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6509.2 REV-5 CHG-2

A.

Historic Preservation:  For historic properties, reviewers should evaluate programs in light of the allowance of interim controls and ongoing lead-based paint maintenance, where abatement of lead-based paint hazards is otherwise required. Reviewers should look for inappropriate programmatic insistence on abatement where interim controls are technically feasible and are, in fact, preferable in historic properties.  Prices (per square or linear foot of building component) for abatement are generally higher than interim controls.  This insistence on abatement could represent unnecessary costs to the program.

Through the Lead Safe Housing Rule, the interests of the historic preservation and lead-safe housing communities shift from competing to complementary.  For programs that routinely perform rehabilitation of historic properties, reviewers should evaluate programs in light of the Lead Safe Housing Rule’s allowance of interim controls and ongoing lead-based paint maintenance, instead of lead hazard abatement that would otherwise be required [24 CFR 35.115(a)(13)].  If the property has been listed or been determined to be eligible for listing in the National Register of Historic Places or contributing to a National Register Historic District, the Rule states that interim controls may be used instead of abatement if requested by the State Historic Preservation Officer (SHPO).

Some HUD program participants and subrecipients appear to be confused over the application of the Lead-Safe Housing Rule to historic properties.  According to some SHPOs, confusion stems from the fact that some program participants and subrecipients believe, despite the language of the Rule, that abatement is the only treatment suitable for properties with lead-based paint hazards.  In many cases, certain forms of abatement, like removal of original material, encapsulation, or replacement with inappropriate material, adversely affect historic properties.  Consequently, SHPOs find themselves objecting to, or disagreeing with, program participants and subrecipients over lead hazard reduction methods, thereby causing some delay with Section 106 compliance (36 CFR Part 800, Protection of Historic Properties.)

In other cases, performing interim controls on building components in very poor condition may be infeasible from a technical perspective, e.g., the components lack the structural integrity to support a repair or interim control treatment.  In these cases, preserving the existing structure of the property may not be in its best interest from the historical, lead hazard control, or financial perspectives.  In cases such as these, program participants are encouraged to work with SHPOs to identify historically acceptable strategies, such as the use of satisfactory replacement materials and safe work practices that also reduce identified lead hazards.  To this end, program participants should document their position that interim controls are not effective or adequately durable before requesting approval of abatement from their SHPO.

While it is generally easier and sometimes more cost-effective to replace building components, HUD and the National Park Service agree that the historical fabric and character of the property is important.  When interim controls are feasible for

24-1103/2008

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