Community Report on Historic Designation

Introduction

Since late 2023, the Palmer Woods Board of Directors has been considering a question that has been percolating for years in our neighborhood, if not for decades – the question of whether Palmer Woods should become a historically designated neighborhood. 

Through a series of meetings, committee work, and thorough research, the Board has compiled the attached Community Report on Historic Designation., which explores the various issues, concerns, and requirements involved with historic designation. It is meant to be a resource as we, the Palmer Woods Association, consider whether historic designation would be right for us. In preparing this report, we recognize that there is much misinformation regarding designation – both for and against – which must be dispelled with concrete facts, objective reporting, and community outreach.

The PWA Board strongly believes that this Report, and consideration of the question of designation in general, is both timely and highly relevant. In recent years, the Board and its members have fielded numerous queries from our neighbors as to why we are not historically designated, how we could become historically designated, and what it would mean in practice. Further, this Report is written with the understanding that most PW residents decided to move here because it is one of Detroit’s most historic communities and/or have a strong interest in historical preservation. Whether or not Palmer Woods ultimately decides to become historically designated, this Report is meant to serve as a historical document for future generations of PW residents to understand the full range of considerations involved. 

Most importantly, this Report reaches no overall conclusions in terms of whether historic designation would, or would not, be appropriate for our community. It is the firm belief of the Board of Directors that no representative body (i.e. the Board of Directors), should reach any predeterminations in what should be a decision for our entire community. Rather, this Report is meant to serve as a resource for our friends and neighbors as we consider the question of historic designation and what it would and would not mean for us.

Executive Summary

Currently, Palmer Woods is not listed as a historically designated neighborhood within the City of Detroit. The decision of whether to become historically designated is one that should be taken very seriously and one that should be considered with full and thorough information, presented in an objective and transparent manner. There are many significant benefits and responsibilities that come with historic designation. On one hand, historic designation would protect our many architectural and historical assets for generations to come, raise property values, and foster a sense of our neighborhood’s historical and architectural legacy. On the other hand, historic designation comes with it the ongoing responsibility of maintaining our home and preserving its architectural assets, which may at times limit our ability to alter our properties in particular ways. The ultimate decision whether or not to pursue historic designation requires careful consideration and informed choices.

Historic Designation in Detroit

Historic designation in Detroit refers to the recognition of certain buildings, structures, or districts that have historical, architectural, or cultural significance. The City has established local historic districts that are overseen by the Detroit Historic District Commission (HDC). These districts have specific guidelines for alterations, demolitions, and new constructions to preserve their historical character. Historic designation can result in increased property values, tourism, and potential tax incentives for renovation and maintenance. However, historic designation also carries with it a number of responsibilities to homeowners. Through these designations, Detroit aims to preserve its rich history and cultural heritage while encouraging sustainable development. 

There are more than 190 historically designated districts, buildings, or structures within the City of Detroit, including districts such as Sherwood Forest, Boston Edison, Arden Park, Indian Village, and cherished communities. Each district aims to preserve the unique architectural and historical character of those areas.  

Benefits of Historic Designation

• Historic designation gives communities a voice in their future and in the future of their historical and architectural assets.
• Preservation of significant architectural and historical assets increases the beauty and uniqueness of a neighborhood.
• Local historic district designation enhances property values. In 2010, local historic district designation added between 10.6% and 28.5% in home value when compared to similar non-designated properties. Properties within local historic districts also appreciate at greater rates than the local market overall as well as faster than similar, non-designated neighborhoods.
• Local districts protect the investments of owners and residents of historic properties, and protect properties from short-term investors who do not have the historical and architectural integrity of the home in mind. 
• Under the State Historic Tax Credit Program, tax credits of up to $1M are available for owner-occupied residential dwellings in local historic districts. This opportunity allows a property owner to receive a state tax credit for 25% of qualified rehabilitation expenses.
• Property neglect and blight can be prevented by the use of the “demolition by neglect” portion of the ordinance that requires owners to repair their properties before they reach such a state of disrepair that they have to be demolished.
• Historic districts are a vehicle for education. They are a tangible link to the past and a way to bring meaning to history and to people’s lives.
• Protecting local historic districts can enhance desirability for potential residents.
• Designation fosters a sense of responsibility to future generations of homeowners to maintain the historical and architectural heritage of our neighborhood.
• Informed by professional staff (including architects, architectural historians, landscape architects, and other professionals), the Historic District Commission may serve as an invaluable resource for homeowners who are interested in maintaining the historical and architectural integrity of their homes.
• Designation encourages homeowners to obtain permits and to comply with building codes, which helps assure compliance with construction standards within the historically designated community. 

Responsibilities of Historic Designation

• The ongoing responsibility of stewardship of your historic properties and its surroundings.
• Any modifications you would like to make to the exterior of your property (including windows, landscape, fences, demolition and new construction) is required to be approved by the HDC prior to obtaining a building permit to perform the work.
• Although some projects may be approved administratively, more significant projects will be required to go before full review by the HDC, increasing the time involved in obtaining permits. 
• Designation requires homeowners seeking project approval to be organized, well-researched, detail oriented, and transparent, as well as requiring due diligence on the part of homeowners in selecting materials, features, and design.
• Where repair is reasonably possible, replacement / removal of certain architectural features will generally not be allowed (subject to economic & technical feasibility considerations)
• Modern, often less expensive materials will generally not be approved, and homeowners will be required to repair original features wherever reasonably feasible. 

Definitions and Key Concepts

Historic District Commission (HDC):

Appointed by the Mayor, the HDC is composed of seven Detroit residents, all of whom are required to be residents of an historic neighborhood. The HDC meets regularly at least once per month, typically the second Wednesday of the month. The HDC considers project proposals that cannot be approved administratively, and reviews and evaluates all proposed exterior changes using the Secretary of the Interior’s Standards for Rehabilitation, as overseen by the National Park Service. The HDC oversees more than 190 historically designated districts and individual properties within the City of Detroit.

The HDC is additionally supported by six (6) permanent Staff employed under the Planning & Development Department, which is composed of architects, architectural historians, landscape architects, and other professional Staff. The permanent Staff makes recommendations to the sitting HDC members regarding proposed projects and, where appropriate, may administratively approve certain projects. 

Historic Designation Advisory Board (HDAB):

The HDAB has nine (9) members, who are residents of Detroit, and two ex officio members as represented by the Director of the City Planning Commission and the Director of the Planning and Development Department. Two ad hoc members are appointed by City Council in conjunction with studies of particular proposed historic districts. HDAB advises the City Council on all matters regarding historic preservation. Working with neighborhoods seeking historic designation, HDAB researches and produces the Final Report to be voted on by City Council and drafts guideline ordinances. The HDAB meets regularly at least once per month, typically the second Thursday of the month.

The HDAB is additionally supported by seven (7) permanent Staff, who are responsible for researching and developing the Preliminary and Final Reports. 

Exterior Only:

Historic designation applies only to exterior work, particularly with respect to the elements of design, detail, materials, or craftsmanship which typify a significant architectural asset (i.e. buildings and landscape). Interior projects are not subject to HDC approval. 

Elements of Design:

Defined as “the characteristic relationships of the various features within an historic district which are significant to the appearance of the district and to be defined for each historic district.” These are composed of twenty-two (22) design characteristics which may or may not apply in the particular case of Palmer Woods.

Administrative Approval:

Where appropriate, and to be determined on a case-by-case basis, certain exterior changes of limited scope can be approved administratively, i.e. approved by HDC Staff rather than needing to be submitted to the full HDC. This streamlined function has expanded in recent years, as HDC has received more funding and additional resources. Thus, depending on the scope of the work, HDC Staff may be able to approve the work and issue a Certificate of Appropriateness (COA) within a few days. If it’s not possible to get an approval at the Staff level, applicants will be added to the next available meeting agenda to go before the HDC for review. 

Appropriateness Standard:

A proposed project before HDC (Preservation, Rehabilitation, Restoration, or Reconstruction) may be deemed “appropriate” if distinctive materials, features, and spaces are essentially intact and convey the building’s historical significance. Higher standard than the “compatibility” standard.

Compatibility Standard:

Applies to replacement of non-original work (i.e. replacement of vinyl windows that were in place at the time the neighborhood became historically designated). The new work must be “compatible” with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment. Compatibility does NOT require replacement with “original” features once those features have been removed.

Certificate of Appropriateness (COA):

In historic districts, a COA is required before a building permit is obtained. COA is issued upon HDC approval of a proposed project. With the COA in hand, a homeowner can obtain a building permit from the Buildings, Safety, Engineering & Environmental Department (BSEED).

Repair Over Replacement:

Generally, where a historically significant architectural element is capable of being repaired, repair is favored over replacement. This applies to all architectural details but comes up most frequently in windows, roofs, and doors. Where repair is not economically feasible or an architectural element is beyond repair, any replacement must be historically “appropriate.”

Grandfathering:

At the time that a neighborhood becomes historically designated, the neighborhood’s architectural assets – whether completely original or significantly altered over generations of ownership – are frozen in time, with the current state of its architectural assets becoming the ongoing standard for future development. Thus, there will be no requirement that the home must be restored to a prior version of itself (i.e. installation of a new slate roof to match what was on the house originally). Thus, at the time historic designation is confirmed, the current state will become the standard for exterior projects going forward.

Economic & Technical Feasibility Analysis:

Although HDC will generally favor repair over replacement, if a structure is so deteriorated such that repair is reasonably possible, HDC will consider the economic and technical feasibility of a proposed replacement project. The HDC recognizes that certain replacements can be quite costly. Where this is the case, they are not likely to require a homeowner to spend an exorbitant amount to replace elements with historically appropriate materials. For example, when a full roof replacement is warranted (i.e. repair is not feasible), it is not necessarily the case that a slate roof MUST be replaced with a slate roof. Rather, the HDC will consider whether the slate roof can be replaced with other, less costly alternatives.

Demolition by Neglect:

In historically designated neighborhoods, property neglect can be prevented by the use of the “demolition by neglect” portion of the ordinance that requires owners to repair their properties before they reach such a state of disrepair that they have to be demolished.

“Demolition by neglect” means neglect in the maintenance, repair or security of a resource resulting in deterioration of an exterior feature of the resource, the loss of structural integrity of the resource, or any of the following conditions:

1. The deterioration of exterior walls or other vertical supports;
2. The deterioration of roofs or other horizontal members;
3. The deterioration of exterior chimneys;
4. The deterioration of exterior plaster, or mortar or stucco.
5. The ineffective weatherproofing of exterior walls, roofs and foundations, including broken windows and doors; or
6. The serious deterioration of any documented exterior architectural feature or significant landscape feature which in the judgment of the commission produces a detrimental effect upon the character of the district.

Projects that Require HDC Approval

**APPLIES TO EXTERIOR PROJECTS ONLY**

The majority of these project proposals will require full approval before the HDC. However, on a case-by-case basis, certain projects of limited scope can be approved administratively by HDC Staff. When in doubt, it is always best to inquire with HDC Staff as to whether approval would be necessary. 

• Window Replacement 
• Roof Replacement
• Siding Replacement
• Painting
• Demolition
• New Construction/Additions
• Door & Garage Door Replacement
• Solar Panels
• Lighting Installation/ Replacement
• Building Cleaning
• Fence Installation/Removal
• Porch Repair and/or Reconstruction
• Landscaping Projects*
  

*Although less strictly reviewed than structural projects, landscaping work also falls under the purview of the HDC. Particular attention is paid to large-scale landscaping projects such as the removal of established trees, installation/removal of hardscape elements, or other significant changes where a permit would be required. Though considered on a case-by-case basis, small-scale landscaping projects will not require approval and/or can be administratively approved.

Process for Project Approval Before HDC

The responsibilities listed above are regulated and managed through the administration of a simple building permit application review. Depending on the complexity of the proposed work, an applicant may be required to appear before the HDC for their review.

1. 1. Submit Application: Applicants must submit their Project Review Request Form along with all of the required checklist items pertaining to the exterior work to be completed to HDC Staff.
   2. Preliminary Review: Depending on the scope of the work, HDC Staff may be able to approve the work and issue a Certificate of Appropriateness (COA) within a few days. If it’s not possible to get an approval at the Staff level, the project will be added to the next available meeting agenda to go before the HDC for review.
   3. HDC Hearing Process:
      1. Presentation of Applications Subject HDC Approval
      2. HDC Staff Recommendation is presented to the Commission
         Compatible/Appropriate → Recommend Approval;
         Not Compatible/Not Appropriate → Recommend Denial
      3. Opportunity for Homeowners or Representative to speak in favor of approval
      4. Public Comment
      5. HDC Discussion
      6. HDC Issues Decision via Motion to Approve/Deny
   4. Approval → Proceed to COA: As soon as the applicant has received the COA for the proposed work, the applicant should proceed to the Buildings, Safety Engineering and Environmental Department (BSEED) to obtain the building permit to perform the work.
   5. Denial → Resubmit or Appeal: If an application is ultimately denied, an applicant may (1) submit a corrected application with required documentation to the HDC, or (2) file an appeal with the State Historic Preservation Review Board.

Process for Historic Designation Before HDAB / City Council

Seven steps are involved, providing multiple opportunities for HDAB/City Council to consider the designation, and two public hearings, which provide an opportunity for all interested parties to express their views. 

NOTE: Unlike with SAD designation, there is no requirement for a majority vote or majority support in order for a proposed district to become designated. The process may be initiated by a portion/subset of representatives of a proposed district (i.e., an Association Board), with community opinion and feedback being considered through two public hearings.

1. 1. Initial Request: A citizen request is sent to City Council (via Representative Calloway) to consider our designation. (see Note above) The citizen request is first sent to the City Clerk to consider a designation. The request should state the reason for seeking the designation and describe the significance of the proposed district. The request is assigned a petition number and forwarded to the City Council.
   2. Study Period: City Council may adopt a resolution directing HDAB to study the proposed district. City Council adopts a resolution directing the HDAB to study the proposal and appoints two ad hoc members to represent the proposed district.
   3. Preliminary Report: HDAB Staff prepares a Preliminary Report, describing the historic and architectural value of the proposed district. The Preliminary Report describes the proposed historic district, and outlines its historic and/or architectural value.
   4. Public Hearing Before HDAB: HDAB Staff prepares a Final Report after a public hearing and presents it to the City Council. If the recommendation is for designation, it will contain a draft ordinance. The public hearing is held not less than 60 days after the issuance of the Preliminary report, the HDAB holds. The public hearing provides an opportunity for all interested parties to express their views.
   5. Final Report: HDAB issues a Final Report to City Council, describing the proposed district, its architectural and/or historical value, with a recommendation to the Council either for or against the designation. If the recommendation is in favor of designation, the report also contains a draft ordinance of designation for Council consideration.
   6. Public Hearing Before the City Council: A public hearing before the Council is held, providing an opportunity for all interested parties to express their views.
   7. Ordinance: Based on community feedback, City Council may introduce the ordinance of designation. After it passes, the local historic district will be in effect and become regulated through the HDC.

Conclusion

As described above, there are many significant benefits and responsibilities that come with historic designation, which must be considered with full and thorough information. Crucially, this Community Report reaches no conclusions in terms of whether historic designation would, or would not, be appropriate for our community. Further, the Board of Directors declines to  reach any predeterminations in what, in essence, should be a decision for our entire community. If we as a community are to ultimately move forward with historic designation – or not, the decision must be based on informed choices, transparent communication, and thorough consideration.