MANAGING CHANGE:

Preservation and 

Rightsizing in America
B | RIGHTSIZING TASK FORCE REPORT

Chairman’s Message

The Advisory Council on Historic Preservation (ACHP) is pleased to present this report addressing 

rightsizing and historic preservation in America. This issue of rightsizing and its implications for historic 

preservation have been the focus of considerable attention since 2011 when the devastating effects 

of the economic downturn on historic properties within legacy cities became apparent to the 

preservation community. Residents urged the ACHP to assist in managing the effects of major changes 

occurring to historic properties in local neighborhoods across the country. Recognizing the important 

role the ACHP could play in advising stakeholders on how to incorporate historic preservation goals 

and requirements into community efforts, I designated a task force in 2011 to address this issue. 

The result of our efforts is incorporated in this report, Managing Change: Preservation and 

Rightsizing in America, which makes key recommendations for ensuring that historic preservation 

is a vital part of the solution for communities looking to reinvent themselves. The report documents 

the ACHP’s findings based on site visits to legacy cities, participation in conferences and meetings, 

and research. In addition, it makes recommendations to federal agencies and the diverse stakeholders 

involved in rightsizing in legacy cities and other communities. The phenomenon of rightsizing is similar to 

challenges presented decades ago by the Urban Renewal Program that resulted in the substantial loss 

of local historic assets. The lessons learned during that period have positioned us now to ensure that 

historic preservation informs the revitalization of our communities and is not considered an impediment 

to economic recovery.

In Section 1(b) of the National Historic Preservation Act (NHPA), Congress specifically states 

that the spirit and direction of the nation are founded upon and reflected in its historic heritage. 

Nowhere is this truth more important than in our legacy cities, where the very identity of the 

community is often tied to its rich heritage and the places that evidence that heritage. Despite that, 

in communities around the nation, historic buildings are being abandoned, designated as blighted, and 

ultimately demolished without due consideration to their value to the future. We know well that as 

historic buildings are lost, residential neighborhoods decline, schools are closed, industrial buildings 

are abandoned, and most importantly, people leave cities to which they were once deeply connected. 

While this abandonment, demolition, and neglect are not part of an orchestrated plan to destroy 

historic assets, this appears to be a widespread occurrence.

As we approach the 50th anniversary of the NHPA, the ACHP is providing leadership and 

assistance to federal agencies and communities that recognize the importance of the iconic 

buildings and neighborhoods significant to the heritage of their communities. Such resources 

stabilize neighborhoods, preserve heritage, promote sustainability, and provide a foundation for 

redevelopment activities when cities need them most. Indeed, rightsizing and historic preservation 

can and should be considered complementary terms that are used to promote strong communities. 

This report recommends that federal resources can and should be used to manage change and leverage 

historic assets. We urge federal, state, and local agencies and the private sector to incorporate historic 

preservation strategies in future public and private activities in communities affected by rightsizing.

Milford Wayne Donaldson, FAIA

Chairman
RIGHTSIZING TASK FORCE REPORT | i

Table of Contents

Executive Summary ............................................................................................................................................. ii

Introduction .......................................................................................................................................................... v

I. Rightsizing Defined ...........................................................................................................................................1

Background and History.............................................................................................................................................................. 5

Census Data Illustrates Effects of Rightsizing................................................................................................................... 6

Vacancies and Abandonment ................................................................................................................................................... 8

Industrial Abandonment and Reuse ..................................................................................................................................10

Base Closure and Rightsizing...................................................................................................................................................11

II. The Role of Historic Preservation Tools in Rightsizing..........................................................................13

Planning and Zoning ...................................................................................................................................................................13

Urban Agriculture and Forestry ............................................................................................................................................14

Rehabilitation and Reuse...........................................................................................................................................................15

Tax Act.................................................................................................................................................................................................17

Preserve America..........................................................................................................................................................................20

III. Federal Programs and Policies Related to Rightsizing ..........................................................................22

Federal Assistance, Loans, and Grants for Rightsizing Activities..........................................................................26

Accommodating Federal Assistance and Historic Preservation: The Section 106 Process.................32

IV. Enhanced Federal Program Coordination...............................................................................................35

Incorporating Historic Preservation in 

Federal Initiatives............................................................................................................................................................................38

Historic Preservation in Federal Grant Programs......................................................................................................39

V. Leveraging Federal Funds for Local Preservation Initiatives ...............................................................41

The Role of Non-Profits and 

Institutions in Rightsizing ..........................................................................................................................................................42

The Role of Banks in Historic Preservation ..................................................................................................................45

VI. Public Policy and Historic Preservation ..................................................................................................48

VII. Next Steps for Integrating Historic Preservation in Federal Programs ........................................51

Selected Bibliography ........................................................................................................................................54

Acknowledgements...........................................................................................................................................60

Cover: Downtown Newark, NJ, showcases old and 

new in one of America’s legacy cities.
ii | RIGHTSIZING TASK FORCE REPORT

Established population 

centers, rich in cultural 

heritage, have been, 

and continue to be, 

going through radical 

transformation, as their 

economic bases evolve, 

their populations shift, 

and their entire reason 

for being is in question. 

Executive Summary

A major challenge to the American social fabric is the dramatic changes to the nation’s cities in 

the post-industrial economy. Established population centers, rich in cultural heritage, have been, 

and continue to be, going through radical transformation, as their economic bases evolve, their 

populations shift, and their entire reason for being is in question. Change is inevitable in urban areas 

and is pronounced in legacy cities, defined as those communities developed at the height of the 

industrial revolution as centers of industry, commerce, business, and employment throughout the 

New England, Mid-Atlantic, and Midwest regions. Legacy cities can also include communities located 

in the West and Southwest regions that emerged for similar reasons at a later period, where shrinking 

populations, military base closures, and high rate of foreclosures have resulted in significant economic 

and employment shifts. Regardless of location or specific impetus, these communities face similar 

challenges, and how they deal with them will have a lasting and substantial effect on the cultural 

heritage of the nation. A popular term for the process these places are undergoing is “rightsizing,” 

defined as the process of reducing to an optimum size. 

To assess this phenomenon and its historic preservation implications, the Advisory Council on 

Historic Preservation (ACHP) created a Rightsizing Task Force in May 2011. Its goals were to identify 

policy needs regarding historic preservation in community renewal efforts; augment work done by 

other interagency task forces on livability and sustainability; provide best practices and case studies to 

localities and state and federal agencies; and to promote the consideration of historic assets early in 

the planning process.

In order to fully understand rightsizing from a historic preservation perspective, the Task Force 

solicited assistance from PlaceEconomics, a real estate and economic development consulting 

firm specializing in services to public and non-profit sector clients addressing downtown and 

neighborhood commercial district revitalization and the reuse of historic structures. They were 

asked to prepare a survey and analysis of a representative sample of rightsizing communities. 

Completed in May 2012, “Historic Preservation and Rightsizing” enabled the Task Force to assess 

how communities view the role of historic preservation and what federal programs were used to 

revitalize infrastructure and real properties, including historic properties. Additionally, Task Force 

members visited Detroit and Saginaw, Michigan; Buffalo, New York; Cleveland, Ohio; and Newark, 

New Jersey. These on-site visits confirmed the survey’s findings and provided an opportunity for Task 

Force members to interact directly with communities to understand their challenges as well as their 

successes in addressing historic preservation as part of rightsizing.

Based on the survey conducted by PlaceEconomics, meetings with community representatives, and 

extensive research of published articles and reports on the issue, the Rightsizing Task Force made 

several findings. Most notable are the following:

» Historic preservation offers a variety of tools and strategies that have proven useful in addressing 

issues of urban change and redevelopment.

» Historic preservation should be better integrated with local plans and economic development 

strategies in cities addressing rightsizing.
RIGHTSIZING TASK FORCE REPORT | iii

» Local governments need assistance from state and federal agencies as well as organizations such 

as the American Planning Association (APA) to develop and use preservation planning toolkits in 

all aspects of physical and economic development.

» Federal resources are not generally tied to the implementation of comprehensive plans, which 

typically consider community values such as transportation, sustainability, affordable housing, and 

historic preservation. Failure to tie resources to comprehensive plans or related master planning 

plans misses an opportunity to consider further these values. 

» Federal policies are inconsistent in their approach to rightsizing and do not fully incorporate 

historic preservation during implementation.

» The Federal Historic Preservation Tax Incentives Program is an important program that has been 

instrumental in the preservation and redevelopment of the core areas and mixed-use historic 

neighborhoods in legacy cities. 

This report addresses these findings and makes recommendations to federal agencies, 

local governments, and others for improving collaboration between local communities and 

preservationists. It also underscores the importance of raising awareness at a local level 

about historic preservation values in initiatives such as comprehensive and master planning, 

redevelopment efforts, and public-private partnerships focused on target areas. Federal programs 

have made substantial investments in communities for many decades. However, when such 

improvements are not tied to personal values, such as historic preservation, they may be short 

lived and not yield the benefits anticipated. In addition, the report includes actions that the 

ACHP itself can take to bring historic preservation to the attention of the Administration as it 

develops and implements public policies and procedures related to urban affairs and economic 

development. Key recommendations in the report include the following:

» The National Park Service (NPS) should collaborate with the ACHP, the National Trust 

for Historic Preservation, Department of Housing and Urban Development (HUD), and 

State Historic Preservation Officers (SHPOs) to promote the value of the Federal Historic 

Rehabilitation Tax Incentive Program to legacy cities. 

Historic buildings provide homes to 

residents and character to neighborhoods 

in communities, both urban and rural.

Historic preservation 

offers a variety of tools 

and strategies that 

have proven useful 

in addressing issues 

of urban change and 

redevelopment. 

CREDIT: © MAKSYMOWICZ - FOTOLIA
iv | RIGHTSIZING TASK FORCE REPORT

» The Administration should support expansion of the current Federal Historic Rehabilitation Tax 

Incentive Program to apply to owner-occupied structures, with special emphasis on low- and 

moderate-income owners.

» Federal agencies should ensure that the Section 106 process begins at the earliest stages of 

planning and that local governments coordinate planning and environmental reviews for all federal 

assistance in a comprehensive manner. 

» HUD should educate state and local grant administrators regarding effective measures to improve 

environmental reviews, including Section 106, for legacy cities. 

» The ACHP should work with Strong Cities, Strong Communities (SC2) to promote an 

understanding of the value of historic preservation strategies among federal agencies and local 

governments involved in planning federally assisted redevelopment efforts and to encourage 

collaboration among them.

» The ACHP and the preservation community should coordinate with the Federal Reserve, Federal 

Deposit Insurance Corporation, and other banking agencies to encourage them to promote 

preservation strategies in their programs.

» The Administration should engage the ACHP as an active participant in shaping federal urban 

policies to ensure historic preservation goals and practices are incorporated.

As the federal government refines its economic development and urban affairs policies for the 21st 

century, the value of historic preservation needs greater attention. In the absence of such consideration, 

one of the core values in local planning, the protection and reuse of existing assets, may be overlooked. 

With the passage of the National Historic Preservation Act (NHPA) in 1966, Congress expected federal 

agencies to show leadership in the preservation and contemporary use of the nation’s historic resources. 

However, as the 50th anniversary of NHPA approaches, this goal remains elusive, but the opportunities 

to achieve it are there. Numerous federal agencies will continue to participate in economic development, 

redevelopment, and revitalization efforts as communities are targeted for additional resources for both 

shrinking and growth activities. Such an initiative is the SC2, which was developed in 2011 to provide 

additional federal resources to targeted communities. Instead of avoiding the use of historic properties and 

identifying historic preservation as an impediment, state and local governments need to learn to maximize 

the use of these assets. Federal agencies, supported with technical assistance and guidance from qualified 

sources such as the NPS and SHPOs located in each state, must provide the vision and the leadership to 

integrate heritage assets into vibrant cities of the future. 

Protecting historic buildings, repurposing land, preserving neighborhoods, redeveloping downtowns, 

and connecting historic resources to regional plans through cooperative efforts will enable cities to 

transition to healthy communities that attract new residents and new businesses to meet the needs 

of the 21st century. Historic assets that are preserved and reused are the foundation for the future. 
RIGHTSIZING TASK FORCE REPORT | v

Preservationists and 

planners have defined 

“rightsizing” as the 

process through which 

legacy cities address 

significant physical 

and social changes to 

undergo a reduction to 

an optimal size.

Introduction

When the National Historic Preservation Act was enacted in 1966, Congress declared that: 

1. the spirit and direction of the nation are founded upon and reflected in its historic heritage; 

2. the historical and cultural foundations of the nation should be preserved as a living part 

of our community life and development in order to give a sense of orientation to the 

American people; 

3. historic properties significant to the nation’s heritage are being lost or substantially altered, 

often inadvertently, with increasing frequency; and

4. the preservation of this irreplaceable heritage is in the public interest so that its vital legacy of 

cultural, educational, aesthetic, inspirational, economic, and energy benefits will be maintained 

and enriched for future generations of Americans.

This visionary statement maintains its relevance today as the nation faces the challenge of preserving 

its major cities during the economic and physical changes of the 21st century.

Throughout the country, communities both large and small have experienced long-term economic 

transformation that can be associated with the decline of the manufacturing industries, collapsing 

financial markets, continuous population loss, and the mortgage crisis. The response to these 

financial, social, and economic challenges has not been well coordinated or efficient, resulting 

in resident frustration and increased flight from the legacy city to healthier communities in the 

metropolitan area. Not voluntarily, these cities are forced to “rightsize.” Preservationists and 

planners have defined “rightsizing” as the process through which legacy cities address significant 

physical and social changes to undergo a reduction to an optimal size. The term applies to business, 

Abandoned buildings create blighting influences in neighborhoods. 

This urban decay is illustrated by an abandoned commercial 

building with fire damage from arsonists in Detroit, MI.

CREDIT: ISTOCKPHOTO
vi | RIGHTSIZING TASK FORCE REPORT

land use, and economic changes. The 65 industrial cities reviewed in the 2007 Brookings Institution 

report “Restoring Prosperity” would all fit this definition of rightsizing legacy cities. As discussed 

during the 110th American Assembly of Columbia University, the Center for Community Progress, 

and the Center for Urban Sustainable Development, legacy cities have rich histories. Most have 

numerous physical assets; nevertheless, they struggle with staying relevant in today’s economy.

There is no question that the rightsizing process poses serious threats to the nation’s historic 

urban fabric. Research focused on 65 of the nation’s older industrial cities revealed they 

collectively have 4,209 listings on the National Register of Historic Places, many of which 

are historic districts comprising hundreds of individual properties. The listings do not include 

the even larger number of properties eligible for the National Register, thus it is likely these 

communities could document a far greater wealth of historic assets if comprehensive local 

surveys were completed. Unfortunately, as communities grapple with a diminishing tax base, 

reduced work force, declining public education systems, and increased poverty, historic 

preservation has not been recognized as a gauge regarding the quality of the community, and 

the value of historic buildings to economic recovery and community identity has not been 

universally acknowledged. Thousands of properties, a large percentage of which are defined 

as historic, have been vacated or gone into foreclosure, often leading to blighted conditions in 

neighborhoods that are home to residents who cannot or chose not to leave places to which 

they have a cultural, historical, economic, or social connection. 

The ACHP, in its oversight role of federal historic preservation reviews required by Section 106 of 

the NHPA, has monitored the trend of rightsizing in its work with HUD’s Community Development 

Block Grant (CDBG) entitlement communities. The ACHP recognized the need to address this 

issue due to its serious implications for historic preservation. Because legacy cities challenged by 

rightsizing have rich histories and abundant historic properties, it is critical that local, state, and federal 

From left, Youngstown Mayor Jay Williams, Michigan State 

Historic Preservation Officer Brian Conway, and Royce Yeater of 

the National Trust share information with the ACHP regarding 

rightsizing and its effects on local historic properties. (May 2011) 
RIGHTSIZING TASK FORCE REPORT | vii

decision makers acknowledge their value to the community and the opportunities to use them as 

a catalyst for future economic development. The reuse of historic properties is also a sustainability 

principle advanced by federal and state agencies to conserve resources and protect the environment. 

If large numbers of historic properties are vacant and blighted, cities will be unable to undertake 

preservation-based revitalization efforts in distressed neighborhoods and will lose the essence 

of their heritage and culture—qualities important to residents and visitors. More importantly, the 

city’s tax base is compromised as local property taxes and other administrative fees are lost due to 

declining property values and a lack of economic activity.

It is without dispute that America’s older legacy cities and their revitalization are critical to the country’s 

economy and its international economic competitiveness. Rightsizing, therefore, is a major public policy 

issue that must be confronted to stabilize communities that have suffered significant population and 

job loss, resulting in large-scale abandonment and vacancy. In 2012, as part of SC2, the Administration 

designated seven cities as the target of its initial effort to stem the tide of declining communities. While 

SC2 was not developed to specifically address rightsizing, it was an attempt to address many of the 

same elements that are associated with the phenomenon. Meanwhile numerous federal agencies 

continue to assist in myriad activities that shape the urban landscape by investing billions of dollars 

annually in redevelopment, transportation, affordable housing, remediation, and infrastructure.

Preservationists have long recognized that historic buildings are an essential part of the local 

aesthetics and an integral part of local character that is important to residents. They demonstrate 

continuity with the past, and provide an important context for future land use and design. On a 

personal level, they connect celebrated events in the lives of residents with iconic or familiar places. 

For these reasons and many others, federal, state, and local governments must acknowledge the 

intersection between rightsizing and historic preservation when formulating practical and timely 

It is without dispute 

that America’s older 

legacy cities and their 

revitalization are critical 

to the country’s 

economy and its 

international economic 

competitiveness. 

Maintaining historic facades 

is important to the heritage 

of communities.

CREDIT: KENNETH SPONSLER/ SHUTTERSTOCK
viii | RIGHTSIZING TASK FORCE REPORT

urban public policy. Historic preservation is an important element of a holistic approach taken to 

plan for future changes in a community or region. Preservation is one of the most potent tools for 

city revitalization. That message should not get lost amid worries about city shrinkage, notes Roberta 

Brandes Gratz in Citiwire.net. This report is intended to educate stakeholders and to provide a 

framework for developing the vision for a reconfigured community that incorporates and builds on 

historic assets. 

Historic preservation and the historic preservation community have an important role in 

advancing rightsizing initiatives. When government policies are developed, the business community, 

foundations, non-profit organizations, and grassroots organizations must be engaged early to 

shape rightsizing strategies that can achieve preservation outcomes. To demonstrate this, the 

report presents recent case studies illustrating the benefit of integrating historic properties 

into revitalization plans. Likewise, the ACHP’s recommendations provide a basis for the historic 

preservation community, federal agencies, and state and local governments to reconsider how 

historic assets can build resiliency in communities and help attract new residents and new 

businesses capable of revitalizing the community. 

Historic preservation 

and the historic 

preservation community 

have an important 

role in advancing 

rightsizing initiatives. 

Demolition is often 

considered the most feasible 

option to combat blight.
CHAPTER 1: RIGHTSIZING DEFINED | 1

Rightsizing is the process 

of change confronting 

communities that have 

drastically reduced 

population and excess 

infrastructure with a 

dwindling tax base.

I. Rightsizing Defined

Rightsizing is a term that has been used by businesses for the past three decades. Merriam-Webster’s 

dictionary defines it in this context as an enterprise that needs “to undergo a reduction to an optimal 

size.” However, the definition of rightsizing relates to a process that is dynamic and differs depending 

on the profession and context in which it is used. In the past decade, it has been used frequently to 

define the process of change confronting communities that have drastically reduced population and 

excess infrastructure with a dwindling tax base, leaving them as “shrinking cities” in need of planning 

to recalibrate. It is this definition that has guided the ACHP in preparing this report.

Rightsizing appeared as an urban planning and public policy issue for many preservationists as 

legacy cities such as Detroit, Baltimore, and Cleveland grappled with continually increasing levels 

of residential abandonment and deteriorating properties in violation of local building codes and 

ordinances. The concept also emerged during the Department of Defense’s implementation of the 

Base Realignment and Closure (BRAC) program, which affected hundreds of communities located 

near military installations across the nation. 

Regardless of the terminology, government programs have attempted to address the problem of 

rightsizing for decades. While federal, state, and local monies have been consistently appropriated 

since the 1970s to assist in stabilizing distressed communities, the management of blight—a common 

product of population loss—continues to be a major challenge. Over the years, HUD has created 

several new programs to supplement existing block grants. However, cities were often required to 

compete for funding or rely on congressional earmarks, which are no longer available. Since public 

funding could not keep pace with the growing need of cities attempting to address systemic issues of 

transformation, legacy cities have been experiencing continuous decline, and other communities are 

now confronting similar rightsizing issues. 

Rightsizing neighborhoods, like 

this one in Philadelphia, can 

often lack a sense of vitality. 

CREDIT: HUD
2 | RIGHTSIZING TASK FORCE REPORT

Of primary concern 

was the intersection 

between program 

goals and the federal 

historic preservation 

review requirements 

of Section 106. 

The passage of the American Recovery and Reinvestment Act of 2009 (ARRA), which included the 

Neighborhood Stabilization Program (NSP) administered by HUD, provided billions of dollars in 

funding to legacy cities. The ARRA funding was distributed through existing federal programs. Given 

the unprecedented level of federal resources, SHPOs, Certified Local Governments (CLGs), and the 

National Trust for Historic Preservation contacted the ACHP to obtain guidance on how to best 

respond to the challenges of HUD’s three NSP programs. Of primary concern was the intersection 

between program goals and the federal historic preservation review requirements of Section 

106. While the ACHP emphasized the need for an efficient approach to Section 106, it became 

apparent that there was also a need for federal agencies and local communities to consider historic 

preservation in developing new programs or redevelopment plans, as frequently, historic preservation 

was not adequately considered in those efforts. At this point, the ACHP determined that a hard look 

at rightsizing and historic preservation was needed. 

In an effort to better understand the effects of rightsizing on legacy communities with extensive 

amounts of historic properties, the ACHP convened a panel of three experts at its May 2011 

meeting: the Honorable Jay Williams, then-Mayor of Youngstown, Ohio; Brian Conway, Michigan 

SHPO; and Royce Yeater, former director of the Midwest Regional Office of the National 

Trust. Their presentations highlighted myriad challenges associated with rightsizing proposals, 

particularly those that did not consider the benefits of historic preservation in rapidly changing 

cities. Based upon the follow-up discussions between the ACHP membership and the panelists, 

ACHP Chairman Milford Wayne Donaldson empaneled an ACHP task force to more thoroughly 

investigate the challenges of rightsizing to communities and the role of historic preservation in 

assisting cities to recalibrate for the future.

The Rightsizing Task Force (Task Force) was chaired by ACHP Citizen Member Bradford White, 

and co-chaired by the National Trust for Historic Preservation. Other members included HUD, the 

Departments of Transportation (DOT), Agriculture (USDA), and the Interior (DOI), Environmental 

Protection Agency (EPA), National Conference of State Historic Preservation Officers (NCSHPO), 

National Alliance of Preservation Commissions (NAPC), Mayor Michael Coleman of Columbus, Ohio, 

and ACHP Vice Chairman Clement Price. The Task Force held monthly meetings, conducted on-site 

visits, and undertook relevant research and surveys. The goal was to develop a final report that 

Task Force Chairman Bradford White and Kathleen Crowther of the Cleveland Restoration Society discuss 

rightsizing during the Cleveland on-site meeting in June 2012.
CHAPTER 1: RIGHTSIZING DEFINED | 3

assembled the Task Force’s findings and recommendations, and to explore specific actions that could 

be implemented by members. 

At the outset, the Task Force concluded that it needed to have a consistent definition of rightsizing, as 

well as a concise mission statement. The Task Force agreed to define rightsizing as:

“...the redevelopment of the community in response to prolonged job and population loss, housing 

vacancy and abandonment, and deterioration of infrastructure, all of which create challenges in the 

management of stabilization and reinvestment efforts in existing neighborhoods.The community’s 

response to rightsizing would typically be a holistic approach to developing and implementing 

plans and activities that improve land use, real estate, infrastructure, and other systems needed to 

enhance quality of life, job creation, and the delivery of social services.”

To clarify the Task Force’s purpose and goals, the following mission statement was developed:

“The ACHP’s Rightsizing Task Force encourages the awareness and use of historic preservation as a 

tool for federal, state, and local governments in the revitalization of communities confronting rightsizing. 

The Task Force seeks to integrate federal policies and program initiatives with regulatory mandates in 

innovative and creative ways to stabilize and revitalize challenged communities.”

Common characteristics of rightsizing communities were important for the Task Force. The most 

significant characteristics identified in these communities include the following:

» urban areas with substantial decline in population; 

» eroding tax base; 

» excessive poverty compared to the metropolitan area; 

» excessive amount of vacant and abandoned houses in neighborhoods; 

» depressed center cities surrounded by strong suburbs;

» excess infrastructure based upon existing number of residents; 

» majority-minority demographic profile;

» changing demographics;

» high rate of poverty; 

Spot demolition is a regular occurrence 

in rightsizing cities where efforts are 

focused only on removing blight, not 

long-term redevelopment. 
4 | RIGHTSIZING TASK FORCE REPORT

» high crime rate;

» poorly functioning educational system; 

» substantial loss of industry and manufacturing; and

» prolonged high rates of unemployment.

The Task Force engaged PlaceEconomics, a Washington D.C.-based real estate and economic 

development consulting firm, to survey 20 legacy cities that were listed in the 2007 Brookings 

Institution report, “Restoring Prosperity.” These cities were expected to be the hardest hit by the 

rightsizing crisis, due to high unemployment, significant population loss, and aging infrastructure. 

The survey utilized both online surveys and phone interviews to better understand the problems 

associated with long-term population loss, the municipalities’ use of federal resources, and the role 

historic preservation currently plays in revitalization efforts. PlaceEconomics completed its report, 

“Historic Preservation and Rightsizing” in May 2012. This report was well-received and contained 

noteworthy findings. Two that were important to the Task Force were related to: (1) many cities 

are unaware of federal programs that can assist in rightsizing efforts, and (2) cities do not associate 

their redevelopment activities with rightsizing.

To ensure that its work was not conducted in a vacuum, the Task Force members individually or 

collectively conducted on-site visits to learn more about the intersection among federal, state, and 

local rightsizing efforts. The Task Force conducted on-site visits to the following cities: 

Detroit, Michigan (July 2011) 

Saginaw, Michigan (July 2011) 

Buffalo, New York (November 2011) 

Cleveland, Ohio (June 2012) 

Newark, New Jersey (August 2012)

These visits enriched the Task Force’s understanding of rightsizing and provided an opportunity for 

Task Force members to interact directly with affected community residents and local officials. While 

the Task Force was unable to go to all 20 legacy cities, it determined that this sample was particularly 

The Task Force consults with the community during the 

Newark on-site meeting; residents opened houses on 

this block to demonstrate adaptive reuse.
CHAPTER 1: RIGHTSIZING DEFINED | 5

illustrative of the depth and breadth of the rightsizing issues that are currently being addressed. 

Although the visits focused on the Rust Belt and the Northeast, it was clear that the phenomenon of 

rightsizing also occurs on the west coast and in the Midwest and South, and in cities perceived to be 

healthy and stable. The location of other rightsizing cities can be gleaned from Census Bureau data, 

foreclosure statistics, and the allocation of HUD NSP funds. The site visits clarified that legacy cities 

undergo changes for a variety of reasons, but the symptoms and consequences of rightsizing are 

generally the same, even if the causes are different.

BACKGROUND AND HISTORY

Rightsizing has been occurring in cities for decades as communities respond to transformative events, 

which brought major changes within legacy cities. Urban planners, preservationists, mayors, academics, 

and federal research agencies have observed increases in property vacancies, abandonment, 

homelessness, eroding tax base, increased crime, and other systemic issues in many older cities. The 

census data has documented declining urban populations since the 1960s, when manufacturing and 

industries reached their peak. Despite the recognition by residents and local officials that there was 

increasing abandonment of buildings, rapid decline of municipal services, increasing homelessness 

and poverty rates, and declining educational opportunities, it did not result in coordinated federal 

intervention or targeted resources. As populations declined, federal block grant funding decreased 

based on population figures. Communities were forced to seek other sources of funding like 

competitive federal grants and philanthropic assistance to fund redevelopment activities. Since 1980, 

it has been challenging to define a consistent public policy to deal with shrinking cities and the 

rightsizing challenge.

HOUSING DENSITY CASE STUDY

DENSITY CAPACITY CURRENT DENSITY

LELAND

McDOUGALL

MORAN

WILLIS

LELAND

McDOUGALL

MORAN

WILLIS HOUSING DENSITY CASE STUDY 

Tax calculations are based on a 

household income of $30,000 and 

housing value of $50,000. The 

resident income tax rate is 2.5%, 

and the current millage rate for 

the City of Detroit is 65.14 per 

1,000. 

+/- 185 HOMES

$440,023 IN TAXES

540 PEOPLE

23 PEOPLE/ACRE

+/- 40 HOMES

$95,140 IN TAXES

116 PEOPLE

5 PEOPLE/ACRE

Many people remember urban renewal during the 1950s and 1960s and the devastating impact 

it had on communities. In fact, some communities are still recovering from its effects decades 

later. While on the surface rightsizing may appear to be the new version of urban renewal due to 

similarities in widespread demolitions and efforts to reduce blight, the two concepts differ in several 

ways. Urban renewal primarily utilized a top-down decision-making approach for its redevelopment 

strategy, where the federal government determined which projects would best benefit a city without 

necessarily involving the public. Today, rightsizing is generally conducted on a local level with state 

assistance and a greater emphasis on public-private partnerships to maximize returns on assistance 

from federal programs. Urban renewal focused on moving people out of city centers and into 
6 | RIGHTSIZING TASK FORCE REPORT

Today’s legacy cities are 

a recognized component 

of larger regional 

or metropolitan areas 

that are home to 

millions of residents. 

the suburbs. Rightsizing recognizes the need to sustain cities, especially the downtown core and 

neighborhoods, and tries to build on their assets. 

During urban renewal, distressed cities were perceived as independent of activities in the 

surrounding suburbs. Therefore, the well-being of the community was limited to its downtown 

core and surrounding neighborhoods. Today’s legacy cities are a recognized component of larger 

regional or metropolitan areas that are home to millions of residents. Local heritage and culture 

are often considered in a regional context and not exclusively on a particular community. Regions 

in the Northeast such as Massachusetts, Rhode Island, and Connecticut, and those in northern 

Ohio: Cleveland, Toledo, and Youngstown, are comprised of diverse neighborhoods with ethnic 

communities built around historic churches and schools. When the neighborhoods change due to 

deteriorated housing, shuttered institutions, limited retail and entertainment, and the closure of 

businesses, social and cultural values may change, and adverse impacts on historic properties become 

pervasive, particularly in historic districts. The cumulative effect of these local changes is demolition or 

abandonment of residential historic properties and the long-term vacancies of institutional properties 

that reflect declining populations or poverty. Residents with financial wherewithal often relocate from 

these older, distressed communities to suburbs that have the services and amenities they feel are 

critical to their quality of life. These shifts mean that existing infrastructure is not appropriate for the 

population that remains. 

Rightsizing is a response to economic and social conditions that require more expansive and 

comprehensive planning and project implementation than occurred in past urban renewal programs. 

Legacy cities undergoing rightsizing must make timely decisions about the long-term physical, 

economic, and social conditions of their community, recognizing that the city is part of a region where 

it functions as an interdependent unit. Local officials have realized that such decision making must 

involve federal and state government and the private sector if redevelopment strategies are to be 

funded and implemented.

In the 1960s and 1970s, federal programs addressed many of the systemic issues that were 

occurring in legacy cities in an ad hoc manner. Historic preservation and environmental reviews 

established by legislation were in their infancy, and regulations and guidance documents were not 

developed, leaving federal agencies to interpret the requirements according to their program 

needs. In 1979, the ACHP and the Council on Environmental Quality first issued regulations 

to implement Section 106 of the NHPA and the National Environmental Policy Act (NEPA) 

respectively, establishing formal historic preservation and environmental reviews for federally 

supported activities. Subsequent to the issuance of these regulations and their requirements that 

federal agencies engage stakeholders in project reviews, local governments began to address 

historic preservation in a more systematic manner. However, it should be noted that considerable 

adverse effects to historic properties occurred prior to 1979 from such programs as HUD’s 

Federal Housing Administration loan guarantees and Section 312 Rehabilitation Program, the 

Economic Development Administration’s planning and redevelopment programs, Federal Highway 

Administration funding, and Small Business Administration loans. 

CENSUS DATA ILLUSTRATES EFFECTS OF RIGHTSIZING

The economic ills, increased crime rates, ineffective education systems, declining tax bases, and changing 

demographics associated with rightsizing communities often exist in otherwise economically robust 

metropolitan areas. This is a dilemma that many state and local officials find difficult to reconcile. During 

the identification of rightsizing communities, several were found to be located in a strong census 

Metropolitan Statistical Area (MSA), which is defined as a large population nucleus together with 

adjacent communities having a high degree of social and economic integration with that core. An MSA 
CHAPTER 1: RIGHTSIZING DEFINED | 7

may comprise one or more entire counties. Typically, the core population is centered in the city, with 

the remaining population spread throughout surrounding suburbs and smaller cities. In rightsizing cities, 

however, the MSA population is flipped: there is a higher population in the surrounding area than in the 

central city. Examples of this reverse trend include Detroit, Philadelphia, Indianapolis, and St. Louis. This 

reversal revealed that many residents had begun to exit the central city and relocate into neighboring 

suburbs with lucrative businesses, diverse housing types, stronger tax bases, better school systems, and 

low crime rates. Moreover, the infrastructure in suburbs tends to be newer and, due to a tax base of 

primarily middle- and upper-income residents, well-maintained. The systematic relocation of stable, more 

prosperous families away from the core cities in a region has resulted in many of the issues associated 

with rightsizing. As the populations declined and the tax base eroded, the existing infrastructure became 

excess to the needs of the cities and difficult to sustain financially. 

CITY POPULATION 1950 POPULATION 2010 % CHANGE

Baltimore, MD 949,708 620,961 -34.6%

Binghamton, NY 80,674 47,376 -41.3%

Buffalo, NY 580,132 261,310 -55.0%

Canton, OH 116,912 73,007 -37.6%

Cincinnati, OH 503,998 296,943 -41.1%

Cleveland, OH 914,808 396,815 -56.6%

Dayton, OH 243,872 141,527 -42.0%

Detroit, MI 1,849,568 713,777 -61.4%

Flint, MI 163,143 102,434 -37.2%

Harrisburg, PA 89,544 49,528 -44.7%

Huntington, WV 86,353 49,138 -43.1%

Newark, NJ 438,776 277,140 -36.8%

Pittsburg, PA 676,806 305,704 -54.8%

Rochester, NY 332,488 210,565 -36.7%

Saginaw, MI 92,918 51,508 -44.6%

Scranton, PA 125,536 76,089 -39.4%

St. Louis, MO 856,796 319,294 -62.7%

Syracuse, NY 220,583 145,170 -34.2%

Utica, NY 100,489 62,235 -38.1%

Youngstown, OH 168,330 66,982 -60.2%

8,591,434 4,267,503 -50.3%

There are compelling indicators of this shift of economic resources. June 2013 census data indicated 

that one in seven people in the U.S. received food stamps. The same data indicated that the amount 

of recipients in legacy cities was triple this amount. The 2011 American Community Survey Data 

documented disproportionately higher high school dropout rates, a growing percentage of elderly 

and single mother households, and escalating numbers of children who qualify for federal subsidized 

lunch programs in these communities. Another important indicator in legacy cities experiencing 

rightsizing is the level of homelessness among families and single individuals. Prolonged periods of 

unemployment are documented as the reason for protracted homelessness and increasing rates of 

foreclosures. These changing trends in population and demographics not only diminish the tax base in 

legacy cities but also lead to a growing reliance on federal, state, and local programs to support the 

financially-challenged residents that remain. 
8 | RIGHTSIZING TASK FORCE REPORT

The cost of dealing 

with abandoned 

properties has had 

major adverse impacts 

on local budgets as 

vacant lands and 

properties require 

attention and public 

expenditures.

VACANCIES AND ABANDONMENT

Rightsizing’s effects on legacy cities include significant financial burdens and maintenance challenges, 

particularly as they relate to historic properties. The cost of dealing with abandoned properties 

has had major adverse impacts on local budgets as vacant lands and properties require attention 

and public expenditures. Supplemental resources are needed to secure vacant properties and 

protect them from vandalism, provide expanded public safety, conduct judicial and administrative 

hearings regarding code enforcement and property laws, and safeguard the neighborhood from 

crime. In addition, local governments have had to allocate scarce resources for demolition of 

blighted properties, recognizing that providing for the safety and welfare of residents is necessary 

to retain those who want to remain in once-stable neighborhoods. Without a resident to provide 

maintenance, properties, many of which may be historic, often deteriorate, become designated as 

dilapidated and “blighted,” and are subsequently demolished. In neighborhoods with large numbers 

of blighted structures, local governments may feel that the only option is to demolish properties to 

provide safety for residents and to provide some form of community stabilization.

A recent article in the New York Times indicated that “large-scale destruction is not only underway 

in Detroit but also in Baltimore, Philadelphia, Cleveland, Cincinnati, Buffalo and other legacy cities 

at a cost of more than $250 million.” The goal of these demolition efforts is ostensibly to stimulate 

economic growth, reduce crime and blight, and increase environmental sustainability. Local officials, 

however, have not always explored alternatives to demolition, which worries some stakeholders. 

While local decision makers are not required to consider alternatives when using state and 

local monies, federal funds are subject to laws and procedures that mandate evaluation of viable 

alternatives in coordination with the public. For example, HUD’s environmental regulations require 

communities that receive its funding to consider alternatives to demolition, such as rehabilitation 

in accordance with the recommended approaches in “The Secretary of the Interior’s Standards 

Blighted multi-family residential 

property has been cordoned off 

for safety purposes.
CHAPTER 1: RIGHTSIZING DEFINED | 9

The proliferation of 

vacant and abandoned 

houses is normally first 

noticed by the residents 

who live within the 

neighborhood and 

who are powerless to 

stem the tide.

for the Treatment of Historic Properties” (Standards). Following the Standards rather than merely 

bringing properties up to code with incompatible materials and unsympathetic treatments can 

result in better preservation outcomes. Unfortunately, the dire situations confronting legacy cities 

appear to have led to relaxed environmental reviews, including historic preservation, and too often 

rehabilitation and reuse get only cursory consideration.

Residential abandonment in legacy cities typically occurs in a piecemeal manner. The proliferation 

of vacant and abandoned houses is normally first noticed by the residents who live within the 

neighborhood and who are powerless to stem the tide. Often the cumulative effect of excessive 

abandonment is considered to cause blight, which is defined by local and state laws and by HUD. 

Within planning and redevelopment, blight may refer to impacts on a city’s physical fabric (i.e. 

buildings). The Ohio Revised Code defines “blighted area” and “slum” as an area in which at least 70 

percent of the parcels are blighted parcels, and those blighted parcels substantially impair or arrest 

the sound growth of the state or a political subdivision of the state, retard the provision of housing 

accommodations, constitute an economic or social liability, or are a menace to the public health, 

safety, morals, or welfare in their present condition and use. 

In Ohio, for example, “blighted parcel” means the following: 

A parcel that has one or more of the following conditions: 

(a) A structure that is dilapidated, unsanitary, unsafe, or vermin-infested and that because of its 

condition has been designated by an agency that is responsible for the enforcement of housing, 

building, or fire codes as unfit for human habitation or use; 

(b) The property poses a direct threat to public health or safety in its present condition by reason 

of environmentally hazardous conditions, solid waste pollution, or contamination; or,

(c) Tax or special assessment delinquencies exceeding the fair value of the land that remains 

unpaid 35 days after notice to pay has been mailed. 

Excessive numbers of blighted structures in a community lead to plummeting real estate values, 

increases in crime, and a lack of community services. Blighted residences and deteriorating 

infrastructure also affect whether families will remain in their homes or move to suburbs or other 

cities, causing further population loss and increasing concerns about safety, return on investment, 

and overall quality of life. In neighborhoods with increased vacancies, officials have observed that 

homes that remain occupied have blended intergenerational families due to financial hardship, 

unemployment, and foreclosures. Systemic community changes such as these, which seriously 

undermine the local tax base, often lead to massive disinvestment in local services and resources 

necessary to maintain excess infrastructure.

Representatives of legacy cities challenged by rightsizing acknowledge the daunting changes that 

increased vacancies have caused to the built environment. A Government Accountability Office 

(GAO) study from November 2011 entitled, “Vacant Properties: Growing Number Increases 

Communities’ Cost and Challenges,” analyzed data from the Census Bureau, the Federal Housing 

Administration, the United States Postal Service, and two housing-related government-sponsored 

enterprises, Fannie Mae and Freddie Mac. Congress requested this study to determine the effect of 

foreclosures and unemployment on property vacancies. It also sought to clarify how vacancies were 

defined and what factors were considered to differentiate vacancies related to seasonal housing 

versus those related to foreclosures and abandonment. This study revealed which states and cities 

were experiencing the most serious problems with vacancies. 
10 | RIGHTSIZING TASK FORCE REPORT

Following their 

abandonment, industrial 

and manufacturing 

buildings typically 

suffer from demolition 

by neglect... As such, 

they are easy targets for 

arson, vandalism, and 

other public nuisances. 

Census data showed that “non-seasonal vacant properties increased 51 percent nationally between 

2000 and 2010, with 10 states seeing increases of 70 percent or more.” GAO’s report noted that 

officials in Baltimore, Chicago, Cleveland, and Indianapolis found that unattended vacant properties 

in those cities are largely concentrated in economically distressed and blighted areas. The report’s 

data confirmed that the increase in vacancies contributed to worsening local economic conditions, 

demonstrated by staggering unemployment rates, seizure of properties for tax delinquencies, inability 

of investors to sell residences quickly, and population decline. 

INDUSTRIAL ABANDONMENT AND REUSE 

The shuttering of manufacturing and industrial complexes often occurs prior to the loss of population 

in cities. In fact, it is often the loss of employment opportunities that result in a domino effect of 

foreclosures, vacancies, and blight. As such, any discussion of rightsizing must address the challenges of 

repurposing and reusing industrial and manufacturing sites.

Local officials are typically not forewarned by businesses when closures are imminent. Thus, the city 

is rarely prepared for, or capable of, planning for the necessary transitions. The location and nature 

of these businesses can result in challenges to developing reuse strategies. In older, industrial cities, 

it is particularly complicated to identify new uses for obsolete trades and services that have been 

replaced by new technology or outsourced in the global economy. Factories that built obsolete 

equipment and industrial facilities that have been upgraded in new locations are often overlooked 

when exploring redevelopment opportunities in rightsizing communities. It should be noted, 

however, that factories, mills, and warehouses also may have important associations with community 

development history and civic identity, like the tobacco mills located throughout North Carolina.

Following their abandonment, industrial and manufacturing buildings typically suffer from demolition 

by neglect. These facilities are often not properly secured, nor are they mothballed or stabilized 

following their closure, marketing, or transfer to third parties. As such, they are easy targets for arson, 

vandalism, and other public nuisances. The Buck Hosiery Mill in Philadelphia is a tragic example of 

The redevelopment of the former Bethlehem Steel Corporation plant in 

Bethlehem, PA, took into account the broader needs of the community when it 

conveyed contributing buildings to the state and city for adaptive reuse, including 

the construction of a Sands Hotel and Casino (top right). Former Bethlehem Steel 

Corporation headquarters, or “Main Office” as it was known, is in the center.

CREDIT: NATIONAL MUSEUM OF INDUSTRIAL HISTORY, BETHLEHEM, PA
CHAPTER 1: RIGHTSIZING DEFINED | 11

arson which resulted in the death of two firefighters. These abandoned industrial facilities, while 

posing challenges such as environmental remediation, can serve as valuable assets in addressing 

rightsizing. Preservation strategies offer effective tools for their stabilization and reuse as vibrant hubs 

of community life and economic development. Unfortunately, local officials too often view them as 

signs of decay and a threat to redevelopment, rather than the assets that they can be. 

The redevelopment of the iconic and historic Bethlehem Steel Corporation plant (1857–2003) in 

Bethlehem, Pennsylvania, demonstrates how an industrial site can be successfully repurposed and 

contribute to community rejuvenation. Bethlehem Steel recognized the historical significance of the 

property, listed on the National Register, and based on extensive input from the local community, 

agreed to redevelop the site. The project included the state’s largest brownfields remediation in 

preparation for the construction of a casino and hotel, which opened in 2010 and 2011 respectively. 

Through a strong public-private partnership, a reuse alternative was developed that not only used 

major elements of the historic site but also replaced some of the jobs and income that were in 

jeopardy with the closure of the plant. 

BASE CLOSURE AND RIGHTSIZING

As the Task Force explored the range of legacy cities that are rightsizing, military communities could 

not be overlooked as the Department of Defense (DoD) was actually one of the first federal 

agencies to confront rightsizing. Over the past two decades, communities tied to military bases 

experienced excessive population loss and high rates of residential vacancy following the relocation 

of the military and closure of the facility. The cities adjacent to bases selected by the DoD’s BRAC 

Commission and Congress often experience major economic decline like legacy cities. Similar to the 

loss of industry or manufacturers, the closure of military bases entails the loss of military personnel 

and support services that comprise an economic engine for the region. Base closures can have 

catastrophic impacts on local employment, local businesses, housing, and the tax base. Unlike the 

situation legacy cities are left to confront in determining next steps with limited resources, base 

closure cities have had support from the DoD’s Office of Economic Adjustment (OEA). The OEA 

provides planning assistance to communities, helps establish redevelopment authorities, and assists 

with work force development to avoid a local financial crisis. This is a model from which other federal 

agencies would benefit in their work with legacy cities. 

The selection of military installations to be closed by DoD began in 1990. The Secretary of Defense 

developed a list of proposed closures and realignments in coordination with the BRAC Commission 

and submitted them to the President for approval. Upon approval by the President, the list went to 

Congress for its approval. There have been several rounds of BRAC actions, with the last occurring in 

2005 when 182 installations were closed or realigned. 

In 1991, Congress approved the closure of Fort Ord, a 28,000-acre U.S. Army post established in 

1917 located near Monterey, California. This BRAC action resulted in the loss of a major employer in 

the area and the need to find alternative employers to capitalize on a unique historic asset. As part 

of the closure of this installation, the Army had to comply with a variety of federal requirements to 

determine whether portions of the base would be used for other federal purposes or supportive 

services for the homeless or conveyed through public benefit transfers, public auctions, negotiated 

sales, or Economic Development Conveyances (EDC). EDCs include historic property preservation, 

rehabilitation, and marketing for development and reuse. Immediately following the base’s closure, the 

Fort Ord Reuse Authority was established to allow local, state, and federal agencies and the private 

sector to develop a reuse plan. The development of the reuse plan, which was intended to take a 

holistic approach to redevelopment, was informed by the federal screening process as well as NEPA 

and Section 106 reviews. 
12 | RIGHTSIZING TASK FORCE REPORT

In accordance with the federal screening process, most of the land was returned to the State 

of California and was used by California State University, Monterey Bay, as a secondary campus. 

The Veterans Transitional Center obtained a substantial portion of the base to serve veterans by 

providing training and counseling. The City of Marina received a substantial site through the Economic 

Development Conveyance process, which was ultimately used to develop a mixed use project that 

included retail, residential development, and open space with recreational amenities. Finally, in 2012, 

President Obama designated another part of Fort Ord as a National Monument, to be managed by 

the Bureau of Land Management. This 14, 651 acre site captures the historic nature of the site and 

highlights its natural beauty and abundant wildlife. The monument includes 83 miles of biking, hiking, 

and equestrian trails for the greater public to enjoy. 

Without the successful federal screening of the installation and the interagency collaboration 

and flexibility, the installation’s closure would have resulted in a huge swath of unused land in the 

community. Instead, today it is an example of a repurposed property that was redeveloped in the 

public interest and acts as catalyst for economic development in the city and state. The critical 

element in this success story was an integrated planning process that recognized from the outset the 

important historic characteristics of the property; engaged all levels of government, stakeholders, and 

the public; and viewed the resources as assets.

As part of the closure of the Fort Ord, CA, Army base in 1991, a Reuse Authority, comprised of federal, state, and local representatives, was established to determine a 

redevelopment strategy for the base. A portion of the installation was transferred to California State University, which reused a number of the historic buildings (like 

these former bachelor officers quarters) for dormitories. 

CREDIT: CALIFORNIA STATE UNIVERSITY-MONTEREY BAY
 CHAPTER 2: THE ROLE OF HISTORIC PRESERVATION TOOLS IN RIGHTSIZING | 13

II. The Role of Historic Preservation 

Tools in Rightsizing

When residents are asked what they enjoy most about their communities, their responses are 

frequently things like access to public transportation; proximity to services like schools, banks, 

and stores; the sense of place; distinctive architecture; and neighborhood character. Historic 

districts, many of which are residential neighborhoods, often have all these features. Maintaining 

the historic integrity of these areas preserves the sought-after local color and character, providing 

an important element of maintaining community stability, livability, and walkability. At the same 

time, historic preservation strategies advance sustainable redevelopment and capitalize on existing 

transportation systems and infrastructure.

Legacy cities across the country have used a number of tools to address rightsizing that have 

historic preservation implications. The PlaceEconomics survey was an overview of the types of 

federal programs available to local communities. Additional programs are identified in this report to 

demonstrate how they also could be used to preserve and reuse historic properties. In its policy on 

redevelopment issued in 2004, the APA specifically cites historic preservation as a tool for effective 

redevelopment. However, projects that are funded at the federal level often overlook the options 

that involve historic properties. Consistent with the policies of the NHPA, federal agencies should 

show leadership in introducing historic preservation to prospective state and local applicants and 

non-governmental organizations that may be interested in applying for their programs. After all, 

historic preservation is a proven strategy to use federal resources to assist cities addressing current 

challenges and plan for a strong, revitalized community. 

PLANNING AND ZONING 

The Rightsizing Task Force concluded during its meetings that in most legacy cities, current zoning 

practices are focused only on land use or density and frequently lack protocols for newer practices 

like adaptive use and infill construction that could stabilize historic streetscapes or allow for other 

innovative uses that can benefit the community. By amending zoning ordinances, cities are able to 

redevelop and reuse vacant parcels as productive pieces of land for economic development. Through 

revisions to its zoning regulations, the City of Cleveland has now been able to implement innovative 

land uses with much success. Other cities have developed programs where side yards are provided 

to adjacent landowners for food and flower gardens. Where zoning ordinances have been reviewed 

to ensure their relevancy to new conditions and circumstances and subsequently updated, they have 

been shown to be useful tools for dealing with rightsizing challenges. 

However, zoning and building codes are only as effective as their enforcement, which is carried out by 

local employees who handle administrative and technical reviews. In a climate of declining revenues 

and staff reductions, the ability of local officials to implement zoning ordinances and building codes is 

challenged. Accordingly, enforcement is not always consistent and cannot be presumed to identify all 

vacant and underutilized properties. In the Cleveland suburb of Lakewood, Ohio, officials recognized 

this challenge and used staff to proactively survey the entire area and classify each property according 

to its code compliance. The city then targeted its efforts on those properties that needed the most 

intervention, offering the owners financial and technical assistance to fix their property. This creative 

Maintaining the 

historic integrity of 

these areas preserves the 

sought-after local color 

and character, providing 

an important element of 

maintaining community 

stability, livability, 

and walkability.
14 | RIGHTSIZING TASK FORCE REPORT

Once a community 

experiences widespread 

demolition, it is 

difficult, if not 

impossible, to rebuild 

in full or replicate the 

original neighborhood, 

its buildings, setting, 

and landscape.

approach has also been successful in coordinating historic preservation with implementation of local 

administrative activities such as the issuance of building permits required for infill construction. 

Most communities have a separate regulatory mechanism to address land use and design issues 

related to historic preservation. These are often administered by separate bodies with their own 

staff. As a result, to ensure that historic preservation is considered in comprehensive planning and 

redevelopment planning, collaboration among planning and historic preservation staff and local 

preservation commissions is required. Such collaboration must be consistent and transparent to 

inform residents of decision making efforts. The key is to get survey information into comprehensive 

plans so redevelopment proposals can properly factor in historic properties. Comprehensive plans 

developed in a holistic manner can serve as a blueprint for protecting and reusing existing assets. 

Such plans address the location and proposed treatment of diverse land use and infrastructure. The 

plans also identify different development or redevelopment strategies prepared to meet goals such as 

sustainability and smart growth. Accordingly, a working relationship between the planning department 

and the local redevelopment agencies responsible for allocating HUD funds is necessary. They can 

assist in expediting the implementation of neighborhood master plans, once the local preservation 

commission approves design principles for future projects. This approach was used in New Orleans 

as part of the Hurricanes Katrina and Rita federally funded disaster recovery efforts. 

URBAN AGRICULTURE AND FORESTRY

The reuse of vacant urban spaces created by extensive demolition often presents major 

challenges in many rightsizing communities. Once a community experiences widespread 

demolition, it is difficult, if not impossible, to rebuild in full or replicate the original neighborhood, 

its buildings, setting, and landscape. New concepts such as urban agriculture and forestry are 

beginning to make effective use of vacant lots and assist communities in pursuing healthy-living 

initiatives highlighted in sustainability and planning literature. 

The Summer Sprout program in Cleveland is a partnership between the city and the Ohio State 

University Extension that supports more than 170 community gardens. The program provides 

seeds and other garden resources to eligible gardens based on an application from a “garden 

leader.” Many gardens have the potential to bring local residents together around a shared 

resource and experience. 

“Mapping” Distressed Neighborhoods

A February 17, 2014 New York Times article profiled the City of Detroit’s efforts to tour neighborhoods 

and document each house, business, and vacant lot to quantify the level of blight in the city. The proposed 

evaluation of approximately 380,200 parcels will document current conditions and occupancy status. 

This type of documentation is referred to as “mapping.” The information collected from mapping is used 

to create local databases that assist local and state decision makers in managing blight and planning 

redevelopment strategies. GIS is a versatile mapping tool widely used by cities to address planning issues. 

While mapping is not a new phenomenon in legacy cities such as Philadelphia, Chicago, St. Louis, and 

Boston, its 21st century use is attached to GIS applications and Web sites that make it easier than ever to 

identify properties suited to preservation-based redevelopment approaches. Additional information can 

be obtained at http://mappingdecline.lib.uiowa.edu/links/.
 CHAPTER 2: THE ROLE OF HISTORIC PRESERVATION TOOLS IN RIGHTSIZING | 15

Other cities such as Philadelphia and Indianapolis have utilized vacant land to grow and harvest fresh 

produce, which can then be sold at a farmers’ market. This well-received agricultural strategy brings 

healthful food into areas that may not have easy access to grocery stores otherwise. Markets and 

urban agriculture provide entrepreneurial opportunities and can create jobs for the local residents. 

They also are becoming an integral component of local educational curricula. 

Another innovative use of vacant parcels in rightsizing communities is urban forestry. Using trees and 

greenery provides benefits such as cleaner air and better storm water management systems. The 

Greening of Detroit, a nonprofit organization that regularly partners with local, state, and federal 

agencies, has planted more than 6,000 trees in a strategic landscape plan to make the most of vacant 

lots and provide a cleaner, healthier environment. Although forestry is not traditionally viewed as a 

historic preservation strategy, it actually helps stabilize historic districts by adding environmental and 

aesthetic amenities that reinforce existing neighborhoods.

REHABILITATION AND REUSE

Rehabilitation is often the preferred redevelopment strategy among residents who reside in the 

legacy city neighborhoods. The rehabilitation and adaptive reuse of historic buildings is perhaps 

the most significant contribution historic preservation can make to revitalized and sustainable 

communities. Rehabilitating these properties can provide serviceable structures that can be put back 

in use quickly to meet contemporary needs while providing continuity with a community’s unique 

past. It can also galvanize the citizens around preserving local history and culture. 

Rehabilitation is defined as the process of returning a property to a state of utility, through repair 

or alteration, which makes possible an efficient contemporary use while preserving those portions 

and features of the property that embody its historic, architectural, and cultural values. Incentive 

programs have been developed at the federal and state level that provide tax credits for incomeproducing properties, and in some states, owner occupied residences. In order to take advantage of 

Urban gardens like the one 

in this photo from Chicago, 

IL, provide employment, 

educational, and recreational 

opportunities to local residents.

CREDIT: WIKIPEDIA
16 | RIGHTSIZING TASK FORCE REPORT

HUD defines 

mothballing as the 

temporary stabilization 

and protection of a 

property from the 

elements while alternative 

uses or funds for its 

rehabilitation are sought.

the 20 percent credit offered in the Federal Historic Preservation Tax Incentive Program, a private 

sector investor must rehabilitate an income-producing “certified historic structure,” as defined by the 

NPS. The rehabilitation of the property must also adhere to the recommended approaches in the 

“Secretary’s Standards for Rehabilitation” and be approved by the SHPO and NPS. A credit of 10 

percent is available for income-producing buildings that are not historic but placed in service before 

1936. The rehabilitation of these properties does not require a review by the SHPO or NPS.

When rehabilitation of a historic property is not a short-term option, property owners and state or 

local government often consider the interim step of mothballing. HUD defines mothballing as the 

temporary stabilization and protection of a property from the elements while alternative uses or 

funds for its rehabilitation are sought. Decisions to mothball historic properties require thoughtful 

evaluation of reuse opportunities as part of a holistic planning process. While this strategy requires 

an initial investment for securing, monitoring, and protecting properties as reuse plans are being 

explored, it can save valuable historic assets for future use. 

A land bank is defined by HUD as a public or quasi-governmental agency created to acquire, hold, 

manage, and develop foreclosed, dilapidated, tax delinquent, or abandoned properties for which 

owners cannot be identified for a short-term period (10 years). While these properties, most of 

which are older buildings, are secured, they have a negative impact on the community and convey 

a sense of blight and neglect. Since many of the properties included in land banks are located in 

historic districts or potentially eligible historic districts, they may adversely affect the character 

of the district. Proposals to redevelop neighborhoods often fail to consider these properties as 

it is assumed that the cost for rehabilitation exceeds that for new construction. Therefore, too 

often land banks are not perceived as an effective tool unless the goal is to identify properties for 

demolition and redevelopment.

Some states and localities have created land banks that have a solid mission that promotes reuse and 

rehabilitation. Included in its policy is a commitment to rehabilitate properties and sell them according 

to an approved formula. Another noteworthy provision is the land bank’s ability to hold the title of 

properties for community development corporations or other entities for a specified time period 

while they determine how to reuse the property according to the terms of agreement. 

In December 2013, Philadelphia passed legislation to establish a land bank to manage more than 

40,000 vacant and blighted properties, 30,000 of which are privately owned. A percentage of 

these properties are “storefronts and boarded row houses located along bustling corridors in 

middle-income neighborhoods,” it was reported. However, the goal of the land bank will be to 

consolidate vacant parcels and erase past debts so that they can be sold. The city will require private 

bidders to have an actual plan for the lots or property, which must be approved by the city council 

representative for the neighborhood. This will allow residents to have a voice, and most important, it 

will allow them to comment on the disposition of the lots with the improvements. 

Rehabilitation and reuse of properties embody sustainability principles. Since 2009, the Preservation 

Green Lab, a Seattle-based program of the National Trust for Historic Preservation, has been 

working to strengthen the fabric of communities by leveraging the value of existing buildings to 

reduce resource waste, create jobs, and bolster a strong sense of community. In 2011, it published 

The Greenest Building: Quantifying the Environmental Value of Building Reuse, summarizing research that 

documents that rehabilitating a historic building produces superior results to new construction in 

reducing greenhouse gas emissions over the life cycle of the building. The findings cast serious doubt 

on the wisdom of communities nationwide demolishing a billion square feet of buildings annually. The 

evidence that preservation and rehabilitation of existing buildings is a key component of sustainability 

has been accepted by HUD, EPA, and other federal agencies that have researched this issue. In fact, 
 CHAPTER 2: THE ROLE OF HISTORIC PRESERVATION TOOLS IN RIGHTSIZING | 17

Despite the 

compelling evidence 

that preservation and 

rehabilitation offer 

substantial community 

benefits, local 

government officials 

often see historic 

preservation as an 

impediment to reducing 

blight and preparing 

areas for revitalization.

most states have established sustainability programs that acknowledge the benefits of preservation 

and reuse of older buildings. A disconnect exists, however, in whether states and local governments 

want to integrate sustainability principles in their policies and principles. As hundreds of millions of 

dollars are allocated for demolition, rarely are state or local agencies invoking sustainability principles 

to divert resources into rehabilitation or even the reuse of materials from historic properties. 

TAX ACT

Despite the compelling evidence that preservation and rehabilitation offer substantial community 

benefits, local government officials often see historic preservation as an impediment to reducing blight 

and preparing areas for revitalization. While local officials have indicated they must overcome a number 

of challenges, including financing, code compliance, and lead abatement, they do not acknowledge that 

historic preservation tools such as rehabilitation techniques and financial incentives can often address 

these challenges. Combining federal historic rehabilitation tax credits (for income-producing properties) 

or state historic rehabilitation tax credits (which may include residential properties) with other creative 

financing sources, as well as using a developer who knows how to build upon the property’s historic 

characteristics, can lead to the successful, sustainable reuse of a building or a cluster of buildings.

Based on the research conducted by the Task Force, it is clear that tax incentives at all levels (federal, 

state, and local) are strong inducements for integrating historic preservation into rightsizing response 

efforts. Principal among these is the Federal Historic Preservation Tax Incentive of a 20 percent credit 

for the rehabilitation of historic properties used for the production of income-commercial and industrial 

buildings, hotels, apartment buildings, residential rentals, and the like. The projects are subject to professional 

reviews by SHPOs and the NPS to ensure that the outcome is good preservation. A 2013 report by the 

Secretary of the Interior acknowledged that since 1976 the Federal Historic Preservation Tax Program had 

generated 2.4 million jobs and $66 billion in private investment in the rehabilitation of historic buildings. It 

further noted that the program promotes community development and economic success in addition to 

New Jersey’s iconic Newark Symphony Hall, a National 

Register-listed property since 1977, has been preserved 

and continues to be a focal point in the area just south 

of Downtown known as The Coast.
18 | RIGHTSIZING TASK FORCE REPORT

It is clear that tax 

incentives at all levels 

(federal, state, and local) 

are strong inducements 

for integrating 

historic preservation 

into rightsizing 

response efforts. 

historic preservation, and that it is a strong and effective tool for cities leveraging existing assets. An earlier 

2011 NPS report on the program included the following overview about its successes:

“The incentives have been instrumental in preserving the historic places that gave cities and towns and 

rural areas their special character, and have attracted private investments to historic cores of cities 

and towns. The tax incentives also generate jobs, enhance property values, create affordable housing, 

and augment revenues for federal, state, and local governments. Through this program, abandoned and 

underutilized schools, warehouses, factories, churches, retail stores, apartments, hotels, houses, and offices 

throughout the country have been restored to life in a manner that retains their historic character.” 

Projects using federal rehabilitation tax incentives primarily involve historic commercial buildings that are 

often easier to list on the National Register of Historic Places because they are iconic and are important 

to the history of a community. Tax credit reviews customarily address issues regarding treatment of 

materials and significant features and focus on funding, design, and linkages to other projects. Quite 

often the resulting project becomes the centerpiece of a local renewal effort, restoring a cherished local 

landmark to its original place as an object of local pride and community identity.

Complementing the federal incentives are state and local tax credit programs that can be used 

for owner-occupied residential properties, which have arguably suffered the most from vacancy 

and abandonment. As of 2014, 31 states have established a State Historic Preservation Tax Credit 

Program, emulating the federal model by providing credits against an investor’s state income tax 

obligation. Like those qualifying for the federal incentives, the historic properties eligible for these 

programs must be certified as listed in the National Register or are contributing resources in a 

National Register or local historic district. The state programs obviously will continue to play an 

integral role in preserving historic neighborhoods.

States with homeowner rehabilitation tax programs have been able to support local development 

and attract new residents. Local officials can encourage revitalized residential areas around a National 

Register district or Main Street area that is used for commercial purposes, thereby attracting federal 

tax credit projects. Such efforts are doubly successful, since they have the benefit of incorporating 

historic preservation into areas that are inherently sustainable, aesthetically appealing, and close to 

amenities, factors for many single residents and empty nesters that are choosing to relocate to cities.

Kentucky Showcases Investment in Historic Preservation

The Kentucky State Historic Preservation Officer indicated in the Lane Report in August 2013 that since 

2005, projects utilizing both the state and Federal Historic Rehabilitation Tax Credits have resulted in total 

public and private investment of $253 million in historic preservation across the state. This includes 425 

completed residential and commercial projects, with average private investment of $595,184 per project, 

facilitated by a state tax credit averaging $44,801 and federal credit averaging $193,121 per project. In 

2013, all commercial and residential rehabilitation projects using the state tax credits alone are poised 

to generate nearly $79 million of estimated investment in 113 projects in 31 counties. Individual project 

budgets range from $23,000 to $7.5 million, while tax credit allocations range from nearly $2,300 to just 

under $200,000 per project.

The exclusion of private owner-occupied properties from the federal tax incentive program has 

long been a major concern within the preservation community. Although preservationists have 

lobbied for years to get a federal residential tax credit, such legislation has not been enacted. The 
 CHAPTER 2: THE ROLE OF HISTORIC PRESERVATION TOOLS IN RIGHTSIZING | 19

The former Pennsylvania Railroad Depot in Richmond, IN, fell into disrepair, but because of its importance to the community, local citizens secured funds for its rehabilitation. 

preservation community continues to pursue legislation that it believes is desperately needed 

as local governments approve large-scale demolition in distressed communities. Legislation such 

as the currently pending historic homeowners tax credit has been repeatedly introduced in the 

Congress to extend tax credits to this larger pool, with provisions that tailor the benefits to the 

kind of housing for low- and moderate-income residents that is so commonly found in distressed 

communities. Enactment of such legislation, which has been endorsed by the ACHP, could be a 

major incentive to stabilizing rightsizing neighborhoods.

Another concern expressed about the tax credits is the lack of flexibility in applying the Secretary 

of the Interior’s Standards for Rehabilitation, which must be met to receive the tax credits. The 

Standards are broad guidelines that outline the recommended approaches for the restoration, 

rehabilitation, and replacement of significant features of historic properties. Given that tax credit 

projects can be rejected when they do not meet the Standards, developers, in particular, are 

concerned that the SHPOs and the NPS are not sufficiently flexible when reviewing project 

designs and treatments. It has been suggested that the Standards should be updated to take into 

consideration new techniques and approaches to design and architectural treatments that protect 

the character of historic properties.

The Secretary of the Interior’s 2013 report on the Federal Historic Preservation Tax Program, while 

acknowledging the effectiveness of the credits as a preservation and economic development tool, 

also concluded that the following improvements could be made to benefit cities: 

» Develop additional guidance to make the Secretary’s Standards for Rehabilitation easier to use for 

interior spaces and new uses;

» Provide greater training opportunities using both webinars and classroom training for state and 

local partners; and

» Partner with the Administration’s Strong Cities, Strong Communities initiative to incorporate the 

use of the federal tax credit program.

These changes may make the current Federal Historic Preservation Tax Incentive more useful for urban 

revitalization. However, until the tax incentives are expanded to cover not only income-producing 

properties but owner-occupied houses, thousands of historic residences will continue to fall outside the 

purview of this program that has demonstrated such success in turning vacant and underused historic 

structures into valuable community assets.

CREDIT: PALLADIUM-ITEM

The exclusion of 

private owner-occupied 

properties from the 

federal tax incentive 

program has long 

been a major concern 

within the preservation 

community.
20 | RIGHTSIZING TASK FORCE REPORT

 To date, there are 890 Preserve America 

Communities; many of them are located in 

legacy cities. 

Residents and local officials are most familiar with HUD’s CDBG program as a tool for rehabilitation 

and reuse for abandoned properties in communities. Approximately 70 percent of annual funding from 

CDBG goes to entitlement communities, which includes most rightsizing communities. Other federal 

programs fund local rehabilitation efforts but few are well known by state and local officials and the 

private sector. An accessible and detailed list of federal programs could ensure that officials properly 

consider the feasibility of using historic properties when federal funds, grants, or loans were available. 

Currently, www.grants.gov lists available federal funding sources, as well as basic information about 

eligible activities. The ACHP has also developed a list of programs to assist with sustainability projects at 

www.achp.gov/funding.html. Case studies illustrate how historic preservation projects with co-mingled 

resources can make projects cost-effective while still being sensitive to historic preservation principles. 

PRESERVE AMERICA

The Preserve America program is a federal initiative that encourages and supports community 

efforts to preserve and use heritage assets. The goals of the program include a greater shared 

knowledge about the nation’s past, strengthened regional identities and local pride, increased local 

participation in preserving the country’s cultural and natural heritage assets, and support for the 

economic vitality of our communities. A major component of this program is the designation of 

Preserve America Communities, which recognizes communities and neighborhoods that use heritage 

resources for economic development and community revitalization and encourages people to 

experience and appreciate local historic resources through education and heritage tourism programs. 

To date, there are 890 Preserve America Communities; many of them are located in legacy cities. 

As part of the Preserve America Summit, a meeting of preservationists, government officials, and 

stakeholders convened in 2006 to chart a path for the future of the historic preservation program, 

participants acknowledged the importance of communities embracing historic properties as critical 

assets that can generate revenues through heritage tourism. In that regard, these same assets can 

be an important component of any city’s efforts to revitalize neighborhoods. The national network 

of these Preserve America Communities offers opportunities for sharing community strategies for 
 CHAPTER 2: THE ROLE OF HISTORIC PRESERVATION TOOLS IN RIGHTSIZING | 21

historic preservation to assist struggling localities, identifying management practices and innovative 

approaches for reusing historic assets to market and stabilize communities. 

FINDING: Historic preservation offers a variety of tools and strategies that have proven useful over 

time in addressing issues of urban change and redevelopment.

FINDING: Historic preservation needs to be better integrated with local plans and economic 

development strategies in cities addressing rightsizing.

FINDING: Local governments need assistance from state and federal agencies, as well as 

organizations such as the APA and the National Trust, to provide guidance on the use of preservation 

as an economic and community development tool.

FINDING: Tax incentives, in particular the Federal Historic Preservation Tax Incentives Program, 

offer the greatest public financial stimulus to the redevelopment of historic properties and are 

invaluable tools that need to be broadened in their reach to realize their full potential to address 

rightsizing challenges.

GOAL: To make historic preservation tools available to local governments, investors and developers, 

and residents as they develop and implement strategies that will stabilize and revitalize legacy cities.

RECOMMENDATION: The NPS should collaborate with the National Trust, the ACHP, HUD, and 

SHPOs to determine how to best emphasize the value of the Federal Historic Rehabilitation Tax 

Incentive Program to legacy cities. 

RECOMMENDATION: The Administration should support expansion of the current Federal Historic 

Rehabilitation Tax Incentive Program to apply to owner-occupied structures, with special emphasis on 

low- and moderate-income owners.

RECOMMENDATION: The National Trust, preservation partners, and organizations like APA and 

the Urban Land Institute, should explore new approaches and the adoption of best practices that 

incorporate preservation principles into general planning and zoning development.

RECOMMENDATION: HUD should develop and post on its Web site a consolidated report on federal 

programs available to assist in local planning and historic preservation strategies in legacy cities. 
22 | RIGHTSIZING TASK FORCE REPORT

Understanding 

the successes and 

limitations of these 

programs is essential 

to appreciating current 

challenges to developing 

comprehensive urban 

public policies and 

practices to manage 

growth and coordinate 

redevelopment efforts in 

legacy cities.

III. Federal Programs and Policies 

Related to Rightsizing

Federal urban public policies related to rightsizing date to the urban renewal program in the 1950s, 

a time when the federal government made an effort to remove dilapidated low- and moderateincome housing from urban areas to eliminate blight and develop cleared tracts for planned 

redevelopment projects. The effects of urban renewal were often destructive and divisive, removing 

residents to outlying areas without creating linkages to their community. Since the inception 

of the urban renewal program, subsequent federal policies to address vacant, deteriorated 

housing, and stabilization and new construction were designed to be more inclusive, reflect 

broader community goals, and improve the quality of life for diverse residents. Understanding 

the successes and limitations of these programs is essential to appreciating current challenges to 

developing comprehensive urban public policies and practices to manage growth and coordinate 

redevelopment efforts in legacy cities. 

The Model Cities Program was created in 1966 as part of the War on Poverty. It was an ambitious 

program that ended in 1974; during that time, 150 communities received approximately $3 

billion. The goal of the Model Cities Program was to improve the coordination of existing urban 

programs, such as urban renewal. Several legacy cities received funding from the Model Cities 

Program, such as Detroit, St. Louis, Minneapolis, New Orleans, and Newark. Under this program, 

local governments had to develop comprehensive plans that included rehabilitation as well as new 

construction; facilitate citizen participation; deliver social services to targeted areas; and improve 

local police protection. An example of a Model Cities project that involved historic properties is in 

New Haven, Connecticut. The Wooster Square Project redeveloped New Haven’s Italian American 

neighborhood that was cleared as part of the construction of Interstate 91. Due in large measure 

to the Model Cities funds, the project was instrumental in preserving and rehabilitating a number 

of historic buildings for use by the residents.

This program was not universally viewed as a success as it was inadequate to address the impacts 

of the race riots which occurred between 1966 and 1969 in many legacy cities, resulting in 

white flight, blight, and increased suburbanization. As the nation’s leadership changed in 1969, the 

urban public policies shifted and the priorities of the War on Poverty diminished as other urban 

issues became more pressing. Further, there was extensive conflict within Congress regarding 

the selection of Model Cities and the long-term benefits of implementing plans that no longer 

responded to community needs. As a result of the program’s perceived failure, there was a shift 

in urban policies to focus on bricks and mortar projects rather than redevelopment that was 

integrally linked to social services. 

Following the urban renewal and Model Cities Program, in 1978 HUD created the Urban 

Development Action Grant program (UDAG), which awarded $4.6 billion to assist more than 

3,000 economic development projects in center cities across the country during its 12 years 

in existence. This program received mixed reviews that were not always favorable among 

preservationists. UDAG was intended to complete urban renewal projects that were aborted due 

to economic changes in the nation. This program was predicated on public-private partnerships 

in which the local government played a major role in assembling parcels for redevelopment. 
 CHAPTER 3: FEDERAL PROGRAMS AND POLICIES RELATED TO RIGHTSIZING | 23

Holistic planning for UDAG projects was sometimes lacking, resulting in improperly sited projects 

that needlessly demolished historic properties and whole swaths of other buildings without firm 

financing or approvals for redevelopment projects. 

The HOPE VI Program, established in the 1990s, was another urban program administered 

by HUD. It was focused on reducing the concentration of poverty resulting from decades of 

mismanagement and little maintenance by replacing obsolete public housing developments with 

mixed-income housing. By promoting mixed-income development, the program attempted to 

create viable urban neighborhoods where public housing once existed. Although the HOPE VI 

Program was administered on a competitive basis, many neighborhoods subject to rightsizing 

benefited from the program, and some legacy cities actually received funding for multiple projects 

selected by HUD. HOPE VI Projects were often coupled with federal and state Low Income 

Housing Tax Credits, which helped to augment HOPE VI funding with tax credit equity necessary 

to develop the replacement housing required for public housing residents, as well as affordable 

housing for low- and moderate-income residents. Unfortunately, as discussed in the 2004 

report “A Decade of HOPE VI: Research Findings and Policy Challenges,” HOPE VI placed a 

disproportionate emphasis on demolition, and some communities were uprooted and scattered. 

In some cases, the demolished public housing projects, designed and built to high standards, 

were recognized as being of National Register quality. Examples of major HOPE VI projects that 

transformed distressed developments include Techwood in Atlanta, Georgia; Allen Parkway Village 

in Houston, Texas; Richard Allen Homes in Philadelphia, Pennsylvania; and LeMoyne Gardens in 

Memphis, Tennessee. 

Other federal programs that were often combined with HOPE VI include the CDBG and Home 

Investment Ownership Program (HOME) programs. HOME was the largest federal block grant 

program to states and local governments designed to create affordable housing for low-income 

residents. HOME funds are often used for developing scattered site housing associated with HOPE 

VI Projects. The federal policies for communities varied depending on the Administration, its priorities, 

and urban policies. In the 1990s, HUD and the Economic Development Administration (EDA) 

St. Louis has been the 

recipient of numerous 

federal grants which it has 

used to stabilize formerly 

distressed neighborhoods.

CREDIT: TONY MEYERS, CITY OF ST. LOUIS
24 | RIGHTSIZING TASK FORCE REPORT

participated in a program viewed as transformative for revitalizing regional areas. The Empowerment 

Zone (EZ)/Enterprise Communities (EC) Program was established to revitalize impoverished urban 

and rural communities respectively. The EZ/EC Program was designed to encourage comprehensive 

planning and investment aimed at the economic, physical, and social development of the neediest 

urban and rural areas in the nation. Under the initial 1994 round of funding, 71 urban sites received 

EZ/EC designation. The major share of the federal funding went to the six sites designated as 

Empowerment Zones, and the remaining funds went to Enterprise Communities. Although 

considerable latitude was given to local decision makers regarding the selection of specific strategies 

and activities to pursue, each funded community’s efforts at Enterprise Zone transformation were 

expected to reflect four key principles: 

» Economic opportunity 

» Community-based partnerships 

» Sustainable community development, and 

» A strategic vision for change. 

There have been multiple EZ/EC rounds since 1994. By 2006, $1 billion had been appropriated 

in federal grant funding. Grant recipients spent funds on community development projects, 

economic development opportunities, job training, and loan programs. In addition, tax incentives 

were available in the EZ/EC communities, supporting the program goal of leveraging federal 

funds with other non-governmental resources. While historic preservation was a component 

of redevelopment strategies in EZ/EC, the program preserved more downtown commercial 

properties than residences in distressed historic districts. HUD suspended funding for this 

program in 2009.

In 2009, the ARRA provided massive amounts of funding to various federal assistance agencies and 

their grantees to create new jobs and retain existing ones, stimulate economic activity, and invest 

in long-term redevelopment. The majority of ARRA funding was used for salaries and equipment 

in local communities that had dwindling budgets. Remaining funds in the $787 billion appropriation 

were used for so-called “shovel-ready” projects. These are bricks and mortar projects focused on 

activities that would improve infrastructure; expand property acquisition; stabilize neighborhoods 

through the demolition of blighted housing; expand local weatherization programs; increase access 

to residential mortgage relief programs; promote urban agriculture; and support local business 

development and retention. Based on the data in www.recovery.gov, states that included large 

numbers of legacy cities were recipients of approximately $13.6 billion in HUD funding. Although 

substantial amounts of funding were used to eliminate blight, considerable funding supported 

historic preservation activities such as rehabilitation, land banking, and infill new construction. 

The funding for states with large numbers of rightsizing communities included: Ohio $549 million; 

Michigan $487 million; New York $545 million; New Jersey $322 million; Pennsylvania $420 million; 

and Indiana $158 million. Despite this unprecedented level of assistance from federal agencies, 

ARRA proved inadequate to abate the unprecedented level of poverty, increased vacancies, 

unemployment, and shuttering of businesses.

On a more modest scale and more specifically targeted, the Administration created the SC2 

Program in 2011. The program was designed to assist distressed cities and regions such as those 

selected in the first round (Detroit, Michigan; Memphis, Tennessee; New Orleans, Louisiana; Chester, 

Pennsylvania; Fresno, California; and Cleveland-Youngstown, Ohio). All of these communities 

had lost their economic drivers during the past four decades, and were in need of federal, state, 

and local resources to help identify innovative strategies to accomplish more with less. The SC2 

initiative consists of four components:
 CHAPTER 3: FEDERAL PROGRAMS AND POLICIES RELATED TO RIGHTSIZING | 25

1. Community Solutions Teams (CSTs), comprised of federal employees from a variety of 

agencies to assist cities directly in coordinating multiple sources of federal funding;

2. A Fellowship Program, supporting mid-career professionals serving multi-year terms in local 

government positions to provide additional capacity in cities;

3. An Economic Planning Challenge, assisting cities in developing comprehensive economic and 

land use plans; and

4. The National Resource Network, providing cities and regions with access to national experts 

for technical assistance and implementation support.

CSTs were embedded in select communities to work with mayors and city managers to identify 

their particular challenges and prioritize action areas that would benefit from CST support. 

Through federal technical assistance and capacity building, the use of Program Fellows, and publicprivate partnerships, the first seven cities were able to successfully identify revitalization priorities, 

coordinate federal reviews, and highlight best management practices. 

Following the deployment of the CSTs, Executive Order 13602 was issued, which established a White 

House Council for SC2. The high-level placement of the Council within the Administration provides 

a vehicle for senior policy makers to shape government responses to the challenges facing distressed 

urban communities. Since future urban policies are likely to be informed by the work of the Council 

for SC2, it is this organization that should adopt and promote the historic preservation ethic 

important in distressed communities and regions around the nation. More importantly, the nexus 

between historic preservation and sustainability should be highlighted so that existing tools in the 

federal historic preservation program could be effectively used in the work of the Council for SC2.

Historic preservation and sustainability are viewed by many federal, state, and local governments 

as complimentary concepts. In fact, many local governments recognize that the improvement 

of existing built assets, including historic and older buildings, is foundational to developing green 

places, livable communities, and healthier neighborhoods. The renovation of historic properties 

can be the anchor of a redevelopment project that proposes to preserve the city’s heritage, 

culture, sense of place, and investment in existing infrastructure. Sustainability promotes the 

repurposing of older, vacant buildings to minimize the need for new construction and its impact 

on the environment. Further, by reusing buildings, the waste associated with demolition is 

avoided and reinvestment in existing neighborhoods becomes a priority. The DOT, HUD, and 

the EPA developed a Partnership for Sustainable Communities (Partnership) in 2009 to assist 

communities with news, research, and best management practices on innovative sustainability 

activities. Cities confronting rightsizing can access the Partnership’s technical assistance for 

planning, redevelopment, and economic development to explore options that preserve, rather 

than demolish, historic properties in urban and rural communities. 

The federal government’s commitment to urban communities in recent decades is evident by 

the variety of strategies devised and the level of funding committed. However, the funding has 

not always been provided after adequate consideration of its relation to local comprehensive 

plans or how funds could be leveraged to achieve broader redevelopment goals. One of the 

primary reasons to implement a coordinated approach to local redevelopment is to most 

effectively use the full range of available federal programs. For instance, formula grants, such as 

CDBG and HOME are distributed to states or entitlement communities based on population 

and a consolidated plan. These funds follow strict guidelines with sub-grantees limited in the 

type of activities they propose. Conversely, competitive federal grant programs, such as the 

Homeless Assistance Program and Continuum of Care Program that are tied to annual funding 

appropriations, allow for more innovative projects developed by a diverse group of applicants. 

Historic preservation 

and sustainability 

are viewed by many 

federal, state, and 

local governments 

as complimentary 

concepts.
26 | RIGHTSIZING TASK FORCE REPORT

The lack of creativity 

in using federal funds 

could be attributed 

to limited technical 

assistance and an 

absence of best 

practice guidance 

to help state and local 

officials explore 

other alternatives.

Developing a comprehensive local redevelopment strategy based on an understanding of 

the particular requirements of these various programs can ensure that they all contribute 

to advancing a unified vision of a community’s future. Just as important is having access to a 

comprehensive list and explanation of federal assistance programs and available federal resources. 

The following overview is intended to provide potential avenues for communities to explore 

available funding for redevelopment efforts in legacy cities. 

FEDERAL ASSISTANCE, LOANS, AND GRANTS FOR 

RIGHTSIZING ACTIVITIES

Over the years, many cities have used local funds to make significant investments in infrastructure 

and aid residents during transitional periods. Federal resources are used to augment, not replace, 

local redevelopment efforts. However, for many legacy cities, limited local resources have increased 

the urgency of identifying federal programs to help implement redevelopment activities. There are 

hundreds of federal programs available to provide loans and grants to states and local communities. 

Many of these programs are not known by local governments due to limited outreach efforts 

by federal agencies regarding the availability of appropriations and an explanation of qualifying 

requirements. Several HUD programs like HOPE VI have had success; however, Congress has not 

funded this program since Fiscal Year 2010. As such, local governments and potential applicants 

need to actively research all funding availability and qualifying criteria when seeking federal financial 

assistance, loans, and grants. 

PlaceEconomics noted in the “Historic Preservation and Rightsizing” report that “out of 25 

federal programs that could be used for reclaiming vacant property, only five seem to be used 

for rightsizing, and of those, most of the funds were used for demolition.” The lack of creativity 

in using federal funds could be attributed to limited technical assistance and an absence of best 

practice guidance to help state and local officials explore other alternatives. The development 

of a toolkit for local governments that explains the nexus between federal programs and the 

preservation and protection of historic properties would be an invaluable tool for local officials 

as well as grassroots organizations that may not have extensive knowledge of the possible 

federal resources available for stabilizing neighborhoods.

While the full range of federal programs can be found on www.grants.gov, this report 

examines those programs that should be most helpful to rightsizing communities, foundations, 

institutions, and banks that seek resources including financial assistance, loans, grants, technical 

assistance, and best management practices to support redevelopment and economic 

development projects. 

The street cars of New 

Orleans are both historic 

and support sustainable 

practices by encouraging 

mass transportation.

CREDIT: NEW ORLEANS CONVENTION & VISITORS BUREAU 
 CHAPTER 3: FEDERAL PROGRAMS AND POLICIES RELATED TO RIGHTSIZING | 27

Housing and Urban Development Programs 

HUD’s mission is to create strong, sustainable, inclusive communities and quality affordable homes for 

all. HUD is working to strengthen the housing market to bolster the economy and protect consumers; 

meet the need for quality, affordable rental homes; utilize housing as a platform for improving quality of 

life; and build inclusive and sustainable communities free from discrimination. HUD programs that are 

most useful for affordable housing, redevelopment, and economic development include the following:

» Community Development Block Grants (CDBG)

» HOME Investment Partnership Programs

» HOPE VI

» Neighborhood Stabilization Program Grants (NSP)

» Federal Housing Administration (FHA)

» Choice Neighborhood Initiative

» Public Assistance Housing and Section 8

» Rental Housing for the Elderly

» Single Room Occupancy

» Healthy Homes and Lead Hazard Control

» Mortgage Insurance for Healthcare

In addition, HUD funds diverse planning programs used by local governments and housing authorities 

such as: 

» Sustainable Communities Regional Planning Grant Program

» HUD-DOT Community Challenge Grants

» Choice Neighborhood Planning Grants

Information on HUD programs can be found at http://portal.hud.gov/hudportal/HUD?src=/topics/grants.

Department of Transportation Programs

The DOT mission is to provide a fast, safe, efficient, accessible, and convenient transportation system that 

meets national interests and enhances the quality of life of the American people, today and into the future. 

DOT projects include highway, transit, and intermodal activities as well as neighborhood improvements. 

» FHWA Innovative Program Delivery

» New Starts (FTA)

» TIGER Grants

» Metropolitan Planning

» Congestion Mitigation and Air Quality Improvement Program

» National Highway Performance Program

» Highway Safety Improvement Program

» Livability Initiative

» Economic Development Planning

» Transportation Asset Management Program

Information on DOT programs can be found at www.dot.gov/grants.
28 | RIGHTSIZING TASK FORCE REPORT

Environmental Protection Agency Programs

EPA’s mission is to protect human health and the environment. Nearly half of its budget provides 

grants to state environmental agencies, non-profit organizations, educational institutions, and others 

to support the EPA mission of a clean, safe environment. These programs can assist legacy cities to 

remediate environmental concerns at industrial sites so that they can be used as infrastructure to 

support and facilitate redevelopment activities.

» Areawide Planning Program

» Assessment Grants

» Revolving Loan Fund Grants

» Cleanup Grants

» Environmental Workforce Development and Job Training Grants

» Multi-Purpose Pilot Grants

» Training, Research, and Technical Assistance Grants

» Targeted Brownfields Assessments

» State and Tribal Response Programs

» Sustainability Pilots

Information on EPA programs can be found at http://www2.epa.gov/home/grants-and-otherfunding-opportunities. 

Economic Development Administration Grants 

The EDA helps states, regions, and local communities minimize poverty and increase economic 

opportunities by promoting a favorable business environment to attract private capital investment 

and higher-skill, higher wage jobs through capacity building, planning, infrastructure, research, and 

strategic initiatives. 

» Public Works

» Economic Adjustment

» Partnership Planning

» University Centers

» Research and National Technical Assistance

» Local Technical Assistance

Information on these programs is available at http://www.eda.gov/programs.htm

Information on EDA grants can be found at www.eda.gov/ffo.htm.

Department of the Interior Programs

The Department of the Interior protects America’s natural resources and heritage, honors our 

cultures and tribal communities, and supplies the energy to power our future. DOI’s programs 

supplement local funding to preserve and stabilize local historic properties that help to distinguish 

heritage and culture.

» Save America’s Treasures

» Preserve America Grants
 CHAPTER 3: FEDERAL PROGRAMS AND POLICIES RELATED TO RIGHTSIZING | 29

» Land and Water Conservation Fund

» SHPO Historic Preservation Fund Grants

» Tribal Historic Preservation Office Grants

» Historically Black Colleges and Universities Grants

» Hurricane Disaster Relief Grants

Information on DOI programs can be found at www.doi.gov.

National Endowment for the Arts (NEA) Programs

The NEA supports artistic excellence, creativity, and innovation for the benefit of individuals 

and communities. The NEA extends its work through partnerships with state arts agencies, local 

leaders, other federal agencies, and the philanthropic sector. In recent years, NEA has been a major 

participant in enhancing local redevelopment activities that support public art.

» Challenge America Fast-Track

» Our Town Grant Program

» Art Works Grant Program

Information on NEA programs can be found at www.nea.gov/grants.

Health and Human Services (HHS) Programs

HHS is the principal federal agency for protecting the health of all Americans and providing essential 

human services, especially for those who are least able to help themselves. In recent years, HHS 

agencies such as the Centers for Disease Control and Prevention have played a pivotal role in 

creating healthy communities that promote livability. 

» Service Area Competition

» Social Services Block Grants

» Head Start Program

» Community Economic Development Program

» Center for Faith-based and Neighborhood Partnerships

» Centers for Disease Control

» Community Services Block Grant

Information on HHS programs can be found at www.hhs.gov/grants/index.html.

Department of Labor (DOL) Programs

The DOL fosters, promotes, and develops the welfare of the wage earners, job seekers, and retirees 

of the United States; improves working conditions; advances opportunities for profitable employment; 

and assures work-related benefits and rights. DOL works closely with local governments to ensure 

that they create pools of labor to support new and expanded business opportunities. 

» Job Corps (125 centers around the nation)

» Office of Recovery for Auto Communities and Workers

Information on DOL programs can be found at www.dol.gov/dol/grants.
30 | RIGHTSIZING TASK FORCE REPORT

Department of the Treasury Programs

The Department of the Treasury’s primary role is to maintain a strong economy and create 

economic and job opportunities by promoting the conditions that enable economic growth and 

stability at home and abroad. It manages a variety of programs which may impact historic properties 

but may not be considered federal undertakings subject to Section 106 when researched by Treasury 

due to the agency’s limited authority.

» The Hardest Hit Fund (HHF) is a program created by the Troubled Asset Relief Program (TARP), 

and is meant to provide targeted aid to 18 states and the District of Columbia for families most 

affected by the economic and housing downturn. This program also includes blight elimination.

» The Low Income Housing Tax Credit (LIHTC) is administered by state housing finance agencies, 

with oversight and technical assistance from HUD and the Internal Revenue Service. 

» The U.S. Treasury Community Development Financial Institutions Fund promotes economic 

revitalization and community development through investment in and assistance to financial institutions.

» The Federal Historic Preservation Tax Incentives program encourages private sector investment 

in the rehabilitation and reuse of historic buildings. The NPS and the Internal Revenue Service

administer the program in partnership with SHPOs. 

Federal Reserve System Program

The Federal Reserve, which has 12 separate banks across the country, oversees the nation’s 

monetary policy. It influences the monetary and credit conditions in the economy in pursuit of 

maximum employment, stable prices, and moderate long-term interest rates.

» The Community Affairs Program 

Information on Federal Reserve System programs can be found at www.federalreserve.gov/

communityaffairs/national/.

U.S. Department of Agriculture Programs

The USDA works to expand economic opportunities in rural America by promoting agriculture 

production, feeding state residents, preserving and conserving our nation’s natural resources, restoring 

forests, and improving watersheds and privately owned lands. 

» Community Facilities Grants and Loans

» Farmers Market Promotion Program

» Community Food Projects Competitive Grants Program

» Urban and Community Forestry Grants

Information on USDA programs can be found at www.usda.gov/wps/portal/usda/

usdahome?navid=GRANTS_LOANS).

Small Business Administration (SBA) Programs

The SBA recognizes that small business is critical to the nation’s economic recovery and strength and 

to building America’s future. It provides loans and offers technical assistance to qualified enterprises 

that support the local economy.

» CDC/504 for major assets (i.e., real estate or equipment) 

» General small business loans

Information on SBA programs can be found at www.sba.gov/category/navigation-structure/loans-grants.
 CHAPTER 3: FEDERAL PROGRAMS AND POLICIES RELATED TO RIGHTSIZING | 31

Partnership for Sustainable Communities 

The Partnership for Sustainable Communities provides information, news, research, and advocacy 

tools to assist communities with urban planning, land use, zoning, and development policies and 

practices that encourage locally and environmentally efficient development. The partnership agencies 

include HUD, DOT, and EPA. Livability principles are to: 

1. provide more transportation choices;

Develop safe, reliable, and economical transportation choices to decrease household 

transportation costs, reduce our nation’s dependence on foreign oil, improve air quality, 

reduce greenhouse gas emissions, and promote public health. 

2. promote equitable, affordable housing; 

Expand location- and energy-efficient housing choices for people of all ages, incomes, 

races, and ethnicities to increase mobility and lower the combined cost of housing and 

transportation. 

3. enhance economic competitiveness; 

Improve economic competitiveness through reliable and timely access to employment centers, 

educational opportunities, services and other basic needs by workers, as well as expanded 

business access to markets. 

4. support existing communities;

Target federal funding toward existing communities—through strategies like transit-oriented, 

mixed-use development and land recycling—to increase community revitalization and the 

efficiency of public works investments and safeguard rural landscapes. 

5. coordinate and leverage federal policies and investment; 

Align federal policies and funding to remove barriers to collaboration, leverage funding, and 

increase the accountability and effectiveness of all levels of government to plan for future 

growth, including making smart energy choices such as locally generated renewable energy. 

6. value communities and neighborhoods;

Enhance the unique characteristics of all communities by investing in healthy, safe, and walkable 

neighborhoods—rural, urban, or suburban. 

Information on the Partnership can be found at http://www.sustainablecommunities.gov

Alabama’s Multi-Agency Projects

A redevelopment project that illustrates a collaborative effort that used federal grants was the Selma to 

Montgomery National Historic Trail in Montgomery, Alabama. HUD’s CDBG funds were used in the city 

of Montgomery for streetscape improvements, affordable housing, and repairs to the historic Mount Zion 

Church associated with the National Historic Trail. In addition, the Department of Labor Job Corps and 

the city trained young adults on green building techniques so they would be able to get employment in 

the private sector building community gardens and renovating homes in the Peacock neighborhood. The 

Department of Energy’s Weatherization Program funds were used in the revitalization of houses, and 

EPA provided technical assistance to help the city rehabilitate a part of the trail under the interstates. 

The partnership epitomizes the type of work that rightsizing communities need to have available to 

reinvigorate local planning. Moreover, it illustrates that when local officials develop their plans and visions 

with the community, federal resources can be targeted on implementation and serve as a catalyst for 

future economic development activities.

This project was recognized in the Partnership for Sustainable Communities’ three year report available 

at http://www.sustainablecommunities.gov/pdf/partnership_accomplishments_report_508%20

compliant_final_062112.pdf
32 | RIGHTSIZING TASK FORCE REPORT

Smart Growth

Smart Growth is a sustainable planning approach that emphasizes 10 principles. EPA helps 

communities grow in ways that expand economic opportunity, protect public health and the 

environment, and create and enhance the places that people love. Through research, tools, 

partnerships, case studies, grants, and technical assistance, EPA is helping America’s communities turn 

their visions of the future into reality. The Smart Growth concept is implemented on an interagency 

basis that promotes holistic redevelopment that incorporates the following principles: 

1. Mix land uses;

2. Build well-designed, compact neighborhoods; 

3. Provide a variety of transportation choices; 

4. Create diverse housing opportunities; 

5. Encourage growth in existing communities;

6. Preserve open spaces, natural beauty, and environmentally sensitive areas;

7. Protect and enhance agricultural lands;

8. Utilize smarter, and cheaper infrastructure and green buildings; 

9. Foster a unique neighborhood identity; and

10. Nurture engaged citizens

Information on the Federal Smart Growth Program can be found at http://www.epa.gov/

smartgrowth/partnership/

ACCOMMODATING FEDERAL ASSISTANCE AND HISTORIC 

PRESERVATION: THE SECTION 106 PROCESS

Congress passed the NHPA in 1966 to develop a federal historic preservation program 

in response to widespread public concern about the loss of historic properties due to the 

implementation of federal programs such as the urban renewal program, the interstate highway 

program, and the U.S. Army Corps of Engineers Civil Works program. A key provision was Section 

106, which requires federal agencies to take into account the effects of their undertakings on 

historic properties and afford the ACHP a reasonable opportunity to comment. This has evolved 

into a consultative process involving diverse stakeholders as well as the federal agency. Agencies 

must consider effects on historic properties, defined in the NHPA as districts, sites, buildings, 

structures, and objects included in, or eligible for inclusion in, the National Register of Historic 

Places, which is maintained by the Secretary of the Interior. 

To successfully complete Section 106 review, federal agencies must do the following:

» gather information to decide which properties in the area that may be affected by the project are listed, 

or are eligible for listing, in the National Register of Historic Places (referred to as “historic properties”);

» determine how those historic properties might be affected;

» explore measures to avoid or reduce harm (“adverse effect”) to historic properties; and

» reach agreement with the SHPO/Tribal Historic Preservation Office (and the ACHP in some cases) 

on such measures to resolve any adverse effects or, failing that, obtain advisory comments from the 

ACHP, which are sent to the head of the agency.
 CHAPTER 3: FEDERAL PROGRAMS AND POLICIES RELATED TO RIGHTSIZING | 33

Initiating Section 106 

review early in project 

planning provides a 

number of advantages to 

local governments, but 

such coordination often 

does not take place due 

to a lack of knowledge 

by federal agencies and 

project recipients.

While federal agencies assume responsibility for meeting the requirements of Section 106, an 

exception is made for certain HUD programs such as CDBG, Disaster Recovery Programs, and 

HOME which delegate the responsibility to comply with environmental reviews to state and local 

governments. HUD has included on its Web site information on historic preservation review 

requirements, HUD preservation awards, and case studies: http://www.huduser.org. While applicants 

and grant recipients for other federal programs do not have the same legal obligation, it is crucial that 

they have a good working knowledge of the Section 106 process. Early and inclusive consultation, 

involving both project sponsors and preservation stakeholders, ensures that the Section 106 

review promotes historic preservation principles and helps to develop outcomes that integrate the 

protection of historic properties important to the local community into urban revitalization goals.

Initiating Section 106 review early in project planning provides a number of advantages to local 

governments, but such coordination often does not take place due to a lack of knowledge by 

federal agencies and project recipients regarding the utility of Section 106 as a planning tool. Early 

consultation with SHPOs to identify and to evaluate historic properties makes important information 

available during the consideration of alternative strategies for redeveloping neighborhoods. The 

Section 106 review can be helpful to neighborhoods impacted by rightsizing because it requires 

the development of project alternatives and requires public participation, identifying those historic 

properties that are important to the community. This review process also can spare historic 

properties from demolition that should be viewed as assets in redevelopment schemes. In addition, 

the information gathered during a Section 106 review may expedite related state and federal reviews 

by providing baseline data and analyses, saving time and money. The ACHP has recently issued a 

toolkit for applicants involved in the Section 106 review. It is helpful in explaining the review process 

and clarifying the role of developers, applicants, and other stakeholders. 

Federal programs have frequently been used to assist local governments and non-profit applicants 

such as community development corporations with the implementation of activities that are part of a 

master plan or neighborhood strategy plan for targeted areas. Many of these activities are developed 

with input from residents and grassroots organizations that are unclear about federal programs and 

their missions. Therefore, residents are dependent on local officials when preparing grant applications, 

The ACHP members conduct 

regular business meetings 

and sometimes review 

individual Section 106 cases.
34 | RIGHTSIZING TASK FORCE REPORT

although residents may ultimately be the sub-grantee responsible for administering the project. Since 

grant applications are more likely to be successful when they address all of the relevant federal, 

state, and local policies, historic preservation and environmental reviews are required before funds 

are released. Section 106 is recognized as a planning tool that assists agencies and applicants with 

project planning. Not only does it require that diverse consulting parties participate in project 

planning to consider the effects of the project on historic properties, it also encourages agencies and 

applicants to avoid, minimize, and mitigate adverse effects, when feasible. Many federal agencies that 

are responsible for ensuring that Section 106 is completed are not always knowledgeable about the 

requirements of Section 106 and the creative outcomes that occur during this review. Section 106 is 

required by law and is often helpful to local governments and applicants as it provides an opportunity 

to negotiate better project outcomes. Furthermore, if agencies are to avoid delays in project reviews 

and the release of project funds, they must not only learn about the benefits of Section 106, but also 

ensure that pertinent background information necessary to complete grant applications is submitted 

or prepared by applicants, as appropriate. 

FINDING: There is a wealth of existing federal programs that can support rightsizing in a manner that 

builds on community historic resources, but information about those programs is not readily available 

to local governments and other stakeholders.

FINDING: Non-profit organizations and developers often need help identifying federal grants to fund 

or provide supplemental financing for major redevelopment projects.

FINDING: Section 106 of the NHPA is an important planning process that engages diverse 

stakeholders to inform decision making and limit adverse effects on historic properties. 

FINDING: Early initiation of the Section 106 process facilitates the analysis of alternative 

redevelopment strategies that can integrate historic properties important to the community.

GOAL: To better use federal resources and processes to pursue preservation-based strategies to 

address rightsizing in legacy cities.

RECOMMENDATION: Federal agencies providing assistance to local governments for redevelopment 

activities should ensure that the Section 106 process begins at the earliest stages of planning and 

that local governments coordinate planning and environmental reviews for all federal assistance in a 

comprehensive manner. 

RECOMMENDATION: HUD, in consultation with the ACHP, should educate state and local grant 

administrators for legacy cities regarding effective measures to better consider opportunities to reuse 

historic properties during environmental reviews, including Section 106. 

RECOMMENDATION: The SC2 initiative, working through its member agencies and in collaboration 

with the ACHP, should provide user-friendly guidance for state and local governments and 

stakeholders on federal assistance available when using historic properties in redevelopment projects.

RECOMMENDATION: The ACHP, in consultation with historic preservation partners, should develop 

Web-based guidance that explains the federal historic preservation programs that can address 

rightsizing issues and publicize best practices and innovative strategies. 
 CHAPTER 4: ENHANCED FEDERAL PROGRAM COORDINATION | 35

Federal initiatives 

such as sustainability 

have generated new 

public policies that are 

applicable to rightsizing 

and may offer the 

potential to provide 

much needed guidance 

to local communities.

IV. Enhanced Federal Program 

Coordination

Federal initiatives such as sustainability have generated new public policies that are applicable to 

rightsizing and may offer the potential to provide much needed guidance to local communities. 

A 2009 survey conducted by the Living Cities Collaborative concluded that 80 percent of larger 

cities report that sustainability is among their top five priorities. The similarities between the goals 

of sustainability and historic preservation underscore the essential link between the two. In order 

to demonstrate the Administration’s commitment to sustainability, the Partnership for Sustainable 

Communities was established with the goal of assisting communities by cutting red tape, getting 

the most out of federal resources, and attracting new state, local, and private funding. Legacy cities 

such as Detroit, Cleveland, Flint, Pittsburgh, and St. Louis have received funds from the Partnership 

for demonstration projects that focused on sustainable practices in transportation and housing. 

Local officials have indicated that their communities have benefitted from the Partnership support, 

particularly assistance on how to use holistic and collaborative approaches to build strong publicprivate partnerships. 

Organizations like the Brookings Institution, APA, and Initiative for a Competitive Inner City (ICIC) 

have explored the issue of legacy cities and rightsizing to address the economic, social, and land 

use implications on the future of communities. While the research has been compelling, and the 

recommendations such as approaching local planning from a metropolitan or regional framework 

rather than local are sound, formal action has not been taken to manage rightsizing. Urban public 

policies, regrettably, have lagged behind the needs of legacy cities. Federal initiatives such as 

sustainability have generated new public policies that are applicable to rightsizing and may offer the 

potential to provide much needed guidance to local communities. If local officials are unfamiliar with 

sustainability or smart growth principles, they are likely to be unaware of actions and programs that 

could provide much needed financial and technical assistance.

The federal government has intermittently issued urban public policies related to legacy cities. 

Recently, SC2 has been recognized for improving federal project planning and implementation in 

select cities. Initiatives in which multiple agencies are involved must adhere to principles to ensure 

that programs inform long-term, bottom-up project planning. For instance, HUD programs that 

are designed to develop mixed income neighborhoods must consider HOME requirements for 

affordable housing, DOT livability principles, and EDA planning requirements to have a meaningful 

impact. However, missing from this otherwise laudable equation is a uniform approach to integrating 

historic preservation, both as a strategy and as a planning consideration. When that happens, this may 

result in lost opportunities for sustainable redevelopment and, worse, lost historic properties.

During 2013, the Treasury Department has taken an active role in assisting cities, particularly legacy 

cities, by providing reinvestment funds and extensive research. However, a failure to properly 

integrate historic preservation concerns into the delivery of this assistance bodes ill. The Treasury 

Department recently allocated hundreds of millions of dollars from the Hardest Hit Fund to three 

states (Indiana, Ohio, and Michigan) to assist cities or counties in implementing blight elimination 

activities. Although it is highly probable that these programs will affect historic properties, Treasury 

determined that they were not subject to Section 106 or other environmental review processes, 
36 | RIGHTSIZING TASK FORCE REPORT

A panel discussion for the 

“Rebuilding America’s Legacy 

Cities” book launch by the 

Brookings Institution featured 

leading speakers on rightsizing.

so no formal consideration of historic properties was conducted with preservation authorities or 

local stakeholders prior to the disbursement of funds. Consequently, monitoring the prospective 

demolition of properties will fall to state and local processes, which are inconsistent and unlikely to 

be adequate to ensure that blight removal does not result in the decimation of National Registerlisted and eligible districts. 

The 2013 activities by Treasury with the Hardest Hit Fund would have benefitted from the best 

management practices of programs like the Partnership or SC2. The interagency collaboration in 

these programs could have addressed immediate and long-term goals for legacy cities receiving 

federal funds. In addition, the state and local governments could have identified the type of technical 

assistance and guidance that would help in identifying innovative approaches to repurposing historic 

properties to rebuild neighborhoods. At the 2013 Boston Federal Reserve Conference, Chairman 

Ben Bernanke shared with the audience his observation that, after decades of large-scale, top down 

federal efforts, it has become increasingly apparent that a one-size-fits-all approach did not serve 

local communities well. Most importantly, he indicated that resilient communities require more than 

decent housing; they require an array of amenities that support the social fabric of the community 

residents. This is a message that all federal agencies need to heed.

The Center for Housing Policy in its introduction to the report on “Local Policy Options to 

Support Sustainable and Equitable Development” stated that “local actors are recognizing 

the benefits of targeting infrastructure, housing, and economic development investments in a 

coordinated fashion to location-efficient areas.” This is a timely observation, as the future in 

sustainability efforts is in coordinating resources and allocating them based upon approved local 

and neighborhood plans for target areas. While this is not a new concept, it is one that is not 

always applied in the delivery of federal assistance. Rather than developing a framework that 

ensures local governments properly use federal funds to support redevelopment and revitalization 

activities in targeted areas, most federal assistance and grants are made without any type of 

coordination. While metrics are in place to track overall federal spending by agency, the federal 

government does not track spending by cities or redevelopment activities and often does not 

CREDIT: THE AMERICAN ASSEMBLY COLUMBIA UNIVERSITY
 CHAPTER 4: ENHANCED FEDERAL PROGRAM COORDINATION | 37

In many jurisdictions, 

long-term abandoned 

homes are not eligible 

for land banking.

provide targeted assistance. If metrics were established to monitor annual federal expenditures in 

legacy cities, the federal government might be able to improve the allocation of public resources so 

that funds can be leveraged with private resources. 

Legislation related to metrics for federal resources to cities is the Digital Accountability and 

Transparency Act of 2013 (DATA) introduced in the House of Representatives in November 

2013. This bill, pending in Congress, would require the Treasury Department to maintain the 

Web site already established by the Office of Management and Budget (OMB) in 2006 to 

provide public information about awards of federal funds. When the DATA bill was originally 

introduced in the last Congress, it was endorsed by 113 bi-partisan mayors from around the 

nation who sought reforms to improve reporting and transparency on federal grants. Although 

the reporting proposed in the bill would occur at the federal level, it would be coordinated 

with local governments. The City of Philadelphia, a supporter of the bill, provides an example 

of why the DATA bill would be useful. The city announced in July 2013 that Mayor Michael 

Nutter had signed an executive order establishing the “Mayor’s Office of Grants” to increase 

the city’s capacity and capabilities to compete for federal, state, and philanthropic grants and 

to manage funding with transparency. As a legacy city, Philadelphia has obtained a large number 

of federal grants in the past decades, receiving $1.2 billion in federal and state grants in 2011. 

With a centralized grant process, the Mayor’s Office of Grants anticipated it would “easily apply 

for grants, monitor them, and improve the process.” Other legacy cities would also benefit from 

building capacity to receive resources since redevelopment activities are dependent on publicprivate financing, including Federal Historic Preservation Tax credits. 

In addition to improved coordination of federal assistance, better planning in local governments is 

essential if legacy cities are to be successful in their rightsizing efforts. In Facing the Urban Challenge: 

The Federal Government and America’s Older Distressed Cities, Alan Mallach states “In retrospect, it 

is equally clear that few of the activities pursued by older cities themselves over the past decades 

were based upon a strategic framework designed to lead to a stronger future city.” He continues 

“cities have scattered billions in investments in new housing, new schools, and public facilities, 

without weaving them into larger strategies or targeting them to areas with strong assets for 

future revitalization.” This reference to strong assets brings historic preservation into the analysis, 

recognizing that a framework—which should include historic preservation—is necessary so that 

legacy cities do not take a piecemeal approach toward building new communities. 

An example of where greater coordination among state and local officials and federal agencies 

would offer opportunities for preserving historic properties so that they could contribute to future 

revitalization efforts is land banking. HUD’s NSP programs authorized the use of funds to establish 

and operate land banks for foreclosed residential properties resulting in the creation of numerous 

local, regional, and state governmental organizations. In many jurisdictions, long-term abandoned 

homes are not eligible for land banking. This may limit the ability of legacy cities to use the land 

bank for a certain category of residential properties that would provide the greatest assistance to 

the community. Further, local officials must clarify whether land banking is intended to stimulate 

new development on cleared parcels or use vacant properties to stabilize existing neighborhoods 

and to promote homeownership to eliminate blight. Federal funding can be used only when 

specified criteria are met for the reuse of properties or land. If land banks are to be used to 

expand local affordable housing, strategies could be established to attract developers who could 

use federal and state tax incentives to rehabilitate income-producing rental properties. As it relates 

to rightsizing, land banking can be an effective tool if it is tied to a program with clearly articulated 

mission statements and project goals that include rehabilitation activities as well as demolition and 

new construction on cleared lots. 
38 | RIGHTSIZING TASK FORCE REPORT

INCORPORATING HISTORIC PRESERVATION IN 

FEDERAL INITIATIVES

Historic preservation should be an integral part of federal initiatives like the current SC2 program, 

providing an opportunity for resource agencies like the ACHP and NPS to help shape policy and 

provide technical assistance during program formulation and project planning. To address the ACHP’s 

lack of participation, the Administration needs to recognize the value of historic preservation and 

identify appropriate federal agencies to determine how best to incorporate historic preservation in 

federal programs. With regard to project implementation, SHPOs, CLGs that receive a portion of 

SHPO resources and are authorized to assist them in identifying and evaluating historic properties, 

and local historic preservation commissions can play major roles in local historic preservation 

activities. Unfortunately, new federal initiatives have not included them in local discussions as 

evidenced in the case studies for the first round communities of the SC2. CST’s for each locale 

focused on a topic related to rightsizing communities, such as economic development, job creation, 

or public safety. There is no indication, however, that the teams brought in preservation practitioners 

or gave serious consideration to historic preservation as a tool to achieve program goals. The 

opportunity to demonstrate the value of historic preservation strategies in framing policies and 

creating innovative solutions, in both the target city and as a model for communities addressing 

similar issues, was lost. 

The White House Neighborhood Revitalization Initiative (NRI) is a collaborative established in 2010 

and administered by the White House Office of Urban Affairs dedicated to achieving innovative 

results through federal agency collaboration. The NRI provides technical assistance and grants for 

place-based programs, like HUD’s Choice Neighborhoods Initiative (CNI). CNI supports locally 

driven strategies to address struggling neighborhoods through a comprehensive approach to 

neighborhood transformation. Best practices are shared through an annual report to demonstrate 

how communities have used federal funds and other resources to achieve comprehensive 

Some states and localities have created land banks that have a solid mission that promotes reuse and rehabilitation. For instance, Genesee County, MI’s land bank 

mission is to: “restore value to the community by acquiring, developing and selling vacant and abandoned properties in cooperation with stakeholders who value 

responsible land ownership.” A noteworthy provision is the land bank’s ability to hold the title of properties for community development corporations or other entities 

for a specified time period while they determine how to reuse the property according to the terms of agreement. http://www.thelandbank.org/

CREDIT: GENESEE COUNTY LAND BANK
 CHAPTER 4: ENHANCED FEDERAL PROGRAM COORDINATION | 39

The latest HUD program to assist challenged communities is the 

Choice Neighborhoods Initiative, which supports locally driven strategies 

for neighborhoods that include distressed public or HUD-assisted 

housing, like the Iberville Public Housing Complex in New Orleans, LA.

As experience has ably 

demonstrated, historic 

preservation is a proven 

revitalization strategy 

that, if integrated into 

federal assistance and 

grant programs, can 

promote economic and 

community development.

neighborhood revitalization. While the NRI emphasizes the coordination of federal funds, it also 

provides an opportunity to leverage state and local resources for maximum impact. The NRI’s placebased approach to transforming neighborhoods and communities is designed to be interdisciplinary, 

coordinated, flexible and data- and results-driven. Like the SC2 program, historic preservation is not 

an integral part of CNI, but the potential exists to work with local preservationists to adopt historic 

preservation principles as a means of achieving the program’s goals. 

HISTORIC PRESERVATION IN FEDERAL GRANT PROGRAMS

As experience has ably demonstrated, historic preservation is a proven revitalization strategy that, 

if integrated into federal assistance and grant programs, can promote economic and community 

development. Similarly, historic preservation has been able to preserve the local heritage by 

protecting iconic resources that are important to the local identity. It can help local governments 

engage the public about the importance of the community’s heritage and how redevelopment can 

build on rather than destroy those elements that define its character and culture. The federal Smart 

Growth initiative recognizes this essential truth, which EPA has highlighted on the initiative’s Web site: 

http://www.epa.gov/dced/topics/historic_pres.htm

Smart Growth

The federal Smart Growth initiative has explained its importance on its Web site: “The preservation 

and renovation of historic properties is an important part of a sustainable, smart growth approach. The 

renovation of an historic property is often a starting point and anchor for the redevelopment of a block, 

street, or district. An historic building or district can be a tangible symbol of a community’s interest in 

honoring its heritage, valuing its character and sense of place, getting the most out of prior investments 

in infrastructure and development, and encouraging growth in already-developed areas. Rehabilitating 

historic properties can also be a critical part of promoting energy efficiency by preserving the energy 

already represented by existing buildings (known as “embodied energy”), rather than expending 

additional energy for new construction.”

CREDIT: HUD
40 | RIGHTSIZING TASK FORCE REPORT

Unfortunately, federal grant managers do not have a uniformly high level of knowledge about 

historic preservation. Consequently, when agencies establish qualifying characteristics for funding 

programs, historic preservation is often not considered an important ranking factor in reviewing grant 

applications. Likewise, the federal notices of funding availability published by agencies to announce 

grant opportunities rarely note that historic preservation strategies can be used to meet primary 

program goals such as affordable housing. 

Beyond failing to encourage beneficial uses of federal grants for historic preservation purposes, too 

often funds that are made available cause harm to historic resources. For example, current state 

and local proposals seeking federal funding for blight elimination activities are focused exclusively 

on demolition as they were not developed in public forums or by engaging preservation experts. 

Demolition not only affects the target structure but also has cumulative effects on the viability of 

historic neighborhoods. Similarly, redevelopment projects may change the character of historic 

districts in harmful ways if they do not properly factor in the existing historic environment. 

Integration of historic preservation into the planning and delivery of federal assistance is the clear 

remedy to this situation. The tools are available to do this, at the federal, state, and local level. 

Collaboration, education, and commitment are needed to achieve the desired result.

FINDING: Federal agencies do not regularly collaborate with each other in the delivery of assistance 

to communities, resulting in lost opportunities to use preservation as part of a comprehensive 

redevelopment strategy.

FINDING: Federal policies are inconsistent in their approach to redevelopment, often failing to 

incorporate historic preservation programs. 

FINDING: The Administration’s SC2 initiative can be an effective tool in the development of federal 

public policies and practices that promote interagency coordination and benefit long-term local 

preservation goals. 

FINDING: Federal programs that are targeted to demolition do not always reflect the preferences of 

the residents of the community, especially when they are seeking historic preservation options. 

GOAL: To encourage collaboration among federal agencies, state and local governments, and 

the public so that funding for rightsizing efforts can be channeled in a holistic manner, with due 

consideration of historic preservation issues and opportunities.

RECOMMENDATION: The ACHP should work with SC2 and Promise Zone initiatives to promote 

an understanding of the value of historic preservation strategies among federal agencies and local 

governments involved in planning federally assisted redevelopment efforts and to encourage 

collaboration among them. 

RECOMMENDATION: HUD should work with the Treasury Department to develop metrics to 

effectively monitor the annual expenditure of federal resources in legacy cities. 
 CHAPTER 5: LEVERAGING FEDERAL FUNDS FOR LOCAL PRESERVATION INITIATIVES | 41

V. Leveraging Federal Funds for 

Local Preservation Initiatives 

Former Mayor Mark Mallory of Cincinnati, Ohio, noted during the 2012 conference “Reclaiming 

Vacant Properties” that he was not a “big tear-down fan.” He stated that he “prefers working with 

community-based groups to renovate empty properties and put people back in homes.” He also 

was known to tour all buildings proposed for demolition by local officials to understand the impact 

on communities. Based on the number of large-scale demolition plans proposed by legacy cities in 

recent years, it appears that his thinking is uncommon among city leaders. The standard operating 

procedure is for local officials to take federal funds to demolish properties and create cleared parcels 

for unknown future development. However, creative public-private partnerships led by non-profits, 

and supported by foundations, are trying to persuade local governments to use federal funds to assist 

in recovery and rehabilitation efforts, which can have many positive effects for historic preservation 

and local assets.

Urban homesteading is a practice for addressing blight that has been discussed many times 

throughout the years, and several cities have had success in implementing such a program—most 

notably, Baltimore. Following a failed attempt at an interstate construction in 1973, the city found itself 

as the owner of a large cluster of vacant properties in marginal neighborhoods. To address this issue, 

the city developed the Dollar House Program as a public-private initiative which was implemented 

from 1973 to 1980. People were invited to purchase a home in targeted areas for $1. As the 

properties required a significant amount of renovation and rehabilitation, traditional banks would not 

provide the necessary loans for such efforts, so the city issued bonds and provided low interest loans 

to the new homeowners. The city also eventually used HUD funds to assist with rehabilitation costs 

Baltimore’s Dollar House Program in the 

1970s was an unparalleled success, creating 

long-term revitalization in neighborhoods like 

West Baltimore, Federal Hill, and Otterbein.

CREDIT: WIKIMEDIA COMMONS
42 | RIGHTSIZING TASK FORCE REPORT

and provided technical assistance with design and construction. The earlier rehabilitation program 

was different from many of today’s programs that require homeowners to reside in the property for 

a minimum period of time. The Dollar House Program was considered a success, as it redeveloped 

neighborhoods by people who were invested not just in a property but in the community. Because 

of this program, a large number of urban blocks became successful neighborhoods, and generated 

profits for the city.Although urban homesteading is not currently widely promoted given the massive 

number of foreclosures and their complex financial liabilities, this program may have merit when 

properties acquired by local governments and land banks have clear titles and are not assets of 

banking institutions and mortgage companies. 

An important technique for leveraging federal funds is through partnerships between state or local 

agencies and the private sector. The National Council on Public-Private Partnerships (NCPPP) defines 

a public-private partnership (P3) as a contractual arrangement between public and private sector 

parties, whereby the resources, risks, and rewards of both the public agency and private company 

are combined. Partnerships provide access to capital and improved compliance with government 

regulations. The use of P3s in legacy cities can be a method for local and state agencies to overcome 

challenges in obtaining traditional financing. Finally, P3s can have a “snowball effect,” where one 

successful project leads to other projects being undertaken in the same geographic area with positive 

cumulative impacts. 

P3 historic preservation projects have followed this model for years. Federally funded projects 

are frequently used as “collateral” by communities when seeking private sector funds or financing. 

As community action plans are developed and approved by local officials, the plans strategically 

use the private sector resources. Such partnerships are a promising way for cities experiencing 

economic downturns to provide sustained levels of service despite the need for budget cuts. The 

value of these partnerships is summed up in a 2013 press release from Dave Adkisson, President 

of the Kentucky Chamber of Commerce: “The pressure on public resources is compounded by an 

economy that is still recovering from the recession as well as by unsustainable spending in several 

areas of state government...We believe Kentucky can take an important step... to create a system 

for partnerships that will make the best use of tax dollars to deliver the services Kentuckians need 

and deserve.” 

THE ROLE OF NON-PROFITS AND 

INSTITUTIONS IN RIGHTSIZING 

Useful resources are not limited to those provided by government programs. Because legacy cities 

often have a significant number of historic properties, many downtown areas in smaller cities have 

benefited from the Main Street Program, a non-profit program incorporating historic preservation into 

urban revitalization. Created by the National Trust for Historic Preservation, the program has received 

widespread accolades for its sound business model and its success in renewing downtowns and 

neighborhood commercial areas. This program has assisted approximately 2,000 communities to improve 

their older commercial districts. By adopting the Main Street program, communities have created more 

than 450,000 jobs, and 229,000 historic buildings were rehabilitated during the past 33 years. 

The four-point approach used in the Main Street Program is organization, promotion, design, and 

economic restructuring. This framework can address many of the actions that legacy cities need to 

take to revitalize distressed neighborhoods and capitalize on historic assets. Moreover, the research 

and resources provided by Main Street augment local economic development plans for targeted 

neighborhoods to facilitate the creation of commercial hubs that support housing programs. Main 

Street works closely with chambers of commerce, universities, foundations, and others to support 

By adopting the 

Main Street program, 

communities have created 

more than 450,000 

jobs, and 229,000 

historic buildings were 

rehabilitated during the 

past 33 years. 
 CHAPTER 5: LEVERAGING FEDERAL FUNDS FOR LOCAL PRESERVATION INITIATIVES | 43

reinvestment opportunities in historic areas. Through the program, local planners can learn the 

value of revitalizing legacy cities one historic neighborhood at a time, rather than taking on major 

redevelopment projects which may not provide long-term, lasting economic benefits to the cities. 

An example of an urban Main Street is the “H Street District,” one of the earliest commercial 

corridors within the District of Columbia. The area was substantially impacted during the race 

riots in 1968 and for decades economic development in this distressed area occurred only 

sporadically. Local revitalization efforts focused on automobile traffic traveling through a major 

corridor to the suburbs rather than building on the neighborhood’s proximity to the Capitol and 

the downtown core. Beginning in 2002, the DC Office of Planning led a community-based planning 

The H Street Main Street, established in 2002, 

is an example of an urban Main Street, and 

includes one of the earliest historic commercial 

corridors within the District of Columbia.

This Smethport, PA, streetscape illustrates how a Main Street/Preserve America Community can be used for 

sporting events as well as shopping.

CREDIT: H STREET MAIN STREET
44 | RIGHTSIZING TASK FORCE REPORT

effort to invigorate the 1.5 mile street corridor. The H Street Main Street (HSMS) organization 

was subsequently created to support these planning efforts. HSMS used the National Main Street 

principles in developing its goals for being the non-profit voice of the area, which emphasized 

comprehensive, incremental changes and partnerships with other entities. The resulting strategic 

plan focused on the area’s access to transportation, historic housing stock, and its potential for 

a retail and entertainment district. Over the past decade, the H Street District has re-imagined 

itself into an area with affordable housing, market rate new construction, expanded public 

transportation, and an entertainment corridor. This urban Main Street program was able to 

develop public-private partnerships that helped to create a model for redeveloping a distressed, 

disadvantaged community with historic properties into a livable community. 

Larger established foundations, including the Rockefeller, Ford, Annie Casey, Bank of America, W. 

K. Kellogg, DuPont, Prudential Insurance Company, Kresge, MacArthur, and Citi Foundation, assist 

projects that contribute to neighborhood revitalization, as they have available resources that may 

not have as many restrictions as federal programs. Foundation support can often encourage 

other innovative solutions that can be incorporated into projects which can then utilize federal 

funding. These foundations have an intensive interest in promoting successful, healthy communities. 

Foundations often provide gap financing for projects that may fall short of federal or state match 

requirements. Non-profit and grassroots organizations generally have a degree of familiarity and 

comfort with large foundations, as foundation staff spend considerable time in the community 

learning about the day-to-day complexities in delivering services and implementing projects.

One of the foundations actively involved in neighborhood revitalization programs is the Citi 

Foundation, which invested more than $10 million in 2012 in distressed communities. The foundation 

is committed to maintaining economically vibrant communities by increasing the flow of capital to 

low- and moderate-income residents. These resources are available to develop and preserve affordable 

housing, rehabilitate commercial corridors, and develop community facilities such as charter schools 

The former American Brewery 

Building in Baltimore, MD, 

recently became the home 

of a local non-profit following 

an extensive rehabilitation. 

It celebrates the building’s 

historic character while 

acting as a catalyst for 

future development in the 

surrounding neighborhood.

Foundations often 

provide gap financing 

for projects that may fall 

short of federal or state 

match requirements. 

CREDIT: WIKIPEDIA
 CHAPTER 5: LEVERAGING FEDERAL FUNDS FOR LOCAL PRESERVATION INITIATIVES | 45

and community centers. Citi Foundation’s Web site http://www.citigroup.com/citi/foundation/invest/

revitaliz.htm explains how to access grants and includes case studies of successful projects. 

In February 2013, a diverse group of foundation leaders met in Beaverton, Oregon, to explore 

opportunities for working more effectively with local and state governments. They indicated that 

they were sometimes skeptical about developing public-private partnerships because of limited 

understanding of public agency constraints; inconsistent positive experiences from previous grants; 

and lack of respect for the breadth of their non-financial contributions. 

During a panel discussion, local foundation representatives indicated that planning local redevelopment 

projects has unique challenges, such as funding, community support, and land assembly. Projects that had 

received positive federal recognition were presented as models of how to overcome local challenges 

such as communities with excess vacancies and increased residential abandonment. 

Despite challenges articulated by foundation leaders, they still recognize the benefits of 

collaborating with public agencies. Likewise, they acknowledge the necessity of public-private 

involvement in developing viable redevelopment strategies. A list of the foundations that are 

actively involved in resolving urban affairs issues can be found at http://foundationcenter.org/

findfunders/topfunders/top100giving.html.

THE ROLE OF BANKS IN HISTORIC PRESERVATION 

Banking agencies such as the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller 

of the Currency (OCC), and Federal Reserve are key players in the fate of legacy cities. The Community 

Reinvestment Act (CRA), first passed in 1977, requires banks and savings associations to help meet 

the needs of the communities in which borrowers are located, including those residing in low- and 

moderate-income neighborhoods. One of the congressional goals in passing this legislation was to 

eliminate the practice of redlining, the refusal of lending institutions to lend in targeted areas. This was 

accomplished by requiring supervisory financial agencies to encourage regulated banks to help meet 

the needs of local communities through lending, sound yet flexible underwriting standards, and helping 

small businesses. Since the effectiveness of the program was not tied to performance goals, in 1989 and 

Banking institutions frequently 

support the rehabilitation of historic 

neighborhoods, including residential 

and commercial properties, like these 

in Columbus, OH.

CREDIT: CAPITAL CROSSROADS SPECIAL IMPROVEMENT DISTRICT
46 | RIGHTSIZING TASK FORCE REPORT

again in 1995, Congress reformed CRA to improve the process of examining insured institutions and to 

require performance ratings. In addition, institutions were encouraged to be less process-oriented and 

work more closely with communities to achieve outcomes.

On June 24, 2010, the banking agencies collectively published revisions to the rules implementing CRA to 

revise the term “community development” to “include loans, investments, and services that support, enable, 

or facilitate projects or activities” that meet the criteria described in the Housing and Economic Recovery 

Act of 2008 (HERA) and are conducted in designated target areas identified under the Neighborhood 

Stabilization Program established by HERA and the ARRA. These revisions allowed institutions to use CRA 

to assist middle-income borrowers as well as low- and moderate-income borrowers. While this change 

was viewed favorably, tangible outcomes in distressed communities were not substantial. 

Academics and think tanks have had mixed views on whether CRA has helped minority communities 

which are often in distressed areas of the cities. Without a doubt, changes in lending practices and 

business loans helped to preserve some older communities. Institutions have been a major source of 

funding for Federal Historic Preservation Tax Credit projects since the passage of the federal tax act 

program. OCC has prepared a fact sheet for its Community Affairs officers to use when encouraging 

banks to work with local communities. The fact sheet and related list of contacts of participants in 

federal historic tax act projects is the type of outreach that other non-banking federal agencies can 

develop to incorporate historic preservation in their activities. 

During the Rightsizing Task Force on-site visits, it was noted that the Federal Reserve, as part of its CRA 

compliance requirements, is actively involved with legacy cities as it provides a nexus between project 

proponents and non-profit organizations. The Federal Reserve is an important conduit between banking 

agencies and investors with capital to invest in communities and community development corporations 

with creative redevelopment schemes. Federal Reserve Banks are located across the nation and are 

effective at establishing opportunities for foundations and local communities to explore partnerships 

that can assist in the economic development of distressed communities. Since not all legacy cities have 

demonstrated an understanding of the role of partnerships in rebuilding stable, resilient communities, 

the guidance and toolkits provided by the Federal Reserve Banks are sorely needed. 

Universities can be a 

partner for legacy cities by 

utilizing vacant properties 

for administration or 

classroom purposes.
 CHAPTER 5: LEVERAGING FEDERAL FUNDS FOR LOCAL PRESERVATION INITIATIVES | 47

As foundations and banks can be sources of assistance to legacy cities, so are local universities and 

social and religious institutions with an interest in planning and urban affairs. Not only can they educate 

residents, they can also provide additional resources such as college internships and externships to 

conduct research. In Camden County, New Jersey, collaboration between Rutgers University and Rowan 

University resulted in the creation of a tool that will assist in identifying federal, state, county, and local 

resources to assist with redevelopment. This innovative tool creates a “one-stop shopping” directory 

that will establish efficiencies in identifying redevelopment funding. Specifically, the Web site database 

will assist governmental and non-governmental entities to learn what resources the county is eligible 

to apply for either individually or as part of a region. Resources that can support historic preservation 

planning efforts within the county are also included in the database. The county intends to ask towns to 

become part of a shared services agreement if they want to use the database. 

All of the non-governmental organizations (NGOs) that are sources of funding for local government 

projects have acknowledged the value of historic preservation in publications, social media, and Web 

sites. Although the NGOs would not necessarily say that historic preservation was a priority, their 

support of local preservation projects is evident throughout most communities. It is apparent to many 

of their board members that NGOs have a preservation ethic given their mission to preserve local 

assets and promote the city’s history and culture. With additional education about historic preservation 

and more case studies that illustrate how they help to leverage federal and state resources, NGOs, 

banks, and local educational institutions will better appreciate their role in historic preservation. 

FINDING: Public-private partnerships can help to leverage scarce public funds needed to implement 

major redevelopment projects. 

FINDING: National foundations and local educational institutions can provide essential expertise, 

funding, and administrative skills to assist legacy cities.

FINDING: The role of the banking industry, most notably the Federal Reserve, is not widely 

understood by preservationists, and the banking industry does not fully appreciate the value of 

historic preservation as an investment strategy.

GOAL: To encourage communities to work with multiple partners to resolve the impacts of 

rightsizing, including local institutions and national foundations and businesses. 

RECOMMENDATION: The ACHP should collaborate with the National Trust to develop historic 

preservation briefing materials to distribute to foundations and institutions involved in publicprivate partnerships. 

RECOMMENDATION: The ACHP, in collaboration with the National Trust, should host a blog on the 

effect of rightsizing in legacy cities so that redevelopment strategies to protect historic assets can be 

shared with diverse stakeholders. 

RECOMMENDATION: The ACHP and the preservation community should coordinate with the 

Federal Reserve, FDIC, and other banking agencies to encourage them to promote preservation 

strategies in their programs.
48 | RIGHTSIZING TASK FORCE REPORT

VI. Public Policy and Historic 

Preservation

It is apparent that rightsizing in legacy cities is a burgeoning urban policy issue that will have an effect 

on hundreds of thousands of historic properties in the coming years. Beginning in 2009 with the 

creation of the Partnership for Sustainable Communities, and the Department of Labor’s Office of 

Recovery for Auto Communities and Workers, the federal government has indicated its commitment 

to assisting legacy cities, in particular to explore holistic interagency approaches to rebuilding 

sustainable, resilient communities. While such initiatives are more often considered under the issue of 

“sustainability,” rightsizing and redevelopment have many of the same characteristics. In fact, it would 

be practical to combine the two concepts as the Administration moves forward with developing 

urban public policies. The federal government is to be applauded for its success with SC2. However, 

a more expansive urban policy is needed that integrates sustainability, affordable housing, economic 

development, smart growth, and historic preservation. 

Historic preservation has long been in the forefront of sustainable development, and the idea of 

“sustainability” is where society or community, the environment, and the economy come together. 

Many historic buildings are inherently “green” in their materials and construction and can have 

their energy efficiency maximized by sensitive retrofitting. Reinvestment in historic districts and 

communities promotes reuse of existing buildings and infrastructure and supports areas that 

generally are walkable and have good transit access options in order to reduce greenhouse gas 

emissions. When it comes to historic buildings, in most cases the greenest building indeed is the one 

already built. The repair and retrofitting of existing and historic buildings is considered by many to be 

the ultimate recycling project. 

Rehabilitation of properties 

located on anchor corners 

such as this Philadelphia, 

PA, neighborhood can be a 

catalyst for other rehabilitation 

and reuse activities. 

CREDIT: HUD
 CHAPTER 6: PUBLIC POLICY AND HISTORIC PRESERVATION | 49

The ACHP, in its implementation of Section 106 and its advisory role on policy matters, can 

play a role in helping other federal agencies enhance their sustainability efforts as it did with the 

Department of Energy’s weatherization programs: Energy Efficiency and Conservation Block Grant 

Program (EECBG), State Energy Efficiency Programs (SEP), and Weatherization Assistance Program 

(WAP). It is important that representatives of federal, state, tribal, and local interests; preservation 

organizations; and private sector experts be brought together to mesh preservation goals with 

other public needs. Sustainability offers an opportunity to inform other urban policies as well. Since 

applicants who are recipients of federal assistance, grants, and loans rely on agencies to outline 

sustainability goals that must be met, it is incumbent on them to highlight agency policies and 

practices so that federally assisted projects can incorporate them in redevelopment projects. 

In April 2013, the SC2 released its first annual report, which included accomplishments in the 

pilot cities as well as policy lessons and next steps to be taken. The report emphasizes the need 

for partnerships at all levels to achieve the maximum use of each dollar but also discusses the 

expansion of the SC2 program to areas that are designated as “Promise Zones.” Over the next 

four years, these Promise Zones will include 20 urban, rural, and tribal communities hardest hit by 

the long term-economic decline and recession and will likely include numerous legacy cities. While 

the Promise Zones will not receive direct federal funds, they will have access to federal technical 

assistance and resources. The first five Promise Zones announced by the Administration on 

January 8, 2014, are Los Angeles, San Antonio, West Philadelphia, Southeastern Kentucky, and the 

Choctaw Nation of Oklahoma. 

The success of the Partnership and commitment of the Administration to the SC2 initiative 

makes the ultimate expansion of these programs in all cities a logical progression. However, the 

Administration needs to include a strong historic preservation ethic in future programs like the 

Promise Zones to ensure that the use of federal resources to transform distressed cities preserves 

their assets and builds on their history and culture. The lack of involvement of the ACHP in past 

SC2 initiatives was a missed opportunity as qualified preservation professionals who could have 

provided cities with technical assistance to preserve historic properties and reuse them as focal 

points for neighborhood redevelopment were not involved. In addition, historic preservation 

expertise could have been shared with stakeholders who were developing public-private 

partnerships as well as grassroots community organizations to help build a local preservation ethic. 

Infill construction can revitalize dilapidated blocks 

and add a physical edge to neighborhoods.
50 | RIGHTSIZING TASK FORCE REPORT 

As the federal government focuses on developing sustainable communities, historic preservation 

will need to be part of the discussion. To fill a perceived policy gap, a growing group of 

preservationists, local officials, and planners from around the nation, especially legacy cities, 

established the Preservation Rightsizing Network in 2013. This initiative attempts to expand 

the conversation about solutions beyond government officials and “reach people who live 

in places whose revitalization members can foresee and assist: the people who live in the 

neighborhood.” It recognizes the need for racial and socio-economic diversity in historic 

preservation. More important, the Network acknowledges that “many preservation battles don’t 

involve demolition—they involve keeping homeowners and renters in their homes so that the 

buildings don’t become vacant.” The geographic diversity of members of the Network and their 

varied experience in working with historic assets will generate much needed discussions as 

legacy cities are redeveloped. At the November 1, 2013, Network meeting held in Indianapolis, 

Indiana, participants expressed concerns about the need for a national clearinghouse to 

facilitate discussions among preservationists as legacy cities develop blight elimination proposals 

that many described as the “wholesale clearance” of historic properties. Although it was 

acknowledged that several organizations exist to address distressed communities, it was evident 

that these organizations do not address historic preservation, and that this gap needed to be 

addressed in the public and private sectors. 

It is clear that government agencies and their partners must consider the role of historic 

preservation in developing policies and programs to address blight, homelessness, and other 

social and economic challenges for legacy cities. As these cities define local and regional heritage 

and culture, it is important to plan for their future while building on the strength of their past. 

Even though the population may be smaller, the infrastructure deteriorated, and neighborhoods 

recalibrated, those who have lived in or were raised in legacy cities still have fond memories and 

emotional ties. Thus, it is incumbent on local officials and regional leaders to eliminate existing silos 

and recognize historic preservation as an integral component of urban strategies, whether they 

are called rightsizing, redevelopment, rebuilding, revitalization, or any other term used to define 

the process of change in the existing community. By acknowledging the importance of historic 

preservation, communities will not only be able to stabilize and revitalize neighborhoods but also 

have valuable marketing tools to attract new investors and residents seeking to enjoy and promote 

existing culture, heritage, and tourism. 

FINDING: Historic preservation shares common principles, goals, and practices with sustainability as a 

policy and can contribute to sustainable urban redevelopment.

FINDING: Rightsizing, sustainability, and historic preservation are often considered separate 

policy issues.

GOAL: To work with the Administration to recognize and incorporate rightsizing as an integral part 

of sustainable communities’ policy.

RECOMMENDATION: The Administration should engage the ACHP as an active participant in 

shaping federal urban policies to ensure historic preservation goals and practices are incorporated.

RECOMMENDATION: Federal agencies should support the Preservation Rightsizing Network and 

take advantage of its access to grassroots organizations and local organizations interested in historic 

preservation in legacy cities. 

As the federal 

government focuses on 

developing sustainable 

communities, historic 

preservation will 

need to be part 

of the discussion. 
 CHAPTER 7: NEXT STEPS FOR INTEGRATING HISTORIC PRESERVATION IN FEDERAL PROGRAMS | 51

VII. Next Steps for Integrating Historic 

Preservation in Federal Programs 

With the news of Detroit’s bankruptcy filing in the summer of 2013 and the announcement 

of the Hardest Hit Fund Program by the Treasury Department in Indiana, Ohio, and Michigan, 

preservationists and grassroots organizations have expressed concern about losing more historic 

properties to programs designed to eliminate blight through demolition rather than innovative 

solutions. These developments underscored the urgency of finding solutions for rightsizing in legacy 

cities. Historic assets, like public art museums and Carnegie libraries, are at risk and may be used 

to pay off debts as part of the bankruptcy. If their value as assets for the future is not properly 

recognized by officials, historic properties will be absent in redevelopment equations, leading 

to demolition or left to deteriorate by neglect, causing irreparable long-term harm to historic 

neighborhoods.The federal government in funding demolition of thousands of buildings to eliminate 

blight in Indiana, Michigan, and Ohio overlooked the opportunity to create healthy, sustainable 

communities by mothballing, rehabilitating, or reusing properties located in historic districts or 

iconic institutional buildings. Instead of proceeding to demolish historic properties without a clear 

redevelopment strategy, a wiser course of action would have been to provide for the retention of 

usable historic properties as building blocks for rejuvenated communities. 

The ACHP’s examination has brought home a compelling point: only when historic preservation 

considerations are integrated into federal, state, and local planning will public urban policies 

and programs really be holistic and honor the desires of residents to rebuild their communities 

with respect for their heritage and culture. Historic communities and neighborhoods have been 

foundational in many legacy cities. Those entities that are in a position to manage change, whether in 

government or as a partner, need to recognize this and act on it. 

Historic communities 

and neighborhoods 

have been foundational 

in many legacy cities. 

Those entities that are 

in a position to manage 

change, whether in 

government or as a 

partner, need to recognize 

this and act on it. 

Reusing historic buildings for urban schools in cities like 

Detroit, MI, can give students a sense of community pride 

as well as teach them the value of historic preservation. 

CREDIT: DETROIT ACHIEVEMENT ACADEMY
52 | RIGHTSIZING TASK FORCE REPORT 

A primary mission of the ACHP is to advise the Administration on historic preservation matters. The 

ACHP has an obligation to convey to senior policy makers the importance of the role that historic 

preservation plays in building resilient, sustainable, and vibrant communities. This report is intended 

to facilitate a dialogue among federal agency leadership actively involved in the redevelopment of 

legacy cities, recognizing that historic preservation is critical to the future of those places. As the 50th 

anniversary of the NHPA approaches, it is sobering to note the similarities of the challenges facing 

the historic fabric of the nation’s cities. When NHPA was created in 1966, downtowns were being 

reshaped and neighborhoods eradicated at unprecedented levels. Today, our legacy cities face many 

of the same threats and too often the problems are being addressed in the same manner. It is worth 

noting that since 1966, historic preservation helped the nation to turn the corner and rebuild vibrant 

The sale of churches in neighborhoods (like this one 

in Baltimore, MD) illustrates creative reuse options 

for iconic buildings important to the community.

The ACHP presents at 

the National Preservation 

Conference to further 

the conversation about 

rightsizing in America.
 CHAPTER 7: NEXT STEPS FOR INTEGRATING HISTORIC PRESERVATION IN FEDERAL PROGRAMS | 53

historic communities in which residents could work, reside, and socialize. The same resources exist to 

achieve these outcomes as legacy cities are redeveloped in the 21st century. 

Historic preservation, given the opportunities recommended in this report, can be a powerful force 

in ensuring that future generations will experience the rich history and stimulating environment of 

the nation’s cities and neighborhoods. To that end, the ACHP, in collaboration with the preservation 

community and its federal agency partners, intends to address rightsizing in legacy and non-legacy 

communities alike by implementing the recommendations outlined in this report using the following 

four-pronged approach:

1. Educate stakeholders about historic preservation and encourage local governments to use 

this indicator when determining redevelopment goals.

2. Collaborate with federal agencies to ensure that historic preservation values are incorporated 

in their programs and in new and updated urban policies.

3. Communicate noteworthy historic preservation outcomes with diverse stakeholders via social 

media, Web sites, newsletters, and other multi-media products to keep preservationists aware 

of current developments in rightsizing.

4. Promote historic preservation through programs such as Preserve America that reach out to 

local communities, neighborhoods, youth, and culture and tourism programs. 

Cities across the country are facing daunting challenges, but there is a growing library of success 

stories where these challenges have been met with creative solutions based on heritage assets. As 

these strategies and techniques gain broader appreciation and application, 21st century American 

cities will find they can have a vibrant and sustainable future by maintaining continuity with the history 

and culture that defines them as unique places.
54 | RIGHTSIZING TASK FORCE REPORT

Selected Bibliography

The works and sources listed in this extensive bibliography are a record of the diverse materials 

reviewed and consulted to prepare this report. It summarizes the substance and range of books, 

reports, articles, and Internet materials published over the past seven years related to rightsizing, 

shrinking cities, legacy cities, urban policies, and historic preservation. We hope it will be useful to 

those who want to conduct additional research, review the relevant resources, or visit Web sites with 

timely ideas and best management practices. 

Advisory Council on Historic Preservation. The Contribution of Historic Preservation to Urban Revitalization.

Case Study, Washington: Government Printing Office, 1979.

Altshuler, Alan A. The City Planning Process: A Political Analysis. Ithaca and London: Cornell University Press, 1965.

American Planning Association. “Blight Fight.” Planning, June 2007: 1-4.

—. “Policy Guide on Public Redevelopment.” www.planning.org. April 25, 2004. http://www.planning.org/

policy/guides/adopted/redevelopment.htm (accessed January 28, 2014).

—. “Sustaining Places Initiative.” planning.org. March 2010. www.planning.org/sustainingplaces/ (accessed 

January 28, 2014).

Anderson, Michelle Wilde. “Dissolving Cities.” Yale Law Journal. April 1, 2012. http://www.yalelawjournal.org/

the-yale-law-journal/article/dissolving-cities/ (accessed January 28, 2014).

Arnold, David. S., Editor. The Practice of Local Government Planning. Washington, D.C.: International City 

Management Association, 1979.

Aupperlee, Aaron. “After years of hurdles, Pittsburgh’s Garden Theatre project on cusp of taking off.” 

TribLive.com. June 30, 2013. http://triblive.com/news/allegheny/4258169-74/project-theatergarden#axzz2ribNN996 (accessed January 28, 2014).

Badger, Emily. “How One Mayor Pulled His City Back From the Brink of Bankruptcy.” The Atlantic Cities.

December 16, 2013. http://www.theatlanticcities.com/politics/2013/12/how-one-mayor-pulled-back-hiscity-back-brink-bankruptcy/7881/ (accessed January 28, 2014).

Banham, Russ. “Cities on the Brink.” CFO Magazine. November 13, 2013. http://ww2.cfo.com/accountingtax/2013/11/cities-brink/ (accessed January 28, 2014).

Bernanke, Chairman Ben S. “Board of Governors of the Federal Reserve System.” federalreserve.gov. April 13, 2013. 

http://www.federalreserve.gov/newsevents/speech/bernanke20130412a.htm (accessed January 28, 2014).

—. Creating Resilient Communities. April 12, 2013. http://www.federalreserve.gov/newsevents/speech/

bernanke20130412a.htm (accessed January 28, 2014).

Blumgart, Jake. “New land bank in Philadelphia could boost blighted areas.” Yes! Magazine, January 16 , 2014: 4.

Brachman, Alan Mallach and Lavea. “Gateway Cities Don’t Need a Silver Bullet.” Boston Globe. July 

20, 2013. http://www.bostonglobe.com/opinion/2013/07/19/how-rebuild-our-legacy-cities/

ILOeY4bU4fRRMNBtBMgSNO/story.html (accessed January 28, 2014).

Brookings Metropolitan Policy Program. “Michigan’s Urban and Metropolitan Strategy.” www.brookings.edu.

February 23, 2012. http://www.brookings.edu/reports/2012/0223_michigan_economy.aspx (accessed 

January 28, 2014).

Brownlee II, E. Richard, and June A. West. “Case in Point: From Bethlehem Steel, a Roadmap for Detroit.” 

washingtonpost.com. July 26, 2013. http://www.washingtonpost.com/business/case-in-point-in-bethlehempa-a-road-map-for-detroit/2013/07/25/a744d070-f3dc-11e2-a2f1-a7acf9bd5d3a_story.html (accessed 

January 28, 2014).
RIGHTSIZING TASK FORCE REPORT | 55

Byrnes, Mark. “An Intimate Portrait of a Baltimore Neighborhood.” The Atlantic Cities. December 10, 

2013. http://www.theatlanticcities.com/arts-and-lifestyle/2013/12/intimate-portrait-baltimoreneighborhood/7566/ (accessed January 28, 2014).

Calmes, Jackie. “In His Hometown of Chicago, a Policy Speech by Obama Turns Personal.” www.nytimes.com.

February 15, 2013. http://www.nytimes.com/2013/02/16/us/politics/obama-promise-zone-... (accessed 

May 24, 2013).

Center for Court Innovation. “Facilitating a Community Asset Mapping Exercise.” Center for Court Innovation 

website. n.d. http://www.courtinnovation.org/research/facilitating-community-asset-mapping-exercise 

(accessed January 28, 2014).

Center for Housing Policy. “Local Policy Options to Support Sustainable and Equitable Development.” nhc.org.

n.d. http://www.nhc.org/media/documents/ORAMlocal_final2.pdf (accessed January 28, 2014).

—. “State Policy Options to SUpport Sustainable and Equitable Development.” nhc.org. n.d. http://www.nhc.

org/media/documents/ORAMstate_brief_final.pdf (accessed January 28, 2014).

Center for the Study of Social Policy. Neighborhood Investment. n.d. http://www.cssp.org/community/

neighborhood-investment (accessed January 28, 2014).

City of Buffalo, developed at the request of Mayor Byron Brown. Buffalo Building Reuse Project. Buffalo, NY: 

Buffalo Niagara Partnership, 2012.

City of Philadelphia. “Mayor Nutter Signs Executive Order Establishing Mayor’s Office of Grants.” Philadelphia 

Recovery. July 18, 2012. http://philarecovery.wordpress.com/2012/07/18/city-of-philadelphia-mayor-nuttersigns-executive-order-establishing-mayors-office-of-grants/ (accessed January 28, 2014).

Cohen, James R. “Combining Historic Preservation and Income Class Integration: A Case Study of the Butchers 

Hill Neighborhood of Baltimore.” Housing Policy Debate, Volume 9, Issue 3, 1998.

Columbus Dispatch. “Many Ways to Fight Blight.” November 13, 2013. http://www.dispatch.com/content/

stories/editorials/2013/11/21/many-ways-to-fight-blight.html (accessed January 28, 2014).

David R. Godschalk, FAICP and William R. Anderson, FAICP. Sustaining Places: The Role of Comprehensive 

Plan. Planning Advisory Service Report Number 567, Chicago, IL: American Planning Association, 2012.

Denson, Jonathon. Discovering Historic Pittsburgh: Abandoned and Endangered Buildings. January 10, 2011. 

http://www.jonathondenson.com/2011/01/abandoned-building-of-week.html (accessed January 28, 2014).

Department of the Treasury, Community Development Financial Instituition. “Bank Enterprise Award Program 

Fact Sheet.” www.cdfifund.gov. 2013. www.cdfifund.gov/bea (accessed January 28, 2014).

Department of the Treasury, Community Development Financial Institution. “Community Development 

Financial Institutions Program Fact Sheet.” www.cdfifund.gov. 2013. www.cdfifund.gov/cdfi (accessed 

January 28, 2014).

Detroit Works Project. Detroit Future City. Brochure, Detroit: Detroit Works Project: Long Term 

Planning, 2012.

Dubb, Steve. Why Eds and Meds Matter for Community Economic Development. December 3, 2013. http://

www.rooflines.org/3530/why_eds_and_meds_matter_for_community_economic_development/ (accessed 

January 28, 2014).

Favro, Tony. “US Cities Use Demolition as Planning Tool but Results Are Often Problematic.” citymayors.com.

May 7, 2006. http://www.citymayors.com/development/demolition_usa.html (accessed January 28, 2014).

Federal Deposit Insurance Corporation. “Using Government Financing Programs.” November 2011. www.fdic.

gov/about/diversity/sbrp/33.ppt (accessed January 28, 2014).

Fink, James. “Reviving Main Street Next for Developing Buffalo.” Buffalo Business First. August 6, 2013. http://

www.bizjournals.com/buffalo/news/2013/08/06/reviving-main-street-next-for.html (accessed January 28, 

2014).

Fitzpatrick, Dan. The Story of Urban Renewal. May 21, 2000. http://old.post-gazette.com//

businessnews/2000521eastliberty 1.asp.

Florida, Richard. “2013’s Best Performing American Cities.” The Atlantic Cities. December 18, 2013. http://www.

theatlanticcities.com/jobs-and-economy/2013/12/2013s-best-performing-american-cities/7887/ (accessed 

January 28, 2014).
56 | RIGHTSIZING TASK FORCE REPORT

Follain, James R., Ph.D. A Study of Real Estate Markets in Declining Cities. Special Report, Washington D.C.: 

Research Institute for Housing America, 2010.

Fox, Kathleen. “Taking the Rust Off the Belt: By Any Other Name, Can Legacy Cities Regenerate?” Urban 

Current. August 19, 2013. http://urbancurrent.org/2013/08/19/taking-the-rust-off-the-belt-by-any-othername-can-legacy-cities-regenerate/ (accessed January 28, 2014).

Gamble, Janne Corneil and David. “Ideas Per Square Foot.” Planning , February 2013: 22- 28.

Gerlie, Merete F. Resources for Grantseekers. Washington: Congressional Research Service, 2012.

Gilmartin, Dan. “A Tale of Two (Shrinking) Cities, Historic Preservation Style.” www.economicsofplace.com.

November 23, 2012. www.economicsofplace.com/2012/11/a-tale-of-two-shrinking-cities-historic-preservat... 

(accessed April 8, 2013).

Glaeser, Edward L. Bulldozing America’s Shrinking Cities . June 16, 2009. http://economix.blogs.nytimes.

com/2009/06/16/bulldozing-americas-shriniking-cities/.

Goebel, Alison D., Editor. Collected by John Gardocki. “Best Practices for Community Revitalization and 

Stabilization.” www.greaterohio.org. 2012. www.greaterohio.org/policy-and-research/best-practices-forcommunity-revitalization... (accessed June 3, 2013).

Goodyear, Sarah. “Why the Feds Agreed to Spend TARP Money on Demolishing Michigan’s Empty Buildings.” 

The Atlantic Cities. June 7, 2013. http://www.theatlanticcities.com/jobs-and-economy/2013/06/why-fedsagreed-spend-tarp-money-demolishing-michigans-empty-buildings/5842/ (accessed January 28, 2017).

Gratz, Roberta Brandes. “In Shrinking Cities, Preserving Existing Buildings Can Stem the Loss.” citiwire.net. July 

20, 2012. http://citiwire.net/columns/in-shrinking-cities-preserving-existing-buildings-can-stem-the-loss/ 

(accessed January 28, 2014).

—. Opiniontor. September 10, 2010. http://opinionator.blogs.nytimes.com/2010/09/01/o-urban-pioneers/ 

(accessed 3 2013, June).

Gratz, Roberta Brandes, and Norman Mintz. Cities Back From the Edge: New Life for Downtown. New York: 

John Wiley, 1998.

Heffern, Sarah. A Who’s Who of Preservation Organizations. January 28, 2014. http://blog.preservationnation.

org/2014/01/28/10-tuesday-whos-preservation-organizations/#.Uuf9PXd2MuM.twitter (accessed January 

28, 2014).

Hembree, Tess. APA Policy News for Planners: President Proposes “Promise Zones,” Choice Neighborhood 

Expansion . April 12, 2013. http://blogs.planning.org/policy/tag/choice-neighborhoods/.

Historic Preservation and Sustainability. n.d. http://www.sustainablecitiesinstitute.org/view/page.basic/class/

feature.class/Lesson_Historic_Preserv_Sustain (accessed January 28, 2014).

Hollander, Justin B. “Surprising Facts from the Census.” Planning, March 2011: 40.

Initiative for a Competitive Inner City. 2012 Inner City Economic Summit. September 19-20, 2012. http://www.

icic.org/urban-economic-development/inner-city-economic-development (accessed August 20, 2013).

—. “City by City Snapshots.” www.icic.org. April 8, 2013. http://www.icic.org/urban-economic-development/

city-profiles (accessed January 28, 2014).

—. “Links to Online Resources.” www.icic.org. April 8, 2013. http://www.icic.org/resources-for-inner-city-ceos/

links-to-online-resources (accessed January 28, 2014).

International Meetings Review. “Buffalo, NY, Breaks Ground on Construction of Hotel Projects.” International 

Meetings Review. June 28, 2013. http://www.bizjournals.com/buffalo/news/2013/08/06/reviving-mainstreet-next-for.html (accessed January 28, 2014).

Jacobs, Allan B. Making City Planning Work. Chicago, Illinois: American Planning Association, 1980.

Jones, Larry. “U.S. Mayor: 113 Mayors Sign Letter Recommending Improvements to Legislation Promoting 

Accountability, Transparency in Reporting on Federal Grants.” Philadelphia Recovery. September 17, 2012. 

http://philarecovery.wordpress.com/2012/09/17/u-s-mayor-113-mayors-sign-letter-recommendingimprovements-to-legislation-promoting-accountability-transparency-in-reporting-on-federal-grants/ 

(accessed January 28, 2014).
RIGHTSIZING TASK FORCE REPORT | 57

—. “U.S. Mayor: Revised DATA Act Bill Still Needs Work to Minimize Unnecessary Burdens, Costs on Local 

Government.” Philadelphia Recovery. October 5, 2012. http://philarecovery.wordpress.com/2012/10/05/u-smayor-revised-data-act-bill-still-needs-work-to-minimize-unnecessary-burdens-costs-on-local-government/ 

(accessed January 28, 2014).

Katz, Bruce and Jennifer Bradley. The Metropolitan Revolution. Washington, DC: The Brookings 

Institution, 2013.

Kellogg, Alex P. Black Flight Hits Detroit. June 5, 2010. http://online.wsj.com/news/articles/SB1000142405274

8704292004575230532248715858 (accessed January 28, 2014).

Kleiman, Neil, and Matt Pacena. “Green Cities: How Urban Sustainability Efforts Can and Must Drive 

America’s Climate Change Policies.” livingcities.com. May 2009. www.livingcities.org/knowledge/

media/?action=download&id=6 (accessed January 28, 2014).

Kneebone, Elizabeth. Job Sprawl Stalls: The Great Recession and Metropolitan Employment Location . Research; 

Metropolitan Opportunity Series , Washington, DC: Brookings Institution, 2013.

Kneebone, Elizabeth, and Alan Berube. Confronting Suburban Poverty in America. Washington: Brookings 

Institution Press, 2013.

Kolko, Jed. “Where the Empty Houses Are.” The Atlantic Cities. November 6, 2013. http://www.theatlanticcities.

com/housing/2013/11/where-empty-houses-are/7497/ (accessed January 28, 2014).

Krohe Jr, James. “The Incredible Shrinking City.” Planning, November 2011: 12-15.

Listokin, David, Barbara Listokin, Michael Lahr, and Rutgers University. “Beyond This Old House: Historic 

Preservation in Community Development.” Housing Policy Debate, Volume 9, Issue 3 (Fannie Mae 

Foundation), 1998: 431.

Loftsgordon, Amy. “Ohio’s Hardest Hit Program: Save the Dream Ohio.” nolo.com. n.d. http://www.nolo.com/

legal-encyclopedia/ohios-hardest-hit-program-save-the-dream-ohio.html (accessed January 28, 2014).

Louisiana Office of Cultural Development, Division of Historic Preservation . Tax Incentives Program - 

Frequently Asked Questions. n.d. http://www.crt.state.la.us/hp/tax_incentives/faq.aspx (accessed January 

28, 2014).

Mallach, Alan. Facing the Urban Challenge: The Federal Government and American’s Older Distressed Cities.

Policy, Washington, DC: Brookings, 2010.

Mallach, Alan. Laying the Groundwork for Change: Demolition, Urban Strategy, and Policy Reform. Washington, 

D.C.: Brookings Metropolitan Policy Program, 2012.

Maloney, Brenna. Putting the Right in Right-Sizing: A historic preservation case study. Research Report, 

Washington, DC: The National Trust for Historic Preservation and the Michigan Historic Preservation 

Network, 2013.

Merriam, Dwight, Editor and David J. Brower, Philip D. Tegeler. Inclusionary Zoning Moves Downtown.

Chicago, Illinois: American Planning Association, 1985.

Miller, Alan D. “Houses in Disrepair Have Place in History.” Columbus Dispatch. June 9, 2013. http://www.

dispatch.com/content/stories/home_and_garden/2013/06/09/houses-in-disrepair-have-place-in-history.

html (accessed January 28, 2014).

National Center for Children in Poverty. “Researchers: Detroit, Cleveland, Cincinnati, Buffalo, Milwaukee 

Lead the Nation in Child Poverty.” nccp.org. 2011. http://www.nccp.org/media/releases/release_153.html 

(accessed January 28, 2014).

National Endowment for the Arts. The Mayors’ Institute on City Design. 2013. www.micd.org (accessed 2014).

National Main Street Center. Main Street Four-Point Approach. n.d. http://www.preservationnation.org/mainstreet/about-main-street/the-approach/#.Uuf3pNIo7cs (accessed January 28, 2014).

—. The Eight Principles. n.d. http://www.preservationnation.org/main-street/about-main-street/the-approach/

eight-principles.html (accessed January 28, 2014).

National Park Service, U.S. Department of Interior, Technical Preservation Services and Rutgers University. 

Annual Report on the Economic Impact of the Federal Historic Tax Credit for FY 2012. Program , Washington, 

DC: National Park Service , 2013.
58 | RIGHTSIZING TASK FORCE REPORT

Needleman, Sarah E. Finding the Silk Purse. November 9, 2009. http://online.wsj.com/article (accessed 

June 3, 2013).

New Jersey Department of Community Affairs. “2012 Grants and Resources.” Grants and Resources 

for Nonprofits and Other Eligible Agencies. 2012. http://www.state.nj.us/dca/publications/pdf/

dcagrantsandresourcesbook.pdf (accessed January 28, 2014).

Office of Management and Budget. “Building Ladders of Opportunity.” White House. n.d. http://www.

whitehouse.gov/omb/budget/factsheet/building-ladders-of-opportunity (accessed January 28, 2014).

Ohio Housing Finance Agency. “Ohio Hardest-Hit Fund (Ohio HHF) Plan Approved by U.S. Department 

of Treasury.” Ohio Housing Finance Agency. August 4, 2010. http://www.ohiohome.org/newsreleases/

rlsOhioHHFapproved.aspx (accessed January 28, 28).

Parternship for Sustainability. “Three Years of Helping Communities Achieve Their Visions for Growth and 

Prosperity.” June 2012. http://www.sustainablecommunities.gov/pdf/partnership_accomplishments_

report_508%20compliant_final_062112.pdf (accessed January 28, 2014).

Pavel, Edited by M. Paloma. Breakthrough Communities: Sustainability and Justice in the Next American 

Metropolis. Cambridge, Massachusetts : The MIT Press, 2009.

Pennsylvania Department of Community and Economic Development. “Community Revitalization Desktop 

Guide.” Pennsylvania Department of Community and Economic Development. May 1, 2012. http://www.

newpa.com/strengthen-your-community/redeveloping-your-community/community-revitalization-guide 

(accessed January 28, 2014).

PlaceEconomics. Population Change in Historic Neighborhoods. Supplement, Washington: Place Economics, 2012.

Planetizen. Next Steps for Shrinking Cities: Results of the Planetizen Brainstorm. July 9, 2009. http://www/

planetizen.com.node.39619.

Popper, Deborah E. Popper and Frank J. “Small Can Be Beautiful.” Planning, July 2002: 20-23.

Powell, John A. “Reflections on the Past, Looking to the Future: The Fair Housing Act at 40.” Indiana Law 

Review, Volume 41, Number 3, 2008: 605.

PRNewswire-USNewswire. “National program connects inner city companies to $703 million in capital.” 

www.prnewswire.com. November 9, 2012. http://www.prnewswire.com/news-releases/national-programconnects-growing-inner-city-companies-to-703-million-in-capital-178080571.html (accessed January 28, 

2014).

Ronald Lee Flemming, AICP. “Planning.” The Preservation Movement Needs Some Crackle, and Pop, 2005: 2.

Rutgers University, Edward J. Bloustein School of Planning and Public Policy. Annual Report on the Economic 

Impact of the Federal Historic Tax Credit for FY 2012. Executive Summary, New Brunswick, NJ: Center for 

Urban Policy Research, 2013.

Ryan, Brent D. “Rightsizing Shrinking Cities.” In The City After Abandonment, by eds. Margaret Dewar and June 

Manning Thomas, Chapter 14. Philadelphia: University of Philadelphia Press, 2012.

Schocker, Laura. What Pittsburgh Can Teach the Rest of the Country About Living Well. December 18, 2013. http://

www.huffingtonpost.com/2013/12/18/pittsburgh-health_n_4339476.html (accessed January 28, 2014).

Segal, David. A Missionary’s Quest to Remake Motor City. April 13, 2013. http://www.nytimes.

com/2013/04/14 (accessed June 3, 2013 ).

Travel and Leisure. America’s Greatest Main Streets. May 2012. http://www.travelandleisure.com/articles/

americas-greatest-main-streets (accessed January 28, 2014).

U.S. Department of Agriculture report Improving and Facilitating a Farmers Market in a Low Income 

Neighborhood: a Washington, D.C. case study, 2002

U.S. Department of Housing and Urban Development. Establishing and Operating Land Banks. Washington, 

DC, April 10, 2012.

U.S. Department of the Interior, National Park Service and the National Trust for Historic Preservation. Affordable 

Housing Through Historic Preservation. Case Study, Washington: Government Printing Office, 1994.

U.S. House, 112th Congress. “H.R. 3502, Project Rebuild Act.” November 18, 2011. http://beta.congress.gov/

bill/112th-congress/house-bill/3502 (accessed January 28, 2014).
RIGHTSIZING TASK FORCE REPORT | 59

U.S. House, 113th Congress. H.R. 2061, Digital Accountability and Transparency Act. Washington: Government 

Printing Office, 2013.

Urban Redevelopment Authority of Pittsburgh. n.d. http://www.ura.org/everywhere/ (accessed January 28, 2014).

Vey, Jennifer S. Restoring Prosperity: The State Role in Revitalizing American’s Older Industrial Cities.

Metropolitian Policy Program , Washington, DC: Brookings Institution, 207.

Weaver, Clifford L. and Richard F. Babcock. City Zoning: The Once and Future Frontier. Chicago, Illinois: 

American Planning Association, 1979.

White House Council on Strong Cities, Strong Communities. “Strong, Cities, Strong Communities Initiative: 

1st Annual Report.” Annual Report, Washington, 2013.

White House Neighborhood Revitalization Initiative. “Building Neighborhoods of Opportunity.” July 2011. 

http://www.whitehouse.gov/sites/default/files/uploads/nri_report.pdf (accessed January 28, 2014).

Williams, Timothy. “Blighted Cities Prefer Razing to Rebuilding.” New York Times. November 12, 2013. 

http://www.nytimes.com/2013/11/12/us/blighted-cities-prefer-razing-to-rebuilding.html?_r=0 

(accessed January 28, 2014).

Wit, Jessica de. Revitalizing Blighted Communities with Land Banks. 2005. http://www.umich.edu/econdeve/

landbank (accessed June 19, 2013).

Yeado, Kirstin Noe. “Administration Announces Promise Zones.” Investing in Community Change. July 2, 2013. 

http://financing-community-change.blogspot.com/2013/07/administration-announces-promise-zones.html 

(accessed January 28, 2014).

Youngstown Neighborhood Development Corporation. Creating Healthy Homes Through Innovative Programs.

n.d. https://yndc.org/programs (accessed January 28, 2014).
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Acknowledgements

The Advisory Council on Historic Preservation wishes to extend its appreciation and thanks to the 

following individuals and organizations for their guidance and contributions in preparing this report. 

Advisory Council on Historic Preservation Rightsizing Task Force

Bradford J. White, Task Force Chairman

National Trust for Historic Preservation, Task Force Vice Chairman

Milford Wayne Donaldson, FAIA, ACHP Chairman

Clement Price, Ph.D., ACHP Vice Chairman

Honorable Michael B. Coleman, Mayor of Columbus, Ohio

Terry Guen

Horace Foxall

U.S. Department of Agriculture

U.S. Department of Housing and Urban Development

U.S. Department of Transportation

U.S. Department of the Interior, National Park Service

U.S. Environmental Protection Agency

National Conference of State Historic Preservation Officers 

National Alliance of Preservation Commissions 

Katherine Slick, President, ACHP Alumni Foundation

Advisory Council on Historic Preservation Staff

John M. Fowler, Executive Director

Reid J. Nelson, Director, Office of Federal Agency Programs

Charlene Dwin Vaughn, AICP, Assistant Director, Office of Federal Agency Programs (report co-author)

Jaime Loichinger, Program Analyst (report co-author)

Susan Glimcher, Director, Office of Communications, Education, and Outreach

Shayla Shrieves, Senior Writer-Editor

Special Thanks To: 

Cleveland Restoration Society

Cara Bertron

Donovan Rypkema

City of Buffalo, New York

City of Cleveland, Ohio

City of Columbus, Ohio

City of Detroit, Michigan

City of Flint, Michigan

City of Newark, New Jersey

City of Saginaw, Michigan

Advisory Council on Historic Preservation

1100 Pennsylvania Avenue NW, Suite 803, Washington, DC 20004

Phone: 202-606-8503 • Fax: 202-606-8647

www.achp.gov