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Sunday, April 22, 2018

Crossing the Talbot Avenue Bridge

On April 21, 2018, I visited the Talbot Avenue Bridge in Silver Spring, Maryland. The bridge, which spans the CSX Railroad tracks, has for the last century been the main connection between the largely African-American community of Lyttonsville and the more upscale white neighborhoods across the tracks, as well as the Georgia Avenue corridor into the District of Columbia.
The gathering on the bridge

The occasion for my visit was the installation of a “pop-up park” on the bridge by my colleague and friend, historian David Rotenstein, who has made it his business to remind us here in liberal Montgomery County – and coincidentally in my birthplace, Decatur, Georgia – of our Jim Crow traditions. Perhaps a hundred people attended. David and his colleagues had affixed interpretive placards to the bridge rails, and there was a “conversation corner” where people could share stories about the bridge and their communities. There were speeches, by David and by elders of the African-American community. The elders talked of the role the bridge had played in the life of their community, as essentially their only connection with the outside world and the larger society and economy.

Why was the event staged? Because the century-old bridge will soon be demolished to make way for the “Purple Line,” a largely federally funded rapid transit project. Katherine Shaver’s September 24, 2016 story in the Washington Post tells the tale: see

Lyttonsville elder Charlotte Coffield (L) confers with 
David Rotenstein (R). The white taped line symbollically
represented the division between Black (B) and White (W) communities

A couple of the placards recounted the history of the Purple Line’s environmental impact assessment under Section 102(c) of the National Environmental Policy Act and Section 106 of the National Historic Preservation Act. In the course of this assessment, based on a consultant’s report, the bridge was found eligible for the National Register of Historic Places, but only as a work of engineering. Its sociocultural significance seems to have been entirely ignored.

I take it that the existing Talbot Avenue Bridge will be replaced by a modern structure capable of spanning the widened railroad tracks, so the connective tissue it represents will be maintained. And history has moved on; Montgomery County is no longer the segregated set of communities it once was (though in these difficult times, even here segregationist attitudes occasionally resurface). So maybe losing the bridge is no big deal. But damn, people, is it really right for a property like the Talbot Avenue Bridge to be evaluated for the National Register, and hence considered under Section 106, purely as a piece of engineering? Should its traditional cultural value not have been considered, leading in this case – perhaps – to a more respectful outcome?
Among the "popup park's" markers

I know, there’s King flapping his lips again about traditional cultural places. And this time after the fact. No argument; I just think it’s sad that once again Section 106 review – and NEPA review – of impacts on a place of cultural significance to a community has been short-circuited by narrowminded application of the National Register criteria. I guess I should be used to it by now.


Anonymous said...

Why not Criteria A, and leave it at that ?

And, it's very good to see your postings again. Been awhile.

Darby S said...

It seems to me that if the people writing the MOA were concerned about the types of things you are talking about, they could have included stipulations accordingly. There is no requirement to only include mitigation associated with a documented adverse effects, is there? If no one came forward with the concern, what;s an agency to do? However, remembering David from the old days of ACRA-L, I suspect he was trying to get his interests and concerns addressed. If so, did he fail because only Criterion C was idneitfy in the NR evaluation?

My real question, however, concerns the ability to revisit National Register nominations in later undertakings that affect the historic property. When we evaluate a traditional cultural place for NR eligibility during a project, we only document those characteristics of the TCP that pertain to the undertaking at hand. So if the undertaking will impact one part of the TCP, we might only talk about those aspects of the TCP located in the area to be effected. We do not, and indeed it would often be impossible, to describe the TCP in toto; we would not try to say everything about the TCP, or give every reason we believed it eligible under each criterion mainly because it is sensitive information, but also from a practical standpoint, we would not want to bother people who may know about certain aspects of the TCP if those aspects were not threatened. So, our evaluation is not meant to be the be all and end all for that place, just what is needed for the undertaking at hand.

But, what happens when the next project comes along and is going to impact another part or aspect of the TCP? Are we locked into the existing NR evaluation? I assume we can go back and take another look at the TCP site form and evaluation, and revise it as we see necessary.

We do run into problems occasionally when someone will say, "we mitigated that property during such and such project." Then we have to remind them, "No, you mitigated the effects of that project, you did not mitigate the property. Now you have to consider the effects of this project. The previous mitigation may suffice, but may not." It does drive project people crazy sometimes, but that's the way it is.

So,,,,are National Register evaluations and nominations living documents? They have to be, don't they?

Tom King said...

Darby -- First off, the "living document" business is one reason I recommend against NOMINATING things to the NRHP -- a formal listing is a pretty damned dead (to say nothing of deadly dull, and dead-tree) document. A determination of eligibility, and still better an agreement to REGARD as eligible for the 106 case in progress, is much more flexible, more living and breathing and capable of evolution.

As to the Talbot Ave. Bridge, it wasn't nominated; it was regarded as eligible, based on a narrowly constructed consultant's report. Why didn't people come forward with their cultural concerns? I don't know, but my guess is that they didn't know how to do it in a way that would make any difference. You know how that works; for better or worse, one of the few reasons anyone hires me any more is to help translate community concerns into Register Rhetoric and Section 106 Speak. It shouldn't be that way, which is why Claudia Nissley and I have offered our suggested amendment to Section 106.

At the time the Talbot Ave. Bridge case went through Section 106, I think David was down in Georgia getting beaten up for opposing gentrification-based resegregation, and nobody asked me about it.