Friends of Ocmulgee Old Fields

LETTER WARNS ROADS THREATEN HISTORIC DISTRICT 'PIECEMEAL' PLANNING CITED

Johnathan Burns and Jennifer Plunkett, The Macon Telegraph

The Macon-Bibb County road program's "piecemeal" approach to projects threatens historic Macon neighborhoods, according to a November letter by a former state historic preservation officer who says he resigned his position after being ordered not to release the letter.

The undelivered note, written by Mark Edwards and addressed to Mayor Jim Marshall, recommends a review of the overall impact of projects in the road program to avoid an incremental erosion of the "historic fabric of the district."

Edwards warns that current planning for individual projects could constitute "segmentation" of transportation planning --- which is prohibited in federally assisted transportation projects under historic review.

The two road projects in question are located in the heart of Macon's Intown historic district on College Street and are part of the $300 million Macon-Bibb County Road Improvement Program, which was approved by voters in 1994.

Members of a neighborhood group opposed to several projects in the road program said Sunday that news of Edwards' letter "further damages the public trust."

"We're trying so hard to build this bridge to do some good for our neighborhood," CAUTION Macon member and Intown Macon Neighborhood resident Walker Rivers said. "Every time we start digging deep to find out what's going on, these are the kinds of things we're digging up."

Edwards said this weekend from his Washington, D.C., home that he was ordered by Lonice Barrett, commissioner of the state Department of Natural Resources, not to send his Nov. 13 letter.

Barrett and Ben Porter, former DNR chairman and now 8th District representative on the Natural Resources board, both confirmed Saturday that Edwards was told not to send the letter.

"I don't like DNR to find itself in the middle of an issue that is as hot as I believe that one is down there," said Barrett, a Macon native. "I stand by that decision."

Barrett said he did not consult with Porter about the decision, nor did he think Porter knew the letter existed. But Porter said he saw a draft of Edwards' letter and discussed it with Barrett.

"I suggested to Barrett they might want to review the projects more thoroughly ... and told him to hold the letter," Porter said.

Edwards said he resigned the job he had held four years after being told not to send the letter.

"In my view, this was certainly the final straw in a difficult situation," said Edwards, who now works for a private historic preservation firm.

"I'm sure this was part of an effort to squelch this particular set of viewpoints and keep the local transportation project moving ahead," he said. "Certainly it was pretty common knowledge that Mr. Porter and others in the area were unhappy with the state Historic Preservation Division doing its job."

Bibb County Commission Chairman Larry Justice said he received a copy of Edwards' letter late last week and faxed a copy to Porter. Justice said he will order a review of the plans for College Street intersections at Georgia Avenue and Washington Avenue, which are now being designed by Moreland Altobelli Associates and city officials.

"Naturally my first reaction to that is, if in fact (the projects) had the potential of doing that, we'd have to step back and think about it," Justice said. "We have too great a historical district. I'm going to try my best to pull everybody together to understand what it means."

The letter was circulated last week as an attachment to a confidential memo sent by Mayor Marshall to Barrett, Porter, road program officials and CAUTION Macon.

Marshall's memo states that he spoke with Edwards on March 1 by telephone. Marshall said Edwards criticized road planning for lacking openness, for posing a threat to historically significant properties and for possibly requiring federal review.

"He suggested, as I understood it, that a (federal) Section 106 review was needed for our roads program because it was so intimately tied to the use of current and federal funding for local roads," Marshall wrote. "... He was suggesting that the allocation of local funds to historically significant projects could not circumvent the Section 106 process."

Section 106 concerns federally funded projects in historic areas. The policy dictates that governments must determine the impact such projects will have and decide, with public input, how to avoid adverse effects.

Edwards said the section is skirted when communities do not look at the comprehensive impact of projects. In most cases, local governments avoid the law by reviewing projects individually, he said.

Edwards' letter outlines how poor planning could harm the historic district and jeopardize its listing on the National Register. Road projects could:

Encroach into historic properties on either side of the street from road construction.

Possibly destroy several historic street and yard trees and damage long-established root systems.

Diminish the scale and character of the historic district by creating more-open intersections and reducing historic yards.

GA. OFFICER'S LETTERS SHOW FEARS ABOUT ROAD WORKS

Johnathan Burns and Jennifer Plunkett, The Macon Telegraph

Last summer, the state's top historic preservation officer started to question how the Macon-Bibb County Road Improvement Program would affect the city's historic district.

By mid-October, after meeting with road officials and residents, Mark Edwards had come to a conclusion: Macon's historic character was at risk from traffic projects of unproven necessity.

Further, he had determined the historic district's place on the National Historic Register could be in jeopardy, and transportation officials were not listening to the public.

Edwards' involvement in the roads controversy is marked by two letters that lay out his concerns about the $300 million program. His official involvement ended with a Nov. 13 letter to Macon Mayor Jim Marshall --- a letter his superiors directed him not to send. Edwards then submitted his resignation from the job he had held for four years.

"I felt like I wasn't able to do my job," Edwards said Monday from his private-sector historic preservation job in Washington, D.C. "We were supposed to be the advocate of the state's heritage and resources. There is no doubt those projects would adversely impact the district."

In a Sept. 1, 1998, letter, Edwards suggested a review of the program's impact on the historic district. Edwards addressed the letter to Marshall and copied it to Bibb County Commission Chairman Larry Justice, local historic preservation leaders and residents.

Edwards drafted the letter after receiving at least 20 phone calls from residents.

"I cannot urge you too strongly to carefully consider the potential effects of proposed local transportation projects on Macon's unique historic resources," Edwards wrote.

As a result, Justice said on Sept. 7 he asked the staff of Moreland Altobelli Associates Inc. to develop a plan with the state Department of Transportation for preserving the district's distinction. Justice said Monday he didn't know if his direction was followed or if the plan was created.

Marshall replied to Edwards in a Sept. 10, 1998, letter requesting the assistance of Edwards and the staff of the department of Natural Resources' Historic Preservation Division. In the letter, Marshall said he wanted Edwards to evaluate the Intown Macon projects planned at two College Street intersections, as well as the entire road program's impact. Marshall asked Moreland Altobelli staff to work with Edwards.

A meeting was set up between Moreland Altobelli and Edwards' staff, said Moreland Altobelli's historian Greg Schneider. Schneider said he set the meeting for Oct. 13, 1998.

The meeting took place at Edwards' offices in Atlanta and was attended by Macon Heritage Foundation Executive Director Maryel Battin and Intown Macon residents Walker and Suzan Rivers, who are also members of CAUTION Macon, the neighborhood group opposed to aspects of the road program.

"We didn't know (Battin and the Rivers) were going to be there," Schneider said Monday. "We were trying to appease the folks with the concerns. We thought we ought to show it to (Edwards)."

Schneider said he believed the projects along College Street had minimal impact in the historic district. Since both were funded with local tax dollars --- not state or federal funds --- no impact study was required, Schneider said.

Edwards and two other Historic Preservation Division employees attended the meeting.

"We all had identical opinions on the matter," Edwards said. "We were all struck by the adverse impact it would have."

After discussing the matter for two weeks, Edwards said he drafted a letter to Marshall and dated it Nov. 13, 1998. The letter was critical of the program's plans for Intown Macon, which, to his knowledge, had proceeded with little public input. He warned Marshall of the program's practice of using only local funds for particular projects

"There seems to be little consideration given to the cumulative effects of all these transportation projects on Macon's historic resources in the local transportation planning process," Edwards wrote. "This is akin to the phenomenon of project 'segmentation' which is prohibited in the state and federally assisted transportation projects we review."

That letter caught the attention of Ben Porter, then chairman of the Department of Natural Resources and Lonice Barrett, DNR commissioner. Porter said he reviewed the letter and told Barrett it should not be made public, Porter said Saturday. Barrett ordered Edwards not to mail the correspondence, which made it into the hands of Marshall last week through a third party.

Barrett said he made the decision because he did not want DNR placed in the middle of the Bibb County road controversy. Porter said he suggested to Barrett that DNR conduct a more thorough review of the projects and that he hold the letter.

Withholding the letter was the final straw in a bad situation, Edwards said. He submitted a resignation --- effective Nov. 13.

"In hindsight, it was tremendously disappointing," Edwards said. "That was the best job I ever had. But I didn't see any point in putting my head in the sand. We didn't see any desire in the local planning process to include public input or (the impact) on historic preservation ... I didn't like leaving. It seemed that a lot of business decisions were driving our policy decisions."

He moved to Washington, D.C., taking a job with a private historic preservation firm in January. Over the past six months, Edwards maintained some contact with people in Macon. He said he received a March 1 call from Marshall, who told Edwards that he was concerned about potential litigation the road program faced.

Edwards said he expected the letter would be made public. He also said he has concerns about the politics driving the decisions made in the road program.

"I think it's important, as this case played out, that people understand the professional conclusions my office raised," he said. "It goes back to what government is supposed to be doing."

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The Honorable James C. Marshall, Mayor

City of Macon

P.O. Box 247

Macon, GA 31202

Dear Mayor Marshall:

Our office has been contacted recently by several Macon residents who are concerned about the possible effects of proposed local street improvements on the National Register or National Historic Landmark status of their properties. We also have been contacted by organizations concerned with the effects of these projects on the overall National Register eligibility of the Macon Historic District.

While we do not have all the details of the proposed projects, it is our understanding that they involve street and intersection widenings of Georgia Avenue at College Street and Washington Avenue at College Street, the heart of the historic College Hill neighborhood in the Macon National Register Historic District, and that may result in the loss of historic curbs, sidewalks, street trees and portions of front yards of an individually listed National Register property (Holt-Peeler-Snow House, an extraordinary Greek-Revival-style house dating from the 1840s), a designated National Historic Landmark (the 1840s Raines-Miller-Carmichael House, a truly unique architectural design and prominently situated at the heart of the College Hill neighborhood), a historic community landmark building (the historic Macon library), and other historic houses listed in the National Register as contributing properties in the Macon National Register Historic District.

Should this be the case, the significance and National Register eligibility of these individual properties and the Macon Historic District as a whole would likely be diminished, possibly to the point where it would be necessary for our office, in consultation with the U.S. Department of the Interior, to formally amend the National Register nominations for these properties to reflect the loss of significant historic features of the properties and the district.

I would like to take this opportunity to point out that Macon has traditionally led the state in the number of National Register nominations, and that Macon now has more National Register-listed properties than any other city in Georgia. Some of the state's earliest National Register nominations came from Macon --- including the nominations for the properties that might be affected by the proposed transportation projects --- as well as some of the state's precedent-setting nominations including those for Pleasant Hill and the Railroad Industrial District. Property owners have used the benefits of National Register designation to great advantage in rehabilitating intown properties and in revitalizing residential neighborhoods and commercial areas --- with consequent increases in the local property tax digest. Largely through these efforts, Macon now enjoys viable intown neighborhoods and an active historic central business district. The community as a whole has seized upon heritage tourism as an economic development activity, focused on such local landmarks as the Johnson-Hay House and Ocmulgee Mounds, but bolstered by the intact historic neighborhoods that secure these local landmarks.

Like you, I care deeply about the beauty of Macon's historic properties, and want to ensure that your pre-eminent position as Georgia's lead city in historic preservation activities continues and will grow in the future. I cannot urge you too strongly to carefully consider the potential effects of proposed local transportation projects on Macon's unique historic resources, which represent some of the state's best and most significant historic properties. If our office can be of assistance in helping you determine the short- and long-term effects of these projects on historic properties in Macon, so that they can be fully taken into account in your local planning process, we would most certainly be glad to do so.

As State Historic Preservation Officer, I would most deeply regret having to take any follow-up actions on Macon's National Register nominations that might be necessitated by the detrimental effects of local transportation projects, especially if those effects could be minimized or avoided altogether in light of the significance and value of your local historic resources. Please feel free to contact me if our office can be of assistance as you carry our your local transportation planning activities.

Sincerely,

Mark R. Edwards

Director and State Historic Preservation Officer

cc: Mr. Larry Justice, Chairman, Bibb County Commission

Mr. Bo Shippen, Intown Macon Neighborhood Association

Ms. Maryel Battin, Macon Heritage Foundation

Mrs. Kitty Oliver, Middle Georgia Historical Society

Mr. Cecil McKithan, National Park Service

Mr. Greg Paxton, Georgia Trust for Historic Preservation

Marshall's Response: Sept. 10, 1998

Mr. Mark R. Edwards, Director

Historic Preservation Division

Ga. Dept. of Natural Resources

500 The Healey Building

57 Forsyth Street, N.W.

Atlanta, Georgia 30303

Dear Mark:

I appreciate your letter of September 1, 1998 expressing concern about the impact that our Road Improvement Program might have upon historic properties in the Intown Neighborhood. I also appreciate and accept your offer of assistance in evaluating the potential impact of our transportation program.

Could you suggest how your input and guidance might be obtained? Perhaps the simplest mechanism might be for you to speak with the local manager of our program, Mr. Van Etheridge at Moreland Altobelli Associates Inc. By copy of this letter to Van, I ask that he contact you to obtain your assistance.

Very truly yours,

Jim Marshall

Mayor

cc: Van Etheridge

Chairman Justice

Bo Shippen

Maryel Battin

Kitty Oliver

Cecil McKithan

Greg Paxton

Edwards' unreleased letter: Nov. 13, 1998

The Honorable James C. Marshall

Mayor, City of Macon

P.O. Box 247

Macon, GA 31202

Dear Mayor Marshall:

I am responding to your request for a review of the proposed intersection improvements at Georgia Avenue and College Street and at College Street and Washington Street in the College Hill neighborhood of the Macon National Register Historic District.

As you know, Macon has an extraordinary heritage which is reflected in the fact that there are more properties listed in the National Register in Macon than in any other city in the state. The Macon Historic District, encompassing the historic downtown business district and the College Hill residential neighborhood, is the city's 'flagship' National Register listing --- and its first historic district listing. It is accompanied by complementary listings for early 20th Century-planned suburbs, railroad-related industrial areas, African-American neighborhoods and prehistoric archaeological sites. These historic resources have become catalysts for heritage tourism, downtown revitalization and neighborhood stabilization. Over the years, Macon has benefitted from federal and state grants and historic preservation tax incentives that have attracted hundreds of thousands of dollars of private re-investment in intown historic properties. Indeed, Macon has been a leader in capitalizing on its historic resources in the name of community development. You are justifiably concerned about maintaining the viability of Macon's historic places.

On October 13, 1998, my staff and I met with representatives of Moreland Altobelli, Macon-Bibb County's transportation planning consultants, to review the two proposed intersection improvements in the College Hill neighborhood. Also present at this meeting were Walker Rivers and his wife representing the Intown Macon Association, as well as Maryel Battin, Executive Director of Historic Macon Foundation.

Both proposed intersection-improvement projects are located in the Macon National Register Historic District; one is directly adjacent to the Raines-Miller-Carmichael House, an individually designated National Historic Landmark within the Macon Historic District. After reviewing the proposed projects and applying the same criteria and considerations that we apply to transportation projects statewide, we determined that the proposed projects would have what is called an 'adverse effect' on the Macon Historic District. This means that the proposed projects would negatively impact the historic district by diminishing its overall historic integrity and altering its historic character and appearance. The projects also would have an adverse effect on the Raines-Miller-Carmichael House (the National Historic Landmark) as well.

Specific adverse effects from the proposed projects include the following:

Encroachment by several feet into the historic properties on either side of the streets, reducing the size of the yards associated with historic houses and altering their character and appearance, primarily from widening the streets and relocating the sidewalks;

Cutting into the existing slopes of front and side yards of historic properties along the streets, necessitating regrading at sharper angles, thereby changing the historic grades of the yards;

Possibly damaging or destroying several historic street and yard trees, not so much from cutting these trees down as from ground disturbance which would damage long-established root systems;

Impacting the overall scale and character of the district by creating widened, more open intersections and diminishing the extent of historic yards, thereby changing the ratio of landscaped yards to pavement;

Encroaching upon the historic yard of the Raines-Miller-Carmichael House, a National Historic Landmark, and altering its historic setting at this intersection in the historic district.

Other adverse effects would result from increased traffic flow through this historic residential neighborhood. The introduction of more and faster-moving traffic would negatively affect the historic neighborhood character of College Hill. It would render sidewalks, front yards and front porches in the vicinity less viable for use by neighborhood residents, guests and tourists. Pedestrian travel in the area would be negatively impacted by the challenge of crossing a widened intersection with faster through and turning traffic. Increased traffic through the area could result in future demands for more 'improvements,' beginning a cycle of greater and greater impacts to the historic district.

We also would like to point out the cumulative adverse effect of these seemingly small-scaled traffic improvements to the historic district. Each of these proposed projects, although relatively small in scale in and of itself, incrementally erodes the historic fabric of the district; taken together, the cumulative negative effects of these projects can take on great magnitude. The overall effect can considerably change the historic character and appearance of the neighborhood and greatly alter its sense of time and place which qualify it for listing in the National Register. There seems to be little consideration given to the cumulative effects of all these transportation projects on Macon's historic resources in the local transportation planning process. This is akin to the phenomenon of project 'segmentation' which is prohibited in the state and federally assisted transportation projects we review. If unchecked, this piecemealed approach will tend to mask the overall negative impacts of these projects on historic resources like the Macon Historic District until they are actually implemented; then, of course, it may be too late to effectively deal with them. I would urge you to take as comprehensive look as possible to the overall and long-term effects of local transportation projects on Macon's historic resources.

We also would like to note that, in comparison to other transportation projects we review, the 'need and purpose' rationale for these proposed projects, as presented to us at our technical-assistance meeting, was less than compelling. It was not well-supported in terms of traffic volume statistics or trends, traffic delays, safety concerns, accident reports or public demand. Indeed, neighborhood representatives contend that traffic flow along this corridor actually is decreasing , which would call into question the need for the projects in light of their adverse effect on Macon's paramount National Register historic district.

Finally, and again in comparison to other transportation projects we review on a statewide basis, we would note that there seems to be a lack of meaningful public participation in the local transportation planning process, at least concerning impacts to historic properties. Local historic preservationists and neighborhood representatives have expressed frustration over their inability to learn about proposed transportation projects and to materially participate in the transportation planning process. In terms of other transportation projects we review under state and federal law, public participation is a requirement and historic preservation concerns must be taken into account at the earliest possible point. In our experience, this has helped avoid problems as well as misunderstandings early in the planning process and insures that all community values are considered at an opportune time in project development.

It would be of great help to us in future reviews of local projects to have at least basic area transportation planning information and an overall map showing the locations of all local SPLOST projects for reference. This will be of critical importance if, as was mentioned in our technical-assistance meeting, some or many of these local projects also involve state or federal transportation funds or require other federal permits (such as Corps of Engineers 404 permits) which will trigger our involvement at a later date. Again, we would prefer to be able to help you avoid problems or resolve issues at the earliest possible time, rather than to have to deal with them later in the planning or construction process when commitments may have been made and alternatives to avoid or lessen impacts precluded.

We very much appreciate your interest in historic preservation and your desire to see that historic preservation values are considered in the planning for local transportation projects in your city. As always, please feel free to call upon us again if you have further questions or need additional information.

Sincerely,

Mark R. Edwards

Director and State Historic Preservation Officer

cc:

Mr. Larry Justice, Chairman, Bibb County Commission

Mr. Bo Shippen, Intown Macon Neighborhood Association

Ms. Maryel Battin, Macon Heritage Foundation

Mrs. Kitty Oliver, Middle Georgia Heritage Society

Mr. Cecil McKithan, National Park Service

Mr. Greg Paxton, Georgia Trust for Historic Preservation

Marshall's memo to Road Officials: March 1, 1999

CONFIDENTIAL MEMORANDUM

To:

Lonice Barrett, Commissioner DNR

Ben Porter

Executive Committee Members, Road Improvement Program

Van Etheridge (for distribution to appropriate others)

John Comer and Joe Popper, Attorneys for Road Improvement Program

Pope Langstaff, City Attorney

From: Jim Marshall

Re: Letter from Mark R. Edwards, Director and State Historic Preservation Officer

Date: March 1, 1999

I am very sorry to be the bearer of bad tidings but thought you needed to know about this as soon as possible.

I am hurriedly dictating this as I try to get out of town with my wife for our trip. Your files should reflect a letter sent by Mark Edwards to me sometime last year and a letter I sent him in reply. I have not had time to review those letters, but recall that, in essence, Edwards indicated that our Roads Program might have an adverse impact on historically significant properties. I, as I recall, replied that we certainly intended to be sensitive to these issues. I also indicated that we would be quite willing to have his advice.

I attach a copy of a letter that was never sent. It is dated November 13, 1998 and addressed to me with copies to most of you. I am afraid this letter will shortly become public and that its author, Mark Edwards, will be interviewed by the press and lawyers representing CAUTION Macon. If he is, he tells me he will say the following, at least according to a telephone call I had with him today.

I understand a meeting was arranged in Atlanta sometime after this exchange. Edwards told me that, as a result of that meeting and, perhaps, some independent analysis done, he had concluded that our planning process 'was not very open' and that the plans would have an adverse effect upon historically significant properties and neighborhoods that would be a 'cumulative effect over time.' Edwards said he discussed this matter with Commissioner Barrett immediately after the meeting. He also said evidently Commissioner Barrett spoke with Ben Porter who was then Chairman of the Department of Natural Resources. Edwards also prepared the attached letter to be sent to me. I have not had time to read this letter before my trip.

Edwards said he was concerned with how the Roads Program fit with future federal programs that require Section 106 review. He suggested, as I understood it, that a Section 106 review was needed for our roads program because it was so intimately tied to the use of current and future federal funding for local roads. Again as I understood him, he was suggesting that the allocation of local funds to historically sensitive projects could not circumvent the section 106 process.

He described his conclusion that we had an 'inwardly directed planning process' instead of an 'outward one' that involved all of the affected communities in a way that would produce a plan that was a 'community winner.' He said that the entire problem 'really comes down to the approach to planning.'

In any event, Edwards told me he was told by Commissioner Barrett that Ben Porter, as Chair of the Department of Natural Resources, objected to the letter being sent. As a matter of professional integrity, Edwards then decided to submit his resignation although he said that this matter was 'not the only reason for the resignation.'

He said that his office was supposed to be independent and that a fair amount of discussion was now going on concerning 'over-reaching.' He said, 'in Ben's zeal to assure this roadway [Fall Line Freeway] is built, he is making a mockery out of the democratic process.'

Again, I have not read the letter. I thought all of you needed to know what Mr. Edwards is saying because he has said it elsewhere and I am certain that it will be brought to the attention of CAUTION Macon members, the press and CAUTION's lawyer. I don't believe I have ever met Mr. Edwards. I think this is the first telephone conversation I have ever had with him. Sorry to share the bad news. All of the quoted passages are the verbatim words of Mr. Edwards.

cc:

Mr. Larry Justice, Chairman, Bibb County Commission

Mr. Bo Shippen, Intown Macon Neighborhood Association

Ms. Maryel Battin, Macon Heritage Foundation

Mrs. Kitty Oliver, Middle Georgia Historical Society

Dictated but not read by Mayor

Mayor's Secretary's note: I also attach the referenced September 1, 1998 letter to Mayor Marshall from Mark R. Edwards and Mayor Marshall's reply letter dated September 10, 1998.

Illustration:Informational box: (1) Complete text of letters between

Edwards and Mayor