Cover Page
LOUISIANA STATE HISTORIC PRESERVATION OFFICE
FINAL PROJECT REPORT
NPS HURRICANE GRANT RECOVERY PROGRAM
NPS GRANT #22-06-HR-21572
NPS GRANT #22-07-HR-21671
January 31, 2014
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
January 2014
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.
Pamela Breaux
Louisiana State Historic Preservation Officer & Assistant Secretary, Office of Cultural Development
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
From the Louisiana State Historic Preservation Officer,
Dear National Park Service,
We wish to thank you and the Congress for your quick response to the devastation in the Gulf Coast and
particularly in Louisiana after Hurricanes Katrina and Rita back in 2005. Our rich cultural landscape was
significantly impacted by the effects of these hurricanes, but we were not to be deterred. Many building
owners wanted and needed to rebuild not only their lives, by repairing their historic properties,
businesses and communities. The appropriations received from Congress helped many of our
constituents return to Louisiana.
The Historic Building Recovery Grant Program (HBRGP) provided the National Park Service and the State
Historic Preservation Office with an opportunity to play a major role in the recovery process when our
constituents needed it most.
While Louisiana and the Gulf Coast is no stranger to Hurricanes, in 2005 Hurricane Katrina proved to be
the most ruinous disaster our communities had seen. Louisiana was the only state along with Mississippi
and Alabama, to receive a second appropriation due to the extent of damages we incurred. These funds
brought real and immediate financial relief to our constituents in their time of need. And, this program
(HBRGP) made a significant and tremendous difference in saving a number of our historic resources
from total destruction.
As with many things, time allows for a level of reflection that cannot be gained in the immediate. This
final report will reflect on the important role the HBRGP played in making a difference in our historic
communities by reporting the processes that were developed to address the historic building recovery
efforts throughout Southern Louisiana. It will also address the things that worked well and not so well
for the good of our constituents during their time of recovery and rebuilding.
3
Table of Contents
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
4
8) Sub-grant Preservation Agreement Policies and Procedures
9) National Park Service Reporting and Requirements
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
Part B: Archaeology
Part C: SHPO Thoughts on NPS Compliance Requirement/ Support for Future Undertakings
Part D: Case Studies
Part E: Federal and State Assistance
Partnerships
a. PNOLA
b. Qatar Tremé Renewal Project
c. United Way
d. Rebuilding Together
e. Louisiana State Museum
f. Preservation Resource Center
g. GIS & Survey / Damage Assessment
h. Volunteer Response and Debris Removal
i. Building Assessments and Renovation Plans
j. Comprehension of Secretary of the Interior Standards
k. Contractors / Craftsmen
Part F: Required Data Documentation for each sub-grant project
Appendix 1: Hurricane Recovery Printed & Published Materials/Conference Presentations
5
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
List of Maps and Tables
 Maps
 Tables
6
Executive Summary
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]
7
Introduction to Historic Louisiana and
Impacts from Hurricanes Katrina and Rita
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, per capita.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 reported that 25
times more debris was removed from the state than was removed from the World Trade Center site in
4
Ibid.
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
5
9
New York. The LRA also reported that Louisiana had more than twice the severe damage to homes as
Alabama, Mississippi, Florida, and Texas combined.
Through it all, as the grantee, the LASHPO had to be cognizant of the emotional toll this extraordinary
disaster brought to bear on our constituents. In addition to the tangible losses captured daily, weekly
and then monthly on the news for the world to see, HBRGP Project Officers witnessed firsthand how
some sub-grantees, their families, friends and neighbors struggled to cope with the reality of wide
spread damages and unforeseen 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 losses to their familiar spaces. Many New Orleanians witnessed their homes
being 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 in New Orleans had to be evacuated from the area on “rescue buses” and
brought to other states. Many of these variables 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. 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)
10
National
Register
Records
1
1
Orleans
St. Tammany
143
39
National
Register
Historic
Districts
23
2
1
1
1
2
Jefferson
St. Bernard
Plaquemines
East Baton Rouge
19
8
8
85
1
2
0
9
2
Tangipahoa
32
4
2
2
Pointe Coupee
West Feliciana
32
31
0
2
Certified Local
Governments
(*also a Main Street
Community)
New Orleans* †
Covington
Slidell*
Kenner
Baton Rouge
Hammond*
Ponchatoula*
New Roads*
St. Francisville*
Figure 1. Louisiana Planning Regions Source:
Louisiana Division of Administration
Figure 2. LA Go-Zone Parishes
2
2
2
2
2
East Feliciana
Iberville
Ascension
Washington
West Baton
Rouge
Livingston
31
22
20
15
13
1
1
1
0
2
Clinton*
Plaquemine*
Donaldsonville*
Bogalusa*
12
0
Denham
Springs*
2
22
21
17
16
0
1
1
1
1
3
3
4
St. Helena
Lafourche
St. James
Terrebonne
St. John the
Baptist
Assumption
St. Charles
St. Landry
10
6
37
0
0
3
4
Iberia
30
1
4
St. Mary
27
1
4
4
4
4
4
St. Martin
Lafayette
Vermilion
Acadia
Evangeline
25
24
17
7
6
2
2
2
1
0
5
Calcasieu
18
1
5
5
5
5
6
7
7
Jefferson Davis
Beauregard
Allen
Cameron
Vernon
Natchitoches
Sabine
18
14
4
2
16
30
7
0
1
0
0
1
1
1
2
2
3
3
3
3
Thibodaux*
Figure 2. Gulf Opportunity Zone Parishes
Source: Louisiana Economic Development
Houma*
Eunice*
Opelousas*
Jeanerette
New Iberia*
Franklin*
Morgan City*
St. Martinville*
Abbeville*
Crowley*
Mamou
Ville Platte
DeQuincy
Lake Charles
DeRidder*
Kinder
Leesville*
Natchitoches*
† 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. 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
11
Register historic district. The shaded sections represent Orleans Parish historic districts where the most
significant flooding occurred during Hurricanes Katrina and Rita.
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
Broadmoor Historic District
Bywater Historic District
Carrollton Historic District
Central City Historic District
Esplanade Ridge Historic District
Gentilly Terrace Historic District
Holy Cross Historic District
Lower Central Business District
Mid-City Historic District
New Marigny Historic District
Parkview Historic District
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
Old Arabi Historic District (St. Bernard)
Friscoville Street Historic District (St.
Bernard)
Denotes higher levels of flooding
Number of
Structures
1,075
2,050
6,220
4,013
4,146
665
857
290
4,498
3,533
1,349
164
512
1,763
2,100
1,137
2,000
1,180
10,716
2,039
Number of
Contributing
Elements
940
1,785
5,143
3,531
3,843
544
634
259
3,567
2,826
1,239
164
438
1,670
2,100
951
2,000
956
8,787
1,737
Locally
Regulated
HDLC
HDLC
HDLC
HDLC
HDLC
HDLC
HDLC
HDLC
HDLC
-
Total
Impacted
24,913
18,201
VCC
50,307
43,114
10
43,114
Waiting for any stats from NR Program on these nominations or
other information
140
106
-
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. The FEMA Federal Preservation
Officer arrived in Baton Rouge, LA two-weeks after Hurricane Katrina touched down to set up an office
in the capitol city to assist his agency in addressing the massive disaster by meeting with a number of
federal and state agencies including the LASHPO. After many of the roads were cleared of debris, the
12
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. 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.
Property owners had to navigate the complex application processes for assistance from FEMA and the
U.S. Department of Housing and Urban Development (HUD), specifically the Disaster Community
Development Block Grant (DCDBG) awarded to the Louisiana Recovery Authority and known as The
Road Home Program. As of December 28, 2006, the Road Home program funded only 101 closings and
by August 9, 2007 only 41,619 closings had been handled for the estimated 515,000 properties damaged
statewide.
13
Overview of Emergency Supplemental Appropriation
to Historic Preservation Fund for Louisiana
The LA SHPO, comprised of the Division of Historic Preservation and the Division of Archaeology, 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), provided training CAMPS to the CLGs and also funded the Regional Archaeology
programs (as approved by NPS). 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 official 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 LASHPO 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 also
able to hire two temporary staff to handle the influx of reviews from areas across South Louisiana
relating to hurricane recovery efforts with FEMA funding. By 2006, the LASHPO had just begun to work
with FEMA and other agencies on multiple Programmatic Agreements to address the recovery process.
14
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
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.
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
Grant Program
 Restoration of historic buildings
 Project management assistance
 Planning
NPS Grant#
22-06-HR-21572:
22-07-HR-21671:
Amount
$10,575,000
$ 9,500,000
Total
$ 20,075,000
Section 106 for all federal projects in
Louisiana
22-06-HR-21572:
22-07-HR-21671:
$ 1,300,000
$-
$ 1,300,000
Administrative costs
22-06-HR-21572:
22-07-HR-21671:
$ 625,000
$ 500,000
$ 1,125,000
National Alliance of Preservation
Commissions Conference, July 2008
22-06-HR-21572:
22-07-HR-21671:
$ 209,567
$-
$
209,567
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 Part F. The LASHPO hopes to show the complexities that
arose during this 7-year program and provide some suggestions for both policy and procedural
15
improvements. Within the report, sidebars called “Lessons Learned” will provide key insights on how
the LASHPO and/or NPS should do things differently in the future. These “Lessons Learned” consider
the conditions 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
PART A
HISTORIC BUILDING RECOVERY
GRANT PROGRAM
17
BACKGROUND
The ESHPF was the first specific appropriation for repairs to historic buildings the LASHPO implemented
at such a grand scale 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 subgrantees created a significantly different role for the LASHPO. The decision to offer mini-grants up to
$45,000 was intended to help more Louisiana residents who lived in historic buildings return home. This
course 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-HR21572, 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.
DESIRED OUTCOMES
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 when the ESHPF was awarded, pushed for programs that would aid
in helping Louisiana residents return home, given the mass exodus from communities in South
Louisiana. The need for funding was immediate and wide-spread. The HBRGP would play an important
role in the recovery process, as it sought to begin to restore historic properties, which in turn helped to
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
18
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 would allow the LASHPO to
positively impact historic preservation in Louisiana in a significant way. 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:
“The decisions we made were difficult ones,'' Gallas said, adding that he hopes the
grants will serve as a "catalyst'' in those communities.8
8
Gyan, Joe Jr., “Grants to rebuild historic La. Homes,” Advocate, The, Baton Rouge, LA, Wednesday,
February 28, 2007 - Wednesday, February 27, 2007
19
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.
GRANT PROGRAM GUIDELINES
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.
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.
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
BUY THE BOOK! One Block: A New Orleans
those regarding adverse effect determinations, was not
Neighborhood Rebuilds by Dave Anderson. The
included in the Guidelines. The Guidelines were also
book looks at the rebuilding efforts of one block
in the Holy Cross National Register Historic
limited in the amount of information contained on the
District. Almost half of the block received an
Secretary of the Interior’s Standards for the Treatment
HBRGP grant.
of Historic Properties as well as pertinent information
from the Historic Preservation Fund Manual. The four
key elements included were:
1) Eligibility
2) Congressional mandates according to Public Law 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.
20
Eligibility
To reach the broadest constituency possible, the only criterion established to be eligible for the grant
was the National Register status of the building. Any historic building listed or determined 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
Damage Caused by Katrina/Rita
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 also 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.
LESSON LEARNED:
One major challenge faced by the HBRGP was that many historic buildings had deferred maintenance
issues which were merely compounded by the hurricane related damage. Some components of the
house may not have been addressed in the scope of work initially, however when repairs began,
9
During early property assessments of historic properties in New Orleans by FEMA, 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 assessments of Orleans Parish National Register Historic Districts, the LASHPO proposed two additional
National Register Historic District expansions: 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. Both Expansions were later officially
updated in the National Register.
21
homeowners discovered other issues directly or indirectly related to the hurricane-related damage.
With this in mind, 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.
Duplication of Benefit
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
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 financial realities caused many individuals to use dollars
already awarded for building renovations on other uses.
11
Louisiana Action Plan to National Park Service, page 5, the Selection Process
22
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.
LESSONS LEARNED
As previously stated, by December 28, 2006, only 101
closings for funding had been made for the roughly 515,000
Application Questions on Duplication
estimated damaged buildings statewide. By August 9,
of Benefit
2007, the number of closing would jump to 41,619 closings,
8. Insurance: Have you received or do you
but still far short of the total number eligible for benefits.
expect to receive any insurance proceeds
Additionally, there was not a history of the LASHPO being
as a result of damage caused by either
included with other state recovery program operations.
Hurricanes Katrina or Rita?
The LASHPO did not have an established seat at the table
 YES  NO
with other state recovery programs and did not have the
If YES, did your insurance settlement
inner working knowledge to evaluate duplication of benefit
allow for repair or replacement of your
as it pertained to other recovery dollars.
building’s historically-significant features,
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 applications 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.
Financial Need
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 hurricane-related
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 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.
23
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 2006, 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.
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
12
Louisiana Division of Historic Preservation Action Plan Narrative, The Selection Process, page 5-6.
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.
13
24
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.
Compliance with Federal Laws and Programmatic Agreement
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
25
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 physical and emotional toll of the surviving such devastating hurricanes and coming to grips with the
recovery process did not fully allow many applicants to process much of the information they were
provided.
Evaluation Criteria and Application Requirements
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)
(2)
(3)
(4)
(5)
(6)
(7)
Located in National Heritage Area (the Cane River Heritage Area in
Natchitoches Parish)
Potential for expeditious repair
Owner-occupied property
Extent to which project will save an endangered property, restore
habitability, or restore architectural character
Financial need and commitment to rebuild
Project viability, reasonable cost, likely execution
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. Understandably,
26
no prior application form existed for such an undertaking, therefore, the NPS federal tax incentives
application form 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 the majority of
applicants that applied to the program 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.
COMMUNICATION & OUTREACH
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,
 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,
27
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.
Public Notice and Advertising of 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
Type of
Announcement
July 26, 2006 Press Release
October 5, 2006 Press Release
October 2006 Article
October 23, 2006 Press Release
October 31, 2006 Article
No Date Article
November 2006 Article
November 14, 2006 Web
Announcement
November 26, 2006 Radio Interview
November 26, 2006 Web
Announcement
November 27, 2006 Press Release
November 28, 2006 Article
November 28, 2006 Press Release
November 28, 2006 Calendar
28
Agency & Title
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”
The Times-Picayune (New Orleans, Louisiana) Metro
Section, “Historic home rehab grants offered – many
storm-hurt properties eligible”
The Daily Iberian (New Iberia, Louisiana)
Preservation Resource Center, Preservation in Print,
“Guidelines finalized: Deadline extended for historic
building recovery grants”
New Orleans Neighborhood Partnership Network,
“Historic Building Recovery Grant Program”
WRNO 99.5 FM Interview with Preservation Resource
Center
WRNO 99.5 FM, www.thenew995fm.com, “State offers
money to fix your historic home”
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”
December 2006 Article
December 2006 Advertisement
February 2007 Article
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
Call Center
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
Historic Preservation Grant Call Center
agency website via an online web form and from general
(225) 342-0227 or
inquiries to a generic email address. Between the toll-free
Toll-free at (866) 406-7043
hotline, the web form and the general email, approximately
3,000 individuals requested assistance related to the grant
Monday – Friday, 8:00am – 6:00pm
program.
Saturday, 12:00 noon – 5:00pm
hpgrantscallcenter@crt.state.la.us
Figure 3. Louisiana Division of Historic Preservation employee, Lois Dunn, answers the Grants Call Center line on opening day, September 15,
2006.
29
Informational Presentations to the Public
A key component of any grants program was the
ability to connect locally with constituents. An initial
series of five information presentations on the grant
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.
October 24,
6:00 p.m.
October 25,
6:00 p.m.
October 26,
6:00 p.m.
October 30,
6:00 p.m.
City & Location
Attendance
New Iberia, Sliman
4
Theater for the
Performing Arts
New Orleans, Grace
116
Episcopal Church
Lake Charles, Central
14
School Arts and
Humanities Center
Franklinton, Hillcrest
8
Baptist Church
New Orleans, Holy
157
Angels Catholic
Church
TOTAL
299
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
provided a better outreach mechanism to
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
9th Ward.
2) Broadmoor Fest: November 11, 2006 – a neighborhood street festival of booths and vendors
sharing information about recovery opportunities, 75 booth stops.
3) Broadmoor Neighborhood Association (BNA) General Meeting: November 15, 2006 – a
presentation to the community about the grant program, 30 attendees
30
4) 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 – 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
Figure 4. Satellite Office Advertisement
published in Preservation in Print, November
Mills building and in the Central Business District, 30
2006
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.
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.
Individual Assistance & Satellite Office
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 oneon-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 16th – 10 consultations
 November 17th – 12 consultations
 November 23-24th – 0 consultations (Thanksgiving)
 November 30th – 20 consultations
31





December 1st – 7 consultations
December 7th – 17 consultations
December 8th – 19 consultations
December 14th – 61 consultations
December 15th – 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 FUNDING DETERMINATIONS
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
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.
32
Intake
Evaluation
Funding
Data Processing &
Verification
Professional Panel
Review
Ranking Cut-Off
National Register
Eligibility
Scoring and Ranking
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.
Intake
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
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 verified the location of each
building on hard-copy maps of National Register Historic Districts (GIS was not used by our office yet).
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
determinations 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
33
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 SHPO16
(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.
National Register status codes (4) and (5) were developed
based on results from early FEMA reviews conducted. The
LESSONS LEARNED
LASHPO’s paper based files were not satisfactory for the
During application intake processing
and the review for National Register
use of expedited reviews. FEMA and the LASHPO quickly
eligibility, National Historic Landmark
determined that windshield surveys would have to be
status buildings were not separately
conducted in addition to FEMA placing their teams on the
identified. As a result, the requirement
ground to assess eligibility quickly. FEMA also
for submission of Project Notifications
supplemented their team with GIS personnel to map all
to the National Park Service was not
met as the maximum allocation amount
districts and sites located within boundaries already
was $45,000 and only projects over
established in SHPO paper maps. The FEMA/SHPO reviews
$50,000 required the Notification. A
proved critical to our National Register staff as they had
total of 65 buildings, including 4
not revisited the historic districts in New Orleans since
individually listed buildings, 18
contributing elements of the Vieux
many of them were listed back in the 1980s and 90s.
Carré (French Quarter) and 7
Architectural Historians working on behalf of FEMA
contributing elements of the Garden
recognized the need to update and expand some districts
District received grants; however,
as part of the 106 review process as the overall
Project Notifications were not
undertaking began to take shape. Item four includes
submitted. This level of identification
would likely have had two immediate
expansion areas for Bywater and Esplanade Ridge National
impacts, first to funding determinations
Register Historic Districts and the addition of two eligible
and second to track the requirements
historic districts, Pontchartrain Park and Edgewood Park
for HPF properties.
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 Broadmoor and Carrollton expansion has been
reviewed by the State Board and approved by the Keeper.
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.
34
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 duplicated and all
photographic documentation submitted was 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.
Evaluation
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 (panelist(s)). The panelists were assigned different committees that 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
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
35
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:
January 7th to
18th:
Notifiy Applicants
and Panelists
January 18th to
26th:
Panelist Review
Public Hearings
(12 days)
(9 days)
(7 days)
January 29th to
February 2nd:
Approve Funding
Recommendations Notice to Applicants
(5 days)
There was not sufficient time to review proposed scopes of work and determine project categories as
detailed above, while at the same time providing sufficient time for the panelists to review as many as
200 applications. With the first hearing date scheduled for January 18th, applications needed to be
collated and distributed to panelists 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
January 18, 2007
January 19, 2007
January 22, 2007
January 23, 2007
January 24, 2007
January 25, 2007
January 26, 2007
36
Category
Statewide (not New Orleans), Individually Listed and Individually
Eligible, Garden District
Groups, Vieux Carré, Lower CBD, Upper CBD
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
# of
Applicants
89
187
187
207
181
195
202
Figure 5
Panel Evaluation
Distribution of Applications
January 18, 2007
16%
7%
January 19, 2007
15%
January 23, 2007
16%
15%
January 24, 2007
January 25, 2007
14%
17%
37
January 22, 2007
January 26, 2007
LESSONS LEARNED
Given the unique situation of the disaster and the new role primarily assumed by DHP, 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 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 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
panelists. 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 panelists required approval of the State Historic Preservation Officer
(SHPO) prior to inviting the individual to serve on a committee. In total, 52 panelists were selected and
38
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
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
Friday, January 19, 2007: Group
Applications, Vieux Carre, Lower
CBD, Upper CBD
Monday, January 22, 2007:
Esplanade Ridge
39
Tuesday, January 23, 2007: Holy
Cross, Bywater, Algiers Point,
Parkview
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
40
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
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 panelists 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 their committee members (panelists) 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
41
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 committee. This system created a ranking order
that would initiate discussion during the public hearing. Prior to the public hearing, however, the PreScore 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:
No=1 point, or Yes=5 points
2. Located in a National Heritage Area:
No=1 point, or Yes=5 points
3. Financial need and commitment to rebuild: 1, 2, 3, 4, or 5 points
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
(10%)
(10%)
(10%)
(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 Selection
Criteria Guide Sheet & 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 general discussion during the public
42
hearing on the basis for that scoring. Once a group of applications were reviewed, typically about 7-10
applications having consistent scoring, the panelists in each committee 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 committee 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 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 committee. Finally, the applications were ranked from highest to lowest.
The ranking worksheet was then distributed to the committee for review. The committee 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 committee made a recommendation
for an appropriate cut-off point for funding. The cut-off point reflected the committee’s opinion of the
point where funding for the pool of applicants would no longer provide impact on historic resources.
One representative from each of the seven committees was also selected to serve on the funding panel.
Any of the seven committees were also 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,
next section below). Only one committee decided to deny funding. During the January 19th public
hearing, the committee agreed to deny funding to the 25 individual applicants of the Federal Fibre Mills
apartment building. The LASHPO did not prepare for applicants in large historic buildings with multiunits and multiple owners during the application process. Therefore, LASHPO was unable to determine
how they would be addressed prior to the application deadline and suggested constituents move
forward with an application, at which time a determination would be made regarding eligibility during
the review process. In the case of the Federal Fibre Mills, the committee determined that only one
application for funding could be allowed for this historic building. The rationale was that 25 individual
owners were seeking funding for repairs to primarily interior masonry walls without addressing the
exterior masonry damage. However, repairs to the exterior were the responsibility of the building
association. A motion was made by the committee to deny funding, and the motion was passed.
Subsequent to the committee motion, the LASHPO referred to the definition of a historic structure per
36 CFR 67.2 Definitions of Certified Historic Structures, section (b) that indicates portions of larger
buildings, such as single condominium units, are not independently considered certified historic
structures. As such, the 25 individual Federal Fibre Mills apartment building applications would not
have been eligible for grant funding anyway.
Scores from the committee were combined into one absolute ranking sheet. The committees reviewed
cut-off recommendations 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 of the request they receive is dependent on the cut-off point
43
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 18th:
January 19th:
January 22nd:
January 23rd:
January 24th:
January 25th:
January 26th:
Recommended a 2.0 cut-off point
Recommended a 2.9, 2.7 or 2.683 cut-off point
Recommended to fund more by providing only a percentage of the requested
amount
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
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.
Fully fund applicants until funding runs out
Stop at 3.0 and or provide a 60-40-20 percentage of request, split for each 1/3rd
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.
44
Appeals
LESSONS LEARNED
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 was 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 23rd 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 an appeal was 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
45
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 15th 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
Late
Not
Funded
Inappropriate
Grant Award
Adjustment
6
14
172
4
11
2
5
13
4
0
2
0
2
1
4
1
2
1
0
6
0
TOTAL
NonContributing
Not
Eligible
Incomplete
Photos
Incomplete
Application
287
22
36
33
Appeals to Reconsider
45
7
3
Appeals Funded in Round 1
10
1
Appeals Funded in Round 2
11
1
Appeal Status
Appeals Received
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
Number
of
properties
Funding Committee Recommendation
283
Appeals Review
6
TOTAL
289
46
Amount
allocated
$9,601,512.00
$ 275,800.00
$9,877,312.00
Additional $10 Million Congressional Allocation
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
SHPO 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-grantee 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.
f) Ownership Not Clear – The applicant is not the owner or a “for sale” sign appears in the
application photos.
47
g) Demolition – The City of New Orleans and FEMA issued a property listing for properties
on the demolition list.
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
226
Yellow
Red
14
9
Results of Mandatory Site Inspection
17 applications required additional monitoring; no mandatory site
inspection
1 not eligible; 8 allocated funding; 5 received increased grant award
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.
Reallocation of Funding
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-grantee 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
Reduction of Original Grant
Completed At or Below Cost
0% - No Reduction in Grant
1-10% of Original Award
11-25% of Original Award
48
NPS GRANT
22-06-HR-21572
NPS GRANT
22-07-HR-21671
224
26
26
192
33
16
75%
9%
9%
71%
12%
6%
TOTAL
416
59
42
73%
10%
7%
Sub-Total
276
93%
241
89%
517
91%
26-50% of Original Award
13
4%
15
6%
28
5%
51-80% of Original Award
100% of Original Award/Did Not Execute Grant
100% of Original Award/Collections Proceedings
Sub-Total
5
2
2
22
2%
.5%
.5%
7%
7
2
7
31
3%
1%
3%
11%
12
4
9
53
2%
1%
2%
9%
TOTAL
298
100%
272
100%
570
100%
Terminated or Inability to Complete
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-grantees were allocated funding totaling $19,608,182. In the end, however, only 557
sub-grantee 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.
Table 12
Reduction of Grant Award
12 13
0% - No Reduction in
Grant
28
1-10% of Original Award
11-25% of Original Award
42
59
26-50% of Original Award
416
51-80% of Original Award
100% of Original Award
Table 13
# of
Applicants
Application Status
Eligible
Not Eligible
TOTAL
49
Amount
Requested
1,242
$43,415,406
643
$22,192,026
1,885
$65,607,432
Table 14
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
# of
Applicants
198
173
159
22
53
13
25
643
Table 15
National Register Status
Eligible
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
TOTAL
19
18
1061
63
Initial
Funding
Allocation
16
12
480
23
Final
Grant
Funded
14
11
470
23
16
65
1242
9
30
570
9
30
557
Table 16
NPS Grant#
22-06-HR-21572
22-07-HR-21671
TOTAL
Original # of
Final # of
Sub-Grants Sub-Grants
Allocated
Awarded
298
294
272
263
570
557
Original
Allocated
Final
Paid
$10,154,991.00
$9,448,290.00
$19,603,281.00
$9,685,282.83
$8,881,651.63
$18,566,934.46
Table 17
Parish
Acadia
Ascension
Assumption
50
City
Crowley
Donaldsonville
Napoleonville
Applied
2
1
1
Eligible
2
1
1
Funded
(Final)
1
1
1
Total Grant
Expended
$45,000
$45,000
$31,800
Calcasieu
East Baton Rouge
Iberia
Iberia
Jefferson
Jefferson
Jefferson Davis
Lafayette
Lafourche
Lafourche
Morehouse
Natchitoches
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
Vermilion
Vermilion
Washington
West Carroll
51
Lake Charles
Baton Rouge
Jeanerette
New Iberia
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
Erath
Gueydan
Franklinton
Oak Grove
TOTAL
8
2
1
1
2
1
1
1
2
1
1
1
1
1,768
1
1
1
42
5
1
1
3
1
2
2
3
12
1
2
1
3
1
2
2
2
1
1,885
5
1
1
1
1
1
1
1,173
1
1
28
2
1
1
3
1
1
1
2
3
1
2
1
1
2
2
1,242
2
1
1
1
508
1
21
2
1
1
3
1
1
1
2
2
1
1
2
1
557
$88,074
$0
$0
$34,190
$0
$0
$0
$36,000
$0
$0
$0
$43,412
$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
$0
$54,072
$45,000
$0
$18,279,361
Table 18 Applicants and Funding List of Properties Individually Listed in or Eligible for the National Register of Historic
Places.
National
Register Status
Parish
City
Listing
National Historic
Landmark
National Historic
Landmark
National Historic
Landmark
Individually
Listed
Individually
Listed
Natchitoches
Derry
Magnolia Plantation
Assumption
Napoleonville
St. James
Vacherie
Ascension
Donaldsonville
Iberia
New Iberia
Individually
Listed
Individually
Listed
Individually
Listed
Lafayette
Youngville
# of
Applicants
%
Funded
1
# of
Funded
(Final)
1
Madewood Plantation
1
1
100%
Oak Alley Plantation
3
3
100%
1
1
100%
1
1
100%
1
1
100%
1
0
0%
5
3
80%
2
2
100%
100%
Lemann Block Building
Lutzenberger Foundry &
Pattern Shop Building
The Duplex House
Lafourche
Lockport
Orleans
New Orleans
Individually
Listed
St. Bernard
St. Bernard
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Listed
Individually
Eligible
Individually
Eligible
St. Charles
Destrehan
Ormond Plantation House
1
1
100%
St. James
Convent
Judge Felix Poche Plantation
1
1
100%
St. John
Garyville
Emilie Plantation House
1
1
100%
St. Tammany
Lacombe
Rankin House/Fountainhead
1
1
100%
St. Tammany
Slidell
Francois Cousin House
1
0
0%
Tangipahoa
Amite
Epney
1
0
0%
Terrebonne
Houma
Herman A. Cook House
1
1
100%
Vermilion
Gueydan
Bank of Gueydan
1
1
100%
Jefferson
Marrero
Louis H. Marrero Home
1
0
0%
Orleans
New Orleans
5
3
60%
Individually
Plaquemines
Buras
Porteus House; Lustron
Home; H. Jordan Mackenzie
House, "Blue Roof"; 445
South Rampart Street; 447449 South Rampart Street
1st Hospital in Plaquemines
1
0
0%
52
Boaverans Plantation House
The Pitot House; A.P.
Tureaud, Sr. House;
Lafcadio Hearn Residence;
Carver Theatre; BullittLongenecker House/"The
Swiss Chalet"
Kenilworth Plantation;
Sebastopol Plantation
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Individually
Eligible
Parish
Plaquemines
St. Tammany
Pointe-a-laHache
Covington
Adema Plantation House
1
1
100%
St. Tammany
Mandeville
Original St. Tammany Parish
Courthouse
Rest-a-While; Magnolia Rest
1
1
100%
2
2
100%
St. Tammany
Slidell
Old Salmen Commissary
2
2
100%
Tangipahoa
Hammond
2
0
0%
Vermilion
Gueydan
Allen Doss Martin House
1
1
100%
Washington
Franklinton
Bouey-Moore House
2
1
50%
42
30
74%
Total Individual Buildings
Table 129
National Register
Status
Historic District
Parish
Acadia
City
Crowley
Historic District
Crowley Historic District
Historic District
Calcasieu
Lake Charles
Historic District
Jefferson
Gretna
Lake Charles Historic
District
Gretna Historic District
Historic District
St. Bernard
Arabi
Historic District
Historic District
Friscoville Street
Historic District
St. Bernard
Arabi
Old Arabi Historic
District
Vermilion
Abbeville
Downtown Abbeville
Historic District
National Register Historic Districts - Statewide
# of
Applicants
2
# of Funded
(Final)
1
%
Funded
50%
5
2
40%
1
0
0%
8
4
50%
20
17
85%
1
1
100%
37
25
68%
National Historic
Landmark
National Historic
Landmark
Historic District
Orleans
New Orleans
Garden District
12
7
58%
Orleans
New Orleans
Vieux Carre
48
18
38%
Orleans
New Orleans
Algiers Point
14
6
43%
Historic District
Orleans
New Orleans
Broadmoor
46
25
54%
Historic District
Orleans
New Orleans
Broadmoor Expansion
8
4
50%
Historic District
Orleans
New Orleans
Bywater
58
24
41%
Historic District
Orleans
New Orleans
Bywater Expansion
3
1
33%
Historic District
Orleans
New Orleans
Carrollton
37
21
57%
Historic District
Orleans
New Orleans
Carrollton Expansion
Historic District
Orleans
New Orleans
Central City
Historic District
Orleans
New Orleans
Historic District
Orleans
New Orleans
53
8
5
63%
37
11
30%
Esplanade Ridge
183
83
45%
Esplanade Ridge
17
5
29%
Expansion
Historic District
Orleans
New Orleans
Faubourg Marigny
29
16
55%
Historic District
Orleans
New Orleans
Gentilly Terrace
31
22
71%
Historic District
Orleans
New Orleans
Holy Cross
118
80
68%
Historic District
Orleans
New Orleans
Irish Channel
33
9
27%
Historic District
Orleans
New Orleans
Lower CBD
10
7
70%
Historic District
Orleans
New Orleans
Lower Garden District
38
12
32%
Historic District
Orleans
New Orleans
Mid City
137
56
41%
Historic District
Orleans
New Orleans
New Marigny
76
27
36%
Historic District
Orleans
New Orleans
Parkview
28
17
61%
Historic District
Orleans
New Orleans
South Lakeview
10
5
50%
Historic District
Orleans
New Orleans
Upper CBD
37
6
16%
Historic District
Orleans
New Orleans
Uptown
102
18
18%
Eligible Historic
District
Eligible Historic
District
Orleans
New Orleans
Edgewood Park
37
15
41%
Orleans
New Orleans
Pontchartrain Park
6
2
33%
1163
502
43%
National Register Historic Districts - New Orleans
Table 20
Property Use
Number
# of
of
Grants
Applicants Allocated
# of Grants
Final
Grants per
Building Use
Primary Residence
890
366
362
Part Primary Residence/
Part Rental
252
106
99
Rental Primary Residence/
Part Commercial Building
149
36
36
Commercial Building
78
36
35
Rental Property
25
26
25
11% Income
Producing
Not Available*
491
0
0
-
Total
1885
570
557
89% Owner
Occupied
* Building use data was not entered in the information management system for all ineligible applicants
Table 21
Congressional
District
1
2
54
Applicants
112
1680
Eligible
67
1115
Funded
35
480
Total Grant Expended
$1,116,223.00
$15,674,240.46
3
4
5
6
7
66
1
7
2
17
1885
44
1
4
0
11
1242
34
1
0
0
7
557
$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.
SUB-GRANTEE CHARACTERISTICS
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, Sub-grants, Contracts, and Third-Party Agreements,
Section D. Standards Applicable to Sub-grantees, 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 sub-grantee as responsible, the State Historic
Preservation Officer must ensure that a sub-grantee meets and
maintains the following standards as they relate to the scope of a
particular project:
NPS Compliance
The HPF Manual is not
designed to be used during
disaster recovery. Consider
this- during the Section 106
process, the federal agency
is required to determine
ways to avoid, minimize or
mitigate adverse effects.
The Section 106 process
does not mandate
preservation, while the HPF
manual does.
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
sub-agreements);
2. Be able to comply with the proposed or required
These two very different
completion schedule for the project;
requirements must be
considered when applying
3. Have a satisfactory record of integrity, judgment, and
the current HPF to a
performance, especially with prior performance upon
disaster situation where
grants and contracts;
Section 106 review is also
4. Have an adequate accounting system and auditing
required.
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;
55
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 sub-grantees (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
DISASTER
HPF
STANDARD
HPF
of the funding, many, but not all of the applicants applying for funding were very different than those
served by the LASHPO in the past. This is a very important point for the LASHPO because the difference
in sub-grantees served by this disaster recovery program made a big difference in outcomes. The HPF
did not change their requirements, although the situation our sub-grantees were placed in was nowhere
close to that found in a normal grant cycle. On one end of the spectrum, when applying these funds to
disaster recover, 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,
when applying these funds to disaster recovery, the needs of individuals to have a safe & secure
structure to come back to for home or business 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 or would have hired experienced preservation professionals to oversee
56
their project, and would have had adequate time to thoroughly plan the rehabilitation work funded by
the sub-grant.17
One of the most important points we can present in this document is how political pressure can and will
impact outcomes. Because of the nature of the devastation, many of our directives from the Governor
and Lt. Governor’s office focused on “LA Rebirth” and bringing folks back to Louisiana through the “Road
Home Program”. Our staff was doing an honest job of trying to contend with many obstacles that came
their way. Some obstacles included contractors who would refute the directions they provided to
particular sub-grantees, which presented problems at the next site visit, or the project officer had to
contend with some homeowners who never dealt with a bank before and had no bank account or
checks to use. The inability to understand itemizing resources had a direct correlation to how many subgrantees failed to understand why it was important to secure written contracts, invoices, and receipts.
The recovery 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.
An eligibility category was established in the Action Plan narrative to help offset some of the challenges
that may have been encountered by this new applicant pool 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
17
U.S. Department of the Interior, National Park Service, Historic Preservation Fund Grants Manual,
Chapter 8, Section D (2007), 8-3.
57
owners with multiple rental properties, and nonprofit organizations who owned property specifically for
redevelopment or community-based social service needs.
Table 22
Group App
Yes-A
Yes-B
Yes-C
Yes-D
Yes-E
Yes-F
Yes-G
Yes-H
Yes-I
Group Name, if applicable
Count Of
Grant#
23
12
16
5
70
11
J&R Rental Properties
Julie Skjolaas
Morris Kahn/Susan Smith, Contact
10th Capital Management/Naghi
Properties
DMR Builders
Preservation Resource Center
UJAMAA Community Development
Corporation
4
21
6
168
T
Table 23
Group Applicants
Preservation Resource
Center/Operation Comeback and
Rebuilding Together
Preservation Resource Center/
Rebuilding Together
UJAMAA Community Development
Corporation/St. Peter Claver Catholic
Church
Julie Skjolaas
Applications Submitted
21
Grants Awarded
7
2
2
6
5
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 9th
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 was sold at the conclusion of the
sub-grant project to first time home buyers. In this instance, the concept of the Group Applicant worked
58
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:
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. However, it might 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 to select the best candidates due to an unmanageable size of building stock or lack of
participation by the community. Having a coordinated effort for survey and assessment of historic
districts as a part of any disaster recovery system could be one of the benefits to many communities. 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.
A later 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.
59
Property Ownership
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.18
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 and
damage that occurred to many governmental buildings. Therefore, proof of ownership was not required
under the conditions 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.19
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.
#01756, David Margulis on behalf of William Chapman
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.
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
18
Historic Building Recovery Grant Program Guidelines, Eligibility Requirements, National Register of Historic Places, page 4.
19
Historic Building Recovery Grant Program Guidelines, Eligibility Requirements, Hurricane-Related, page 4.
60
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.
#00914, Tyrone Taylor on behalf of Robert L. Lucien, Sr.
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
$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
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.
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.
01686, William “Banks” McClintock on behalf of owner
Jennifer Coolidge
LESSONS LEARNED
There were significant challenges
for many property owners
resulting from the level of
destruction, even one year after
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
and manage the grant on behalf
of the owner was prudent as
many would not be able to
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
would assume responsibility in
the event the person acting on
their behalf was unable to
continue in that role.
The application submitted by Mr. Banks McClintock was for
Rather than only requesting basic
the renovation of 1228 Race Street, a three-story 10,000contact information for the
square-foot Italianate residence in the Lower Garden District.
owner, the LASHPO should have
The last major residence designed by noted architect Henry
requested specific information
Howard before the Civil War, the building was plotted in 1861
on the legal owners listed on the
for John T. Moore, a steamboat captain and wholesaler.
property deed and/or mortgage
When Hurricane Katrina hit, the house sustained serious
note along with full contact
damage from wind and a sinking foundation. The problems
information. Further, the legal
were so severe that the City of New Orleans red-tagged the
requirements for owners should
property as eligible for demolition. HBRGP helped fund the
have clearly defined and included
in the grant agreement. Lastly,
unearthing and rebuilding of the original, underground wine
property owners should have
cellar as part of the effort to address the foundation issues
been required to sign the
and remove the red-tag listing. The grant also contributed to
Preservation Agreement rather
repairing hardwood and marble tile floors, the front porch
than a designee.
foundation, masonry and windows, along with reconstruction
of 12 marble mantels. The owner of the property is Ms.
Jennifer Coolidge, but her 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
61
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.
LIFE CYCLE OF A SUB-GRANT PROJECT
Grant Agreement
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,
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.
62
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.
While the Action Plan did not specify when the Preservation Agreement would be executed, the LASHPO
chose to execute it at the end of the project. The intent was to include any requirements of the subgrantee 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 and 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 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 then advised that the grant agreement must contain provisions for
repayment of funds received if the sub-grantee deviate from the scope of work and a property is
adversely affected, or if alteration and damage occurs to the building that makes the property non-
63
contributing 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.
Scope of Work
Immediately following Hurricanes Katrina and Rita, it was clear that Louisiana’s, and in
particular New Orleans’, vast historic building stock was seriously compromised. The
LASHPO was busy working with FEMA, HUD and other Federal Agencies to address the
Section 106 process. The LASHPO/106 staff gained valuable information and also gained
access to areas closed to the immediate public as a result of FEMA reviews to address
cultural resources. In addition to the myriad federal undertakings now occurring as a result
of both hurricanes the LASHPO had other communities across the state that were not
affected by the Hurricanes that needed their attention. As a result, the burden of
responsibility for the appropriateness of historic repairs was placed first on the property
owner.
During all public meetings, the application process was discussed, all applicants were
instructed of the requirement for repairs to meet SOIS. The grant program guidelines
included the following paragraph related to SOIS:
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.
64
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 executed on site with laptops
and portable printers. 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 discussed after their
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 outlined in the application. Based on past experience, the LASHPO staff relied on this to be
true. 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. Most of the sub-grantees were homeowners whose primary
goal was to return to their familiar spaces, their homes. They truly had no concept of the requirements
they were signing up for. The HBRGP signified a glimmer of hope for many of our constituent to return
home.
65
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 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, the Program Director advised the Project Officers of the
following clarification regarding grant recipients they may encounter when the grant award may be
more than what was 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 some applicants had already been 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 given their ability to secure other funding. 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.
66
Site Visits
The LASHPO assigned each successful applicant to a Project Officer who worked closely with
each individual to: (1) develop and execute a scope of work and grant agreement; (2)
continually guide and monitor each project; and (3) ensure that all work met federal historic
preservation standards. Successful applicants were encouraged to stay in close touch with
their assigned Project Officer. Based on the large number of applicants in place to receive
grants, the LASHPO knew that site visits were critical to achieving successful outcomes. The
LASHPO had no pre-established contractor/craftsman list to refer to prior to the storm. The
Preservation Resource Center of New Orleans had such a list, but the list proved inadequate
after the storm. Many of these individuals were no longer accessible; because of the
widespread devastation many phone numbers were lost, changed or cancelled. Also, those
who remained were in such heavy demand that they could not assist all who called on them
to help, in a timely fashion. South Louisiana saw many new carpenters, masons, contractors,
and self-proclaimed contractors enter the area to assist in recovery efforts.
LESSONS LEARNED
The HBRGP emphasized for our office, how the use of a property can make the difference ones
outlook of the property. There is a big difference when working with a sub-grantee on repairs
associated with a historic commercial structure, an institutional building, or a museum, as
opposed to working with a sub-grantee on repairs associated with their primary residence. Unless
the homeowner is in-tune with the historic character and features extant throughout their house
and is prepared to take an active role in safeguarding these features throughout the
rehabilitation project, we found that many homeowners were willing to sacrifice interior features
that needed to be retained and repaired with funds being spent elsewhere in order to get back to
their homes and their communities quicker. The level of emotional damage encountered by our
sub-grantees also played a role in the level of control our Project Officers were truly able to
maintain.
67
The HBRGP Director developed instructions for the Project Officers when out in the field, given the large
number of sub-grantees each had to work with.
Each grant recipient received a grant package at the first site visit. The package included the following
items:
Project Officer- Notes for Site Visits:
















68
Construction estimates – all/general and specific to the project
Style of House
Any age / info on the 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 original folders to carry with you on site visits… should carry these with you in
case you speak to someone on the phone while out, do not have internet and need
info in their files…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).








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
Table 24 provides a perspective of the quantity and volume of reviews staff were engaged in during
initial site inspections:
Table 24
Site Insp 1
2/7/2007
2/8/2007
2/9/2007
2/13/2007
2/14/2007
2/15/2007
2/16/2007
2/17/2007
2/18/2007
2/21/2007
2/22/2007
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
69
NPS Fund
Code
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
Count Of Grant#
1
3
3
10
9
8
7
7
2
7
9
8
6
6
8
8
10
4
1
8
125
Sum of Pay1
$26,100.00
$59,980.20
$63,981.60
$198,297.00
$170,744.00
$139,985.00
$156,120.00
$139,312.00
$40,050.00
$121,830.00
$207,570.00
$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
Site Insp 1
3/7/2007
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
4/18/2007
4/19/2007
4/24/2007
4/25/2007
4/27/2007
5/1/2007
5/4/2007
70
NPS Fund
Code
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
Count Of Grant#
Sum of Pay1
9
9
8
2
1
8
7
6
6
8
6
7
4
1
6
4
2
2
8
4
9
117
$160,913.00
$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
5
5
4
2
2
4
3
2
4
2
3
1
2
2
$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
Site Insp 1
NPS Fund
Code
5/8/2007
90-Day Benchmark
4/10/2007
4/12/2007
4/13/2007
4/18/2007
4/19/2007
4/20/2007
4/24/2007
4/25/2007
4/26/2007
5/1/2007
5/2/2007
5/3/2007
5/4/2007
Sub-Total 90Benchmark
NPS Fund
Code
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
5672
Count Of Grant#
Sum of Pay1
41
$866,649.00
Count Of Grant#
Sum of Pay2
1
2
2
3
1
1
1
2
1
6
1
4
2
27
68
$6,400.00
$17,800.00
$9,664.00
$18,064.00
$4,880.00
$9,000.00
$1,800.00
$9,000.00
$2,697.00
$27,751.00
$6,900.00
$26,700.00
$16,255.00
$156,911.00
$1023,560.00
Beginning after the 60 day benchmark, sub-grant projects were underway and sub-grantees began
requesting second site inspections.
The second site inspection allowed Project Officers the opportunity to inspect work completed to date
and to ensure that repairs were being done in accordance with SOIS. At this point the Project Officer
was able to access work progress to determine work items that should have begun that had not been
implemented yet; what was close to beginning but could not for certain reasons; take photos to track
progress. It also allowed the Project Officers to ensure that all paperwork that the grant program
required were in order, keep an eye out for fraud or misappropriation of funds, then access whether to
recommend approval for a second payment of 20% of the grant award to the program director.
A 2nd Site Visit Procedures guide book was sent to every grantee after the 1st 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].
The second site guide book included the following language:
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
71
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
Cashier’s 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.
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 (Appendix 1 or 2) 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
Final Payment and Site Visit Requirements
72
The purpose of the Final Site Visit is to:
a) Inspect remaining work that is being funded by the Grant and
ensure repairs were completed 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,
c) Ensure that all contractors and expenses have been paid in full,
d) Approve and initiate reimbursement of your final 20% of the grant award, and
e) To finalize and complete your Grant Agreement with the State.
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.
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. 20
Payments
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
20
HPF, Chapter 6, C.5.
73
Grant Amendments
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-grantee
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-granteeee ran out of grant funds or the grant
agreement ended and was not extended were considered adverse effects as the sub-granteeee 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 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 sub-grantees 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, sub-grantees
did not comply with these types of requirements as they were not familiar with required project
management.
74
Project Timelines and Extensions
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.
Table 25
SUMMARY OF PROJECT COMPLETION
Count
Entire Renovation Completed (C)
% of
Total
Grants
379
66%
In Progress at 50-80% Complete (PM: Partial Mid)
99
17%
In Progress at 50-80% Complete (PM: Partial Mid) - Large
Renovation
22
4%
Only 10-50% Complete (PL: Partial Low)
44
8%
26
5%
570
100%
Only 10-50% Complete (PL: Partial Low) - Large Renovation
TOTAL
22-06-HR-21572
22-07-HR-21671
22-06-HR-21572
22-07-HR-21671
288
255
10
17
570
9/15/2008
6/30/2009
10/31/2009 - 3/1/2010
10/31/2009 – 5/30/2010
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:
Table 26
Score
NPS Grant#
4.600
22-06-HR-21572
75
Project
Completion
PM-LG
Location / National Register
Historic District
Esplanade Ridge
Building Name
NO Jazz and Heritage Festival
and Foundation
Grant#
00601
4.257
22-06-HR-21572
PM-LG
Lake Charles Historic District
4.217
22-06-HR-21572
PM-LG
Lower Garden District
Gov. Sam Houston Jones
House
00700
00051
1st Hospital in Plaquemines
Parish
4.214
22-06-HR-21572
PL-LG
Buras, Louisiana
01804
4.167
22-06-HR-21572
PM-LG
Carrollton
4.167
22-06-HR-21572
PM-LG
4.100
22-06-HR-21572
PL-LG
Mid City
Downtown Abbeville Historic
District
4.083
22-06-HR-21572
PM-LG
Lower Garden District
4.033
22-06-HR-21572
PL-LG
Holy Cross
4.029
22-06-HR-21572
PL-LG
Donaldsonville, Louisiana
4.000
22-06-HR-21572
PL-LG
Holy Cross
4.000
22-06-HR-21572
PL-LG
Pointe-a-la-Hache, Louisiana
3.950
22-06-HR-21572
PM-LG
Lower Garden District
3.938
22-06-HR-21572
PM-LG
Vieux Carre
The Doll House
01539
3.938
22-06-HR-21572
PM-LG
Lower CBD
Boudreaux's Jewelry Building
01026
3.920
22-06-HR-21572
PL-LG
Esplanade Ridge
01383
3.914
22-06-HR-21572
PL-LG
Crowley Historic District
L'Hote Townhouse
Grand Opera House of the
South
3.883
22-06-HR-21572
PL-LG
Mid City
3.883
22-06-HR-21572
PM-LG
Faubourg Marigny
3.867
22-06-HR-21572
PL-LG
Uptown
00797
3.867
22-06-HR-21572
PL-LG
Broadmoor Expansion
00739
3.850
22-06-HR-21572
PM-LG
Lower Garden District
00070
3.843
22-06-HR-21572
PL-LG
Lacombe, Louisiana
3.820
22-06-HR-21572
PM-LG
Esplanade Ridge
3.786
22-06-HR-21572
PL-LG
Lower CBD
E.F. Virgin Building (James
Dakin, Architect)
01813
3.786
22-07-HR-21671
PL-LG
Lower CBD
E.F. Virgin Building (James
Dakin, Architect)
01814
3.786
22-07-HR-21671
PL-LG
Lower CBD
E.F. Virgin Building (James
Dakin, Architect)
00845
3.783
22-06-HR-21572
PL-LG
Lower Garden District
00735
Canal Street Guesthouse
00004
The Frank's Theater
00673
Griffin House (Henry
Howard, Architect)
01680
00884
Lemann Block Building
00307
01719
Adema Plantation House
00119
01549
01163
01610
Musee Rosette Rochon
Rankin House/Fountainhead
00167
00058
00711
00854
3.775
22-06-HR-21572
PL-LG
Vieux Carre
St. Philip Street Ventures,
LLC.
3.775
22-06-HR-21572
PL-LG
Upper CBD
Julia Row, Good Sisters LLC
01374
3.775
22-06-HR-21572
PL-LG
Upper CBD
Julia Row, Good Sisters LLC
01368
3.767
22-06-HR-21572
PM-LG
Holy Cross
00009
3.733
22-06-HR-21572
PL-LG
00692
3.686
22-06-HR-21572
PL-LG
Broadmoor
West End Boulevard,
Lakeview, New Orleans
3.667
22-06-HR-21572
PM-LG
Carrollton Expansion
76
Porteus House
00900
01003
00545
3.667
22-06-HR-21572
PM-LG
Uptown
00623
3.633
22-06-HR-21572
PM-LG
Esplanade Ridge Expansion
00234
Rest-a-While, King's
Daughters and Sons of
Louisiana
3.571
22-07-HR-21671
PM-LG
Mandeville, Louisiana
3.567
22-07-HR-21671
PL-LG
Algiers Point
00285
3.550
22-07-HR-21671
PM-LG
Central City
00455
3.517
22-07-HR-21671
PM-LG
Lower Garden District
John T. Moore House (Henry
Howard, Architect)
01686
3.500
22-07-HR-21671
PL-LG
Garden District
Magnolia Mansion LLC
01678
3.460
22-07-HR-21671
PM-LG
Esplanade Ridge
00370
3.383
22-07-HR-21671
PM-LG
Uptown
01347
3.367
22-07-HR-21671
PL-LG
Mid City
00020
3.333
22-07-HR-21671
PL-LG
Holy Cross
01002
3.300
22-07-HR-21671
PL-LG
Esplanade Ridge
3.280
22-07-HR-21671
PM-LG
Esplanade Ridge
Carver Theatre
01782
00038
00604
Typical Grant Cycle
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
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 “PartialLow” 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
77
40
95
7%
17%
146
214
26%
38%
30
6
39
5%
1%
7%
1st Payment
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 1st 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.
Table 27
NPS Grant#
22-06-HR-21572
22-07-HR-21671
Deadlines & Extensions
By 9/15/2008
Gustav Extension
Completion Extension
New Grants (Reallocated) Post
Deadline
By 6/30/2009
Completion Extension
New Grants (Reallocated) Post
Deadline
Count
198
70
20
10
Percent
66%
24%
7%
3%
Total: 298
180
75
17
100%
66%
28%
6%
Total: 272
100%
Unallowable Costs and Financial Documents
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.
78
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.
Table 28
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
2. Collections Total
5
$67,431.60
Attorney General
2
$53,385.60
Internal Payment Plan
1
$4,500.00
Pending Determination
2
$9,546.00
67
$764,101.13
105
$1,232,061.14
1. Sub-Grant Repairs Not SOIS Total
33
$430,503.78
2. Collections Total
22
$233,573.00
Attorney General
5
$58,579.00
Internal Payment Plan
12
$118,879.00
Pending Determination
5
$56,115.00
3. Financial Documentation Total
TOTAL i
Table 29
NPS GRANT 22-07-HR-21671
(272 Sub-Grant Projects/$8,948,539.63)
79
3. Financial Documentation Total
50
$732,656.67
105
$1,396,733.45
1. Sub-Grant Repairs Not SOIS Total
66
$831,032.19
2. Collections Total
27
$301,004.60
Attorney General
7
$111,964.60
Internal Payment Plan
13
$123,379.00
Pending Determination
7
$65,661.00
TOTALii
Table 30
COMBINED
(570 Sub-Grant Projects/$18,566,759.46)
3. Financial Documentation Total
TOTAL iii
117
$1,496,757.80
210
$2,628,794.59
Table 31
Classification of Financial Documentation
Cash
Cost
Count
No
Cancelled No Invoice
Check
Fraud
Not Eligible Not In SOW No Receipt
$1,141,976. $154,425.06 $71,255.45 $71,049.00 $26,731.68 $22,682.98 $7,137.25
108
25
12
6
5
6
7
Theft
$1,500.00
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.
80
Table 32/ Chart
Financial Documentation on File
70
60
15
50
40
12
30
3
46
20
33
22
10
15
0
5
8
3
8
Invoice PAIDInvoice Only
Invoice/Receipt/
Check only Receipt Only None
Cancelled Check
No Affidavit
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.
Terminations and Cancelled Grants
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.
Table 33
NPS
Grant#
22-07HR21671
22-07HR21671
22-07-
81
Grant#
00030
GrantFina
l
$0.00
Paid
00038
$0.00
$27,000.0
0
$45,000.00
00114
$0.00
$27,000.0
$45,000.00
$0.00
GrantOrigina
l
$45,000.00
Amount
Owed
Repayment
Code
$27,000.0 Internal
0 Payment Plan
All
$27,000.0 Pending
Subgrantee
William &
Pomeroy
Lowry
Eugene
Oppman
Percy Gray
HR21671
22-07HR21671
22-06HR21572
22-07HR21671
22-06HR21572
22-07HR21671
22-07HR21671
22-07HR21671
22-06HR21572
22-07HR21671
22-06HR21572
0
0 Determinatio
n
$27,000.0 Internal
0 Payment Plan
All
$27,000.0 Attorney
0 General All
00510
$0.00
$27,000.0
0
$45,000.00
00699
$0.00
$27,000.0
0
$45,000.00
00753
$0.00
$5,280.00
$6,600.00
$5,280.00 Paid in Full
Kenneth
Johnson
00947
$0.00
$25,200.0
0
$42,000.00
$25,200.0 Paid in Full
0
Brenda J.
Kernell
00962
$0.00
$27,000.0
0
$45,000.00
Attorney
General All
01202
$0.00
$24,600.0
0
$41,000.00
01334
$0.00
$27,000.0
0
$45,000.00
01482
$0.00
$27,000.0
0
$45,000.00
01803
$0.00
$16,560.0
0
$27,600.00
01804
$0.00
$26,933.0
0
$44,888.00
$24,600.0 Internal
0 Payment Plan
All
$27,000.0 Internal
0 Payment Plan
All
$27,000.0 Attorney
0 General All
$16,560.0 Internal
0 Payment Plan
All
$26,933.0 Paid in Full
0
Keith M.
Pete
Kendrik D.
Foster
Wayne
Washingto
n
Cheryl R.
Austin
Victor W.
Davis
William
Inlow
Etta Y. Polk
Dana Johno
Repayment Procedures
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
82
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]
Table 34
Repayment Code
Attorney General All
Attorney General Partial
Internal Payment Plan All
Internal Payment Plan Partial
Pending Determination
TOTAL
Paid in Full
No. of
Subgrante
es
3
4
6
8
6
27
27
Total Amount
Paid to SubGrantee
$54,000.00
$73,481.00
$149,160.00
$235,200.00
$124,565.00
$636,406.00
$592,425.00
Owed
$54,000.00
$32,451.00
$149,160.00
$51,407.00
TBD
$287,018.00
$176,689.25
Balloon
Payment
(Portion of
Owed)
N/A
N/A
$83,860.00
$32,012.00
N/A
$115,872.00
N/A
Received
$698.00
$0.00
$31,250.00
$14,868
$0.00
$46,816.00
$176,689.25
NPS Project Notifications and Environmental Certifications
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
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.
83
Sub-grant Section 106 Review
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.”21
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.”
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.22 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:
21
Pam Breaux, email to LASHPO staff, January 3, 2007.
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.”
22
84
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.23 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.24 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.25 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.26
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
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.
23
Hampton Tucker, letter to Scott Hutcheson, July 13, 2009.
Jon C. Smith, letter to Phil Boggan, June 10, 2010.
25
Id.
26
Pam Breaux, email to LASHPO staff, January 3, 2007.
24
85
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.27 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.
Table 35 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
27
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.
86
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 35
Classification
Number of Sub-Grant
Projects Resulting in An
Adverse Effect
31
25
Percentage of all 78
Adverse Effects
Percentage of all 570
Sub-Grant Projects
40%
32%
5%
4%
Severe
Mitigated
15
7
19%
9%
3%
1%
Total
78
100%
13%
Insignificant
Minor
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.
87
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 36
HBRGP
Sub-Grantee
Classification
00105
Stella Parker
Insignificant
00155
Danny Santiago Sr.
Insignificant
00271
Carmen Ledesma
Insignificant
00283
Roland Williby Sr.
Insignificant
00291
Michael Prados
Insignificant
Insulation
00382
Gerard Moore
Insignificant
00485
LaJuan Booker
Insignificant
Flooring, Foundation,
Roof
Doors, Misc.
00602
Alberta Graf
Insignificant
Roof
00668
Bernice Crump
Insignificant
00693
Eugene Meunier
Insignificant
Insulation
00720
Kathleen Cresson
Insignificant
Insulation
00727
Katherine LeBlanc
Insignificant
Doors, Framing, Walls
88
Special
Determination
Collection
Code
Scope Of Work Item
Flooring
Demo by Neglect
Framing, Siding,
Windows
Gutters, Roof, Siding
Demo by Neglect
Roof, Siding
Terminated,
Repayment
AG, Partial
n/a – owner funded
00739
Donald Harrison
Insignificant
Foundation
00784
Frank D'Amico
Insignificant
Misc.
00789
Cheryl Raske
Insignificant
00796
Robert Nelson
Insignificant
Insulation
00907
Charles London
Insignificant
Insulation
00928
Vanessa Johnson
Insignificant
Doors
00940
Leonard Lewis
Insignificant
Doors, Windows
01235
Deidra Taylor
Insignificant
Doors
01334
Amy Davis
Insignificant
Terminated
01337
UJAMAA CDC
Insignificant
Design Review,
Terminated
01343
Glade Bilby II
Insignificant
01460
Eric Franklin
Insignificant
Terminated
Siding
01501
Troy Legeaux
Insignificant
Design Review
Gutters
01551
Shirley Charlot
Insignificant
Doors
01574
Celeste Williams
Insignificant
Doors
01588
Gloria Hilliard
Insignificant
01589
Ella Ware
Insignificant
01725
Jessie Rose
Insignificant
01835
Rhodesia Douglas
Insignificant
00099
Letitia Youngblood
Minor
00164
Jason Sampler
Minor
00237
Irvin Parker
Minor
Repayment
IPP, Partial
Doors, Porch, Roof
00464
00521
Willie McCloud
Ray Bush
Minor
Minor
Repayment
IPP, Partial
00590
00621
D. Joan Rhodes-Brown
Vyntrella Menzies
Minor
Minor
00679
Wilfred Sanchez Sr.
Minor
Electrical
Additions, Roof,
Windows
Foundation
Doors, Foundation,
Millwork
Siding
00736
Charline Cager
Minor
Foundation, Millwork
00900
L. Bryan Francher
Minor
Foundation
00916
Mary Watson
Minor
Doors, Porch, Walls
01019
Katie Pete
Minor
01224
Nicholas Scapin
Minor
Doors, Flooring,
Foundation
Roof, Windows
01357
Almetta Matthews
Minor
01416
Carlee Waites
Minor
Doors, Flooring,
Foundation
Foundation
01464
Reving Broussard, Jr.
Minor
Siding
01472
Edgar Poree, Jr
Minor
Foundation
89
Terminated
n/a – owner funded
IPP, All
Foundation, Walls
Foundation
Walls
Terminated
Foundation
Foundation
Design Review,
Terminated
Foundation, Siding,
Walls, Windows
Flooring
Doors, Flooring, Roof,
Siding, Windows
Insulation, Windows
Design Review
01532
Mario Richard
Minor
Windows
01542
Laurie Gilbert
Minor
01572
Markus Wittmann
Minor
01638
Nathaniel Chesnut
Minor
Doors, Millwork, Siding,
Windows
Doors, Millwork,
Windows
Foundation
01677
01740
Christine Santa Marina
Lucristia Woods
Minor
Minor
Doors, Millwork
Siding
01793
Stanley Sinegal
Minor
01852
Gloria Prevost-Hicks
Minor
00009
Adrian Allen
Severe
Reconstruction
00029
Michael Homan
Severe
Design Review
00114
Percy Gray
Severe
Non-Contributing
(SHPO),
Terminated
00169
Marcos Picolo
Severe
00444
Richard Powell, Sr
Severe
00474
Lakeba Griffith
Severe
Non-Contributing
(SHPO),
Terminated
Design Review
00613
Fabian Smith
Severe
Terminated
00699
Kedrick Foster
Severe
AG, All
00810
Stephen Peychaud
Severe
Non-Contributing
(NPS), Terminated
Reconstruction
Doors, Foundation,
Misc., Porch, Windows
Additions, Demo,
Flooring, Foundation,
Framing, Millwork, Walls,
Windows
Additions, Demo
00962
Wayne Washington
Severe
Demolished,
Terminated
IPP, All
Demo, Flooring,
Foundation, Framing,
Millwork, Siding, Walls,
Windows
Demo
01202
Cheryl Austin
Severe
Non-Contributing
(NPS), Terminated
IPP, All
01381
Lou Jean Sartin
Severe
01529
JoAnn Najolia
Severe
Non-Contributing
(NPS), Terminated
Reconstruction
01739
Robert Bridger
Severe
01901
Mark Stephens
Severe
90
Demo by Neglect
AG, Partial
Doors
Doors, Windows
AG, All
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
Non-Contributing
(NPS), Terminated
Reconstruction
Roof, Siding
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
Mitigation Completed
00326
Henry Holzenthal
Insignificant
00762
Ulysses Bentley
Minor
Design Review,
Mitigation
Design Review
Foundation, Porch
01331
Dionnelyn Sampson
Minor
Mitigation
Doors, Porch, Windows
01718
Ella Julian
Minor
Addition, Doors, Porch
01735
James Hagerty
Minor
01798
Cheryl Young
Minor
Design Review,
Mitigation
Mitigation,
Terminated
Design Review
00906
Deborah Walther
Severe
Design Review
IPP, Partial
Additions, Windows
Porch
Framing, Siding,
Windows
Additions, Doors,
Foundation, Roof,
Windows
Sub-grant Preservation Agreement Policies and Procedures
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:
Monitoring includes steps that meet the federal requirements28 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.
28
HPF Grants Manual, Chapter 6, 6-31, M(3)(e)
91
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. 29
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
E. 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.30
F. The LASHPO will conduct a Preservation Agreement Compliance Review (exterior and interior)31
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.
G. 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.
H. 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.
29
HPF Grants Manual, Chapter 6, 6-28, M(2)(a)(1)
30
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.
31 See Attachment A, HBBRGP Preservation Agreement Compliance Form and Instructions
92
I.
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.32
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: 33
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.34
2. If any alteration is not to the Secretary of the Interior’s Standards for Rehabilitation.
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?35
b) Did the sub-grantee maintain his or her property as required by the preservation agreement?36
32 See also the Secretary of the Interior’s Standards for Rehabilitation for guidance on maintenance and Attachment A: Preservation
Agreement Compliance Form Instructions.
33
email from Hampton Tucker on 1/3/2007 that indicates only those items that were grant funded fall under the Preservation Agreement
requirements.
34
Programmatic Agreement, Louisiana Treatment Protocols, “…to prevent inappropriate, incompatible, and/or irreversible changes…”
35: Louisiana Preservation Agreement, #2
36: Programmatic Agreement, Treatment Protocols and Attachment B: Louisiana Preservation Agreement, #1
93
c) Did the sub-grantee make inappropriate, incompatible and/or irreversible changes to the
property?37
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? 38
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) days39 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
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. 40
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.
37: Programmatic Agreement, Treatment Protocols
38 Programmatic Agreement, Louisiana Treatment Protocols and Attachment B: Louisiana Preservation Agreement, #1
39
Attachment B: Preservation Agreement, section 7.
40
Attachment G: HPF Grants Manual, Section 6, 6-33, 3.c
94
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.41
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.42
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.
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
repairs. Rather than provide one overall status code, we provide details for each inspection or
monitoring scenario as it arises.):
Table 37
PA Compliance Status
Not Applicable
No Changes
Approved
Approved with Conditions
Not Approved
Violation
Violation: Maintenance
Count of
Grant#
64
352
96
30
6
14
29
591
41 See also Operating Procedures for Repayment, Collections, Section 3. Collections, Item A.
42
Attachment G: HPF Grants Manual, Section M, p 6-32, #B
95
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
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).
No Changes:
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
96
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
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
97


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
Appendix xxx has the complete list and summary of current violations.
PARTNERSHIPS
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.
98
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.
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 17th 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 reducing loss to properties that had significant roof damage.
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.
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
99
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.
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,
100
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.
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.
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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 hardworking volunteers. By focusing our program in seven
target neighborhoods , RTNO meets 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.):
Table 38
NPS
Grant#
22-06-HR21572
22-06-HR21572
22-06-HR21572
HBRGP
Grant#
00366
01238
00574
Sub-Grantee
Hilda Hopkins
Robert A.
Smith,Sr.
Bari Landry
NR Historic
District
Esplanade
Ridge
Property
Address
1226-1228
Treme Street
Holy Cross
South
Lakeview
5222-5224
Dauphine
Street
811 Louque
Place
Building Name
Final Grant
$44,830.00
Partnership
NTHA/
RTNO
$29,160.00
$3,750.00
NTHA/
RTNO
NTHA
22-06-HR21572
00041
Veronica
Stevenson
Esplanade
Ridge
1803 Ursulines
Avenue
$27,000.00
NTHA
22-07-HR21671
01152
Cynthia A. Rice
Holy Cross
725 Lizardi
Street
$45,000.00
NTHA
22-06-HR21572
01616
Emelda M.
Skidmore
Holy Cross
939 Deslonde
Street
$36,600.00
NTHA
22-07-HR21671
01624
L'Tanya P. Jackson
Holy Cross
933 Deslonde
Street
$25,000.00
NTHA
102
George "Kid
Sheik" Cola(r)
Home
22-06-HR21572
01446
Preservation
Resource Center
Holy Cross
711 Caffin Ave
$45,000.00
OC
22-06-HR21572
01450
Preservation
Resource Center
Holy Cross
4804 Dauphine
Street
$45,000.00
OC
22-07-HR21671
01458
Preservation
Resource Center
Holy Cross
5124 Dauphine
Street
$45,000.00
OC
22-06-HR21572
01461
Preservation
Resource Center
Holy Cross
5442 Dauphine
Street
$45,000.00
OC
22-07-HR21671
01462
Preservation
Resource Center
Holy Cross
717 Deslonde
Street
$45,000.00
OC
22-07-HR21671
01481
Preservation
Resource Center
Holy Cross
429-31 St.
Maurice
Avenue
$45,000.00
OC
22-06-HR21572
01751
Preservation
Resource Center
Holy Cross
5118 Burgundy
Street
$45,000.00
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
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
103
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 4th 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 AmeriCorps 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.
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:
104
 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) sub-grant 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.
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
105
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.
ADMINISTRATIVE OPERATIONS
Staffing and Job Descriptions
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.
106
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.
Table 39/ Chart
LASHPO
Deputy SHPO
Executive
Director,
Archaeology
Executive
Director, Historic
Preservation
HBRGP
Accounting
Manager
Project Officer
HBRGP Program
Director
Accounting
Assistant
Administrative
Assistant
Project
Supervisor
Project Officer
Project Officer
Project Officer
Section 106
Project Officer
Section 106
Project Officer
We anticipate that it may not be possible to recruit an adequate coterie of architectural historians
and/or historic architects. A number of federal agencies currently have a large presence in the
Gulf Coast Region. While we will attempt to recruit preservation professionals, we recognize
that we may have to focus upon recruiting and training administrative management professionals
to move these programs forward. Regardless of whether the incumbents are preservation
professionals or administrative managers, they will be overseen by the existing professional
SHPO staff.
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
107
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.
Important to note that 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 applications once received and hiring all the staff once the funding was
determined. aone in New Orleans
Database and File Management
NPS Quarterly Reports and Site Visits
Office Space
Vehicles / Mobile Office
Budget
ACTION PLAN NARRATIVE HURRICANE RECOVERY GRANT
HISTORIC STRUCTURES GRANTS PROGRAM
Administrative Budget
FY2006
Division of Historic Preservation Staff–Paid
Overtime (15%), 3 staff persons
$1,550.00
Division of Historic Preservation Staff–Paid
Overtime (15%), 5 staff persons
FY2007
Fringe benefit (26%)
108
FY2009
TOTAL
$1,550.00
$30,232.00
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
FY2008
$30,232.00
$23,535.00
$23,535.00
$51,481.00
$51,481.00
$18,088.00
$18,088.00
Administrative Manager 4 Restricted
Appointment 1 month at mid-point salary
range
Fringe benefits (7.65%)
$3,687.00
$3,687.00
$282.00
$282.00
Accountant Manager 1 Job Appointment, Midpoint salary range
Fringe benefits (26%)
Contract Grants Review 2 Job Appointment,
Mid-point salary range
Fringe benefits (26%)
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
Call Center Line, Computers, Furniture
Travel
$47,341.00
$49,234.00
$12,308.00
$108,883.00
$12,309.00
$12,801.00
$3,200.00
$28,310.00
$33,738.00
$35,088.00
$8,772.00
$77,598.00
$8,772.00
$9,123.00
$2,280.00
$20,175.00
$10,000.00
$10,000.00
$5,000.00
$5,000.00
$4,000.00
$4,000.00
$6,000.00
$500.00
Operating Supplies & Telephone
Photography
Postage, Printing & Copying
Automotive Purchase (2)
$6,000.00
$500.00
$500.00
$10,000.00
$10,000.00
$2,000.00
$3,000.00
$7,000.00
$10,000.00
Modular Furniture
$7,000.00
$6,000.00
$10,000.00
$10,000.00
$20,000.00
$27,000.00
$14,000.00
FY2006
Master Grants Maker – Planner, Administrative
Manager 5, Midpoint salary range
Fringe benefits (26%)
Restoration Project OfficersPredevelopment/Technical Assistance - (4)
Architectural Historian 2 or (4) Administrative
Managers 3, (see narrative) ($38,623 each)
Fringe benefits (26%)
Travel
TOTAL
Grants & Discretionary Funding
Historic building repair grants, both individual
109
$2,000.00
$10,000.00
$19,019.00
$0.00
FY2006
$22,000.00
$6,000.00
$330,461.00
$10,000.00
$14,000.00
Contingency
Planning, Technical Assistance,
Predevelopment Budget
$5,000.00
$40,000.00
Public Awareness
CODOFIL Outreach Assistance
$22,000.00
$5,000.00
$2,000.00
Furniture and Equipment Purchase
TOTAL
$2,000.00
$40,000.00
Automotive Maintenance
Advertising
$1,500.00
$155,281.00
$11,679.00
$11,679.00
$55,239.00
$560,000.00
FY2009
TOTAL
FY2007
FY2008
$56,648.00
$58,914.00
$115,562.00
$14,728.00
$15,317.00
$30,045.00
$154,492.00
$160,671.00
$315,163.00
$40,168.00
$41,775.00
$81,943.00
$12,000.00
$12,000.00
$278,036.00
$288,677.00
FY2007
FY2008
$24,000.00
$0.00
FY2009
$566,713.00
TOTAL
$9,373,287.00
and group
Contingency Funds (as described)
$350,000.00
Director’s Discretionary Fund
$150,000.00
Archaeological Stabilization Program
$200,000.00
TOTAL
$10,073,287.00
TOTAL HISTORIC STRUCTURES PROGRAM
$19,019.00
$608,497.00
$443,958.00
$55,239.00
$11,200,000.00
Section 106
20% Overtime Pay for Sec.106 and Related HP
Positions
Existing Architectural Historian Manager (50%
for ¾ state FY)
FY2006
$1,296.00
FY2008
$25,449.00
FY2009
TOTAL
$51,215.00
$51,795.00
$51,795.00
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
FY2007
$24,470.00
$13,467.00
$13,467.00
$0.00
$20,086.00
$20,889.00
$77,252.00
$80,342.00
$11,725.00
$11,725.00
$4,611.00
$4,800.00
$40,975.00
$157,594.00
$2,850.00
$26,300.00
Existing Section 106 Archaeology Staff
$44,868.00
Existing Section 106 Archaeology Staff (9 mo.)
Fringe @ 26%
$11,666.00
$9,411.00
$44,868.00
$11,666.00
Archaeologist 1 (2 positions restricted)
$6,811.00
Archeologist 2 (1 position restricted)
$3,900.00
$6,811.00
$3,900.00
2 Archaeologist 2 positions job app
$67,600.00
$70,304.00
2 Archaeologist 2 positions Fringe @
26%
2 Archaeologist 1 positions job appt
$17,576.00
$18,279.00
$59,030.00
$61,391.00
2 Archaeologist 1 positions Fringe @
$15,348.00
$15,702.00
$137,904.00
$35,855.00
$120,421.00
26%
Reallocation Archaeologist Manager
$532.00
$31,050.00
$532.00
Archaeologist 1 (2 positions restricted) FICA
$521.00
$521.00
Archeologist 2 (1 position restricted) FICA
$298.00
Accountant 3 (Archaeology)
Accountant 3 Fringe @ 26%
Travel (Historic Preservation)
$298.00
$41,330.00
$42,983.00
$11,176.00
$95,489.00
$10,746.00
$11,176.00
$2,906.00
$24,828.00
$7,000.00
$7,000.00
$14,000.00
$7,000.00
$18,000.00
Travel (Archaeology)
$2,000.00
$9,000.00
Computers (PCs) (Archaeology)
$4,500.00
$9,000.00
$3,000.00
$13,500.00
Computers (Historic Preservation)
Modular Furniture (Archaeology)
$15,000.00
$15,000.00
110
$3,000.00
Modular Furniture (Historic Preservation)
$20,000.00
2 Vehicles Lease (Archaeology)
$10,800.00
$7,800.00
$18,600.00
Supplies (Historic Preservation)
$9,000.00
$9,000.00
$18,000.00
$22,500.00
$22,500.00
$45,000.00
Supplies (Archaeology)
GIS Server & Associated Hardware
(Archaeology)
GIS Software (Archaeology)
$60,000.00
$60,000.00
$40,000.00
$40,000.00
GIS Technical Support Training (Archaeology)
$20,000.00
GIS Maintenance Support (Archaeology)
$10,000.00
Improved Online Access to 106 Information
(Archaeology)
Standing Structures Survey (Historic
Preservation)
Copy Machine Rental (Archaeology)
$30,000.00
111
$20,000.00
$10,000.00
$20,000.00
$30,000.00
$60,000.00
$60,000.00
$800.00
$9,600.00
Accountability Initiative (Archaeology)
TOTAL
$20,000.00
$123,508.00
$706,470.00
$9,600.00
$20,000.00
$20,000.00
$20,000.00
$455,940.00
$14,082.00
$1,300,000.00
TIMELINE
ADD ALL DATES TO THIS TIMELINE – WORKSHOPS, PUBLIC MEETINGS, OFFICE CONSULTATIONS
112
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
LASHPO Action Plan due to NPS per Grant Agreement Special Condition
#20
September 28, 2006
NPS approves LASHPO Action Plan
October 15, 2006
HBRGP Grant Program Guidelines and Application available
December 1, 2006
NPS Grant Agreement increase of $209,567 for LASHPO
December 15, 2006
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
January 18-26, 2007
HBRGP grant review panels for 1,243 eligible applications
January 29, 2007
HBRGP funding determinations made on 289 grants
February 5, 2007
NPS hurricane recovery staff begins
February 7, 2007
through April 27, 2007
HBRGP grant agreements executed
February 9, 2007
LA, MS, AL SHPO Treatment Protocols due for Programmatic Agreement
March 15, 2007
Programmatic Agreement executed
March 31, 2007
NPS Interim Progress Report submitted
May 25, 2007
Public Law 110-28: Emergency Supplemental Appropriation, National
Park Service, Historic Preservation Fund, additional $10 million
May 31, 2007
NPS Grant Agreement for additional $10 million (22-07-HR-21672)
June 1, 2007
Division of Historic Preservation, Executive Director Phil Boggan begins
(double encumbered through August 17, 2007)
June 9, 2007 through
September 8, 2007
HBRGP Program Director Dabne Whitemore on part-time maternity leave
June 17-19, 2007
NPS makes first site visit to Louisiana
June 30, 2007
NPS Interim Progress Report submitted
July 16, 2007
HBRGP policies for additional allocation of $10 million due to NPS
113
August 17, 2007
Division of Historic Preservation, Executive Director Jonathan Fricker
retires
September 17, 2007
through December 7,
2007
HBRGP grant agreements executed for 241 grantees
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
NPS Interim Progress Report submitted
March 31, 2008
NPS Interim Progress Report submitted
May 5-6, 2008
NPS Site Visit
June 11, 2008
Conference Call between MS, AL, LA hurricane recovery grant staff
June 30, 2008
NPS Interim Progress Report submitted
July 1, 2008
Deputy Assistant Secretary/Assistant SHPO Phil Boggan begins;
Executive Director Nicole Hobson-Morris begins
July 10-13, 2008
National Alliance of Preservation Commission National Conference, New
Orleans, Louisiana
July 22, 2008
New Assistant Secretary/SHPO Scott Hutcheson appointed
July 22, 2008
New HBRGP Program Director Tracy Nelson begins
September 9, 2008
Hurricane Gustav hits Louisiana
September 15, 2008
HBRGP $12.7 million allocation for sub-grant projects ends (extensions
until October 1, 2008 due to Hurricane Gustav)
September 30, 2008
NPS Interim Progress Report submitted
October 2008 November 2009
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
National Conference of State Historic Preservation Offices conference call
on disaster recovery
March 31, 2009
NPS Interim Progress Report submitted
June 30, 2009
HBRGP $10 million allocation for sub-grant projects ends
June 30, 2009
NPS Interim Progress Report submitted
June 30, 2009
NPS-LASHPO conference call on sub-grant project issues / Section 106
and Adverse Effect
114
July 13, 2009
NPS sends LASHPO follow-up letter on Section 106
September 18, 2009
LASHPO sends NPS response letter
September 30, 2009
NPS Interim Progress Report submitted
October 13, 2009
NPS sends LASHPO follow-up letter
October 26, 2009
LASHPO Section 106 review letter on 30 properties
November 6, 2009
LASHPO Section 106 review letter on 9 properties (Adverse Effect)
November 23, 2009
NPS site visit and meeting with LASHPO
December 4, 2009
LASHPO Section 106 review letter on 3 properties with mitigation
December 31, 2009
NPS Interim Progress Report submitted
January 25, 2010
LASHPO Section 106 Design Review on 12 properties (1 adverse effect)
January 25, 2010
LASHPO Section 106 review letter on 2 properties with mitigation
February 5, 2010
NPS site visit
February 9, 2010
LASHPO Section 106 Design Review on 1 property
March 1, 2010
Assistant Secretary/SHPO Scott Hutcheson begins leave of absence
(resigns May 1, 2010)
March 2, 2010
LASHPO Section 106 review letter on 1 property
March 31, 2010
LASHPO Section 106 Design Review on 1 property
March 31, 2010
NPS Interim Progress Report submitted
April 19, 2010
LASHPO Section 106 review letter on 1 property (adverse effect)
April 28, 2010
LASHPO Section 106 review letter on 3 properties (adverse effect)
April 29, 2010
NPS site visit
May 13, 2010
LASHPO Section 106 review letter on 1 property (adverse effect)
May 17, 2010
MS Hurricane Recovery grants meeting
June 30, 2010
NPS Interim Progress Report submitted
September 1, 2010
NPS Site Visit
September 1, 2010
LASHPO Section 106 review letter, Batch 1 and Batch 2
September 30, 2010
NPS Interim Progress Report submitted
November 22, 2010
NPS Site Visit
December 1, 2010
Assistant Secretary/SHPO Pam Breaux appointed
January 11, 2011
LASHPO Section 106 review letter, Batch 3
115
January 14, 2011
HBRGP Program Director Dabne Whitemore begins
January 26, 2011
LASHPO Section 106 review letter, Batch 4
March 15, 2011
NPS/Cultural Resources meeting with LASHPO
March 31, 2011
NPS Interim Progress Report submitted
April 6, 2011
LASHPO Section 106 review letter, Batch 5
June 30, 2011
NPS Interim Progress Report submitted
August 26, 2011
LASHPO Section 106 review letter, Batch 6
August 30, 2011
LASHPO Section 106 review letter, Batch 7
September 30, 2011
NPS Interim Progress Report submitted
October 25, 2011
LASHPO Section 106 review letter, Batch 8
November 30, 2011
LASHPO Section 106 review letter, Batch 9
December 31, 2011
NPS Interim Progress Report submitted
January 4, 2012
LASHPO Section 106 review letter on 23 properties
February 20, 2012
NPS Site Visit
March 31, 2012
NPS Interim Progress Report submitted
May 29, 2012
LASHPO Section 106 review letter, Batch 10
May 31, 2012
NPS Grant on $12.7 million allocation ends (22-06-HR-21572)
June 30, 2012
NPS Interim Progress Report submitted
August 30, 2012
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.
May 31, 2013
NPS Grant on $10 million allocation ends (22-07-HR-21671)
August 30, 2013
NPS Final Report due on $10 million allocation (22-07-HR-21671)
116
PART B
ARCHAEOLOGY PROGRAM
117
Archaeology
The archaeological program funded a two-year effort through the University of New Orleans to develop
a revised and more robust Geographic Information System (GIS) – based probability model for
archaeological resources within the greater New Orleans area. Immediately after Hurricane Katrina, an
initial model of site location probability was developed and was used to guide Section 106 reviews and
assessments of archaeological site historic property potential throughout the early years of the
response. This initial model was not based on a rigorous evaluation of available data but general
expectations about site location probability reflecting professional archaeological experience. With the
HBRGP program, there was the opportunity to develop a more robust model that could be used to
assess not only overall archaeological potential but more specific evaluations of which type of
archaeological deposits might be anticipated in a given location.
Over 200 historic maps were digitized for this project. Data was organized into five temporal periods
reflecting broad patterns in New Orleans development, including French Colonial (1718-1769), Spanish
Colonial (1769-1803), Antebellum (1803-1860), Civil War and Aftermath (1860-1890), and Industrial and
Modern (1890-1940). In addition, specific information relevant to a series of 17 Research Themes was
digitized from the various maps; these themes include Cemeteries, Historic Native American
Settlements, Plantations, Military, Recreation, and Transportation Corridors, among others. The result is
a large series of GIS coverages that can provide information on the archaeological potential for many
parts of the modern city. In addition, a series of coverages that assess the archaeological potential for
deposits of each temporal period across the project area were developed.
The project was very successful in tracing the urban development of the region through historic maps in
a GIS platform and highlighting areas of archaeological sensitivity. The geo referenced maps are stacked
in the geodatabase and can be digitally peeled back to reveal the potential archaeological deposits lying
in any particular location within the urban landscape. Users can employ the sensitivity maps, together
with the underlying historic maps and databases to assess the likelihood of archaeological deposits, their
age, and nature of the deposits for any given proposed project area in the City. This provides a much
greater ability to evaluate projects and assess their potential impact upon the City’s archaeological
history
See “The Greater New Orleans Archaeology Program End of Year Report 2009”
118
I.
Lessons Learned
A.
GIS & Survey
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.
B.
Building Assessments and Renovation Plans
C.
Volunteer Response and Debris Removal
(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)
119
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.
120
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
High Level of Integrity Total:
Medium
NAE
Medium
Adverse Effect
CountOfGrant#
352
22
374
84
21
Medium Level of Integrity Total:
Low
NAE
Low
Adverse Effect
Low Level of Integrity Total:
106
54
36
90
Of Integrity
94%
6%
79%
21%
60%
40%
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.
D.
Grant Program Changes
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:
121
a) Louisiana’s Action Plan did not include provisions for monitoring the entire sub-grant
project activity, only the use of grant funds ranging between $5,000 and $45,000.
b) The grant application did not ask applicants to provide entire renovation details, only
information on the use of grant funds.
c) The entire renovation project at that point in time was unknown as many property owners
were facing problems with CDBG/HUD (The Road Home Program), FEMA, or
insurance programs. Many lending companies forced property owners to pay off
mortgages with insurance proceeds rather than repairing properties. Applicants were
unable to provide entire renovation and financing details when applying for funding.
d) Louisiana’s priority was to award grant funds to those with the greatest financial need,
specifically those without any funds available for the renovation project, the application
would only include information on the grant request, not the entire renovation.
e) The number of staff required to monitor repairs on sub-grant projects may be too low if
an entire building assessment would be required and full scopes of work drafted. The
time allotted to monitor and oversee the entire renovation project to the Standards would
be much greater, and it would limit the number of sub-grant projects assigned to each
staff person. The current staff projection as detailed in the Action Plan accounted for
three (3) 36 CFR 61 qualified Project Officers overseeing approximately 70 sub-grantees
per person. This number would increase, if staff monitored the entire renovation project.
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
122
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
123
PART C
NPS GRANT COMPLIANCE
REQUIREMENTS
ASSISTANCE/ SUPPORT FOR
FUTURE UNDERTAKINGS
124
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
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
125
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
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 9th Ward, property owners were not allowed to return
to their homes for as long as 8 months.
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 noncompliant 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 sub-grant project would
have proved counter-productive.
A.
Contractors / Craftsmen
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?
126
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.
127
PART D
HURRICANE RECOVERY
GRANT PROGRAM CASE STUDIES
128
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, 2nd 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, 18th 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
129
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
130
PART E
FEDERAL AND STATE ASSISTANCERECOVERY AND RESPONSE
PROGRAMS
131
Other Federal and State Assistance Recovery and Response Programs
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.
A.
Louisiana Road Home Program – Louisiana Recovery Authority (LRA) and Louisiana Office of
Community Development, Disaster Recovery Unit
B.
FEMA
C.
City of New Orleans Demolition
D.
Flood Response and Elevation
E.
Hazard Mitigation
132
PART F
HURRICANE RECOVERY
REQUIRED DATA DOCUMENTATION
FOR EACH SUB-GRANT PROJECT
133
FINAL PROJECT REPORT
NPS Hurricane Grant Recovery Program
NATIONAL PARK SERVICE, DEPARTMENT OF INTERIOR
HISTORIC PRESERVATION GRANTS DIVISION
Required Data and Documentation for Each Sub-grant of the Program
1. Property Name, Property Owner, Address (include City & County/Parish), and
Congressional District
2. Project Type:
Residential
Commercial
Public Resource
Other:
3. Grant Amount:
4. Total Budget (if known):
5. Project Start and End Dates:
6. Project Description:
7. National Register Status:
8. Section 106 Status:
9. Easement or Preservation Agreement: Term Length of Protection:
10. Data Entered by:
Please attach at least one before and one after image of the property more images can
provide
134
APPENDIX 1
HURRICANE RECOVERY PRINTED &
PUBLISHED MATERIALS
Determine if you want to include the actual copy or just a list that the copy exists:
Date of Publication
February 27, 2006
February 28, 2006
February 28, 2006
March 2007
March 2007
March 5, 2007
March 5, 2007
March 11, 2007
April 2007
May 2007
May 14, 2007
June 4, 2007
May-June 2007
July-August 2007
August 15, 2007
September 11, 2007
October 4, 2007
October 9, 2007
October 18-20, 2007
135
Title
Lt. Governor Press Conference in Holy Cross/Lower 9th Ward on Grant
Awards
The Times-Picayune Article
The Advocate (Baton Rouge, Louisiana) Article
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
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 9th Ward
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
New Orleans City Business Article
Traditional Building Exhibition and Conference, Ernest N. Morial
Convention Center, New Orleans, www.traditionalbuildingshow.com,
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
December 2008-January
2009
136
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:
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
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
November 2009
December 2009 /
137
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
12th 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-20th 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
Preservation Resource Center Preservation in Print Magazine Article:
Researching Historic Buildings
Preservation Resource Center Preservation in Print Magazine Article:
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
138
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
APPENDIX 2
BACKGROUND DOCUMENTS
List of Attached Background Documents:
139

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
APPENDIX 3
SAMPLE PROGRAM DOCUMENTS
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].
140
APPENDIX 3
All Group Applicants
Applicant
Group
Number of
Applications
Submitted
Number
of Grants
Awarded
% of
Grants
Awarded
Value of
Grants
Preservation Resource Center/Operation Comeback &
Rebuilding Together
Group H
23
9
39%
$387,830.0
0
UJAMAA Community Development Corp
Group I
6
5
83%
$195,000.00
Joseph Clark
4
3
75%
$135,000.00
Landreth Loft Company LLC
3
3
100%
$135,000.00
Julie Simpson
3
3
100%
$130,400.00
Degas House, LLC/Duvigneaud House, LLC
3
3
100%
$114,000.00
Alberta Graf
3
3
100%
$104,338.00
Oak Alley Foundation
3
3
100%
$74,380.00
New Orleans African American Museum
3
2
67%
$52,700.00
Julia's Guest House, LLC
3
2
67%
$29,340.00
Calvin Alexander, Jr
2
2
100%
$88,279.00
Shannon Johnson
2
2
100%
$75,700.00
Lillie Davis
2
2
100%
$69,000.00
Mark Holian
2
2
100%
$55,000.00
Good Sisters LLC
2
2
100%
$46,188.00
7
1
14%
$20,022.00
LeRoy and Frankie Gardner
5
1
20%
$45,000.00
Joseph Fertitta
4
1
25%
$45,000.00
WC & Ruthie Marie LLC
4
1
25%
$5,800.00
Bernice Crump
3
1
33%
$45,000.00
Fannie Higgins
3
1
33%
$45,000.00
Julie Skjolaas
141
Group D
Pat Shelby
3
1
33%
$45,000.00
Lathan Madison
3
1
33%
$14,000.00
Ruth Bodenheimer
2
1
50%
$45,000.00
Kathleen Cresson
2
1
50%
$45,000.00
Georgiana Gray
2
1
50%
$45,000.00
The King's Daughters and Sons of Louisiana/LA. Branch
of the International Order of Kings
2
1
50%
$45,000.00
William Maloney
2
1
50%
$45,000.00
Anthony Marinaro
2
1
50%
$45,000.00
JoAnn Najolia
2
1
50%
$45,000.00
Hollie Vest
2
1
50%
$45,000.00
Blanche Lovelly
2
1
50%
$38,000.00
Carmencita Baker
2
1
50%
$37,618.00
Kimbley Sceau
2
1
50%
$35,000.00
Daniel Ryan
2
1
50%
$34,854.00
Karen Jackson
2
1
50%
$26,300.00
Thelma Chopin
2
1
50%
$23,660.00
Christopher Lund
2
1
50%
$22,700.00
Fatma Aydin
2
1
50%
$20,000.00
Wanda Fernandez
2
1
50%
$18,000.00
Willie Anderson
2
1
50%
132
72
$4,000.00
$2,577,109.
00
SUB-TOTAL:
Susan Smith as agent for multiple property owners
Group E
66
0
0%
$0.00
James & Richard Realty Holdings, LLC/J&R Realty
Holdings/Michelle Cahn Wolfson Trust
Group C
18
0
0%
$0.00
11
0
0%
$0.00
William Alden / Crescent City Property
Redevelopment, LLC/Side by Side Redevelopment, LLC
Donald Moore, Jr.
Group B
11
0
0%
$0.00
Shahram "Benny" Naghi c/o Belinda Little-Wood, 10th
Capital Management, LLC
Group F
11
0
0%
$0.00
6
0
0%
$0.00
John Orgon and 930 Tchoupitoulas Ventures, LLC;
Engine 22, LLC; Turquoise Ventures
142
Venti Investments LLC
DMR Builders, LLC
0
0%
$0.00
4
0
0%
$0.00
Doby Properties, LLC
4
0
0%
$0.00
Esther Clesi
4
0
0%
$0.00
Gwendolyn Esteen
4
0
0%
$0.00
Shakir Hameed
4
0
0%
$0.00
Phyllis Smith
4
0
0%
$0.00
George Akehurst
3
0
0%
$0.00
Nham Dao
3
0
0%
$0.00
Ernest Riley
3
0
0%
$0.00
Shaun Scott
3
0
0%
$0.00
Deborah Small
3
0
0%
$0.00
Acadian Heritage & Culture Foundation, Inc.
2
0
0%
$0.00
Jacqueline Adams
2
0
0%
$0.00
Sammuel Alexander Sr.
2
0
0%
$0.00
Carmen Baham
2
0
0%
$0.00
Edward Breaux, Jr.
2
0
0%
$0.00
George & Nina Buck
2
0
0%
$0.00
Carol Carrone
2
0
0%
$0.00
Jimmie Chambers
2
0
0%
$0.00
Edgar Chase, IV
2
0
0%
$0.00
Clarkanal LLC
2
0
0%
$0.00
Steve Collara
2
0
0%
$0.00
Johnny Darby
2
0
0%
$0.00
Josephine Davis
2
0
0%
$0.00
Lorna DeLay
2
0
0%
$0.00
David Dotson
2
0
0%
$0.00
Joseph Dousey
2
0
0%
$0.00
Bert Dupre
2
0
0%
$0.00
Michael Duronslet
2
0
0%
$0.00
Cabrina England
2
0
0%
$0.00
Willie Franklin Sr.
2
0
0%
$0.00
Marie Galatas
2
0
0%
$0.00
Gretchen Gattuso
2
0
0%
$0.00
Fernanda Guillen
2
0
0%
$0.00
Robyn Halvorsen
2
0
0%
$0.00
Aucion Hatcher
2
0
0%
$0.00
Dewawn Hatcher
2
0
0%
$0.00
Jeffrey Hunter
2
0
0%
$0.00
Cassandra Hyer, CD Hyer Property Management
2
0
0%
$0.00
Glynn Hyer
2
0
0%
$0.00
143
Group G
5
Katz-Derbes Properties, LLC
2
0
0%
$0.00
Troy Lawrence Sr.
2
0
0%
$0.00
Linda LeBlanc
2
0
0%
$0.00
Jeanne Lee
2
0
0%
$0.00
Michael Lewis
2
0
0%
$0.00
Liberty Village, INC.
2
0
0%
$0.00
Edward Lirette
2
0
0%
$0.00
Keith Mason
2
0
0%
$0.00
Beverly McKenna
2
0
0%
$0.00
John Messina, Jr.
2
0
0%
$0.00
Kenneth Mitchell
2
0
0%
$0.00
Lester Nicholas
2
0
0%
$0.00
Belva Pichon / Pocte Corporation
2
0
0%
$0.00
Rosita Rodriguez
2
0
0%
$0.00
Douglas Roome
2
0
0%
$0.00
Lara Schultz
2
0
0%
$0.00
Carolyn Seaton
2
0
0%
$0.00
Carl and Rita Severan
2
0
0%
$0.00
Artis Solomon
2
0
0%
$0.00
Augustus Taylor
2
0
0%
$0.00
James Terry
2
0
0%
$0.00
Tiffany Treadaway
2
0
0%
$0.00
Christine and Anthony Williams
2
0
0%
$0.00
Henry and Orietta Williams
2
0
0%
$0.00
Roberta Williams
2
0
0%
$0.00
2
277
0
0
0%
SUB-TOTAL:
TOTAL:
409
72
$0.00
$0.00
$2,577,109.
00
Andre Wilson
Scope of Work Assessment – how many had high integrity and had problems with the grant
Building
Integrity
High
High
High
144
HBRGP
Of
Determination CountOfGrant# Integrity Overall
NAE
352
94%
62%
AE Minor
10
3%
2%
AE
Insignificant
12
3%
2%
22
6%
4%
374
66%
Medium
Medium
Medium
Medium
Low
Low
Low
Low
TOTAL
NAE
AE
i
NAE
AE Severe
AE Minor
AE
Insignificant
NAE
AE Severe
AE Minor
AE
Insignificant
AE Overall
84
1
11
79%
1%
10%
15%
0%
2%
10
21
106
9%
20%
2%
4%
19%
54
15
10
60%
17%
11%
9%
3%
2%
11
36
90
12%
40%
2%
6%
16%
570
86%
14%
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
is $1,044,216.37 on 91 sub-grant projects. The following details the overlap in exposure:
 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.

145
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
is $1,072,046.13 on 84 sub-grant projects. The following details the overlap in exposure:
 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
146