Massachusetts Historical Commission weighs in favor of saving Paul Rudolph

The Boston Government Service Center’s Hurley Building, as seen from the Cambridge Street corner of the complex. The Massachusetts Historical Commission (MHC) has responded to the state’s proposal to sell off part of the complex to private developer…

The Boston Government Service Center’s Hurley Building, as seen from the Cambridge Street corner of the complex. The Massachusetts Historical Commission (MHC) has responded to the state’s proposal to sell off part of the complex to private developers—which would result in part-or-all of the Hurley Building being demolished.

The Commission’s verdict: the state’s current approach will have an “adverse affect” (so the planners must go back to the drawing board to come up with non-destructive proposals.) Photo by Kelvin Dickinson © The Paul Rudolph Heritage Foundation

DEVELOPMENTS TO DATE:

The Boston Government Service Center— the unique urban complex designed by Paul Rudolph, and the home of many vital services for the citizens of Boston—is threatened by the state’s plan to sell-off a significant part of it (the Hurley Building) to a private developer. If approved, much-or-all of the Hurley Building will be lost (as well as a part of the complex’s public plaza; and murals by internationally-known artist Constantino Nivola.)

Speaking out—against this potential loss of significant architecture, public space, and important artwork—are the Paul Rudolph Heritage Foundation, OverUnder, DOCOMOMO-US, DOCOMOMO-New England, the family and foundation of artist Constantino Nivola, and the Boston Preservation Alliance. Each have issued powerful letters and statements in support of preservation.

AND NOW: THE MASSACHUSETTS HISTORICAL COMMISSION — GIVES ITS VERDICT

The report, commissioned by the state’s Division of Capital Asset Management and Maintenance (DCAMM). All of the report’s four proposals would entail partial-or-full destruction of the Boston Government Service Center’s Hurley Building. Those speaki…

The report, commissioned by the state’s Division of Capital Asset Management and Maintenance (DCAMM). All of the report’s four proposals would entail partial-or-full destruction of the Boston Government Service Center’s Hurley Building. Those speaking out for the preservation of the building (and the integrity of the complex-as-a-whole) all criticize the report’s assumption that demolition is the necessary path for the best use of of the site. In their letter, the Massachusetts Historical Commission asks that the planners come up with additional options: ones which don’t entail the destruction of the Hurley Building.

Recognizing that “the continuing presence of historic properties in Massachusetts immeasurably enhances the quality of our lives; they help to establish our sense of place and to define the very character of our communities,“ the Massachusetts Historical Commission (MHC) was established by the state legislature in 1963 “to identify, evaluate, and protect important historical and archaeological assets of the Commonwealth.”

The MHC—as long ago as 1991—had already recommended the Boston Government Service Center (including the Hurley Building) as being worthy of being added to the National Register of Historic Places. But, because the state’s development plan would entail the transfer of state-owned property, that proposed action is subject to review by the MHC—and they’ve studied the options outlined in the state’s report.

In a compelling official letter issued this week, the Massachusetts Historical Commission (MHC) assessed the state’s proposals—all of which entail some-or-total demolition of the Hurley building.

THEY DON’T LIKE IT

For all of the scenarios outlined by the state, the MHC gives their determination:

“After review of our files and the information submitted, MHC has determined that the proposed project will have an "adverse effect" . . . . on the Government Service Center through transfer or sale of the historic property without adequate conditions or restrictions regarding preservation, maintenance or use of the property; and the destruction of the Hurley Building.”

“Adverse effect” means that the currently offered development scenarios cannot proceed (or can try to do so only with great difficulty.)

Some of the MHC letter’s other key points included:

“It has been MHC staff opinion for many years that the Boston Government Service Center, including the Lindemann Center, Hurley Building, and site features, meets the criteria of eligibility for listing in the State and National Registers Of Historic Places . . . . at the local, state, and national levels of significance for its extraordinary Modern Architecture and its association with master architect Paul Rudolph.”

“The PNF outlines four site development alternatives for the Hurley Building site. . . . these four alternatives are quite prescriptive for demolition of the Hurley Building in whole or in part and do not explore other possible alternatives that would lead to substantial preservation of this historic building and site.”

“Specifically, the Site Development Alternatives do not consider (a) retention and rehabilitation of the Hurley Building, potentially leveraged by federal and/ or state historic rehabilitation tax credits, or (b) retention and rehabilitation of the Hurley Building with new construction.”

“MHC requests that the RFP include additional options: (1) retention and rehabilitation of the Hurley Building; and (2) retention and rehabilitation of the Hurley Building with new construction, which should precede the options [already offered}. . . . The RFP should promote retention of the Hurley Building.”

“The MHC recognizes the challenges of retrofitting aging buildings to meet current standards and code. Thousands of buildings in the Commonwealth have managed to accommodate modern services while retaining vast amounts of architecturally significant spaces and materials, proving that rehabilitation of historic buildings is a viable option.”

“The MHC is concerned with the long term planning for the Government Service Center Complex. MHC staff participated in the life safety improvement projects at the Government Service Center, which took much time, effort, and state funds to implement. It is disheartening to have completed the project only to have [the state] consider demolition of the architecturally significant features that the life safety improvement project took great care to preserve. . . .”

Here is the MHC’s full letter:

The Commonwealth of Massachusetts

Massachusetts Historical Commission

220 Morrissey Boulevard, Boston, Massachusetts 02125

(617) 727-8470 Fax:  (617) 727-5128

www.sec.state.ma.us/mhc

February 25, 2020

Carol Meeker Deputy General Counsel

Division of Capital Asset Management and Maintenance

One Ashburton Place, 15th Floor Boston, MA 02108

RE:         Long Term Ground Lease of Hurley Building, Government Service Center Complex, 9 Staniford Street, Boston (Downtown), MA; MHC# RC.56843

Dear Ms. Meeker:

The Massachusetts Historical Commission (MHC) is in receipt of a Project Notification Form (PNF) filed by Epsilon Associates on behalf of the Division of Capital Asset Management and Maintenance (DCAMM) for the Long Term Ground Lease Of the Hurley Building, received at this office on January 27, 2020. The staff of the MHC have reviewed the information submitted and have the following comments.

DCAMM proposes to solicit redevelopment proposals and subsequently enter into a long-term ground lease for the redevelopment of a parcel of land at the Boston Government Service Center. The ground lease parcel includes approximately 3.25 acres Of land containing the Charles F. Hurley Building at 19 Staniford Street. As proposed, the entire Hurley Building site will be ground-leased to a redevelopment partner who will lead the planning, permitting, financing, and construction for the site.

It has been MHC staff opinion for many years that the Boston Government Service Center, including the Lindemann Center, Hurley Building, and site features, meets the criteria of eligibility for listing in the State and National Registers Of Historic Places under criteria C at the local, state, and national levels of significance for its extraordinary Modern Architecture and its association with master architect Paul Rudolph.

Highly respected architect Paul Rudolph was appointed the coordinating architect for the entire site, creating a single master plan and produced design guidelines for all three buildings along with public spaces. Rudolph designed the Garage Plaza and landscaping and also oversaw the design of the buildings. When the original architects for the HEW tower were dismissed, Rudolph then redesigned the tower. While the final tower component of the Government Service Center Complex was never realized, many important and significant features of the complex are retained today, including the Hurley Building, Lindemann Center, and associated site features.

The PNF outlines four site development alternatives for the Hurley Building site. The Preservation Report by Bruner/Cott Architects (January 2020), included as an Appendix to the PNF, provides additional information on these four site development alternatives. The report states, "These alternatives are not meant to be an exhaustive study of all of the ways that the site may be redeveloped but instead are meant as radically different scenarios that allow the testing or potential outcomes for a broad range of approaches." However, these four alternatives are quite prescriptive for demolition of the Hurley Building in whole or in part and do not explore other possible alternatives that would lead to substantial preservation of this historic building and site.

Specifically, the Site Development Alternatives do not consider (a) retention and rehabilitation of the Hurley Building, potentially leveraged by federal and/ or state historic rehabilitation tax credits, or (b) retention and rehabilitation of the Hurley Building with new construction.

The MHC requests a copy of the draft Request for proposal (RFP) for review and comment. MHC requests that the RFP include additional options: (1) retention and rehabilitation of the Hurley Building; and (2) retention and rehabilitation of the Hurley Building with new construction, which should precede the options listed within the PNF (Options A — D) in importance. The RFP should promote retention of the Hurley Building and should consider impacts to the entire Government Services Center site.

The MHC recognizes the challenges of retrofitting aging buildings to meet current standards and code. Thousands of buildings in the Commonwealth have managed to accommodate modern services while retaining vast amounts of architecturally significant spaces and materials, proving that rehabilitation of historic buildings is a viable option.

The MHC also recognizes pedestrian challenges to the site. Different access points and passageway openings could be developed to promote cross site access and inviting public spaces.

After review of our files and the information submitted, MHC has determined that the proposed project will have an "adverse effect" ((950 CMR 71.05(a)), (950 CMR 71 .05(e)), and (950 CMR 71.07 (2)(b)(3))) on the Government Service Center through transfer or sale of the historic property without adequate conditions or restrictions regarding preservation, maintenance or use of the property; and the destruction of the Hurley Building.

Pursuant to 950 CMR 71.07(3), the MHC looks forward to consulting with Massachusetts Division Of Capital Asset Management and Maintenance (DCAMM) to seek ways to avoid, minimize, or mitigate the adverse effect of the proposed demolition. The MHC hereby initiates its consultation process.

The demolition of a significant historic property that is included in MHC's Inventory triggers the filing of an Environmental Notification Form (ENF). If demolition of an inventoried historic property is the only anticipated ENF threshold, the proponent may consult with the MHC and change the project to result in a "no adverse effect" determination, or, as a result of consultation, seek to enter into a Memorandum of Agreement with the MHC in lieu of filing an ENF (301 CMR 11.03(10).

The MHC is concerned with the long term planning for the Government Service Center Complex. MHC staff participated in the life safety improvement projects at the Government Service Center, which took much time, effort, and state funds to implement. It is disheartening to have completed the project only to have DCAMM consider demolition of the architecturally significant features that the life safety improvement project took great care to preserve. The MHC is also concerned with the conditions of the Lindemann Center. The Preservation Report by Bruner/Cott Architects submitted with this PNF highlights the deteriorated concrete surfaces on the grand external stair and throughout the Merrimac Street plaza.

These comments are offered to assist in compliance with M.G.L. Chapter 9, sections 26-27C (950 CMR 71.00) and MEPA (301 CMR 11). Please do not hesitate to contact Elizabeth Sherva of my staff if you have any questions.

Sincerely,

Brona Simon

State Historic Preservation Officer

Executive Director

Massachusetts Historical Commission

xc:

Doug Kelleher, Epsilon Associates, Inc.

Rosanne Foley, BLC

Gary Wolf, DOCOMOMO/US NE

Greg Galer, BPA

Kelvin Dickinson, Paul Rudolph Heritage Foundation

Mark Pasnik, OverUnder

Below is the Massachusetts Historical Commission’s letter, in its original format:

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WHAT YOU CAN DO NOW…

First, we encourage you to send a letter of support (and thanks) to Brona Simon of the Massachusetts Historical Commission, at the following address:

Brona Simon, Executive Director
Massachusetts Historical Commission
220 Morrissey Boulevard
Boston, MA 02125

You can also sign the petition to preserve the overall complex.

We have over 1,000 signatures so far, and each one helps build the case that Rudolph’s Boston Government Service Center needs to be preserved.

You can sign the petition HERE.

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