January 17, 2020

Brona Simon
Massachusetts Historical Commission
220 Morrissey Boulevard
Boston, MA 02125

Project Notification Form Response Concord Free Public Library Expansion MHC #RC.66817

Dear Ms. Simon:

We received your response to our Project Notification Form, dated December 13, 2019, and we respectfully disagree with your determination that the proposed project will have an adverse effect on the building and district. Similarly, we do not understand your statement that it does not meet Standards 9 and 10 of the Secretary of the Interior’s Standards for Rehabilitation, as the proposed project will not destroy any historic materials and was carefully designed to preserve the form and integrity of the historic portions of the Heywood- Benjamin House, with the proposed additions designed to be subservient to but compatible with the massing, size, scale and architectural features of the existing House. We are concerned that the decision may have been based on inaccurate information.

In reviewing the MHC project file materials that were made available to us on January 6, 2020, we noted several inaccurate statements in letters from interested parties opposed to the project, many of which were raised and addressed during the review by the Historic Districts Commission and Zoning Board of Appeals. Those inaccuracies were refuted during the local review process, and are further disproved by the information submitted with the initial Project Notification Form on September 23, 2019, as well as the additional information submitted on November 12, 2019 and December 4, 2019.

Project Was Approved by Local Boards

The design was approved by both the Concord Historic Districts Commission and the Concord Zoning Board of Appeals. These local boards are most familiar with the community, the Main Street Historic District, and the Heywood-Benjamin House. They granted their approval after a comprehensive review process that included extensive input from the public, beginning with an informal presentation in January 2018 while the proposed design was being developed. The design was refined through the review process, incorporating comments from both board members and the public, and it is widely supported by the community as evidenced by public comments at these meetings as well as many other public meetings in the past six years since the Heywood-Benjamin House was purchased by the Concord Free Public Library Corporation.

The Historic Districts Commission also performed two site visits to gain a full understanding of the existing conditions, making their final site visit earlier on the same day that they voted to approve a Certificate of Appropriateness for the project. Along with the Library Trustees and Lawrence Sorli, the Library’s preservation consultant, we believe a site visit by MHC staff would clearly show that the project will not destroy any historic materials, and will preserve the form and integrity of the historic portions of the Heywood-Benjamin House.

Project Designed with History in Mind

We have worked diligently with the Library Trustees to find a solution that meets the needs of the Library, the Code requirements for an adaptive reuse, and the approval of the Concord Historic Districts Commission. This work began with an extensive study of design alternatives, ranging from renovating the Heywood-Benjamin House without connecting to the existing Library building, to significantly more extensive exterior renovations to the House than what is proposed. The proposed design is the one that meets all of the programmatic, operational and Code requirements for the project. It also leaves the form and details of the historic portions of the House intact.

We have carefully considered both the Concord Historic Districts Guidelines and Secretary of the Interior’s Standards for Rehabilitation from the outset of the design. Throughout the design process, we have sought to minimize disruption to the historic fabric of the Heywood- Benjamin House. This has involved research on the construction history of the House by Lawrence Sorli and by our office, as well as a historic paint analysis by Dr. Judith Selwyn. The Library may continue to conduct research on the property, and we will supplement this response with additional information as we learn it.

The proposed addition has been intentionally designed to largely replace existing, recently constructed non-historic additions. The stair and corridor, where the program and Code require entirely new additions, have been located along heavily modified walls where the materials have all been recently replaced, usually with historically inappropriate replacements. These additions have been deliberately located behind the prominent, street- facing historic portions of the Heywood-Benjamin House.

No Historic Portion of the Building Will Be Removed

We have been careful in designing the proposed addition to leave the form and footprint of the historic c.1797, c.1840 and c.1875 portions of the House intact.

As demonstrated in our response to your request for additional information, dated November 14, 2019, and Lawrence Sorli’s letter, dated November 25, 2019, the portions of the Heywood-Benjamin House proposed to be removed are of recent construction and are not historic.

Materials to Be Removed Are Not Historic and Do Not Characterize the Property

The materials, including windows, siding and trim, that are proposed to be removed or enclosed are also of recent construction, not historic and do not characterize the property, as exhibited in our submission, including building permits and photographs of several of these materials being installed. The windows are replacement windows dating to the last several decades, and the siding and trim in the areas of the proposed work were all replaced in recent decades as well. The non-historic nature of these materials is further established by Dr. Judith Selwyn’s letter, dated December 13, 2018 and submitted here for the first time, specifically the statement that her historic paint analysis was complicated by “Late twentieth century alterations, including replacement of all siding, corner boards and windows….”

Essential Form and Integrity of the Building Will Not Be Impaired

The main c.1797 portion of the House, which you note has been the prominent portion of the building facing the street, along with the c.1840 wing, are proposed to remain entirely intact with no additions or modifications, other than painting and repairs of deteriorated materials.

Our submission, including the Existing Floor Plans (submitted on November 12, 2019) and Proposed Floor Plans (submitted on September 23, 2019), indicates that the essential form and integrity of the original c.1797 house, along with the c.1840 wing and c.1875 ells will remain intact, and would be unimpaired if the proposed Link addition were removed in the future. As the Existing Elevations and Proposed Elevations (submitted on November 12, 2019) indicate, the proposed addition largely takes the place of existing recent additions that are proposed to be removed. As such, we take exception to your description of the proposed Link addition as engulfing the rear ells: the eastern and western rear ells are already largely surrounded by recent additions which are proposed to be removed.

As indicated in our Responses to Additional Information Requested (submitted on November 12, 2019), the existing exterior walls of the historic portions of the House will remain, with some becoming interior walls, and with some reconfigured window and door openings as required by the program and Code. Where possible, such as at the corridor and workshop (interior courtyard), the existing exterior materials will remain to preserve and articulate the form of the historic House. While some recently installed, non-historic materials, including siding, trim and windows, are proposed to be removed or concealed, the framed openings will remain in most cases. As such, if the proposed work were removed at a future date, the historic form and integrity of the House would be clearly evident and unimpaired, with only non-historic replacement materials proposed to be removed.

Siding Will Be Restored at East Ell

The only portion of the east ell that is not currently concealed is a small section of the east wall. A new single-story corridor addition is proposed at this small section of wall, along with the portion of this wall currently concealed by a mudroom built c.2002. This proposed corridor

addition would leave the existing windows of the ell in place, replace one window at the end of the corridor with a door in a slightly enlarged opening, and restore the siding of the existing House that was removed during construction of the mudroom. In this way, the addition will be clearly differentiated from the existing House with the existing walls of the House appearing as exterior walls within an enclosed porch, and will be more intact than they are currently.

While already concealed at the Ground Floor by recent additions proposed to be removed, the chimney and several feet of the rear-most east ell were constructed c.1991, as shown in the attached construction photo and plan, both obtained from Building Department and Historic Districts Commission files.

West Ell Façade is Not Historic

The only portion of the west ell that is not currently concealed is the west wall. The addition is proposed in this area to accommodate a Code-required second means of egress from the Second Floor. While the existing west ell is proposed to remain and become an interior wall, the Code requirements for fire-rating of this stair preclude leaving the existing window openings or siding in place. As demonstrated in our Responses to Additional Information Requested and the accompanying photographs and building permits (submitted on November 12, 2019), this wall has been heavily modified in recent years, with entirely new windows, siding and trim, none of which are historic. As seen in the previously submitted photograph attached, the windows are all replacement windows, some with false shutters and some in clearly recent openings, with several dryer-vent type louvers penetrating the façade.

The addition proposed at the west ell is designed to step back from the historic c.1840 wing, while remaining compatible in terms of massing, size, scale and architectural features. This will be more historically appropriate than the recent siding, nominal 2x-trim, and replacement windows and false shutters that are proposed to be removed from the west wall.

Requests for Information and Opportunity to Meet

We received your Project Notification Form response, dated December 13, 2019 on December 18, 2019. We have been making an effort to respond in a timely manner but needed some additional clarification and information before we could send an appropriate response. In an effort to get this information, we called your office on December 23, 2019 and again on December 31, 2019, and left a message requesting a meeting to clarify the areas of concern mentioned in your letter. We spoke by phone with Elizabeth Sherva of your office on January 2, 2020, and reviewed certain MHC project file materials that were made available to us on January 6, 2020. At that time, and again on January 8, 2020, we requested a meeting with MHC staff to clarify your letter.

In order to respond accurately to your letter, we again respectfully request a meeting to clarify areas of concern. We, along with the Library Corporation Trustees, believe that a timely meeting with MHC staff, the Library Corporation, its preservation consultant, and us, in

addition to a review of MHC supporting documentation are crucial to address the issues cited in your letter. Please contact me at your earliest convenience to schedule a meeting.

Sincerely,

Michael Bellefeuille, AIA Associate

cc: Elizabeth Sherva, Massachusetts Historical Commission Sherry Litwack, Concord Free Public Library Corporation Jeffrey Adams, Concord Free Public Library Corporation Marcy Eckel, Concord Free Public Library Corporation Stephen Crane, Town Manager, Town of Concord Peter Nobile, Concord Historic Districts Commission Lawrence Sorli