Written by:
Dabne Whitemore, Program Director, Historic Building Recovery Grant Program, Division of Historic
Preservation
With contributions by:
Kristin Sanders, Executive Management Officer/Legal Liaison, Office of Cultural Development
Nicole Hobson-Morris, Executive Director, Louisiana Division of Historic Preservation
Michael Varnado, Architectural Historian & Section 106 Reviewer, Louisiana Division of Historic Preservation
Cynthia Steward, Architectural Historian, Louisiana Division of Historic Preservation
Dr. Chip McGimsey, State Archaeologist & Executive Director, Louisiana Division of Archaeology
Rachel Watson, Archaeologist & Section 106 Manager, Louisiana Division of Archaeology
December 2013
1

The Louisiana State Historic Preservation Officer oversees the Louisiana Division of Historic Preservation and the Louisiana Division of Archaeology in the Office of Cultural Development, Department of Culture,
Recreation and Tourism, Office of the Lt. Governor for the State of Louisiana. The Office of Cultural
Development is also responsible for the Louisiana Division of the Arts and Council for the Development of
French in Louisiana.
Phillip Boggan, Deputy State Historic Preservation Officer & Deputy Assistant Secretary, Office of Cultural Development
Nicole Hobson-Morris, Deputy State Historic Preservation Officer & Executive Director, Louisiana Division of Historic Preservation
Chip McGimsey, Deputy State Historic Preservation Officer/State Archaeologist & Executive Director, Louisiana Division of Archaeology
Office of Cultural Development
Post Office Box 44247
Baton Rouge, Louisiana 70804-4247
Phone (225) 342-8200 ocd@crt.la.gov www.crt.la.gov/culture
2

3

Executive Summary
Introduction to Historic Louisiana and the Impacts of Hurricane Katrina and Rita
Overview of Emergency Supplemental Appropriation to Historic Preservation Fund for Louisiana
Part A: Historic Building Recovery Grant Program
1) Background
2) Desired Outcomes
3) Grant Program Guidelines a.
Eligibility b.
Damage Caused By Katrina/Rita c.
Duplication of Benefit and Financial Need d.
Compliance with Federal Laws and Programmatic Agreement e.
Evaluation Criteria and Application Requirements
4) Communication & Outreach a.
Public Notice and Advertising of Grant Opportunity b.
Call Center c.
Informational Presentations to the Public d.
Individual Assistance & Satellite Office e.
SPECIAL REPORT: GRANTS CLINIC
5) Grant Application Processing and Funding Determinations a.
Grant Evaluation Committee b.
Panel meetings c.
Funding Determinations d.
Appeals e.
Additional $10 million Congressional Allocation
6) Applicant Characteristics a.
Typical Sub-grantee Under HPF through the LASHPO b.
Individual Assistance c.
Group Applicants
7) Sub-grant Project Life Cycle a.
Grant Agreement b.
Scope of Work c.
Site Visits d.
Payments e.
Grant Amendments f.
Extensions g.
Project Timelines h.
Financial Documents i.
Terminations and 14 Cancelled Grants j.
Repayment Procedures
8) Sub-grant Preservation Agreement Policies and Procedures
9) National Park Service Reporting and Requirements
4

a.
NPS Quarterly Reports and Site Visits b.
Sub-grant Section 106 Review c.
Project Notifications and Environmental Certifications
10) Administrative Operations a.
Staffing and Job Descriptions i.
LASHPO Leadership ii.
Program Director iii.
Program Supervisor iv.
Project Officer v.
Administrative Coordinator vi.
Accounting Manager vii.
Accounting Analyst b.
Database and File Management c.
Office Space i.
Baton Rouge ii.
New Orleans d.
Vehicles / Mobile Office e.
Budget
11) Partnerships a.
PNOLA b.
Qatar Tremé Renewal Project c.
United Way d.
Rebuilding Together e.
Louisiana State Museum f.
Preservation Resource Center
Part B: Hurricane Recovery Grant Program Case Studies
Part C: LASHPO Section 106 & Archaeology
1) Section 106 Activities
2) Federal and State Assistance Recovery and Response Programs (This could go under Part D instead) a.
Louisiana Road Home Program – Louisiana Recovery Authority (LRA) and Louisiana
Office of Community Development, Disaster Recovery Unit b.
FEMA c.
Flood Response and Elevation d.
Hazard Mitigation e.
City of New Orleans Demolition
3) Archaeology
4) Administrative Operations a.
Staffing and Job Descriptions b.
Budget c.
Anything else that might be related to administrative operations for Section 106
Part D: Disaster Response Lessons Learned g.
GIS & Survey / Damage Assessment h.
Volunteer Response and Debris Removal i.
Building Assessments and Renovation Plans
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j.
Comprehension of Secretary of the Interior Standards k.
Contractors / Craftsmen
Appendix 1: Hurricane Recovery Printed & Published Materials/Conference Presentations
Appendix 2: Background Documents

Public Law 109-234 and 110-28

HPF Award Letters and Grant Agreements

LASHPO Action Plan Narrative

Programmatic Agreement ($11.2 million)

First Amendment to Programmatic Agreement ($10 million)

Louisiana Treatment Protocols
Appendix 3: Samples of Grant Program Documents

List of documents

Letters

Panel score sheets

Funding spreadsheets

Etc.
Separate NPS Final Report Package:
1.
Hurricane Recovery Final Report Form
2.
Hurricane Recovery Budget Documents
3.
Hurricane Recovery Required Data Documentation Form for Each Sub-Grant Project


6

This report will provide a critical assessment and analysis of the response by the Louisiana State Historic
Preservation Office (LASHPO) to the devastation caused by Hurricanes Katrina and Rita in 2005. This comprehensive review will hopefully serve to provide insights and procedural best practices to protect our nation’s most valuable historic assets and sites, but also to remind us of the needs of the individuals as stewards of these resources. These historic buildings and places are valuable to the American people, but they also serve as home and community. During a disaster scenario, the needs of both become equally important.
[To be completed when the report is finished to give the overall summary of key points]
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Louisiana has a rich and unique history in the development as a place, beginning some 12,000 years ago.
One of the most unique developments in Louisiana occurred not in the recent past, but some 3,700 to
3,100 years ago at the Poverty Point archaeological site in West Carroll Parish. For its time, this intricate complex was the largest and most elaborate in North America. Poverty Point now is a State Historic Site, a National Historic Landmark, a National Monument, and is on the U.S. Tentative List to be a World
Heritage Site.
1
The force of European contact across the American Southeast in the 16th, 17th, and 18th centuries brought collapse and social dislocation to Louisiana’s Native American cultures. Louisiana began to emerge as a colonial outpost, first of the French and then of the Spanish. The physical legacies of the colonial era embodied through historic districts across the state, the isolated plantations up and down the Mississippi River and in the Red River Valley, and the lonely frontier outposts at Opelousas,
Natchitoches, and Los Adaes are important on a national scale. They represent, individually and collectively, the immersion of European and African identities into the colonization and development of the Americas.
2
Most historians date the beginning of the historic period in Louisiana at 1682. The City of New Orleans, founded in 1718, is one of the oldest cities in the United States. In 1803, Napoleon sold the vast
Mississippi Valley territory to the United States through the Louisiana Purchase and in 1812, Louisiana officially became the 16th state in the Union. The principal city, New Orleans, was the nation’s second busiest port after New York.
Louisiana’s history of French and Spanish colonization set it apart from other places in the United States in many ways, not excluding its African American experience. The French and Spanish laws, which dictated the rights and allowable treatment of people of African descent, set the foundation for African
Americans in Louisiana. There were free people of African descent in Louisiana as early as 1722 and in the antebellum years, Louisiana came to have one of the largest populations of Free People of Color in the United States and the largest in the lower South. Louisiana’s population of African descent was composed of a large number of Louisiana-born people, or Creoles.
3
There was a significant natural increase in growth of New Orleans’ black population between the years
1766 and 1785, from 3,971 to 10,420. While most people of African descent arrived in Louisiana as slaves, many were able to gain their freedom and live as free persons in the colony. The 1791 census of
New Orleans provides a rough idea of the breakdown between enslaved and free people in the city: it
1 Louisiana State Plan for Historic Preservation 2011-2015, January 2011, http://www.crt.state.la.us/HP/SHPO_Jan_2011.pdf
2 Ibid.
3 Blokker, Laura Ewing, The African American Experience in Louisiana, May 15, 2012, historic context for the National Register of Historic Places http://www.crt.state.la.us/hp/nationalregister/historic_contexts/The_African_American_Experience_in
_Louisiana.pdf
8

lists 2,386 whites, 862 Free People of Color, and 1,789 slaves. By 1803, Free People of Color comprised approximately one-seventh of New Orleans population. By 1830, New Orleans’ black population was
28,595 – approximately half of which was free – while there were an estimated 21,221 whites.
4
Louisiana came into its own as a commercial economy built upon cotton, sugar, and enslaved labor. The plantations located on the Mississippi and Red Rivers, and over into the bayou country of the Lafourche and Teche districts, produced immense crops that were then moved by water to New Orleans, and then from this great metropolis to overseas markets. Plantation society in the state evolved along its own trajectory, varying from region to region both by the crops grown and the ethnic origins of planters and slaves. Other areas of Louisiana attracted migrants with different ethnic heritages and cultural characteristics. Each of these communities persisted with their own identities and customs, often down to the present day.
New Orleans remained a world unto itself, a vast and diverse port city that numbered almost 170,000 by
1860 compared with Baton Rouge, the state capital, which was home to fewer than 6,000 persons. As a fully-formed city by the time of the Civil War, New Orleans’ built environment accommodated an impressive array of architectural styles that met its housing and commercial needs, making it today one of the most rich areas of historic structures.
5 There are over 20 nationally registered historic districts and more than 50,000 historic buildings identified as contributing elements making New Orleans ranked number 1 in the United States with the most number of historic buildings.
6 More importantly, according to the 2000 U.S. Census, over 92,900 (43.2%) of housing units were built before 1949, or over 50-years old, thus meeting the age requirement for the National Register of Historic Places.
On August 29, 2005, Hurricane Katrina hit the State of Louisiana, claiming the lives of 1,580 Louisiana residents and displacing 1.3 million Louisianans.
7 By August 31, eighty percent (80%) of the city of New
Orleans was flooded by Hurricane Katrina, with some parts of the city under 20 feet (6.1 m), of water.
Over 50 breaches in the region's levee system occurred, five of which resulted in massive flooding of
New Orleans.
Katrina was the costliest natural disaster in United States history. When Hurricane Rita made landfall along the Texas/Louisiana border just three weeks later on September 24, 2005, it was a category 3 hurricane with winds in excess of 120 miles per hour pushing a 20-foot storm surge. The devastation it left behind made it the fourth most expensive natural disaster.
According to the Louisiana Recovery Authority (LRA), 123,000 homes in the state suffered major or severe damage and 82,000 rental properties suffered severe damage. In addition, more than 18,000 businesses were destroyed and approximately 178,000 jobs were lost in the New Orleans area alone.
Combined, the storms destroyed more than 10 hospitals and 40 schools, with damage to an additional
835 schools, and destroyed over 200 square miles of Louisiana marshland. The LRA also reports that 25 times more debris was removed from the state than was removed from the World Trade Center site in
4 Ibid.
5 Louisiana State Plan for Historic Preservation 2011-2015, January 2011, http://www.crt.state.la.us/HP/SHPO_Jan_2011.pdf
6 US Department of the Interior, National Park Service, National Register of Historic Places
7 Louisiana Recovery Authority, “Hurricane Katrina Anniversary Data for Louisiana,” August 20, 2006, http://lra.louisiana.gov/assets/docs/searchable/LouisianaKatrinaAnniversaryData082206.pdf
9

New York. Finally, according to the LRA, Louisiana had more than twice the severe damage to homes as
Alabama, Mississippi, Florida, and Texas combined.
In addition to the tangible losses captured daily, weekly and then monthly on the news, HBRGP project officers witnessed firsthand as many of the grantees, their families, friends and neighbors confronted the damages and losses to their communities and their lives as a whole. It became glaringly clear to our office very early that the human psyche too would need to be seriously considered throughout the recovery process. As the water receded and volunteers came and went, residents were still left with the undeniable loss of their familiar spaces. Many New Orleanians witnessed their homes get consumed by intense water surges resulting from one of the many breaches that occurred in Orleans Parish. Others witnessed the destruction from the televisions of family and friends at a distance, while yet another group had to be evacuated from the area on “rescue buses” and brought to another state. This added yet another difficult layer to the recovery efforts. The HBRGP had a number of applicants who applied while still located in other parishes or states. More than 30 parishes across south Louisiana saw their governmental sectors and educational systems impacted due to a whole or partial loss of staff and buildings, damages to roadways and infrastructure, and loss of electricity, just to name a few. The sheer density of the housing stock in the New Orleans urban environment, which boasted the largest number of historic districts in the Nation, per capita, presented a tremendous recovery challenge. Orleans Parish held the largest number of applicants to the HBRGP program. Therefore, much of this report will focus on the recovery efforts associated with projects located in that parish.
At the time of the disaster, the National Register of Historic Places listed approximately 1,275 properties and sites in Louisiana. All parishes in the State of Louisiana were Presidentially-declared disaster area.
The Gulf Opportunity Zone (GO Zone) established by Congress covered the core-disaster area, which incorporated parishes hit by Hurricanes Katrina and Rita, respectively. Table 1 summarizes the GO Zone parishes and historic properties as designated by the National Register of Historic Places.
Table 1. Gulf Opportunity Parishes (GO Zone) and National Register of Historic Places
Designations in Southern Louisiana
Region Parish (County)
Figure 1. Louisiana Planning Regions Source:
Louisiana Division of Administration National
Register
Records
National
Register
Historic
Districts
Certified Local
Governments
(*also a Main Street
Community)
1
1
Orleans
St. Tammany
143
39
23
2
New Orleans* †
Covington
Slidell*
1 Jefferson
1 St. Bernard
1 Plaquemines
2 East Baton Rouge
19
8
8
85
1
2
0
9
Kenner
Baton Rouge
2 Tangipahoa 32 4
2
2 West Feliciana
2 East Feliciana
2
2 Ascension
2 Washington
2
Pointe Coupee
Iberville
West Baton
32
31
31
22
20
15
13
0
2
1
1
1
0
2
Hammond*
Ponchatoula*
New Roads*
St. Francisville*
Clinton*
Plaquemine*
Donaldsonville*
Bogalusa*
10

2
Rouge
Livingston
2 St. Helena
3 Lafourche
3 St. James
3 Terrebonne
3 St. John the
Baptist
3 Assumption
3
4
4
4
St. Charles
St. Landry
Iberia
St. Mary
12
2
22
21
17
16
10
6
37
30
27
0
0
1
1
1
1
0
0
3
1
1
Denham
Springs*
Thibodaux*
Houma*
Eunice*
Opelousas*
Jeanerette
New Iberia*
Franklin*
Morgan City*
Figure 2. Gulf Opportunity Zone Parishes
Source: Louisiana Economic Development
4 St. Martin
4 Lafayette
4 Vermilion
4
4
5
Acadia
Evangeline
Calcasieu
25
24
17
7
6
18
2
2
2
1
0
1
St. Martinville*
Abbeville*
Crowley*
Mamou
Ville Platte
DeQuincy
Lake Charles
5 Jefferson Davis
5 Beauregard
5 Allen
5 Cameron
18
14
4
2
0
1
0
0
DeRidder*
Kinder
6 Vernon
7 Natchitoches
16
30
1
1
Leesville*
Natchitoches*
7 Sabine 7 1
† The City of New Orleans is not a designated Certified Local Government as defined by Louisiana state law, which requires a single agency. The City of
New Orleans has two agencies – the Historic District Landmarks Commission (HDLC) and the Vieux Carre Commission (VCC).
In 2005, Orleans Parish had 143 National Register records which include individually listed properties and historic districts. In a historic district, all the contributing elements within the district also qualify as historic buildings and are eligible for the same benefits as individually listed properties. Counting individually listed properties and contributing elements to historic districts, the total number of potentially impacted historic buildings in Orleans Parish was over 45,000. Table 2 provides a summary of the number of structures and contributing elements in each National Register historic district. The shaded sections represent Orleans Parish historic districts where the most significant flooding occurred during Hurricanes Katrina and Rita.
11

Table 2. Structures and Contributing Elements for Orleans Parish National Register of Historic Places designated Historic Districts. Source:
Nomination documents, Louisiana National Register Database.
National Register of Historic Places,
Historic District Name
Number of
Structures
Number of
Contributing
Elements
Locally
Regulated
Total
Impacted
Broadmoor Historic District
Bywater Historic District
1,075
2,050
940 -
1,785 HDLC
Carrollton Historic District
Central City Historic District
Esplanade Ridge Historic District
6,220
4,013
4,146
5,143
3,531
-
-
3,843 HDLC
Gentilly Terrace Historic District
Holy Cross Historic District
Lower Central Business District
Mid-City Historic District
New Marigny Historic District
Parkview Historic District
665
857
290
4,498
3,533
1,349
544 -
634 HDLC
259 HDLC
3,567
2,826
1,239
-
-
-
24,913
South Lakeview Historic District
Upper Central Business District
Algiers Point Historic District
Faubourg Marigny Historic District
Garden District
Irish Channel Area Architectural District
Lower Garden District
Uptown New Orleans Historic District
Vieux Carre
Pontchartrain Park – FEMA eligible
Edgewood Park – FEMA eligible
164
512
1,763
164 -
438 HDLC
1,670 HDLC
2,100
1,137
2,000
2,100 HDLC
951 -
2,000 HDLC 18,201
1,180 956 HDLC
10,716 8,787 -
2,039 1,737
VCC
50,307 43,114 10 43,114
Waiting for any stats from NR Program on these nominations or other information
Old Arabi Historic District (St. Bernard) 140 106 -
Friscoville Street Historic District (St.
Bernard)
Denotes higher levels of flooding
95 71 -
The State of Louisiana found itself in the midst of one of the largest urban renewal projects ever undertaken in this country given the level of damage and destruction. After many of the roads were cleared, the LRA began meeting in various parishes with community leaders, elected officials, public policy makers, planners, developers and interested parties to develop a Planning Tool Kit and Pattern
Book with the mission of helping to guide the overall rebuilding process in the State. As planning scenarios unfolded, some communities in the city of New Orleans were not targeted for redevelopment, including Holy Cross and Broadmoor. In addition, areas of Mid-City were slated for massive demolition
12

to allow for two new hospitals. On August 20, 2006, the LRA issued a one-year status report with the following to-date figures for the New Orleans Metropolitan Statistical Area (MSA):

Continued loss of 225,000 residents

Continued loss of 183,000 jobs

81,688 living in Federal Emergency Management Agency (FEMA) trailers, of those 16,245 located at group, commercial, or industrial sites

Public transportation operating at 17%

Former utilities customers at 60%

Only 3 of 7 hospitals opened

Portions of the Lower Ninth Ward and Plaquemines Parish were under a boil water advisory

7,300 participated in planning meetings focused on rebuilding
Much of the recovery efforts were dependent on the outcomes of massive rebuilding efforts, which in turn were heavily dependent on the availability of financial resources. There were concerns regarding the status of historic buildings and entire communities as property owners realized they were significantly under-insured, if at all. In Louisiana, 26% of owner occupied units did not have any insurance and for 33% of flooded properties, owners carried hazard insurance but no flood insurance because it was not required. Further, many residents were not fiscally solvent to cope with needed repairs. Based on figures from the 2000 U.S. Census for Orleans Parish, 27% of the population
(approximately 130,000 people) is officially listed as living below the federal poverty line. The median household income was $27,143, and the median rent was $488 per month.
FEMA’s Individual and Household coverage for property owners was limited to either $5,200 to make emergency repairs or $10,200 for replacement housing. All property owners were referred to the Small
Business Administration (SBA) program and if not financially capable, a FEMA grant could be issued.
Individuals were required to handle FEMA awards and applications and individuals were required to apply for funding provided through the U.S. Department of Housing and Urban Development (HUD) and the Community Development Block Grant (CDBG)awarded to the Louisiana Recovery Authority, specifically The Road Home Program. As of December 28, 2006, only 101 closings for funding had been made and by August 9, 2007 only 41,619 closings had been handled for the estimated 515,000 properties damaged statewide.
13

The LA SHPO was a different agency than what would be required after August 29, 2005. Funds received by the LASHPO from the Historic Preservation Fund (HPF) typically supported a small number of grants to Certified Local Governments (CLG) and provided training CAMPS to the CLGs. Approximately two or three Historic American Building Survey (HABS) projects conducted by local universities and two or three survey projects were funded annually. Funding through HPF was approximately $350,000 for grants with the remaining funds supplementing staff salaries to carry on the mandated duties of the SHPO.
Staff provided centralized services, drafting 99% of the National Register nominations presented to the
National Register Review Committee, reviewing applications for and providing technical assistance to applicants of the federal tax credit program, and reviewing approximately 2,700 Section 106 reviews yearly, in addition to other requests for assistance. LASHPO relied on a strictly paper-based system of filing and information sharing. Maps existed on paper and had yet to be scanned into a Geospatial
Information System (GIS). Because of the dense urban building stock in New Orleans, nominations existed without surveys to identify many of the structures located in any of the 20 plus districts.
Hurricane Katrina precipitated a dynamic change to the LASHPO. Immediately following the disaster, the LASHPO began to work with FEMA, as part of the Section 106 process, to address cultural resources impacted by the devastating hurricane. The LASHPO assigned two of their existing staff to act as liaisons to FEMA until actual liaisons could be hired to fill the positions. Because of the widespread damage to, versus total loss of, the built and archaeological environment, and in an effort to expedite the eligibility determination process, LASHPO National Register staff accompanied FEMA in conducting
“windshield” surveys in many damaged areas across Southeast Louisiana. The SHPO Section 106 staff
(of one) then worked with the FEMA environmental review staff to assess effects. LASHPO and FEMA conducted the following “windshield” surveys:

September 13, 2005 – New Orleans

September 27, 2005 – Slidell and Covington

September 29, 2005 – St. Bernard Parish

October 3, 2005 – St. Bernard Parish

October 5, 2005 – St. Bernard Parish

September 30, 2005 – Opelousas

November 20, 3005 – New Orleans: Legislative and Federal Agency Tour

January 18, 2006 – New Orleans
The LASHPO was not prepared for the increased caseload of federally mandated reviews resulting from
Hurricanes Katrina and Rita. The caseload of Section 106 Reviews increased from 2,705 reviews in 2005 to more than 23,000 by the end of 2006. In addition to the SHPO/FEMA liaison, the LASHPO was later able to hire two temporary staff to handle the influx of reviews from areas across South Louisiana relating to hurricane recovery efforts. By 2006, the LASHPO had also begun to work with FEMA and other agencies on multiple Programmatic Agreements to address the recovery process.
On June 15, 2006, Public Law 109-234 authorized an Emergency Supplemental Appropriation to the
Historic Preservation Fund (ESHPF) for the states of Louisiana, Mississippi, and Alabama that would
14

cover necessary expenses related to the consequences of Hurricane Katrina and other hurricanes of the
2005 season. Under this law, Congress awarded $39.45 million for grants and $3 million to support
Section 106 assistance for the three impacted states. The National Park Service (NPS) released
Louisiana’s grant agreement and a total amount of $12.5 million for Louisiana on July 24, 2006 requiring the submission of an Action Plan within 30 days. The NPS Action Plan required details on the services to be provided, problems to be addressed, a preliminary proposed list of projects and the expected results.
While Louisiana had been aware of efforts to receive an additional appropriation, many Legislative initiatives do not achieve enactment. Given the 30 day deadline, the LASHPO did not feel it was in the best interest of the public to publicize a potential grant program and pre-select proposed projects unless the overall plan was approved by NPS and the funding available for immediate distribution. Louisiana’s
Action Plan included the services to be provided along with the draft versions of grant program guidelines, an application form, a description of Section 106 activities and staffing, the archaeology work plan, and a staffing structure under the terms of the funding. On September 28, 2006, NPS submitted a letter approving the Action Plan, and the LASHPO immediately began implementing the Action Plan, specifically releasing the grant program guidelines and staffing the Section 106 program.
Based on the significant level of damage evidenced in the grant program application process and the sheer volume of eligible applications received, on May 25, 2007 Congress approved a $10 million increase to Louisiana’s funding allocation through Public Law 110-28. Louisiana was the only state to receive an additional allocation of funding. The total NPS funding to the LASHPO is summarized in Table
3, below.
Table 3. Summary of Louisiana’s share of the Emergency Supplemental Appropriation to the Historic Preservation Fund, 2006 and 2007
Purpose NPS Grant# Amount Total
Grant Program

Restoration of historic buildings

Project management assistance

Planning
22-06-HR-21572:
22-07-HR-21671:
$10,575,000
$ 9,500,000
$ 20,075,000
Section 106 for all federal projects in
Louisiana
Administrative costs
22-06-HR-21572:
22-07-HR-21671:
$ 1,300,000
$ -
$ 1,300,000
22-06-HR-21572:
22-07-HR-21671:
$ 625,000
$ 500,000
$ 1,125,000
22-06-HR-21572:
22-07-HR-21671:
$ 209,567
$ -
$ 209,567 National Alliance of Preservation
Commissions Conference, July 2008
The following sections of this report will detail the administration of the ESHPF, including the grant program, Section 106 activities, and the administrative functions established as a result of the funding.
A summary of all publications and events along with case studies of key projects is also included. Final project forms are included for each project in Appendix A. The LASHPO hopes to show the complexities that arose during this 7-year program and provide some suggestions for both policy and procedural improvements. Within the report, sidebars called “Lessons Learned” will provide key insights on how the LASHPO would do things differently in the future. These “Lessons Learned” consider the conditions
15

that existed at the time, how we might have changed the program for greater benefit and suggestions for global change in the event of a future disaster.
16

17

Since the late 1970s, the NPS provided funding to all State Historic Preservation Offices through the HPF
Program under the National Historic Preservation Act of 1966 (NHPA). Each year, the LASHPO typically awards approximately $350,000 in sub-grants to roughly 10-15 organizations across the state for historic preservation projects. The funding provides a service to the American people by protecting nationally recognized historic resources and ensuring these assets are available to the public for the future. In
Louisiana, funding is typically provided for local programs and documentation services through two types of sub-grantees. First, Louisiana’s 45 CLGs apply for funding through a mandatory allocation per
NHPA. These projects include but are not limited to:

Design guidelines for the local historic districts

Local survey and historic resource inventories

Feasibility studies on single historic buildings or groups of historic buildings

Condition assessments and historic structures reports

Public information, education, or tourism projects relative to historic preservation

Training programs for CLG staff and officials
Other sub-grantees include historical and preservation advocacy organizations, parish governments, economic development districts, planning commissions, museum houses, state agencies, municipal governments, educational institutions and historic district commissions. Types of projects typically include:

Regional, parish, and local historic standing structure surveys where no surveys or only partial surveys have been completed

Development of historic structure reports

HABS Program and using HABS as an educational tool
The ESHPF was the first specific appropriation for repairs to historic buildings the LASHPO implemented at such a grand scale and awarded to individual property owners, rather than local government agencies or nonprofit organizations. This shift from overseeing a small number of sub-grants to managing over
550 sub-grantees created a significantly different role for the agency. The decision to offer mini-grants up to $45,000 was intended to help more Louisiana residents return home but it also meant a larger pool of applicants, many of whom had no knowledge of the Secretary of the Interior’s Standards for the
Treatment of Historic Properties.
When funding for this program was awarded under National Park Service Grant Agreement 22-06-HR-
21572, Special Condition #20 called for the submission of a revised Action Plan Narrative and Project
Budget. This document was to be submitted within 30-days and include major services to be provided, the problems to be addressed, a preliminary list of proposed projects, and the expected results. Using
Public Law 109-234, staff eyewitness accounts of damage, and other damage and recovery data being circulated, the LASHPO created a grant program that would best address the needs and circumstances at that point in time -- one year to the day Hurricane Katrina made landfall.
18

This program sought to deliver immediate results that were essential to Louisiana’s recovery. The lack of preparation in the New Orleans area prior to Hurricane Katrina resulted in an unprecedented effort by the city of New Orleans and the State to move people out of harm’s way, resulting in the relocation of Louisiana residents to other states like Texas, Georgia, South Carolina, and North Carolina. Mitch
Landrieu, Lt. Governor of Louisiana at the time of the Hurricanes, pushed for programs that would aid in helping Louisiana residents return home. The need for funding was immediate and wide-spread. The
HBRGP would plan an important role in the recovery process, as it sought to begin to restore historic properties as well as repopulate hurricane-devastated communities. Many individuals did not have any additional funds, or were uncertain of the amount that would be available from either insurance or other disaster recovery programs. The priority of the LASHPO’s funding became immediate relief and immediate distribution of funds. The LASHPO developed the HBRGP grant program with the following outcomes in mind:
1.
Get the funding where it is needed as quickly as possible. The LASHPO’s first goal was to disburse funds to sub-grantees as quickly as possible so that the rebuilding process could begin.
This was achieved three-fold. First, through making the grant program available to the public immediately following approval of the Action Plan by the NPS. The window of opportunity to apply for funds was limited to two months so those that were the most prepared to apply would be in a position to submit the application form and begin repairs immediately, if funded. Lastly, all applications were to be processed and funding decisions made within 45 days, or by January
31, 2007. Returning property owners to their communities would limit the number of individuals settling in another city or state, thus limiting further loss of historic buildings through abandonment and blight.
2.
Allocate a substantial number of relatively small grant awards to benefit the greatest number of property owners . Sub-grant funding was restricted to between $5,000 and $45,000 to provide funding to a larger number of damaged properties and to open the opportunity to all
45,000 eligible historic properties not just a select few.
3.
Allocate relief grants broadly to give the program maximum reach.
The smaller grant award allowed a broader range of options for what damage could be repaired with grant funds. A property had to fit into one of the general funding objectives and no single funding objective was given priority. The three general funding objectives were: a) Secure historic buildings made structurally unsound by the storms b) Make structurally sound historic buildings habitable c) Preserve historic architectural character by repairing or replacing missing or damaged architectural features.
Louisiana was in a challenging situation. The allocation of the ESHPF allocation allowed the LASHPO to significantly impact historic preservation in Louisiana. However, given the limited resources initially allocated of $9.5 million and the significant demand for these resources, the challenge was making a significant impact in a targeted and strategic way. Rather than the impact being quantified by individual buildings, it was the ability to begin the renovation process or to bring to completion a stalled project due to lack of funds. Walter Gallas, then director of the New Orleans field office of the National Trust for Historic Preservation, summarized the situation well:
19

“The decisions we made were difficult ones,'' Gallas said, adding that he hopes the grants will serve as a "catalyst'' in those communities.
8
Overall, the LASHPO hoped the funding would provide immediate relief and action within communities. This funding showed that the people of Louisiana, and , of New
Orleans in particular, were ready to come back home, ready to rebuild, and cared about the unique and historic character of the neighborhoods they called home.
The Grant Program Guidelines (Guidelines) were submitted in draft form to the National Park Service on
August 24, 2006 as a part of the Action Plan. NPS approved the Guidelines and intent of the grant program and the Grant Program was activated on October 1, 2006.
The Guidelines included the basic rules and requirements of the grant program and an application form. Both were intended to be user-friendly for potential applicants that were typically unfamiliar with either grants program or historic preservation jargon. Ease of use in completing the application was also paramount and was intended to offset much of the negative press associated with other recovery programs that were difficult to navigate and required significant levels of documentation. The HBRGP requirements were limited to basic photographic documentation, yes and no questions, and minimal scope of work descriptions to correspond with the photographic documentation.
Further, when the Guidelines were circulated, the
Programmatic Agreement between the states and the NPS was not yet finalized; as a result, any information regarding potential sub-grant requirements, such as those regarding adverse effect determinations, was not included in the Guidelines. The Guidelines were also limited in the amount of information contained on the Secretary of the
Interior’s Standards
Properties
for the Treatment of Historic
as well as pertinent information from the
Historic Preservation Fund Manual. The four key elements included were:
LESSONS LEARNED
One funding objective was missing within
Louisiana’s grant program. Generally, we were able to account for the situation and address the needs at the time - the slow pace of recovery funding to begin rebuilding except for those who were insured, the relative unknowns regarding the needs of historic buildings, and the need to reach many individuals rather than a relative few. In hindsight, an additional objective could have been added:
Implement a targeted, cluster approach to investing rebuilding dollars.
This objective could have been achieved twofold:
(1) Determine priority locations based on damage, and/or
(2) Assess block-by-block locations for concentrated development
Targeted development with multiple properties in one location can provide a greater catalyst than funding a single property on a street or general area. In some circumstances, if the integrity of the surrounding properties is high and the potential is high for a single renovation, those situations can also serve as a more significant catalyst for a neighborhood, impacting the overall district more significantly.
During the grant funding process for the Mid-
City Rehabilitation Grant Program that resulted from the demolition and removal of 27-blocks within the Mid-City National Register Historic
District. This sentence is missing words.
BUY THE BOOK! One Block: A New Orleans
Neighborhood Rebuilds by Dave Anderson. The book looks at the rebuilding efforts of one block in the Holy Cross National Register Historic
District. Almost half of the block received an
HBRGP grant.
1) Eligibility
2) Congressional mandates according to Public Law
8 Gyan, Joe Jr., “Grants to rebuild historic La. Homes,” Advocate, The, Baton Rouge, LA, Wednesday,
February 28, 2007 - Wednesday, February 27, 2007
20

109-234
3) Evaluation Criteria for selection of grant recipients
4) Application Form and submittal requirements.
Each of these items is detailed below with regards to implications regarding the Guidelines and
Application process. A copy of the grant program Guidelines and Application Form booklet is included in
Appendix C.
To reach the broadest constituency possible, the only criterion established to be eligible for the grant the National Register status of the building. Any historic building considered eligible for the National
Register was considered eligible for the grant and no building was given preferential treatment over another. National Register Status was classified in five ways as follows:
1.
Individually listed on the National Register
2.
Individually eligible for the National Register
3.
A contributing element in a National Register historic district
4.
A contributing element in a historic district being officially treated as eligible for the National
Register by mutual agreement of the SHPO and FEMA 9
5.
A contributing element in a historic district that is being proposed by the SHPO or FEMA to be treated as eligible for the National Register 10
In addition to the basic eligibility criterion, Congress mandated three requirements, discussed below, as it pertained to the use of grant funds: damage caused by Hurricanes Katrina or Rita; no duplication of benefits; and financial need
When Congress approved a supplemental appropriation to the states of Alabama, Mississippi, and
Louisiana through the NPS’s HPF program, the appropriation was to be used solely for recovery from
Hurricane Katrina and Hurricane Rita and not for general historic preservation activities. Property owners seeking funding not due to hurricanes – those looking to strictly rehabilitate a historic building - were not eligible to apply. Since this funding was statewide, this was an important distinction to make for any person who owned a historic property. To ensure funding was only available to hurricanedamaged properties, the application form required photographic documentation of the current condition of the building in addition to applicants signing the “Certification Statement” asserting all proposed construction/renovation work was hurricane related. Ideally, the program would have required photographic or other form of documentation as to the condition of the property prior to the storms; however, many property owners lost all personal effects and contents due to flooding, and this level of documentation was not readily available. Further, applications were accepted by individuals that purchased or acquired the property since the storm, in which case no previous documentation would have existed on the building. Rather than place requirements that could not be met, by act of an original and dated signature by the applicant, the LASHPO accepted the damage as hurricane-related.
9
During the FEMA resurvey of Orleans parish National Register Historic Districts, the LASHPO concurred with the following proposed historic district boundary expansions and potentially eligible districts: Bywater Historic District expansion, Edgewood
Park proposed district, Esplanade Ridge expansion, and Pontchartrain Park proposed district.
10
During the FEMA resurvey of Orleans parish National Register Historic Districts, the LASHPO proposed two additional
National Register Historic Districts for expansion: Broadmoor and Carrollton. These districts were not recommended by FEMA, but for the purposes of the grant program, the LASHPO considered buildings in these sectors.
21

LESSON LEARNED:
The challenge faced by the LASHPO was that many historic buildings had deferred maintenance issues that needed to be addressed, in addition to hurricane-related damage. To repair hurricane damage without first addressing pre-existing deficiencies in the building was often impossible because each part of the building assembly that relied on another element became impacted when work began. It did not make sense to pull the funding on a project solely because of pre-existing damage. Further, many property owners did not have funds to fix the pre-existing damage with their own funds. Therefore, the
HBRGP program allowed “associated repairs” to be eligible for funding as a means of completing the item outlined in the project scope of work. The “big picture of recovery” required a level of compromise in a time of uncertainty and despair.
A second Congressional Mandate required funding not to be used for work already funded by an insurance settlement or by other recovery dollars available. The Action Plan submitted to the National
Park Serve was explicit in this requirement:
We will prohibit using these funds to pay for work already covered by insurance settlements or other recovery dollars made available to the applicant.
11
The LASHPO’s understanding was that the grant opportunity would be an offset of insurance settlements or other recovery funding. The expectation was two-fold: (a) potential applicants would have received a sufficient insurance settlement, but the insurance settlement did not account for the higher cost and (b) that other recovery funds were already being distributed for recovery, and the ESHPF funding would offset those proceeds.
As language for the application form was developed and the policy was translated to procedure, the
“Duplication of Benefit” mandate had two implications as it pertained to insurance settlements and other recovery programs:
1.
The LASHPO would need full disclosure of the applicant’s insurance settlement and status, and for mortgaged properties, any lender requirements
2.
The LASHPO would need full disclosure on the cost estimation process, application timeline, and distribution of other recovery dollars, through both the FEMA and the LRA.
Both requirements would require a significant amount of documentation and in the case of other recovery dollars, strong, working relationships with other state recovery leaders would be needed.
Neither were viable options procedurally. The media was reporting the soaring number of claims by insured individuals that the insurance companies were undervaluing damage or repairs. For others, mortgage lenders were also co-signers on insurance settlement checks and then either kept the settlement to pay off or reduce the mortgage owed as a way to limit the holding of overvalued property.
In other circumstances, property owners paid off mortgages with the insurance settlement. Imagine one year after a storm and no neighbors have returned to your street and you are currently holding a
$100,000 mortgage with the bank but also have a large insurance settlement check to complete repairs.
The dilemma was do you repair your property and risk not being able to sell the property or having the bank foreclose, or do you pay off the mortgage and not make the needed repairs? For many, the only
11 Louisiana Action Plan to National Park Service, page 5, the Selection Process
22

financially viable option was to pay off the mortgage. Another issue encountered was the ability to cover day-to-day expenses. Many were forced to use insurance settlements to maintain their livelihood and to cover day-to-day expenses, in particular if an individual was displaced, unable to live in their home, living in a FEMA trailer, or jobless. These
Application Questions on
Duplication of Benefit financial realities caused many individuals to use dollars already awarded for building renovations on other uses.
Another factor affecting the LASHPO’s ability to verify duplication of benefits was the slow pace of other recovery dollars through the LRA and the Road Home Program for those that were uninsured or under-insured. As previously stated, by
December 28, 2006, only 101 closings for funding had been made for the roughly 515,000 estimated damaged buildings statewide. By August 9, 2007, the number of closing would jump to 41,619 closings, but still far short of the total number eligible for benefits. Additionally, there was not a history of the
LASHPO being included with other state recovery program operations. The LASHPO did not have an established seat at the table with other state recovery programs and did not have the inner working knowledge to evaluate duplication of benefit as it pertained to other recovery dollars.
When the application opened on October 1, 2006, DHP applied the Congressional Mandate of “No Duplication of Benefit” as broadly as possible to ensure the HBRGP would not cause undo delays or burden to any potential applicant. The desired outcome was to move this funding swiftly. By limiting the level of documentation, the amount of staff time to review application and the amount of time it would take an applicant to complete the application was reduced drastically. The
LASHPO determined the application process would rely solely on the status of the applicant’s insurance and financial situation at the point in time the application was due. As a result, the application form required very basic questions to be completed and relied on the honesty and integrity of the applicant by signature of the Certification Statement.
8. Insurance: Have you received or do you expect to receive any insurance proceeds as a result of damage caused by either Hurricanes
Katrina or Rita?
 YES  NO
If YES, did your insurance settlement allow for repair or replacement of your building’s historicallysignificant features, including (but not limited to) hard roofing (i.e. slate, tile or metal); ceramic ridge caps, ceramic or cast iron cresting; copper or galvanized metal flashing, gutters and downspouts; decorative brick chimneys; or decorative trim
(brackets, cornices, parapets, handrails, door surrounds, soffits, and fascias)?
 Yes  No Briefly explain.
9. Other Assistance: To date, have you received any other hurricanerelated assistance from any other source for the purpose of repairing, restoring or stabilizing your property?  YES  NO (Note: If
YES, grant awards cannot be used for work already funded by other sources, including insurance).
Certification Statement…I further certify that funding sought is in no way a duplication of benefits received from any other source, including insurance proceeds, charitable donations of labor or materials, or other hurricane recovery funding sources...
Another component of the Congressional mandate was to ensure the funding made a difference in cases in which there was a financial need. There were two components of this policy, one of which was related to duplication of benefits. For instance, if a property had a tile roof, but insurance only covered the cost of a shingle roof, there would be a qualified financial need as the insurance settlement was not sufficient to cover the added cost of repairing the tile roof. The other component of the policy was to evaluate applicant responses related to a specific financial need of the individual property owner.
Translating these components from the Action Plan to the Grant Guidelines and then to Application
23

Form varied greatly. The following is the difference in language used regarding Financial Need and how financial need was interpreted:
Action Plan: “Importantly, we will prohibit using these funds to pay for work already covered by insurance settlements or recovery dollars made available to the applicant.
Rather, we will see that these funds are used to make a difference in cases in which there is a financial need. Thus, applicants will be invited to submit a statement of financial need along with any relevant supporting materials.” 12
Under the Action Plan, it was assumed that if insurance settlements were provided, there was no financial need.
Guidelines: “Applicants will need to include a statement of financial need within their applications, and state their commitment to rebuild and remain in the community. Such a statement should include any appropriate documentation that supports the claim of financial need.” 13
Application Form: “Question 7.D. If you do not receive this grant, are you unable to afford the costs associated with this project? YES NO
Between the three documents, there were three requirements stated, but in the end, our agency could only evaluate what was provided in the application form. This question as worded ended up being too confusing for most applicants. Further, there was no place on the application form that indicated a Statement of Financial Need was required. A statement was added to the application in late November year? to help clarify the Statement of Financial need as described in the Guidelines. As the original intention in the Action Plan was to make this only a suggestion, it really ended up making a difference as to who would receive a grant or not. If an applicant knew to include this statement, then the personal circumstances swayed the panel more so than those that did not include the Statement and simply answered the question. For most evaluators, though, the answer became whether or not the applicant received insurance or not, considering an average of 44 percent of buildings without flood insurance had flood damage and over 16 percent of buildings without flood damage had no insurance.
14
In order to realistically evaluate the financial need of any applicant, we would have required submission of financial statements, tax returns, bank statements, most recent earning statement, etc. This would have provided insight into how much money an individual earned.
Rather than approach the evaluation of financial need in this way, the objective was to standardize and simplify the responses to simple YES or NO answers in order to reduce documentation applicants were required to submit.
12 Louisiana Division of Historic Preservation Action Plan Narrative, The Selection Process, page 5-6.
13 Historic Building Recovery Grant Program Guidelines and Application Form Booklet, page 6, Financial Need section.
14 United States Department of Housing and Urban Development, Office of Policy Development and Research,
“Current Housing Unit Damage Estimates, Hurricanes Katrina, Rita, and Wilma - Orleans Parish, LA Total Housing
Damage,” February 12, 2006, revised April 7, 2006, page 23.
24

LESSON LEARNED:
Financial need was interpreted by different grant evaluation committee members in regards to properties purchased after the storms. There was not a uniform standard for determining if those individuals should be uniformly qualified; therefore, a property reviewed by one panel may have had a distinct advantage over a property reviewed by another review committee. A noted complication to the evaluation was the grammatical usage of the application question. A double negative was used for a Yes or No question:
“Question 7.D. If you do not receive this grant, are you unable to afford the costs associated with this project? YES NO” - The correct answer to qualify for a financial need was
“YES.”
Additionally, the application form did not refer to the statement of financial need, even though this was one of the evaluation criteria. There was also confusion as to whether or not this should have been required, or if it should have been requested. See language from the Action
Plan versus the Grant Program Guidelines.
Lastly, many interpreted the overall scale of the renovation project in determining financial need. Therefore, the grant criteria morphed into not only Financial Need, but also the
Commitment to Rebuild. In hindsight, these two items should have been separate. An applicant’s commitment to rebuild should have been an indicator of an individual’s commitment to completing a historic renovation project.
Under the evaluation criteria description of the Grant Program Guidelines, the following language was included:
This program seeks to deliver results that are important to Louisiana’s recovery. In particular, it seeks to restore historic properties as well as rebuild and repopulate hurricanedevastated communities. Accordingly, successful applications will be those that demonstrate a strong commitment to preserving historic properties and rebuilding our communities.
Under the Financial Need section, the following language was used:
Applicants will need to include a statement of financial need within their applications, and state their commitment to rebuild and remain in the community. Such a statement should include any appropriate documentation that supports the claim of financial need.
As previously noted, the application form was updated to include a “Statement of Financial
Need” as a required attachment. However, a more clearly written application question and better developed evaluation criteria would have made evaluation of this factor more consistent.
25

Under the terms of the federal grant, any sub-grant recipient was responsible for all applicable laws and requirements of the Historic Preservation Fund Manual, the Programmatic Agreement, and the Preservation Agreement. .. Notably, the Programmatic Agreement was not yet completed or signed when the sub-grantees submitted the application and signed Certification
Statement which stated:
I understand that all recipients of a Historic Building Recovery Grant must execute a
Preservation Agreement stating that they will (1) properly maintain and repair the property as necessary and (2) obtain written permission from the State Historic
Preservation Officer prior to any visual or structural alterations to the property for a period of five (5) years from the date of completion of the project.
The only mention of the requirements of the grant program were included in that single statement.
After the grant was awarded, as part of the grant initiation process, all project officers met with their pool of grantees and provided the small green Secretary of the Interior booklets of the Guidelines along with other material for the applicants to use as guides. However, the project officers came to realize that the emotional toll of the recovery process did not allow many applicants to process much of the information they provided.
The evaluation criterion is the most important element of a competitive grant program. Along with the grant program outcomes, the criteria and how the criteria is translated into the application form establishes the basis for selecting grant recipients from a pool of all eligible applicants. Not all projects are worthy of funding, even though they meet the basic eligibility, and the establishment of the criteria provides the method for reviewing application data to conduct a fair and unbiased evaluation.
Initially, NPS requested a list of eligible projects as a part of the Action Plan. The assumption was likely there were individual buildings threatened that needed an immediate influx of funding to secure and preserve them. As such, the LASHPO would be able to provide an immediate list of properties that would receive funding. However, Louisiana was dealing with a more global problem that included a significant number of individual buildings, all potentially eligible. Rather than hand select projects for funding, a competitive grant process was developed. There was not sufficient time to implement the competitive grant program within the 30-day timeframe for submitting the Action Plan to NPS. Rather, the LASHPO submitted a summary of the grant program and the basis for the funding decisions – the evaluation criteria.
The Congressional mandates played a large role in drafting the HBRGP evaluation criteria. For instance, the following criteria are specifically identified in Public Law 109-234.
(1) Located in National Heritage Area (the Cane River Heritage Area in
Natchitoches Parish)
(2) Potential for expeditious repair
(3) Owner-occupied property
(4) Extent to which project will save an endangered property, restore habitability, or restore architectural character
26

(5) Financial need and commitment to rebuild
(6) Project viability, reasonable cost, likely execution
(7) For group applications only: the applicant group’s fiscal management capability will be considered.
The criteria and the application form requirements are the most important tools to evaluate and score each application. The application form should be explicit in the requirements so the reviewers can effectively evaluate the application according to the established and approved criteria. No prior application form existed for the grants focused on the repair of a building. The tax credit application was modified to obtain basic information on the types of repairs individuals were seeking, and for all other items to provide a simple and easy form to complete.
The funding was intended to restore historic buildings, regardless of use. Thus, applications could be submitted by any type of property owner. A building could serve as an owner-occupied residence, rental, or commercial property, or even some combination of all three. While any type of historic building property owner could apply for funds, there was a preference in the scoring system for owner occupied properties. The majority of applicants, or 47%, of properties were owner-occupied properties, with an additional 22% being utilized for the owner’s residence but also used as an income producing property where a portion of the building is utilized for business or rental housing purposes. This number increased to a total of 89% for owner occupied units when the grants were awarded funding. Only 11% were strictly used for income producing purposes. Per the Congressional Mandate, these funds were awarded with a preference for owner-occupied houses and as such, individual property owners were able to receive the financial assistance to actively restore their properties. Appendix xx, Table XX has full details on building use for applicants and grant recipients.
Lessons Learned:
The Congressional mandate to spend funds expeditiously was translated to evaluation criteria in the grant program – “potential for expeditious repair.” This became difficult to evaluate as every applicant that applied was in dire need of the grant funds at that point in time. The application form required the applicant to check off if a grant project would take (a) 0-3 months, (b) 4-6 months, (c) 6-9 months, (d)
10-12 months, or (e) more than a year. Any of these time frames would be considered legitimate and should not have been considered part of the evaluation criteria. The Congressional Mandate in this circumstance was better intended as a directive to the LASHPO to not prolong the process unnecessarily. Allowing more time to make decisions and conduct an internal review and assessment of damages would have allowed for better decision making practices.
According to the Action Plan submitted to NPS, the LASHPO’s planned communication strategy included:

Publishing the guidelines and application in Preservation in Print, Louisiana’s statewide preservation periodical,
27


Posting notices in the New Orleans Times-Picayune, Baton Rouge Morning Advocate (the official journal of the State of Louisiana), Lafayette Daily Advertiser, and the Lake Charles American
Press.

Producing and distributing a brochure giving basic information about the availability of hurricane grants, including a section with frequently asked questions.
After approval of the Action Plan by NPS, the immediate task was to publish the article in Preservation in
Print, which required a four-week lead-time prior to publication. Next, a series of six informational meetings were scheduled across the state and a toll-free call center was established with existing
LASHPO staffing. Media releases were sent to the major news outlets, and a satellite work station was established in the lobby of the Preservation Resource Center in downtown New Orleans. In the end, staff focused efforts on individual outreach within the communities through community meetings and one-on-one assistance rather than through any more advertising and media driven campaign. The following sections summarize the various operations related to the individual outreach activities conducted to ensure individuals were appropriately notified of the grant opportunity.
Table The following is a list of dates for press announcements and other media regarding availability of the grant program:
Table 4. Summary of Media Regarding Historic Building Recovery Grant Program Funding Availability
Date Agency & Title Type of
Announcement
July 26, 2006 Press Release
October 5, 2006 Press Release
October 2006 Article
October 23, 2006 Press Release
U.S. Department of the Interior, “Secretary Kempthorne announces $12.5 million in grants for hurricane disaster in Louisiana”
Office of the Lt. Governor, “Lt. Governor Landrieu announces hurricane recovery grants for historic properties are available”
Preservation Resource Center, Preservation in Print,
“Coming soon: Hurricane grants for historic properties”
Office of the Lt. Governor, “Lt. Governor Landrieu announces hurricane recovery grants for historic properties are available”
October 31, 2006 Article The Times-Picayune (New Orleans, Louisiana) Metro
Section, “Historic home rehab grants offered – many storm-hurt properties eligible”
The Daily Iberian (New Iberia, Louisiana) No Date Article
November 2006 Article Preservation Resource Center, Preservation in Print,
“Guidelines finalized: Deadline extended for historic building recovery grants”
November 14, 2006 Web
Announcement
New Orleans Neighborhood Partnership Network,
“Historic Building Recovery Grant Program”
November 26, 2006 Radio Interview WRNO 99.5 FM Interview with Preservation Resource
Center
November 26, 2006 Web
Announcement
WRNO 99.5 FM, www.thenew995fm.com, “State offers money to fix your historic home”
28

November 27, 2006 Press Release
November 28, 2006 Article
November 28, 2006 Press Release
November 28, 2006 Calendar
December 2006 Article
December 2006 Advertisement
February 2007 Article
Office of the Lt. Governor, “Lt. Governor Landrieu announces public meeting on hurricane recovery grants for historic properties”
New Orleans City Business (New Orleans, Louisiana), “Lt.
Governor announces hurricane recovery grants”
Preservation Resource Center, “Free money! Repair your historic structure”
The Times-Picayune (New Orleans, Louisiana) Meetings
Section, “Historic Building Recovery Grant Program
Meeting”
Preservation Resource Center, Preservation in Print,
“Secretary’s Standards and Guidelines 101: Important information for Historic Building Recovery Grant
Recipients”
Preservation Resource Center, Preservation in Print,
“Notice to Historic Building Grant Applicants: Division of
Historic Preservation New Orleans satellite office has staff available to answer grant questions November 2 to
December 15, 2006”
Preservation Resource Center Preservation in Print
Magazine Article: Summary of Grants Workshop
A toll-free hotline and web form was established to field inquiries related to the grant program. The call center was located in available office space within the LASHPO building and generally focused on answering questions related to the application process; such as is my house historic, what is the deadline, and where do I submit the application. The Call Center fielded over 2,300 inquiries and requests for grants assistance. The heaviest volume was between October and December 2006 when the Call Center received almost 1,600 phone calls during regular business hours – 600 in October, 780 in November and
170 in December. Staffing was limited to one dedicated grants staff person in addition to regular LASHPO staff available on a rotating basis for two-hour shifts when not occupied with regular LASHPO responsibilities. The Call Center also responded to inquiries coming in through the agency website via an online web form and from general inquiries to a generic email address. Between the toll-free hotline, the web form and the general email, approximately 3,000 individuals requested assistance related to the grant program.
29

Figure 3.
Louisiana Division of Historic Preservation employee, Lois Dunn, answers the Grants Call Center line on opening day, September 15,
2006.
A key component of any grants program is the ability to connect locally with constituents. An initial series of five information presentations on the grant
Historic Preservation Grant Call Center
(225) 342-0227 or
Toll-free at (866) 406-7043
Monday – Friday, 8:00am – 6:00pm
Saturday, 12:00 noon – 5:00pm hpgrantscallcenter@crt.state.la.us program were convened across the state. The presentations provided an opportunity for potential applicants to find out about the rules of the program and receive the grant guidelines and application form. A copy of the grants workshop PowerPoint presentation is included in Appendix
C. Table 5 shows the initial public outreach originally scheduled with attendance across the state.
Table 5. Original Schedule of 2006 Informational Grants Presentations
Date & Time
October 19,
6:00 p.m.
City & Location
New Iberia, Sliman
Theater for the
Performing Arts
Attendance
4
116 October 24,
6:00 p.m.
October 25,
6:00 p.m.
October 26,
6:00 p.m.
October 30,
6:00 p.m.
New Orleans, Grace
Episcopal Church
Lake Charles, Central
School Arts and
Humanities Center
Franklinton, Hillcrest
Baptist Church
New Orleans, Holy Angels
Catholic Church
TOTAL
14
8
157
299
30

After assessing the attendance at grants workshops across the state and the volume of calls coming in through the Call
Center the LASHPO adjusted its strategy. The best way to reach constituents was to convene meetings within their own communities and engage with residents directly. Additional meetings were scheduled as follows:
1) Preservation Trades Network: October 26-28, 2006 – a three-day workshop and preservation conference in the Holy Cross National Register Historic District, 200 registered participants received grant information.
Professional preservation craftsmen from across the country provided demonstrations and trainings on repair practices using damaged houses in the Lower
9 th Ward.
2) Broadmoor Fest: November 11, 2006 – a
3)
4) neighborhood street festival of booths and vendors sharing information about recovery opportunities, 75 booth stops.
Broadmoor Neighborhood Association (BNA)
General Meeting: November 15, 2006 – a presentation to the community about the grant program, 30 attendees
Downtown Neighborhood Improvement Association
(DNIA) General Meeting: November 24, 2 006 – a presentation to the community about the grant program, 20 attendees
5) Preservation Resource Center: November 28, 2006 – a presentation to the Historic Neighborhood Council,
146 attendees
6) Preservation Resource Center: November 30, 2006 –
LESSONS LEARNED
Initially considered as a part of the Action
Plan, the LASHPO did not purchase advertisements in the newspapers as originally devised. Efforts of the Lt.
Governor’s Communication Office were limited to press releases and relying on journalists and editors to publish stories related to the funding opportunity. The first newspaper article was published in
October 31, 2006, leaving only one and a half months for applicants to apply. After the article was published, the Call Center recorded an increase in calls from 4 to 131 the day the article was published. A larger number of constituents would likely have engaged in the program had a series of advertisements been published on a regular basis in statewide periodicals. For the additional advertisements to have the desired effect, the Call Center would require greater staffing capabilities with knowledgeable staff to handle the call volume.
The other communication strategy we were not able to implement was the creation of a simple two-sided, rack card brochure for placement in the local historic district commission and safety and permits offices as well as at community centers, libraries, and recovery center locations within historic district communities.
Both of these strategies would have a follow-up presentation give the high demand and lack of seating at the Historic Neighborhood Council meeting, 17 attendees
7) Phoenix New Orleans (PNOLA): December 4, 2006 – a meeting of the Tulane-Gravier neighborhood in the site of the proposed University Medical Center (Charity Hospital) and
Veterans Affairs hospitals, 15 attendees
8) St. Bernard Parish Government: December 6, 2006 – a presentation on the grant opportunity to residents of St. Bernard Parish, 26 attendees
9) Tarps New Orleans in partnership with PNOLA: December 9, 2006 – an full day clinic, 57 participants
10) Federal Fibre Mills: December 11, 2006 – a presentation to individuals within the Federal Fibre
Mills building and in the Central Business District, 30 participants
11) Tarps New Orleans in partnership with PNOLA: December 13, 2006 -
12) Louisiana Department of Culture, Recreation and Tourism Changing Louisiana Conference:
March 5, 2007 – conference by the office of social entrepreneurship after the deadline for individuals still need of assistance in the event of additional funding, 32 booth stops.
31

13) French Quarter Citizens and the North Rampart Urban Main Street Program – a presentation on the grant opportunity to residents of the French Quarter, 9 participants
Between October and December, the LASHPO hosted at least one public meeting per week in a community, in addition to the published schedule of meetings in the grant program guidelines.
Approximately 650 individuals were provided with information during community outreach events.
Figure 4. Satellite Office Advertisement published in Preservation in Print, November
2006
In an effort to provide the best customer service to individuals dealing with recovery issues and to ease the call volume at the
Call Center, the Preservation Resource Center in New Orleans provided space for a Satellite Office on Thursdays and Fridays of each week. This provided an opportunity to conduct one-on-one consultations with potential applicants, review photographs of damage, consult on the how to make appropriate repairs, and guide applicants in how to complete the application form. Over
197 individual consultations were conducted with potential applicants, with 103 occurring within the two days prior to the grant application deadline.

November 16
 th – 10 consultations
November 17 th – 12 consultations

November 23-24 th – 0 consultations (Thanksgiving)

November 30 th – 20 consultations

December 1 st – 7 consultations

December 7 th – 17 consultations

December 8 th – 19 consultations

December 14 th – 61 consultations

December 15 th – 51 consultations (day of deadline)
In total, 1,423 individuals attended workshops, presentations or individual consultations sponsored by the LASHPO regarding the grant program.
Grant Clinic in the Mid City neighborhood in partnership with Tarps New Orleans and Phoenix New
Orleans (PNOLA).
Sat 12/9/2006 from 10 am to 2 pm at 2414 Palmyra in Mid City.
PNOLA helped residents in the Tulane-Gravier neighborhood of New Orleans, the oldest section of the
Mid City National Register Historic District that sustained substantial flooding due to the levee break at the 17 th Street Canal. Tarps New Orleans is a nonprofit that began immediately following Katrina that installed “blue” tarps on damaged historic building roofs - slate, tile and asbestos shingle roofs as FEMA would only tarp asphalt shingle roofs or roofs where the owner requested repair. Tarps New Orleans would tarp properties where property owners were still evacuated and unable to see the condition of their roof. The tarps were a great aid in reducingloss to properties that had significant roof damage.
32

The Clinic utilized a vacant house that was donated to PNOLA for use as an office. Step 1 was to get applicant information and verify the property was in a qualified area. If the applicant had photographs of the property already, they would be moved to Step 2 where construction and preservation volunteers reviewed photographs of damage and helped developed a scope of work to meet the $45,000 grant threshold. The volunteers and the applicant would complete the application form on site and if completed, would move to Step 3, where SHPO staff was on call to officially record and receive the application form. If an applicant did not have photographs of their building, as many individuals did not have cameras or understood the needed photographic documentation requirements, historic preservation volunteers were staffed to go to an applicant’s property to photograph the current condition of the property on their behalf. A complete intake process was available for residents that may not have ever had to complete a formal grant application previously. Volunteers took photos for seventeen potential applicants and while on site, the volunteer would review the needed repairs to include in the application form.
(Do we disregard individuals just because they don’t how to fix their house. If so, we would be working with a very limited, mostly education affluent community of individuals…)
INTAKE AND BASIC QUESTIONS
Alice-Anne Krishnan
Charles Lesher
ESTIMATES
Philip Gilmore and his father
Ken Follett (available long distance via phone/email)
PHOTOS
Tracy Nelson (she’ll bring a laptop and a camera, I’ll provide extra cameras)
Heather Twichell
FINAL REVIEW AND TOUGH QUESTIONS
Staff from the LA-SHPO grants program (Dabne and Peggy)
Attendees can also hand in their completed applications at the clinic.
Grants Clinic Redux: Wed 12/13, 6pm-8pm
Under Louisiana’s Action Plan, a single grant application process was developed rather than developing multiple grant allocation systems. The intent was to create one grant program, one application, and one deadline rather than creating multiple systems based on different selection criteria for eligibility and evaluation. In essence, the LASHPO cast a wide net to capture as many potential applicants as possible.
At the same time balancing the reality that the funding was not sufficient to cover the volume of damage and given the large number of historic properties impacted, there was little data available to help to focus funding on a particular type of damage, locality, or some other criterion. In the Action
Plan, provisions were made to provide a system of fairness. If all eligible properties were to flood the application pool, the process would be extremely strained and we would be unable to differentiate one property from another as they were all suffering similar status given the identical building forms and
33

styles within historic districts and the type of level and type damage that is localized in a disaster. This is one of the prevailing issues in funding historic districts in a disaster situation. As a result, the grant process included a significant number of applications submitted on behalf of property owners covering a wide variety of damage.
Between October 5, 2006 and December 15, 2006, a total of 1,885 applications were received under the
HBRGP program. By February 2, 2007, a period of only 45 days, the LASHPO processed all applications and allocated the initial grant funding of $9.3 million according to the criteria established in the Action
Plan Narrative. This process and timeline was established with a priority on the needs of the constituents given the challenges many encountered regarding damage settlements and the cash flow for repairs. By processing the grant applications quickly, the LASHPO would be able to provide the needed relief to those selected for funding, and for those not funded, they would quickly know the outcome and be able to move on with their project or continue to wait for other recovery available funds.
To achieve these results, a very rigorous and swift process was implemented to determine the final funding awards. The process consisted of three components, including application intake and determination of eligibility, panel review and evaluation, and funding determinations. Further, funding determinations were affected in three ways. First, after the initial funding allocations were approved, an appeals process was established that allowed an opportunity for additional grants to be awarded.
Second, when the LASHPO received a second allocation of funding in 2007, the funding was distributed using the initial panel review and evaluation system. Third, when a grant recipient did not use all grant funds allocated, those funds were redistributed to new grantees, also based on the initial panel review and evaluation system.
Data Processing &
Verification
National Register
Eligibility
Professional Panel
Review
Scoring and Ranking
Ranking Cut-Off
Appeals
Second Congressional
Allocation
Redistribution
Each of these components of the funding distribution system will be detailed in full. Detailed tables on applicant and funding data are included at the end of this section.
A total 1,885 applications were received by the December 15, 2006 deadline with only 15 days allocated for processing. Processing included verifying the application was complete, entering all pertinent data
34

from the application form in an information management system, and confirming National Register status for eligibility purposes. A total of ten temporary employees were contracted to handle data entry and applicant verification while LASHPO staff reviewed applications for National Register eligibility. All application data was entered into an information management system designed in-house by the grants program manager. A data input form was created to make data entry as seamless as possible and reduce entry and coding errors, which had the potential to significantly delay the process.
The first step in the procedure called for date stamping and numbering each grant application. A basic checklist was also created so the temporary employees could verify all required components of the application were included, such as contact information, a completed scope of work, photographs of the front and side elevations, and a signed certification statement. If any of these components were missing, the application was deemed not eligible based on insufficient information to review. If the application contained minimum requirements, then the application was forwarded to LASHPO staff to determine
National Register eligibility based on National Register criteria.
To qualify the application as eligible for the National Register, DHP staff determined the exact location of the building and verified the location on hard-copy maps of National Register Historic Districts. The
National Register Database was also used to research individually listed buildings. Once the location and listing were verified, application photographs of the façade and side elevations were reviewed to ensure the property was a contributing element or contained sufficient integrity for the National Register. Staff verified the National Register status on the application form and entered the eligibility criteria in the information management system. The National Register Coordinator reviewed all calls made by DHP staff to ensure consistency and appropriateness in the reviews overall. Each file contains the required documentation for the National Register determination per the Historic Preservation Fund Manual,
Chapter 6, Section J.2.a.
15
Each application received a National Register Status code to differentiate the properties. The categories are as follows:
(1) Individually listed on the National Register
(2) Individually eligible for the National Register, as determined by the SHPO 16
(3) A historic building (as determined by the SHPO) in a National Register historic district
(4) A historic building (as determined by the SHPO) within a historic district being officially treated as eligible for the National Register by mutual agreement of the
SHPO and FEMA
(5) A historic building (as determined by the SHPO) in a historic district that is being proposed by the SHPO or FEMA to be treated as eligible for the National Register.
15
HPF Manual, chapter 6, Section J. 2.a.: National Register Listing. The property for which the Development project is proposed must be listed in the National Register of Historic Places either individually or identified in the nomination as contributing to a listing in the National Register.
If the property is not so identified in the National Register nomination, it must be certified by the State Historic Preservation Officer to be contributing to a National Register listing. When the State Historic Preservation Officer certifies on the Project Notification (or in its files for
States with Reduced Review Status) that a property is contributing, the Project Notification (and the State's files) must contain sufficient information to allow NPS to understand the property's significance and how it was evaluated. Note that adding properties as contributing to existing National Register listings requires consultation with the State Review Board and must result in a supplemental listing form being transmitted to the Keeper of the National Register (see 36 CFR 60). See also, National Register Criteria Applied. HPF, Chapter 6, c.6.a and b.
16
According to Public Law 109-234, the Programmatic Agreement Preamble, and the NPS Grant Agreement Special Condition #1 Scope of Work and Budget, the LASHPO could award grants to any property eligible for the National Register of Historic Places. The property did not have to be listed on the National Register at the time the application was due.
35

National Register status codes (4) and (5) were developed based on results from early FEMA reviews conducted. The LASHPO’s paper based files were not satisfactory for the use of expedited reviews.
FEMA and the LASHPO quickly determined that windshield surveys would have to be conducted in addition to FEMA placing their teams on the ground to assess eligibility quickly. FEMA also supplemented their team with GIS personnel to map all districts and sites located within boundaries already established in SHPO paper maps. The FEMA/SHPO reviews proved critical to our National
Register staff as they had not revisited the historic districts in New Orleans since many of them were listed back in the 1980s and 90s. Architectural Historians working on behalf of FEMA recognized the need to update and expand some districts as part of the review process as the overall undertaking began to take shape.. Item four includes expansion areas for Bywater and Esplanade Ridge National
Register Historic Districts and the addition of two eligible historic districts, Pontchartrain Park and
Edgewood Park that both the SHPO and FEMA were in agreement over. Item five included the expanded areas of Carrollton and Broadmoor that FEMA did not recommend as eligible, but the SHPO did. Since the FEMA surveys, only the Carrollton expansion has been reviewed by the
State Board and approved by the Keeper.
The final step in the intake process was the preparation of panel review packages. Applicants were required to submit one original application for review. The applications were be duplicated and all photographic documentation submitted was be scanned for electronic duplication with consistent naming protocols. To alleviate any unnecessary delays in processing due to public bid requirements, the Louisiana Office of State Printing handled all scanning and duplicating needs.
The Historic Building Recovery Grant Program received 1,885 applications for funding between October 5, 2006 and December
15, 2006. Within 15 calendar days, all applications were processed and prepared for the next step of the evaluation process – the evaluation of grant applications and determination of funding.
LESSONS LEARNED
During application intake processing and the review for National Register eligibility, National Historic Landmark status buildings were not separately identified. As a result, the requirement for submission of Project Notifications to the National Park Service was not met as the maximum allocation amount was $45,000 and only projects over
$50,000 required the Notification. A total of 65 buildings, including 4 individually listed buildings, 18 contributing elements of the Vieux
Carre (French Quarter) and 7 contributing elements of the Garden
District received grants; however,
Project Notifications were not submitted. This level of identification would likely have had two immediate impacts, first to funding determinations and second to track the requirements for HPF properties.
The next step in the evaluation of each application as described in the Action Plan Narrative was to analyze all eligible applications by LASHPO staff and determine project categories. The applications were assigned to a project category, and each category was evaluated by an independent panel of professionals. The review panels conducted all business in an open, public hearing format to ensure accountability and transparency in the process and to provide an opportunity for applicants to know as quickly as possible the outcome of their grant application.
The analysis of applications to determine project categories provided a logical review of applications given the building condition unknowns and applicant financial need prior to establishing the grant program guidelines. It also established a system to divide the large number of applications received.
Suggested categories initially included separating buildings into those requiring: a) Structural stability, avoiding demolition
36

b) Basic habitability needs c) Restoration of architectural and character-defining elements d) All or most of the above
Other application characteristics that would contribute to the assignment of project categories also included: e) Restoring the character of damaged neighborhoods f) Assisting owners whose insurance settlements will not permit restoring significant properties up to the Secretary of the Interior’s Standards for Rehabilitation g) Blocks of grants (group applications), such as a Certified Local Government applying on behalf of a host of historic properties within its jurisdiction h) Removing elements not eligible for funding and adjusting request levels
There were 1,248 applications determined eligible after the initial intake and eligibility review.
This process took approximately two weeks utilizing all available LASHPO staff to conduct the
National Register review of complete applications and ten temporary staff hired strictly for verifying the application was complete and data entry of basic application information into the grants management system. There were only 30 calendar days remaining to make funding determinations, which included securing an appropriate number of principally professional historic preservation panel members, collating all available application packages, providing sufficient time to review applications, notifying all eligible applicants regarding the status and review of their application, and conducting open, public hearings.
December 15th to
31st:
Application
Deadline and Intake
Process
(16 days)
January 1st to
7th:
Notifiy Applicants and Panelists
(7 days)
January 7th to
18th:
Panel Review
(12 days)
January 18th to
26th:
Public Hearings
(9 days)
January 29th to
February 2nd:
Approve Funding
Recommendations -
Notice to Applicants
(5 days)
There was not sufficient time to review the proposed scope of work and determine project categories as detailed above, while at the same time providing sufficient time for the panel to review as many as 200 applications. With the first hearing date scheduled for January 18 th , applications needed to be collated and distributed to panel committee members as quickly as possible to ensure sufficient time to evaluate and score applications. A determination was made to review applications using categories that were already existing within the application data. The categories included National Register status and
National Register Historic District location. Table 6 provides a breakdown of the categories established for the review and evaluation of applications.
Table 6
Public Hearing Date Category
January 18, 2007
January 19, 2007
Statewide (not New Orleans), Individually Listed and Individually
Eligible, Garden District
Groups, Vieux Carré, Lower CBD, Upper CBD
# of
Applicants
89
187
37

January 22, 2007
January 23, 2007
January 24, 2007
January 25, 2007
January 26, 2007
Figure 5
Esplanade Ridge
Holy Cross, Bywater, Algiers Point, Parkview
Faubourg Marigny, New Marigny, Edgewood Park, Gentilly Terrace,
Pontchartrain Park, South Lakeview
Lower Garden District, Irish Channel, Central City, Uptown
Carrollton, Broadmoor, Mid City
16%
16%
7%
15%
14%
17%
15%
Январь 18, 2007
Январь 19, 2007
Январь 22, 2007
Январь 23, 2007
Январь 24, 2007
Январь 25, 2007
Январь 26, 2007
Review and reword Lessons learned info below.
187
207
181
195
202
38

Given the unique situation of the disaster and the new role DHP assumed, there were considerable unknowns prior to the application process. The expectation was that a more focused investment strategy would be determined once staff analyzed the application materials and created project categories that would form the basis for the evaluation and funding determinations of applications. The agency would be able to have a clearer understanding of the Congressional mandates and the level of damage. Further, the less subjective items could have been pre-reviewed and points assigned, such as whether or not the property was owner occupied, if there was a financial need based on consistent data, and the type of project.
In order to accommodate a staff review and identification of project categories as initially intended, two things were needed, sufficient professional staffing resources to analyze the 1242 eligible applications and sufficient time to conduct the analysis. At the time, there were only two staff people assigned to the grant program, a program director and a project officer initially hired as a temporary job appointment under state civil service requirements. Regular staff was not available to conduct the duties required of the grant program in addition to the already expanded role they were assuming in regards to day-to-day operations.
Further, the focus was on the needs of the constituents and the immediate need for distribution of financial relief. The timeline would have been delayed by a minimum of 30 days, potentially more, depending on available staffing. The benefit would have been a better understanding of the needs of the applicants and more effective strategy for distribution of funds.
Lastly, the panel committee assumed the full burden of responsibility for evaluation and investment of public dollars in a very short turnaround time with a significant number of applications. This panel process in place was typical for other grant programs under the LASHPO; however, the constituent base typically served by the panel review system usually had a previous track record of performance or there was a level of professional understanding with regards to applicants, such as Certified Local Governments, universitybased architecture and preservation programs, or other historic and architectural nonprofits. The applicants to the HBRGP program were unique. Providing a system of initial staff review and analysis would have established a certain project categories that would have contributed to a more focused review and a more critical analysis of the applications to determine those most competitive for funding. It would have placed an equal burden of responsibility for evaluation on staff and the panel committee.
In total, seven panel committees were created for the review of grant application as opposed to four identified in the Action Plan narrative. According to Louisiana’s Action Plan narrative, each committee would be represented by the following:

At least one-third must meet the Secretary of the Interior’s Standards for Professional
Qualifications, 36 CFR 61 (historians, architectural historians, and historical architects)

Include six to nine members

Represent the broadest range of preservation disciplines

Achieve a diverse representation of panelists
To recruit the maximum number of panelists needed, or 63 individuals, a Call for Nominations was circulated to recruit interested individuals that resulted in a pool of approximately 130 potential committee members. The deadline to submit a resume to be considered was initially December 8, 2006; however, when it was determined that there was an insufficient number of interested individuals; nominations were accepted until applications were forwarded to committees for review, or between
January 2 and January 16, 2007. All prospective panel members required approval of the State Historic
Preservation Officer (SHPO) prior to inviting the individual to serve on a committee. In total, 52
39

panelists were selected and served, of which 98 percent were qualified according to the Secretary of the
Interior Professional Standards. For their service, each panelist received an honorarium of $500 and per diem travel expenses. Table 7 includes a list of individuals who served on the evaluation committee.
(The bios were in the database, but the database was expunged by Marilyn and Greg Wirth – there is still a copy somewhere and there is a hard copy of all the resumes and bios in the files if someone wants to put them together and attach in the Appendix C)
Table 7
Panel Day and Agenda Panelists
Thursday, January 18, 2007:
Statewide, Individually Listed and
Individually Eligible, Garden
District National Historic
Landmark District
Friday, January 19, 2007: Group
Applications, Vieux Carre, Lower
CBD, Upper CBD
Monday, January 22, 2007:
Esplanade Ridge
1.
Elizabeth McDougall, Director of Tourism, St. Bernard Parish,
Chalmette, LA
2.
Ronald Sapp, Architect, Baton Rouge, LA
3.
William Highland, Historian, St. Bernard Parish, Chalmette, LA
4.
Winnie Guillory, Calcasieu Preservation Society, Lake Charles,
LA
5.
Virginia Webb, Lake Charles Area Preservationist, Lake
Charles, LA
6.
Brian Driscoll, Technical Services Coordinator, Arkansas
Historic Preservation Program, Little Rock, AK
7.
Lauren Harrell, Architect, Sulpher, LA
1.
Matthew Daigrepont, Architect, Baton Rouge, LA
2.
Martha Saloman, Architect, Baton Rouge, LA
3.
Judith Allain, CLG Chair, Franklin, LA
4.
Ben Nash, Franklin CLG, Franklin, LA
5.
Brian Driscoll, Technical Services Coordinator, Arkansas
Historic Preservation Program, Little Rock, AK
6.
Julie Ernstein, Associate Professor of Anthropology,
Northwestern State University, Heritage Resources Program,
Natchitoches, LA
7.
Geoffrey Hartnett, Architect, New Orleans, LA
8.
Rick Normand, Past President of Louisiana Landmarks Society,
Past President of Louisiana Trust for Historic Preservation
(formerly LA. Preservation Alliance), New Orleans, LA
1.
Benjamin Bradford, Architect, Baton Rouge, LA
2.
William Brockway, Retired, LSU School of Architecture, Baton
Rouge, LA
3.
Nancy Morgan, Executive Director, Cane River National
Heritage Area, Natchitoches, LA
4.
Walter Gallas, AICP, Director New Orleans Field Office,
National Trust for Historic Preservation, New Orleans, LA
5.
Ann Williams, National Register Panelist, New Orleans, LA
40

Tuesday, January 23, 2007:
Parkview
Holy
Cross, Bywater, Algiers Point,
Wednesday, January 24, 2007:
Faubourg Marigny, New Marigny,
Edgewood Park, Gentilly Terrace,
Pontchartrain Park, South
Lakeview
Thursday, January 25, 2007:
Lower Garden District, Irish
Channel, Central City, Uptown
Friday, January 26, 2007:
Carrollton, Broadmoor, Mid City
1.
Jill Bambury, Associate Professor, Southern University, School of Architecture, Baton Rouge, LA
2.
Laddie Bolden, DOC-DHL, INC., Baton Rouge, LA
3.
Pamela Keller, Economic Development Director, City of
Covington, Covington, LA
4.
Andy Ferrell, NCPTT, Architecture and Engineering Program,
Natchitoches, LA
5.
Gerald Gesser, Architect, New Iberia, LA*
6.
Caitlin Cain, Economic Development Program Manager, New
Orleans Regional Planning Commission, New Orleans, LA
7.
Elliot Perkins, Executive Director, Historic District Landmarks
Commission, New Orleans, LA
1.
Charlene Beckett, Main Street Coordinator, Abbeville Main
Street, Abbeville, LA
2.
Judy Thompson, Main Street Manager, Minden Main Street
Program, Minden, LA
3.
Rick Fifield, Architect, New Orleans, LA
4.
Jim Logan, Lawyer, New Orleans, LA
5.
Maurice Sholas MD PH.D, Director, Pediatric Rehabilitation
Program, Children’s Hospital / Property Renovator, New
Orleans, LA
6.
Jan Corrales, Main Street Manager, Springhill Main Street
Program, Springhill, LA
1.
William Tudor, Architect, Alexandria, LA
2.
Allen R. Lenhardt, Formerly with LA Preservation Alliance,
Baton Rouge, LA
3.
James Hendrickson, Jackson Historic District Commission,
Jackson, LA
4.
Katy Coyle, VP Cultural Resource Management/Historian, New
Orleans, LA
5.
Karen Gadbois, Outreach Director, Think New Orleans, New
Orleans, LA
6.
Laureen Lentz, Historic Preservation Americorp Working in
Tremé, New Orleans, LA
1.
Jennifer Lee, General Counsel, Hammond, LA
2.
Therese Guillory Lemoine, Historic Preservation Specialist,
Metairie, LA
3.
Jim Cripps, Architect, New Orleans, LA
4.
Lary Hesdorffer, Executive Director, Vieux Carre Commission,
New Orleans, LA
5.
Carolyn Bennett, Foundation for Historical LA, Baton Rouge,
LA
6.
Jay D. Edwards, Director, Fred B. Kniffen Cultural Resources
Lab – LSU, Baton Rouge, LA
41

HBRGP Funding Panel:
Monday, January 29, 2007
One representative from each of the seven Evaluation Committees
1.
Ronald Sapp, Architect, Baton Rouge, LA
2.
Ben Nash, Franklin CLG, Franklin, LA
3.
Walter Gallas, AICP, Director New Orleans Field Office,
National Trust for Historic Preservation, New Orleans, LA
4.
Elliot Perkins, Executive Director, Historic District Landmarks
Commission, New Orleans, LA
5.
Maurice Sholas, MD PH.D, Director, Pediatric Rehabilitation
Program, Children’s Hospital / Property Renovator, New
Orleans, LA
6.
Allen R. Lenhardt, Formerly with LA Preservation Alliance,
Baton Rouge, LA
7.
Therese Guillory Lemoine, Historic Preservation Specialist,
Metairie, LA
Once committee participation was confirmed, panelists were provided with approximately 10-14 days to review and evaluate assigned applications, a fairly daunting task given the number of applicants under review. The requirements for serving as a panelist were as follows:

Review the grant program guidelines for the basic overview of the rules and requirements of the
HBRGP program

Review each application and digital application photographs for evaluation according to the criteria

Complete and submit in advance a Pre-Score Form that asked panelists to score the overall application as a high, medium, or low priority

Complete a Score Sheet for each application by the Public Hearing date for submission at the end of the meeting.
The agenda for the public hearing played an important role in the evaluation of each application. As there were on average 200 applications being reviewed during each public hearing, not all applicants would be individually reviewed. The first priority was establishing a method for reducing the level of discussion needed per application. Furthermore, each panelist needed to understand the importance of the public hearing. Through the Lt. Governor Mitch Landrieu’s Louisiana Rebirth Recovery Plan, strict mandates on providing high performance, accountability and ethical behavior were tantamount in all functions of the department. All evaluation decisions were held in public meetings to ensure sound decision-making practices were employed. This also made the Grant Evaluation Committee member’s responsibility more important as all commentary would be a matter of public record.
The most efficient use of time during the public hearing would be to focus on those applications where panelist opinions varied widely. The panel also did not have a significant amount of time for review and evaluation, and the process for evaluation needed to reflect these limitations. The Committee would simply have an opportunity to come together to review how each person evaluated the applications and identify universally where committee members were in agreement or where there was difference of opinion in how an application was perceived.
To begin the process, each panelist was responsible for completing the Pre-Score Form. The Pre-Score
Forms asked panelists to give their overall impression of the application by using a simple priority scale of high, medium or low. This allowed panelists to review all the applications first to determine how they would interpret priorities that would form the basis for the evaluation criteria. Reviewing all
42

applications first also gave them a better perspective of the level of damage in a given community and provided a quick system to cycle through the applications and photographs. Panelists could also reorder applications and place them together. This system was a practical, guided system for establishing an internal project category for each panelist as staff was unable to do this prior to distributing the applications to panelists. After this initial Pre-score review, a panelist could then assess each application more consistently according to the published evaluation criteria when similar conditions applied. A copy of the pre-score form and tabulation guide are included in Appendix C.
Once the panelist completed the Pre-Score form and returned the form, staff tabulated the scores for each panelist and created a score based on the entire panel committee. This system created a ranking order that would initiate discussion during the public hearing. Prior to the public hearing, however, the
Pre-Score worksheet was provided to each panelist to show the results of the pre-scoring system. Each panelist could use this worksheet, in addition to their individual pre-scores, as a guide for completing the Score Sheet for each application.
The Score Sheet provided the weighted point system that ultimately determined funding. The Score
Sheet listed each of four evaluation criterion and asked panelists to provide a score each one by assigning points. Once the scores were submitted to staff, the scores were weighted according to the
Action Plan narrative weighted system. The weighted point system for each of the evaluation criterion is as follows:
1. Owner-occupied:
2. Located in a National Heritage Area:
No=1 point, or Yes=5 points
No=1 point, or Yes=5 points
3. Financial need and commitment to rebuild: 1, 2, 3, 4, or 5 points
(10%)
(10%)
(10%)
4. Extent to which project will: 1, 2, 3, 4, or 5 points o save endangered property (structural stability); o restore habitability; or o restore architectural character
WITH o potential for expeditious repair exists; o project is viable and will likely be executed; and o costs are reasonable
(70%)
Given the importance of scoring to the funding determinations, panelists needed a system to ensure the scoring was valid, appropriate to the application, and applied consistently across all applications. To assist in the scoring process, each panelist received a “Selection Criteria Guide Sheet” that provided specific instructions to panelists on where information was located on the application form. The Guide
Sheet, along with the Pre-Score Worksheet, was intended to provide an efficient process for reviewing a large number of application forms in a short amount of time. It served to direct panelists to the required information rather than having panelists guess, using inconsistent methods, or focusing on the wrong questions when evaluating the application.
During the public hearing, there was not an opportunity to review 200 applications individually. Rather, each panelist was required to bring the applications and a completed Score Sheet. The meeting began with a review of the Pre-Scores ranked from high to low. The Pre-Score Worksheet provided each panelist’s score. (See Appendix C for a copy of the Pre-Score Worksheet). The public hearing first focused on describing the characteristics of applications that scored similarly. For instance, if all panelists felt the application was a high priority they would discuss generally what made the application a high priority. Conversely, if the entire panel felt the application was a low priority, there would be
43

general discussion during the public hearing on the basis for that scoring. Once a group of applications were reviewed, typically about 7-10 applications having consistent scoring, the panel would be provided with an opportunity to review the applications, the Score Sheet and individual scoring. Once all the panelists concluded their review, staff collected those Score Sheets for tabulation. After all the applications with similar scores were discussed, the panel then focused on individual applications where there was a wide variance in scoring and for those applications that scored somewhere in the middle – ones that were neither a high priority nor a low priority.
The next step in the panel process was to review the overall scores. Each evaluation criteria was given a certain number of points on the Score Sheet. Each score was then weighted and tabulated by staff to provide a total score per application per panelist. The overall score for each application was averaged amongst the members of the panel. Finally, the applications were ranked from highest to lowest. The ranking worksheet was then distributed to the committee for review. The panel was able to see this final ranking to ensure there were no inconsistencies and to ensure agreement prior to finalizing the applicant score. Any scores that the committee did not feel were an accurate reflection of the application would be reviewed. Using the ranking worksheet, the panel made a recommendation for an appropriate cut-off point for funding. The cut-off point reflected the panel’s opinion of the point where funding for the pool of applicants would no longer provide impact on historic resources. One representative of each panel was also selected to serve on the funding panel.
Selection panels also were able to deny funding to a particular application as the members deemed appropriate. Persons denied funding in this way could appeal to the SHPO (see Appeals Process, below).
Only one panel committee decided to deny funding. During the January 19 th public hearing, the panel agreed to deny funding to the individual applicants of the Federal Fibre Mills apartment building. The
Grant Program did not provide sufficient direction regarding historic buildings that were multi-unit with multiple owners. Staff was unable to determine the eligibility of individual owners prior to the deadline and suggested applications be submitted at which time a determination would be made as to eligibility after applying. The panel decided that even though each individual unit was the responsibility each owner, that only one application for funding could be allowed; therefore,, the panel decided to deny funding to all applicants of the Federal Fibre Mills building. The rationale was that the 25 individual owners were primarily seeking funding for masonry repairs or window repairs for each of their individual units. As only the interior masonry would be addressed without addressing the exterior masonry damage that was the responsibility of the entire building association, it would not be in the public’s best interest to fund any of the individual applications. A motion was made by the committee to deny funding, and the motion was passed by the committee. Subsequent to the committee motion, the definition of a historic structure per 36 CFR 67.2 Definitions of Certified Historic Structures, section
(b) indicates portions of larger buildings, such as single condominium units, are not independently considered certified historic structures. As such, the individual Federal Fibre Mills apartment building applications would not have been eligible for grant funding.
During the funding panel, the scores from the committee were combined into one absolute ranking sheet. The panel reviewed the cut-off recommendations from each individual committee and discussed what funding formula would be applied, in particular whether full funding or partial funding should be awarded. By fully funding an applicant’s request per their scope of work and according to the ranking, funding would be allocated to any applicant with a score greater than 3.617. If the panel decided to provide partial funding, a formula would need to be determined. For instance, the Louisiana Division of the Arts uses a project funding formula whereby the panel determines cut-off score and the funding formula distributes the funding in a decreasing formula until the funding is exhausted. The percentage
44

of the request they receive is dependent on the cut-off point for funding, the number of applications, the amount of the requests, and the amount of the funding available. The funding committee reviewed the recommendations from each panel as follows:
January 18 th : Recommended a 2.0 cut-off point
January 19 th : Recommended a 2.9, 2.7 or 2.683 cut-off point
January 22 nd : Recommended to fund more by providing only a percentage of the requested amount
January 23 rd : Recommended fully funding higher scores only, fund meaningful grants rather than providing less than what is requested, 3.0 or 3.2 cut-off point
January 24 th : Recommended a sliding scale or percentage of request based on the scoring.
“4” receiving between 100-80 percent of request; 3.5-4.0 receiving 50 percent of request; 3.0-3.5 receiving 25 percent of request amount.
January 25 th : Fully fund applicants until funding runs out
January 26 th : Stop at 3.0 and or provide a 60-40-20 percentage of request split for each 1/3 rd of applicants falling within that range.
Given the financial difficulties many individuals were facing and undervaluation of repairs by insurance companies, the funding committee determined that full funding should be provided to applicants as opposed to funding all applicants at roughly $8,000 per application. Further, the funding committee believed that there were applications that were not worthy of funding, even if funding were to be available; it would be a disservice to provide funding to some applicants at the expense of others.
Of the 1,242 eligible applicants, the funding committee recommendation was to allocate a total of
$9,601,512 for 283 applicants. Out of a total score of 5.0, full funding was allocated through applicant scores of 3.617, funding 23 percent of eligible applicants. A final report was prepared and the funding determinations were approved by the SHPO and the Lt. Governor. Notifications of funding letters were sent by February 2, 2007 and the first site visits began February 7, 2007.
Each applicant was sent a confirmation and receipt of application letter that included the public hearing date. A total of 72 members of the public attended the public hearings. Further, all meetings were transcribed for the public if there was an interest in the evaluation outcomes or discussions. These transcripts were public record and copies were made available through public records requests. After the funding committee meeting, all applicants received correspondence regarding the final status of their application.
45

The Action Plan and the Grant Program Guidelines identified six individual selection criteria. During the panel review and tabulation of an applicant’s score, three of the criterion were combined. Under the
Action Plan, the following criteria were weighted separately:

10 percent - Potential for expeditious repair

20 percent - Project viability, reasonable cost, likely execution

40 percent - Extent to which project save endangered property, restore habitability, or restore character
When the Selection Criteria Guide Sheet was developed for panelists, the application form proved to be overly vague in regards to information that could be evaluated by panelists, even though it proved easy to complete on the part of the applicant. There were further concerns that the scoring would be handled strictly based on the individual responses rather than in combination with the overall project scope. For instance, a project could score low for project scope, however it could be completed expeditiously and be executed. These criteria, if evaluated individually, had the potential to create a higher overall score even though the project may have little impact. Further, project scope and project management made more sense if viewed as a whole rather than independently. There was also a concern that requiring a panel to complete a score sheet with 6 factors would take longer than 4 factors. By combining the criteria into one overall score, it created a more efficient scoring system and a simpler method for validating the score.
Any applicant objecting to a decision had the opportunity to appeal to the SHPO, or a designee. Appeals were required to be in writing and received by the SHPO within fifteen days of the notice on the decision. Further, the SHPO was required to respond within 45 calendar days. In responding, the SHPO had the option of (1) supporting the original decision; (2) recommending reconsideration of the decision; (3) entering into consultation to resolve the issue; or (4) overturning the decision, and if applicable, take such action as she may deem appropriate.
Any applicant objecting to the outcome of the grant process had 3 weeks, or until February 23rd, to submit an appeal. A total of 262 appeals were received by the February 23 rd appeal deadline, with an additional 26 appeals received after that date. Overall, 288 appeals were received after the initial notification of funding. The basis for appeals were as follows:
(1) Not Individually Listed or Eligible: The property did not meet the criteria to qualify for the
National Register or there was insufficient evidence in the application to make a determination.
(2) Loss of Integrity: The property is in a National Register Historic District or eligible Historic
District, but the property had undergone too many alterations to be considered a contributing element.
(3) Insufficient Photographs: Each application required three (3) elevation photographs consisting of the front and right and left side elevations of the building. These photographs were used by staff to determine if the application met the eligibility criteria. In some instances, the photographs were insufficient to make a determination. If this was the case, the application was not considered eligible for a grant.
(4) Incomplete Application Form: Even though the application form included a “Required
Attachment checklist” not all of the items were submitted. Since there were such a large number of applicants that did not provide all the information, a minimum level of data was
46

determined to ensure the application was considered complete. If any of these key pieces, such as the Scope of Work section, were not included, the application was not considered eligible for a grant.
(5) Late: Applications were accepted by hand delivery until 6 pm at the Preservation Resource
Center and at the main office in Baton Rouge at the State Capitol Annex. Applications could also be postmarked by the December 15 th deadline. Any application hand delivered or postmarked after this date was not considered eligible.
(6) Eligible, Not Funded: Out of the 1242 applications eligible to be considered for a grant, only 283 applications were selected for funding given the limited amount of funds available. Although many appealed the decision not to fund their application, only appeals that had sufficient cause to show that their application was inappropriately reviewed by the Grant Evaluation Committee would warrant reconsideration, or if there was proof that a scoring error occurred.
Any appeal received based on a National Register determination was reviewed by the Executive Director and National Register Coordinator of the Division of Historic Preservation. The HBRGP Program Director reviewed all other appeals received. A review of each application was conducted and a recommendation was made to either support the original decision or reconsider the application for review and evaluation. If an application was reconsidered and evaluated, the application would receive a score and would be placed in line with all other applicants. Forty-five applications were reconsidered under the appeal process; however, there was only sufficient funding available to fund six of those applications. All others were placed in the funding ranking with the other eligible applications in the event more funding was allocated.
Table 8
Appeal Status
Appeals Received
Appeals to Reconsider
Appeals Funded in Round 1
Appeals Funded in Round 2
TOTAL
287
45
10
11
Non-
Contributing
22
7
1
1
Not
Eligible
36
3
0
1
Incomplete
Photos
33
11
2
2
Incomplete
Application Late
6
Not
Funded
14 172
2
0
1
5
2
0
13
1
6
The original Action Plan narrative also accounted for a Director’s Discretionary Fund and a Contingency
Fund. Given the overall demand of the grant application process, both of these line items were deemed unsustainable and the funds allocated in both line items were expended on grant awards during
Appeals.
Table 9
Inappropriate
Grant Award
Adjustment
4
4
4
0
Funding Committee Recommendation
Appeals Review
TOTAL
Number of properties
283
6
289
Amount allocated
$9,601,512.00
$ 275,800.00
$9,877,312.00
47

The Lt. Governor and Louisiana Delegation lobbied Congress for an additional allocation to meet the needed demand of 953 eligible applicants, or 76 percent of applicants, still unfunded. On May 25, 2007,
Public Law 110-28 approved an additional $10 million allocation to the LASHPO for Hurricane Recovery, bringing the total allocation for the grants program to $22.2 million for direct grants, planning and technical assistance and administration of the grants program.
The LASHPO sent a revised Action Plan on July 16, 2007 that directed that funds would be applied to the current applicant pool based on the ranking provided during the funding panel on January 29, 2007. The
State Historic Preservation Officer had the option of determining an application was ineligible for the following reasons: a) The property had been demolished; b) The property ownership had changed and the original applicant no longer owns the building; c) The applicant/owner failed to respond to efforts to make contact and execute a grant agreement; and d) Any other compelling reason a project is deemed no longer viable.
NPS approved the new action plan by July 20, 2007.
To accommodate item (d) above, a staff review of applications was built into the process prior to sending award letters. The review system categorized applicants into three groups identified as Green,
Yellow and Red.
Green-rated applications: Staff identified no issues with the project. The applicant was then immediately notified of the funding allocation. In a few cases, a question was identified, but not significant enough to require a mandatory site visit.
Yellow-rated applications: Staff identified potential issues with the sub grant project. The applicant was sent a letter identifying the issue along with a request to schedule a site inspection to resolve the issue. Once the issue was resolved, the sub grantee would get an official award letter indicating the amount of the grant. If the issue was not resolved, the application was rated Red. Issues for Yellow-rated applications, included: a) Viability – Concerns about the cost or scope of the project, such as the proposed cost estimate was too low or the scope of work was too vague. b) Feasibility – Concerns the funding provided would not fully weatherize the structure, and the owner has no additional funds available according to the application form. The stabilization of the property is necessary, but cannot be ensured. c) Ineligible scope of work – The grant amount requested is for a large portion of ineligible items. d) Scope of Work Not Appropriate – The application scope of work identifies items that are a lower priority when compared to the overall needs of the building, such as an applicant listed restoration of historic elements when the house is completely gutted. e) Non-historic repairs completed – Some properties were partially repaired since the grant application was submitted and the repairs did not meet SOIS potentially impacting the National Register status of the application.
48

f) Ownership Not Clear – The applicant is not the owner or a “for sale” sign appears in the application photos. g) Demolition – The City of New Orleans and FEMA issued a property listing for properties on the demolition list. Also, any property located within the Veteran’s Affairs Medical
Center footprint was also now in danger of demolition 17 .
Red-rated applications: Staff identified issues that made the application potentially ineligible.
The applicant was sent a letter identifying the issue along with a request to schedule a site inspection to verify the issue. If the issue was resolved, the grantee received an official award letter indicating the amount of the grant. If the issue was not resolved and the property was no longer eligible, the applicant was provided with an opportunity to appeal. Issues for Red-rated applications included: a) Properties where the contributing status is in question by HBRGP staff b) A Yellow-rated applicant that has not resolved the issue c) Properties that are demolished d) Properties where the damage does not appear to be hurricane damage
Table 10 includes a summary for the number of applications pre-reviewed and the outcome of the mandatory site inspection.
Table 10
Category
Green
# of Applicants Results of Mandatory Site Inspection
226
14
17 applications required additional monitoring; no mandatory site inspection
1 not eligible; 8 allocated funding; 5 received increased grant award Yellow
Red 9 3 not eligible; 5 allocated funding
After the initial review of applications, 249 grants were awarded totaling $8,743,669. After all initial site inspections were conducted and additional projects were identified as ineligible or completed, the total awarded for the second allocation increased to 256 grants and a total grant allocation of $8,952,969.
During the course of a sub grant project, many repairs came in under budget or a project stalled for a variety of reasons (see Terminations and Cancelled Grants). Not all sub grant projects were completed according to the amount allocated. Table 11 shows the number of grants that were reduced. As a result of grant funds being returned, the funding policy allowed grants to be awarded to the next applicant in the ranking by score from the grant evaluation committee. The same internal review as established for the second Congressional allocation applied.
Table 11
TOTAL Reduction of Original Grant NPS GRANT
22-06-HR-21572
NPS GRANT
22-07-HR-21671
17 No Round 2 funded applications were located in the Veterans Affairs Medical Center footprint.
49

Completed At or Below Cost
0% - No Reduction in Grant
1-10% of Original Award
11-25% of Original Award
224
26
26
Sub-Total 276
Terminated or Inability to Complete
26-50% of Original Award 13
51-80% of Original Award
100% of Original Award/Did Not Execute Grant
5
2
100% of Original Award/Collections Proceedings 2
Sub-Total 22
4%
2%
.5%
.5%
7%
75%
9%
9%
93%
15
7
2
7
31
192
33
16
241
6%
3%
1%
3%
11%
71%
12%
6%
89%
28
12
4
9
53
416 73%
59
42
10%
7%
517 91%
5%
2%
1%
2%
9%
TOTAL 298 100% 272 100% 570 100%
From the first payment to a sub grantee on February 23, 2007 to the last payment on May 27, 2011, a total of 570 sub grants were allocated funding totaling $19,608,182. In the end, however, only 557 sub grant projects retained funding for allowable project costs totaling $18,078,967.21. Tables 12 through
20 provide overall summaries regarding the processing of grant applications and funding determinations.
12 13 0% - No Reduction in
Grant
1-10% of Original Award
42
28
11-25% of Original Award
59
26-50% of Original Award
416
51-80% of Original Award
100% of Original Award
Table 12
Application Status
Eligible
# of
Applicants
Amount
Requested
1,242 $43,415,406
50

Not Eligible
TOTAL
643
$22,192,026
1,885 $65,607,432
Table 13
Applicants Not Eligible
Located in a National Register Historic District, but not a Contributing
Element
Not located in National Register Historic District, not individually listed, and not individually eligible
Unable to make National Register determination based on incomplete photos submitted with application
Application package incomplete
Application postmarked after the grant deadline
Applicant not eligible – church or government-owned building
Other: determined ineligible after award allocation
TOTAL
Table 14
# of
Applicants
198
173
159
22
53
13
25
643
National Register Status
Individually Listed
Individually Eligible
Contributing Element in Historic District
Contributing Element in an eligible Historic District, SHPO and
FEMA
Contributing Element in an eligible Historic District
National Historic Landmark
Table 15
TOTAL
16
65
1242
Eligible
19
18
1061
63
Initial
Funding
Allocation
16
12
480
23
9
30
570
NPS Grant#
22-06-HR-21572
22-07-HR-21671
TOTAL
Original # of
Sub-Grants
Allocated
298
272
570
Final # of
Sub-Grants
Awarded
Original
Allocated
294 $10,154,991.00
263 $9,448,290.00
557 $19,603,281.00
Final
Paid
$9,685,282.83
$8,881,651.63
$18,566,934.46
Final
Grant
Funded
14
11
470
23
9
30
557
51

Table 16
Natchitoches
Orleans
Plaquemines
Plaquemines
Plaquemines
St. Bernard
St. Bernard
St. Charles
St. James
St. James
St. John
St. Tammany
St. Tammany
St. Tammany
St. Tammany
Tangipahoa
Tangipahoa
Terrebonne
Terrebonne
Vermilion
Acadia
Parish
Ascension
Assumption
City
Crowley
Donaldsonville
Napoleonville
Calcasieu Lake Charles
East Baton Rouge Baton Rouge
Iberia
Iberia
Jeanerette
New Iberia
Jefferson
Jefferson
Jefferson Davis
Lafayette
Lafourche
Lafourche
Morehouse
Natchitoches
Gretna
Marrero
Welsh
Youngville
Lockport
Thibodaux
Bastrop
Derry
Natchitoches
New Orleans
Buras
Empire
Pointe-a-la-Hache
Arabi
St. Bernard
Destrehan
Convent
Vacherie
Garyville
Covington
Lacombe
Mandeville
Slidell
Amite
Hammond
Gibson
Houma
Abbeville
1
1
2
1
1
1
2
1
Applied Eligible
2 2
1
1
1
1
1
1
8
2
5
-
-
1
-
-
1
-
-
1
1
1
2
3
12
1
1
2
1
3
1 1
1,768 1,173
1
1
1
-
1
42
5
1
1
28
2
1
3
1
2
1
1
1
2
-
3
1
1
2
1
1
1
3
2
-
1
2
1
1
1
3
1
1
-
-
1
21
2
1
-
508
-
-
-
1
-
-
-
1
-
-
Funded
(Final)
1
1
1
-
1
2
-
$0
$16,521,505
$0
$0
$45,000
$737,050
$58,000
$45,000
$44,470
$74,380
$40,050
$20,927
$40,300
$90,000
$72,731
$0
$0
$0
$22,400
$45,000
Total Grant
Expended
$45,000
$45,000
$31,800
$88,074
$0
$0
$34,190
$0
$0
$0
$36,000
$0
$0
$0
$43,412
52

Vermilion
Vermilion
Washington
West Carroll
Erath
Gueydan
Franklinton
Oak Grove
2
2
2
1
-
2
2
-
TOTAL 1,885 1,242
1
-
-
2
557
$0
$54,072
$45,000
$0
$18,279,361
Table 17. Applicants and Funding List of Properties Individually Listed in or Eligible for the National Register of Historic
Places.
National
Register Status
Parish City Listing
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
National Historic
Landmark
National Historic
Landmark
National Historic
Landmark
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Natchitoches Derry
Assumption Napoleonville Madewood Plantation
St. James Vacherie
Magnolia Plantation
Oak Alley Plantation
Ascension
Iberia
Lafayette
Lafourche
Orleans
St. Bernard
Donaldsonville
Lemann Block Building
New Iberia
Lutzenberger Foundry &
Pattern Shop Building
Youngville
The Duplex House
Lockport
Boaverans Plantation House
New Orleans The Pitot House; A.P.
St. Bernard
Tureaud, Sr. House;
Lafcadio Hearn Residence;
Carver Theatre; Bullitt-
Longenecker House/"The
Swiss Chalet"
Kenilworth Plantation;
Sebastopol Plantation
St. Charles Destrehan Ormond Plantation House
St. James
St. John
Convent
Garyville
St. Tammany Lacombe
St. Tammany Slidell
Tangipahoa
Terrebonne
Vermilion
Amite
Houma
Gueydan
Judge Felix Poche Plantation
Emilie Plantation House
Rankin House/Fountainhead
Francois Cousin House
Epney
Herman A. Cook House
Bank of Gueydan
# of
Applicants
1
# of
Funded
(Final)
%
Funded
1 100%
1
3
1
1
1
1
5
2
1
1
1
1
1
1
1
1
1
3
1
1
1
0
3
2
1
1
1
1
0
0
1
1
100%
100%
100%
100%
100%
0%
80%
100%
100%
100%
100%
100%
0%
0%
100%
100%
53

Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Table 18
Jefferson Marrero Louis H. Marrero Home
Orleans New Orleans Porteus House; Lustron
Home; H. Jordan Mackenzie
House, "Blue Roof"; 445
Plaquemines Buras
Plaquemines Pointe-a-la-
Hache
South Rampart Street; 447-
449 South Rampart Street
1st Hospital in Plaquemines
Parish
Adema Plantation House
St. Tammany Covington
St. Tammany Mandeville
Original St. Tammany Parish
Courthouse
Rest-a-While; Magnolia Rest
St. Tammany Slidell Old Salmen Commissary
Tangipahoa Hammond
Vermilion Gueydan
Washington Franklinton
Allen Doss Martin House
Bouey-Moore House
Total Individual Buildings
1
2
42
1
2
2
2
1
1
1
5
0
3
0%
60%
0 0%
1 100%
1 100%
2 100%
2 100%
0 0%
1 100%
1 50%
30 74%
National Register
Status
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
National Historic
Landmark
National Historic
Landmark
Historic District
Historic District
Historic District
Historic District
Parish
Acadia
City
Crowley
Historic District
Crowley Historic District
Calcasieu
Jefferson
Lake Charles Lake Charles Historic
District
Gretna Gretna Historic District
St. Bernard
St. Bernard
Arabi
Arabi
Friscoville Street
Historic District
Old Arabi Historic
District
Vermilion Abbeville Downtown Abbeville
Historic District
National Register Historic Districts - Statewide
Orleans New Orleans Garden District
Orleans
Orleans
Orleans
Orleans
Orleans
New Orleans
New Orleans
Vieux Carre
Algiers Point
New Orleans Broadmoor
New Orleans Broadmoor Expansion
New Orleans Bywater
# of
Applicants
2
5
# of Funded
(Final)
1
2
%
Funded
50%
40%
1
8
20
1
37
12
48
14
46
8
58
0
4
17
1
25
7
18
6
25
4
24
0%
50%
85%
100%
68%
58%
38%
43%
54%
50%
41%
54

Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Historic District
Eligible Historic
District
Eligible Historic
District
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
Orleans
New Orleans Bywater Expansion
New Orleans Carrollton
New Orleans Carrollton Expansion
New Orleans Central City
New Orleans Esplanade Ridge
New Orleans Esplanade Ridge
Expansion
New Orleans Faubourg Marigny
New Orleans Gentilly Terrace
New Orleans Holy Cross
New Orleans Irish Channel
New Orleans Lower CBD
New Orleans Lower Garden District
New Orleans Mid City
New Orleans New Marigny
New Orleans Parkview
New Orleans South Lakeview
New Orleans Upper CBD
New Orleans Uptown
New Orleans Edgewood Park
New Orleans Pontchartrain Park
3
37
8
37
183
17
6
National Register Historic Districts - New Orleans 1163
Table 19
Property Use Number of
Applicants
# of
Grants
Allocated
890 366
# of Grants
Final
362
Grants per
Building Use
Primary Residence
Part Primary Residence/
Part Rental
252 106 99
89% Owner
Occupied
Rental Primary Residence/
Part Commercial Building
149 36 36
Commercial Building 78 36 35
11% Income
Producing
Rental Property 25 26 25
Not Available* 491 0 0
Total 1885 570 557
* Building use data was not entered in the information management system for all ineligible applicants
-
29
31
118
33
10
38
137
76
28
10
37
102
37
55
55%
71%
68%
27%
70%
32%
41%
36%
61%
50%
16%
18%
41%
33%
57%
63%
30%
45%
29%
33%
43%
7
12
56
27
17
16
22
80
9
18
15
5
6
1
21
5
11
83
5
2
502

Table 20
Congressional
District
1
2
3
4
5
6
7
Applicants Eligible
112
1680
66
1
7
2
17
1885
67
1115
44
1
4
0
11
1242
Funded Total Grant Expended
35
480
34
1
0
0
7
557
$1,116,223.00
$15,674,240.46
$1,177,340.00
$43,412.00
$0.00
$0.00
$268,146.00
$18,279,361.46
After the sub-grant funding was allocated, the next phase of the program began - execution and monitoring of sub-grant project activities. The next section of this report details the progression of a sub-grant project from beginning to end and articulates the challenges that were encountered along the way.
Historically, the LASHPO primarily served partner or local government agencies competing for limited funds available. Further to this objective, the HPF Manual provides guidance to SHPOs and other recipients as to the qualifications and expectations for anyone awarded funding through the HPF program. Under Chapter 8 of the HPF Manual, Subgrants, Contracts, and Third-Party Agreements,
Section D. Standards Applicable to Subgrantees, the language reads as follows:
“It is essential that precautions be taken by grantees to award grants only to reliable and capable applicants who can reasonably be expected to comply with grant requirements.
“To qualify a subgrantee as responsible, the State Historic Preservation Officer must ensure that a subgrantee meets and maintains the following standards as they relate to the scope of a particular project:
1.
Have adequate financial resources for performance, the necessary experience, organization, technical qualifications, and facilities; or a firm commitment, arrangement, or ability to obtain such (including proposed subagreements);
2.
Be able to comply with the proposed or required completion schedule for the project;
3.
Have a satisfactory record of integrity, judgment, and performance, especially with prior performance upon grants and contracts;
4.
Have an adequate accounting system and auditing procedures to provide effective accountability and control of property, funds, and assets sufficient to meet grantee needs and grantee audit requirements (see Chapters 21 and 23);
5.
Maintain Federal procurement standards which will comply with Chapter 17;
56

6.
Maintain a property management system for the acquisition, maintenance, safeguarding, and disposition of property (applicable standards are detailed in
Chapter 19);
7.
Conform with debarment requirements.
8.
Conform with the civil rights, equal employment opportunity, and labor law requirements of Federal grants; and
9.
Be otherwise qualified and eligible to receive a grant award under applicable laws and regulations.
“The award of grants to subgrantees (and contractors) who are not responsible is a disservice to the public, which is entitled to receive full benefit from the award of grants for the protection of cultural resources.
“Such awards are unfair to other competing applicants capable of performance, and may discourage them from applying for future grants.”
Under the Standards for Sub-grantees chapter of HPF, the objective of the funding was to invest in the protection of America’s cultural resources and to provide said funding to those with the capabilities and experience necessary to handle historic preservation requirements. Under the disaster recovery nature of the funding, many, but not all of the applicants applying for funding were very different than those
DISASTER
HPF
STANDARD
HPF served by the agency in the past. One end of the spectrum, the HPF is concerned primarily with the conservation of historic buildings that are places of importance and significance to the history of
America. On the other end of the spectrum, the needs of individuals to have a roof over their head became the first priority. As a part of this emergency supplemental allocation, the needs of historic buildings were essentially caught in the middle. As a result, the rules of the HPF Manual and the needs of individuals as stewards of historic buildings began to diverge. In keeping with the HPF Grants Manual, sub-grantees were required to have knowledge of historic preservation principles, would have hired experienced preservation professionals to oversee their project, and would have had adequate time to thoroughly plan the rehabilitation work funded by the sub-grant.
18 The ESHPF was a departure from the standard HPF sub-grants awarded by LASHPO.
18 U.S. Department of the Interior, National Park Service, Historic Preservation Fund Grants Manual,
Chapter 8, Section D (2007), 8-3.
57

After Hurricanes Katrina and Rita, the needs of individual property owners became primary given the significant damage to historic buildings located in National Register Historic Districts. While individual property owners are stewards and owners of historic buildings, an individual is not required to be an expert in historic preservation practices, or to understand the working environment of the historic preservation community. The grant program was designed to make the program accessible to all rather than to the few who may have been able to meet the standards for sub-grantees articulated in Chapter
8 of the HPF Manual. The objective for targeting funding was to ensure that any eligible historic resource, and thus, any owner of that building, would be eligible to qualify for funding.
To help offset some of the challenges that may have been encountered by this new applicant pool, an eligibility category was established in the Action Plan narrative that allowed a single entity to submit a block of applications as a “Group” on behalf of multiple property owners. For instance, a Certified Local
Government or a Main Street organization could submit multiple applications on behalf of historic property owners within their jurisdiction. This structure is similar to another DHP grant program specifically for Louisiana Main Street communities called the Redevelopment Incentive Grant (RIG), which provides grants for facades or interiors of commercial properties. Under the RIG program, the applicant must submit the application to the local historic district commission in advance of submitting the application to the LASHPO. The intention is that for the property to be eligible for the grant, the grant must first be reviewed by the local historic preservation professionals – the historic district commission and the main street coordinator. This provides an opportunity for the applicant to receive a level of assistance that could benefit a potential grant recipient to the HBRGP program.
The group applicant needn’t be limited to a nonprofit applicant either. Oversight could be managed by a contractor or an architect, too. The key is to have an entity with the ability and experience to manage a construction project. Typically, certified local government staff or commissions or Main Street
Managers and their respective boards do not have the background or experience to manage the construction project. They would ideally need to outsource the overall construction management to a sub-contractor. The idea of having a single entity submit applications on behalf of the property owner is a solid one, in that the management of the grant responsibilities can be controlled and monitored on a more day-to-day basis, most likely by entities that more closely align with the HPF manual standards.
Once intake was completed, nine (9) Group applications were on behalf of 168 individual properties, with the largest block submitting on behalf of 70 properties and the smallest submitting on behalf of 4 properties. The Group Applicants identified were professional tax credit consultants, individual property owners with multiple rental properties, and nonprofit organizations who owned property specifically for redevelopment or community-based social service needs.
Applications Reviewed as a “Group Applicant”
GroupApp
Group Name, if applicable CountOf
Grant#
Yes-A
Yes-B
Yes-C J&R Rental Properties
23
12
16
Yes-D Julie Skjolaas
Yes-E Morris Kahn/Susan Smith, Contact
5
70
58

GroupApp
Group Name, if applicable
Yes-F 10 th Capital Management/Naghi Properties
Yes-G DMR Builders
Yes-H Preservation Resource Center
Yes-I UJAMAA Community Development
Corporation
CountOf
Grant#
11
4
21
6
168
Applicant
Preservation Resource
Center/Operation Comeback and
Rebuilding Together
Preservation Resource Center/
Rebuilding Together
Applications Submitted Grants Awarded
21
2
7
2
UJAMAA Community Development
Corporation/St. Peter Claver Catholic
Church
6 5
Julie Skjolaas 7 1
In the case of Julie Skjolaas, the resulting single application within the group received funding because it was an owner-occupied property and thus received preferential points. Using the Preservation
Resource Center as another example, they received a total of 7 grants to rehabilitate properties in the
Holy Cross neighborhood. They were able to leverage these grants to renovate and recirculate properties back into the community when few individuals were interested in rebuilding in the Lower 9 th
Ward because of the extremely high vacancy rates within the neighborhood (see also Partnership section xxx regarding Preservation Resource Center, National Trust for Historic Preservation Home
Again! programs). All properties awarded a grant for rehabilitation were sold at the conclusion of the sub-grant project to first time home buyers. In this instance, the concept of the Group Applicant worked to the benefit of the historic building as well as to the historic district as listed on the National Register of Historic Places since 1986.
LESSON LEARNED ON GROUP APPLICANTS:
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There were a few identified issues with the Group Applicant approach. First, there was insufficient time for a single group point of contact to serve as applicant and then identify and coordinate all completed applications for submission on behalf of the community. Further compounding the situation is that most public notices did not occur until late in October and into early November, which only left one month to prepare applications. Next, the Action Plan narrative articulated the protocol for group application submissions, but in the haste to build the program, this information was not readily translated into the grant program guidelines nor was information requested on the application form to evaluate the required criteria. This resulted in a random mix of grants from group submissions. It also made the identification of a Group Applicant challenging for staff. Further, during the evaluation review, the applications were reviewed as a whole, but evaluated individually. It did not matter that the applications came in as a group. Once they received a score the applications were placed in the mix with all the other individual applications. Another challenge this created is that group applicants were evaluated on the management capacity of the single point of contact; however, there was no place in the application that requested information to evaluate management capacity.
In the future, a better scenario would be to introduce a competitive application process for only group applicants, specifying the geographic area to be served. The applicant would receive a professional assessment of qualifications based on education, training, and previous construction experience restoring historic buildings. Once the group applicants have been selected, they would have an opportunity to identify the most worthy potential candidates using the resources of the local neighborhood, such as neighborhood association representatives, local business associations, and/or residents. The process for selecting the best candidates could be established by the LASHPO or it could be established by the local community as long as they defined the system utilized. It would be difficult for extremely large communities such as the Uptown National Register Historic District (see table 2) or under-represented neighborhoods such as the New Marigny National Register Historic District. This could be one of the benefits of having a coordinated effort for survey and assessment of historic districts as a part of any disaster recovery system. If a system could be devised that allowed a portion of the emergency supplemental funding to go for survey and assessment as it pertained to historic buildings, this funding could also go towards providing an intake system for more targeted distribution of public dollars.
An assessment of the applicant pool showed that in actuality, 413 property applications were submitted by an individual with more than one property, or 22% of the entire property pool. A total of 114 individual applicants submitted more than one application, but only 9 of these were identified as
“Group” applicants. Considering the significant number of multiple applications, this information should have been identified early in the process.
Out of the 114 applicants submitting multiple applications, 41 applicants received multiple grants or 7% of the total 570 grantee pool. Approximately $2.58 million was awarded to individuals who submitted multiple applications. Twenty-six of the 41 multiple grant sub grantees received only one grant out of all the applications submitted, totaling almost $885,000. There were 10 sub-grantees that received funding for each grant application submitted. The remaining 73 sub-grantees received nothing.
Lesson Learned: Multiple Property Applicants
By the application deadline, only a few applicants were identified as submitting multiple applications, or as a Group. Staff identified applicants as a Group if they worked directly with the LASHPO office and self-identified themselves as a Group applicant. The information management system was not set up to
60

identify duplicate contact information so many applicants submitting more than one property were not readily identified or coded as a “Group” applicant.
Generally, applicants to this program were owners of historic properties. However, the LASHPO recognized that some property owners were still displaced or may need assistance from family in completing the application or grant requirements and allowed another individual to submit the application and handle all grant related requirements on behalf of the owner. The Grant Program
Guidelines indicated that an applicant would be required to submit signed documentation of the owner’s permission and support for the project. Furthermore, in the case of divided ownership, owners comprising a majority of the property’s ownership were required to provide permission for the project.
19
Given the environment of loss on many levels associated with Hurricane’s Katrina and Rita, it was evident that many sub grantees would not have access to many of their personal documents, nor would this information be readily accessible via any governmental agency due to overarching closures. Proof of ownership was not required under the requirements of the application form nor was information on a property owner’s legal ownership of the building required to receive the grant. Information regarding whether or not a property was mortgaged was not requested and no title search was done on the property prior to authorizing a grant. All that was required was a signed Certification Statement at the end of the grant application. Ownership was based on the contact information provided on the grant application.
20
If a second person was listed on the application form, the LASHPO required a notarized statement from the owners indicating the person executing the grant had authorization to receive funds and conduct repairs to the property. Furthermore, an additional paragraph was added to the Grant Agreement:
The Grantee hereby confirms his/her authorization to assume full responsibility for the administration of grant funds and all requirements stated herein on behalf of the owner of the Property.
In total, there were 55 sub-grant projects with individuals acting on behalf of the owner of the property.
In most situations, it was a relation to the owner, such as a husband or wife, son or daughter, or niece or nephew. We also authorized management and grant awards to be allocated to a nonprofit organization acting on behalf of the owner. Two sub-grant projects were managed through a partnership with the
Preservation Resource Center, Rebuilding Together Program for low-income, elderly homeowners. This allowed payments to be made directly to the nonprofit who was also serving as the general contractor.
There were three ownership issues related to sub-grant projects out of 570, each detailed below.
David Margulis submitted an application on behalf of the current owner indicating he was under a bond for deed purchase agreement. During the staff review of applications to allocate funding under the second Congressional appropriation, the application was flagged due to ownership concerns.
19
Historic Building Recovery Grant Program Guidelines, Eligibility Requirements, National Register of Historic Places, page 4.
20
Historic Building Recovery Grant Program Guidelines, Eligibility Requirements, Hurricane-Related, page 4.
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Conversations with the attorney for Mr. Margulis on October 9, 2007 revealed that the land had been sold and there were plans to move the building. DHP The LASHPO authorized a grant on the conditions that Mr. Margulis become the legal owner of the property by March 1, 2008 and that once the building was moved, it must retain contributing status. There was no progress on the ownership issue for the property as of the
March 1 deadline. A notice was sent in April 2008 cancelling the grant and reallocating funds to the next available sub-
grant project.
There were significant challenges for many property owners resulting from the level of destruction, even one year after
Mr. Tyrone Taylor, lessee of the property?, applied for a grant on behalf of the property owner, Robert Lucien, Sr. During the sub-grant period, the lessee attempted to purchase the property, but was unsuccessful. Mr. Taylor stopped work on the property. He received the initial payment of $27,000 to begin repairs, but only submitted financial documentation for the storm. A total of 191 applications were submitted by designees on behalf of owners, or approximately 10 percent of all applications received.
Allowing a designee to submit
$14,500. Mr. Taylor failed to complete repairs by the grant agreement deadline or submit financial accounting for all funds received. The LASHPO initiated collection proceedings and manage the grant on behalf of the owner was prudent as many would not be able to against Mr. Taylor for the $12,500 owed. Mr. Taylor entered into a repayment agreement with the State and has returned
$8,000, with $4,500 still outstanding. handle the requirements necessary to complete the grant.
In all but a small percentage, ownership was a non-issue.
What was lacking however was an assurance that the owner
Another ownership issue under this sub-grant project is the responsibility for the five-year Preservation Agreement. Mr.
Taylor executed the Preservation Agreement with the State rather than owner of the property, Mr. Lucien, Sr. However,, the property has fallen into a state of neglect and the owner did not assume any requirements for the property. would assume responsibility in the event the person acting on their behalf was unable to continue in that role.
Rather than only requesting basic contact information for the
owner, the LASHPO should have requested specific information on the legal owners listed on the
The application submitted by Mr. Banks McClintock was for the renovation of 1228 Race Street, a three-story 10,000square-foot Italianate residence in the Lower Garden District.
The last major residence designed by noted architect Henry
Howard before the Civil War, the building was plotted in 1861 for John T. Moore, a steamboat captain and wholesaler.
When Hurricane Katrina hit, the house sustained serious property deed and/or mortgage note along with full contact information. Further, the legal requirements for owners should have clearly defined and included in the grant agreement. Lastly, property owners should have damage from wind and a sinking foundation. The problems were so severe that the City of New Orleans red-tagged the property as eligible for demolition. HBRGP helped fund the unearthing and rebuilding of the original, underground wine cellar as part of the effort to address the foundation issues been required to sign the
Preservation Agreement rather than a designee. and remove the red-tag listing. The grant also contributed to repairing hardwood and marble tile floors, the front porch foundation, masonry and windows, along with reconstruction of 12 marble mantels. The owner of the property is Ms. Jennifer Coolidge, but her
62

partner, William “Banks” McClintock handled all the repairs from a joint checking account. The two individuals ended the partnership during the grant period, at which point Ms. Coolidge became aware of the federal requirements on her property. She did not provide any permission to work on the project and was unaware of the federal grant awarded for repairs to the property. After working with the attorney for Ms. Coolidge, the LASHPO was able to transfer the rights and requirements of the sub-grant to Ms. Coolidge, including the grant agreement and Preservation Agreement and to receive all necessary financial documentation to evidence grant expenditures.
The HBRGP program utilized the existing grant agreement imposed for all HPF grant recipients. The grant agreement between the LASHPO and the sub-grantee was also reviewed and vetted by the DCRT legal counsel. There were a few modifications proposed to the grant agreement that were intended to address requirements of the Hurricane Recovery Program.
First, the Grant Agreement draft included new language related to the hurricane recovery program documents, including the Grant Program Guidelines, the Secretary of the Interior Standards, and the
Programmatic Agreement. The standard agreement originally included provisions for OMB circulars only.
The Grantee will do all work in accordance with the State's Historic Building Recovery Grant
Program Guidelines, the U.S. Secretary of Interior’s Standards for Rehabilitation, the
Programmatic Agreement between the National Park Service and the Division of Historic
Preservation and with the applicable OMB Circular A-133 or A-110 "Uniform Administrative
Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and
Other Nonprofit Organizations" or OMB Circular A-128 or A-102 "Uniform Administrative
Requirements for Grants and Agreements with State and Local Governments" and the federal cost principles set forth in OMB Circular A-122 for nonprofit organizations, OMB Circular A-21 for public and private schools of higher education, and OMB Circular A-87 for state and local governments including state, local, or federally recognized Indian tribal governments shall be used to determine the applicability of costs accrued and to confect all required statements and reports. In the event the grantee deviates from the Scope of Work or work is not incompliance, further payments will not be allowed and the State may begin recoupment procedures for payments already made.
There was a concern that the typical grantee would not understand the requirements set forth in this paragraph as this was the first time these requirements were mentioned, with the exception of the
Standards for Rehabilitation. First, efforts were made to try to obtain and distribute easily understandable guidelines on the OMB circulars. Hurricane recovery staff was unable to find any detailed specifics related to these legal requirements and as the language was mostly applicable to nonprofits and government agencies, no information was forwarded. Next, an Attachment was proposed for the grant agreement that would include the Programmatic Agreement as this was the first time a sub-grantee would be made aware of the requirements set forth in that document. The proposed Attachment was removed as the Programmatic Agreement was not finalized until March 12,
63

2007 and the Treatment Protocols were still in draft format when the initial grants were executed. A suggestion was made to provide a copy of the Programmatic Agreement to each sub-grantee at a later date. This information was not formally integrated into the sub-grantee’s management plan.
Secondly, a paragraph was added in lieu of requiring sub-grantees to execute a separate Preservation
Agreement document. The language proposed to the National Park Service in the Action Plan narrative stated:
Per National Park Service regulations, grant recipients must execute a Preservation Agreement with the State Historic Preservation Officer. The Agreement states that the grant recipient/property owner will: (1) properly maintain and repair the property as necessary, and (2) obtain written permission from the SHPO prior to any visual or structural alterations to the property for a period of five years from the date of completion of the project.
Given that the agreement was to be executed at the completion of the grant, the following clause was amended into the grant agreement:
The grantee will properly maintain and repair the property as necessary and obtain written permission from the State Historic Preservation Officer prior to any visual or structural alterations to the property for a period of five (5) years from the date of completion of the project.
The intent was to include any requirements of the sub-grantee during the life of the grant period in the grant agreement scope of work and that a separate Preservation Agreement would be executed at the completion of the project in an effort to provide a specific five-year timeframe with beginning and ending dates in the Preservation Agreement document itself. The brief language regarding the
Preservation Agreement was used instead of the more specific language found in the Historic
Preservation Fund Manual. On March 3, 2007, a month after the first grant agreements were executed,
NPS provided comments on the language of the grant agreement. The NPS draft comments included requiring a preservation agreement to be completed prior to awarding grant funds, in keeping with the requirements of the HPF Manual. The NPS comments were received by the LASHPO when over half of the 289 grant agreements were already executed and almost $3 million in grant funds expended. The
LASHPO did not address these NPS comments until the second round of funding because of the staff logistics and scheduling required.
During the second allocation of funding, the grant agreements were to be amended to include additional changes, including (a) the NPS comments from the initial grant agreement, (b) requirements for additional site visits and payment arrangements, and (c) requirement that all repairs be done by licensed and insured contractors as required by the State of Louisiana Licensing Law and in accordance with local permitting regulations. For (a) the information related to the preservation agreement was mistakenly omitted. Item (b) was implemented. Item (c) did include the reference; however, it should have also referenced that all repairs be completed to state and local building code. Building code requirements are different for each municipality and for the State. No staff member was formally trained in the uniform building code approved and required by any of the entities and as such, there was difficulty in applying the legal parameters to the quality of the repairs being completed.
In 2009, after a majority of the grants were nearing completion, the LASHPO reallocated funds to the next available applicants. NPS also advised that the grant agreement must contain provisions for repayment of funds received if the sub-grantee deviates from the scope of work and a property is
64

adversely effected, or if alteration and damage occurs to the building that makes the property noncontributing during the life of the grant. According to NPS, any funds allocated and expended would need to be repaid in the event the property is significantly altered.
Any exterior alterations to the building must be approved by the State prior to the work being done. If alterations are made that are inappropriate to the Secretary of Interior Standards these changes may cause the building to lose its contributing status, which will put the Grantee in default of this grant. This requirement becomes effective on the date of this grant agreement and extends five years past the completion date of the grant. In the event the Grantee deviates from the Scope of Work or work is not in compliance, further payments will not be allowed and the State may begin recoupment procedures for payments already made.
Should the State so elect to terminate this grant, the State shall reimburse the Grantee the federal and state shares of all eligible costs, direct and indirect, incurred prior to the effective date of termination with grant funds prior to said date. In the event the Grantee has received payment above and beyond reimbursable expenses, the Grantee shall return all remaining funds to the State.
Only 23 sub-grant agreements were executed using this new language, and only one sub-grant project was significantly affected, #00699 Kendrick Foster. This sub-grant project is currently in collection with the State of Louisiana Office of the Attorney General Collections Division.
Requirements. In addition to the General Requirements for Grant-Assisted Activity discussed in Section C and general
Development/Acquisition/Covenants Requirements in Section J.2., above, the following requirements apply to Development: Predevelopment.
In order to properly determine the appropriate treatment(s) to preserve a particular property, predevelopment preparation is required.
Predevelopment is the historical, architectural, and/or archeological research necessary to properly and adequately document the historic significance and the existing physical condition of the materials and features of a property or site; it must be performed prior to the commencement of development work. 1) Assess all Resources Present. Decisions to proceed with any proposed work are based on an analysis of the significance and integrity of all the resources present in an area, including architecture, historic landscape, and archeology. These decisions should not be based on information about only one type of resource.
21
Immediately following Hurricanes Katrina and Rita, it was clear that Louisiana’s, and in particular New Orleans’, vast historic building stock was seriously compromised.
Unfortunately, the LASHPO was not equipped to handle the type of devastation at the statelevel. Many issues needed to be handled at the local level as the State was dealing with all
64 parishes, in addition to the myriad federal undertakings now occurring as a result of both hurricanes. As a result, the burden of responsibility for the appropriateness of historic repairs was placed first on the property owner.
During the application process, all applicants were instructed of the requirement for repairs to meet SOIS. The grant program guidelines included the following paragraph related to
SOIS:
21 HPF Manual, Chapter 6. K.2.a.1,
65

The National Park Service funds this program. Under NPS regulations, all repair/restoration must conform to Secretary of the Interior’s Standards for Rehabilitation. The Standards are available on the National Park Service website (www.cr.nps.gov/standards.htm). The SHPO staff will assist each successful applicant in making sure the scope of work meets these
Standards.
The application required applicants to provide a scope of work outlining how the building would be repaired. However, it became apparent during the evaluation process that many individuals were not aware how to appropriately repair a historic building. The lack of awareness was anticipated and became a key factor in assigning a project officer to each sub-grant project to guide repairs to meet the SOIS.
All project officers were provided with a template and training on how to draft a scope of work. The following language was placed in the grant agreement as it pertained to the
Scope of Work:
Conduct all work in accordance with Secretary of Interior Standards for Rehabilitation.
To Project Officer: Insert itemized scope of work according to grant agreement and hurricane damage in accordance with the Secretary of Interior Standards. Include suggested and alternative materials, units, measurements, etc.
The intent was for the Project Officer to assess the application, inspect the property, and draft the scope of work on site with the owner present. The grant agreement was then be executed on site. These procedures were put in place by the Lt. Governor as all initial payments were to be executed within 45 days of the funding determination. In order to accomplish the timeline and benchmark imposed, the
Project Officers were limited for each property to no more than 3 hours, including travel time, photograph and inspection, review of all legal requirements of the grant, drafting of the scope of work according to the Standards, and execution of all the paperwork. The project officers had the application scope of work already typed and drafted within the grant agreement Scope of Work, but specific repair details to meet the Standards could not be developed until the property was inspected. Scopes of Work made apparent that there was insufficient time to thoroughly inspect the property, review the application scope of work, determine the appropriate repairs along with an appropriate budget, and draft the Scope of Work within the timeframe allotted. Project Officers were in the field four of five days each week with, at most, only one day in the office. Rather than require that each Project Officer meet with the property owner again to revise the Scope of Work, the Project Officers would provide consultation during site visits and amend Scopes of Work as needed after this initial site inspection.
Table xx shows the frenzy with which grant agreements, Scope of Work and payments were being processed immediately following the funding determinations.
Another issue that arose during the development of the Scope of Work was adding items that the applicant did not include in the application. Under typical grant programs, there is a very specific objective the person applying for a grant wishes to achieve, and ideally, the entity applying for those funds is very specific about how to achieve that objective. Funding is then evaluated based on the specifics on the application. Based on past experience, the LASHPO staff relied on this to be true. For example, in most tax credit projects, an experienced developer or architect would submit plans for
66

commercial tax credit projects, thus an expert would present a plan with a very specific preservation scope of work with a very detailed drawings, plans and specifications. Likewise, most HPF grants were submitted by applicants, local CLGs or universities to do very specific HABS drawings or surveys by experienced professionals. Many of these entities were able to take the time to contract with a consultant if they did not have the expertise in-house. However, under the HBRGP program, what was included in the grant application and reviewed by the panel related most to the type of work the homeowner felt he/she needed most to return to the house, creating a very different dynamic..
Because property owners were not equipped to develop a thorough and detailed renovation plan, they did not truly understand the needs of the building, the full renovation costs, and precisely where and when funding should be applied. Also, as often occurs during a rehabilitation project, additional needed repairs were discovered, whether from deferred maintenance, termite damage and infestation, or simply with what was going on with the use of grant funds.
To address poorly developed scopes of work in the application and unexpected problems once work began, a set of policies and rationale was developed for the initial round of funding:

Applications were evaluated and scored based on the scope of work - reasoning for keeping to what was in the application only.

Can't add items to the scope of work in the grant agreement if it wasn't in the application scope of work, can only modify the budget estimates - reasoning is that we don't want to receive an audit during this process and have them compare the application and grant agreement and they are completely different.

If it generally meets the scope of work, it is okay to expand to account for the full grant award - reasoning is don't allow completely new items unless they are moderately referenced in the original application.

Take it on a case-by-case basis
Some applicants had a benefit in that they put an entire project renovation in the grant application, which meant that we could have more options in what we placed in the scope of work. For instance, the number of applicants that were funded who put full scopes of work, meaning total project costs in the applications were above $45,000, which is 119 or 42% and the other 164 or 58% only included work at $45,000 or below. The latter, however, may or may not represent the full scope of the grant recipient's needed work. Based on this information, our discussion resulted in the following clarification regarding those grant recipients that you will all have - when the grant award may be more than what is allowed:

Determine the overall objective of the grant in line with the grant program objectives – is the grant for structural stability, basic habitability, repair of only character defining architectural features or a combination of all three.

Assess the property and review the grant application. Generally, if 75% of the grant budget is attributed to the original scope of work in the grant application, you can add additional items as long as those items are in the spirit of the application - related to structural issues, habitability, or architectural character - and as long as the expenses are eligible per the program guidelines.

If the scope of work is only one or two items, do not allow additional items to be added.
This guideline is intended for those applications that will likely be around $25,000-
45,000.
When the second round of funding was allocated, a policy was developed that allowed new items to be added to the scope of work, in particular because applicants had already been
67

notified that they would not be receiving a grant and thus moved forward with whatever repairs may have been necessary at that point in time. Now that a significant amount of time had elapsed, it was likely the requested repairs may have been completed, but other repairs may be necessary. Rather than passing over that individual grant applicant when additional hurricane repairs were necessary, a determination was made to allow new items to be funded as long as they qualified as hurricane damage.
Development.
1. General. Buildings, structures, sites, and objects listed in the National Register of Historic Places deteriorate over time; therefore, these properties require periodic work to preserve and protect their historic significance and integrity. The Secretary of the Interior's "Standards for the
Treatment of Historic Properties" (see Appendices) define appropriate treatments for historic properties. 2. Requirements. In addition to the
General Requirements for Grant-Assisted Activity discussed in Section C and general Development/Acquisition/Covenants Requirements in
Section J.2., above, the following requirements apply to Development: 3) Reports of Predevelopment Studies Must be Prepared. Historic
Structure Reports, Engineering Reports, Landscape Studies , Archeological Documentation Reports, and other required documentation must present an assessment of potential impacts on the proposed work on the resources and must clearly illustrate how the work will be carried out in conformance with the Secretary’s “Treatment Standards,” with the “Archeological Documentation Standards” if applicable, and with other accepted professional standards or technical guidance for resource preservation, when relevant. These reports must define the project so that all aspects of the proposed grant-assisted work can be understood by objective reviewers familiar with the applicable Secretary of the Interior’s
“Standards for the Treatment of Historic Properties.” The scale and complexity of the proposed work will determine the amount of research required to carry out work in a manner consistent with the Secretary’s “Standards.” Such predevelopment reports are not a substitute for detailed working plans and specifications. (See also Chapter 13, Section C.8. if preagreement costs are involved).
4) Working Drawings/Architectural or Archeological Plans and Specifications Must be Prepared. These required documents must detail the exact scope of development work to be carried out, and must be accurately drawn to scale so that measurements can be verified at the project site. Plans and specifications must define the project so that all aspects of work can be understood by objective reviewers familiar with the applicable
Secretary of the Interior’s “Standards for the Treatment of Historic Properties.” The plans and specifications must demonstrate conformity with those “Standards” and specify the treatment proposed. If the treatment is the stabilization of an archeological site, the particular technique selected must be one that protects the site and its contents from further damage. Archeological stabilization plans and specifications must be prepared and/or reviewed by professionals who have technical expertise in such work.
22
1.
Use of Grant Funds When Repairs Have Been Completed
It is anticipated that a percentage of the next round of grantees will have either completed a large portion of the work scope proposed in their application in the intervening nine months or have finished completely. To address the issue of No Retroactive Reimbursement per the National Park
Service narrative, yet at the same time address the program’s ability to “execute grant agreements, developed in cooperation with assigned project officers, (that) will detail eligible work items.”
For those Grantees who have completed a portion of their scope of work or have completed all items:
If work proposed in original request is partially or completely finished – we will reallocate the extra funds towards any eligible work items up to 100% to fund items first, identified in the grant application, and 2) eligible, hurricane-related repairs that were not asked for in original application.
Round 2 funds are dedicated to hurricane recovery and there are still individuals waiting for grant funds to repair hurricane damage.
This policy assumes that in comparing Round 1 and Round 2 recipients that would potentially have an equal final scope of work for a property that includes work that is individually financed and grant financed. Round 1 would have utilized grant funds to address the most pressing needs for the historic structure. Round 2 would have utilized their own funds. Round 1, once the grant is over, could invest their own funds in historic elements. Round 2, as they have already addressed the most pressing needs for
22 HPF, Chapter 6.K.2.a.3 and 4
68

the property with their own funds, could now utilize the grant funds for historic elements.
A possible Round 3 Grant Program would allow new applications, under new guidelines. Within that program, the SHPO would consider applications that allows grant funds to be applied to historic elements that will improve the contributing status of the building.
Better site visit practices: a) Quality of work checklist that gives the PO guidelines on how to verify that the work already completed is up to the Standards of the grant. b) Increase requirement for mandatory site visits from 3 to 5. c) Legal recourse/plan of action to retrieve grant funds that have been misused or the Standards have not been upheld. Perhaps put together an outline for grantee on what the consequences are. Also a guideline for PO on how to track/document this problem. d) Hire David Gibney or a local craftsman to partner with PO on initial site visit to identify best solutions for proposed work as well as specific material recommendations. e) Amend the requirements in the grant agreement to have the appropriate building permits, the
HDLC permit when required, the hiring of licensed/insured Louisiana contractors for all electrical and plumbing work, etc. f) If we are given the opportunity to do an internal review on the potential grantees this are some of the suggestions for that process… g) Potential Guidelines/Handouts needed for Grantees: Pre-approved material list for specific work
(use David Gibney’s recommendations), Clarify what is considered Katrina damage and what will be considered pre-existing, Better contractor list, Material receipts – need to let them know that personal items need to be paid separately so that the receipt only reflects items for the grant
Chap 6. Pg. 6-2 c.5 Secretary of the Interior’s “Standards” Applied.
As a general rule, work supported by HPF or matching share, or reported in the End-of-Year Report must meet the Secretary's “Standards.” These include: 1) Standards and Guidelines for Preservation Planning, 2) Standards and Guidelines for Identification, 3) Standards and Guidelines for
Evaluation, 4) Standards and Guidelines for Registration, 5) Standards and Guidelines for Historical Documentation, 6) Standards and Guidelines for Architectural and Engineering Documentation, 7) Standards and Guidelines for Archeological Documentation, 8) Standards for the Treatment of Historic Properties, 9) Standards and Guidelines for the Rehabilitation of Historic Buildings, and 10) Historic Preservation Professional
Qualification Standards. See the Appendices.
States must document that grant-assisted work meets the Secretary’s “Standards” and other Historic Preservation Fund Grants
Manual requirements. Adequate documentation for this requirement is an official written record verifying who on the staff conducted the review, and/or wrote the opinion or recommendation; what the final opinion or recommendation was; and the date of the review, opinion, and/or recommendation. When an opinion pertains to more than one type of resource, and if staff members meeting the professional qualifications in different disciplines review the eligibility of the resource, each review must be documented. When individual reviewer opinions differ, the final decision must be clearly apparent. State offices may include this information in the appropriate project files or maintain a central file or logging system which references the project file. This documentation may take the form of written notes, use of a pre-printed stamp or review sheet, memoranda to files, or copies of letters.
69

Project Officer Notes to take for Site Visits:

Construction estimates – all/general and specific to the project

Style of House

Any age / info on his structure

Identify materials that pertain to proposed work
 highlight Secretary of Interior Standards clause – review green book and 10 Standards
 Develop work schedule (scope) / timeframe (their plans to start work) / structure of funds
(budget – how far the grant funds will go). Try and fund the most important item in its entirety first. Ex. roof
 Document proposed work … make sure that you photograph each work item on scope, take several shots as this can be critical on second site visit---photos of everything, not just damages-
--it will prove to be useful later. Also, photos of surrounding area or street---also handy when leveling issues come into play.
 Photograph owner/house … photograph owner in front of house (include entire elevation), get a close up of grantee, photograph any exterior elevations that you think may be relevant as a reference or documentation of before and after. You cannot have too many photos!
 Go over HDLC requirements for work
 talk about hiring construction/craftsmen, are there guidelines/requirements from our office on what they should require from their contractors other than license & proof of insurance
 Go over legal language of grant agreement
 Go over handouts – especially the paperwork information for the recordkeeping, need for photocopies, detailed invoices, canceled checks, etc
 Their responsibilities – hiring contractor, finding materials, executing the scope of work, etc. The project officer is not the project manager
 our responsibilities – provide guidance on how to execute the repair, inspect the repair, determine if repair meets Standards, approve repairs, review financial documentation, initial payment procedures
 what areas do we resource out, ie: PRC, local resources, etc
 What requirements do we have on how they manage the funds
 Pull originals folders to carry with you on site visit … should carry these with you in case you speak to someone on the phone, do not have internet and need info in their file .. also, download their date onto your laptop hard drive so it is available to you in the field … include scanned PDFs of their application photos (on H drive)
Do we do more than inspect quality of work after completion or do we do site visits periodically? More visits may delay the pace of the project if they wait for our input (due to incompatibility of schedules) and maybe should only be used for recipients who need the additional attention.
After the site visit:
 Tracking info: Project management .. keep database updated – fill in first site visit date, notes from site visit (this can be cut and pasted from site report), and contact data or other relevant information from site visit, make sure data matches W-9
 Site Visit Report – A site visit report is needed for each official site visit. It is recommended that notes are taken from each visit with Grantee so that conversations and solutions are documented for future reference.
Each grant recipient received a grant package at the first site visit
70

 A copy of the grant guidelines as it has all the rules and restrictions
 Secretary of Interior Standards and Guidelines for Rehabilitation for Historic Buildings (in best case scenarios, this information would have been pulled from the book and referenced in the grant agreement, or the pages that were relevant to the scope of work would have been highlighted with the owner. Rather it was simply a hand out for the owner to read at their own time – they didn’t read it or try and understand how to apply it.
 List of Preservation Briefs
 HDLC requirements
 Preservation Trades Network Guide
 Cost estimates averages for all proposed projects
 A professional estimate/invoice as a reference to what they can expect from a contractor
 Contractor Lists from PRC and BIA
To provide a perspective of the quantity and volume of reviews staff were engaged in during initial site inspections:
SiteInsp1
NPS Fund
Code
CountOfGrant# SumOfPay1
2/7/2007
2/8/2007
2/9/2007
5672
5672
5672
1
3
3
$26,100.00
$59,980.20
$63,981.60
2/13/2007
2/14/2007
2/15/2007
2/16/2007
2/17/2007
2/18/2007
2/21/2007
2/22/2007
5672
5672
5672
5672
5672
5672
5672
5672
10
9
8
7
7
2
7
9
$198,297.00
$170,744.00
$139,985.00
$156,120.00
$139,312.00
$40,050.00
$121,830.00
$207,570.00
2/23/2007
2/24/2007
2/27/2007
2/28/2007
3/1/2007
3/2/2007
3/3/2007
3/4/2007
3/6/2007
30-day benchmark
3/7/2007
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
8
6
6
8
8
10
4
1
8
125
9
$127,800.00
$109,110.00
$132,203.00
$188,550.00
$143,014.00
$228,191.00
$104,340.00
$3,006.00
$138,216.00
$2,498,399.80
$160,913.00
71

SiteInsp1
3/8/2007
3/9/2007
3/10/2007
3/12/2007
3/13/2007
3/14/2007
3/15/2007
3/16/2007
3/20/2007
3/21/2007
3/22/2007
3/23/2007
3/24/2007
3/27/2007
3/28/2007
3/29/2007
3/30/2007
4/3/2007
4/4/2007
4/5/2007
60-day benchmark
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/14/2007
4/17/2007
NPS Fund
Code
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
4/18/2007
4/19/2007
4/24/2007
4/25/2007
4/27/2007
5/1/2007
5/4/2007
5/8/2007
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
CountOfGrant#
7
4
1
6
8
6
8
7
6
9
8
2
1
2
8
4
6
4
2
9
117
2
2
41
2
4
2
3
1
2
4
3
5
5
4
2
SumOfPay1
$173,665.00
$151,500.00
$54,000.00
$17,700.00
$192,948.00
$123,891.00
$149,520.00
$132,054.00
$160,825.00
$144,660.00
$135,803.00
$95,082.00
$5,010.00
$81,960.00
$102,000.00
$40,800.00
$49,800.00
$201,390.00
$74,280.00
$151,433.00
$2,399,234.00
$82,350.00
$120,780.00
$93,344.00
$42,510.00
$37,074.00
$52,428.00
$55,706.00
$49,439.00
$84,558.00
$40,620.00
$73,200.00
$27,000.00
$54,000.00
$53,640.00
$866,649.00
72

SiteInsp1
NPS Fund
Code
90-Day Benchmark NPS Fund
Code
CountOfGrant#
CountOfGrant#
SumOfPay1
SumOfPay2
SiteInsp2
4/10/2007
4/12/2007
4/13/2007
4/18/2007
4/19/2007
4/20/2007
5672
5672
5672
5672
5672
5672
5672
1
1
1
1
2
2
3
$6,400.00
$17,800.00
$9,664.00
$18,064.00
$4,880.00
$9,000.00
$1,800.00
4/24/2007
4/25/2007
4/26/2007
5/1/2007
5/2/2007
5672
5672
5672
5672
5672
6
1
2
1
4
$9,000.00
$2,697.00
$27,751.00
$6,900.00
$26,700.00
5/3/2007
5/4/2007
5672 2
27
$16,255.00
$156,911.00
Sub-Total 90-
Benchmark
68 $1023,560.00
Beginning after the 60 day benchmark, sub-grant projects were underway and sub-grantees began requesting second site inspections.
2 nd Inspection: when we do quality control on the work in progress as well as the contractors, we should set up some standards of what to expect for each type of repair (– note from project officer)
The purpose of the Second Site Visit is to: a) Inspect work completed to date and ensure repairs are being done in accordance with the U.S. Secretary of Interior/National Park
Service Standards for the Rehabilitation of Historic Properties, b) Ensure all paperwork required for the grant is in order, and c) Approve 2 nd Payment of 20% of the grant award.
Review scope of work and see how far along the project is – how many items a) started and completed, b) started and in progress, c) about to be started, d) plan to start, or e) not even close to being started. that should reflect progress of the scope of work as well as payment.
Approve 2 nd payment depending on the percentage of items between (a) through (d) that you can say yes. If more than 80% percent, approve second payment.
In project management notes, indicate status of each work item or reference the budget – Dabne checks project management form before signing off on second payment.
1) pics of construction
3) compare to original scope of work –
73

5) advise on sec's standards if needed
Print out all photos so that you can compare what was there at your first visit and what has been changed, especially the doors or windows.
Print our budget and scope .. go over each item individually and make sure all work has been done .. make sure all costs are accurate
-hold off payment if one or more of the following occurs: a)work does not meet standards b)no invoices c)no receipts. d)no proof of payment e)apparent that little or no work has been completed, fraud or misappropriation of funds i.e., like a new
BMW in the driveway, etc.
A 2 nd Site Visit Procedures guide book was sent to every grantee after the 1 st site inspection and along with the grant agreement. This allowed the sub-grantee to be prepared for what was required during the next site inspection. [attach copy of all site visit procedure documents and hand outs to the appendix].
At your second site inspection, please have the following items organized for your Project
Officer:
1) During this site visit, the Project Officer will go over the original scope of work, document the completed work and clarify the work still to be finished as well as help to structure the logical sequence of the remaining repairs. Additionally, we will document the progress of each item in the grant scope of work (ie: we will define whether the work is completed, has been started or is in progress, about to start, planned with an estimated date, or no start date determined and the reason for delay).
2) Have copies of all receipts, invoices and contracts that have accumulated to date. You should be able to reference what payments are related to repairs indicated in your grant agreement Scope of Work (Attachment A) and Budget (Attachment B).
3) Have copies of all forms of payment made to date. You must show who was paid and that the form of payment has cleared the account. This must be in one of the following forms:

Cancelled checks

Cashiers Check

Bank statement

Credit card statement

Cash payments for materials are allowed as long as an invoice or receipt accompanies it and the receipt or invoice indicates “CASH” was paid for that specific item(s).

Cash payments for labor – in the form of a check made out to “CASH” - are not recommended; however, if you must pay for labor in the form of cash, you must submit a statement indicating why you paid cash. You must also submit invoices and receipts from the laborer that include name, address, telephone number, services to be provided, date payment was made and the amount. You should also include the laborers name or a reference to the repair in the “Memo” line on your check.
74

At this point, we received guidance from the Office of Management of Finance for DCRT that cash payments would be acceptable. The difference is who made out checks to cash with the required information and who didn’t. This is identified in the database in Financial documentation.
4) Please have your Itemized Grant Expenditures Form (Attachment C) filled out (page 8 in your grant agreement) to the best of your ability. This document should itemize and reference all the above receipts so that it states specifically what each invoice is for, how much money was paid out, and to whom (person/company) the funds went to. This allows the Project Officer to clearly understand where the grant monies have gone.
5) Please be able to show your general building permit from the city. For New Orleans properties, you will also need to show your HDLC (Historic District Landmark Commission)
Certificate of Appropriateness, if applicable.
6) Have copies of license and insurance for any contractor required to have this documentation. Note: We recommend that every contractor be licensed and insured for
your own protection.
7) You MUST contact your Project Officer for any changes that you want to make to your original scope of work BEFORE the work is started. A change order cannot be retroactive. This change order is a written description of the new work that you wish the grant funds to pay for and has to be signed by both you, the grantee as well as the State.
The change order form is page 9 of your grant agreement.
8) Attachments for your review:

National Park Service Standards for Rehabilitation of Historic Properties

Louisiana State Licensing Board for Contractors Public Education Website Information

Sample contractor invoices
During the Final Site Visit, the Project Officer will review all remaining work that has been completed since the second site visit, verify the invoices and receipts, document the project and take an “after” photo of you and your property. Since the final payment is a reimbursement to you for funds already expended, it will not be necessary to conduct any further site visits unless a work item or payment record comes into question. IMPORTANT: If you have completed work that is not according to federal standards for the repair of historic buildings or are not part of your scope of work, your repairs MAY
NOT BE ELIGIBLE under the terms of your grant agreement!
A GRANTEE EXIT INTERVIEW form was also created; however it is unclear if this form was placed into practice as few files have a record of the survey.
75

Secretary of the Interior’s “Standards” Applied. States must document that grant-assisted work meets the Secretary’s “Standards” and other
Historic Preservation Fund Grants Manual requirements. Adequate documentation for this requirement is an official written record verifying who on the staff conducted the review, and/or wrote the opinion or recommendation; what the final opinion or recommendation was; and the date of the review, opinion, and/or recommendation. When an opinion pertains to more than one type of resource, and if staff members meeting the professional qualifications in different disciplines review the eligibility of the resource, each review must be documented. When individual reviewer opinions differ, the final decision must be clearly apparent. State offices may include this information in the appropriate project files or maintain a central file or logging system which references the project file. This documentation may take the form of written notes, use of a pre-printed stamp or review sheet, memoranda to files, or copies of letters. 23
Due to the emergency nature of this grants program, the National Park Service waived the normal requirement for matching funds. Awardees received 60% of their grant payment upon the full signing of the grant agreement. Once work began, and the Project Officer was satisfied that the scope of work would meet NPS standards, he/she requested authorization for another 20% payment. The final 20% payment was authorized upon successful completion of the project, as determined by the Project Officer after making a final site visit, and after the applicant filed a final report.
Funds- dispersed in form of a check
-takes 2-3 weeks to get funds out
-they can use that timeframe to line up their contractors so when funding comes through They are ready to go .. we can help them with the priority of their work as well as a schedule
 stress the reimbursement
The grant agreement contained standard language requiring sub grantees to obtain written approval for any changes in the Scope of Work before the changes could be implemented. However, Project Officers would conduct follow-up site visits to monitor progress and authorize payments on sub grant projects.
During those visits, changes in the scope of work would be identified and an item needed to be modified, added to or deleted from the scope of work. A new scope of work would be drafted that identified the change to the original language and then the language that was modified, added or deleted. From there a new full scope and budget would be drafted for clarity to represent the most recent status of the project.
Grant Amendments were also intended to be completed at the final site visit to provide an approved final scope of work and budget for any items that were not complete or were modified. For administrative efficiency purposes, this process was reduced to simply state what was completed in the
Final Site Report rather than complete a formal agreement document that required signatures and routing to be effective. This ended up causing some confusion during the Section 106 process as items that were not completed either because the sub grantee ran out of grant funds or the grant agreement ended and was not extended were considered adverse effects as the sub grantee did not comply with the agreed upon scope of work. The HBRGP program operated more from the standpoint that hurricane damage needed to be repaired and we offered property owners a grant based on that amount. This also goes towards the evaluation criteria and how generic it was. The program operated off the assumption
23 HPF, Chapter 6, C.5.
76

that we were required to fund what was specifically requested in the application. However, most individuals really didn’t know what to ask for.
LESSON LEARNED:
Given the rapid pace of grant agreement executions, all scopes of work should have been amended to comply with the Standards, providing explicit and detailed specifications. However, sometimes these specifications were not known until the contractor’s work scope was submitted providing the technical requirements for the repair. Ideally, this work scope should have been incorporated into the State’s grant agreement. Under the first round of grants, however, there were no requirements for site visits, only follow-up visits to authorize payment. In the second round of grant funding, mandatory site visits were added to the grant agreement to ensure that all parties understand the requirements for compliance, both with documentation of the financial transactions and the quality of the repairs. When these site visits did occur, the information was not translated into a formal contract nor was there any follow-up other than a site visit record for the file. As the record keeping and grant agreement scope did not explicitly follow the Standards and Guidelines for a given repair, this lack of clarity in language lead to almost all instances of adverse effects.
Under the first grant agreement, there were no requirements for meeting with the subgrantees and contractors. In the second grant agreement, additional language was included that required the subgrantee to meet with the project officer prior to starting work and to meet with the contractor selected for the project. This was added as an assurance that the work would conform to the Standards and that the contractor had the required skills to work on the project. In most instances, subgrantees did not comply with these types of requirements as they were not familiar with required project management.
All files were assessed for overall completion at the end of the sub-grant project period. The following table summarizes the condition of the historic building at the end of the grant period.
Entire Renovation Completed (C)
In Progress at 50-80% Complete (PM: Partial Mid)
Only 10-50% Complete (PL: Partial Low)
77

TOTAL
In looking at the difference between the NPS grant allocations, the most significant difference in comparing project completion were for very large renovation projects. There were considerably more large renovations funded in the initial round of funding than in the second, 37 versus 11 overall, even though the amounts of funding were considered equal. These sub-grant projects would have been determined a priority by the Grant Evaluation Committee due to the integrity and significance to that community or historic district resulting in a higher score overall. The following table shows the comparison and significance of buildings:
Score NPS Grant#
Project
Completion
Location / National Register
Historic District Building Name Grant#
4.600 22-06-HR-21572 PM-LG
4.257 22-06-HR-21572 PM-LG
4.217 22-06-HR-21572 PM-LG
4.214 22-06-HR-21572 PL-LG
4.167 22-06-HR-21572 PM-LG
4.167 22-06-HR-21572 PM-LG
4.100 22-06-HR-21572 PL-LG
4.083 22-06-HR-21572 PM-LG
4.033 22-06-HR-21572 PL-LG
4.029 22-06-HR-21572 PL-LG
4.000 22-06-HR-21572 PL-LG
4.000 22-06-HR-21572 PL-LG
3.950 22-06-HR-21572 PM-LG
3.938 22-06-HR-21572 PM-LG
3.938 22-06-HR-21572 PM-LG
3.920 22-06-HR-21572 PL-LG
3.914 22-06-HR-21572 PL-LG
3.883 22-06-HR-21572 PL-LG
Esplanade Ridge
Lake Charles Historic District
Lower Garden District
Buras, Louisiana
Carrollton
Mid City
Downtown Abbeville Historic
District
NO Jazz and Heritage Festival and Foundation
Gov. Sam Houston Jones
House
1st Hospital in Plaquemines
Parish
Canal Street Guesthouse
The Frank's Theater
00601
00700
00051
01804
00735
00004
00673
Lower Garden District
Holy Cross
Donaldsonville, Louisiana
Holy Cross
Pointe-a-la-Hache, Louisiana Adema Plantation House
Lower Garden District
Vieux Carre
Lower CBD
The Doll House
00119
01549
01539
Boudreaux's Jewelry Building 01026
Esplanade Ridge
Crowley Historic District
Mid City
Griffin House (Henry
Howard, Architect)
Lemann Block Building
L'Hote Townhouse
Grand Opera House of the
South
01680
00884
00307
01719
01383
01163
01610
78

3.883 22-06-HR-21572 PM-LG
3.867 22-06-HR-21572 PL-LG
3.867 22-06-HR-21572 PL-LG
3.850 22-06-HR-21572 PM-LG
3.843 22-06-HR-21572 PL-LG
3.820 22-06-HR-21572 PM-LG
Faubourg Marigny
Uptown
Broadmoor Expansion
Lower Garden District
Lacombe, Louisiana
Esplanade Ridge
Musee Rosette Rochon 00167
00797
00739
00070
Rankin House/Fountainhead 00058
00711
E.F. Virgin Building (James
Dakin, Architect) 01813 3.786 22-06-HR-21572 PL-LG Lower CBD
3.786 22-07-HR-21671 PL-LG
3.786 22-07-HR-21671 PL-LG
3.783 22-06-HR-21572 PL-LG
3.775 22-06-HR-21572 PL-LG
3.775 22-06-HR-21572 PL-LG
3.775 22-06-HR-21572 PL-LG
3.767 22-06-HR-21572 PM-LG
3.733 22-06-HR-21572 PL-LG
3.686 22-06-HR-21572 PL-LG
3.667 22-06-HR-21572 PM-LG
3.667 22-06-HR-21572 PM-LG
3.633 22-06-HR-21572 PM-LG
3.571 22-07-HR-21671 PM-LG
3.567 22-07-HR-21671 PL-LG
3.550 22-07-HR-21671 PM-LG
Lower CBD
Lower CBD
Lower Garden District
Vieux Carre
Upper CBD
Upper CBD
Holy Cross
Broadmoor
West End Boulevard,
Lakeview, New Orleans
Carrollton Expansion
Uptown
Esplanade Ridge Expansion
Mandeville, Louisiana
Algiers Point
Central City
E.F. Virgin Building (James
Dakin, Architect)
E.F. Virgin Building (James
Dakin, Architect)
St. Philip Street Ventures,
LLC.
Julia Row, Good Sisters LLC
Julia Row, Good Sisters LLC
Porteus House
Rest-a-While, King's
Daughters and Sons of
Louisiana
01814
00845
00854
00900
01374
01368
00009
00692
01003
00545
00623
00234
01782
00285
00455
3.517 22-07-HR-21671 PM-LG
3.500 22-07-HR-21671 PL-LG
3.460 22-07-HR-21671 PM-LG
3.383 22-07-HR-21671 PM-LG
Lower Garden District
Garden District
Esplanade Ridge
Uptown
John T. Moore House (Henry
Howard, Architect)
Magnolia Mansion LLC
01686
01678
00370
01347
3.367 22-07-HR-21671 PL-LG
3.333 22-07-HR-21671 PL-LG
3.300 22-07-HR-21671 PL-LG
Mid City
Holy Cross
Esplanade Ridge Carver Theatre
00020
01002
00038
3.280 22-07-HR-21671 PM-LG Esplanade Ridge 00604
Forty-six percent of projects were completed with the original parameters of the grant program end date; no extensions were required. The remaining 20 percent were completed, but required additional
79

time to finish their project. Given that the grants only covered a percentage of the repairs, two thirds of all sub-grant projects were completed and individuals were able to live in the hurricane damaged property. An additional 8 percent were extremely large renovation project that would likely be on-going for a significant period of time after the grant ended. These projects would also require a significant investment to complete the repairs, well beyond what was available from the grant. The 97 projects that were considered in progress and nearing completion were the first to be assessed for completion during Preservation Agreement Compliance Reviews. The 47 projects that were categorized as “Partial-
Low” are those that required stabilization. In these cases, the grant was intended to serve a very specific purpose as to not jeopardize the property causing the building to be demolished.
On average, it took a sub-grant project one year and 4 months to complete project activities. The shortest amount of time to complete a grant was 59 days, ending on 6/8/2007 and the longest was
1100. The last sub-grant project ended on 5/27/2011.
6 months
1 year
1 year and 6 months
2 years
2 years and 6 months
Up to 3 years
Only received
1 st Payment
40
95
146
214
30
6
7%
17%
26%
38%
5%
1%
39 7%
570 100%
The original end date for the initial round of grants was September 15, 2008. Seven days before this deadline occurred, Hurricane Gustav hit south Louisiana causing widespread damage throughout the
Baton Rouge area. Many sub-grantees were evacuating just prior to the end date and were unable to finish the last requirements of the grant by the 15th. For this initial round of 289 sub-grant projects, 70 percent of sub-grantees finished on schedule and 70 sub-grantees were issued an extension through
November 1 st as a result of evacuations due to Hurricane Gustav. An additional 19 sub-grant projects required extensions as late as March 1, 2010. The second allocation of funding originally intended on ending June 30, 2009. There were 180 sub-grant projects that finished on schedule. Many sub-grant projects in the second round of funding required significantly more extensions to complete their projects, roughly half of the sub-grant projects requiring extensions only needed an additional 4 months, but the other half were extended as late as March 30, 2011. Any returned or unused portions of initial grant allocations were reallocated. Those reallocated grants in the second round of funding ended between October 31, 2009 and January 30, 2011.
NPS Grant# Deadlines & Extensions
By 9/15/2008
Count
198
Percent
66%
22-06-HR-21572
Gustav Extension 70 24%
Completion Extension
New Grants (Reallocated) Post
20
10
7%
3%
80

Deadline
22-07-HR-21671
By 6/30/2009
Completion Extension
New Grants (Reallocated) Post
Deadline
Total: 298
180
75
17
Total: 272
100%
66%
28%
6%
100%
During the determination of effect reviews of each sub-grant file, if a repair was not completed to SOIS this action was determined to be an adverse effect under Stipulation IV of the PA as stated above. In addition and according to HPF, a repair not completed to SOIS would be considered unallowable per
Chapter 13, section D.30; therefore, the sub-grantee would then be placed with bear the cost of the expenditure and any additional costs incurred from the mitigation. As discussed later in this report, based on the disaster and emergency response nature of this funding, the reality that sub-grant projects were managed by predominantly low-income, property owners who were not well versed in preservation requirements, and the conflicting guidance LASHPO received, the costs of these repairs were paid under the grant is some circumstances.
During the determination of effect for Section 106, an analysis of the financial documentation on file was also conducted. During sub-grant project monitoring, the Project Officer was required to photo document and inspect repairs during the course of the project. They were also required to review all the financial documentation provided by the sub-grantee. In 2007, staff met with their state agency’s
Office of Management & Finance (OMF) to review procedures and documentation required to authorize payments and to close out files. OMF verified that the procedures and the HBRGP required documentation were sufficient. For example, if there was visual evidence of a repair, but there was insufficient documentation, sub-grantees were permitted to obtain notarized affidavits attesting to the cost of the expenditure rather than disallowing those expenditures. NPS has indicated a notarized affidavit may not be sufficient. Additionally, LASHPO, with OMF’s approval, accepted documentation showing that payments were made in cash for labor or repairs. NPS has indicated that payments made with cash are not allowed for labor. Lastly, sub-grantees were required to follow federal procurement policies per HPF Chapter 17, Procurement Standards. As such, these expenditures by sub-grantees may also be ineligible. It is estimated that 35-45 percent of sub-grant projects may have procurement and/or financial documentation deficiencies, in particular for cash payments rather than payment by check or credit card. It should also be noted that the LASHPO does not have staff sufficiently trained in federal procurement requirements issued by the federal Office of Management and Budget, and it is the opinion of the LASHPO that the HPF Manual does not provide sufficient guidance on this issue. In both circumstances (a) and (b) detailed above, NPS has verbally indicated these costs may be allowable; however, no final determination has been made.
NPS GRANT 22-06-HR-21572
(298 Sub-Grant Projects/$9,618,219.83)
1. Sub-Grant Repairs Not SOIS Total 33 $400,528.41
81

2. Collections Total
Attorney General
Internal Payment Plan
Pending Determination
3. Financial Documentation Total
TOTAL i
NPS GRANT 22-07-HR-21671
(272 Sub-Grant Projects/$8,948,539.63)
1. Sub-Grant Repairs Not SOIS Total 33
2. Collections Total 22
Attorney General
Internal Payment Plan
Pending Determination
3. Financial Documentation Total
5
12
5
50
TOTAL ii 105
COMBINED
(570 Sub-Grant Projects/$18,566,759.46)
1. Sub-Grant Repairs Not SOIS Total 66
2. Collections Total
Attorney General
27
7
Internal Payment Plan
Pending Determination
3. Financial Documentation Total
TOTAL iii
13
7
117
210
1
2
5
2
67
105
$67,431.60
$53,385.60
$4,500.00
$9,546.00
$764,101.13
$1,232,061.14
$430,503.78
$233,573.00
$58,579.00
$118,879.00
$56,115.00
$732,656.67
$1,396,733.45
$831,032.19
$301,004.60
$111,964.60
$123,379.00
$65,661.00
$1,496,757.80
$2,628,794.59
82

Cash
No
Cancelled
Check
No Invoice Fraud Not Eligible Not In SOW No Receipt Theft
Cost $1 141 976, $154 425,06 $71 255,45 $71 049,00 $26 731,68 $22 682,98 $7 137,25 $1 500,00
Count 108 25 12 6 5 6 7 1
The total Financial Documentation exposure cost is $1,496,757.80 within 117 sub-grant projects; however, some subgrant projects contained multiple issues. Overall, 170 issues were identified within sub-grant projects.
70
60
50
15
40
12
30
20
46 3
33
10 22
15
5
8
3
8
0
Invoice/Receipt/ None
Affidavit
The LASHPO has devised an accounting system so that any funds received after the NPS grant period ends is accounted for and the funds returned to NPS. This includes any payments received on the
$12.5 million NPS grant after May 31, 2012 and any payments received on the $10 million NPS grant after May 31, 2013.
83

22-06-
HR-
21572
22-07-
HR-
21671
22-07-
HR-
21671
22-07-
HR-
21671
NPS
Grant#
22-07-
HR-
21671
22-07-
HR-
21671
22-07-
HR-
21671
22-07-
HR-
21671
22-06-
HR-
21572
22-07-
HR-
21671
The LASHPO terminated the grant agreement without a formal determination of adverse effect if a grant-funded repair negatively impacted a property’s National Register eligibility or if the sub-grantee was not compliant with the scope of work or project officer’s guidance. Remind me again – did we require repayment? Something needs to be included about the financial implication of terminating the grants.
Grant# GrantFina l
00030 $0.00
00038 $0.00
Paid GrantOrigina l
$0.00 $45,000.00
$27,000.0
0
$45,000.00
Amount
Owed
$27,000.0
0
Repayment
Code
Subgrantee
William &
Pomeroy
Lowry
Eugene
Oppman
00114
00510
00699
00753
$0.00
$0.00
$0.00
$0.00
$27,000.0
0
$27,000.0
0
$27,000.0
0
$5,280.00
$45,000.00
$45,000.00
$45,000.00
$6,600.00
$27,000.0
0
$27,000.0
0
$27,000.0
0
Internal
Payment Plan
All
Pending
Determinatio n
Internal
Payment Plan
All
Attorney
General All
$5,280.00 Paid in Full
Percy Gray
Keith M.
Pete
Kendrik D.
Foster
Kenneth
Johnson
00947 $0.00 $25,200.0
0
$42,000.00 $25,200.0
0
Paid in Full Brenda J.
Kernell
22-06-
HR-
21572
22-07-
HR-
00962
01202
01334
01482
01803
$0.00
$0.00
$0.00
$0.00
$0.00
$27,000.0
0
$24,600.0
0
$27,000.0
0
$27,000.0
0
$16,560.0
0
$45,000.00
$41,000.00
$45,000.00
$45,000.00
$27,600.00
$24,600.0
0
$27,000.0
0
$27,000.0
0
$16,560.0
0
Attorney
General All
Internal
Payment Plan
All
Internal
Payment Plan
All
Attorney
General All
Internal
Payment Plan
Wayne
Washingto n
Cheryl R.
Austin
Victor W.
Davis
William
Inlow
Etta Y. Polk
84

21671
22-06-
HR-
21572
01804 $0.00 $26,933.0
0
$44,888.00 $26,933.0
0
All
Paid in Full Dana Johno
During the course of a sub-grant project or upon completion of the project, if a sub-grantee did not provide sufficient financial documentation nor could repairs be verified through qualified site inspections, funds would be withheld or the sub-grantee would be responsible for repayment of funds received. In half the cases where repayment of funds was required, the sub-grantee made one payment in full. However, there are currently twenty-one (21) sub-grantees in collections and six (6) are pending determination based on a variety of factors, including death, bank repossession, eligibility, and assessment of allowable costs. Of the twenty-one, seven (7) have been or will be sent to the Attorney
General for collection and fourteen (14) are currently in payment plans with the Office of Cultural
Development. For those in payment plans, a sub-grantee pays the State an amount each month and the balance is owed in a final balloon payment at the end of the agreement period. Under the $12.5 million, one balloon payment of $4,500 is owed, and we are in the process of collecting that payment. All other remaining balloon payments are due in December 2012. The balances for Attorney General collections and internal payment plans are as follows:
[these numbers need to be updated]
Repayment Code
Attorney General All
Attorney General Partial
Internal Payment Plan All
Internal Payment Plan Partial
Pending Determination 6
TOTAL 27
Paid in Full 27
No. of
Subgrante es
3
4
6
8
Total Amount
Paid to Sub-
Grantee
Owed
$54,000.00 $54,000.00
$73,481.00 $32,451.00
$149,160.00 $149,160.00
$235,200.00 $51,407.00
Balloon
Payment
(Portion of
Owed)
N/A
Received
$698.00
N/A $0.00
$83,860.00 $31,250.00
$32,012.00 $14,868
$124,565.00 TBD N/A $0.00
$636,406.00 $287,018.00 $115,872.00 $46,816.00
$592,425.00 $176,689.25 N/A $176,689.25
Generally, HBRGP grants were limited to $45,000 and as such did not meet the threshold for submission of Project Notification documents to NPS prior to executing the grant agreement. However, National
Historic Landmarks would have been required for review along with the Environmental Certification
85

document. It was not until the grants were completed that it was identified that 2 National Register
Historic Districts are National Historic Landmarks – the Vieux Carré and Garden District. In addition, three other properties with Landmark status were also awarded funds – Oak Alley Plantation,
Madewood Plantation, and Magnolia Plantation. A total of thirty (30) projects were submitted on June
27, 2012 for review by the National Park Service. Because of a lack of familiarity with project notification for sub-grant projects, the HBRGP program director did not set up sufficient protocols to identify these properties in advance. Furthermore, as Project Notifications were not submitted to the
NPS, neither was the required Environment Certification form.
LESSONS LEARNED:
During the application intake and eligibility review, properties were reviewed by the National Register according to the 5 eligibility options. These options did not include isolating those properties that were listed as National Historic Landmarks. The application should have included an additional eligibility category for National Historic Landmarks, so staff could identify these properties early in the process and provide the documentation required by the HPF manual to NPS.
The Section 106 undertaking is the LASHPO’s implementation of a disaster recovery sub-grant program funded by the Emergency Supplemental Historic Preservation Fund (ESHPF) appropriation. The LASHPO awarded 570 sub-grants. Of these, 78 resulted in adverse effects to historic properties. Seven of the adverse effects have been mitigated. Fifty-six resulted in an insignificant or minor adverse effect. Only
15, or 3% of all sub-grants, resulted in a severe adverse effect on historic properties.
The LASHPO hired SOI qualified staff as Project Officers. It was the LASHPO’s intent that the SOI qualified Project Officers would closely monitor sub-grantee projects for compliance with the SOIS. The
LASHPO believed this satisfied the requirements of Section 106 while also simplifying the review process to avoid undue delays, as provided for in the Louisiana Treatment Protocols.
On December 7, 2006, the LASHPO sent an email request to NPS requesting clarification on the
LASHPO’s authority to require non-grant funded repairs to meet the Standards. On January 3, 2007, an email circulated summarizing a phone conversation between the State Historic Preservation Officer (the
SHPO) and NPS regarding the issue of segmentation (Appendix A):
“Our [Louisiana’s] grant funds are limited with respect to the devastation we’re trying to address. Consequently, he [NPS] believes that we should only hold grantees accountable for following the Standards for the money we’re actually investing in their projects. And further, only those restorations we fund should be held to the five-year rule. So, if we fund a roof replacement, then only that activity should be held to the
Standards, and so on.” 24
The Louisiana Treatment Protocols submitted to NPS by February 9, 2007 also stated, “Appropriate sections of the Secretary of the Interior’s Standards for the Treatment of Historic Properties shall be used to administer construction project activities funded by the HPF Emergency Supplemental funds.”
24 Pam Breaux, email to LASHPO staff, January 3, 2007.
86

Emphasis added. Consequently, the LASHPO proceeded with SOI qualified project officers monitoring grant-funded rehabilitation work only. If a grant funded repair activity deviated from the Scope of
Work, the project officer reviewed the repair to see if it met the definition of an adverse effect as defined by 36 CFR 800.5(a)(1) and (2). The LASHPO did not define an adverse effect strictly by those individual repairs not completed to the Standards; rather, the project officer reviewed the repair in conjunction with all the qualifying characteristics of the building and assessed impact on the property’s overall context, location, setting, materials, workmanship, feeling, and association.
25 Ninety-seven percent of sub-grant projects were located within National Register Historic Districts; therefore, LASHPO staff assessed the impact to the building in context with the integrity of the Historic District, not only the individual building. The assessment would result in a determination of No Adverse Effect if: a) The single repair minimally impacted material and/or workmanship of a character defining feature of that building, b) The overall building retained sufficient integrity to remain a contributing element to the
National Register Historic District.
In February 2009 discussions between the LASHPO and NPS identified a possible deficiency in the
LASHPO’s Section 106 procedures. On June 30, 2009 the ACHP, NPS and LASHPO held a conference call to discuss several issues, including the Section 106 procedures. Following the conference call, NPS formally requested confirmation that Section 106 reviews for all sub-grants had been completed in accordance with the HPF Grants Manual.
26 A June 10, 2010 letter from NPS to the LASHPO states that the LASHPO’s Section 106 reviewers must conduct the reviews and an effect determination letter must be present in each file.
27 NPS further clarified that the entire building rehabilitation, both grant and owner funded, was to be reviewed; any repair item not completed to the Standards is an adverse effect; and removal of any intact historic material from the time the grant agreement was executed should be considered an adverse effect.
28 The requirement to review all repairs, not just grant-funded repairs, was in direct conflict with the initial direction NPS provided and with the approved Louisiana Treatment
Protocols.
29
Notably, the end date for all remaining grants occurred on June 30, 2009 with 93 percent of projects completed as of this date. Nevertheless, the LASHPO immediately began a Section 106 review of all subgrant projects in accordance with the new directive, starting first with those projects that were ongoing.
Based on the review of all 570 sub-grant project activities as newly defined by the NPS in its 2010 correspondence, seventy-eight (78) sub-grant projects resulted in an adverse effect determination, or 13 percent overall.
Upon conclusion of the LASHPO Section 106 review, seven (7) sub-grant projects identified as an adverse effect remained active under the terms of the grant agreement. The LASHPO authorized an amendment to the grant agreement scope of work to detail the mitigation measure instead of executing an MOA per
Stipulation IV of the PA. For the remaining seventy-one (71) adverse effect determinations, the projects
25 36 CFR
§
800.5(a)(1) “An adverse effect is found when an undertaking may alter, directly or indirectly, any of the characteristics of a historic property that qualify the property for inclusion in the National
Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling, or association.”
26 Hampton Tucker, letter to Scott Hutcheson, July 13, 2009.
27 Jon C. Smith, letter to Phil Boggan, June 10, 2010.
28 Id.
29 Pam Breaux, email to LASHPO staff, January 3, 2007.
87

had ended, with as long as two years passing between the determination of adverse effect and the end date of some of the grant agreements. The LASHPO did not attempt to individually mitigate these 71 sub-grant projects or execute individual MOAs. In an email from the ACHP following the conference call on June 30, 2009 (Appendix B) ACHP staff stated that if all the LASHPO can do is to document the property, that might be the sum total of the MOA.
Some of the difficulties the LASHPO faced in mitigating adverse effects and executing individual MOAs according to Stipulation IV include:
1.
Neither the HBRGP guidelines nor the grant agreement articulated to sub-grantees that the entire building renovation must meet SOI Standards.
2.
SOI qualified project officers originally approved many of the repairs now identified as adverse effects under the 2010 NPS guidance.
3.
HBRGP funds were allocated to those with the greatest financial need and those without financial resources. Sub-grantees are not able to finance subsequent mitigation efforts.
4.
Deferred maintenance was a major issue in many historic homes, resulting in significantly higher costs than estimated to repair hurricane damages.
5.
Some sub-grantees whose projects resulted in adverse effects were unresponsive and noncompliant with the legal requirements of the grant. The LASHPO is unable to make contact with sub-grantees and, therefore, has no way to develop mitigation strategies or execute individual
MOAs. However, the LASHPO has placed these sub-grantees in a collection process with the
Louisiana Attorney General.
6.
Under Stipulation IV consulting parties and members of the public must be invited to participate in the review of alternatives and the development of the mitigation/treatment plan.
30 The ACHP verbally expressed that it would be in the public’s best interest not to hold public meetings regarding an individual sub-grantee’s actions given the tenuous environment and disaster recovery nature of the funding.
The LASHPO endeavored to avoid adverse effects to historic properties by requiring project officers to conduct periodic site inspections of each sub-grant project. The LASHPO attempted to minimize or mitigate adverse effects as they occurred by amending a sub-grant project’s scope of work, requiring the sub-grantee to assume financial responsibility for repairs not to the Standards, terminating sub-grant agreements, and placing sub-grantees in a collection process with the Louisiana Attorney General or an
Internal Payment Plan. Due to the circumstances set forth herein, however, the LASHPO was unable to avoid adverse effects entirely.
30 Programmatic Agreement between the National Park Service, the Alabama State Historic Preservation
Office, the Louisiana State Historic Preservation Office, the Mississippi State Historic Preservation Office, and the Advisory Council on Historic Preservation regarding the Emergency Supplemental
Appropriations to the Historic Preservation Fund for Recovery from Hurricanes Katrina and Rita in the
Gulf Coast States, Stipulation IV, Item 6, March 12, 2007.
88

Table 21 provides a breakdown of all adverse effect determinations by number and percentage. Also, in consideration that all changes resulting in an adverse effect determination negatively impact the historic building in some way, but effects to the character, feeling and association will vary widely, some with no impact to others with significant impact. Table 1 classifies the adverse effect determinations according to the level of impact to the overall character and integrity of the historic building. The four levels of classification are Insignificant, Minor, Severe, and Mitigated.
The definitions are as follows:
Insignificant: designated when a repair to a portion of a character-defining element did not follow the Standards and Guidelines, but there is limited to no impact to the original integrity of the building and/or that element. The location, feeling, association, and context for the building remain the same.
Minor: designated when a repair resulted in the modification of a character-defining element, or when there are cumulative impacts to more than one character-defining element. Feeling and association are impacted, but the building still comprises sufficient elements to retain contributing status. This classification was typical in buildings that were severely gutted following the disaster (prior to grant funds being awarded) or when a contractor/craftsmen removed and replaced intact material rather than make repairs. These items resulted from a lack of detail on the exact method of repair in the scope of work. The implication is that “repair” translated to “replacement” in many instances.
Severe: designated when a building resulted in extreme gutting and other mass removal of original material by unqualified contractors, or alterations so significant the building is no longer considered a contributing element due to a loss in feeling, association and context. In most of these cases, the sub-grant projects were terminated for non-compliance and funding recouped as allowable.
Mitigated: designated when during the course of the project activity the grant recipient was financially able to cover both the cost of the inappropriate treatment and incur additional expense for the mitigation.
Table 21
Classification Percentage of all 78
Adverse Effects
Percentage of all 570
Sub-Grant Projects
Insignificant
Minor
Severe
Mitigated
Total
Number of Sub-Grant
Projects Resulting in An
Adverse Effect
31
25
15
7
78
40%
32%
19%
9%
100%
5%
4%
3%
1%
13%
89

Table 2 provides a list of all Adverse Effect determinations by classification with additional designations that impact the determination (see also the attached CD for illustrative images of each sub-grant project activity). The following definitions explain the column headings used in Table 2:
Special Determination: when federally funded repairs met the Standards, and thus the adverse effect determination was based on something other than the quality of the federally funded repair.
Demo by Neglect: when the sub-grantee did not continue repairs even though repairs completed met the Standards. These sub-grant projects typically resulted in reduced grant funding.
Repayment: when a sub-grantee did not fulfill the terms of the grant agreement and is now in a collection process. The determination is not based on the quality of the repair.
Terminated: when the State terminated the grant agreement and redeployed funds to other subgrant activities.
Design Review: when a sub-grant project resulted in a design change to the building, the Deputy
SHPO and the National Register Coordinator reviewed the sub-grant project activity to ensure the project retained contributing status before and after completion of the alteration. Design changes were in most circumstances the result of owner-funded activity, not federally funded.
Reconstruction: when a sub-grant project resulted in reconstruction of a building, either due to collapse of the structure or systematic demolition of intact, original material during rebuild.
Non-contributing: when a sub-grant project resulted in the property no longer remaining eligible for the National Register of Historic Places as a contributing element of the Historic District. NPS indicates NPS reviewed and concurred with the SHPO determination. SHPO indicates a review and determination by the SHPO only.
Collection Code: when the sub-grantee is currently repaying the state either because they did not provide any financial documentation to account for funds or federal funds paid for ineligible costs.
AG represents individuals that were unresponsive and are in collections with the Louisiana Attorney
General’s Office for recoupment of funds. IPP stands for “Internal Payment Plan” and represents individuals that entered into an agreement with the LASHPO and are repaying funds owed on a regular basis rather than going through the Attorney General’s office for official collection proceedings. Partial and All refers to the percentage of the grant repaid to the State. Partial means some work was eligible and the sub-grantee is only returning a portion of federal funds received. All means no work was eligible and the sub-grantee is returning all funds received.
Scope of Work Item: represents items in the grant agreement scope of work impacted by the determination.
Table 22
HBRGP Sub-Grantee Scope Of Work Item
00105
00155
Stella Parker
Danny Santiago Sr.
Classification Special
Determination
Insignificant
Insignificant Demo by Neglect
Collection
Code
Flooring
Framing, Siding,
Windows
90

00271
00283
00291
00382
00485
00602
00668
00693
00720
00727
00739
00784
00789
00796
00907
00928
00940
01235
01334
01337
01343
01460
01501
01551
01574
01588
01589
01725
01835
00099
00164
00237
00464
00521
00590
00621
Carmen Ledesma
Roland Williby Sr.
Michael Prados
Gerard Moore
LaJuan Booker
Alberta Graf
Bernice Crump
Eugene Meunier
Kathleen Cresson
Katherine LeBlanc
Donald Harrison
Frank D'Amico
Cheryl Raske
Robert Nelson
Charles London
Vanessa Johnson
Leonard Lewis
Deidra Taylor
Amy Davis
UJAMAA CDC
Glade Bilby II
Eric Franklin
Troy Legeaux
Shirley Charlot
Celeste Williams
Gloria Hilliard
Ella Ware
Jessie Rose
Rhodesia Douglas
Letitia Youngblood
Jason Sampler
Irvin Parker
Willie McCloud
Ray Bush
Minor
Minor
D. Joan Rhodes-Brown Minor
Vyntrella Menzies Minor
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Minor
Minor
Minor
Demo by Neglect
Terminated,
Repayment
Terminated
Terminated
Design Review,
Terminated
Terminated
Design Review
Terminated
Design Review,
Terminated
Repayment
AG, Partial
IPP, All
IPP, Partial
Repayment IPP, Partial
Gutters, Roof, Siding
Roof, Siding
Insulation
Flooring, Foundation,
Roof
Doors, Misc.
Roof
n/a – owner funded
Insulation
Insulation
Doors, Framing, Walls
Foundation
Misc.
n/a – owner funded
Insulation
Insulation
Doors
Doors, Windows
Doors
Foundation, Walls
Foundation
Walls
Siding
Gutters
Doors
Doors
Foundation
Foundation
Foundation, Siding,
Walls, Windows
Flooring
Doors, Flooring, Roof,
Siding, Windows
Insulation, Windows
Doors, Porch, Roof
Electrical
Additions, Roof,
Windows
Foundation
Doors, Foundation,
Millwork
91

00679
00736
00900
00916
01019
01224
01357
01416
01464
01472
01532
01542
01572
01638
01677
01740
01793
01852
00009
Wilfred Sanchez Sr.
Charline Cager
L. Bryan Francher
Mary Watson
Katie Pete
Nicholas Scapin
Almetta Matthews
Carlee Waites
Reving Broussard, Jr.
Edgar Poree, Jr
Mario Richard
Laurie Gilbert
Markus Wittmann Minor
Nathaniel Chesnut Minor
Christine Santa Marina Minor
Lucristia Woods Minor
Stanley Sinegal Minor
Gloria Prevost-Hicks
Adrian Allen
Minor
Severe
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
Minor
00029
00114
00169
Michael Homan
Percy Gray
Marcos Picolo
Severe
Severe
Severe
00444
00474
00613
Richard Powell, Sr
Lakeba Griffith
Fabian Smith
Severe
Severe
Severe
00699
00810
Kedrick Foster
Stephen Peychaud
Severe
Severe
Design Review
Demo by Neglect
Reconstruction
AG, Partial
Design Review
Non-Contributing
(SHPO),
Terminated
Non-Contributing
(SHPO),
Terminated
Design Review
Terminated
Non-Contributing
(NPS), Terminated
Reconstruction
AG, All
AG, All
Siding
Foundation, Millwork
Foundation
Doors, Porch, Walls
Doors, Flooring,
Foundation
Roof, Windows
Doors, Flooring,
Foundation
Foundation
Siding
Foundation
Windows
Doors, Millwork, Siding,
Windows
Doors, Millwork,
Windows
Foundation
Doors, Millwork
Siding
Doors
Doors, Windows
Demo, Foundation,
Framing, Millwork,
Porch, Roof, Siding,
Walls, Windows
Additions, Doors,
Millwork, Porch,
Windows
Additions, Foundation,
Siding, Windows
Additions, Doors,
Flooring, Foundation,
Porch, Siding, Windows
Roof, Siding
Doors, Foundation,
Misc., Porch, Windows
Additions, Demo,
Flooring, Foundation,
Framing, Millwork, Walls,
Windows
Additions, Demo
Demo, Flooring,
Foundation, Framing,
Millwork, Siding, Walls,
Windows
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00962
01202
01381
01529
Wayne Washington
Cheryl Austin
Lou Jean Sartin
JoAnn Najolia
Severe
Severe
Severe
Severe
Demolished,
Terminated
Non-Contributing
(NPS), Terminated
IPP, All
IPP, All
Non-Contributing
(NPS), Terminated
Reconstruction
Demo
Demo, Flooring,
Foundation, Framing,
Millwork, Roof, Siding,
Walls, Windows
Demo, Foundation,
Siding
Demo, Doors, Flooring,
Foundation, Siding,
Walls, Windows
Additions, Porch
Demo, Framing, Siding,
Windows
01739 Robert Bridger
01901 Mark Stephens
Mitigation Completed
00326 Henry Holzenthal
00762
01331
01718
01735
Ulysses Bentley
Dionnelyn Sampson
Ella Julian
James Hagerty
01798
00906
Cheryl Young
Deborah Walther
Severe
Severe
Insignificant
Minor
Minor
Minor
Minor
Minor
Severe
Non-Contributing
(NPS), Terminated
Reconstruction
Design Review,
Mitigation
Design Review
Mitigation
Design Review,
Mitigation
Mitigation,
Terminated
Design Review
Design Review
IPP, Partial
Foundation, Porch
Additions, Windows
Doors, Porch, Windows
Addition, Doors, Porch
Porch
Framing, Siding,
Windows
Additions, Doors,
Foundation, Roof,
Windows
The form used by the LASHPO as the Preservation Agreement for all completed grants is included in
Attachment A. The Preservation Agreement was signed at the final site inspection at the property.
The LASHPO will monitor all preservation agreements by making contact with a random sample of completed sub-grant projects twice yearly. A site inspection of the property will be conducted to ensure no unapproved changes have been made to the property since the completion of the grant agreement.
For sub-grant recipients who are ready to make a modification or repair to their property, the first step is to contact the LASHPO. The LASHPO will advise the sub-grantee and ensure all repairs or modifications to the property meet the Secretary of Interior Standards.
The LASHPO’s draft policy and procedure for monitoring is as follows:
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Monitoring includes steps that meet the federal requirements 31 that necessitate the SHPO to conduct occasional site visits and to send correspondence to sub-grantees reminding them of the requirements under their Preservation Agreement for monitoring and inspection.
LASHPO Monitoring
A.
An initial site inspection of the exterior of grant-funded building(s) will be conducted no earlier than 6 months after the completion of the grant project. These site visits are to be documented in the individual sub-grant project file and will consist of a written, dated form and contextual photographs of the exterior (see Attachment A Form and Instructions).
B.
It will be the responsibility of the Project Officer to identify properties that will have an interior
Preservation Agreement Compliance Review. The following criteria will be used by the Project
Officers to determine when an interior review is required:
1) If items were pending completion at the time of the grant’s conclusion, or the subgrantee indicated work would be completed.
2) Repairs that were written into the Grant Agreement Scope of Work but not completed upon final site inspection will be reviewed even if the grant funds were not sufficient to complete the repairs.
3) Poor projects, previously blighted properties, or any issue that may require additional follow-up.
NOTE: This agreement is not recorded with the deed and therefore is not enforceable on future owners. 32
C.
Correspondence to all grantees with active Preservation Agreements will be sent out prior to closure of HBRGP office. This correspondence will remind sub-grantees of requirements under the Preservation Agreement, consequence for non-compliance, and the contact information for the appropriate staff person of the LASHPO.
D.
Once the initial inspection is performed on all properties, occasional site visits and/or correspondence will be conducted during the five (5) year period of the preservation agreement by the LASHPO.
Sub-grantee Requirement to Notify LASHPO
A.
A sub-grantee shall notify the designated staff person of the LASHPO and detail the alterations or changes to the property, either verbally or in writing. If the alteration is a structural change or addition to the building/property/site/lot, architectural drawings will be required for review.
33
B.
The LASHPO will conduct a Preservation Agreement Compliance Review (exterior and interior) 34 with the sub-grantee and will determine whether or not the alteration or change meets the SOIS and/or how to modify the alteration or change so it meets SOIS. Changes to grant funded repairs, even if they meet SOIS should be taken into consideration. A meeting may be called as necessary to review appropriate alterations or changes to buildings.
31 HPF Grants Manual, Chapter 6, 6-31, M(3)(e)
32
HPF Grants Manual, Chapter 6, 6-28, M(2)(a)(1)
33
HPF Manual, Section M, 6-30, Covenants and Preservation Agreements, item 2(a) and requirements and item 3a-c, details on provisions for site protection, archaeology, and maintenance.
34 See Attachment A, HBBRGP Preservation Agreement Compliance Form and Instructions
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C.
Meetings with local historic district commission staff or other federal section 106 representative may be necessary. In situations where the property is under the jurisdiction of another entity, due diligence will be made by the LASHPO to receive comments from that entity prior to notifying the sub-grantee in writing. If there is only partial or no jurisdiction for a particular repair, the LASHPO will make the required determinations as to whether a repair meets the
SOIS. Local historic district commissions may issue the COA prior to LASHPO approval, in which case LASHPO may elect to issue an approval concurring with local historic district commission requirements.
D.
LASHPO determinations will be detailed in writing, either by email or in a letter to the subgrantee, with a carbon copy to any other local or federal entities with approval authority over the project. All correspondence shall be discussed with or reviewed by HBRGP Program Director prior to sending.
E.
The following procedures will be followed if a change is determined after the fact.
If the sub-grantee made an alteration to the property, but the alteration does not change the building’s status on the National Register of Historic Places and/or if the alteration was done to the Secretary of the Interior’s Standards for Rehabilitation, then no violation has occurred.
However, a courtesy letter should be sent to the sub-grantee reminding him/her of the requirement to obtain written permission prior to making any visual or structural alterations.
Written permission will not be necessary for instances of repairs for day-to-day maintenance.
35
All requests and alterations shall be documented in the HBRGP database in the Preservation Agreement sub-form and placed in the appropriate file – hard copy and electronic.
All approved changes should be monitored to ensure that the repair is completed. When a project is complete, it shall be checked off as completed in the HBRGP database Preservation Agreement subform.
3.Violations
This section defines what steps to take when a modification to the building has occurred since the final site visit without notification and/or approval of the LASHPO and the modification does not meet the
Secretary of the Interior Standards or compromises grant funded work.
A violation will occur under the following circumstances: 36
1.
If any alteration resulted in any loss of original material to the building that is not replaced according to Secretary of the Interior’s Standards for Rehabilitation.
37
2.
If any alteration is not to the Secretary of the Interior’s Standards for Rehabilitation.
35 See also the Secretary of the Interior’s Standards for Rehabilitation for guidance on maintenance and Attachment A: Preservation
Agreement Compliance Form Instructions.
36
, email from Hampton Tucker on 1/3/2007 that indicates only those items that were grant funded fall under the Preservation Agreement requirements.
37
Programmatic Agreement, Louisiana Treatment Protocols, “…to prevent inappropriate, incompatible, and/or irreversible changes…”
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3.
If any alteration irreversibly diminishes the integrity and character of the building to the point it is no longer eligible for the National Register.
4.
If the property is not being adequately maintained.
The following questions should be answered in making a determination that a violation has occurred. If the answer to the question is “No,” then a violation has occurred. a) Did the sub-grantee obtain written permission from the LASHPO before making any visual or structural alterations to the property?
38 b) Did the sub-grantee maintain his or her property as required by the preservation agreement?
39 c) Did the sub-grantee make inappropriate, incompatible and/or irreversible changes to the property?
40 d) Did the sub-grantee preserve the historical and architectural integrity of the features, materials, appearance, workmanship and environment that made the property eligible for listing in the
National Register of Historic Places? 41 e) Were changes or alterations made according to the Secretary of the Interior’s Standards for
Rehabilitation?
If a violation occurred, the file will go through a staff review and will then be forwarded to the HBRGP
Program Director or designee to confirm a violation exists. The LASHPO’s office will always be a party to the confirmation of a violation.
4Enforcement
The following procedures shall be followed when a violation is confirmed:
A.
Written correspondence will be sent to sub-grantee notifying them of the violation, required mitigation, and consequence for non-compliance. The sub-grantee will have thirty (30) days 42 to respond.
1.
If response from the sub-grantee is received before the deadline but mitigation cannot be started or, if started, cannot be completed within the timeframe, the LASHPO will work with sub-grantee to develop a viable work plan. (This correspondence will be sent by regular mail). Note: Extensions will be allowed for health, financial and logistical reasons.
2.
If there is no response from the sub-grantee, the LASHPO will send a second letter notifying the sub-grantee of the date they will be sent to the Louisiana Attorney General
(AG)for noncompliance. The sub-grantee will be allowed to contact our office and work
38: Louisiana Preservation Agreement, #2
39: Programmatic Agreement, Treatment Protocols and Attachment B: Louisiana Preservation Agreement, #1
40: Programmatic Agreement, Treatment Protocols
41 Programmatic Agreement, Louisiana Treatment Protocols and Attachment B: Louisiana Preservation Agreement, #1
42
Attachment B: Preservation Agreement, section 7.
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towards an agreeable resolution any time prior to the file being forwarded to the AG.
(This correspondence will be sent by certified mail.)
Note: Section 6-33 of the Historic Preservation Fund allows amendments to
Preservation Agreements to lessen the protection provided by the agreement, but only if prior written NPS concurrence is obtained. 43
3.
If response from sub-grantee is not received by the deadline stated in the second letter, the LASHPO will forward the sub-grant project file to the AG for collections of all grant funds received. Once the sub-grantee has been forwarded to the Attorney General, the sub-grantee will work directly with the AG, in consultation with the LASHPO, as detailed in the policies and procedures for Repayments, Attorney General Collections section.
If a violation is not corrected, then the sub-grantee (owner and/or designee) will be
(jointly) responsible for the return of all grant funds.
44
B.
If the violation resulted in the property being (a) lost or damaged due to a natural disaster or (b) destroyed through deliberate action or through gross negligence, the LASHPO will submit to the
NPS a summary of the violation including (a) an assessment of the nature and extent of the damage and (b) a description and estimate of the cost of restoration work necessary to return the property to the condition existing at the time of the grant-assisted project’s completion.
45
The summary shall also include before and after photo documentation of the violation. If the property is destroyed, either accidentally or by natural causes, the LASHPO will also notify the
Keeper of the National Register.
To date, approximately 612 preservation agreement compliance reviews have been conducted. This does not include sub-grantee projects that have received multiple reviews due to a compliance issue.
What has proved challenging in the monitoring of the Preservation Agreements is the information provided to sub-grantees prior to the application process. as discussed previously, prior to awarding funds to sub-grantees, the LASHPO requested clarification from NPS on whether the LASHPO was responsible for monitoring the entire project or only where federal funds were applied. The response was that given the hurricane recovery nature of the funding and the limited amounts provided under the grant per sub-grantee, that the monitoring applied only to grant-funded repairs. LASHPO applied this same scope to the Preservation Agreement as well. To date, we are in the process of itemizing the
Scope of Work per each sub-grantee within the information management system to make tracking which items would apply, if indeed the responsibility is for only grant funded items.
The following is summary of Preservation Agreement compliance review monitoring (note: A sub-grant project may have received multiple reviews and inspections, in which case, the outcome of each inspection is represented. The chart does not provide an overall status of a sub-grant project. Some sub-grant projects have contacted our office on multiple occasions for approvals for different types of
43
Attachment G: HPF Grants Manual, Section 6, 6-33, 3.c
44 See also Operating Procedures for Repayment, Collections, Section 3. Collections, Item A.
45
Attachment G: HPF Grants Manual, Section M, p 6-32, #B
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repairs. Rather than provide one overall status code, we provide details for each inspection or monitoring scenario as it arises.):
PAC Status
Not Applicable
No Changes
Approved
CountOfGrant#
64
352
96
Approved with Conditions
Not Approved
Violation
Violation: Maintenance
30
6
14
29
591
The following sections provide more detail regarding the overall Status of Preservation Agreements.
Not Applicable:
According to HPF regulations, if the property is no longer owned by the same entity who received the grant, such as if a property is sold or title is transferred, the Preservation Agreement is null and void.
There are 64 sub-grant projects where the Preservation Agreement is no longer applicable.

Completed Projects: 28 sub-grant projects

Partially Completed (PM/PM-LG): 18 sub-grant projects. These sub-grant renovation projects appeared complete following an exterior inspection of the property. All properties are occupied. Three projects under this category are unique: o #00004, Canal Street Guest House, was purchased by the State of Louisiana and demolished for the LSU-Medical Center of New Orleans (aka replacement to Charity
Hospital). o #01803, Etta Polk, is in full repayment for all funds received as no funds were applied to the renovation of the building. o #00792, Harry Singreen, is deceased

Partially Completed (PL/PL-LG): 18 sub-grant projects. This category has the most variance in issues related to the status of the Preservation Agreement. They are as follows: o Four (4) large renovations were completed and the property was subsequently sold
(#01368, #01374, #01678, #00237) o Two (2) are deceased and were in the process a repaying the unused portion of grant funds received as an advance. (#00153, #00762) o Three (3) sub-grants repaid all funds in full at the end of the grant term (#01804,
#00947, #00753). One of these properties was purchased by the State of Louisiana and demolished for the LSU-Medical Center of New Orleans (aka replacement to Charity
No Changes:
Hospital). o Four (4) sub-grant projects are in the process of repaying all funds and are currently in
Collections with the Louisiana Office of the Attorney General (#00699, #00962, #00510,
#00038). Two of these properties were demolished during the terms of the grant. o Five (5) sub-grant projects are in an unknown state as the title transfer occurred prior to an interior inspection of the property (#00243, #00900, #00976, 00993, #01383).
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Overall, there were 352 inspections conducted on sub-grant projects whereby the inspection indicates no changes have occurred to the building since the last site visit.

Completed Projects: 278 sub-grant projects, or 79 percent where no changes have occurred. For monitoring purposes, these projects have been identified as the lowest priority for conducting interior site inspections.

Partially Completed (PM/PM-LG): 45 sub-grant projects. Five of these sub-grant projects are currently in collections. 29 are under active Preservation Agreements that have not expired.

Partially Completed (PL/PL-LG): 29 sub-grant projects. Four of these sub-grant projects are currently in collections. 20 are under active Preservation Agreements that have not expired.
The combined 74 Partially Completed sub-grant projects are the most problematic of all projects as these projects likely stalled after initial HBRGP funding. Based on exterior inspections, these projects are still the same as when the grant closed-out. Half of the projects received the maximum funding, but the other half may have requested too little given the damage sustained to the property or the project may have been a major renovation and the property owner has been unable to obtain the necessary funding to complete the projects.
Approved and Approved with Conditions:
Approval refers to properties that have undergone a change, either grant funded or not grant funded, since the grant closed-out. The change complies with the Secretary of the Interior Standards. Approved with Conditions indicates that the sub-grantee has contacted the LASHPO and certain conditions are applied to ensure compliance with the Secretary of the Interior Standards.

Completed Projects: 58 Approved changes, 38 changes completed with the remaining changes partially completed or on-going

Partially Completed (PM/PM-LG): 51 Approved changes, 24 marked as completed. (A final site visit inspection is required to verify the final completion of all items compared to the grant application and condition of the property at the initial site visit.)

Partially Completed (PL/PL-LG): 15 Approved changes, 7 marked as completed. (A final site visit inspection is required to verify the final completion of all items compared to the grant application and condition of the property at the initial site visit.)
When the grant program closed, a total of 379 were marked as Completed. At this date, 31 additional projects have been Completed bringing the total to 410 sub-grant projects of 570, or 72%.
Not Approved:
In six (6) instances, a sub-grantee contacted our office and requested a treatment to the property that was not consistent with the Secretary of the Interior’s Standards. In these instances, the sub-grantee was informed of the requirements under the Preservation Agreement and instructed that may not proceed with the treatment requested. The requested treatments include two demolitions, inappropriate shutters and an elevation of the property.
Violations & Maintenance Issues:
There are currently 43 sub-grant projects with identified changes that have occurred to the property since the terms of the sub-grant project ended - 14 violations and 29 maintenance violations. These changes either (a) impact grant funded scope of work items, (b) constitute a change to the building that is not to SOIS, or (c) is a maintenance issue that may cause damage to the building over time. The 29
99

maintenance issues have been sent a letter instructing them of the potential damage to the building if the maintenance issue is not corrected.
Under the 14 Preservation Agreement violations, there are a few statistics that make enforcement challenging. A full report of violations is attached in Appendix xxx.

Adverse Effect Determinations - 5 of 14 the violations are also sub-grant projects that resulted in an adverse effect, one of which is considered severe.

Low Integrity: 7 of the 14 properties also have been characterized as having low integrity of character defining features when the project began. Three (3) of these sub-grant projects with low integrity also resulted in an adverse effect during the project. As such, there was already considerable challenges with these project at the onset and it would be difficult to ensure compliance with requirements. The likelihood of an appropriate change being made to the building are low and the likelihood of the sub-grantee returning funds as a consequence of nonaction is also low. As only 7 of 570 sub-grant projects, or 1%, fall under this category, we have determined that these are the lowest priority of all Preservation Agreement issues as the resulting action would not benefit either the property or the State.

Repayment Plan: 2 of the 14 sub-grant projects under violation are also in collections due to abandonment of the project.

Partial Completion: 9 sub-grant projects were only partially completed when the grant terminated and the expectations related to grants meeting SOIS may not have been clearly articulated as the terminology in the Grant Program Guidelines and Preservation Agreement was vague in how it pertained to the responsibilities of the sub-grantee.
The major impediment to correcting violations is the lack of clear direction to sub-grantees both prior to awarding funds and after the project was completed. The information presented in the HPF Manual and per NPS is far more substantial than what was provided to sub-grantees. The funding was presented more as hurricane relief to buildings that qualify for the National Register. Even though statements were included that indicated all repairs were required to meet Secretary of the Interior Standards, the
LASHPO had primarily relied on the expertise of the parties involved, such as with tax credit projects or other HPF grants. LASHPO provided guidance, but not specifics related to repairs and establishing concrete work scopes. We were able to provide general guidelines and it was the responsibility of the property owner to understand and implement those guidelines appropriately. No formal building renovation plan was created to guide the property owner as to appropriateness of all remaining repairs to the building, and in particular what character defining features should not be removed or repaired without first seeking approval from the LASHPO. For some, issues arose after the grant closed out, and without a clear understanding of the need to contact the LASHPO prior to making repairs, many property owners moved forwarded with a repair, impacting character defining features in the process.
Even for projects that were considered completed, there may have been minor items that were not completed at the close-out of the grant. These items have not been tracked with any specific coding and would be dependent on reviewing each file report for all properties. In other words, there is no formal tracking method to see what remaining repairs needed to be completed, for either partially completed projects or even completed projects. The only method of tracking would be to read each file report.
Overall, there are 169 projects with changes to the building since the grant closed out, either approved or a determined to be a violation. Furthermore, there were an additional 74 where it appears no changes have occurred to projects that were in progress. These 243 projects require follow-up and site inspections
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Appendix xxx has the complete list and summary of current violations.
This allocation enabled the LASHPO to be out in the community serving the needs of individuals that had not been previously served by the LASHPO, specifically moderate to low income individuals and property owners. This opportunity allowed the LASHPO to capitalize on partnerships with other entities that were providing similar services in the community.
As HBRGP Project Officers began working with property owners, it became apparent that the Project
Officer could not manage the project on behalf of the sub-grantee. Many sub-grantees lacked either the knowledge or skills to handle a major renovation, or they simply did not have the financial resources.
Staff utilized the assistance of volunteer and social service organizations who were serving communities struggling to rebuild and by providing services to individuals in need. The following describes the partnerships between sub-grantees, the LASHPO, and social service agencies that occurred during the rebuilding process.
Preservation Resource Center & National Trust For Historic Preservation Home Again! - Holy Cross
In the aftermath of Hurricane Katrina, speculation by some city officials in New Orleans projected that
50-60,000 homes would have to be demolished. The initial city listing of homes in National Register and local historic districts in New Orleans "red tagged" contained the addresses of over 2,400 homes. In the midst of this speculation and the general confusion of the early days after the Hurricane and levee breeches, the National Trust for Historic Preservation (National Trust)and its local partner, the Preservation Resource Center (PRC), immediately initiated efforts to evaluate the physical conditions of the structures in the historic districts of the city slated for demolition with hundreds of volunteer preservationists, architects, and contractors. As homeowners began to return to the city and wondered if their historic homes could be repaired and renovated, these volunteers helped nearly 1,000 homeowners with building assessments, remediation, and rehabilitation advice to use as a guide in rebuilding. As well, they participated in weekly workshops updating residents on current rebuilding issues.
In the midst of the rush to demolish buildings and the massive amounts of misinformation regarding mold and the structural integrity of older homes, it quickly became evident to the National Trust and the
PRC that a program was needed to visually, physically demonstrate that the historic homes of New
Orleans could indeed withstand and recover from the massive flooding following Katrina and the failed levees. While homeowners fought with their insurance companies over their claims and everyone waited to see if the federal government would provide any resources to help homeowners rebuild their homes or simply tear them down, the Trust and PRC began to identify homeowners in historic districts ready to rebuild. Thus began the HOME AGAIN! New Orleans program. HOME AGAIN! was designed to make the case that the fastest, most cost-effective, most environmentally friendly way for the damaged historic neighborhoods of the city to recover was to first repair and renovate all historic homes that were salvageable. HOME AGAIN! was designed to demonstrate that with modest assistance, homeowners, including senior citizens, could return to healthy, safe, and comfortable homes, with their great advantage of familiarity and neighborhood ties.
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The decision to concentrate on Holy Cross was the result of several factors. The Holy Cross National
Register Historic District was one of the hardest hit communities following Hurricane Katrina. The historic district sits at the river of the Lower Ninth Ward, the area affected by two breaches of the Inner
Harbor Navigation Canal, or more commonly referred to as the Industrial Canal.
iv The area was cordoned off for eight months for health and safety reasons – in particular massive debris and water main problems on the north side of the neighborhood. Although Holy Cross is on high ground, along the
Mississippi River, with the same elevation as the French Quarter, and the flood waters receded after only a few days; when the city shut off water and utility service to the lower 9th ward, it also enacted a
"Look and Leave" policy for the area whereby residents could only visit their homes during the day, but could not get trailers or remain in the neighborhood overnight. Holy Cross also had a disproportionately large number of "Red Tagged" buildings, slated for demolition despite being structurally sound. "Look and Leave" also left the neighborhood without police and fire services. This condition led to widespread architectural thefts in the historic section of the neighborhood, and added yet more obstacles for homeowners in their efforts to repair their homes.
As the HOME AGAIN! program comes to a close, it has invested over one million dollars into 25 HOME
AGAIN! projects, 17 of which are in Holy Cross. These 25 projects resulted in a total investment of over four million dollars. In addition, between HOME AGAIN!, Operation Comeback, Rebuilding Together, and the State Historic Preservation Office's Historic Building Recovery Grant Program (a grant program lobbied for nationally by the Trust and the Lt. Governor's office that brought over 20 million dollars to
Louisiana) 165 historic homes in Holy Cross have received rebuilding assistance. This represents over
16% of the homes in Holy Cross occupied and currently receiving mail. These preservation dollars were some of the first dollars to begin the rebuilding process in Holy Cross and were decisive in creating the conditions that now has the Holy Cross neighborhood recovery on a par with, or ahead of, other hard hit neighborhoods in the city, despite the eight month delay in access and other unique hardships that it had to endure. However, through the early and ongoing efforts of the HOME AGAIN! program and the other preservation efforts by Trust partners PRC and the State Historic Preservation Office; the ongoing work of a host of other organizations and institutions such as the Preservation Trades Network, World
Monuments Fund, the Center for Sustainable Engagement and Development, Emerging Green Builders,
Louisiana Technical College, Global Green, and ACORN; thousands of volunteers from campuses and church organizations around the country; and, the steadfast work of the residents of Holy Cross and its neighborhood association, Holy Cross is becoming home again.
The PRC's Operation Comeback promotes the purchase, renovation and sale of vacant historic properties. Started in 1987, as a focused effort to revitalize the Lower Garden District, Operation
Comeback rapidly expanded and now works with dozens of neighborhood associations and community development corporations citywide. By acquiring and renovating blighted and adjudicated properties that most would consider hopeless, Operation Comeback provides homes for first-time and repeat homebuyers, serving as a catalyst for the rebirth of New Orleans’ historic neighborhoods. In the effort to put as many properties back into the hands of families as possible, Operation Comeback has developed several ways for many to become involved. The OC Revolving Fund and the Adopt a House program allow individuals, organizations, foundations and corporations to aid in the renovation or construction of homes through donations, volunteering, and education.
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On the 5200 block of Dauphine where we have focused our attention, four families have returned to completely renovated homes and three others will return in the coming months. The owners of every other home and lot on the block are accounted for, and all but two are currently being renovated. In the immediate area of this anchor block, there are 20 projects currently underway, representing collaborations between the National Trust, the PRC, and the State Historic Preservation Office. A host of other organizations, whether in partnership with the National Trust and PRC or independently, have been inspired to raise the banner of the Holy Cross Historic District. These include Global Green,
ACORN, Louisiana Technical College, Emerging Green Builders, HGTV, the Center for Sustainable
Engagement and Development, World Monuments Fund, and the Preservation Trades Network.
On their front porch, however, among the debris that had sat in six feet of water for days, the brothers spotted a five-gallon bucket with a note taped to the lid. "Welcome Home," it read, followed by instructions from the National Trust and Preservation Resource Center of New Orleans (PRC) on where to find help and how to clean and gut a flooded home. Inside the bucket was bleach, soap, insect repellent, scrub brushes, towels, a clothesline and pins, detergent, dust masks, gloves, trash bags and more. Andre and Jamar quickly began the arduous task of dragging all the ruined furniture outside and bleaching the mold growing on their walls.
Rebuilding Together New Orleans is a program of the PRC of New Orleans that focuses on the residents in Orleans Parish using a combination of volunteer and professional labor.
Rebuilding Together New Orleans (RTNO) started in 1988 when the Preservation Resource Center instituted a one-day neighborhood revitalization pilot program in the Lower Garden District. Named
Christmas in October, the pilot program was modeled after the national Christmas in April program. It was implemented to address the needs of existing homeowners, namely the elderly and disabled who had become ill equipped to manage home repair. After Hurricane Katrina, RTNO modified its mission to aid those displaced by the storm. Instead of only smaller projects, RTNO began to focus on the total renovation and rebuilding of storm-damaged homes. By reinvesting in and restoring the existing housing stock of the city, RTNO was able to bring homeowners back to their homes, as well as provide a model for restoring and preserving New Orleans' historic neighborhoods. RTNO's home rehabilitation program targets the urban poor, who are the population in New Orleans most affected by Hurricane Katrina. In
1988, 11 homes and 1 school were painted and repaired, utilizing 373 volunteers provided by 14 corporate and community groups. A total budget of $24,349 was raised through corporate donations.
By 2005, Rebuilding Together New Orleans (RTNO) had become a major component of the overall
Preservation Resource Center neighborhood revitalization effort and an affiliate in the top 4% of Rebuilding Together National programs nationwide. At the start of 2005, RTNO had worked on 900 owner occupied houses, seven neighborhood schools, six community centers, a courthouse and a warehouse through expansion and hard working volunteers. By focusing our program in seven target neighborhoods , RTNOmeets the needs of the communities we serve quickly and efficiently by leveraging corporate, private and public dollars, volunteer labor and help from the AmeriCorps program.
The following projects were completed in partnership with the National Trust Home Again! program,
Rebuilding Together, or the Preservation Resource Center’s Operation Comeback (Green shading denotes additional sub-grant projects funded under the additional $10 million allocation under NPS
Grant 22-07-HR-21671.):
NPS
Grant#
HBRGP
Grant# Sub-Grantee
NR Historic
District
Property
Address Building Name Final Grant Partnership
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22-06-HR-
21572
00366 Hilda Hopkins Esplanade
Ridge
1226-1228
Treme Street
$44,830.00 NTHA/
RTNO
22-06-HR-
21572
22-06-HR-
21572
01238
Robert A.
Smith,Sr.
00574 Bari Landry
22-06-HR-
21572
22-07-HR-
21671
00041 Veronica
Stevenson
01152 Cynthia A. Rice
Holy Cross
South
Lakeview
Esplanade
Ridge
5222-5224
Dauphine
Street
811 Louque
Place
1803 Ursulines
Avenue
Holy Cross 725 Lizardi
Street
22-06-HR-
21572
22-07-HR-
21671
22-06-HR-
21572
01616 Emelda M.
Skidmore
01624 L'Tanya P. Jackson Holy Cross 933 Deslonde
Street
01446 Preservation
Resource Center
Holy Cross 939 Deslonde
Street
George "Kid
Sheik" Cola(r)
Home
Holy Cross 711 Caffin Ave
$29,160.00
$3,750.00
$27,000.00
$45,000.00
$36,600.00
$25,000.00
$45,000.00
$45,000.00 22-06-HR-
21572
01450 Preservation
Resource Center
22-07-HR-
21671
01458 Preservation
Resource Center
22-06-HR-
21572
22-07-HR-
21671
22-07-HR-
21671
22-06-HR-
21572
01461 Preservation
Resource Center
01462 Preservation
Resource Center
01481 Preservation
Resource Center
01751 Preservation
Resource Center
Holy Cross 4804 Dauphine
Street
Holy Cross 5124 Dauphine
Street
Holy Cross 5442 Dauphine
Street
Holy Cross 717 Deslonde
Street
Holy Cross 429-31 St.
Maurice
Avenue
Holy Cross 5118 Burgundy
Street
$45,000.00
$45,000.00
$45,000.00
$45,000.00
$45,000.00
NTHA/
RTNO
NTHA
NTHA
NTHA
NTHA
NTHA
OC
OC
OC
OC
OC
OC
OC
Total Contribution in Federal Funds to Partnership Projects: $526,340.00
This Old House Television Series
In June 2007, This Old House television series approached the LASHPO regarding a ten-episode series for
Season 29 that would focus on the rebuilding effort in New Orleans’ historic neighborhoods. The series would follow the rebuilding effort of a single building and would also include side stories that could provide attention to the rebuilding effort as it pertained to the renovation of historic buildings. HBRGP staff put together a portfolio of 26 properties along with a description of the each house, unique historic characteristics and other background on the property owner. The show’s producers selected Holy Cross
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resident Rashida Ferdinand, #01524, as the topic of the series. Filming began in October 2007 and finished by January 2008 under a very accelerated timetable.
Using a combination of funds, including insurance, Road Home, and HBRGP, along with show sponsored products, Rashida was able to completely renovate the property as well as add-on to the single shotgun property by adding a second story rear addition with upper and lower balconies and a balcony and porch added to the right side elevation. The exterior addition plans received approval of the City of New
Orleans Historic District Landmarks Commission and HBRGP staff worked with the show’s producers to ensure original material remained intact on the historic shotgun building. Under the grant, the LASHPO approved plans to ensure the property did not lose contributing status and thus lose eligibility for the grant funds. As is the case with most architectural plans, plans can change. During the filming and as
Ms. Ferdinand managed the overall costs associated with the budget, the producers offered incentives in the form of free products that could be used on her building. The products were for items in the grant budget that called for restoration rather than replacement, such as historic windows, doors, and the addition of shutters. The HBRGP staff was most concerned with maintaining the integrity of the original shotgun form and allowing new products be introduced only on the new addition; however, Ms.
Ferdinand wanted to expand her budget by using the free products offered rather than repairing the historic features of her house. The products ultimately received HDLC approval and the show’s producers regularly use replacement windows in historic renovations, often winning awards in historic districts. Given the accelerated time frame, there was often insufficient time to execute change orders on the LASHPO’s Grant Agreement to account for all the changes in design, which were not grant funded.
Under this sub-grant project, there was difficulty in translating historic building renovation requirements between multiple historic renovation entities. Trying to translate federal requirements, the LASHPO approvals, the local historic district commission approvals, and the desires of the property owner while simultaneously filming a national television show made the project a challenge to oversee when the
LASHPO was also managing 570 other projects! In the end, the property owner, the 4 th generation in her family to grow up in Holy Cross, was able to come home after Hurricane Katrina and New Orleans received positive press regarding the restoration of older homes.
Phoenix of New Orleans (PNOLA)
The lower portion of the Mid-City National Register Historic District faced significant challenges immediately following Hurricane Katrina. The lower portion, often referred to as Tulane-Gravier, was identified as a potential site for the new Veterans Affairs Hospital as well as the new location for the
University Medical Center to replace the shuttered Charity Hospital. The residents in this area struggling to rebuild their homes, were also fighting with government officials and planners who wanted to tear down their neighborhood and relocate them. PNOLA became the catalyst for the residents that lived in this section of the city, providing them with a voice on the new hospital developments as well helping residents within this area rebuild. Through a partnership with the United Way and AmeriCorp workers,
PNOLA provided general contracting services to rebuild homes through two services, Resident
Volunteers and Project Management. Resident Volunteers were individuals from the community who offered time to assist neighbors in need with his/her rebuilding project. This program offered a way to build leadership in residents and develop a greater sense of community and cohesion. Project
Management consisted of PNOLA managing a building’s renovation directly on behalf of the property owner.
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A sub-grantee served as a Resident Volunteer for PNOLA and offered to provide assistance to subgrantees from the area who may be need. The LASHPO requested a formal proposal from PNOLA regarding shared responsibility on the project. A general outline that followed the national construction model used by Rebuilding Together for labor using volunteers under the direction of professionals was submitted. Americorps volunteers would conduct about 80% of the work and other individual volunteers, skilled and unskilled, would assist in appropriate jobs. There was also the opportunity to utilize donated materials, if available. The goal was to make the grant money stretch as far as possible for a sub-grantee given the $45,000 threshold on grants was not sufficient when the property owner was receiving no additional funds for renovation work to the building. This partnership would allow an entire building to be fully renovated, or at a minimum, made livable. Examples of work PNOLA could provide included the following:

Homeowner would buy roofing materials and PNOLA would do the roofing under direction of skilled roofer on staff.

Homeowner would buy sheetrock and
PNOLA would do the labor.

Homeowner would contract with an electrician and PNOLA would assist with jobs (pulling wire, etc) under the direct supervision of the electrician (licensed and insured).

Homeowner would purchase insulation and
PNOLA would install it.
For the most part, PNOLA was more interested in tackling those portions of the renovation that could be easily accommodated with unskilled labor or under the direction of a skilled volunteer.
Under the HBRGP program, there were six (6) subgrant projects where staff and sub-grantees worked with PNOLA to complete the project.
1.
Roberta Rogers (01576) – Resident Volunteer Managed
2.
Ella Ware (01589) – Resident Volunteer Managed
3.
Francisco Galicia (00321) – Resident Volunteer Managed
4.
Celeste Williams (01574) – Site Management
5.
Lawrence Salvant (01530) – Site Management
6.
Christine Santa-Marina (01677) – Site Management
PNOLA realized early on the need to have professional construction foreman oversee AmeriCorp sponsored Site Managers due to the difficulty in translating the International Building Code, permitting requirements, and historic requirements to those volunteers and property owners without any previous construction experience. Furthermore, the needs of historic buildings were proving challenging to the volunteers since the Rebuilding Together construction model was used primarily on newer construction buildings. While, the partnership with PNOLA allowed a property owner to match federal funds with inkind support, thus allowing the individual to move back home, this often resulted in poor quality repairs to the building, applying a band-aid to a potentially more pressing building issue, or compliance issues with the local office of safety and permits.
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Qatar Tremé Renewal Project
In September 2005, His Highness Sheikh Hamad Bin Khalifa Al-Thani, Amir of the State of Qatar, announced $100 million in aid to assist victims of Hurricane Katrina in the Gulf Coast area. The Qatar
Katrina Fund was established to provide direct cash assistance to people and institutions in most dire need in the wake of the storm. Gifts were committed to healthcare, education, housing, and places of worship. The Qatar Tremé Community Renewal Project provide $2.5 million in financing and construction management for victims of Hurricane Katrina who resided in the Tremé community prior to the hurricane, specifically, within the neighborhood bounded by Rampart Street, Esplanade Avenue,
Broad Street, and Orleans Avenue. This portion of Tremé is within the Esplanade Ridge National Register
Historic District, and is the third oldest establishment within the city of New Orleans, after the French
Quarter and the Faubourg Marigny.
The Qatar grant funds were limited to moderate to low income owners of owner-occupied singles and doubles who were displaced as a result of Hurricane
Katrina, and who do not have sufficient insurance proceeds or financial means to achieve an occupancy certificate from the City. Participants were required to certify that total household income during the year
2005 was $40,912 or below, they received no insurance proceeds for Katrina-related home repairs for that property, and there were insufficient financial resources to finance the repairs to the property. By partnering with the Qatar project managers, we could extend the reach of Qatar’s financing to other eligible households not being met by either program or to ensure all repairs were completed to an
HBRGP grantee’s property, if federal funds were insufficient.
Five (5) sub-grant projects occurred in partnership with the Qatar Tremé Renewal Project:
1.
Rodney Thomas (00365)
2.
Constance Brown (00370)
3.
Sue Press (00619)
4.
Stephen Peychaud (00810)
5.
Cheryl Austin (01202)
With the exception of Rodney Thomas and Constance Brown, HBRGP encountered problems in the quality and scope of work completed by Qatar’s professional contractors. In the most extreme circumstances, Cheryl Austin’s roof collapsed and Stephen Peychaud’s property was entirely gutted by the contractors and to date, his house is still not habitable. In all instances, the impediment to the successful partnership was having three responsible parties – the owner, HBRGP, and Qatar-Tremé – but one construction contractor as established under Qatar grant. This problem arose due to the fact that each grant started at different points in time and each granting agency was solely responsible for interacting with the property owner. As HBRGP staff identified Qatar-Tremé projects, HBRGP staff took action to amend the LASHPO grant scope of work so a single working construction document would exist with explicit responsibilities and controls.
United Way & Catholic Charities
In October 2007, staff identified 44 sub-grantees that required either additional funds to complete the building renovation or required day-to-day management of their property renovation, and in some case
107

both services were needed. For the HBRGP portion of the project to be successful and to return the individual home, additional resources were needed. HBRGP staff reached out to Longer-Term Recovery staff at United Way. During an initial scoping meeting between the two agencies, United Way presented their Case Management program as a viable option. Immediately following this meeting, HBRGP staff forwarded the contact information for each sub-grantee requiring assistance. By February 2008, it became clear that United Way was over extended and unable to take on an advocate role for subgrantees, both due to limited staffing and a lack of available funding. At this point, a meeting was called with a United Way provider, Catholic Charities who was providing case management services, called
Operation Helping Hands. Any property wishing to participate in the program was required to have all financial funds in place and Catholic Charities would manage the construction project on their behalf after submitting the required application and being approved for the program. As HBRGP sub-grantees already had applications as well as scopes of work developed, the intent was to share information that would move individuals directly into the Catholic Charities program. Unfortunately, this resource did not benefit any of the HBRGP grantees.
The LASHPO saw an increase in its budget from approximately $1.3 million to over $23 million in course of one year. This was an unprecedented increase and called for an entirely new way to manage the agency to accomplish goals. Further, the LASHPO office had 30 days to design the programmatic structure for the use of funds as well as the management of funds.
The Action Plan Narrative called for the use of paid overtime for the existing five staff of the LASHPO, plus 50 percent salary of three LASHPO staff to handle the needs of the federal grant allocation. In addition, a total of 10 new hires would be added to the staff to manage the program. These new hires did not have previous experience in management of state historic preservation programs or with other cultural resource management firms, as many of those potential candidates were already sourced as
FEMA employees or sub-contractors. A good analogy we like to use is that we were building the plane while it was flying!
The following chart shows the organizational structure of the staff.
108

LASHPO
Deputy SHPO
HBRGP
Accounting
Manager
Accounting
Assistant
Executive
Director, Historic
Preservation
HBRGP Program
Director
Administrative
Assistant
Project
Supervisor
Section 106
Project Officer Project Officer Project Officer Project Officer Project Officer Project Officer
Executive
Director,
Archaeology
Section 106
This new appropriation will almost double the scope of our original Historic Building Hurricane Recovery
Grants Program. This will present challenges, both in project oversight and administrative support.
Thus, in addition to the existing personnel (previously referenced) we contemplate engaging a deputy program director (with full authority) and three additional project oversight officers. These will be temporary unclassified state positions.
Accountant Manager and Grants Reviewer were to be hired for the administrative functions and processing tasks. A Program Director and an initial 4 Architectural Historians or Administrative
Managers would handle the program management as Program Director and Project Officers. An additional 3 Project Officers were added under the additional $10 million allocation.
What was needed was a licensed architect and a licensed contractor on staff to advise on issues related to appropriateness of design as changes to buildings were required or requested and for issues related to the International Building Code. Louisiana’s sub-grant projects were not funded at a level where every sub-grant project would have an architect or licensed contractor in place. Further, many property owners did not have sufficient education or experience to oversee this type of renovation project.
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Important to note that the there were only two staff people devoted to the grant program - on in Baton Rouge fielding the call center and coordinating mailings and emails and Program Manager getting the program operational and policies and procedures in place at the same time conducting all outreach and workshops across the city and preparing for processing of the grant applicatiohhns once received and hiring all the staff once the funding was determined. aone in New Orleans
ACTION PLAN NARRATIVE HURRICANE RECOVERY GRANT
Administrative Budget
Division of Historic Preservation Staff–Paid
Overtime (15%), 3 staff persons
HISTORIC STRUCTURES GRANTS PROGRAM
FY2006
Division of Historic Preservation Staff–Paid
Overtime (15%), 5 staff persons
Division of Historic Preservation Staff–Paid
Overtime (15%), 4 staff persons
Division of Historic Preservation Existing Staff–3 staff persons, Paid 50% of ¾ of Federal FY
Fringe benefit (26%)
Administrative Manager 4 Restricted
Appointment 1 month at mid-point salary range
Fringe benefits (7.65%)
$1,550.00
$3,687.00
$282.00
Accountant Manager 1 Job Appointment, Midpoint salary range
Fringe benefits (26%)
FY2007
$30,232.00
$51,481.00
$18,088.00
$47,341.00
$12,309.00
FY2008
$23,535.00
$49,234.00
$12,801.00
Contract Grants Review 2 Job Appointment,
Mid-point salary range
Fringe benefits (26%)
$33,738.00
$8,772.00
$35,088.00
$9,123.00
FY2009
$12,308.00
$3,200.00
$8,772.00
$2,280.00
Selection Committee Panels (20) Panelists to serve in a pool on multiple panels, (total 4 panels) -- $500.00 honorarium
Panelists’ expenses – state per diem $500.00 per panelist
Hearings Venue Rental
$10,000.00
$5,000.00
$4,000.00
TOTAL
$1,550.00
$30,232.00
$23,535.00
$51,481.00
$18,088.00
$3,687.00
$282.00
$108,883.00
$28,310.00
$77,598.00
$20,175.00
$10,000.00
$5,000.00
$4,000.00
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Call Center Line, Computers, Furniture
Travel
Operating Supplies & Telephone
Photography
Postage, Printing & Copying
Automotive Purchase (2)
Automotive Maintenance
Furniture and Equipment Purchase
Modular Furniture
Advertising
Public Awareness
CODOFIL Outreach Assistance
Contingency
TOTAL
$6,000.00
$500.00
$7,000.00
$500.00
$10,000.00
$2,000.00
$7,000.00
$40,000.00
$6,000.00
$10,000.00
$20,000.00
$14,000.00
$19,019.00 $330,461.00
$500.00
$10,000.00
$3,000.00
$10,000.00
$2,000.00
$155,281.00
$2,000.00
$5,000.00
$10,000.00
$11,679.00
$55,239.00
Planning, Technical Assistance,
Predevelopment Budget
Master Grants Maker – Planner, Administrative
Manager 5, Midpoint salary range
Fringe benefits (26%)
Restoration Project Officers-
Predevelopment/Technical Assistance - (4)
Architectural Historian 2 or (4) Administrative
Managers 3, (see narrative) ($38,623 each)
Fringe benefits (26%)
Travel
TOTAL
FY2006 FY2007
$56,648.00
$14,728.00
$154,492.00
$40,168.00
$12,000.00
$0.00 $278,036.00
FY2008
$58,914.00
$15,317.00
$160,671.00
$41,775.00
$12,000.00
$288,677.00
FY2009
$0.00
Grants & Discretionary Funding
Historic building repair grants, both individual and group
Contingency Funds (as described)
Director’s Discretionary Fund
Archaeological Stabilization Program
TOTAL
TOTAL HISTORIC STRUCTURES PROGRAM
$6,000.00
$1,500.00
$22,000.00
$5,000.00
$22,000.00
$40,000.00
$2,000.00
$6,000.00
$10,000.00
$27,000.00
$10,000.00
$14,000.00
$11,679.00
$560,000.00
TOTAL
$115,562.00
$30,045.00
$315,163.00
$81,943.00
$24,000.00
$566,713.00
FY2006 FY2007 FY2008 FY2009 TOTAL
$19,019.00 $608,497.00 $443,958.00
$9,373,287.00
$350,000.00
$150,000.00
$200,000.00
$10,073,287.00
$55,239.00 $11,200,000.00
20% Overtime Pay for Sec.106 and Related HP
Positions
Existing Architectural Historian Manager (50% for ¾ state FY)
FY2006
$1,296.00
Section 106
FY2007
$24,470.00
FY2008
$25,449.00
FY2009
$51,795.00
TOTAL
$51,215.00
$51,795.00
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Existing Architectural Historians Fringe @ 26%
Existing Architectural Historian 2 (100% for ¾ state FY)
2 Architectural Historian 2 positions Fringe @
26%
2 Architectural Historian 2 positions (1 GIS, 1
Review)
Overtime Pay for Sec. 106 Archaeology
Positions
Reallocation Archaeology Section 106 Staff
Existing Section 106 Archaeology Staff
Existing Section 106 Archaeology Staff (9 mo.)
Fringe @ 26%
Archaeologist 1 (2 positions restricted)
Archeologist 2 (1 position restricted)
2 Archaeologist 2 positions job app
2 Archaeologist 2 positions Fringe @
26%
2 Archaeologist 1 positions job appt
2 Archaeologist 1 positions Fringe @
26%
Reallocation Archaeologist Manager
Archaeologist 1 (2 positions restricted) FICA
Archeologist 2 (1 position restricted) FICA
Accountant 3 (Archaeology)
Accountant 3 Fringe @ 26%
Travel (Historic Preservation)
Travel (Archaeology)
Computers (PCs) (Archaeology)
Computers (Historic Preservation)
Modular Furniture (Archaeology)
Modular Furniture (Historic Preservation)
2 Vehicles Lease (Archaeology)
Supplies (Historic Preservation)
Supplies (Archaeology)
GIS Server & Associated Hardware
(Archaeology)
GIS Software (Archaeology)
GIS Technical Support Training (Archaeology)
GIS Maintenance Support (Archaeology)
Improved Online Access to 106 Information
(Archaeology)
Standing Structures Survey (Historic
Preservation)
Copy Machine Rental (Archaeology)
Accountability Initiative (Archaeology)
TOTAL
$2,850.00
$13,467.00
$20,086.00 $20,889.00
$77,252.00
$11,725.00
$4,611.00
$44,868.00
$11,666.00
$80,342.00
$11,725.00
$4,800.00
$6,811.00
$3,900.00
$67,600.00
$17,576.00
$70,304.00
$18,279.00
$59,030.00
$15,348.00
$61,391.00
$15,702.00
$532.00
$521.00
$298.00
$2,000.00
$4,500.00
$41,330.00
$10,746.00
$7,000.00
$9,000.00
$9,000.00
$3,000.00
$15,000.00
$20,000.00
$10,800.00
$9,000.00
$22,500.00
$60,000.00
$42,983.00
$11,176.00
$7,000.00
$7,000.00
$7,800.00
$9,000.00
$22,500.00
$11,176.00
$2,906.00
$40,000.00
$20,000.00
$10,000.00
$30,000.00
$10,000.00
$60,000.00
$800.00
$123,508.00
$9,600.00
$706,470.00
$9,600.00
$20,000.00
$455,940.00 $14,082.00
$13,467.00
$0.00
$40,975.00
$157,594.00
$26,300.00
$9,411.00
$44,868.00
$11,666.00
$6,811.00
$3,900.00
$137,904.00
$35,855.00
$120,421.00
$31,050.00
$532.00
$521.00
$298.00
$95,489.00
$24,828.00
$14,000.00
$18,000.00
$13,500.00
$3,000.00
$15,000.00
$20,000.00
$18,600.00
$18,000.00
$45,000.00
$60,000.00
$40,000.00
$20,000.00
$20,000.00
$30,000.00
$60,000.00
$20,000.00
$20,000.00
$1,300,000.00
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113

ADD ALL DATES TO THIS TIMELINE – WORKSHOPS, PUBLIC MEETINGS, OFFICE CONSULTATIONS
June 15, 2006 Public Law 109-234: Emergency Supplemental Appropriation, National
Park Service, Historic Preservation Fund
July 24, 2006 NPS Grant Agreement for $12.5 million (22-06-HR-21572)
August 31, 2006
September 28, 2006
October 15, 2006
December 1, 2006
December 15, 2006
January 18-26, 2007
January 29, 2007
February 5, 2007
February 7, 2007 through April 27, 2007
LASHPO Action Plan due to NPS per Grant Agreement Special Condition
#20
NPS approves LASHPO Action Plan
HBRGP Grant Program Guidelines and Application available
NPS Grant Agreement increase of $209,567 for LASHPO
HBRGP grant application deadline
December 15-31, 2006 HBRGP National Register eligibility review and data entry for 1,884 applications
December 31, 2006 NPS Interim Progress Report submitted
HBRGP grant review panels for 1,243 eligible applications
HBRGP funding determinations made on 289 grants
NPS hurricane recovery staff begins
HBRGP grant agreements executed
February 9, 2007
March 15, 2007
March 31, 2007
May 25, 2007
LA, MS, AL SHPO Treatment Protocols due for Programmatic Agreement
Programmatic Agreement executed
NPS Interim Progress Report submitted
Public Law 110-28: Emergency Supplemental Appropriation, National
Park Service, Historic Preservation Fund, additional $10 million
May 31, 2007
June 1, 2007
NPS Grant Agreement for additional $10 million (22-07-HR-21672)
Division of Historic Preservation, Executive Director Phil Boggan begins
(double encumbered through August 17, 2007)
HBRGP Program Director Dabne Whitemore on part-time maternity leave June 9, 2007 through
September 8, 2007
June 17-19, 2007
June 30, 2007
July 16, 2007
NPS makes first site visit to Louisiana
NPS Interim Progress Report submitted
HBRGP policies for additional allocation of $10 million due to NPS
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115
August 17, 2007 Division of Historic Preservation, Executive Director Jonathan Fricker retires
HBRGP grant agreements executed for 241 grantees September 17, 2007 through December 7,
2007
September 30, 2007 NPS Interim Progress Report submitted
October 4, 2007 Programmatic Agreement Addendum executed
December 17-18, 2007 NPS Site Visit
December 31, 2007
March 31, 2008
May 5-6, 2008
June 11, 2008
June 30, 2008
July 1, 2008
NPS Interim Progress Report submitted
NPS Interim Progress Report submitted
NPS Site Visit
Conference Call between MS, AL, LA hurricane recovery grant staff
NPS Interim Progress Report submitted
Deputy Assistant Secretary/Assistant SHPO Phil Boggan begins;
Executive Director Nicole Hobson-Morris begins
July 10-13, 2008
July 22, 2008
July 22, 2008
September 9, 2008
September 15, 2008
September 30, 2008
October 2008 -
November 2009
National Alliance of Preservation Commission National Conference, New
Orleans, Louisiana
New Assistant Secretary/SHPO Scott Hutcheson appointed
New HBRGP Program Director Tracy Nelson begins
Hurricane Gustav hits Louisiana
HBRGP $12.7 million allocation for sub-grant projects ends (extensions until October 1, 2008 due to Hurricane Gustav)
NPS Interim Progress Report submitted
HBRGP executes additional 47 grants from unused/unallocated grant funds
December 31, 2008 NPS Interim Progress Report submitted
February 16-17, 2009 NPS Site Visit
March 6, 2009
March 31, 2009
National Conference of State Historic Preservation Offices conference call on disaster recovery
NPS Interim Progress Report submitted
June 30, 2009
June 30, 2009
June 30, 2009
HBRGP $10 million allocation for sub-grant projects ends
NPS Interim Progress Report submitted
NPS-LASHPO conference call on sub-grant project issues / Section 106

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July 13, 2009
September 18, 2009
September 30, 2009
October 13, 2009
October 26, 2009
November 6, 2009
November 23, 2009
December 4, 2009
December 31, 2009
January 25, 2010
January 25, 2010
February 5, 2010
February 9, 2010
March 1, 2010
March 2, 2010
March 31, 2010
March 31, 2010
April 19, 2010
April 28, 2010
April 29, 2010
May 13, 2010
May 17, 2010
June 30, 2010
September 1, 2010
September 1, 2010
September 30, 2010
November 22, 2010
December 1, 2010
January 11, 2011 and Adverse Effect
NPS sends LASHPO follow-up letter on Section 106
LASHPO sends NPS response letter
NPS Interim Progress Report submitted
NPS sends LASHPO follow-up letter
LASHPO Section 106 review letter on 30 properties
LASHPO Section 106 review letter on 9 properties (Adverse Effect)
NPS site visit and meeting with LASHPO
LASHPO Section 106 review letter on 3 properties with mitigation
NPS Interim Progress Report submitted
LASHPO Section 106 Design Review on 12 properties (1 adverse effect)
LASHPO Section 106 review letter on 2 properties with mitigation
NPS site visit
LASHPO Section 106 Design Review on 1 property
Assistant Secretary/SHPO Scott Hutcheson begins leave of absence
(resigns May 1, 2010)
LASHPO Section 106 review letter on 1 property
LASHPO Section 106 Design Review on 1 property
NPS Interim Progress Report submitted
LASHPO Section 106 review letter on 1 property (adverse effect)
LASHPO Section 106 review letter on 3 properties (adverse effect)
NPS site visit
LASHPO Section 106 review letter on 1 property (adverse effect)
MS Hurricane Recovery grants meeting
NPS Interim Progress Report submitted
NPS Site Visit
LASHPO Section 106 review letter, Batch 1 and Batch 2
NPS Interim Progress Report submitted
NPS Site Visit
Assistant Secretary/SHPO Pam Breaux appointed
LASHPO Section 106 review letter, Batch 3

January 14, 2011
January 26, 2011
March 15, 2011
March 31, 2011
April 6, 2011
June 30, 2011
August 26, 2011
August 30, 2011
September 30, 2011
October 25, 2011
November 30, 2011
December 31, 2011
January 4, 2012
February 20, 2012
March 31, 2012
May 29, 2012
May 31, 2012
June 30, 2012
August 30, 2012
May 31, 2013
August 30, 2013
HBRGP Program Director Dabne Whitemore begins
LASHPO Section 106 review letter, Batch 4
NPS/Cultural Resources meeting with LASHPO
NPS Interim Progress Report submitted
LASHPO Section 106 review letter, Batch 5
NPS Interim Progress Report submitted
LASHPO Section 106 review letter, Batch 6
LASHPO Section 106 review letter, Batch 7
NPS Interim Progress Report submitted
LASHPO Section 106 review letter, Batch 8
LASHPO Section 106 review letter, Batch 9
NPS Interim Progress Report submitted
LASHPO Section 106 review letter on 23 properties
NPS Site Visit
NPS Interim Progress Report submitted
LASHPO Section 106 review letter, Batch 10
NPS Grant on $12.7 million allocation ends (22-06-HR-21572)
NPS Interim Progress Report submitted
NPS Final Report due on $12.7 allocation (22-06-HR-21572) – pending final determination of Section 106 per email dated August 29, 2012 regarding hurricane ISAAC.
NPS Grant on $10 million allocation ends (22-07-HR-21671)
NPS Final Report due on $10 million allocation (22-07-HR-21671)
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an archaeologist positioned in new orleans will use existing historic maps, archaeological site forms, oral history, and predictive models to identify, monitor, and provide public information about the city’s most important sites. the archaeologist will be available to offer immediate assistance in the case of unanticipated discovery situations. further, the archaeologist will give technical advice to individual homeowners participating in the historic building recovery grants program if rehabilitation of historic properties affects the archaeological sites associated with the buildings.
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Through the Road Home - Homeowner Assistance Program, almost 130,000 residents across the Louisiana coastal region have received more than $8.9 billion to rebuild and protect their homes and rental properties from future storm damage. In addition to assistance for residential homeowners, the Road Home - Small Rental Property Program has provided over $350 million for the restoration of over
8,000 rental units.
This Action Plan amendment describes The Road Home Housing Programs, consisting of four sets of programs for the restoration of
Louisiana's housing stock and its communities: Homeowner Assistance Program, Workforce and Affordable Rental Housing Programs,
Homeless Housing Programs, and Developer Incentives. Future Action Plan amendments will describe other aspects of the State's
CDBG recovery program. Working with the Federal Coordinator of the Office of Gulf Coast Rebuilding, the LRA has demonstrated that the cost of recovery based on the damages to owner-occupied properties, rental properties, and other critical infrastructure such as hospitals, schools, un-funded state and local infrastructure repairs, and sewer and water infrastructure will require no less than $12.1 billion. The current supplemental CDBG funding of $6.21 billion, combined with anticipated Hazard Mitigation Grant Program funds available through the Stafford Act, fall short of this total need by $4.2 billion. Without this additional CDBG funding, the State of
Louisiana cannot fully fund its housing program for homeowners and renters, to meet the scale of the challenge. President Bush's commitment to this funding was made in recognition of this need.
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Prior to Katrina and Rita, the Division of Historic Preservation had surveys of approximately 58,000 historic standing structures across Louisiana; however, almost none focused on Orleans Parish. As the
Section 106 process relies heavily on historic building surveys, the LASHPO arranged with FEMA to survey eight of New Orleans most heavily damaged National Register Historic Districts. Further complicating the situation, almost nothing was available via the Internet or in GIS; almost all paperwork was handled on paper from surveys conducted as far back as the 1970s.
(Not sure when the FEMA surveys were completed or information was shared on the building condition that led to the creation of the grant program. The HBRGP files have FEMA Rapid Building Site Assessment Form and a Detailed
Building and Site Condition Assessment form. These would have provided a perspective as to the amount of damage, but not the overall renovation plans for historic buildings. PRC created a Property Evaluation Form that discussed all levels of integrity and repair exterior and interior, which would have been needed under this grant program. The FEMA surveys also focused almost exclusively on the exteriors. Were there also concerns about the standardization of data collected??)
During Application processing, GIS would have made it easy to determine if a property was located in a National
Register Historic District or if it was an individually listed building. Also, we could have assessed if there was any other available data related to that parcel record, such as the survey form, FEMA surveys or other building assessments, such as the one Developed for FEMA by the NPS National Center for Preservation Technology and
Training in collaboration with the Heritage Emergency National Task Force.
During the management of the grant-funded property, having information as to whether or not the property received other federal recovery dollars, was reviewed by FEMA or OCD-DRU, was a tax credit recipient or received funding under a previous grant program would have provided meaningful context to the renovation of the building. Further, it would have alleviated duplication from a staffing level if there was more than one staff person managing the historic renovation of a property.
Allocate funds for SHPO staffing, immediate damage assessments, community impacts. If SHPO staff does not do this directly, and the local historic preservation commission is in a position to take on this role, they local agency can provide this service. Staff and outreach efforts to address immediate historib building surveys and damage assessments, repair plans, or basic clean-up. Understanding local resources available to people already, such as FEMA emergency response funds to secure the property.
Meeting with volunteer groups that are providing gutting services – coordinate with Louisiana Serve
Commission to work with all the locally designated volunteer groups and United Ways. Survey for immediate assessment of historic buildings on the national register. Objective is not to disrupt normal operations whose caseload is has increased significantly during disaster situations, in particular with
National Register staff, Section 106, and Tax Credits. But, gets people out at the local level, embedded in their community, to assess the situation and determine the needs of the community as it pertains to historic buildings and rental property. This person can also serve as a liaison to the state and local government disaster response.
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123
(Highlight importance both before and after grant was completed so project did not result in a violation for an inappropriate treatment to the building)
(discuss NCPTT forms and why they are deficient)
One issue arose regarding eligibility that became apparent during the first site inspection for those projects that were funded. National Register eligibility was based on the elevation photographs provided in the application. When a project officer went on the initial site inspection, there were a few properties that showed the building was not exactly as it appeared in the photographs. Two examples –
Adrian Allen #00009 and #00444 Richard Powell. (see full case studies on both of these projects in the attachment document)

In both instances, the National Register Coordinator and the Deputy SHPO/Executive Director of the
Division of Historic Preservation indicated the properties contained sufficient massing to remain eligible.
If a project officer was concerned about the contributing status of a building at the initial site inspection, a review by the National Register Coordinator and Deputy SHPO would review the project for compliance prior to executing a grant.
An analysis of the overall integrity of the building was not integrated into the grant evaluation process.
The LASHPO, is typical in most Section 106 matters, only assessed whether or not the property was eligible or listed on the National Register, including whether or not it was considered a contributing element. Truly, in all programs of the LASHPO a determination of overall integrity was not a part of any grant program or tax credit application. Taking integrity into consideration as to it’s contribution to the overall project outcome, you can see that those buildings with the most historic integrity were also better stewards of the grant, and those with the least amount of integrity had more difficulty interpreting and understanding the Standards. According to an internal assessment of integrity with those properties whose activities resulted in an adverse effect, you can see from table xx, there is a direct correlation between those buildings with a degree of integrity and those without.
Building
Integrity
High
High
HBRGP
Determination
No Adverse Effect
Adverse Effect
CountOfGrant#
352
22
Of Integrity
94%
6%
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Medium
Medium
High Level of Integrity Total:
NAE
Adverse Effect
374
84
21
79%
21%
Low
Low
Medium Level of Integrity Total:
NAE
Adverse Effect
106
54
36
60%
40%
Low Level of Integrity Total: 90
Overall, assessment of integrity is not brought into the evaluation process because, ideally, the grants would improve the overall integrity. However, as the grant funds were primarily for hurricane recovery and were not intended to be renovation grants, there was a disconnect between the two objectives. In many instances, the result was an in-kind replacement of material, rather than restoration to historic standards. Had the grant program relied on a more historic renovation approach, rather than a strict adherence to only hurricane recovery, a more balanced approach to the Standards may have been achieved.
Furthermore, as the grant program objectives were not simply a complete restoration of a historic building to SOIS, the priority was placed on the more immediate hurricane recovery needs of the building, such basic habitability and roof replacement, wall repair, and repair or replacement of mechanical and electrical systems. These items did not necessarily constitute a character-defining architectural feature. In other cases, the priority was only on stabilizing the foundation of the building.
In this instance, a property that may be have low integrity was not necessarily improved.
On December 7, 2006 prior to awarding funds to sub-grantees, a request for clarification was sent to NPS regarding the LASHPO’s responsibilities, specifically, requirements to oversee and monitor the sub-grantee’s entire renovation project. The LASHPO addressed the following concerns:
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There was a small percentage of grantees/properties from the first round of funded applicants that were questioned as to their eligibility status after the panel review process was completed.
By the same token that the temporary workers made a certain percentage of mistakes due to sheer volume of clerical work, there were several questionable applicants found in the first 289 grantees.
These seem to be a higher percentage of complicated applications as the process narrows.
Below are some of the identified concerns:
1. It appears that a percentage of the properties that are now eligible will not even be habitable with the infusion of the federal grant funds. The concern is that if the grant funds are not sufficient to even stabilize the structure, much less get the homeowner back into their home, and they do not have other means to invest into the property, will the federal money be spent wisely by applying it to this situation. These particular grantees indicate a lack of additional sources of renovation funds on their application.
While some of them may be qualified for Road Home, it appears from the applications that most of these property owners may not have any other financial resources to renovate their house.
2. There are several applicants that woefully underestimated their renovation costs, therefore making the grant funds requested inadequate to make their project successful.
These applicants also do not appear to have supplemental funds for the property. (Ex: request for $4,700.00 for what appears to be a blighted structure)
3. There are many homeowners that may have lost their contributing status due to alterations to their historic homes, ie: replacing windows, new additions, porch alterations, raising the building due to new flood requirements, etc.
4. There are some applications where the building is considered marginally contributing with very little integrity remaining on the building or the building is not considered having significant integrity for it’s building style and form, and for the historic district for which it is comprised. Further, the integrity of the interior was not taken into consideration as the property only had to be considered based on National Register eligibility from the exterior. Many properties have lost almost integrity on the interior of the building. The ability of staff to manage a complete restoration of the historic fabric of those buildings is
5. extremely difficult and time consuming. Yet, this was an issue that was of major concern.
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For this round of grant funding the primary question is whether to open the process to new applicants or to fund only from the previous pool of eligible homeowners.
One of the most reoccurring points that has been made to me is that those people who were not allowed to go through the review process the first time due to a mistake on their part (ie: insufficient photos, mail delivered to the BR office late due in part to the problems the Postal
Service in NOLA is experiencing, descriptions or estimates that were inadequate for our reviewers to make a judgment on as to the need of the person/property, etc) should have a chance to correct their mistake and go through the State’s review process. Now that our staff has had a chance to make a cursory review of the next potential round of grantees, I would recommend that this be allowed as the pool of viable grantees could use an infusion of new potential projects.
In the grant application process we stated that the grant would not fund ‘renovation’ work or repair pre-existing damage. All work would have to be damage due to Katrina/Rita. For example, we have one grantee where the funds are slated for roof, siding, windows, doors, and electrical work. Upon inspection of the property however, that is not a priority based on the needs of the house. More emphasis was placed on funding exactly what was in the application since that is what was reviewed by the panel. SOP to not change a grant applicant’s scope of work – not considered ethical. However, many applicants are not professionals and did not know specifically what may have been best for the property or if during construction, undiscovered problems were identified. While the grant has replaced her roof, the other work has been completed stalled because she first needs to have the framing work completed before the other work items from the grant can proceed. This leaves the building still in a state of decay due to exposure to the weather. We are trying to find other sources to partner with who have the capacity to provide this service but it is a slow and unrewarding process. In this case, if the grant funds could go towards the framing, we could mothball this house by repairing the framing, replacing the weatherboards and reinstalling the doors and windows thus protecting it from the weather and giving the homeowner the time needed to seek other resources/help.
Philip has a similar situation with a grantee that has damaged sills that have to be replaced before her house leveling can be started. The leveling is paid for by the grant and the whole project is now on hold.
One of the serious questions is whether to fund repairs that have already been completed by the homeowner. the following concerns need to be addressed:
1. Quality of work checklist that gives the PO guidelines on how to verify that the work already completed is up to the standards of the grant.
2. increase requirement for mandatory site visits from 3 to 5. a. Pre-SV – when we make the initial appointment by phone, we need to create a checklist of specific info we need to update ie: verify contact info, email, second form of contact, etc. (this will create an updated grant entry form) We need to ask this second round of grantees how much of the work that is in their application has been completed and if there is any work that was not listed but that is needed (we can let them know what is eligible) POs can gather all this info by talking to grantee after site visit is scheduled but before we actually conduct first visit with them. Also, we need to think about who sets up the site visits. b. 1 st SV – go over legal grant and do site inspection
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c. 2 nd SV – PO meets with the contractor/subs and homeowner once the workers are selected and BEFORE work has started. The PO will verify license/insurance as well as the proposed scope of work – this will allow the PO to verify that the proposed cost are fair, that the contract is itemized to the level the grant requires, and to directly educate the contractor on the work standards required by the program. This will also allow the PO to go over specific information that might have been missed in the first visit as well as to address the level of paperwork required by the grantee during the second payment site visit. We may also need to create a list of work that we want to inspect before it is closed up or hidden by sheetrock. Also, we need to verify permits and HDLC Certificate of
Appropriateness.
For the second site visit we may need to set up the process to get a contractor for the grantee meaning: a. get 3 estimates for comparison, b. choose a contractor, c. BEFORE signing verify license and insurance and better business bureau, d. BEFORE work starts or even before signing the contract, have PO met with homeowner and contractor to make sure all parties understand the requirements of the grant, e. start work
1. Legal recourse/plan of action to retrieve grant funds that have been misused or the
Standards have not been upheld. Perhaps put together an outline for grantee on what the consequences are. Also a guideline for PO on how to track/document this problem.
Need better guidance for a grant recipient than “according to standards” or “historically appropriate”
2. Hire David Gibney or a local craftsman to partner with PO on initial site visit to identify best solutions for proposed work as well as specific material recommendations.
1. Clarify what is considered Katrina damage and what will be considered pre-existing or do we want to keep this vague and who qualifies these boundaries
2. Better contractor list as the PRC list is outdated and incomplete
3. Need to create a better example of a. Itemized contractor invoice or contract b.
Material receipts – need to let them know that personal items need to be paid separately so that the receipt only reflects items for the grant c. Also, we need to verify permits and HDLC Certificate of Appropriateness.
A possible Round 3 Grant Program would allow new applications, under new guidelines. Within that program, the SHPO would consider applications that allows grant funds to be applied to historic elements that will improve the contributing status of the building.
The brief language regarding the Preservation Agreement was used instead of the more specific language found in the Historic Preservation Fund Manual, which should have been thoroughly expressed to any potential applicant the requirements of the Preservation Agreement as stated in the HPF Manual.
These issues identified have been the focus of conversations and meetings with the National Park
Service since the inception of the hurricane recovery program. Both Louisiana and NPS were challenged in that Louisiana did not have previous experience in executing construction grant programs and in particular under the unique challenges in a disaster recovery situation where the devastation is vast and the funding is small, but the National Park Service had also not found itself in a situation where it was providing grants to individuals with no preservation or financial management experience. The HPF program is intended to provide financing to projects that are managed not only by professionals with
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adequate financial management backgrounds, typically through nonprofit or government agencies, but are also overseen by professional architects using architectural plans and full construction documents with work executed by licensed contractors and craftsmen with expertise in historic preservation construction. The reality was far from this intent.
From the onset of this program, Louisiana informed NPS of all issues at the time they were identified.
They were reported on in detail either in Interim Progress Reports submitted quarterly and/or during regular site visits by NPS to Louisiana, which occurred approximately two times per year and included on-site inspections of sub-grant projects. It was not until June 2009 that attempts to meet HPF requirements became the key focus of NPS management. The ideal time for this focus to occur would have been at the initial allocation of funds with sufficient training and education on all appropriate policies and procedures for both the LASHPO and for sub-grantees.
The timing and outcomes of the NPS award allocation could be broken down into two different components. First, an initial allocation of funding to assist the SHPO and local historic preservation agencies was needed to support first response assistance for historic assets and property owners. Thyis funding would have been utilized to fund staff that would be dedicated to the needs of the declared disaster areas and to have feet on the ground without disrupting the normal operations of the LASHPO office as those duties undeniably are increased significantly already. Further, a significant amount of damage is cause in the immediate clean-up resulting in the wholesale removal of intact historic material that can be easily restored rather than discarded. The SHPO as a state agency does not necessarily have the knowledge of the local areas, but this information is often critical during a disaster situation. Had the SHPO had the opportunity to have dedicated staff with boots on the ground on a daily basis in declared disaster areas, but there should be an opportunity to deploy funds to other nonprofit and local government service providers that are taking on additional duties, such as training volunteer groups providing debris removal and clean-up services or advising property owners on what features of the house they should keep. These entities could also play a needed role in identifying the financial need for additional funds and challenges individuals are facing with FEMA funds or their own insurance proceeds.
For instance, the Historic District Landmarks Commission was only in the position to be approving permits. They did not have the available staffing to advise property owners on appropriate restoration of individual buildings. Further complicating the issue is that there are over 20 listed and eligible historic districts representing approximately 50,000 historic structures, but the City of New Orleans only recognizes ten of these districts, leaving the remaining 11 districts unserved. In New Orleans, the
Preservation Resource Center and the National Trust for Historic Preservation were able to take on the role as advocate for first response, but this role was not coordinated in any specific way and was limited to the Holy Cross neighborhood of New Orleans. With opportunities for additional disaster relief assistance specific to historic buildings, CLGs or Main Street communities could receive funding and training on how to reach out and advise owners of historic property on how best to immediately respond to the clean up and then how to properly repair remaining features or restore features that have been lost so as to maintain the integrity of our National Register listed properties. Having a coordinated first responder effort specifically related to the needs of historic buildings would have been
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ideal. If NPS is not in a position at the federal level to initiate this type of assistance in a meaningful way, efforts to coordinate or obtain funding from other disaster recovery resources approved for state and local governments should be considered. Items such as pamphlets, building assessment tools, and even basic clean-up packages consisting of buckets, sponges, safety equipment, and the like could be provided to properties.
Secondly, the level of grant funding made available for development projects should be calculated based on the number of historic resources impacted with special consideration for historic districts. For instance in the city of New Orleans/Orleans Parish, there are currently 143 National Register Listings.
However, 20 of those listings are for National Register Historic Districts. Within each district, it is estimated that there are
The timing of the NPS award allocation and the funding deployment to grantees was optimal. The allocation from NPS came approximately 10 months after storm hit Louisiana’s communities. In some communities, such as Holy Cross and the Lower 9 th Ward, property owners were not allowed to return to their homes for as long as 8 months.
1) Further we will consider applications whose primary purpose is to restore architectural character by repairing/replacing character defining elements.
The organizational structure was ideal originally in that there was program supervisor who managed all the project officers and reviewed all projects for issues related to SOIS. This structure changed before the end of Round 1 and that layer of checks and balances was lost.
Also, the project officers were trained typically once on all the tools available to them and how to use the tools in the field, whether the Green SOIS book, the Preservation Briefs, various articles on material repair identified to aid a sub-grantee, or the site visit guidelines. Training was also provided on revising and providing more detailed guidance on how to specifically apply SOIS for a given subgrant project so there were definitely and technical specifications on how a repair should be conducted. However, there was often so much to keep straight that this information was often forgotten or not utilized as often as it should have been. In particular, the SOIS information should have been used to amend grant agreements if there was a concern an item was overly vague. It was the responsibility of the project officer to recognize when a SOW was not detailed enough.
There was no Uniform Building Code on file so we were unable to really check repairs according to what a laborer may have done.
How can we best network/assist them through the process? Should they only have contact w/Project
Officers or would it be beneficial for them to be able to talk/share resources with other recipients?
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- add information on window workshop by David Gibney – worked only for those who wanted to do their own window repairs. Did not work for people who wanted to learn how it was done so they could develop a scope of work that a qualified craftsmen or laborer could follow. Also wasn’t specific to a house style and form, so the details of the trim after the mechanics of operations were fixed may have been different.
 Develop work schedule (scope) / timeframe (their plans to start work) / structure of funds
(budget – how far the grant funds will go). Try and fund the most important item in its entirety first. Ex. Roof – would have been good to have created an entire building renovation report on the grantees behalf at this point, even for the none grant funded items. It would have also lent to the requirements of the 5-year preservation agreement. Further the entire building scope should have been in the grantee’s grant agreement even though we were only funding a percentage of the project. To do this, you would have needed the grantees entire financing available and stats on Road Home. To know this, LASHPO staff would have needed much more knowledge and training on other state programs, such as Road Home, which we should have had given the Programmatic Agreement regarding Road Home.
 A 2 nd Site Visit Procedures guide book was sent to every grantee after the 1 st site inspection and along with the grant agreement. This allowed the sub-grantee to be prepared for what was required during the next site inspection. At this point, what should have been sent was also standard documentation on how to interpret the standards for each project.
 During this site visit, the Project Officer will go over the original scope of work, document the completed work and clarify the work still to be finished as well as help to structure the logical sequence of the remaining repairs. Additionally, we will document the progress of each item in the grant scope of work (ie: we will define whether the work is completed, has been started or is in progress, about to start, planned with an estimated date, or no start date determined and the reason for delay). More emphasis should have been placed on what the SOIS meant. They were constantly referenced, but so was how complete something was and the final paperwork.
The LASHPO recognized there would be three key challenges following Stipulation IV of the PA and mitigating adverse effects once identified. First, sub-grantees would not perceive any legal obligation for the entire building renovation or understand the language of Section 106 as neither the grant program guidelines nor the grant agreement clearly articulated these requirements. Secondly, the initial sub-grantees identified as adverse effects were also individuals that were unresponsive and non-compliant with the legal requirements of the grant.
Because staff was unable to make contact with many of these sub-grantees, the LASHPO was not in a position to develop mitigation strategies or execute individual MOAs. The third challenge was inviting consulting parties and other members of the public to participate in the process as defined by Stipulation IV. While LASHPO staff was constantly involved in consultations with other Federal Agencies and various municipalities, these public agencies were able to send representatives on their behalf. In contrast, sub-grantees did not have this same level of representation and as such, having them attend public hearings on their own subgrant project would have proved counter-productive.
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The biggest issue that I see is the reliability of the contracted labor .. how do we solve this? Use other orgs contact list, etc
How do we vet the list we provide the recipients?
How do we coordinate/offer access to outside craftsmen that we trust as far as quality of work? I should put together an email to the craftsmen; create database of specific repairs and how many we have of each
We should have a contingency plan in place in the case of a conflict w/contractor or difficult situation that has to be modified .. ie: changing contractor
 Look at proposed work ---talk about recommended preservation methods for the repairs there are proposing … or for electrical/plumbing that it is required to have licensed/insured professional … etc. – needed to have staff that were knowledgeable about the building code and local permitting requirements. As staff were architectural historians, they did not have previous experience in dealing with these issues. As a result, we were ineffective in helping individuals who had no previous renovation experience.
 During the second allocation of funding, there grant agreements were to be amended to include additional changes, including (a) the NPS comments from the initial grant agreement, (b) requirements for additional site visits and payment arrangements, and (c) requirement that all repairs be done by licensed and insured contractors as required by the State of Louisiana
Licensing Law and in accordance with local permitting regulations. For (a) the information related to the preservation agreement was mistakenly omitted. Item (b) was implemented.
Item (c) did include the reference; however, it should have also referenced that all repairs be completed to state and local building code as. The focus was more on the quality of the contractors the sub-grantees were working with rather than the quality of the repairs they were providing. Emphasis should have been placed equally on the quality of the repairs meeting building code requirements. Building code requirements are different for each municipality and for the State. No staff member was formally trained in the uniform building code approved and required by any of the entities and as such, there was difficulty in applying the legal parameters to the quality of the repairs being completed.
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List of Case Studies:
[Pulling from Database - Project Tracking]
00327 Andrew Robinson, Holy Cross
00485 LaJuan Booker, Holy Cross, ACORN project management, now finished!
01798 Cheryl Young, contractor fraud, 2 nd round repairs already completed, now completed
00551 Deborah Wickliff, theft
00604 Danielle and Mark Samuel – house still not completed
00797 Lynne Marie Rivet Beberman, Uptown, Napoleon Avenue, foundation repair
00914 Tyrone Taylor, everything is wrong with this project – adverse effect, ownership issues, internal payment, etc.
00961 Helena Burrell, low integrity, really bad shape, really bad damage images, Central City, good location on Louisiana Avenue
01238 Robert A Smith Sr, National Trust for Historic Preservation Partnership
01429 Oscar Becnel, St. Bernard Parish – excellent steward of the house
00077 Michael Kimble, French Colonial, Bayou St. John, 18 th century house
00382 Gerard Moore, New Marigny,
00700 Joanne Robbins, Governor Sam Houston Jones House
00370, Constance Brown, absolutely incredible house
00993 Chad Talkington, Mid-Century modern
001163 Grand Opera House of the South, multi-year grant by many different agencies, Crowley
Dean Gilbert, SRPP issues
01658 Terry Barthe, maintenance violation and complete porch disintegration due to water issues, plus family history of the Barthe family of plasters, great house
01576, 00947, 01589, 00004 – all four LSU/VA properties
00058 – Jeannine meeds, Rankin House
00119 Pat Featherstone, Adema House, Pointe-a-la-Hache, not near complete
01285 Madewood Plantation, huge falling out with contractor over really bad repairs
01382 Nevels Pittman, showed how we try to bring in experts, even after the fact
01464 Reving Broussard, Lutzenberger Foundry, brick warehouse, really bad masonry mortar repairs
01347 Helene Barnett, excellent renovation
00009 Adrian Allen, reconstruction
00017 Japerlet Wilson, beautiful details, problems with United Way contractors
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01529 Joann Najolia, Adverse Effect, very problematic
01739 Jeffrey Bridger, elevation
01525 Sylvia Beyer elevation and porch rebuild
01803 Etta Polk or maybe 00510 Keith Pete, Repayment
00699 Kendrick Foster, Attorney General
01202 Cheryl Austin and 01381 Lou Jean Sartin, house collapse
01383 Coy LaSister, L’Hote Townhouse in Tremé
01385 Val Ann Amedee – house abandoned
01405 Susan Meredith, Gentilly Terrace, Arts & Crafts unique Bungalow, different building style perspective
01416 Carlee Harried-Waites, Relying on volunteer labor provided by local church
01442 Barbara Longworth turnaround success!
PRC properties – all of them
01491 – Lynn McClean Plaster Repairs
01524 This Old House Comes to Town, Rashida Ferdinand
01532 Mario Richard, difference between giving a grant just because you are eligible for the National
Register versus how to actually repair the property when you have no repair experience at all. Still not home, community totally compromised. Would help explain windshield survey done with FEMA
Wrong doors – 01551 vyntrella menzies, standley Sinegal
01189 Anne Hoskins – entirely new foundation also energy efficiencies
135

136

137

138

139

Determine if you want to include the actual copy or just a list that the copy exists:
Date of Publication
February 27, 2006
Title
Lt. Governor Press Conference in Holy Cross/Lower 9 th Ward on Grant
Awards
February 28, 2006
February 28, 2006
March 2007
The Times-Picayune Article
The Advocate (Baton Rouge, Louisiana) Article
March 2007
Preservation Resource Center Preservation in Print Magazine Article:
Grant Awards Announced
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01246 Shannan Cvitanovic
March 5, 2007
March 5, 2007
March 11, 2007
April 2007
May 2007
May 14, 2007
Unknown Source, Editorial on Historic Preservation Funding
New Orleans City Business Article
The Times-Picayune Article: #00030 William Lowry, Francois Cousin property in Slidell not awarded funding
Preservation Resource Center Preservation in Print Magazine Article:
Three Project Officers Hired
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #00948 Renee Davenport
National Trust for Historic Preservation Press Conference in Holy
Cross/Lower 9 th Ward
June 4, 2007
May-June 2007
July-August 2007
August 15, 2007
September 11, 2007
October 4, 2007
The Baltimore Sun Article
Preservation Resource Center Preservation in Print Magazine Articles:
Case Study on Grant Recipient #00948 Renee Davenport; PRC Ladies in
Red African American Heritage Committee funds #01616 Emelda
Skidmore
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01189 Anne Hoskins
This Old House Online Article
This Old House TV Series Announcement
Lt. Governor Press Conference on Second Allocation of Grant Awards
140

October 9, 2007
October 18-20, 2007
October 2007
November 2007
February 14, 2008
March 2008
May 2008
May 30, 2008
June 2, 2008
June 4, 2008
Summer 2008
July 11, 2008
September 2008
October 2008
November 2008
New Orleans City Business Article
Traditional Building Exhibition and Conference, Ernest N. Morial
Convention Center, New Orleans, www.traditionalbuildingshow.com
,
Session 1: Friday, October 19, 20017 AIA Historic Resources Committee &
National Trust for Historic Preservation Roundtable Presenter, Dabne
Whitemore
Session 2: Saturday, October 20, 2007 Advice for Dealing with Flooded
Structures Presenter, Tracy Nelson, Program Supervisor
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01450 Preservation Resource Center,
Operation Comeback
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01450, #01458, #01462 Preservation Resource
Center, Operation Comeback
National Trust for Historic Preservation Web Article: Home Again!
Program #00574 Bari Landry and #01238 Robert Smith, Sr.
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01238 Robert Smith
Preservation Resource Center Preservation in Print Magazine Article: Case
Studies on Grant Recipients #01003 Yousif Ebrahim, West End Boulevard,
Old Lakeview, New Orleans, LA
National Trust for Historic Preservation Web Article: Home Again!
Program Outcomes (reference #00574 Bari Landry and #01238 Robert
Smith, Sr.)
National Trust for Historic Preservation Web Article: Home Again!
Program #01238 Robert Smith, Sr.
National Trust for Historic Preservation Web Article: Home Again!
Program #00041 Veronica Stevenson
Preservation Resource Center Preservation in Print Magazine Article: Case
Studies on Grant Recipients #00307 B. Lemann & Bro, Inc. in
Donaldsonville, Louisiana; Case Study on National Trust for Historic
Preservation Home Again properties, #00574, 01152, 01238, 01240; Case
Study on PRC Operation Comeback Properties Completed and Ready and
For Sale, #01450, 01462
National Alliance of Preservation Commissions Forum 2008, July 10-13,
2008, Astor Crowne Plaza Hotel, July 11, 9:15 am to 3:30 pm, New
Orleans History and Recovery Mobile Workshop, Tour Planners and
Operators for 2 tours, 25 persons each. Led by Tracy Nelson and Dabne
Whitemore, HBRGP, with Walter Gallas and Kevin Mercadel, National
Trust for Historic Preservation New Orleans. On-site inspections at 10 sub-grantee properties.
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01680 Daniel Ryan
Preservation Resource Center Preservation in Print Magazine Article:
HBRGP Achieves Goals; Case Study on Grant Recipient #01538 John Reed and Jon Kemp
Preservation Resource Center Preservation in Print Magazine Article:
141

December 2008-January
2009
January 9, 2009
February 2009
March 12, 2009
March 2009
April 2009
May 5, 2009
May 2009
June 8, 2009
Summer 2009
August 24, 2009
August 24, 2009
September 2009
October 2009
HBRGP Lends Helping Hand through Project Officer
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #00582 Sebastopol Plantation; Case Study on
Grant Recipient #00366 Hilda Hopkins Partnership ; Case Study on Grant
Recipient #01285 Madewood Plantation, Keith Marshall; Repair Article –
10 Myths About Replacement Windows
Louisiana State Legislature Familiarization Tour of grant funded properties
Preservation Resource Center Preservation in Print Magazine Article:
HBRGP Grant Program Updates and News; Repair Article – Choose a
Qualified Contractor; Case Study on Grant Recipient #01686 Jennifer
Coolidge
12 th Annual US/ICOMOS International Symposium, Field Session in Site
Recovery, Jackson Barracks and Bus Tour of HBRGP Sub-grant projects in
Holy Cross, Presenters and Organizers, Stephen Fowlkes and Tracy Nelson
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #00328 H Jordan Mackenzie Residence, Jean
Matkin, Blue Roof House; Repair Article – Insulation Choices; Case Study on Grant Recipient #00022 Judge Poche Plantation House, Mark
Anderson, St. James Parish Landmark
Preservation Resource Center Preservation in Print Magazine Article:
Repair Article – Plaster; Case Study on Plaster and Limewash, #00241, Lou
Costa; Case Study on Grant Recipient #01163 Grand Opera House,
Crowley, Louisiana; Case Study on National Trust, PRC, and HBRGP
Partnership for #01616 Emelda Skidmore
National Home Builders Association Annual Conference, Conference
Session, Green Building in Historic Homes, Session Case Study on #01246
Shannon Cvitanovic
Preservation Resource Center Preservation in Print Magazine Article:
Repair Article – Masonry and Mortar; Case Study on #00167 Musée
Rochette Rochon, Don Richmond
Preservation Resource Center, Workshop: Top Myths About Replacement
Windows, Presenter, James Crouch
Preservation Resource Center Preservation in Print Magazine Article:
Sustainability Article; Case Study on Mid-20 th Century Buildings, #00093
Chad Talkington
National Trust for Historic Preservation Web Article: Home Again!
Program #01616 Emelda Skidmore and daughter #01624 L’Tanya Jackson
National Trust for Historic Preservation Web Article: Home Again!
Program Outcomes (reference #01616 Emelda Skidmore and daughter
#01624 L’Tanya Jackson)
Preservation Resource Center Preservation in Print Magazine Article:
HBRGP Intern Yuen Ren Profile
Preservation Resource Center Preservation in Print Magazine Article: Old
Arabi National Register Historic District Grants; Repair Article - Energy
Saving Tips for Historic Buildings
142

November 2009
December 2009 /
January 2010
February 2010
May 6, 2010
Summer 2010
September 2010
October 2010
November 2010
December 2010-January
2011
February 2011
March 15, 2011
March 2011
April 12, 2011
May 2011
Preservation Resource Center Preservation in Print Magazine Article:
Researching Historic Buildings
Preservation Resource Center Preservation in Print Magazine Article:
Historic Paint and Coatings for Historic Buildings; Case Study on Grant
Recipient #00167 Musée Rosette Rochon
Preservation Resource Center Preservation in Print Magazine Article:
Recycling and Reusing Salvaged Historic Architectural Features; Repair
Article – Cast Iron
Mississippi Heritage Trust, Historic Preservation Conference
Session: Energy Efficiency for Historic Buildings, Presenter: Tracy Nelson,
Program Director
Preservation Resource Center Preservation in Print Magazine Article: Case
Study on Grant Recipient #01368, 01374, Julia Row Buildings, Pamela
Page
Preservation Resource Center Preservation in Print Magazine Article:
Recovery Warriors – Champions of HBRGP; Article – LASHPO Challenges of Past Five Years
Preservation Resource Center Preservation in Print Magazine Article:
Grant Recipient #01382 Bouey Moore Homestead; Case Study on Grant
Recipient #01782 Rest-A-While, Kings’ Daughters and Sons of Louisiana
Preservation Resource Center Preservation in Print Magazine Ask an
Expert Column by Tracy Nelson
Preservation Resource Center Preservation in Print Magazine Ask an
Expert Column by Tracy Nelson
Preservation Resource Center Preservation in Print Magazine Ask an
Expert Column by Tracy Nelson
George Wright Conference, Session on Disaster Recovery, Presenter
Nicole Hobson-Morris, Executive Director
Preservation Resource Center Preservation in Print Magazine Ask an
Expert Column by Tracy Nelson (new position as Executive Director
Center for Sustainability and Design)
New Orleans Citizens Diplomacy Council, International Visitor Leadership
Program, Cultural Heritage Preservation, A Regional Project for South and
Central Asia, , 11 Leadership Fellows Presentation on Disaster Recovery,
Dabne Whitemore
Preservation Resource Center Preservation in Print Magazine Article:
SHPO Financial Incentives for Historic Renovation
143

List of Attached Background Documents:

Public Law 109-234 and 110-28

LASHPO Action Plan Narrative

Historic Building Recovery Grant Program Guidelines and Application Form

Programmatic Agreement ($11.2 million)

First Amendment to Programmatic Agreement ($10 million)

Louisiana Treatment Protocols

HPF Award Letters and Grant Agreements
144

Anything referenced within the report.
Grant Workshop PowerPoint
Panel Review documents:

Call for nominations,

Applicant letter

Panel letter,

Pre-score form,

Scoring guide sheet,

Pre-score spreadsheet,

Panel spreadsheet,

Bios of panelists,

Panel comments
Grant Agreement
Handouts for Grantees
Letters to grantees
Preservation Agreement Compliance Review Instructions & Form
Policy and Procedures document for Preservation Agreement Compliance Review
Policy and Procedures document for Collections
[insert entire section of maps – statewide, disaster areas, flooding depths, and NRHD in new Orleans, plus the grant maps].
145

Applicant
Preservation Resource Center/Operation Comeback &
Rebuilding Together
UJAMAA Community Development Corp
Joseph Clark
Landreth Loft Company LLC
Julie Simpson
Group
Group H
Group I
Number of
Applications
Submitted
Number of
Grants
Awarded
% of
Grants
Awarde d
23
6
4
3
3
3
3
3
9
5
39%
83%
75%
100%
100%
Degas House, LLC/Duvigneaud House, LLC
Alberta Graf
Oak Alley Foundation
New Orleans African American Museum
Julia's Guest House, LLC
Calvin Alexander, Jr
Shannon Johnson
Lillie Davis
Mark Holian
Good Sisters LLC
Julie Skjolaas
LeRoy and Frankie Gardner
Joseph Fertitta
WC & Ruthie Marie LLC
Bernice Crump
Fannie Higgins
Pat Shelby
Lathan Madison
Ruth Bodenheimer
Kathleen Cresson
Georgiana Gray
The King's Daughters and Sons of Louisiana/LA. Branch of the International Order of Kings
William Maloney
Anthony Marinaro
JoAnn Najolia
Hollie Vest
Blanche Lovelly
Carmencita Baker
Group D 7
5
4
2
2
2
2
3
3
2
3
3
3
3
2
3
3
4
3
2
2
2
2
2
2
2
2
2
1
1
1
2
2
2
2
2
2
2
3
3
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
100%
100%
100%
100%
14%
20%
25%
100%
100%
100%
67%
67%
100%
25%
33%
33%
33%
33%
50%
50%
50%
50%
50%
50%
50%
50%
50%
50%
Value of
Grants
$387,830.00
$195,000.00
$135,000.00
$135,000.00
$130,400.00
$114,000.00
$104,338.00
$74,380.00
$52,700.00
$29,340.00
$88,279.00
$75,700.00
$69,000.00
$55,000.00
$46,188.00
$20,022.00
$45,000.00
$45,000.00
$5,800.00
$45,000.00
$45,000.00
$45,000.00
$14,000.00
$45,000.00
$45,000.00
$45,000.00
$45,000.00
$45,000.00
$45,000.00
$45,000.00
$45,000.00
$38,000.00
$37,618.00
146

Kimbley Sceau
Daniel Ryan
Karen Jackson
Thelma Chopin
Christopher Lund
Fatma Aydin
Wanda Fernandez
Willie Anderson
SUB-TOTAL:
Group E Susan Smith as agent for multiple property owners
James & Richard Realty Holdings, LLC/J&R Realty
Holdings/Michelle Cahn Wolfson Trust Group C
William Alden / Crescent City Property
Redevelopment, LLC/Side by Side Redevelopment, LLC
Donald Moore, Jr. Group B
Shahram "Benny" Naghi c/o Belinda Little-Wood, 10th
Capital Management, LLC Group F
John Orgon and 930 Tchoupitoulas Ventures, LLC;
Engine 22, LLC; Turquoise Ventures
Venti Investments LLC
DMR Builders, LLC
Doby Properties, LLC
Esther Clesi
Gwendolyn Esteen
Shakir Hameed
Phyllis Smith
George Akehurst
Nham Dao
Ernest Riley
Shaun Scott
Deborah Small
Acadian Heritage & Culture Foundation, Inc.
Jacqueline Adams
Sammuel Alexander Sr.
Carmen Baham
Edward Breaux, Jr.
George & Nina Buck
Carol Carrone
Jimmie Chambers
Edgar Chase, IV
Group G
2
2
2
2
2
2
2
2
132
66
18
11
11
11
2
2
3
3
3
3
4
3
4
4
4
4
6
5
4
2
2
2
2
2
2
2
147
0
0
1
1
1
1
1
1
1
1
72
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
50%
50%
50%
50%
50%
50%
50%
50%
0%
0%
$35,000.00
$34,854.00
$26,300.00
$23,660.00
$22,700.00
$20,000.00
$18,000.00
$4,000.00
$2,577,109.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00

Clarkanal LLC
Steve Collara
Johnny Darby
Josephine Davis
Lorna DeLay
David Dotson
Joseph Dousey
Bert Dupre
Michael Duronslet
Cabrina England
Willie Franklin Sr.
Marie Galatas
Gretchen Gattuso
Fernanda Guillen
Robyn Halvorsen
Aucion Hatcher
Dewawn Hatcher
Jeffrey Hunter
Cassandra Hyer, CD Hyer Property Management
Glynn Hyer
Katz-Derbes Properties, LLC
Troy Lawrence Sr.
Linda LeBlanc
Jeanne Lee
Michael Lewis
Liberty Village, INC.
Edward Lirette
Keith Mason
Beverly McKenna
John Messina, Jr.
Kenneth Mitchell
Lester Nicholas
Belva Pichon / Pocte Corporation
Rosita Rodriguez
Douglas Roome
Lara Schultz
Carolyn Seaton
Carl and Rita Severan
Artis Solomon
Augustus Taylor
James Terry
148
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00

Tiffany Treadaway
Christine and Anthony Williams
Henry and Orietta Williams
Roberta Williams
Andre Wilson
SUB-TOTAL:
TOTAL:
2
2
2
2
2
277
409
0
0
0
0
0
0
72
0%
0%
0%
0%
0%
Scope of Work Assessment – how many had high integrity and had problems with the grant
Building
Integrity
High
High
High
Low
Low
Low
HBRGP
Determination CountOfGrant#
NAE 352
10 AE Minor
AE
Insignificant
Medium NAE
Medium AE Severe
Medium AE Minor
Medium
AE
Insignificant
Low
TOTAL
NAE
AE
NAE
AE Severe
AE Minor
AE
Insignificant
AE Overall
12
22
84
1
11
10
21
106
54
15
10
11
36
570
Of
Integrity Overall
94% 62%
374
90
3%
3%
6%
79%
1%
10%
9%
20%
60%
17%
11%
12%
40%
2%
2%
4%
66%
15%
0%
2%
2%
4%
19%
9%
3%
2%
2%
6%
16%
86%
14%
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$2,577,109.00
149

i This total represents the exposure value of all issues and not the total of individual sub-grant projects. Some sub-grant projects contained more than one issue. The total without crossover

1. Total Sub-grant Repairs Not SOIS exposure cost on 33 sub-grant Projects =
$400,528.41. Two (2) Sub-grant Repairs Not SOIS are also in Collections. The exposure value of these is $31,674. Removing these sub-grant projects reduces the total exposure to $368,854.41. Note: The item for which a sub-grantee may be in Collections may not be the same repair cost that qualifies the work as not meeting SOIS, in which case this number may actually increase.

2. Total Financial Documentation Exposure Cost on 67 Sub-grant Projects = $764,101.13.
Twelve (12) sub-grant projects with Financial Documentation issues are also considered not meeting Secretary of the Interior Standards. The exposure value of these is
$156,170.77. Removing those sub-grants with cross-over reduces the total overall
Financial Documentation exposure to $607,930.36. ii This total represents the exposure value of all issues and not the total of individual sub-grant projects. Some sub-grant projects contained more than one issue. The total without crossover
 1. Total Sub-grant Repairs Not SOIS exposure cost on 33 sub-grant Projects =

$430,503.78. Eight (8) Sub-grant Repairs Not SOIS are also in Collections. The exposure value of these is $132,803.30. Removing these sub-grant projects reduces the total exposure to $297,700.48. Note: The item for which a sub-grantee may be in Collections may not be the same repair cost that qualifies the work as not meeting SOIS, in which case this number may actually increase.
2. Total Financial Documentation Exposure Cost on 50 Sub-grant Projects = $732,656.67.
Eleven (11) sub-grant projects with Financial Documentation issues are also considered not meeting Secretary of the Interior Standards. The exposure value of these is
$191,884.02. Removing those sub-grants with cross-over reduces the total overall financial documentation exposure to $540,772.65. iii The total exposure without crossover is $2,116,262.50 on 175 sub-grant projects. The total exposure cost is 14% of all sub-grant expenditures for the repair of historic buildings damaged by Hurricanes Katrina and Rita; however, it represents 31% of all sub-grantees. iv http://www.neworleanshistorical.org/items/show/288
150