CaseStudy:Development of a bank branch within the Liberty Hall National Historic Landmark District

Liberty Hall is a National Historic Landmark (NHL) built in 1772 by William Livingston, a signer of the U.S. Constitution and the Revolutionary War era governor of New Jersey. It was later the home of the prominent Kean family. Today the house is a museum, largely intact and containing many original furnishings, textiles, toys, and tools from the Livingston and Kean families.

A portion of the 14-acre Liberty Hall Historic District in Union, New Jersey, is the proposed site for a new bank building, raising concerns that the historic landscape connected with the NHL will be adversely affected by the project. The Office of the Comptroller of the Currency (OCC) regulates the establishment of new branches by national banks and is the federal agency that coordinated the Section 106 consultation.

Details
Although all the wishes of consulting parties could not be achieved in the project outcome, the Memorandum of Agreement (MOA) for this undertaking represents a significant commitment on the part of OCC and its applicant to modify the project design to minimize its direct and visual effects. The implementation of the project will also integrate interpretation and other preservation activities to mitigate the adverse effect on the NHL.

The parcel of land on which the proposed bank will be constructed is the former location of a historic house that was moved in the 1980s. When OCC made an adverse effect finding in June 2008, the branch was planned to be part of a larger commercial development. Community members voiced strong opposition to the encroachment of commercial construction and parking on this corner and opposed any development within the Liberty Hall district boundary. This undertaking faced similar pressures to others in which a private applicant seeks federal approval for a project carried out in an urban environment in that consultation had to be coordinated with concurrent schedules imposed by local administrative reviews and transactions outside the federal agency’s purview.

Following the start of consultation to resolve adverse effects, the bank redesigned its proposal to eliminate additional commercial development, reducing the footprint of the new construction by about 7,000 square feet and cutting 2/3 of its planned number of parking spaces. Revisions to the landscaping plan provide for vegetative screening along the west side of the parcel facing the rest of the Liberty Hall acreage. The bank building was also repositioned on the site, creating a one-acre landscape buffer at the rear of the bank building. In response to comments raised by the New Jersey State Historic Preservation Officer (SHPO) and other consulting parties, the bank will place the buffer area under a conservation easement donated to the Union County Parks and Recreation Department.

Other mitigation measures include the design and installation of a large color mural of a historic scene or map from the Liberty Hall Foundation archives and accompanying narrative signage in the branch lobby. The bank will also contribute to a preservation project, to be developed in consultation with signatories to the MOA, aimed at achieving long-term preservation of Liberty Hall.

Given the adverse effects to the NHL, the OCC invited the Secretary of the Interior, represented by program staff in the National Park Service’s Northeast Region, to participate in consultation. Other consulting parties included Concerned Citizens of Union County, Union County Historical Society, Liberty Hall Foundation, the City of Elizabeth Council, and several individuals. The ACHP determined that the direct effects to the NHL, combined with strong community concern about the need to limit effects to the historic landscape, merited its participation.

The MOA was executed in January 2009 by the OCC, New Jersey SHPO, the ACHP, the bank, and the NPS.