo o r s o f 

Federa l o f f ic e b u ild in g s . In s h o r t, I suggest t h a t you c o n s id e r e li m in a ­

tin g t h is r e s t r ic t io n so th a t GSA o f f i c i a l s w i l l have th e o p tio n o f 

a c c e p ti n g p ro p o sa ls fo r le a se s on o th e r th an th e gro und f lo o r when th a t 

seems d e s ir a b le .

Where m ig h t th ese concepts be tr ie d ? I w ould sugqest th a t th e concept be 

te s te d as a p o s s ib ilit y w it h e v e ry new Federa l b u ild in g in any c i t y . I 

see no re ason why t h is is a b e tte r id ea in m a jo r c i t ie s as compared w it h 

s m a ll e r c i t i e s , o r v ic e v e rs a . S u re ly i t ought to be t r ie d in W ashin gto n— 

and th e p re s e n t p la n s fo r m ixed use in th e HLBB b u ild in g lo o k v e ry e x c it in g 

to me.
119

Senator Puckley

Paqe 2

March 27, 1975

I can't see any inhe rent energy or cos t savings in th is concept. But

the re nta l of such premium space w ill ob viou sly cut down the lif e cy cle

cost of the b u ildin g, and th at is a cle ar sa vinq . More im po rta nt is the

ad ditio n to urban v it a lit y th at w ill resu lt from your program. And I

th in k i t is the ri g h t image fo r the government to p ro je c t- -t h a t it s bu ild

ings are open encouraging publ ic entr y and a c tiv it y .

I am ju st deliq hte d you took the lea d in sponsoring th is b i l l . (Now how

about sponsoring one encou raging government use of wo rth wh ile ol de r

bui 1 ding s. )

p /s t rega rd s,

Walter F. Wagner,-

Edi to r

WFW/pv

enclo sures
120

mBANKof AMERICA

A R Z IP F

Exec utiv e Vice Pre side nt

May 7, 1975

Honorable James L. Buckley 

United States Senate 

Washington, D. C. 20510

Dear Senator Buckley:

Thank you for your letter of Ma rch 19 to Mr. Walter E. 

Hoadley, Executive Vice President, and for inviting our comments 

on the Public Buildings Cooperative Use Act of 1975. As Senior 

Administrative Officer, my responsibilities include the bank's 

real estate and cons truction activities; thus, we agreed it woul d 

be more approp riate for me to respond.

In addi tion to my own review, I invited comments from 

several associates; and our reaction is very positive in support 

of the dual objec tive s of the Bill. The concept of translating 

the government's needs for office space into a means for preserving architect ural ly and/or histori call y significant buildings and 

the idea of inte grati ng Federal offices into the local community 

and enco uragi ng private enterprise and public use are imaginative - 

and wo uld represent a refreshing depart ure from the traditional 

approach.

In our collective review several points emerged relating 

to the achiev abil ity of the objectives or to potential but not 

insurmountable problems in administration. Recognizing that most, 

if not all, have proba bly alread y been considered I n evertheless 

offer them wi th the hope that they will serve a constructive purpose.

- The twin goals relating to arc hite ctur al/h isto rica l preserv ation and to the Federal Gove rnme nt/local community relat ionship are not necessarily inter-depende nt and probably seldom 

coincidental. To have them inti mately tied together could 

perhap s reduce the potentia l of each to be realized.
Hon or ab le Jam es L. Bu ckley May 7, 1975

The a v a i l a b i li t y of s u ita b le s tr u c tu r e s w it h in an a d m in is tr a ­

tiv e a re a may pr ov e to be a pr ob le m . And i f th e re are few 

tr u ly s ig n if ic a n t a r c h i te c tu r a l/ h i s t o r i c b u il d in g s i t is 

v i t a l th a t th e us e not im pair th e ir im port ance . Thi s u su a ll y 

means ver y c a re fu l and p o ss ib ly ex pen si ve in te g r a tio n of new 

use s to av oid im pi ng in g on th e pri m ar y v a lid ity of th e s tr u c ­

tu r e s .

B u il d in g s, both of a r c h i te c tu r a l/ h i s t o r i c s ig n ific a n c e and 

of le s s e r s ig n if ic a n c e (aband on ed ra il w ay s ta tio n s , war eh o u se s, and s im il a r s tr u c tu r e s ) g e n e ra ll y become ec onom ic al ly 

f e a s ib le when o th e r co mmercial p r o je c ts in th e same a re a are 

bein g undert aken si m u lt an eo u sly or wh ere a d ja ce n t to commerc ia l p u b li c a re a s th a t ha ve be en r e v ita liz e d . In San F ra n cis co 

G h ir a rd e lli Sq ua re and th e Ca nnery a re e x c e ll e n t ex am pl es .

With re s p e c t to comm unity in te g r a tio n (p u b li c u s e /p riv a te 

e n te r p r is e ) i t would pro bably be w ell to gu ar d a g a in st o v erl y 

o p tim is tic e x p e c ta ti o n s . As an ex am pl e, i t is d o u b tf u l th a t 

most c itiz e n s ever th in k of goi ng to a p u b li c b u il d in g exce pt 

on b u sin e ss (a sid e from su ch b u il d in g s as th e Wh ite Ho use, 

Supreme C ourt , e t c .) . A ls o, th e us e g e n e ra ll y of F ed era l 

o f f ic e b u il d in g s on ly be tw een th e hours of 8: 00 a.m. and 

5: 00 p.m . i s a c h a r a c te r is tic th ey sh are w it h n e a rly ever y 

co mmercial b u il d in g in any la rg e c ity .

In g e n era l p re se n t b u il d in g co de s do not r e la te to nor enco urage th e re m odel in g of e x is ti n g h i s t o r i c a l s tr u c tu r e s and in 

some in sta n c e s bec au se of p ro v is io n s li m iti n g im prov em en ts to 

a p erc en ta g e of th e valu e of th e s tr u c tu r e , do not perm it 

e x te n siv e re m odel in g.

O ften in th e r e s to r a tio n of h i s t o r i c a l b u ild in g s , s t r i c t 

ad her en ce to b u il d in g co de s has d est ro y ed th e in te g r ity of 

th e ver y item s to be re s to re d o t p ro te c te d ; th e re fo re , co ns id e r a tio n mu st be giv en to a lte r n a tiv e me tho ds th a t pro vid e 

a re aso n ab le deg re e of s a fe ty to l i f e and p ro p e rt y .

In l o c a l i t i e s wh ere th e F ed era l Government use s i t s own guid elin e s th e q u e sti o n of code en fo rc em en t a u th o rity may a r is e 

when sp ac es are le ase d to p riv a te e n te r p r is e . P o ssib le co nf l i c t s be tw ee n lo c a l codes , F ed era l Code g u id e li n e s , and th e 

F ed era l O ccu pati onal S afe ty and H eal th A d m in is tr ati o n s ta n ­

dard s dese rv e c a re fu l a tte n tio n .
122

Hon or ab le Jam es L. Bu ckley May 7, 1975

The sa vin gs to be re a liz e d in re n o v ati n g an e x is tin g s tr u c tu r e 

ra th e r th an c o n str u c ti n g a new b u il d in g may be illu s o r y . In 

re c o n str u c ti n g an e x is ti n g b u il d in g , wh at is r e a lly sa ve d is 

g e n e ra ll y th e le a s t expen si ve p a rt of th e b u il d in g - th e s h e ll 

i t s e l f . In many in sta n c e s th e re m ai nin g s h e ll im po ses desi gn 

c o n s tra in ts th a t im pair th e e ffic ie n c y of th e re c o n str u c te d 

b u il d in g . U nit c o sts fo r re n o v ati o n work g e n e ra ll y ex ce ed 

th ose fo r new work sin c e th e pr ob lems of sch ed u li n g and se qu en cin g a re much more comp lex. And added to th is is th e c o st of 

b ri n g in g th e b u il d in g up to c u rre n t co de s or a cc ep ta b le guid elin e s .

I f s im il a r sta n d ard s fo r lig h tin g le v e ls , b u il d in g po we r, a i r 

co n d it io n in g re q u ir e m e n ts , e tc . are ap p li e d to both new and 

re novat ed b u il d in g s , en er gy demands w ill be s im ila r .

I hope th ese o b se rv ati o n s w ill be h e lp f u l. The B ill re pre s e n ts a fre s h and p o s itiv e ap pr oa ch and i f th e re i s any way we can 

be of a s s is ta n c e I ho pe you w ill l e t me know.

S in c ere ly
123

UNIVERSITY OF CALIF ORNI A. BERKELEY

BERKELEY • DAVIS • IB VISE • LOS ANCB LCE • RIVERSIDE • SAN DIEGO • SAN FRANCISCO SANTA BARBARA • SANTA CRCZ

COLLEGE OF ENVIRONMENTAL DESIGN

DEPARTMENT OF CITY AND REGIONAL PLANNING

BERKELEY. CALIFORNIA 94720

Mar ch 28, 1975

Senator J ames Buckley 

United States Senate

Com mittee on Interim and Insular Affairs 

Wash ington, D.C. 20510

Dea r Senator Buckley:

Thank y ou for the opportunity to comment on S. 865, the 

"Public Buildings Cooperative Use Ac t of 1975".

Basically I agree with what I un derstan d to be the thrust 

and purpose of the bill. Here speci fical ly, my comment s 

are:

. Section (1), p. 2, line 3: The prob lem here is that 

the Admi nistrator of Gen era l Services, or his agents, 

if they wi sh to, can and wil l always find reasons why 

the use of an old buil din g is not feasible or prudent

. Section (3), p. 2, line 12: Why this section? Here 

you begin to transgress into local respons ibil itie s 

and desires.

. Section (5) p. 2, line 22: Good.

. Page 4, lines 4-12: Good.

I hope the above helps

*

Sinc erel y yours

Prof esso r of C ity & Regiona l Planning

ABJ:py
124

THE OLIVER T. CARR CO MPA NY

A p r i l 4 , 19 75

T he H o n o ra b le Ja m es L . B u c k le y 

U n it e d S t a t e s S e n a te 

W a sh in g to n , D. C. 20 51 0

D ea r S e n a to r B u c k le y :

T han k you f o r g iv in g me th e o p p o r t u n i t y t o re v ie w 

t h e " P u b lic B u ild in g s C o o p e r a tiv e U se A c t o f 1 9 7 5 " . I 

com men d you f o r i n t r o d u c in g t h i s im p o r ta n t b i l l . The 

f o llo w in g co m m en ts an d s u g g e s tio n s a r e f o r y o u r c o n s id ­

e r a t i o n :

1 . On p ag e 2 l i n e 3 , i n s t e a d o f " a c q u i r e " , " l e a s e 

o r p u r c h a s e " m ig h t b e i n s e r t e d t o e n c o u ra g e th e 

r e t e n t i o n o f s u i t a b l e b u i l d i n g s o f h i s t o r i c a l 

an d a r c h i t e c t u r a l s i g n i f i c a n c e b y t h e p r i v a t e 

s e c t o r f o r p u b l i c u se as w e ll a s by t h e p u b l i c 

s e c t o r f o r i t s own u s e .

2 . On p ag e 2 l i n e 12, I w ould s u g g e s t t h a t s p e c i f i c s 

r e g a r d in g t h e i n t r o d u c t i o n o f c o m m e rc ia l an d 

r e l a t e d f a c i l i t i e s i n t o o r n e a r GSA b u i l d i n g s 

s h o u ld i n d i c a t e t h a t su ch f a c i l i t i e s m ig h t b e 

in tr o d u c e d t o e x i s t i n g GSA b u i l d i n g s a s w e ll a s 

b u i l d i n g s t o b e a c q u ir e d , l e a s e d , o r c o n s tr u c te d 

in t h e f u t u r e .

I b e l i e v e t h a t r e t a i n i n g b u i l d i n g s o f h i s t o r i c a l o r 

a r c h i t e c t u r a l s i g n i f i c a n c e an d th e i n t r o d u c t i o n o f comm e r c i a l an d r e l a t e d f a c i l i t i e s i n t o an d a ro u n d p u b l i c b u i l d ­

in g s a s w e ll a s e n c o u r a g in g p u b l i c u s e o f p u b l i c b u i l d i n g s 

i s a so und a p p ro a c h t o p r o v id in g t h e k in d o f a m e n itie s 

in t h e co m m unity n e c e s s a r y t o s e r v e t h e n e e d s o f b o th w o rk e rs 

in p u b l i c b u i l d i n g s an d t h e n e ig h b o rh o o d o f w h ic h t h e p u b l i c
125

The H o n o ra b le Ja m es L . B u c k le y 

P age Two 

A p r i l 4 , 19 75

• b u i l d i n g s h o u ld b e a p a r t and n o t i s o l a t e d fr om b e c a u s e 

o f i t s d e s ig n o r u s e . T he so c a l l e d " K e i t h 's T h e a tr e 

B u ild in g " in W a sh in g to n , D. C. a t t h e c o r n e r o f 1 5 th an d 

G S t r e e t s , N. W ., i s an ex a m p le o f a b u i l d i n g w h ic h m ig h t

* b e le a s e d fr om p r i v a t e o w n ers a f t e r r e n o v a tio n o r a c q u ir e d 

b y t h e G o v ern m en t f o r i t s o c c u p a n c y .

I do n o t b e l i e v e t h a t i t i s p o s s i b l e t o ju d g e w h e th e r 

o r n o t t h e c a p i t a l o u t l a y t o e i t h e r u p g ra d e o r o p e r a t e 

o l d e r s t r u c t u r e s w i l l b e m ore o r l e s s e x p e n s iv e th a n b u i l d ­

in g an d o p e r a t i n g new s t r u c t u r e s . P r o j e c t s w i l l h a v e t o 

b e a n a ly z e d on an i n d i v i d u a l b a s i s . I do b e l i e v e t h a t 

e x i s t i n g s t r u c t u r e s s h o u ld b e r e n o v a te d an d a m e n it ie s added 

w h ic h w i l l s e r v e t o e n h a n c e t h e com m unit y in w h ic h th e y 

a r e lo c a t e d an d p r o v id e t h e k in d o f s e t t i n g t h a t w i l l a s s i s t 

t h e G overn m ent in i t s e f f o r t s t o a t t r a c t an d r e t a i n t h e 

s e r v i c e s o f h i g h l y q u a l i f i e d p u b l i c s e r v a n t s i f i t i s e c o n ­

o m ic a lly f e a s i b l e t o do s o .

P le a s e c a l l o r w r i t e i f I c a n p r o v id e any m ore 

in f o r m a ti o n t o yo u o r y o u r c o m m it te e .

S i n c e r e l y ,

O l i v e r T . C a r r , J r .

O T C ,J r:b jw

54-188 0 - 7 5 — 9
126

CHLOETHIEL WOO DAR D SMITH A ASSOCIATED ARCHITECTS 

10% THO MAS JEFFERSON STREET, N .W . WAS HINGT ON . D. C 20007 202— 5 W 7440

CHLOETHIEL VOOOARD SMITH FAIA

Pl fDAK A VEST AIA

Ai< HA AD I PAST HAL AIA

CA1L A K OH LEA AIA

GENE AAY LEVIS AIA CASLB ADDSBSS TIN FI VIS IX

April 1, 1975

Senator James L. Buckley 

United States Senate 

Room 304

Russell Senate Office Building 

Washington, D.C. 20510 

Dear Senator Buckley:

I thank you for your March 19th letter, a copy 

of the "Public Buildings Cooperative Use Act of 

1975" and your floor statement on the intent of 

the legislation. It is an exciting proposal and 

one that could contribute greatly to the humanization, rehabilitation and reuse of U.S. towns and 

cities. It is increasingly apparent that many 

factors, not the least being energy problems, will 

force us to reconsider our urbanization methods.

This will require major changes in legislation 

framed in the past when continuing expansion into 

the countryside surrounding our towns and cities 

resulted in the abandonment and deterioration of 

usable and often distinguished older structures, 

as well as the under-use of urban land. Your proposed legislation is not only timely, but could 

provide directions for other actions which will be 

needed to solve our urban problems.

I have some question as to implementation. It *

appears to depend on an "administrator" to initiate 

and activate the program. I would think that a 

strong, independent Commission might be more effective 

in establishing a broad program, promoting it, and

following its progress. •
Senator James L. Buckley April 1, 1975

-2-

Perhaps the proposed legislation could be 

broadened to stimulate a greater response 

by a Commission. Perhaps, instead of "To 

promote more efficient use of the nation's 

construction resources" as the first part of 

the bill, it should start with "people and 

their lives in cities" and should include a 

strong, clear statement of design principles.

The definition of "design" is difficult, but 

it should be included as a reminder that it 

is as essential to the reused environment as 

to the new. Perhaps the designation of the 

National Trust only is too limiting — the 

National Endowment for the Arts and many other 

public and private organizations are needed.

And last — specification of "the ground floor" 

in line 18 on page 4 could be unnecessarily 

limiting and seems unnecessary.

As for "buildings and cities where these concepts might be effectively tried", I would think 

a Commission should determine these after it has 

developed a complete program. And any estimates 

on cost savings are premature and should only be 

made by such a Commission. Savings are a goal 

but, until there is a clear program, I don't believe 

they can be quantified.

Again, my great appreciation for your inquiry and I 

hope that your very important and exciting bill will 

be passed.

Sincerely yours

Chloethiel Woodard Smith

cws/hgk

P.S. You might be interested in the attached on 

"Growth Limits" — the Club of Rome and 

Texas is an interesting combination.
128

I* Public Works 

Canada

Travaux publics 

Canada

Capital Region Region de la Capitate

April 22, 1975

Mr. James L. Buckley 

Unit ed States Senate

Washington, D.C. *

20510

Dear Mr. Buckley:

Thank you for your letters of March 19, 1975, to mys elf and Mr. R.

Giroux, my Chief, Space Management and M arketing. I am pleased that 

we were able to be of some ass ista nce to your group w orking on the 

Federal Architecture Project.

Details of our activ ity in this area were discussed in July 1974 with 

Mrs. Lois A. Craig, Staff Director, Guiding Principles for Federal 

Archite ctur e a nd these are still current today.

I w ould like to reiterate that our Depar tment of Public Works' policy 

is to attempt to bring vitality to our Federal complexes, as well as 

to avo id the ster iliz atio n of prim e comme rcia l areas in city core areas 

caused by the cons truc tion of Federal offic e buil ding s devoid of any 

public activ ity except that normally asso ciated wi th the building 

occup ancy itself during office hours. Wit hin this broad policy, we 

have been actively studying markets in the various city cores and where 

demand exists for commercia l activity, we are anal yzin g the economics 

of utiliz ing lower floor space in our building s for such use.

In all of our new large office complexes, we carry out as part of our 

initial design studies, a marketing survey to determine the demand and 

viability of commercia l activity in such complexes. If our study «

indicates a n eed for commerc ial retail facilities, we then strive to 

incorpo rate such activity within the lower floors of our buildings.

As you can well underst and, where we ha ve the oppo rtunity to carry out

such studies in the pre -design stages of maj or complexes, the final

result can be quit e exciting. <

It sh ould be noted, however, that there are occa sion s wher e the Go vernment buildi ngs might be the catalyst for new developmen t in a blighted 

area in the core of a city. Such is the case in many of our urbanrenewa l schemes. We have realised that in such develop ment s the 

comm ercial space is unlike ly to be economic ally viable, and not easily 

rented, for the first year s and until such time as the neighborh ood is 

developed. This doe s n ot p reve nt us from designing and constr ucti ng 

commercial space, whi ch w e m ight use for o ther purposes until such time 

as the demand for it arises.
129

with re fere nce to the r enovation o r rest orat ion of designated heri tage 

buildings, or hist orically sign ifica nt buildings, we do have many 

examples where we have chos en to renovate rather than demolish. A 

number of examples were discusse d w ith Mrs. Crai g during her visit.

There are examples, of course, whe re a "highest and best use" study 

might indicate that econom ics wou ld argu e demol itio n and new c onstruct ion rather than renovation. Restorat ion ca n, however, produce 

attractive offi ce space whil e at the same time adding a sense of 

scale and cha rm to the city scene: this in addition to pro viding a 

link with history. I w ould suggest, however, that decisions in this 

area can neither be mad e all by "heart" nor all by "economics": a 

great deal of judge ment is required.

While the above outlines our general phi losophy and approach, you had 

asked a number of specific que stions wh ich I will attempt to answer.

In relatio n to commercial activities, you were interested as to whether 

we had any sugges tion s as to whic h buildings or cities should receive 

atten tion in the first instance. I think that o ne would logically look 

first to major bu ildi ngs in fairly large popu lation centres. In the 

case of the retention and reno vati on of build ings of histori c interest, 

this c ould apply to any centre and each case woul d have to be judged 

on its own merit.

To come back to commercia l activit ies, the intr oduction of such faci lities 

into major Gover nmen t compl exes poses cer tain proble ms as I pointed out 

earlier. One of the co ncern s relates to the first years of occupancy.

This applies part icularly in an area that m ight be c onsi dere d part of 

an ov eral l rede velo pmen t plan, and p ossibly an area that had v ery little 

comm ercial activit y prior to redevel opment. Where commerci al facilities 

are introduc ed into a Governm ent buil ding in an already viable commercial 

area, the same concerns in relat ion to a devel opin g mark et of course 

would no t apply to the same degree. A further caution related to earlier 

years w oul d be to not attempt the opening of any commercial faciliti es 

in a Fe dera l compl ex while cons truc tion mi ght still be goin g on in a 

part of that complex. It is our g enera l feeling that the idea of incorpora ting commercial areas into selecte d Gover nmen t comp lexe s is not 

only a via ble one from the po int of vie w of the greate r o verall benefit 

to the community, but also one that can be economica lly viable.

In the re storation/ reno vati on of buildings of historic significance, and 

to be use d for on-go ing use as of fic e buil ding s o r whatever, it is impossibl e to gen eral ize in relatio n to "life costs". There are many 

factors to be considered. I referre d earlier to "highest and be st use 

studies". There are also heritag e consid erations. Both of these, of 

course, have to be relate d to cost and b udge t as we all know.

54-1 88 O - 75 — 10
130

While we are enthusiastic about what we are atte mpting to do, we really 

do not have that many years of experience behind u s in these areas to 

enable us to be more sp ecifi c in relation to some of the quest ions you 

had posed. Nonetheless, we feel that the overall obje ctives are valid 

and hold out a grea t deal of promise.

I hope that these thoughts prove to be of some help.

Yours very truly,

H.D. McFa rlan d 

Regional Directo r 

Capital Region
131

CENTER FOR THE VISUAL ENVIRONMENT

1525 N ew H am pshire A venue, N.W , W ashin gto n, D.C. 2003 6 (202) 797-1403

June 1, 1975

Senator James L. Buckley 

Committee on Pu blic Works 

United States Senate 

Washington, D.C.

Dear Senator Buckley:

Thank you fo r your le tt e r regarding the Pu blic Building s Cooperative Use 

Act of 1975. We appreciate th is op po rtu nity to comment on th is important b i ll.

The Center fo r the Visual Environment is a non-p ro fit or ga niza tio n, funded 

through Environmental Action Foundation, which assis ts people in th e ir dir ect 

eff ort s to pr ot ec t and enhance th e ir physical surroundin gs. The Center serves 

a na tiona l constitu ency, co ns isting la rg ely of citiz en groups and in div id uals .

The Center represe nts the be lie f th at the physical aspects of a neighborhood or 

c it y re fl e c t the health and v it a lit y of the citiz e ns, and the nature of the 

c it y it s e lf. We are committed to ma intain ing and improving neighborhoods, and 

working fo r visu al elements which are not only pleasing but re fl e c tiv e of the 

reside nts. The ro le of div ers ity in ma intain ing the lif e and sense of d e fin itio n 

of an area cannot be over-stated. Un fortu na tely, planning and co ns tru ction trends 

of the past decade have been away from div ers ity and toward single -function land 

use designations and single -funct io n bu ild in gs . We are now seeing with c la rit y 

how de structive these trends have been. The Federal government's polic ie s in 

co ns tru ction, lea sing and renting have helped create the anonymous, dead areas 

which now characterize many c it y loca tio ns . According ly, the Federal government 

is in a po sitio n to make a cruc ial di ffe re nc e in changing th is scene fo r the 

better. The Center is de lighted at the whole new direction fo r Federal po lic y 

which S. 865 represents.

There are sev eral specific comments we wish to make.

1. The key to effective implementation of th is b i l l , cle arl y, is the 

bu reau cratic in te rp re ta tion of "feasib le and prudent" altern atives. 

Ho pe fully, GSA w il l assume the positiv e att itude of the b ill's sponsors 

and not s e tt le on a narrow, overly-q uantified method fo r making these 

decision s.
132

Center fo r the Visual Environment 

Page 2

For example, many citiz en groups who are involved in eff ort s to save

bu ild ings from demo lition are presented with a fin ding by an engineerin g

consultant th at the bu ild ing is not sound, and that modernization would «

be too co stly to consider. These stu die s are prepared at the request

of the agency which wishes to des troy the prop erty. Our experience

has been that i f time allow s a second survey to be made, by a firm

with some experience in re h ab ilita tion work, the re su lts are ge ne rally

qu ite d iffe re n t. This re flects not only the subconscious desire of «>

consultants to please the c li e n t; i t shows the simple diffe renc e

experience makes in working with olde r stru ctur es .

We strong ly urge that GSA develop sympathetic c rit e ria fo r structu ra l

analysis of old er bu ild in gs, u til iz in g people with knowledge of th is

work. We also recommend that GSA examine and use a study conducted

by the City of Sea ttl e, in cooperation with the National Tru st , showing

how olde r bu ild ings can be brought to build in g code requirements with ou t

enormous expense or loss of th e ir in te g rit y .

2. The surveys fo r sig nific a nt bu ild ings req uired by the b ill must be

conducted in a thorough and ca reful manner. We urge th at local citiz en

groups (preservation so cieties and others) be used, or th at these groups

at least be allowed to comment on av ailable build in gs. Local res ide nts

have the best fe el fo r bu ild ings which have community sig nific ance, fo r

real tr a ffic * pa tte rns, and fo r locatio ns where re h ab ilita tion of a pro perty 

or des ignatio n fo r mixed-use might tr u ly benefit an area.

3. S im ilarly, we strong ly recommend th at the community be allowed to

partic ip ate in the decision-making process fo r the se lection of commerical

rental clients . Federal bu ild ings are paid fo r by the public , and

responsiveness to the community must go beyond simple market economics.

Selec tion of commercial clie nts w il l not be an easy process, but we

believe the desires and needs of the community should be as valid a

c rit e ria fo r se lection as any othe r. A super market, fo r ins tance, is

often a stro ng need of city reside nt s, and would serve the day-time

working population of a bu ild ing as w ell.

4. I t is p a rt ic u la rl y important th at small olde r build in gs, of the type ♦

often described as the vernacular ar ch ite ct ur e of an area, be u ti liz e d .

Placing Federal offic es in areas where th e ir physical is ola tion is reduced

can only be an improvement over the present situa tion . The more small

structures are used (and there are certain ly many Federal offices which

do not need to be pa rt of a mammoth la byr in th to fu nction,) and the more *

mixed-uses can be adopted, the more the growing Federal paranoia and

exclusiveness w ill be reduced. The estrangement of government from

people is cle arly a major problem of our tim e, and i t applies at a ll

leve ls. Let the Federal government take the leadership in changing

th is a tt itu d e , by making it s o ff ic e s, inform ation and personnel tr u ly

av ailable.
133

Center fo r the Visual Environment 

Page 3

5. The c rit e ria fo r se lecting Federal users fo r prime space contained 

in the le g is la ti o n , those "requ iring regu lar contact with members o f the 

public," should also be used and extended fo r se lecting commercial re nta l 

c lie n ts . F a c ilit ie s with long open hours should have p rio rit y over those 

which close ea rly or often. We p a rt ic u la rl y recommend the in clus ion of 

res tau ran ts wherever possible.

6. Many new Federal bu ild ings are generating large open areas. Some 

are popular and some are not. We wish to bring to the atten tio n o f the 

Committee a study now underway in New York City evalu ating plazas and 

other urban open spaces. The author, well-known w ri te r and scholar 

William H. Whyte, describes in the attached a rti c le simple changes 

which can con vert barren, d ir ty or dangerous expanses of concrete

in to att ra ctive and useable areas fo r people. We recommend that GSA 

be directed to study th is repo rt and inc orporate it s common-sense 

conclusions in to present and fu tu re Federal plaza areas.

The Center works with many people across the country who are pa rt of an e ffo rt 

to ap preciate, pr ot ec t and enhance the physical and so cial aspects of our c it ie s 

Citi es are s t i l l the he art of our- c iv il iz a ti o n and the magnets fo r our population . We welcome th is op po rtu nity to share our views with the Committee, and 

look forward to a changed and po sitiv e approach by the Federal government toward 

c it ie s as a re sult of th is b i ll.

Sin cerely yours

Nancy/Cai 

Di rector
134

DOWNTOWN BROOKLYN DEVELOPMENT ASSOCIATION. INC.. 2 6 COURT STREET. BROOKLYN. NEW YORK 11242, TELEPHONE (2 12 ) 522 7200

March 25, 1975

The Hon. James L. Buckle y 

Uni ted States Senat e 

Washington, D. C. 20510 

Dea r Senator Buckley:

Thank you for your letter of Ma rc h 19 a nd the accom panyin g material 

on you r propose d "Public Bui ldin gs Coopera tive Use Act o f 1975. "

The concep t is enormou sly important, I think. Hav ing spent last 

Friday in Albany and the p revi ous Frid ay in Washington, I've be en 

esp eci all y depre sse d at a fund amental inequity in ou r societ y— whi ch 

is t hat the capita ls seem to hav e unto ld billion s to spend i n deve lopi ng 

inc redible and sterile archi tectura l mont ment s wh ile a great a nd private ly 

pro ductive place like D ownto wn Broo klyn finds it alm ost imp ossi ble to find 

eit her priva te o r public capital to bu ild anything. If you could somehow 

develop a com parison as the dev elopment-c ost- per- pers on bene fit ed ( or even 

per -person-abl e-e ver -to -se e-t he- bui ldi ng) , the d ifferen ce betw een Wash ing ton 

and Brooklyn, or b etw een Alb any a nd Brook lyn mu st be 100-to-one.

We ar e taxing the prod uct ive sector o f our society, esp eci all y in majo r 

cities, to a p oin t whe re its collapse must be cons ide red a re al 

possibility. If monu men t-b uildi ng is n ot the chief rea son for th e gre at 

burden, it is at least the mos t visible, and it is r ankl ing indeed.

Wi th all our chau vinistic h opes for progress in Downt own Brooklyn, we 

do no t feel we nee d an oth er governm ent building. Wh at we do n eed is 

exa ctly what you pr opo se— that th e offic e space ne eds o f the national, 

state, cit y an d bor ough gover nme nts be utiliz ed inte lli gen tly to 

stimul ate mixed -use pri vat e construct ion and recy cli ng e fforts. As 

yo u indicate in your floor statement, Ne w Yor k Ci ty has be gun to do 

some of this, and it has b ee n ben efi cia l to the ec ono my o f our area.

I've no way of provi din g estimates as to savings that migh t resu lt 

fro m yo ur prop os al , but also no doubt that they wo ul d be e no rm ou s.

As to build ing s and cities where these concepts mi ght b e mo st 

effec tiv ely tried, I've two suggestions: 1) Wo rk wit h us in Downt own 

Brooklyn as it relates to Fe der al space needs in the N ew York
135

The Hon. James L. Buckley March 25, 1975

-2 -

metropo litan ar ea ; 2) Ask the approximately 100 members, in as many c it ie s , 

of the In te rn at io nal Dcwntown Exe cuti ves Assoc iatio n—of which I am 

pre si dent- ele ct—fo r th e ir ideas in each lo cali ty .

The most re ce nt issu e o f our ne w slet te r, enclo sed , has an "ed it o ri al" on 

page 2 which you may fi nd in te re st in g and somewhat connected with the 

matter you ra is e.

Please le t me know i f we may pro vid e anything more hel pfu l.

Sinc erely ,

Donald E. Moore 

Pr es iden t

*
136

DO W N TO W N PRO GR ES S

ixicut ivi committii Notional Capital Downtown Committee, Inc. 52 b i 2th Street, N.W. Washington D.C. 20004 • 393*8387

Thornton W Ow»n Knox Bonner Executive Direct'

Chairmen o

i me Board

Ed*>n h Mo«man

Donald S Bittinger

Chairman [lacuhna Commitlaa

Richard E Steen

Sidney Lantburgh Jr

Traaaurar and fmanca Chairman

Michael 0 Brook*

A*smant Traaaurat

Calvin Calntc

April 3, 1975

Theodore R Hagan* Jr

Thoma* A Hay*

John h Kaultmann

George P Kelly

Fo»ler Shannon

C Duke Brannock £* Othoo

Sol LinowiU E* Othoo

Joseph h Riley f« Othoo

BOARD OF DIRECTORS

Franci* G Addi»on III

Marlin Alla*

Robert C Bakei

S Meyer Bameii

W.ii.am . Rati

Leo M Bernstein

Donald S Billmger

Allan J Bloottem

T William Blumenauer Jr

George M Brady Jr

B Bernei Burgunder Jr

Vincent C Burke Jr

Calvin CafnU

Oliver T Carr Jr

Jame* E Cheek

W Graham Claytor Jr

O S Coiclough

Marshall B Coyne

C D Daniel

George W Delranceaun

Cleveland I Dennard

Lloyd H Elliott

Edward L Feggant

Theodore R Hagan* Jr

Thoma* A Hay*

Emeu L Hogan

Darnel L Hurson

George P Kelly

Robert K KoonU Jr

Sidney Lantburgb Jr

Beitnrd V lawion Jr

W Jarvis Moody

E K Morns

Donald Holman

George Oimtied

Thoma* J Owen

John S Pre*cott Jr

Paul E Reichardt

Frank H Rich

William RobmowiU

Douglas R Smith

Jeffrey G Spregen*

Richard E Steen

The Honorable James L. Buckley 

United States Senate 

Washington, D. C. 20510 

Dear Senator Buckley:

Thank you for your recent letter inviting the 

comments of Downtown Progress on S. 865, the 

"Public Buildings Cooperative Use Act of 1975."

We are pleased to offer this letter for the record 

at the hearing that you indicate should be 

scheduled shortly.

We are delighted to support this legislation 

since we have been working for more than twelve 

years to encourage the use of ground floor space 

in public buildings for commercial and related 

activities for the very reasons you state. As 

you know, Downtown Progress is also active in support of appropriate historical and architectural 

preservation in the square mile of Downtown 

Washington between The White House and The 

Capitol. We have played a major role in Ford's 

Theatre restoration, preservation of Adas Israel 

Synagogue, and preservation of the landmark Union 

Station for its conversion to National Visitor 

Center use. We are now working with others to help 

advance prospects for the reopening of the Willard 

Hotel and for the creative reuse of the Old Post 

Office Building.

S. 865 encourages "cooperative use" and 

"adaptive use" in the Federal office building 

program. This should do much to advance prospects 

for the creative reuse of buildings such as the 

Old Post Office. As you have pointed out in 

introducing the bill, this " . . . would bring new 

life, new activity, and new vitality to the blocks 

around . . . Federal office building (s)." This 

"better neighbor" approach on the part of the 

Federal Government could help immensely in carrying 

out downtown revitalization programs in many 

cities, including the Nation's Capital. A host of 

public initiatives have been taken to accomplish

♦

Larry c Williams Sr

Bani M Winstead
Downtown revitalization here, including the planning for 

Pennsylvania Avenue, Downtown redevelopment actions, and METRO. 

The success of these initiatives is important nationally as 

well as locally for many reasons including the fact that 

Washington is regarded as a model for the country. S. 865 would 

provide additional, positive, reinforcement to the thrust of 

these public efforts. With S. 865 enacted, practicable ways 

could be explored for incorporating compatible uses, attractions, and activities in buildings within the Federal Triangle, 

for example, in order that the millions of visitors to 

Washington, D. C., annually can be better accommodated and 

served and can have a more enjoyable and educational experience 

here. It may be still possible to incorporate active uses 

along the ground floor frontages of the J. Edgar Hoover 

Building also, substantially adding to its vitality and that of 

Downtown. Our earlier efforts to accomplish this in the 

design, prior to construction, were not successful.

The concepts embodied in S. 865 appear to be sound and 

workable. This legislation could do much to advance downtown 

revitalization efforts here and elsewhere. Downtown Progress 

heartily supports the bill and urges its prompt enactment and 

implementation.

Thornton W. Owen 

Chairman of the Board
138

D U B IN - M IN D E L L - B LO O M E

A S S O C I A T E S , P .C .

C O N S U L T I N G E N G I N E E R S

F R IO S. D U B IN , R.B . • HAROLD L. M IN D E LL. R E ■ BEL W YN BLO OM E. R E

R E P L Y TO

42 W ES T J IT M STREET

NEW YORK N V. 10 018

March 24, 1975

Honorable Jeunes L. Buckley 

United States Senate 

Washington, D.C. 20510 

Dear Senator Buckley:

In your letter of March 19, 1975 you ask if I would offer 

an opinion on Bill S.865 "Public Buildings Cooperative Use 

Act of 1975". I would like to offer the following opinions 

which are my own, based on my personal knowledge, and 

emphasize that these do not necessarily reflect the opinions 

of the American Consulting Engineers Council for which I am 

the Chairman of the Energy Committee.

I heartily endorse the idea of multi-use buildings for the 

following reasons:

1. The capital costs of building and mechanical and electrical systems are lower.

2. Energy consumption is less in the buildings.

3. Energy consumption for transportation is reduced when 

facilities are combined. It has been our experience that 

combined facilities may reduce the initial size and capital 

costs of mechanical equipments by 15 to 20% as compared to 

housing the same functions in dispersed structures because 

the multi-use buildings take advantage of diversity in sizing 

equipment.

Consumption of energy in the multi-use building will generally 

be less than separate structures for the same functions, due 

to a great reduction in building area, i.e. same corridor 

space can supply the diversified functions within one building; 

whereas the corfidorspace would have to be duplicated in separate structures> and the reduced perimeter area, in most cli ­

matic zones of the country, will result in energy savings for 

the multi-use buildings.

(Cont'd. page 2)
Honorable James L. Buckley -2- 3/24/75

By renovating existing buildings, rather than constructing 

new structures, considerable less energy will be required 

in the production and distribution of construction materials.

While the energy required for construction materials is 

generally less than 1/20 of the energy required to operate 

the building, it is still a considerable quantity and must 

be reckoned with in view of the energy situation as it 

exists today and in the foreseeable fut ure .

In our energy studies we have found that buildings of later 

vintage than 1950, generally consume less energy than those 

built in the last decade.

While some of the difference in energy usage can be contributed 

to lower levels of lighting and less air-conditioning, after 

making allowance for these differences, the energy used for 

old buildings is still less than the newer ones because of 

the thicker walls which provide thermal mass and smaller 

win dow s.

We are finding that the lower levels of lighting and a reduced 

amount of air-conditioning are often adequate and are unlikely 

to be raised to the same thoughtless levels that have been 

characteristic of buildings design within the last 10 to 15 

yea rs.

I have recently completed a study and report for the Federal 

Energy Administration consisting of two volumes, each about 

350 pages long, devoted to energy conservation for existing 

buildings. These reports document our findings that, it is 

possible to conserve almost as much energy in the operation 

of the heating, ventilating, air-conditioning, lighting and 

power systems by retrofitting an existing building, as it is 

in the operation of these systems in a new building designed 

for energy conservation, especially when extensive modifications to the interior of the existing building are required 

for other functional use.

The interior of buildings can be retrofitted without destroying or altering the exterior facades, so that buildings of 

historic and architectural significance, will not be adversely 

affe cted.

I would urge that any building which the Federal Government 

retrofits for i ts ’ own or co-operative use, that an energy 

budget be established which limits the number of B TU 's per
Honorable James L. Buckley -3- 3/24/75

square foot per year it consumes for all services. There is 

sufficient data available now to promulgate energy budgets 

and interim standards for design and construction to attain 

the energy budget.

I would respectfully suggest that demonstration buildings be 

selected in six distinct climatic zones within the United 

States to develop and test the concepts and philosophy expressed 

in the Bill S.865, and in accordance with our suggestions for 

energy budgets.

I appreciate your asking me for opinions on the Bill.

Yours sincerely

DUBIN-MINDELL-BLOOME ASSOCIATES, P.C

Fred S. Dubin, P.E 

President

FSD/bb.
141

First National Bank in St. Louis

Broadway. Locust. Olive, Sixth 

St. Louis. MO 63166

Clarence C. Barksdale 

President 

314/342 6201

March 28, 1975

Honorable James L. Buckley 

United States Senate 

Washington, D. C. 20510

Dear Senator:

In response to your letter of March 19, 1975,

I want to thank you for sending to me a copy of 

your "Public Buildings Cooperative Act of 1975" 

and requesting my reaction to that bill.

While I am not eminently conversant with the 

intracacies of our Federal Government's present policy 

toward creating needed facilities, I am impressed 

with your suggestion that, wherever possible, we 

attempt to make use of existing office space and 

"recycle" existing buildings into new federal offices, 

where appropriate. Conceptually, I am in agreement 

with your approach to this problem, and I commend 

you for your efforts to avoid the creation of expensive, and sometimes inefficient, new monumental types 

of structures.

I hope that this will be helpful in your efforts 

to promote approval of your bill when hearings are 

held before the Senate Committee on Public Works.

Sin cer ely ,

Clarence C. Barksdale

CCB :pc
142

Jr ed er ick (ju th eiiru a ip

1750 Pen nsy lvania Aven ue NW Washin gto n DC 20006 Tel ephone: ( 202 ) 298 - 7780

P ro fessio n a l M em b e rsh ip s America n institute of planners hon American institu te op architects American association op museums

SOCIETY OP ARCHITECTURAL HISTORIANS NATIONAL TRUST FOR HISTORIC PRESERVATION

*

25 March 1975

The Hon or ab le Jam es L. Buckl ey 

U ni te d S ta te s Se na te 

304 R u sse ll O ff ic e B uildin g 

W ashing ton, D.C. 20510

Dear Sen at or Bu ck ley:

Tha nk you fo r se ndi ng me S. 865 and re q u e sti n g comment. I ha ve lo ng been 

in te re s te d in th is s u b je c t.

The p r io r ity giv en h is to r ic and o th e r e x is ti n g b u il d in g s is a welcome re co gn itio n of bot h th e need to e n li v e n th e p ubli c wo rking en vi ro nm en t and to 

ach ie ve p re s e rv a ti o n o b je c ti v e s , p a r tic u la r ly in th e ca se of th e la rg e r 

s tr u c tu re s su ch as p u b li c b u il d in g s , ra il ro a d d e p o ts , e tc . I t may ev en sa ve 

money. Th is cate gory of b u il d in g sh ould be br oa d enoug h to in clu d e some 

im port ant n o n -a rc h it e c tu ra l s tr u c tu re s th a t are u su a ll y consi dere d works of 

e n g in eeri n g ; and th e le g is la tio n sh ou ld consi der th e p o s s ib il ity of a lte r a tio n 

o r a d d it io n s to e x is tin g s tr u c tu r e s , and some desi gn prob lems a sso c ia te d w ith 

su ch ch an ge s. Th is su g g ests amendments to Se c. 2, (1 ).

The o b je c ti v e of d iv e r s if ie d use is a ls o a welcom e a u th o riz a ti o n but re q u ir e s 

more d e ta il e d d is c u ssio n and p ro v is io n . In p a r tic u la r , i f one re cogniz es 

p re se n t s e c u rit y ar ra ng em en ts (an d I b e li e v e th ese a re th e ma in b ar to p u b li c 

use of p u b li c b u il d in g s) th e more p ra c ti c a b le m ea su res towa rd e n li v en in g th e 

p u b li c working en vi ro nm en t w ill be (a) a f te r hour s u ses; (b) s e rv ic e s to 

occ up an ts of th e b u il d in g , or u s e rs of p ubli c s e rv ic e s ; (c ) s p e c ia ll y or gan iz ed 

e v en ts , su ch as c o n c e rt s, le c tu r e s , e tc . I t sh ould a ls o be re co gniz ed th a t 

th e p rin c ip a l are as us ed w ill not be th e F ed era l o ff ic e sp ac e pro per but 

lo b b ie s, c o rrid o rs and o th e r p u b li c sp aces, o u ts id e sp ac e (v iz Se c. 4 (1 7 )). 

Pe rh ap s i t would be wor th sp e c if y in g th e o b je c ti v e of th e se a u th o riz a ti o n s 

as bein g d iv e rs if ie d u se , a l i v e l i e r s o c ia l at m osp her e, e tc .

Se c. 3 (3 )(c ) re q u ir e s c o n su lt a ti o n w ith th e N ati onal T ru st fo r H is to ric 

P re se rv a ti o n . The A d m in is tr ato r sh ould fu r th e r be re q u ir e d to c o n su lt th e 

N ati onal R eg is te r of H is to ric P la ces and S ta te r e g is te r s o r in v e n to ri e s of 

h is to r ic b u il d in g s . I hop e th a t pre vio us experi ence in th is conte xt ha s be en 

examin ed to det er m in e i t s e ffe c ti v e n e s s and any a ss o c ia te d pr ob le m s.

In co n clu si o n , I f e e l th e g re a te s t b e n e fit s w ill come from th e us e of F edera l 

sp ac e a f te r working h o u rs , and by th e ground flo o r co mmercial us es an d/o r 

c o n ce ssi o n e rs . Th ese are m a tt e rs of b u il d in g s managem ent as w e ll as of b u il d ­

in gs d esi gn.

Very s in c e re ly ,

F red e ri c k Guthelm
143

Mitchell/Giurgola Associates Architects

1316 Arch Street Philadelphia Pennsylvania 19107

215/561-1 600

Ehrman B Mitchell. Jr. FAIA

Romaldo Glurgola AIA

Fred L Foote AIA

Rotlin R. La France AIA

John □. Lawson AIA

e G. Daniel Perry AIA

Peter W. Parsons

7 A p ril 1975

T he H o n o ra b le J a m e s L . B u ck le y 

U n it ed S ta te s S e n a to r 

30 4 R u s s e ll S e n a te O ff ic e B uil din g 

W ash in g to n , D. C . 205 10

D e a r S e n a to r B u ck le y :

T h an k you fo r w rit in g to m e c o n c e rn in g y o u r p ro p o se d le g is la tio n , th e 

" P u b li c B u il d in g s C o o p e ra ti v e A c t" , S en ate B il l S. 865. T h is s u b je c t is 

of h ig h i n te r e s t to m e .

T he p ro v is io n fo r " c o o p e ra tiv e u s e " , e n c o u ra g in g o u ts id e i n te r e s t s to 

p a r tic ip a te w it h th e G o v e rn m e n t a s d e s c r ib e d in y o u r p r e s e n ta tio n to th e 

S en ate is in d e e d a n in n o v ati v e id e a . Y o u r p ro p o s a l co u ld h av e a ll th e b e n e fic ia l 

e ffe c ts you f o r e s e e and en h an c e th e p o s s ib ilitie s fo r "a d a p ti v e u s e " of ol d 

b u il d in g s w h ic h h av e g ro u n d flo o r s p a c e th a t o rig in a lly s e r v e d th e s e p u r p o s e s .

As a m e m b e r o f th e N a ti o n a l B o a rd o f D ir e c to r s of th e A m e ric a n In s titu te of 

A r c h ite c ts , I a m f a m ilia r w it h th e A IA 's e x te n s iv e p r o g r a m in th e a r e a of 

p r e s e r v a tio n of h is to r ic an d a r c h ite c tu r a lly s ig n ific a n t b u il d in g s a c r o s s th e 

c o u n tr y . T h e ir r e s o u r c e s co u ld be m o s t h e lp fu l to yo u in d e v elo p in g 

s u b s ta n ti v e m a te r i a l p e r tin e n t to y o u r B il l. In th is r e g a r d , I a m ta k in g th e 

lib e r ty of in tr o d u c in g y o u r r e q u e s t fo r th o u g h ts and su g g e sti o n s to th e 

P re s id e n t of th e In s titu te , M r. W il li a m B. M a r s h a ll, FA IA , 1735 N ew Y o rk 

A v en u e, N . W ., W ash in g to n , D. C . 20006; te le p h o n e : 2 0 2 /7 8 5 -7 3 0 0 .

In a d d r e s s in g y o u r s p e c if ic q u e s tio n s , I c o m m e n t a s fo ll o w s:

1. Is th e id e a a so und an d w o rk a b le o n e ? Y e s. T h e re a r e m a n y fi ne 

e x a m p le s of r e s to r a tio n of s ig n ific a n t o r h is to r ic b u il d in g s th a t h av e 

b e e n a d a p te d fo r M u n ic ip a l o r S ta te G o v e rn m e n t u se th a t w ould s u p p o r t 

th is c o n c lu sio n . T he N a ti o n a l P a r k S e rv ic e h a s p io n e e re d in th is fie ld 

fo r th e F e d e r a l G o v e rn m e n t o v e r th e p a s t s e v e r a l d e c a d e s a c h ie v in g 

c o n s id e r a b le s u c c e s s in P h il a d e lp h ia .
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7 A p ril 197 5 *

pag e tw o

2. S u g g este d c h a n g e s to th e B il l. I fi nd it d iffic u lt to s u g g e st c h an g e s 

to y o u r B il l. It is su c c in c t an d a d e q u a te f r o m a la y p e r s o n 's v ie w .

3. S u g g e sti o n s on b u il d in g s o r c itie s w h e re th e s e c o n c e p ts m ig h t be 

m o s t e ffe c ti v e ly tr ie d . T he b r o a d e s t s o u rc e of in fo rm a tio n c o n c e rn in g 

b u il d in g s and c itie s s u it a b le fo r t r i a l of y o u r c o n c e p ts is th e A m e ric a n 

In s ti tu te of A r c h ite c ts . T he AI A h a s a n a ti o n w id e n e tw o rk of a r c h ite c ts 

w h o se p r in c ip a l c o n c e rn is th e p r e s e r v a tio n of h is to r ic an d

a r c h ite c tu r a lly sig n ific a n t b u il d in g s. I a m s u r e th is r e s o u r c e co u ld

be m o s t v a lu a b le in a s s is tin g you to d e te r m in e th o se c itie s and s p e c if ic 

b u il d in g s th a t w ould be m o st s u it a b le fo r y o u r p u rp o s e s .

4. E s tim a te s on sa v in g s , e ith e r in c a p ita l c o s t o r e n e rg y u s e . S avin gs 

in c a p ita l c o s ts o r e n e rg y u se a r e d if fic u lt to g e n e r a li z e p rin c ip a lly 

b e c a u s e e a c h s itu a tio n w il l h av e its p a r tic u la r a s p e c ts w h ic h w il l b e a r 

on th is is s u e . H o w ev e r, I th in k one co u ld s u g g e s t th a t re c y c li n g c o s ts 

w ould te n d to be le s s e x p e n siv e th an b u il d in g an ew . T he ra n g e co u ld 

be f ro m 10% to 25% d ep en d in g on c ir c u m s ta n c e s . It sh o u ld be 

a n ti c ip a te d th a t n o t a ll b u il d in g s w il l y ie ld a sa v in g s as s u g g e ste d . 

C o n c e rn in g c o n s e rv a tio n of e n e rg y fo r o p e ra tin g su ch b u il d in g s, I'm 

e n c o u ra g e d to b e li e v e th is is p o s s ib le in r e c y c le d old b u il d in g s 

b e c a u s e th ey g e n e r a ll y h av e le s s g la s s a r e a and th ic k e r e n c lo sin g w a lls . 

R e h a b il it a ti o n te c h n iq u e s can be e m p lo y e d to im p ro v e th e ir e n e rg y 

e ffic ie n c y su c h a s re p la c in g d e fe c ti v e w in d o w s, in su la ti n g w a ll s and 

ro o f a r e a s , and m an y o th e r li k e m e a s u r e s .

O u r f ir m is c u r r e n tly en g ag ed in r e s to r in g and p r e p a r in g th e W ain w ri g h t 

B u il d in g in St. L o u is , M is s o u ri fo r g e n e ra l o ffic e s fo r th e S ta te of M is s o u ri. 

We a r e a n ti c ip a ti n g a sa v in g s in c a p it a l c o s ts , and we a r e em p lo y in g 

te c h n iq u e s to c o n s e rv e e n e rg y .

I w ould li k e to ta k e th is o p p o rtu n it y to co m m e n d you fo r in it ia ti n g th is 

im p o r ta n t c o n c e p t an d tr a n s f o rm in g i t in to p o sit iv e a c ti o n . You h av e m y 

fu ll s u p p o rt fo r th is m e a s u r e , an d I s h a ll u rg e m y c o ll e a g u e s to jo in w it h 

m e in th is . I w il l b rin g th is to th e a tt e n ti o n of th e A m e ric a n In sti tu e of 

A r c h ite c ts . T h ey c a n o ffe r you m u ch a s s is ta n c e in c a r r y in g out th is 

le g is la tio n .
145

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,316 Arch Slreel Philadelphia Pennsylvania ,9 ,0 7

T he H o n o ra b le J a m e s L . B u c k le y 

7 A p ril 1975 

page th re e

T h an k yo u fo r y o u r in v it a ti o n to c o m m e n t on S e n a te B il l S. 865 

My b e s t w is h e s fo r it s s u c c e s s f u l e n a c tm e n t.

S in c e re ly ,

c ah

c c : W il li a m B. M a rs h a ll, FA IA

P r e s id e n t, A m e ric a n In s titu te of A r c h ite c ts

W il li a m B. S la y to n , H on. AIA 

E x e c u ti v e V ic e P r e s id e n t 

A m e r ic a n In sti tu te of A r c h ite c ts 

1735 N ew Y o rk A v en u e, N . W.

W ash in g to n , D. C . 200 06

54 -188 O - 75 — 11
146

University of Illinois at U rbana-Champaign

COLLEGE O f LAW • 204 LAW BUILDING • CH AM PA IGN, ILLIN OIS 61820 • (217) 333 0931

Marc h 25 , 1975

♦

H onora ble Ja m es L. B uck le y 

U n it e d S ta te s S en ate 

W as hin gto n, D. C. 20 51 0

D ea r S e n a to r B uckle y:

I t i s a p le a s u re to re sp o n d to your r e q u e s t f o r co mmen ts on S e n a te B i l l 

865. D e sp it e th e b i l l ' s o b v io u s a d v a n ta g e s r e g a rd in g su ch m a tte r s a s en erg y 

c o n s e r v a tio n , em plo ym en t, e t c . , I w i l l r e s t r i c t my co mmen ts to th e b i l l ' s 

p o t e n t i a l i t i e s f o r h i s t o r i c p r e s e r v a tio n .

W ith th e a s s i s t a n c e o f th e N a ti o n a l T r u s t f o r H i s t o r i c P r e s e r v a tio n an d 

th e U n it ed S ta te s D epar tm ent o f H ou si ng an d Urb an R en ew al, I com ple te d l a s t 

May a s tu d y , Spac e A d r i f t : La nd mark P r e s e r v a tio n an d th e M a rk e tp la c e , a co py 

o f w hi ch i s e n c lo s e d . A m a jo r co n ce rn o f th e stu d y was to p r o f i l e th e co m pa ra ­

t i v e c h a r a c t e r i s t i c s f o r down tow n o f f i c e an d com m erc ia l u s e o f la ndm ark s an d 

o f t h e i r ty p i c a l m od ern re p la c e m e n ts . C h ap te r I I I o f S pac e A d r if t le a v e s 

l i t t l e d o u b t t h a t in C h ic a g o 's C e n tra l B u sin e ss D i s t r i c t ( th e a re a ex am in ed in 

th e stu d y ) th e u se o f la ndm ark s t r u c t u r e s f o r c o n te m p o ra ry o f f i c e an d com m erc ia l 

n e ed s i s e n t i r e l y f e a s i b l e . From th e p e r s p e c tiv e s o f o n - s i t e am en it y c o n s id e r ­

a t i o n s an d o f c o n tr ib u tio n to th e c i t y 's u rb a n d e s ig n an d e n v ir o n m e n ta l f a b r i c , 

in f a c t , la ndm ark s a r e d e c id e d ly s u p e r io r to t h e i r g la s s an d s t e e l c o m p e ti to rs .

Th e stu d y r e p o r t s , m o re o v e r, t h a t la ndm ark s a r e n o t ec on om ic "w h it e e le p h a n ts " , 

a s o f te n u n c r i t i c a l l y a s s e r te d by th o s e who m is g u id e d ly id e n t i f y " p ro g r e s s " 

w it h ne w er an d b ig g e r b u ild in g s , b u t t h a t th e s t r u c t u r e s e a rn a re a s o n a b le 

r e t u r n on in v e s te d e q u ity . I t i s o b v io u s t h a t fir m g o v e rn m e n ta l co m m itm en ts to 

le a s e o r o th e rw is e a c q u ire sp ac e in th e s e b u ild in g s — a s c a l le d f o r in th e b i l l — 

can o n ly enhan ce t h e i r c o m p e ti ti v e p o s itio n , th e re b y p ro v id in g an in v a lu a b le 

a s s i s t to t h e i r p r e s e r v a tio n s im ila r to th a t a ffo r d e d to S t. L o u is ' W ai nw ri ght 

B u il d in g by M is s o u ri G over nor B ond's d e c is io n to lo c a te s t a t e o f f i c e fu n c tio n s 

in i t .

In s h o r t , by d i r e c t i n g th e f e d e r a l gover nm en t to c o n s id e r h i s t o r i c an d *

o th e r e x is t in g b u ild in g s in a s s e s s in g i t s sp ac e n e e d s , th e b i l l w i l l s u re ly 

c o n tr ib u te to th e m a in te n an c e o f v i t a l , t r u l y e x c i tin g A m er ic an c i t i e s an d 

p r o te c t c h e r is h e d la ndm ark s t h a t wou ld o th e rw is e be l o s t to th e f o r c e s o f an 

in d is c r im in a te m a rk e tp la c e .

I have o n ly on e m ajo r o b s e r v a tio n r e g a rd in g th e b i l l ' s la n g u a g e . I t 

seem s to me t h a t S e c ti o n 2 ( a ) ( 1 ) g iv e s i n s u f f i c i e n t a t t e n t i o n to b u ild in g s 

l i s t e d on th e N a ti o n a l R e g is te r o f H is to r ic P la c e s a n d , p e rh a p s , th o s e fo rm a ll y 

d e s ig n a te d a s la ndm ark s by s t a t e an d l o c a l govern m ents a s w e ll. As p r e s e n tly 

d r a f t e d , th e s e c tio n em po we rs th e A d m in is tr a to r to d e c l in e to u t i l i z e sp ac e 

in th e s e b u ild in g s i f "u se o f su ch sp ac e wou ld n o t p ro v e f e a s i b l e an d p ru d e n t 

co mpa red w it h a v a i l a b l e a l t e r n a t i v e s . " The q u o te d la n g u a g e i s und u ly v a g u e, 

i n v itin g c ir c u m v e n ti o n by th o s e who— l i k e m ost r e a l e s t a t e man ag em en t fi rm s 

an d o r g a n iz a tio n s — as su m e t h a t d if f e r e n c e s in s p a c e la y - o u t , u t i l i t i e s an d 

o th e r " e f f ic ie n c y f a c t o r s " betw ee n o ld e r an d m od ern b u ild in g s p re s u m p ti v e ly
147

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Ma rch 25, 1975 Pag e 2

«

v

e s t a b l i s h t h a t c h o ic e o f th e o ld e r o v e r th e ne wer I s n o t " f e a s i b l e " o r 

" p r u d e n t." In f a c t , many la n d m a rk s, e . g . , Ol d B ost on C it y H a ll o r C h ic a g o 's 

M arq u ett e B u ild in g , a r e q u ite c o m p e ti ti v e w it h m od er n s t r u c t u r e s on a s t r a i g h t 

e f f ic ie n c y b a s i s .

But wha t o f th e c a s e o f a N a ti o n a l R e g is te r p ro p e rty o r d e s ig n a te d la n d ­

mark th a t i s n o t? As d r a f t e d , th e b i l l wou ld p e rm it th e s e to be p a sse d o v e r.

I wou ld u rg e t h a t th e b i l l be tig h te n e d to p ro v id e t h a t f o r su ch b u ild in g s 

th e fo ll o w in g f a c t o r s be ta k e n in to a c c o u n t in a s s e s s in g th e "p ru d e n c e " o r 

" f e a s i b i l i t y " o f u s e :

1 . th e p o s s i b i l i t y th ro u g h re n o v a ti o n o f m ak in g th e s e s t r u c t u r e s re a s o n ­

a b ly c o m p e ti ti v e on an e f f i c i e n c y b a s is even i f th e c o s ts o f r e n o v a ti o n wou ld 

exce ed th o s e t h a t th e p r i v a t e s e c to r wou ld n o rm a ll y u n d e rta k e a c t in g e x c l u s iv e ly 

from p r o f i t c o n s id e r a tio n s ; o r

2 . th e e x te n t to w hic h th e b u i l d i n g 's a r c h i t e c t u r a l o r h i s t o r i c d i s t i n c t i o n 

an d i t s u rb a n d e s ig n c o n tr ib u tio n s to i t s s u rro u n d ip g a re a an d i t s c i t y m e rit 

p r o te c tio n n o tw it h s ta n d in g th e b u i l d i n g 's r a t i n g on a s t r a i g h t " e f f ic ie n c y " b a s i s .

Thes e c h an g es wou ld s t r e s s th a t g o v e rn m e n t' s s te w a rd s h ip o f b u ild in g s th a t 

c o n tr ib u te m ig h tily to th e n a t i o n 's h e r ita g e e n t a i l s r e s p o n s i b i l i t i e s o f a w h o ll y 

d i f f e r e n t o rd e r from th o s e o f p r iv a te e n tr e p re n e u rs - who se s te w a rd s h ip i s gov ern ed 

by p r o f i t c o n s id e r a tio n s . T h is vie w i s re c o g n iz e d an d im ple m en te d in v i r t u a l l y 

ev ery o th e r c o u n tr y th a t I hav e v i s i t e d . W ith o u r B ic e n te n n ia l o n ly on e y e a r 

aw ay , S e n a te B i l l 86 5 p ro m is e s to c o r r e c t an im b a la n ce t h a t h a s g ra v e ly h in d e re d 

p r e s e r v a tio n e f f o r t s in th e U n it ed S t a t e s .

S in c e r e ly y o u rs ,

a

o s to n is 

P r o f e s s o r o f Law

*

J JC :d s

E n c lo su re
148

Johnson / Burgee Architects 375 Park Avenue 

New York, NY 10022 

212/751-7440

March 27, 1975 *

The Honora ble Jame s L. Buckley 

United States Senate 

Washington, D. C. 20510 

My dear Senator Buckley:

I have read your bill called "Public Buildings 

Cooper ative Use Act of 1975." I have no parti cula r comment except enthusiastic endorsement.

It is very pleasing to an archite ct that our 

lawmakers are so aware of trends in architectural and 

urban design thinking.

Congratu lati ons and good luck!

PJ:jg

Yours

4.
149

L A N D M A R K S

A S S O C I A T I O N

O F

C E N T R A L N Y

A p ril 2, 1975

S e n a to r J a m e s B u ck le y

53 23 D irk s e n S e n a te O ff ic e B u il d in g

W ash in g to n , D. C . 205 10

D e a r S e n a to r B u c k le y :

Y our re c e n t in tr o d u c ti o n of le g is la tio n in C o n g re s s to help th e f e d e ra l 

g o v e rn m e n t re c y c le v a lu a b le o ld e r b u il d in g s in s te a d of c o n s ta n tl y 

e re c tin g " c o n c re te m o n o li th s " is a n o th e r w e lc o m e d si gn th a t h is to r ic 

p r e s e r v a tio n sh o u ld be, an d is , b e c o m in g a c c e p te d p r a c tic e a t a ll le v e ls .

T he L a n d m a rk s A s s o c ia ti o n is th e m a in v e h ic le fo r h is to r ic p r e s e r v a tio n 

a c tiv itie s in th e C e n tr a l Ne w Y o rk a r e a . B oth o u r m e m b e rs h ip an d th e 

C e n tr a l NY co m m u n it y w ou ld be e x tr e m e ly in te r e s te d to le a r n m o re 

abo u t wh y you , a s a U. S. S e n a to r, b e li e v e in th e im p o rta n c e of p r e s e r v in g 

th e b e s t of o u r h is to r ic e n v ir o n m e n t. A m a rv e lo u s o p p o rtu n it y p r e s e n ts 

its e lf, an d we w ould be h ig h ly h o n o re d if yo u w ould be w il li n g to do th is 

at o u r A nnual M eeti n g , b e fo re a t le a s t p a r t of th e c o n s ta n tl y g ro w in g 

" p re s e rv a tio n c o n s ti tu e n c y " in Ne w Y ork S ta te . T h is w il l be th e e v en in g 

of M ay 15 in S y ra c u s e .

It is g e n e ra lly re c o g n iz e d th a t Ne w Y o rk S ta te le a d s th e n a ti o n in o rg a n iz e d 

p r e s e r v a tio n a c tiv ity , an d we a r e a ll p le a s e d to s e e on e of o u r s e n a to rs 

ta k in g a le a d e r s h ip ro le .

S in c e re ly y o u rs ,

*

D en n is J . C o n n o rs 

E x e c u ti v e D ir e c to r

en c.

6 7 8 W . O n o n d a g a S t . / S y r a c u s e . N Y 1 3 2 0 4
150

Landmarks Preservation Service

407 South Dearborn Street • Chicago, 11.60605 • 312-922-1742

A p ri l 2 , 1975

The Hon or ab le Jam es L. Buc kley 

U ni te d S ta te s Se na te 

W as hing to n, D.C. 20510

De ar Mr. Buc kl ey :

I was p le ase d to re c e iv e yo ur l e t t e r of March 19 and have 

exam ine d Sen at e B ill 865 in tr o d u ced by yo u, as w e ll as th e te x t of 

your flo o r sta te m e n t.

As one who i s de ep ly in volv ed in th e pr ob lems o f c e n tr a l c it y 

v i t a l i t y and th e econom ic re u se of o ld e r b u il d in g s in co n ju n cti o n 

w it h new de ve lo pm en t, I ap pla ud th e b i l l and th e flo o r st ate m en t 

mo st h e a r t il y .

The id ea is both soun d and w ork ab le , and Ch icag o would o f f e r 

an e x c it in g are n a fo r te s tin g i t . In downtown Ch icag o we have b u il d ­

in g s id e a lly s itu a te d and in clo se pro xim it y to th e F ed era l C ente r.

Furt herm ore , th ey ha ve re co gniz ed n a ti o n a l and in te r n a tio n a l s i g n i f i ­

ca nc e wh ich was o f f i c i a l l y docume nte d by th e U.S . De pa rtm en t of th e 

I n te r io r in i t s March 1973 re p o rt on th e Chicago Sc ho ol of A rc h it ectu r e . (I w ill en clo se a conden sa ti on of th a t re p o rt in two p a r ts .

The f u l l re p o rt is a v a ila b le from th e U.S . Gov ernment P rin tin g O ffic e ,

sto c k No. I2 9 .2 :C 4 3 .) #

I a ls o w ill e n clo se a copy of CHICAGO’S LANDMARK STRUCTURES: AN 

INVENTORY in wh ich I have in d ic a te d th e lo c a ti o n of th e F ed era l Cen te r 

com plex on th e map on page 3. I would p a r tic u la r ly recommend to yo ur

c o n sid e ra ti o n th e b u il d in g s l is te d in th a t docum ent as b u il d in g s C40, 9

C41, C42, C43 and C45 wh ich a re d esc ri b ed on pa ge s 11 th ro ug h 13 .

We have not be en su c c e ss fu l in in te r e s tin g th e Gen er al S erv ic es 

A d m in is tr ati o n in c o n sid eri n g n a ti o n a ll y Im port ant land mark s tr u c tu re s 

in th e C ity of Chicago fo r fe d e ra l o f f ic e sp ac e usa ge. In deed , we 

have en co unte re d s im il a r d i f f i c u l t i e s w it h o th e r agen cie s of go ve rnment whose ma ndate fo r th e use of fu nd s do es n o t in c lu d e th e pu rp os es 

tr e a te d in your B i ll .
The Hon or ab le Jam es L. Buc kley 

A p ril 2, 1975 

Page Two

The pl ac em en t o f F ed era l o f f ic e s and th e u t i l i z a t i o n o f ph y si ­

c a l f a c i l i t i e s ha s an eno rmous im pa ct on th e c h a ra c te r and v i t a l i t y 

of a ffe c te d co nm unlt le s, b u t many a sp e cts of th a t im pa ct i s sim pl y 

ig n o re d .

Your B ill would be most h e lp fu l in r e c tif y in g an ex tr em ely 

se rio u s ur ba n pr ob le m , e s p e c ia lly in c e n tr a l c ity lo c a ti o n s which 

are fig h ti n g to r e ta in t h e i r v i t a l i t y .

I would obse rv e th a t m er el y p e rm it ti n g GSA to embark on such 

p ro je c ts when "d e sir e d " by lo c a l peo ple and GSA may be in s u f f ic ie n t 

sin c e th a t ag ency and th e lo c a l o f f i c i a l s i t w ill d eal w it h have n o t 

ev id en ce d any p re se n t o r ie n ta tio n to th e pr ob lems you a d d re ss.

Now some comments on s p e c if ic p ro v is io n s o f th e B i ll :

Page 2, lin e 12: Your en co ur ag em en t of co mm erci al us e is 

im p ort ant and d e s ir a b le . A m aj or prob lem in th e re u se o f o ld e r 

b u il d in g s fo r p re se rv a ti o n o r o th e r purp ose s i s to make the m s e l f 

s u s ta in in g . The usu al fo cu s on c u ltu r a l and c iv ic a c t i v i t i e s us e 

o fte n pr od uc es e ith e r an e n d le ss d ra in on m unic ip al fin an ce or an 

u n re a li z a b le p r o je c t. Comm erc ial us e is s e l f s u s ta in in g .

Pag e 4 , lin e 23; R equir in g th a t sp ac e be le a se d a t p re v a il in g 

co mm erci al ra te s on th e grou nd flo o r o f new b u il d in g s o fte n would 

p re clu d e us es wh ich c o n tr ib u te mo st to th e a c t i v it y and am en ity of 

th e a re a . In Chi ca go , o ld e r b u il d in g s pro vid e f a c i l i t i e s fo r re s ta u ­

r a n ts , r e t a i l sh oppin g, and se rv ic e fu n cti o n s wh ich c o n tr ib u te to 

a c t i v it y a t s t r e e t le v e l and to s e rv ic in g th o se who shop and u t i l i z e 

o f f ic e sp ac e in th e, Loop. New c o n str u c ti o n o fte n re q u ir e s a re n t 

s tr u c tu r e wh ich fo rc e s su ch e n te r p r is e s o u t. I th e re fo re su g g est yo ur 

c o n sid e ra ti o n o f an ex ce p ti o n to th e p re v a ili n g co mmercial r a te 

re quir em ent whe re a lo w er r a te is n ecess ary o r d e s ira b le to g en era te 

co mmercial or no n- co m m er ci al use s wh ich w ill en ha nc e th e s o c ia l o r 

econ om ic en vi ro nm en t w it h in o r su rr oundin g F ed era l o f f ic e b u ild in g s .

Page 3, lin e 9 : GSA sh ould be re q u ir e d to c o n su lt w it h 

conm un lty le a d e rs o u ts id e go ve rn men t. "Su ch . . . le a d e rs . . . as 

he th in k s a p p ro p ri a te " is si m pl y n o t s u f f i c ie n t. P u b li c o f f i c i a l s 

a re busy . They w ill to uch bas e w it h one o r two key m unic ip al o f f ic e r s 

and o fte n w ill ig n o re "co mm unity le a d e rs " fo r a v a r ie ty o f re aso n s.

The A d m in is tr ato r sh ould be re q u ir e d to c o n su lt w it h a t a t l e a s t th re e 

community le a d e rs en ga ge d in a c t i v it y or in volv ed w it h o rg a n iz a ti o n s 

who se i n te r e s t s may be a ffe c te d in th e ex ecu ti o n o f h is d u tie s un de r 

S ub secti o n (a ) o f th e S e c ti o n . Fo r ex am pl e, wh ere our o rg a n iz a ti o n is 

en gage d in e f f o r ts to p re serv e land mark co mmercial b u il d in g s in downtown C hi ca go , and GSA i s p ro posi ng us es fo r downtown C hic ag o, ou r 

i n te r e s t s would be a ffe c te d and we sh ould be c o n su lt e d .
152

The Hon or ab le Jam es L. Bu ckley 

A p ril 2 , 1975 

Page Thr ee

Page 6 , lin e s 19 th ro ugh 21: The p ro v is io n wh ich does n o t »

lim it h i s t o r ic a l or a r c h ite c tu r a l s ig n if ic a n c e to N a ti o n a l R e g is te r 

B uil din gs is w ise bec au se r e g is tr a tio n is a com plex p ro cess and i t 

sim pl y i s not p o ssib le to get e v ery th in g onto th e N a ti o n a l R e g is te r 

in ti m ely fa sh io n . We have re p e a te d ly en co unte re d s p e c if ic d i f f i c u l ­

t i e s bec ause an o p p o rt u n it y o r pr ob lem aro se wh ich co uld n o t be a n ti- ’

c ip a te d and th e b u il d in g in volv ed had not y et be en nom in at ed .

I and my co ll eag u es wo uld be mo st in te r e s te d to d is c u ss th is 

le g is la tio n and i t s im ple m en ta tion w it h yo u, yo ur s t a f f , and any 

members o f th e Comm itte e on P u b li c Wo rks.

Be ca use th e se n a to rs fro m I l l i n o i s have ta ken a p a r tic u la r 

i n te r e s t in ou r work, I am ta k in g th e lib e r ty of fo rw ard in g to them 

a copy o f th is l e t t e r .

Our sin c e re th an ks fo r your in te r e s t and c o n sid e ra ti o n in 

a d d re ssin g th is pr ob le m .

Very tr u ly y o u rs ,

R ic ha rd A. M il le r 

P re sid e n t and G en er al Cou ns el

RAMssg 

E n d s .

cc (w /e n c ls ):

The Hon or ab le A dla i St ev en so n 

The Hon or ab le C har le s Pe rc y
153

4

W IL L IA M J. W H IT E 

EXECUTIVE DIRECTOR

T H E CO M M O NW EALT H OF M ASSACHUSETTS 

MAS SA CH US ET TS HO USING FINANCE AG EN CY 

O LD CIT Y H A L L • 4 5 S C H O O L STREET 

BOSTO N. M A S SA C H U SE TTS 0 2 1 0 8 • (6 17) 7 2 3 -9 7 7 0

»

April 9, 1975

The Honorable James L. Buckley 

United States Senate 

Washington, D. C. 20510 

Dear Senator Buckley:

Thank you for your letter of Ma rch 19 along with the copy of 

S. 865. I think this is a very exciting bill, and I believe 

very strongly that so many of our beautiful old buildings have 

new life, and in many cases are looking for a user.

Our Agency has been encouraging the rehabilitation and recycling 

of many of our fine old buildings in this state, and our offices 

are in a building that is in the National Register and has been 

restored. It is used as an office building with some commercial 

facilities such as a bank and a restaurant.

I would be delighted to either send a statement when the 

Committee holds its hearings or I would be pleased to testify 

before the Committee. I am enclosing some material which

might be of interest to you

William J. White

WWJ/lb
154

President

DO NA LD H. McOANNON

Telep hone ( 20 21 39 3-43 32

National Urban League, Inc.

Washington Bureau Ron ald H Brown. Director

425 Thirteenth Street. N.W.

Suite 515

Washington, D.C. 20004

Senio r Vice-Pres ident

WENDELL G. FREELAND

Vice-P residents

DA NIEL A. COLLINS

JAMES R. KE NN ED Y

JEA NNE SPURLOCK April 18, 1975

Secretary

CHESTER BURG ER

Assistant S ecretary

GEORGE JENSEN

Tre asurer

FR EDERICK D WILKINS ON

Ass ista nt Treasurer

CECIL R. FORSTER. Jr.

Ex ec utive Direct or

VE RNON E. JORDAN. Jr

Boan l o f Trustees

Lucy Wilton Benton

Michael Burke

Edward E. Carlton

Litlc C. Carter

Michael C. Clement

Jewel L Cooper

The Right Re* John P. Craine. DD

Ronald K Davenport

Coy G. Eklund

Charlct S. Finch. Jr.

Elizabeth L. Fitter

I Owen Funderburg

Alfreda M Oar I bald!

Jamet H Gilliam

Jette Hill. Jr

William A Hilliard

Fletcher Hodget

Alice K. Houston

Joyce A. Hughes

Richard J. Jacob

Nancy Steeger Jcnningt

Charles W, Johnson

Paula M B. Johnson

W W. Johnson

Lane Kirkland

Daniel H Kruger

Clarence G Littlejohn

William Lucy

Edwaid McMahon

Andrea Torret Mahone

Louis Martin

Bishop Samuel S Morris. Jr.

Edward N. Ney

John E Oxendine

Charles J Pllllod. Jr

Cecil F Poole

John W. Porter

Ida A. Powell

John W Riley. Jr.

Jeannette Rockefeller

Terry Sanford

T. Joseph Semrod

Richard R Shinn

Charles H Smith

Otis M. Smith

Robert B 1 aylor

George F. Toy

Thomas A Wood

Angela T Wright

Martha R Wylie

Theodore L. Yarboro

The Honorable James L. Buckley

United States Senate

304 Russell Senate Office Bldg.

Washington, D. C. 20510 

Dear Senator Buckley:

Thank you for your letter of March 19, 1975. Your 

concerns about more efficient use of the nation's 

construction resources and the preservation of 

buildings of historic or architectural significance 

within and surrounding federal office buildings is 

shared by the National Urban League. Clearly, this 

is a neglected problem and the solution will require 

the kinds of efforts your bill seeks.

On behalf of the National Urban League and myself, 

let me commend you for introducing S. 865.

H onora ry Trusters

W IL LI AM H BALDWIN

LLOYD K (.ARRISON

THEOIMJRF W KH FEL

I INDSLEY F KIM BAIL

JAMES A LIN EN

HENRY STEEGER

Co ntrib ut ions to the Nat io nal Urb an Lea gue a re tax d eductible
155

4

Na tio na l Tru st for Historic Preservation

740-748 JACKSON PLAC E, N. W . W ASH IN GTON, D. C. 20006 (202, 382-3304

March 28, 1975

The Honorable James L. Buckley 

United States Senate 

Washington, D.C. 20510 

Dear Senator Buckley:

Thank you for your letter of March 19, 1975, asking for 

our thoughts and suggestions on the "Public Buildings Cooperative Use Act of 1975" which you introduced as S. 865 on 

February 27, 1975.

By letter dated March 25, 1975, we responded to Public 

Works Committee Chairman Randolph's request of March 6, 1975, 

for our comments on the bill. You will note from the copy of 

our response, forwarded herewith for your information, that 

the National Trust fully supports all of the provisions of the 

bill. In our particular area of interest we believe, further, 

that enactment of the measure would favorably impact the 

preservation of buildings significant to American history and 

culture throughout the nation.

It should not only reverse the Federal trend of abandoning its own historic structures, but also bring about use of 

increasing numbers of other historic buildings not presently 

owned by the Federal government.

We have made no survey to determine the number or location 

of such buildings potentially suitable for Federal use, with or 

without renovation and restoration. We believe, however, that 

they exist in almost every major city and in many other centers 

of Federal concentration.

Our views on resulting energy conservation and laborintensity relationship between renovation and new construction 

are set forth in our letter to Senator Randolph. While, again, 

we have no estimate of the capital cost savings as compared to 

new construction, we believe they would be significant.

We are pleased to have had the opportunity to acquaint 

you with our views on the measure.

Sincerely,

Enclosure
156

THE NATIONAL VARSITY CLU B 955 Len fant Plaza North . S W Washington. D C 200 24 Tel 202-488-4501

March 25, 1975

The Honorable James L. Buckley 

United States Senate 

Washington, D. C. 20510 

Dear Senator Buckley:

Thank you for allowing me to react to your Bill "Public 

Buildings Cooperative Use Act of 1975."

I found the proposal to be commensurate with the general 

principles of economics and conservation of energy and materials.

I believe Section 3 of the Bill has the potential to elevate 

depressed areas and in combination with Section 4, provide 

economic stimulation which would serve as an additive to the 

overall effect.

I am particularly impressed by Section 4 of the Bill, which, 

among other things, would permit multi-use or cooperative use 

to ground floor space for "commercial, cultural, educational, or 

recreational" use. Having worked in both Government and commercial 

buildings, I believe this arrangement would have a very positive 

effect on the overall morale and activity of Government employees. 

Isolating bureaucrats in the "rabbit hutch" environment typical 

of many Government buildings is both stifling and depressing.

Your proposal would, in my opinion, help overcome that phenomenon 

and could further induce substantial economic enterprise.

I hope my above remarks will be helpful as you contemplate 

the merits of your Bill.

Richard O. Keelor, Ph. D. 

Executive Vice President
NEW YORK LANDMARKS CONSERVANCY

17 BATTERY PLACE. NEW YORK. N Y. 10004 425-4085

A pri l 28 , 1975

Senato r Jam es L. Bu ck ley

R u sse ll Sen at e O ffi c e R uil din g - Room 304

Wash ing ton 0. C. 2051 0

Dear S enato r Bu ck ley:

The New York Lan dma rks Con se rv an cy , a p r iv a te , n o t- f o r - p r o f it 

o rg a n iz a ti o n eng aged in a r c h ite c tu r a l and h is to r ic p re se rv a ti o n 

th ro ughout th e S ta te o f New Yo rk, is in f u ll su pp o rt o f th e 

s p i r i t and in te n tio n s o f th e P ubli c B uil din gs C oopera ti ve Use 

Act of 197 5. Tha t th e le g is la tio n h e ra ld s th e concepts o f co ­

o p e ra ti v e use s and th e re c y c li n g o f note w or th y F eder al b u il d in g s 

in th e ur ba n en vi ro nm en t as en er gy conse rv in g and ec onom ic al ly 

s ti m u la ti n g d ev ic es is an en co ura gi ng in d ic a ti o n th a t p ro g re s siv e 

m ea su re s a re be in g undert ak en to make c i t i e s and co mmun iti es more 

d iv e rs e and liv a b le th ro ugh th e in c o rp o ra ti o n o f in n o v ati v e id eas 

and p r a c tic a l m et ho ds .

For th e p a s t two y e a rs , th e New York Landmarks Con se rv an cy ha s 

be en in vol ved in devel opin g and im pl em en tin g a d a p ti v e re -u s e 

p ro p o sa ls fo r a r c h ite c tu r a lly and h i s t o r i c a l l y s ig n if ic a n t 

s tr u c tu r e s in New York C it y , in clu d in g two p ro p e rtie s th a t a re 

under th e ju r is d ic tio n o f th e U ni te d S ta te s G en er al S erv ic es 

A d m in is tr ati o n (GSA ): th e U ni te d S ta te s Custom House a t Bow ling 

Gr ee n and th e Fed er al o f fic e b u il d in g a t 641 W ashing ton S tre e t in 

Green wich V il la g e . The Custom House p ro je c t e x e m p li fi e s a co ­

o p e ra tiv e , and th us f a r s u c c e s s fu l, e f f o r t on th e p a rt o f p u b li c 

and p riv a te in te r e s ts to p re se rv e t h i s d is ti n g u is h e d s tr u c tu r e 

th ro ugh re c y c li n g . The F edera l o f f ic e b u il d in g a t 641 Washing ton 

S tre e t was br oug ht to th e a tte n tio n o f th e Con se rv an cy by 

A d m in is tr ato r Sam pso n’ s o f f ic e , who re o u est ed th a t we co nd uc t a 

f e a s i b i l i t y st udy fo r th e re -u s e o f t h is im po sin g te n - s to r y b u il d in g , 

now v a c a n t, ex ce pt fo r a p o st o f f ic e oc cu py in g only a sm al l p o rti o n 

o f th e to ta l sp ace. Und er th e a e g is of th e Con se rv an cy , th e C ente r 

fo r Res ea rc h and E nv iron m en ta l A ffa ir s a t Colum bia U n iv e rsit y is 

p re p a ri n g th is a n a ly s is .
L e tt e r to S en at or .lames L. Bu ck ley 

A p ri l 28 , 1975 

P a Re 2

Our experi ences w ith th e se Fed er al p ro p e rti e s and in o th e r p ro je c ts 

in th e C it y prom pte d us to i n i t i a t e a su rv ey o f publicl y-o w ned 

b u il d in g s , fo r i t was c le a r th a t sc an t in fo rm ati o n e x is te d re gard in g 

r e a l e s ta te owned by F e d e ra l, S ta te and C it y go ve rn men ts in New York 

C it y . In dev el opin g th e sc op e and des ig n o f th is st u d y , and du ri ng 

th e f i r s t sta g e s o f d ata c o lle c tio n , we le arn ed a g re a t d eal ab ou t 

th e use and managem ent o f pub licl y- ow ne d p ro p e rtie s wh ich form s th e 

b a s is fo r th e fo llow in g comm ents co nce rn in g th e P u b li c B uil din gs 

C oopera ti ve Use Act o f 1975:

1) The i n s titu tio n o f a co o p e ra ti v e us e p o li c y fo r Federa l p ro p e rtie s 

is a w ort hw hi le v e n tu re , ho wev er, f u rth e r in c e n ti v e s fo r p u b li c 

gr ou ps to u t i l i z e F ed er al b u il d in g s and th e ir su rr oundin g a re as 

may be e s s e n tia l fo r th e su ccess of th e pr og ram . While a c e r ta in 

amount o f f l e x i b i l i t y is co nta in ed in th e le g is la tio n w ith re gard 

to m ai nt en an ce and a fte r-h o u rs a c t i v i t i e s , th e re a rc lim ita tio n s 

o f grou nd flo o r oc cu pa nc y and com p eti ti v e re n t le v e ls . The s p a tia l 

ne ed s o f c u ltu r a l and c iv ic o rg a n iz a ti o n s and th e amo unt o f re n t 

th a t many n o t- f o r - p r o f it gr ou ps can affo rd to pay may re q u ir e th e 

in c lu sio n o f a re n t ab at em en t c la u s e , or some s lid in g sc a le s tru c tu re 

to en co ur ag e th e se e n t i t i e s to us e Fed er al ly -o w ne d sp ace .

2) A c l a r i f i c a t i o n is needed in re gar d to pay ment o f c o lle c te d re n ta l 

sums in li e u o f ta x e s to lo c a l i t i e s fo r th e pur po se s o f m un ic ip al 

f is c a l p la n n in g . I t is no t c le a r what ha pp en s to paym ents i f th ese 

sums ex ce ed o r f a l l bel ow ta x v a lu a ti o n s . I t wou ld be f r u i t f u l i f any 

a d d it io n a l fu nd s th a t a re c o ll e c te d co ul d be re se rv e d fo r e ith e r 

p re se rv a ti o n o r c u ltu r a l a c t i v i t i e s .

3) The N ati onal T ru st fo r H is to ric P re se rv a ti o n is d esig n ate d by th e 

Act to recommend a r c h ite c tu r a lly and h i s t o r i c a l l y s ig n if ic a n t 

b u il d in g s th a t may f u l f i l l s p a tia l ne ed s o f th e Fed er al gov ern me nt 

as de te rm in ed by GSA. A q u esti o n a ris e s as to w he th er o r no t th e 

N at io nal T ru st is th e a p p ro p ria te ag en ev to pe rfor m th is fu n c ti o n . 

Wh ile i t is th e le ad ag en cy fo r h is to r ic p re s e rv a ti o n a t th e n a ti o n a l 

le v e l, i t s f a m ilia r ity w ith p ro p e rti e s in lo c a l a re a s mav be in ­

s u f f ic ie n t to make reco mmen da tio ns co nce rn in g th e p o s s i b i l i ty of 

co o p era ti v e use s in giv en lo c a ti o n s . Tt may be u se fu l to s tru c tu re 

s p e c ific pro ce dure s fo r fu rth e r c o o rd in a ti o n among l o c a l . s ta te and 

fe d e ra l ag encie s in to th e le g is la tio n to f a c i l i t a t e in fo rm at io n 

ex ch an ges .

4) I t is s ig n if ic a n t th a t th e le g is la tio n a tt e m p ts to p re se rv e b u il d in g s 

th ro ug h re c y c li n g , ho wev er, th e re a re no p ro v is io n s in th e Act to 

en su re th a t th e p ro p e rtie s th a t GSA w il l a c q u ir e w il l be tre a te d in 

an a r c h ite c tu r a lly s e n s itiv e ma nn er.

5) The p o lic ie s re g ard in g p u b li c ly -u se d sp ac e and su rp lu s p ro p e rti e s 

var y in ea ch u n it o f go ve rnmen t and among ea ch ag en cy th a t ha s 

ju r is d ic tio n over p r o p e rtie s . I t would be h ig h ly v a lu a b le i f th is 

le g is la tio n co uld be s tr u c tu re d to se rv e as a model o r a d ir e c tiv e
159

Letter to Senator James L. Buckley

April 28. 1975

Page 3

4

to st ate and lo ca l governments to pursue a sim ila r approach

to the management o f th ei r re al est a te .

I hope tha t some of th es e sugg estio ns can be incorp ora ted in to

any furth er re vis io ns of the Act, and I look forward to its

prompt pas sage.

7

cc: Mr. Hal Braymenx

Mr. Arthur S. Sampson
160

A N D E R S O N N O T T E R A S S O C IA T E S I N C .

ARCHITECTS AND LAND PLANNERS.1 0 THACHER STREET. BOSTON. MASSACHUSETTS 021 13 .(61 7) 22 7-9 272

A p ril 11, 1975

ft

The H onora ble Ja m es L. B uck le y 

U n it ed S ta te s S e n a te 

W ashin gto n, D.C. 20 51 0

t

Dea r S e n a to r B uckle y:

I v e ry much a p p r e c ia te d y o u r l e t t e r o f M arch 19 to me in w hic h yo u re q u e s te d 

my re v ie w o f y o u r p ro p o se d " P u b li c B u il d in g s C o o p e ra ti v e Use A ct o f 1975".

I hav e re v ie w ed y o u r p ro p o se d b i l l in d e t a i l an d have a ls o had o u r d e v e lo p ­

men t c o u n se l re v ie w i t .

We f e e l th a t t h i s p ro p o se d a c t i s im a g in a ti v e an d sh o u ld a c h ie v e lo n g -n e e d e d 

c o n s id e r a tio n by th e Gov ernm en t in u t i l i z i n g e x i s t i n g re s o u rc e s w h il e a c h ie v in g 

th e p ro p e r p r o te c tio n o f A m e ri c a 's h e r i t a g e . I f e e l i t i s a ls o s i g n i f i c a n t 

th a t yo u a re in tr o d u c in g t h i s b i l l as we b e g in to c e l e b r a te A m e ri c a 's B iC e n te n n ia l. My co m m en ts, w hic h a re m in o r, a re as f o ll o w s :

1. On page 2, l i n e s 3 an d 8 , an d pag e 4, l i n e 11 , I w ou ld s u g g e s t t h a t th e 

a b i l i t y to le a s e sp a c e be in c lu d e d as in ma ny in s ta n c e s th e use o f sp ac e 

by th e govern m ent may be more e f f i c i e n t on a le a s e b a s is r a t h e r th a n an 

a c t u a l a c q u i s i t i o n o f p r o p e r ty .

2 . On pag e 4, th e Act c a l l s f o r th e N a ti o n a l T r u s t f o r H i s t o r i c P r e s e r v a tio n 

to i d e n t i f y e x i s t i n g b u ild in g s . You may w is h to c o n s id e r th e N a ti o n a l 

A d v is o ry C o u n cil o f H i s t o r i c P r e s e r v a tio n w hic h i s a g o v e rn m e n ta l agen cy 

to co n d u ct t h i s f u n c tio n r a t h e r th a n th e N a ti o n a l T r u s t. The N a ti o n a l 

A dvis ory C o u n cil h as s p e c i f i c p u rp o se s w hic h a re co m pli m enta ry to t h i s 

p ro p o se d a c t an d th e y a ls o m a in ta in c o n tin u a l l i a i s o n w it h th e p r e s e r v a ­

tio n o f f i c e r s o f each in d iv id u a l s t a t e .

3. I w ou ld s u g g e s t t h a t th e te rm " h i s t o r i c a l o r a r c h i t e c t u r a l s i g n if ic a n c e " 

on pa ge 6 , l i n e 20 in c lu d e n o t o n ly b u ild in g s b u t a ls o p r o p e r ti e s an d 

t h a t a t th e en d o f l i n e 21, th e fo ll o w in g a d d i t i o n a l la n g u ag e be con ­

s id e r e d : " o r th o s e b u ild in g s an d p r o p e r t i e s de em ed to be o f N a ti o n a l 

R e g is te r q u a l i t y as d e te rm in e d by th e s t a t e h i s t o r i c p r e s e r v a tio n o f f i c e r 

fo r th e s t a t e in w hic h th e b u ild in g o r p r o p e r ty i s lo c a te d .

You a ls o re q u e s te d a b u ild in g w her e th e a c t c o u ld b e e f f e c t i v e l y t r i e d . The 

New London C o n n e c ti c u t R a ilr o a d S ta tio n i s a N a tio n a l R e g is te r p ro p e rty t h a t 

was d e sig n e d in 1885 by H.H . R ic h a rd so n , A m e ri c a 's o u ts ta n d in g a r c h i t e c t .

J, TIMOTH Y ANDERSON

GEORGE M NOTTER. JR •

JAMES G ALEXANDER

ANTH ONY C. PLA TT

p a u i j M c G i n l e y •
161

A N D E R S O N N O T T E R A S S O C IA T E S I N C .

A tte n tio n : The H o n o ra b le Ja m es L. B uck le y 

A p ril 11 , 197 5 

Pa ge 2

We a re p r e s e n tly in v o lv e d as a r c h ite c t- d e v e lo p e r in s a v in g t h i s l a n d m a r k 

from d e m o li ti o n an d hav e p la n s re a d y f o r r e s t o r a t i o n . Ou r pro gra m c a l l s 

f o r a p p ro x im a te ly 7 ,5 0 0 s q u a re f e e t o f o f f i c e sp a c e in a d d itio n to an 

AMTRAK p a ss e n g e r f a c i l i t y . The occu pancy by th e F e d e ra l Gov er nm en t f o r 

o f f i c e use in c o n ju n c ti o n w it h n e a rb y govern m ent f a c i l i t i e s w ou ld be an 

i d e a l d e m o n str a ti o n o f y o u r p ro p o se d a c t . I w ou ld be ha ppy to p u rs u e 

t h i s m a tte r in mo re d e t a i l a t y o u r c o n v e n ie n c e .

I d e ep ly a p p r e c ia te y o u r c o n s id e r a tio n in g iv in g me an o p p o rtu n ity to 

com ment on t h i s in n o v a tiv e a c t .

Ve ry t r u l y y o u rs ,

ANDERSON NOTTER ASSOCIATES INC.

N/b

E n c lo s u re s

)

54 -188 O - 75 — 12
162

I. M. Pe l FAIA

Eaeon H. Leonard FA IA

H an rj N. Cobb FAIA

I. M. PEI & PARTNERS Architects

Au ociate P artner a

Leona rd Jacobson AIA

Ja mes 1. P reed AIA

* Werner Wandelma ler AIA •

May 15, 1975 <

The Honorable Jam es L. Buckley 

United States Senate 

Washington, D. C. 20510

Dear Senator Buckley:

Please forgive my delay in responding to your lette r of March 19, 1975 re ­

garding the "Public Buildings Cooperative Use Act of 1975". In my absence 

from the office, members of my staff prepa red comments which I am pleased 

to offe r you in the memorandum attached.

Since our firm has been involved in the planning and design of urban renewal 

pro jec ts for many yea rs and m ore recently activ e in seve ral significant landma rk conservation progra ms , we support this p rop osal being introduced by 

you and the Senate Committee on Public Works.

Sincerely,

I. M. PEI & PARTNERS 4)

Ieoh Ming Pei

aik

att.
« ,M . P2J i« P A R T N E R S . A rc h it e c t* . <00 M ad is on * « M M , Now Y o rk , N o w Yo rk 10022 IN TS R-O 7? iC 3 COM MU NIC ATION

To Eason H. Leonard

From Harold Fredenburgh

d*u April 30, 1975

no: Public Buildings Cooperative Use Act

co py to

The Public Buildings Cooperative Use Act of 1975 (S.865) laudably 

seek s to foster the conservation and use of historic and archite cturally 

significant buildings and to stimulate the social and economic life of 

the city within and surrounding Federal buildings.

While renewal, rehabilitation and restora tion have been a part of 

Fed era l policy for years , the concept of recycling worthy buildings 

not only as a means of preserv atio n but also as a way of making 

our cities more liveable rep resents an imaginative and timely 

dep artu re from previous government attitudes concerning urban 

redevelopment.

In ord er to best achieve the goals of this Legislation, I would offer 

the following comments and suggestions:

1. The National T rus t for Historic Preservation is designated by 

the Act to recommend architec turally and historically s ign ificant,

buildings which may meet the space needs of Fed eral agencies. 

While the Trust is the leading agency fo r historic preservation 

at the National level, its familiarity with local pro perties may 

be insufficient to make recommendations concerning appropriate 

structure s and cooperative uses. For instance, in New York 

City, the New York City Landmarks Com m issi on , the New York 

Landmarks Conservancy, and the Municipal Arts Society are all 

actively involved with the conservation and use of notable 

buildings within the City. Reference in the Act to procedures 

for coordindation among Local, State and Federal agencies 

would be desirable .

2. Further incentives for public groups to use Federal buildings 

and the ir surrounding areas may be necessary for the succ ess 

of the progra m. While a certain amount of flexibility is contained in the Act with reg ard to maintenance and aft er-hours 

activitie s, there are the limitations of ground floor occupancy 

and competitive rent levels. The space needs of cultural and 

civic organizations and the amount of rent that many non-p rofit 

groups can afford to pay may requ ire the inclusion of a rent 

abatement clause, or some sliding scale to encourage such use s.
164

3. The re is no provision in the Act to ensure that the prop erties 

acquired by the GSA will be developed in an architecturally 

sensitive and compatible manner.

4. There is no provision for the finances necessary to administer 

the Bill, and/or to implement appropriate studies to determine

the feasibility of recycling specific properties. 4

5. A clarification is needed with regard to payment of collected 

rental sums in lieu of taxes to localities for the purpose of 

municipal fisca l planning (Section 4(a)(1)). What happens to 

payments if these sums exceed or fall below tax evaluations?

Can additional funds be rese rved for either preservation or 

cultural activities?

6. The policies regarding publicly-used space and surplus prop erties 

vary with each unit of government. Can this Legislation serve 

as a model or directive to State and Local governments to pursue 

a sim ilar approach to the management of their properties?

4

<
Progressive Archit

Reaches more individ uals who pra ctice architecture than any magazine in the world

ecture

600 Summe r S v w t Stamford Connecticut 06904 203 346 7531

A p ri l 1, 1975

The Hon or ab le Jam es L. Bu ckley 

U nited S ta te s Sen at e 

W as hing ton, D.C . 20510 

De ar S enato r Bu ckley s

I f u ll y en do rs e th e in te n t o f your p u b li c b u il d in g s b i l l , 

an d I have no reco mmen da tio ns fo r ch an ge s in i t . As f a r as I 

can t e l l , i t me ets a l l o f th e ne ed s f o r le g is la ti o n in th is 

a re a q u it e w e ll .

As you in d ic a te d in yo ur f lo o r s ta te m e n t, th is b i l l wo uld pu t 

in to e f f e c t th e reco mmen da tio ns o f th e F ed era l A rc h it e c tu re 

Tas k Fo rc e of th e N ati o n al Endowment. I am co nv in ce d th a t su ch 

le g is la ti o n wo uld be h ig h ly c o n s tr u c tiv e ; i t is only re g re tta b le 

th a t we have not had th e b e n e f it o f su ch a p o li c y so o n er.

As fo r o p p o rtu n it ie s to ap p ly th e se co n cep ts , I ca nn ot giv e a 

co mpr eh en sive l i s t . Th ere a r e , ho we ver, many co mmercial b u il d in g s 

o f r e a l a r c h ite c tu r a l d is tin c tio n and g re a t p o te n tia l u se fu ln e ss 

wh ich co ul d be co nse rv ed unde r su ch a pr og ra m . The G ua ra nt y B uil din g 

by Lo ui s S u ll iv an in B u ff a lo , one o f th e key land marks o f Am erican 

a r c h ite c tu r e , is in da ng er an d is lo c a te d c lo se to th e go ve rnme nt 

c e n te r o f th e c ity . In Ch ica go many o f th e f in e s t o f f ic e b u il d in g s 

of th e 1890's and th e e a r ly de ca des o f th is cen tu ry l i e w it h in a blo ck 

or two o f th e new F edera l C en te r an d could conv en ie n tl y be us ed fo r 

th e e x te n si o n o f F ed era l fu n c ti o n s . The comm ercial d i s t r i c t of 

New O rl eans, wh ich ha s become th e re c e n t su b je c t o f a c o n se rv a ti o n 

e f f o r t , is a ls o w ell lo c a te d f o r su ch u se , i f th e b u il d in g s a re o f an 

a c c e p ta b le sta n d a rd . I do not have an e sti m ate o f p o te n tia l sa vin gs 

a t ha nd . One cas e wh ich m ig ht y ie ld p e rti n e n t eco nomic d a ta wo uld be 

th a t o f th e conver si on of th e Wain wr igh t B uildin g in S t. L ouis , 

a n o th er S u ll iv an la nd m ar k, f o r us e by th e s ta t e of M is so u ri . Fo r 

in fo rm ati o n on th a t I wo uld r e f e r you to th e a r c h ite c ts ,

H ast in gs & C hiv etta (7733 F o rs y th , C la yto n, Mo. 63 10 5) .
Progressive Archite Reaches more individ uals who practice architecture than any magazine in the world

cture

600 Summer Street. Stamford. Co nnecticut 06904 203 348-7531

The Ho no rable Jam es L. Bu ckl ey 

Page two 

A p ri l 1, 1975

Thank you fo r c o n ta c ti n g me re gard in g t h is b i l l . I f I d is cover 

f u r th e r in fo rm ati on o f p o ssib le valu e to yo u, I w ill pass i t 

alo ng pro m pt ly .

S in c e re ly ,

E d it o r
167

WES UHLMAN MAYOR

OFF ICE OF THE MAYOR • CITY OF SEATTLE

April 14, 1975

The Honorable James L. Buckley 

United States Senate 

Washington, D.C. 20510 

Dear Senator Buckley:

I have reviewed with gre at in te re st your proposed "Pub lic Bu ilding s 

Cooperative Use Act of 1975". Our e ff o rt s here in Se attle have been 

devoted to fo st ering the preservation of bu ild ings of h is to ri c or 

arc hitectu ra l sign ifica nc e fo r some time and I feel th at Se attle is 

one of the nat io n's leading c it ie s in th is regard. I can po int with 

pride to our own e ff o rt s in Pioneer Square fo r recogniz ing and encouraging ren ovation e ff o rt s as well as occupying space in renovated 

stru ct ur es . I certain ly welcome and encourage fu rt her renovation of 

existin g bu ild ings in to new fed eral o ff ic e s , esp ec ially in Sea ttle.

Se attle is encouraging a more pe de stria n-oriented and ac tiv e environ ­

ment in it s downtown. As pa rt of th is d irection, we have been 

advocating a more intense use of pub lic space in and around pu blic and 

priv at e developments. We recognize the value of a more multi-us e 

concept of a c ti v it ie s w ithin the downtown as we ll as encouraging 

ad ditio na l pu blic use of pu blic fa c ili tie s a ft e r normal working hours.

Your proposed le g is la tion would support loca l e ff o rt s by adding another 

dimension of public -p rivate use of space in fed era l o ff ic e bu ild ings .

I cert ain ly appre ciate and support your e ff o rt s toward the d e s ir a b ilit y 

1 of commercial space in pu blic buildings as well as re h a b ilita tio n of

worthy and fe as ib le structures fo r expanding federal government needs. 

My thanks fo r your in te re st and support.

Wes Uhlman 

Mayor

WU:aws
168

Your

Seattle

Department of Comm unity Development

OFFICE OF URBAN CONSERV ATIO N - Suite 919 - Arctic Building 

James Braman, Director Seattle, WA 98104 Wes Uhlman, Mayor

Marc h 26, 1975 OUC 120/75

r

Senator James L. Buckl ey 

United States Senate 

Washington, D. C. 20510

RE: S. 865 - Public Buildings Coop erati ve Use Act of 1975 

Dear Senator Buckley:

It is indeed an hon or for me to comment on your prop ose d legislation 

"Public Buildings Cooperat ive Use Act of 1975."

We in Seattle, and I am sure the situation is similar across the country, 

have be en looking forward to the intro duct ion of such legislation at the 

federal level. Our expe rienc es in Seattle have indicated, as quoted in 

your statement on the introduced bill and j oint resolution, that the 

ter m "public bu ildings" has indeed beco me a contradiction.

We have taken steps to alleviate this prob lem at the local level by 

establish ing such po licies as neces sary to allow the Cit y of Seattle to 

lease overf low office space in significant build ings in need of restorat ion 

for competitive rates. The immediate b enef its of this type of policy 

are apparent. The City's credibil ity p rovi des a lease commitment that 

lending institutions will honor. The owner of the b uilding can then solicit 

finan cing to affect the rest orati on of this sign ifica nt building.

Cit y leases ne ed not b e longer than 3 to 5 years and after that term is 

up, the C ity can move on to another site and p erf orm the same service 

for another pro perty owner, whil e giving the first pro per ty owner the 

ability to rent space at a hig her rate to priv ate tenants.

r

Some of the indirect benefits that we have witn essed are: the increased 

property value after restoration, which provide s an increase in tax revenue 

to the city and state; private buildings h ousi ng pub lic facilities are 

brought up to full code comp liance thus eliminat ing pub lic hazards; and all
169

Senator James L. Buckley 

Marc h 26, 1975 

Page Two

arch itect ural barriers are removed to provi de complet e access for the 

handicapped, which n orm ally would not occu r t hrough compl ete private 

« tenancy. Also by injecting a fully occupied buildin g into a neighbo rhoo d

that would otherwise be unstable, provides a deg ree of stability, security, 

and incent ive for buildings and operations to be m aintained and grow 

within the immediate ne ighb orhood. There are othe r benefits that we 

- have seen through our own expe rien ce that I could elaborate on, but I

9 believe you see the feas ibility and common sense be hind this approach

which is embodied in you r proposed legislation.

I wou ld like to make the following construc tive comments regar ding S. 865.

(1) That you expand the descriptio n from building s of histori c or arch itectural 

significance to histori cal sites as s pecifie d in the National Register

of Historic Places. Man y times swapping property that is open space 

for bu ildings or visa -versa can be a useful tool to avoid ing demo lition 

of significant structures. Flexibi lity is the key.

(2) That the federal govern ment, wher e applicable, join wi th other government 

agencies - city, county, state - to j oint ly occupy individual sites

when in fact each agency does not have the capacity to occupy a 

complete building.

(3) That the location of such facilities take into conside rati on local 

develo pment probl ems and h ow the specific location of a federal facility 

could aid in the reso luti on of those problems.

(4) That, wherever pos sible, the federal gove rnment lease with the option to 

purchase, rathe r than to purcha se directly; thus, keeping its options 

open to affect a gr eate r numb er of resto rati ons and adaptive uses.

(5) That pri ori ty should b e given to t hose signific ant sites in need of 

restorat ion and secondly to those that h ave been resto red but are in 

need of tenants. Lease commit ments should be v iewed as an incentive

J to restoration.

(6) The legisla tion should specify not just the National Trust for His tori c 

Preservation, but those ag encie s (federal, state and local) that are

I involved in pre serv ation activities within specific localities.
170

Senator James L. Buckle y 

March 26, 1975 

Page Three

In summing up, I believe that the passage of this bill would do more 

towards federal partici pati on in local preservat ion efforts than any 

single effort yet unde rtaken of this type.

I, not only endorse this legislation, but would stand ready to provide 

any back-up assistance or supp orti ng data that you might need to justify 

the rati onal e and common sense of thi s bill.

C

Since rely

Art hur M. Skolnik 

City Conser vato r

AMS:ww
171

STATE 

UNIVERSITY

CONSTRUCTION FUND

1

A p ril 2 2, 1975

The Hon or ab le Jam es L. Buc kley 

Un ite d. S ta te s Sen at e 

W ashing ton 2 5, D.C .

De ar S en ato r Buc kley :

C h an cell o r Bo yer ha s g iv en me th e o p p o rt u n it y o f re sp ondin g 

to your re c e n t l e t t e r re g ard in g th e "P u b li c B u il d in g s C oopera ti ve 

Use Ac t o f 1975."

I ha ve re vie w ed th e m a te ria l yo u s e n t, and ha ve c o n sid ere d i t 

in l ig h t o f our a c t i v i t i e s in c o n s tr u c ti n g f a c i l i t i e s fo r S ta te U niv er ­

s i t y o f New York. In re sp onse to th e q u e sti o n s r a is e d , I d o, in d eed , 

b e li e v e th a t th e id ea is a soun d an d w or ka bl e on e.

R eg ar di ng ch an ge s in th e B i l l , i t is d i f f i c u l t a t th e S ta te 

le v e l to a sse ss th e im pa ct o f th e s e p ro p o sa ls on th e f e d e ra l b u il d in g 

pr og ram . I wo uld lik e to su g g e st, ho w ev er , t h a t th e r e la tio n s h ip o f 

t h i s p ro p o sa l to th e fe d e ra l f a c i l i t y d e li v e ry p ro c ess be c a r e f u lly 

c o n sid ere d , in o rd e r th a t th e p ro cess i s n o t d is to r te d and d e li v e ry 

o f f a c i l i t i e s u n n e c e ssa ril y d ela y ed .

Becau se o f th e ra p id gr ow th o f S ta te U n iv e rs it y , th e v a st 

m a jo rit y o f th e b u il d in g s in our u n iv e r s ity sy st em are r e la ti v e ly new .

As to your re q u e st fo r su g g e sti o n s re g a rd in g b u ild in g s , o r c i t i e s , wh ere 

th e se conce pts m ig ht be mo st e f f e c tiv e ly t r i e d , th e re a r e , in many New 

j York S ta te co m m un itie s, o r ig in a l so un d s tr u c tu r e s th a t could be r e h a b i li ­

t a te d . The U n iv e rsit y wo uld ha ve no d i f f i c u l t y su p p o rt in g su ch a c t i v i t i e s 

in co mmun ities wh ere we ha ve ca mpu se s.

S ta te U n iv e rsit y has made a s in g u la r ly s ig n if ic a n t d e c is io n w it h 

T re g ard to r e h a b ilita tio n o f e x is tin g b u il d in g s in Albany in th e in sta n c e

o f th e new h e ad q u a rt e rs o f S ta te U n iv e rsit y . Th ese b u il d in g s in th e 

c a p ita l c i t y , w i l l , when com ple te d, be an ex am ple o f th e r e s u l ts t h a t 

your l e g i s l a ti o n m ight be ex p ecte d to a ch ie v e .

The U n iv e rsit y i s c u r re n tly in p ro c ess o f r e h a b i li t a t i n g th re e 

m aj or downtown s tr u c tu r e s : th e fo rm er main o f f ic e b u il d in g o f th e De lawa re
172

The Hon or ab le Jam es L. Bu ck ley 

A p ri l 22, 1975 

Pag e Two

and Hudson R a il ro a d , b u i l t in 19 17 ; th e T im es- Jo urn al B uil din g (1 918); 

and th e o r ig in a l F e d e ra l P o st O ff ic e B u il d in g (l 8 8 U ). The De law are

and Hudson B u il d in g is a copy o f th e famous C lo th G uild H all in Y pre s, k

Belgium , and i s neo -G oth ic in s ty le . Be cause o f i t s ke y lo c a ti o n in 

th e C it y o f A lb an y, th e r e h a b ilita tio n o f t h i s b u il d in g w ill h elp to 

up gr ad e th e su rr o u n d in g a re a .

C h an cell o r Bo yer has s a id , "We as a s o c ie ty have come to th e 

r e a liz a tio n t h a t th e w orl d o f th e fu tu re is n o t one o f tw en ty -a cre p lo ts 

fo r ea ch fa m il y . I b e li e v e th a t th e c ity i s th e p la c e o f th e fu tu r e , 

t i e d to th e n a tu re o f an ev er more complex w o rld ." In t h is co n te x t he 

fu r th e r p o in te d out t h a t " I t is e s p e c ia lly a p p ro p ria te fo r a e s th e tic as 

w e ll as p r a c tic a l re aso n s t h a t th ese b u il d in g s on ce again p la y a s i g n i f i ­

cant and im port ant ro le in A lb any's se co nd m aj or move to r e v it a l i z e t h i s 

h i s t o r ic re g io n ."

The U n iv e rsit y was aw are th a t i t wo uld ha ve be en e a s ie r to fin d 

a s i t e o u ts id e o f th e c ity on wh ich to b u ild a new s tr u c tu r e . A fte r co ns id e ra b le stu d y , C hancell or Boyer was ab le to sa y , "No p r iv a te e n te rp ris e 

co uld a ffo rd to re n o v ate and r e h a b ilita te th e D & H, b u t i t w ill c o st th e 

U n iv e rsit y no more to r e s to r e i t th an to b u ild a new f a c i l i t y . What we 

are g e tt in g is a tr a d e - o f f in h e r ita g e ."

Thi s e f f o r t ha s ha d th e co mmun ity 's su p p o rt, and in an e d it o r i a l 

on November 13 , 19 72 , th e Albany K ni ck er bo ck er News co nc lu de d w it h t h is 

p h ra se: "S o, a s a lu te to U n iv e rsit y C h an cell o r E rn est L. Bo yer and a l l 

o th e rs who ha d t h i s v is io n f o r a U n iv e rsit y h e a d q u a rte rs. Downtown A lb any's 

day i s da w ni ng ."

Alth ou gh th e c o st o f r e h a b ilita tin g t h i s b u il d in g w ill be ap pr ox ­

im ate ly th e same as i f a new b u il d in g we re to be c o n str u c te d , th e re a r e , 

we b e li e v e , in a d d it io n to th e p re se rv a ti o n o f ou r h e r ita g e , p r a c tic a l 

re aso n s fo r do in g so . The e n tir e e x te r io r and a l l m aj or i n te r i o r a sp e cts 

o f th e b u il d in g s are to be sa ved. Thi s re p re s e n ts a sa vin g in c o st and in 

en er gy o f m in in g, m an u fa ctu ri n g , tr a n s p o r ti n g , and e r e c tin g th o se p o rti o n s k

o f th e b u il d in g s which are b ein g sa ved . T h is , we b e lie v e , is a s ig n if ic a n t 

sa v in g o f n a tu r a l re s o u rc e s , p a r tic u la r ly e n erg y , wh ich a t th e same tim e 

do es not m ea su re ab ly re duce th e p o te n tia l fo r employment in co n ju n cti o n 

w it h th e r e h a b i li t a t i n g . -

In r e h a b i li t a t i n g e x is tin g b u ild in g s , th e re is th e p o te n tia l to b u ild 

in en er gy sa v in g s. The Am eri can I n s t i tu t e o f A rc h ite c tu re , in i t s pa m ph le t 

e n ti t le d "A N at io n o f En erg y E f f ic ie n t B u il d in g s By 1990," p o in te d o u t:
The Hon or ab le Jam es L. Buc kley 

A p ril 22, 1975 

Page Th ree

" I f we adopte d a h ig h - p r io r ity n a ti o n a l pr og ram em phas iz in g en er gy 

e f f i c ie n t b u ild in g s , we c o u ld , by 19 90 , be sa v in g th e e q u iv a le n t o f 

1.9 25 m il li o n b a r r e ls o f petr ole um a d ay ." T his pr og ram e n v is io n s 

t h a t "in r e t r o f i t t i n g e x is tin g b u ild in g s , th e demand upo n th e t r a d i ­

tio n a l en er gy sy st em s wo uld be d ecre ase d by an av er ag e o f 30 p e rc e n t.

In new b u ild in g s , 60 p e rce n t sa vin gs are p o s s ib le , acco rd in g to AIA 

e s tim a te s .

In co n sid erin g th e q u e sti o n o f r e h a b i li t a t i n g e x is ti n g b u il d in g s 

i t i s u su a l to th in k o f m aj or u n d e rt a k in g s. We b e lie v e , ho wev er, in 

an on go in g pr og ram o f m inor r e h a b i li t a t i o n , wh ich we p r a c tic e and wh ich 

i s th e p ro cess o f conti nuous re ne w al o f o ld e r b u ild in g .

The pro pose d l e g i s l a t i o n , as yo u p o in t out in your in tr o d u c to ry 

sta te m e n t, ca nn ot be expecte d to work m ir a c le s. I t d o es, ho wev er, 

pro vid e an a d d it io n a l o p ti o n fo r th e p re se rv a ti o n o f fe d e ra l f a c i l i t i e s 

The d e c is io n re g a rd in g th e r e h a b ilita tio n o f an e x is tin g b u il d in g is 

very comp lex. Each ca se sh ould be e v alu ate d on i t s own m e rits , ta k in g 

in to c o n sid e ra ti o n h is to r y , a e s th e tic s , en er gy c o n se rv a ti o n , community 

n eed s, an d c o s t. Th ere a re many cas es wh ere e x is tin g b u ild in g s , fo r a 

co m bi na tion o f th e s e re a so n s , are not wor th y o f r e h a b i li t a t i o n .

F u rth e r, th e re are th o se s itu a tio n s in wh ich f a c i l i t y ne ed s may 

b e s t be s a t i s f i e d by new b u ild in g s .

The w id er ra nge o f a lte r n a tiv e s t h a t an a d m in is tr a to r has a t 

h is d is p o s a l, th e e a s ie r i t i s to fin d th e b e s t p o s s ib le s o lu tio n .

The pro pose d P u b li c B u il d in g s C ooper at iv e Use Act o ff e r s a new 

a lt e r n a t iv e , and we are p le a se d to know o f i t s in tr o d u c tio n .

E S :w El win Ste ven s

Manager o f M ar ket in g and R es ea rc h
S E C R E T A R Y O F S T A T E

BRUCE K. CHAPMAN

SAM SUM NER REED

174

S T A T E O F W A S H IN G T O N

Oly m pia 985 04

A p ril 2 . 19 75

Th e H o n o ra b le Ja m es L. B uckle v 

U n it e d S t a t e s S e n a te 

W ash in g to n . D. C. 20 51 0

D ea r S e n a to r B u c k le v :

T ha nk vo u f o r v o u r l e t t e r an d ac co m pan yin g m a t e r i a l c o n c e rn in g th e 

P u b lic B u ild in g s C o o p e ra ti v e Us e Act o f 19 75 . I am p le a s e d to be a s k e d 

t o com me nt on th e b i l l , an d yo u may c e r t a i n l y u se an y o f my s ta te m e n ts 

f o r i n c l u s i o n in th e h e a r in g r e c o r d .

I th in k t h a t t h i s i s an e x c e l l e n t b i l l , an d th e c o n c e p t t h a t i t 

e m b ra ces i s on e t h a t I have lo n g e n d o rs e d . W hil e I was a member o f th e 

C it y C o u n c il in S e a t t l e , I wa s a b le to s u c c e s s f u l l y pu sh a s i m i l a r pro gra m 

o f a d a p tiv e u se to e n c o u ra g e m u n ic ip a l a g e n c ie s t o l o c a t e in r e s t o r e d 

b u id in g s .

T h e re i s no Q u e s ti o n t h a t p r i v a t e e n t e r p r i s e n e e d s t o be en c o u ra g e d 

to u n d e rta k e r e s t o r a t i o n an d p r e s e r v a t i o n p r o j e c t s . I f a g o v e rn m e n ta l bo dy 

o r ag en cy i s a b le to p ro m is e to le a s e sp a c e in a b u i l d i n g c o n s id e re d f o r 

r e s t o r a t i o n , th e b u ild in g o w ners a r e t h a t much m or e e n c o u ra g e d t o co m p le te 

r e s t o r a t i o n . In S e a t t l e , we w er e a b le to u s e t h i s m et ho d e f f e c t i v e l y in 

a nu m be r o f in s t a n c e s .

I am c u r r e n tl y u rg in g G overn or E va ns t o a d o p t a s i m i l a r p o lic y 

d i r e c t i v e f o r th e D ep art m en t o f G e n e ra l A d m in is tr a tio n a t th e s t a t e l e v e l .

Th e m u lti- u s e c o n c e p t i s one w it h w hic h I h av e had l e s s e x p e r ie n c e , 

b u t o n e f o r w hic h I ca n p ro v id e a u s e f u l a n e c d o te t o i l l u s t r a t e v o u r p o i n t .

When th e G e n e ra l S e r v ic e s A d m in is tra tio n was n e g o t i a t i n g w it h th e l o c a l 

a r c h i t e c t s on th e d e s ig n o f th e F e d e ra l B u ild in g in S e a t t l e , th e d e s ig n te am 

a s k e d GSA f o r p e rm is s io n to in c lu d e sh o p s on th e g ro u n d f l o o r . GSA wa s 

am enable " in p r i n c i p l e " . Th e A r c h ite c ts in tro d u c e d id e a a f t e r id e a f o r 

f l o r i s t sh o p s , s id e w a lk c a f e s , s p e c i a l t y s t o r e s an d so o n , b u t e a c h , in t u r n , L

wa s r e j e c t e d by GSA. F i n a l l y , in e x a s p e r a tio n , th e a r c h i t e c t s a s k e d , "W hat 

i s a c c e p ta b le ? " Th e r e p ly fr om GSA w as , " P u b lic t o i l e t s . " U ltim a te ly , 

some GSA in fo rm a tio n an d p u b l i c a t i o n s o u t l e t s m an ag ed t o g e t on th e o t h e r ­

w is e d ead gro u n d f l o o r , b u t t h a t was i t .

B e st o f lu c k . f

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