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PUBLIC COMMENTon
PROGRAMMATIC AGREEMENTAMONG
THE CITY OF PHILADELPHIA, PENNSYLVANIA,THE PENNSYLVANIA STATE HISTORIC PRESERVATION OFFICER,
AND THETHE ADVISORY COUNCIL ON HISTORIC PRESERVATION
Submitted byFAYE M. ANDERSON
November 4, 2015
I am the founder and director of All That Philly Jazz, a public history project that is telling the story of Philadelphia's rich jazz heritage. We are mapping jazz-related historic properties. Philadelphia's jazz heritage trail winds through the Area of Potential Effects for undertakings implemented with financial assistance from covered U.S. Department of Housing and Urban Development (HUD) programs, including, but not limited to, the Community Development Block Grant Program. Accordingly, I am interested in the Programmatic Agreement between the City of Philadelphia, the Pennsylvania State Historic Preservation Officer and the Advisory Council on Historic Preservation.
On November 3, 2015, voters passed Ballot Question No. 2 which, among other things, places the Philadelphia Historical Commission and the Office of Housing and Community Development under thenewly created Department of Planning and Development. In light of the pending reorganization, I respectfully submit that it is premature for the City of Philadelphia to finalize the Programmatic Agreement.
We do not know the impact of the reorganization on the capacity of the City to assist HUD with the implementation of its Section 106 compliance responsibilities for selected programs. Nor do we know how the reorganization will impact the City's capacity to complete its Section 106 compliance responsibilities for HUD-funded undertakings within its Empowerment Zones.
The formerly independent Philadelphia Historical Commission will now be under the direction of the Planning and Development Director. The new Division of Planning and Zoning will oversee PHC. The reorganization raises the question: Will streamlining planning functions put pressure on PHC to rubber-stamp building permit applications for alterations to, or demolition of, eligible historic properties in the Area of Potential Effects of HUD-funded undertakings?
PHC's perennial underfunding is no secret. Indeed, then-Councilman and now Mayor-elect Jim Kenneyintroduced a bill that would have more than doubled the agency's budget. Without additional Certified Staff, will the push for speed under the reorganization short-circuit the Section 106 review process?
As the City transitions to new leadership and a new direction in planning and development, the time is not ripe for the City of Philadelphia to sign the Programmatic Agreement.
Faye M. AndersonDirectorAll That Philly Jazz (215) 995-5028http://[email protected]@andersonatlarge | @PhillyJazzApp
