On the Blog: Historic Preservation, Section 106 and Affordable Housing

Historic Preservation, Section 106 and Affordable Housing

By: Mary Ann Hawthorne, Environmental Review Historian

If you listen to, watch, or read the news today in almost any large metropolitan area in the United States, you will undoubtedly hear or see stories commenting on the decline in availability of and/or lack of affordable housing.  While affordable housing shortages and crises in large cities and metropolitan areas are often in the headlines, the issue reaches into the suburbs and rural areas, alike. As noted in a 2002 report, Historic Preservation and Affordable Housing: The Missed Connection by prominent preservation economist Donovan Rypkema, the crisis in affordable housing impacts renters, homeowners, and prospective homeowners, affecting a wide cross-section of Americans.

The Environmental Review team at the Historic Preservation Division (HPD) reviews projects every year that are associated with various types of affordable housing in communities statewide ranging from new construction to rehabilitation or adaptive reuse of historic buildings.  The Environmental Review team most often reviews these projects under Section 106 of the National Historic Preservation Act (NHPA) of 1966 due to federal agency involvement. Section 106, as it is commonly known, is the provision in NHPA that requires federal agencies to consider how the projects they undertake, permit, approve, license, or fund can affect historic properties, both above and below ground.   

Many communities leverage U.S. Department of Housing and Urban Development (HUD) programs to provide affordable housing opportunities. In 2022 and 2023, the Environmental Review team reviewed over 100 new construction projects utilizing various HUD programs in Bibb, Catoosa, Fulton, Glynn, Houston, Jackson, Jefferson, Laurens, Muscogee, Newton, Sumter, Tattnall, and Walton Counties, among others.  While constructing new single and multi-family housing is one way to increase affordable housing options, it is clear from studies and news reports that the demand for affordable housing outpaces the available supply of housing, not just here in Georgia, but nationwide. Additionally, the cost of new construction often causes increased pricing and moves the new construction out of the reach of those most in need.

If new construction is not the answer to the affordable housing crisis in Georgia, , what other viable tools are available to communities to meet these challenges? A common saying in the historic preservation community is that “the best historic building is one that is being used.” Preserving our historic neighborhoods is another tool that can be put to good use to address the need for more affordable housing

“Historic” as a classification requires a building or a neighborhood to be more than 50 years old, thus in 2023 buildings and neighborhoods built in 1973 or before are considered historic.  Many older neighborhoods already meet many of the needs of modern Georgians:  proximity to work, access to public transportation, schools, and a variety of shopping opportunities. The HPD sees many examples of older neighborhoods and housing stock being reused for modern needs. In 2022 and 2023, the Environmental Review team reviewed over 450 rehabilitation projects, many involving historic housing, utilizing a variety to HUD programs in Baldwin, Ben Hill, Bleckley, Camden, Chatham, Cherokee, Clarke, Clayton, Cobb, DeKalb, Dougherty, Floyd, Fulton, Gordon, Gwinnett, Hall, Henry, Houston, Jackson, Jefferson, Lowndes, McDuffie, Muscogee, Richmond, Troup, Ware, and Whitfield Counties, among others. 

One notable example of a successful housing rehabilitation project is the rehabilitation of the Capitol View Apartments in Atlanta. The Capitol View Apartments were constructed in 1947 using funds from the Federal Housing Administration’s Veterans’ Emergency Housing program, and when opened, were home to veterans and their families. For decades, the complex served as affordable housing for low-income renters without a significant, property-wide rehabilitation since construction.  The property was purchased in 2018 and with construction financing secured in 2020, a major rehabilitation project leveraging HUD program funding along with state and national historic preservation tax credits and low income housing tax credits, began. By the summer of 2021, all ten of the historic apartment buildings had been rehabilitated and met the Secretary of the Interior’s Standards for the Treatment of Historic Properties.   The Capitol View Apartments are now open to renters and are located in a historic neighborhood where the coveted proximity to work, transportation options, and shopping can be enjoyed by the residents. The property was listed in the National Register of Historic Places in 2023.

New construction and rehabilitation of existing buildings, however, may not be the full answer to the affordable housing question. There are many tools a community can use to address this issue and historic preservation plays an important role in that strategy.  Mr. Rypkema, in his 2002 report, suggests that creating more local historic districts and giving priority to older and historic neighborhoods for infrastructure, educational, and recreational facility improvements can be options for local communities to explore.   While communities throughout Georgia continue to seek creative solutions to their housing crisis, the Environmental Review team at HPD supports communities utilizing federal agency programs to meet those challenges through the Section 106 review process.