EPA Climate Justice Blog: Your Involvement in the Future of Our Legacy Cities

Charlene Dwin Vaughn, AICP, EPA
10/14/14

America’s Legacy Cities were once industrial powerhouses and hubs of business, retail, and services scattered across New England, the Mid-Atlantic, and the Midwest. Their factories provided jobs, and downtown areas were alive with department stores, professional offices, and financial institutions that served large regions. Since the mid-20th century, however, these cities have seen sustained loss of jobs and population, and now face daunting economic, social, physical, and operational challenges. This loss has fallen disproportionately on minority and low-income neighborhoods that have seen a greater degree of disinvestment and abandonment.  But the revitalization of these neighborhoods in collaboration with, and for the benefit of, their residents is not only an imperative of equitable redevelopment but also enshrined in the Federal statutes that guide it.

Earlier this year, I attended the Historic Preservation in America’s Legacy Cities Conference which focused on public policies, programs, and planning issues associated with Legacy Cities and challenges managing shrinking populations, changing demographics, physical alterations, loss of resources, and declining tax bases.  Participants agreed Legacy Cities need to revitalize their communities in the 21st century.

While many agree that change is inevitable, there are those who have not fully accepted that planning for change should be inclusive and take advantage of all available tools. Looking back over the last twenty years, the non-inclusive planning practices of the past resulted in older, minority, and low-income neighborhoods bearing the brunt of the negative impacts of dynamic physical and socio-economic changes—changes that were prompted, in part, by federal actions.

Dr. Clement Price, Vice Chair of the Advisory Council on Historic Preservation (ACHP), an independent federal agency established by Congress to advise the President and Congress and oversee the Section 106 review process, moderated a provocative panel discussion entitled Identifying, Celebrating, and Preserving African-American Landmarks. The presentation was timely as many were grappling with how to protect historic properties, particularly those in communities of color. They wanted to be clear about what qualifies African-American landmarks for the National Register of Historic Places. Is the criteria used by the National Register in evaluating historic properties appropriate for an ethnically and racially-diverse nation? Should African American or other ethnic landmarks be evaluated based on their physical characteristics or on the stories drawn from the history of these properties?

When considering how to best engage the broader public in federal planning, environmental review policies are typically applied. The two major federal environmental reviews required for major actions are the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA). NEPA requires federal agencies to integrate environmental values into their decision making processes by considering the environmental impacts of their proposed actions and reasonable alternatives to those actions. NHPA is intended to preserve historical and archaeological sites in the United States.

Before implementing federally-funded activities such as abandonment, demolition, and property alterations in Legacy Cites, agencies must comply with their NEPA obligations and with NHPA. Since many cities use federal funds to develop public-private partnerships, the scope of federal environmental reviews can be broader for compliance with Title VI of the Civil Rights Act. Notwithstanding the dictates of Title VI, the provisions in NEPA and NHPA require federal agencies to “stop, look, and listen” in project planning.

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