To: Ms. Wight Greger, Director
Housing and Neighborhoods Department
From: Springfield Area Merchants and Business Association
Date: February 14, 2011
Re: NSP 3 Substantial Amendment, City of Jacksonville, Florida (Duval County)
A significant portion of the target area identified for this most recent phase of the Neighborhood Stabilization Program is a nationally recognized historic district. The Springfield Historic District was added to the U.S. Register of Historic Places in 1987. Therefore, the City must be conscious of and make accommodations for the special needs of an historic district when implementing this program. With that in mind, the Springfield Area Merchants and Business Association submits the following comments to the NSP 3 Substantial Amendment proposed by the City of Jacksonville, Florida (Duval County) in January 2011:
Supporting Rationale for the Target Area Selection; Definitions and Descriptions
According to the Amendment, “Systematic demolition of unsafe structures will greatly enhance the neighborhood’s marketability.” Page 8 of 35
While there are properties in the target area that may be appropriate candidates for demolition, demolition should be discouraged in the Historic District. Any decisions about the demolition of historic properties should be made under the supervision of Jacksonville’s Historic Preservation Commission and the City’s historic planners.
The Amendment discusses “Housing Rehabilitation Standards” (pages 10 and 11 of 35) and acknowledges that the target area contains portions of an historic district and that historic preservation standards must be enforced. Historic properties must not be excluded from the program because of the additional costs associated with their rehabilitation. The City must be flexible in its guidelines for administering this program, seeking waivers from Federal authorities where appropriate, to allow for those additional costs to be funded. If necessary, the City should allow additional “gap subsidies” for historic properties. Rehabilitated historic properties add significant value to the target neighborhood and the City will only achieve the goals of the Neighborhood Stabilization Program if historic properties are included. Further, the City must be careful to select only consultants, inspectors and contractors who are familiar with historic restoration and must direct those consultants to make historic preservation a priority when making their recommendations. For example, lead inspectors should allow for preservation rather than removal of historic trim, doors and other features whenever possible.
SAMBA is pleased to see that NSP 3 now requires “Vicinity Hiring”, as described on Page 11 of 35 of the Amendment. We would like to provide assistance to the City in identifying small business firms located within the target area appropriate for participation in the various phases of the program.
Activity 1 – Acquisition/Rehabilitation/Resale
SAMBA reiterates that historic properties must not be excluded from the program because of the additional costs associated with their rehabilitation. The City must be flexible in its guidelines for administering this program, seeking waivers from Federal authorities where appropriate, to allow for those additional costs to be funded. If necessary, the City should allow additional “gap subsidies” for historic properties. Rehabilitated historic properties add significant value to the target neighborhood and the City will only achieve the goals of the Neighborhood Stabilization Program if historic properties are included. The City must be select only consultants, inspectors and contractors familiar with historic restoration and must direct those consultants to make historic preservation a priority when making their recommendations.
The City should also follow the recently expanded definitions of “abandoned” and “foreclosed” provided by the federal government when implementing and approving properties for inclusion in this program. We understand that the City may only be considering properties where foreclosure has been completed or where a tax deed sale is scheduled. The revised federal guidelines clearly allow a much greater range of properties to be included and this program will only be successful in the Springfield Historic District if the City follows those expanded guidelines.
To maximize the positive impact on the target area, the City should consider encouraging Developers to concentrate their efforts on “model blocks” to increase potential sales prices and create momentum for private investment. There are several areas within the historic district that include large numbers of qualified properties (both vacant and developed), such as the portion of 3rd Street East between Hubbard and Liberty Streets.
Finally, the City should encourage Developers to consider mixed use projects in the target area’s commercial districts that would include privately funded commercial or retail spaces beneath NSP3 funded residential units.
Activity 2 – Demolition / Clearance
SAMBA recommends that the City’s efforts within the Springfield Historic District focus on board-up or “mothballing”. We are aware that the City’s Planning Department, Historic Preservation Commission, and Office of the General Counsel are currently preparing mothballing legislation designed, in part, to preserve historic properties. The Housing and Neighborhoods Department should carefully coordinate with the Planning Department to insure the success of the proposed mothballing program.
Paragraph g) on page 17 discusses the “Hiring of Employees/Small Businesses in Target Area Vicinity” in connection with this activity. Again, SAMBA offers its assistance in locating small businesses in the target area.
Activity 4 – Financing Mechanisms
Paragraph g) on page 22 discusses the “Hiring of Employees/Small Businesses in Target Area Vicinity” in connection with this activity and encourages Partners to “work with community based organizations in the area to identify local residents and small businesses for current and future employment and procurement opportunities.” SAMBA is a community based organization prepared to offer this assistance to NSP3 Partners.
Activity 5 – Redevelopment
Paragraph g) on page 24 discusses the “Hiring of Employees/Small Businesses in Target Area Vicinity” in connection with this activity and requires Developers to “work with community based organizations in the area to identify residents for employment opportunities or existing small businesses to work with.” SAMBA is a community based organization prepared to offer this assistance to Developers.
Thank you for allowing the Springfield Merchants and Business Association to provide comments to the NSP 3 Substantial Amendment. If you have questions or would like to discuss these comments further, please contact SAMBA officers Jason Fisher or Christina Parrish.