Memorandum I. INTRODUCTION. louisberger.com. DATE: July 13, HP Lackawanna Office, LLC and Lackawanna SPE, LLC. Dr. Steven M.

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Memorandum DATE: July 13, 2018 TO: FROM: SUBJECT: HP Lackawanna Office, LLC and Lackawanna SPE, LLC Dr. Steven M. Bedford Lackawanna Plaza I. INTRODUCTION. II. By way of establishing my bona fides, I have been working in this field for over 30 years. I have a Ph.D. in Architectural History from the Department of Art History and Archaeology at Columbia University and a professional degree in architecture (B. Arch.) from Rensselaer Polytechnic Institute. I have been a Smithsonian Fellow in Washington, D.C. I meet the Secretary of the Interior s requirements to be considered an architectural historian. I have performed architectural surveys, written National Register of Historic Places (NRHP) nominations and determinations of eligibility for districts and individual structures. I have documented structures to federal Historic American Buildings Survey (HABS)/Historic American Engineering Record (HAER) standards as well as to individual state standards. My work on the architect John Russell Pope was published by Rizzoli, and my articles and reviews have appeared in the Journal of the Society of Architectural Historians, Annals of the American Academy in Rome, and Amcademy, the American Academy s newsletter. I have guest curated exhibitions at the National Gallery of Art, the National Academy of Design, the Parrish Museum of Art, and other locations. I have provided testimony before Boards of Architectural Review, Planning Commissions, Planning Boards and Historic Preservation Commissions in New Jersey, New York, and Connecticut. At your request I have reviewed plans, drawings, reports and various historical documents relating to this project. I visited the site June 13, 2018. NO LINCOLN BUSH TRAIN SHEDS EVER EXISTED AT LACKAWANNA PLAZA. There is a contention in the July 11, 2018 Revised Report prepared by Barton Ross that the former platform canopies are in fact Bush-type train sheds. They are not. The Bush-type train shed (Figures 1-2) was patented by Abraham Lincoln Bush in 1905 as means to avoid the construction of the expensive high-arch train sheds that were common in that era. These arched structures were built high in part to dissipate the corrosive effects of locomotive smoke before it reached the metal structure, but the height also let in much of the weather. 20 Corporate Woods Boulevard Albany New York 12211 USA Tel +1.518.514.9312

Figure 1 Typical Bush Train Shed. (Shorpy) Figure 2 Patent drawing of Bush Train Shed (Google Patents)

Bush developed an alternative train shed that spanned the tracks at a much lower height, just above the standard locomotive smokestack, providing more weather protection using a shorter span. A concrete-coated linear vent at the apex of each span released the exhaust gases away from any unprotected steel. As shown in the historical photos and the patent drawing, the track area was covered. This was never the case at Montclair. The pre-opening images of the Lackawanna Plaza Station clearly show that the area over the tracks was open. There were no train sheds. Rather, what existed in Montclair is referred to as platform canopies. The platform canopies at Montclair did not extend over the tracks and were of a type that was referred to as ordinary (The Architect 19[1909]:156-158). The platform canopies at Montclair are of a type that still exists throughout the Northeast and Mid-Atlantic states from South Station in Boston to Union Station in Washington. The HAER photographs of the Grove Street Bridge at the Library of Congress also demonstrate that the platform canopies at Montclair did not span the tracks (Figure 3). Figure 3 Lackawanna Plaza Station looking towards the Grove Street Bridge. (HAER No. NJ-52) The photo from the National Register nomination also shows that the platform canopies did not extend across the tracks (Figure 4). Furthermore, in 1914 Lincoln Bush published a list of stations that used his patented shed and Montclair was not on the list (Railway Age, July 24, 1914).

III. Figure 4 Lackawanna Plaza Station (National Register) THE CREATION OF THE INTERIOR MALL IN THE 1980 s. Notwithstanding rumors to the contrary, the skylights in the interior mall (that exists at the site of the former train platforms where the platform canopies were located) were installed in the 1980 s. This is confirmed by the drawings for the interior mall structure that were submitted to the Township, which illustrate that new steel was bolted onto the existing platform canopies and new concrete added to the canopy as necessary to create the interior mall (Figures 5-7). Figure 5 Detail from Drawing AR 117 (Lackawanna Plaza Plans)

Figure 6 Section detail from Drawing AR 118 (Lackawanna Plaza Plans)

Figure 7 Detail from Drawing AR 118 (Lackawanna Plaza Plans) Additional canopy supports were added as part of the 1980 s remodeling to create the interior mall. Drawings AR 117 and AR 118 show that the skylights are new, and drawing AR 203 (Figure 8) also notes that the existing concrete was covered and cut off at the edge of the canopy steel and new concrete was poured over the existing concrete. The section drawings also show that the floor levels have been altered and that the pedestals of the canopy supports have been buried under concrete. That the skylights are new can be seen by referring to drawings AR 213 and AR 214 (Figure 9). Drawing RP 104 (Figure 10) reproduces a typical canopy, and one can see that the original canopies do not extend over the tracks. Aside from substantially altering the integrity of the platform canopies, the aforementioned additions that created the interior mall structure in the 1980 s were never part of a train shed.

Figure 8 Detail from Drawing AR 203 (Lackawanna Plaza Plans)

Figure 9 Detail from Drawing AR 214 (Lackawanna Plaza Plans)

IV. Figure 10 Detail from Drawing RP 104 (Lackawanna Plaza Plans) RESPONSE TO OTHER HISTORIC STATUS ASSERTIONS. The suggestion in the Montclair Historic Preservation Commission s Appendix to its April 26, 2018 Memorandum that the Lackawanna Plaza Station is some form of concrete innovation by the architect Botsford is inaccurate. Specifically, the article in Cement Age, cited in the Appendix, while written by Botsford, has nothing to do with Montclair but is, in fact, about a train station in Bloomfield, New Jersey. While Botsford in the article called for a new type of artistic treatment and that it need not be modelled in imitation of any other building material, a radical concept for the era, Montclair station s design did not follow that precept as it is clearly based on classical precedents. Similarly, the claim repeated in Barton Ross s July 11, 2018 Revised Report that the Lackawanna Plaza Station was the finest and most complete suburban passenger station in America should be taken in context. As reported by The New York Times (June 29, 1913), this claim was asserted at the opening of the station by a Montclair politician who had just announced his candidacy for governor of New Jersey. Thus, this statement should be viewed more as self-congratulatory political boosterism than as a reliable, proven fact. V. THE NATIONAL REGISTER AND STATE REGISTER NOMINATIONS. The National Register nomination was written in the early 1970s, over 40 years ago, and is very brief. It would not pass today s requirements for a nomination as it lacks a strong context statement and an analysis of its integrity. The nomination lists the structures comprising the

Lackawanna Plaza prior to any alterations, and as the platforms have since been substantially altered, the nomination does not represent the current state of the platforms. The significance of the listing with respect to the remnants of the platform canopies should be given very limited weight in light of the changes caused by the 1980 s renovation. (The significance of the 1972 listing on the New Jersey Register of the Historic Places with respect to the remnants of the platform canopies should likewise be given very limited weight). National Register and New Jersey State Register listings do not per se compel the conclusion that a structure may never be demolished. Such listings are planning tools. Listing requires status to be taken into account when a state or federally funded project may affect a property. Simply put, the current status of the remnants of the platform canopies should be considered separately from the entirety of the National Register Listing and New Jersey State Register Listing. Lackawanna Plaza is really an agglomeration of structures waiting area, platform, and head house. The utilitarian platform area was and still is distinct from the more highly decorated ticketing/waiting area. (Toward this end, it is subjective and lacking in evidence to conclude that the former platform canopies were an integral element of the National Register or New Jersey State Register listing.) The waiting room and the platform were linked only by a covered passageway. The former waiting room is still recognizable, but the platform area is not. Its appearance has been changed from an open and airy structure to a dark and low exterior as part of an interior mall created in the 1980 s. The former platform area has lost historic integrity, a key requirement for designation at the national and local levels (Section 347-135 of the Montclair Code). Seven integrity criteria are used for determining whether a structure (in this case, the remnants of the platform canopies) has the necessary surviving characteristics to sufficiently convey its historic character and importance as a historic structure. Typically for a structure to have complete integrity, it must have integrity of location, setting, feeling, association, design, materials, and workmanship. A building that only possesses location, setting, feeling, and association cannot be considered to have integrity at the national or state level and this lack of integrity when viewed in the context of Section 347-137(D) of the Montclair Code regarding review criteria for demolition compels a conclusion that demolition of the interior mall is not violative of either historic preservation principals or requirements (and would not otherwise trigger concerns regarding preservation in place). The following is a brief examination of the aforementioned characteristics as applied to the remnants of the platform canopies: Location: It has integrity of location. It is on its original site. Setting: It has lost integrity of setting with the removal of the Grove Street Bridge and the enclosure/conversion of the train platforms as part of the interior mall building. It has lost its context. Feeling: It presently does not convey the feeling of a train platform or a former train platform. It feels like a small indoor mall. A train platform area would have a transparency that the current structure does not. Right now the former train platform elevation looks like a wholesale market or

warehouse loading dock with the addition of extraneous decoration that implies there once was a truss where there never was one. Association: A person coming to the original pre-1980s renovated structure would associate the former train waiting/ticket area with train transportation, but associating the indoor mall with platforms is impossible. Divorced from its original transportation context, it has lost its association with trains. There is no indication that one is walking in a space once occupied by rails. The platform height has also been changed. Design: The design of the platforms and the remnants of the platform canopies are indiscernible from the exterior, and the actual design of the former platform canopies has been altered through the addition of extra steel structure to support the addition of the skylight enclosures. There is no indication of the original platform width. Although the structure is visible to a certain degree, it is difficult to discern the strong rhythm made by the stanchions when platforms were extant. The original design of the platforms is not indicated, and the rhythmic width whose governing module was created by the train tracks has been sacrificed to the commercial exigencies of store design. The loss of rhythm and transparency is critical. It has lost integrity of design. Materials: Although most of the materials are extant, it appears that some of the platform canopy stanchions are replacements and parts of the concrete roof have been replaced or subsumed into other roof structure, hence the integrity of materials has been compromised. The addition of the modern storefronts and the coating on the concrete diminish any sense of the materials. Workmanship: Although workmanship in a utilitarian structure is difficult to discern in general, all of the surfaces of the former platforms have been covered over and/or replaced. Very little of the board formed concrete canopies is visible. The floor no longer reflects that of the original platform. Any sense of workmanship in the platform area has been lost. If one takes these losses of integrity together, the train platforms have lost their integrity and the resulting conclusion is that demolition of the interior mall is not inconsistent with historic preservation principals or requirements. And, based upon: (1) the aforementioned losses of integrity; and (2) the fact that the platform canopies were common (as opposed to being rare or unique Lincoln Bush Train Sheds ), I disagree with the Montclair Historic Preservation Commission s recommendation that the proposed demolition of the interior mall is inconsistent with Section 347-137(D) of the Montclair Code. July 13, 2018.