Historic Harrisburg Association and the GSA

The Business Journal article in its July 21 issue certainly does show the sadder side of the Cumberland Court decision. Also interesting is that it points out that the new manager of the Broad Street Market, David Zwifka, is also executive director of Historic Harrisburg Association. He is quoted as saying an influx of office workers could boost Broad Street Market business. He does seem sympathetic to the plight of Cumberland Court Apartments.

But isn't this the same Zwifka who wrote the following to the GSA? Notice he never mentioned the apparent conflict between his role as Market director (since he now says the Market will benefit from the site selection.) Seems like hypocrisy to me


Dr. David Alan Zwifka
Executive Director
Historic Harrisburg Association
General Services Administration, Mid-Atlantic Region
Attention: Abby Low, Project Manager
20 N. 8th Street
Philadelphia, PA 19107-3191
Dear Ms. Low:
I write today in response to the Draft Environmental Assessment (EA) for site selection of the
Proposed U.S. Courthouse in Harrisburg, Pennsylvania.
On behalf of Historic Harrisburg Association, I wish to express our gratitude for the opportunity
to have input into this important project.
Historic Harrisburg Association (HHA) is aware of the limitations placed upon the GSA from
several sources. The criteria established by legislatures, executive orders, and internal policy
statements can make such a process extremely complicated for those charged with making these decisions. However, HHA is also profoundly aware that the site selection process will have adeep and abiding impact on elements of the Harrisburg community regardless of decision taken.
The EA outlines in detail the site selection process. It further outlines the various factors that ledto the selection of three "short-listed" sites. The EA also outlines in detail, GSA's assessment ofthe many factors that will contribute to a final decision. HHA is aware that this is an assessmentdocument only and not an argument for or against any particular site.
This response will limit its observation to the site at N. 3rd and Forster Streets. HHA's missionfocuses primarily on the preservation of historic assets (fabric and neighborhoods). While HHAboard and members feel strongly about the impact this project will have on other sites listed, itfeels that its prime focus must be historic assets threatened by this project. HHA's observationshere and its effort to confine comment to the single site in no way implies that other proposed sites are to be preferred.
It is the opinion of HHA that the EA overall does not adequately communicate the gravity of
specific factors in the decision process, especially in the EA's Executive Summary. For example,
the report describes the nature of many of the structures at the N. 3rd and Forster site as havinghistoric character. What the report fails to communicate adequately is that these structurescomprise a significant element of the inventory of a post-Civil War neighborhood. If thesestructures are demolished, the negative impact on the historical architectural assets of the citycould be classified only as catastrophic. Moreover, the impact to the historical assets of the area would not be limited to the site only.
What would remain of the architectural inventory in the immediate area would suffer as a sort of"critical mass" is reached where investment in preservation and maintenance of the remaining
structures may suffer from the increase in traffic density, the need for parking, security concerns,and other factors that often have a negative impact on such neighborhoods.
For example, on p. 52 the EA notes "indirect impacts to land use may occur as properties in the
vicinity of the courthouse are converted to commercial space to serve employees and visitors to
the courts or to provide office space for businesses with activities related to the courts.
Properties … could experience a conversion from residential land use to commercial land use or
parking activities. Therefore, this alternative would have moderate, long-term, direct and
indirect adverse impacts on land use planning in the City." The statement, however, fails to
convey the significance of demolishing these historically significant structures.
While existing buildings at the N. 3rd and Forster Streets site might be functionally rebuilt, since
people and functions can be relocated, the structures themselves cannot ever be replaced. Put
bluntly, once they are gone, they are gone forever. This fact needs to be stated boldly, not in
terms that may cause the reader to miss their significance.
On this point alone, the report fails to take cognizance of the strong preservation ethos that existsamong residents of the affected neighborhood and the importance of such neighborhoods to thelarger community. The report notes that the area has undergone a sort resurgence because of other downtown development ("they began renovating the neglected row homes of thedowntown and mid-town neighborhoods."). While the EA recognizes the impact of this projecton the historic district as such, it fails to recognize that much of this work is not merely updatingor repair but genuine preservation and restoration. The area lies not only partly within theHarrisburg National Historic District but also completely within one of Harrisburg's six
municipal historic districts. As a result, the Harrisburg Architectural Review Board must
approve any work done to houses in the area. Moreover, the work already accomplished has
created a cultural environment that cannot be except in like neighborhoods of which there are bydefinition a limited number. As further evidence, many of these homes have been featured on
semi-annual house tours sponsored by HHA that boast of nearly 1000 participants at each event.Many of the houses have been designated as premier examples of historic preservation and restoration through HHA's Preservation Award program, where preservation projects are singledout for excellence using defined criteria.
The report continues concludes that there will be "no cumulative impacts" from this project
concerning the continued trend of downtown "residential and downtown development." On the
contrary, this project represents the kind of development that is antithetical to the redevelopmentrecently experienced in this area. Instead of redeveloping and enhancing existing resources, thisproject would demolish existing assets and lead to the deterioration of what it has taken ageneration to heal.
The report assesses the impact on population and housing for the N. 3rd and Forster Streets site
as follows: "Relocations would have direct, moderate, short-term adverse impacts to individual
tenants . . . There is ample replacement housing available in the City of Harrisburg for the
homeowner/occupants . . . though the replacement neighborhoods lack some of the historic

What would remain of the architectural inventory in the immediate area would suffer as a sort of "critical mass" is reached where investment in preservation and maintenance of the remainingstructures may suffer from the increase in traffic density, the need for parking, security concerns,and other factors that often have a negative impact on such neighborhoods.
For example, on p. 52 the EA notes "indirect impacts to land use may occur as properties in the
vicinity of the courthouse are converted to commercial space to serve employees and visitors to
the courts or to provide office space for businesses with activities related to the courts.
Properties … could experience a conversion from residential land use to commercial land use or
parking activities. Therefore, this alternative would have moderate, long-term, direct and
indirect adverse impacts on land use planning in the City." The statement, however, fails to
convey the significance of demolishing these historically significant structures.
While existing buildings at the N. 3rd and Forster Streets site might be functionally rebuilt, since
people and functions can be relocated, the structures themselves cannot ever be replaced. Put
bluntly, once they are gone, they are gone forever. This fact needs to be stated boldly, not in
terms that may cause the reader to miss their significance.
On this point alone, the report fails to take cognizance of the strong preservation ethos that existsamong residents of the affected neighborhood and the importance of such neighborhoods to thelarger community. The report notes that the area has undergone a sort resurgence because ofother downtown development ("they began renovating the neglected row homes of thedowntown and mid-town neighborhoods."). While the EA recognizes the impact of this projecton the historic district as such, it fails to recognize that much of this work is not merely updatingor repair but genuine preservation and restoration. The area lies not only partly within theHarrisburg National Historic District but also completely within one of Harrisburg's six
municipal historic districts. As a result, the Harrisburg Architectural Review Board must
approve any work done to houses in the area. Moreover, the work already accomplished has
created a cultural environment that cannot be except in like neighborhoods of which there are bydefinition a limited number. As further evidence, many of these homes have been featured on
semi-annual house tours sponsored by HHA that boast of nearly 1000 participants at each event.
Many of the houses have been designated as premier examples of historic preservation and
restoration through HHA's Preservation Award program, where preservation projects are singled
The report continues concludes that there will be "no cumulative impacts" from this project
concerning the continued trend of downtown "residential and downtown development." On the
contrary, this project represents the kind of development that is antithetical to the redevelopmentrecently experienced in this area. Instead of redeveloping and enhancing existing resources, thisproject would demolish existing assets and lead to the deterioration of what it has taken ageneration to heal.
The report assesses the impact on population and housing for the N. 3rd and Forster Streets site
as follows: "Relocations would have direct, moderate, short-term adverse impacts to individual
tenants . . . There is ample replacement housing available in the City of Harrisburg for the
homeowner/occupants . . . though the replacement neighborhoods lack some of the historic
ambience of the subject site." Such a statement demonstrates that the impact assessment misses the mark. The very reason most of the residents of this neighborhood live where they do is precisely because of the "historic ambience." This writer also acts as a real estate professional inthe city of Harrisburg. It is not unusual, when clients look for housing in these neighborhoods, tochoose an older house rather than a "new-build" even though they may be in the same proximate neighborhood. This only underscores the irreplaceable (might one say "priceless"?) nature of a historic architectural asset. Low vacancy rates, waiting lists and other factors point to the importance these assets hold for housing in the city of Harrisburg. Moreover, the N. 3rd andForster Streets site is the only site where there are multiple property owners, several of which are owner-occupants.
With the exception of a single multi-story office building, the mixed-use buildings housing
With the exception of a single multi-story office building, the mixed-use buildings housing
commercial enterprises for the most part are neighborhood-based businesses that thrive because of the context in which they exist. Like other property owners in the area, they respect the historic nature of the neighborhood and are governed by the same standards concerning
renovation or modification of their buildings. Moreover, if these businesses are forced to
relocate, services may be lost to the neighbors that remain causing further deterioration in the
neighborhood fabric.
The impact on neighborhood cohesion seems self-evident. The EA, however, seems to minimize
this impact without a recognition of the human toll involved: "Those who remain would lose
neighbors and local gathering places as affected residents, restaurants and bars/clubs would
move out of the neighborhood . . . These indirect impacts are typically short-term, as remaining
residents adjust to their modified community or decide to leave and others move into the
neighborhood. Therefore, a short-term, moderate adverse impact to the larger CAN community
is anticipated as a result of this alternative." The report seems to conclude "they'll simply get
over it or leave." That conclusion may be correct. HHA for most of its 33 years has seen
neighborhood stabilization and development as part of its mission through the use of a historic
preservation ethos. By its nature, this process understands this kind of development to be slow
and incremental of deeply rooted and dynamic. This project would dismantle many years of
effort by numerous dedicated citizens and expect the situation to right itself with the passing of
time. HHA respectfully disagrees that this outcome is inevitable.
HHA wishes to recognize the EA's conclusion that the project would have a "major, direct, longterm, adverse impact to historic structures" (p.107).
However, this conclusion must be seen in the real-life context of this impact as noted above.
Historic assets are preserved not for themselves but for the community, which they serve. To
see the assets in isolation does not provide an adequate assessment of their importance. Again,
HHA is grateful for the opportunity to respond to this EA. If HHA can offer further input or
guidance, please contact us directly.
With every kind wish, I remain
Sincerely,
Dr. David Alan Zwifka
Executive Director