Oral Testimony to the Historical Architectural Committee 04/23/2024

In response to an earlier Committee Member question, there is also a City
floodplain manager.

In reference to the Econsult Solutions testimony about the undesirability
of non ground-level uses we note that there is level access, above the
floodplain from Shurs Lane where the applicant is proposing building egress.

The foundation of any development on a historical site is what are the
historical elements on the site and how will they be treated.

This site is listed on the National Register of Historic places with their
highest A rating "Significant Building or Structure"

The site contains a intact hotel building from pre-1850 that had
functioned as the Littlewood's business offices. It includes several
mill buildings and infill built at various times since Littlewood's began
operation in 1869.

There has been no inventory of the individual buildings, and their
characteristics, that make up the site.  See our written submission for
photos of parts of the site not show by the consultant reports.

The applicant has solicited multiple consultant reports which, almost in
unison, attempt to establish several false premises also echoed in the
earlier testimony.

    The site must be treated as a whole.  All retail, all restaurants, all
    industrial, etc.  This is, of course, not the case.

    The site must be preserved as a whole. The whole site must be preserved
    and re-used or none of it.  This is, of course, not the case.

    The site is so interconnected that there can be no meaningful separation
    of the component buildings. This is, of course, not the case and no
    evidence was presented.

    The Design Flood Elevation (DFE) is so high that no part of the site
    can be re-used without extensive modifications.  The DFE is defined as
    18" above the 100 year flood level and is the first "occupied" level
    of a new or significantly renovated building.

The applicant's documents provide no information, apart from some fragmented
information on the Hotel building, on the internal makeup of the site. No
floor plans, building outlines, measurements or materials. Virtually no
information relevant to historical preservation.

Hurricane Ida was well above the 100 year flood level. Nate Hommel,
director of planning and design with the University City District, was
quoted in a recent Inquirer article describing Ida as 400 year storm. By
our analysis Hurricane Ida flood level was, in Manayunk, approximately
2.6' above the 100 year flood level.  Ida (at 16.85' in Center City)
was the second highest flood in Philadelphia history topped only by
another Hurricane in 1869 that reached 17'.

The consultant reports relied heavily on descriptions of flooding from
Hurricane Ida and, perhaps as a result, the flood levels used by the
consultants are wildly off base from reality.  The DFE used in the
applicant's submission is 48" over the 400 year flood level of Ida and
80" over the 100 year flood level.  The true DFE should be 18" above
the 100 year flood level or about 62" (5+ feet) lower then they assert.

This level of misrepresentation would, of course, profoundly affect how
the site would be evaluated.

The true flood levels were determined from our own photographic
evidence coordinated with flood gauge level from the USGS Manayunk gauge
(monitoring location 01473800 on the Green Lane bridge) and Philadelphia
gauge (monitoring location 01474500 across from Boathouse Row) and
elevations supplied in the applicant's submission.

Historical preservation standards, we believe, can allow for uses at
the 100 year flood level but even that may not be necessary.

We have identified several obviously significant areas of the site with
floor space above the 100 year flood level and areas possibly worth
preservation, for their architectural significance, for ground level
(i.e. will be flooded) uses such as parking, storage of durable materials,
or access to new development elsewhere on the site such as the applicants
proposed entrance or lobby.

We believe the staff recommendation, to allow complete demolition of
the site, and ultimately, the Committee on Financial Hardship's vote to
adopt the recommendation were based on this misleading and incomplete
information.

In light of this we believe the recommendation should not be accepted
and that the site should be re-evaluated based on actual flood
levels and a thorough site inventory and evaluation.

The Committee on Financial hardship asked, perhaps belatedly, that “The
property at 4045-61 Main Street should be recorded to HABS standards
prior to any demolition.”

We believe that a thorough evaluation is a necessary pre-requisite to
any consideration of demolition or consideration of a development plan.

I would refer the committee to our written submission for more detail
and photographs supporting our arguments.  Also our testimony at the Hardship
Committee hearing where we address more directly points in the consultant
reports.

Our written submission also addresses design, scale and context and John
Hunter, our zoning chair and an architect will comment further.