In the proposed redevelopment of the American Legion Post No. 1, there are two important facts that the City of Phoenix seems to be eager to sweep under the rug. First, that the Post building is, objectively, an important historic building. Second, that in proposing to demolish the bulk of the building, they are violating City-adopted plans and principles.
Community & Economic Development (CED) department staff can’t be blamed for their initial blindness to the significance of the Post. They are not, after all, particularly knowledgeable about history or historic preservation. But sometimes, it seems that they don’t want to know, either. Case in point: from the beginning of the process, the City’s position on preservation of Post No 1 was that it was “not historic.” Despite community calls to save the building, and without having done any research or analysis, staff apparently decided that the building had no historic value, based only on its appearance.
So, since the City apparently lacked the knowledge, resources, or interest to make an informed decision, we decided to help them out.
Starting in 2017, I worked with Donna Reiner, local historian, to document the history of the Post building and prepare a nomination to the National Register of Historic Places that shows exactly why the building qualifies as historic. The nomination was taken through the process and was approved by the Phoenix Historic Preservation Commission, the State Historic Preservation Office (SHPO), and the State Historic Sites Review Committee (HSRC). All that remained to be done in order for the property to be listed individually on the National Register was for the nomination to be forwarded to the Keeper of the Register in Washington DC and for that final approval to be granted.
Then, in 2019 CED sent a letter to SHPO asking to halt progress on processing the nomination while the city “determine[s] the next steps for the property.” That hold is still in effect as of June, 2021, despite the “next steps” having been “determined.” (Note: some have publicly stated, or implied, that the hold was requested by the Legion. This is false, unless I am being misled.)
The city’s requested hold on National Register listing is inexplicable. Listing of the property in the National Register, in and of itself, would have no negative effects on property development. In fact, the effects would all be positive, opening up additional options for redevelopment such as the 20% historic preservation tax credit, the state historic property tax program, and potential historic preservation grant eligibility.
The City should be obliged to treat its historic buildings in the same manner as it expects of the private sector. The City has 100% ownership and control over the property. This is not a case where the City is asking a private property owner to preserve a building that might be blocking a more lucrative development scheme, as the City frequently requires: the David & Gladys Wright House is a prominent example.
The City itself has adopted historic preservation as a core value, particularly downtown. The Phoenix 2015 General Plan’s Downtown chapter includes a “History and Local Business” element (pp. 162-163) which states, in part:
“THE GOAL: Protect downtown’s historic structures, buildings, and neighborhoods while encouraging the growth of local business. Promote and expand upon the distinctive, authentic sense of place experience that downtown Phoenix offers.
“MEASURES FOR SUCCESS: Increase in the number of adaptive use projects each year; Increase in the number of new historic properties on the historical register.
“[CED] should encourage the adaptive reuse of existing buildings and pursue redevelopment at strategic site locations downtown.
“Continue to list eligible downtown historic properties on the Phoenix Historic Property Register and provide strengthened demolition protections for designated and eligible historic properties …”
The City should be obliged to treat its historic buildings in the same manner as it expects of the private sector.
As of this date, the proposed site plan for the property would result in demolition of over half of the building’s floor area, which clearly is not a preservation approach. Only the Main Hall would be reused (“preserved” would be an overstatement). The proposed plan instead incorporates a “memorial garden” and an interpretive exhibit about the Legion, putting these features forth as project “benefits.” (Let’s be clear about the interpretive exhibit: it is mitigation for a loss, not a project benefit, and to call it otherwise is misleading.) The proposed project is clearly not aligned with the City’s General Plan.
This will hopefully dispense with the questions of whether or not the building is historic (of course it is) and whether the City should respect that fact (of course it should). But there are even more reasons to take a preservation approach to this project. The Legion property is a very special one that deserves a visionary plan, of which preservation can play an important role. In addition, such a plan can enhance both the economics and the community benefits the project could bring to Downtown. These topics will be explored in upcoming posts.
From the 1950s through at least the 1980s, Phoenix government was notorious for its disregard of the city’s history. Things seemed to improve in recent decades, but here we are in 2021, once again moving toward civic destruction of one of our few remaining downtown historic buildings. The threat today is to American Legion Post No. 1 – one of the first three (and possibly the first!) American Legion posts in the United States.
The history of the post is detailed in my prior article, Not to be Forgotten. Unknown to most modern-day Phoenicians, the American Legion post was an integral part of life in Phoenix for over fifty years. Evolving from the original Pickrell House that was donated to the City to house the Legion in 1919 into the building you see today, the Post looks pretty much as it did after the last major remodel in 1961. During its most active years, the Post was a veterans’ club, a community social center, and the base for veterans’ initiatives across Arizona, all at the same time.
The City’s 99-year sweetheart lease of the property to the Legion expired two years ago. Instead of renewing the lease for a new term, the City elected to find a developer to buy the property, potentially leaving Post No. 1 homeless. The Legion was given a measure of hope when the City Council required that the Post be provided a place in the redevelopment. The disposition of the historic building was not clear, but the fact that the Legion would be given a home there led many to believe that the building, too, would be preserved.
In May, 2021, the City announced the selection of a developer and rolled out a draft redevelopment plan for the property. At this point, it’s not clear if, or how much of, the Post building might be saved as the property is redeveloped. But early indications are not good: the plan on the table shows two-thirds of the building being demolished, and what’s left being surrounded by four stories of apartments. The facilities needed by Post No. 1 for its normal operations are just not there.
What’s so aggravating about this state of affairs is that it’s a totally avoidable, self-inflicted wound. There are choices being made by city staff that are prioritizing one set of narrow economic interests over all other community interests. This could easily be the type of project that does it all … redevelop the property to provide much needed affordable housing downtown, preserve an important historic building, and revitalize a key organization serving our veterans. But instead, we get one of three.
What’s so aggravating about this state of affairs is that it’s a totally avoidable, self-inflicted wound.
There are a number of complex aspects to this issue, each of which deserve an in-depth discussion. They boil down to these major points, which I will address in future articles:
Despite the City’s resistance to recognizing it, the historic value of the property is not in serious dispute. The city has an obligation to live up to its own stated preservation goals and treat this historic place with the respect it deserves.
As a redevelopment site, the American Legion property is a special one. It deserves a visionary plan that balances all community interests to make it a memorable point of community pride, and not just another apartment block.
Enacting such a plan will provide more and better economics for the project and a return to the City that goes far beyond the money. Historic Preservation incentives, grants to underwrite veterans’ services, and other creative development strategies could all come into play if the City were to take the time to properly develop the plan.
There is still time for the Post No. 1 redevelopment to improve, but the City needs to hear from its citizens that they care, and that the plan on the table just is not good enough. Let’s do this one right.
The development of a new home for the Phoenix
Trolley Museum makes sense in so many ways
By Bob Graham
Near downtown Phoenix, two streetcars wait in a nondescript corrugated metal warehouse. They last rolled on tracks in city streets in 1948, just seven decades past. That’s really not all that long ago. If you are in your 80s or 90s and lived in Phoenix then, you probably remember them. If you are younger, your parents or grandparents may have ridden on them to get to school or work. They were an integral part of the fabric of the city for sixty years.
So how come you see no evidence of them as you drive around town today? Are streetcars even relevant anymore? Why should anyone care?
I grew up in Phoenix in the 1970s. By then the
city, and more specifically downtown, had already been largely transformed into
a modern metropolis, lacking focus and enabled by the dominance of automobiles.
Many seemingly small individual decisions had eroded away the city of
yesteryear; even the trolley system, once a critical part of our urban
infrastructure, had been completely forgotten in the span of twenty or thirty years.
The disappearance of historic Phoenix also meant that recent immigrants from
around the country, who have always outnumbered natives, had no idea that
Phoenix didn’t always look like it did then, or that anything of value might
have been lost.
But much of value has been lost. The small town that became a city was, before World War II, a place that was close-knit, friendly, efficient, and human. A place where you worked and played within walking distance of where you lived. A place where the community banded together to build prominent, well designed civic buildings, as a statement of who we were. Sidewalks downtown bustled with people. All of this was embodied in the urban form itself, which was made possible by streetcars.
In the 21st Century, there is a growing
awareness that the city of the past might have been a better place to live than
what it has become: anonymous, disjointed, inconvenient, and ugly – inhuman rather than human. But what can
be done? How can some of that past quality of life be recovered when so few
recognize its benefits? When each day brings busloads of new residents from
somewhere else, oblivious to the history of the place they have come to, or
that it could be any different?
History education is key. Much has been written about the historically-ignorant being doomed to repeat their mistakes; that the lessons of the past can inform our decisions about the future. Unfortunately, historical institutions have taken some serious hits in Phoenix since the recession of 2008. With the closure of the Phoenix Museum of History, Phoenix is the only US city in the top 20 that does not have a museum dedicated to its history. And the Phoenix Trolley Museum (PTM) lost its home of 40 years in 2016, forcing its major assets into indefinite storage.
Since losing their lease, PTM, owner of the two cars in question, has been busily working to re-establish their streetcar museum on historic Grand Avenue, locus of one of Phoenix’s earliest streetcar lines. In the span of three years, the group has relocated its assets, developed a basic indoor museum exhibit, collected one additional unrestored streetcar, and most recently, purchased the property. This last accomplishment is a landmark for PTM: for the first time, they own their property and can’t be evicted, giving them a permanent home and a solid financial base of equity. But their work has just begun. The new site does not have the facilities to store, protect, and exhibit the fragile museum pieces that are at the core of its collection. For that, they need to develop a “real” museum facility, and all that goes with it both physically and organizationally.
What the New Phoenix Trolley Museum would
bring to Phoenix
Connect people with the Phoenix streetcar story and its relationship to the history and development of Phoenix. This is, of course, the core mission of the museum, but the benefits of his particular piece of historical education are manifest. For the reasons set out above, PTM could tie together issues of urban growth and development, walkability, sustainability, transportation planning, and the physical layout of historic Phoenix in a single appealing narrative.
Create a new tourism and entertainment cultural destination for the city. Museums and similar venues have positive economic effects on their communities that far outweigh their costs. Streetcar and rail buffs make a point of visiting rail museums in each place they visit, and often plan trips around them; likewise for historical fans. These visitors spend money locally on food, lodging, and shopping.
Promote the revitalization of historic Grand Avenue and the west end of the central city. Grand Avenue was in deep decline between 1970 and 1990, after its use as a state highway was bypassed. This decline was worsened by the location of homeless services on the west side of downtown. More recently the area has been colonized by artists and small local businesses and is now an up-and-coming neighborhood. PTM’s location on Grand helps to solidify this progress, and if it can eventually get tracks back in the street, can help tie the area together as a people-mover with heritage streetcar service.
Serve as a bridge to a future downtown circulator, likely a streetcar loop. It’s a little-known fact that the transportation bond passed several years ago to expand the light rail system also included funding for construction and operation of a “downtown circulator,” which most likely would be a streetcar loop around downtown. The planning and construction of such a loop has not been made a high priority, so the idea remains unrealized. A trolley museum would re-familiarize people as to the difference between streetcars and light rail vehicles and their differing purposes, and with the people-mover described above, would give people a taste of how that could work, building community support and demand to build that system.
What you can do to help make this happen
Become a museum member. This is not about money. Or at least, not about YOUR money. The political strength of the museum is measured by its membership. How many people are considered constituents? How many people feel strongly enough to plunk down $20 a year, today a nominal amount? If the museum has 500 members, it will be treated completely differently by our city government and by grant sources than a museum of 50 members.
Donate. OK, in this case it’s about the money. Because the “real” museum has not yet been built, PTM’s only source of unrestricted income comes from donations, sponsorships, and membership dues. PTM owns its site, but land ownership continues to have a cost (there is a small mortgage) and they need to keep the wheels on while the bigger plans come to fruition.
Volunteer. PTM has no paid staff. All the museum has accomplished has been through the hard work of volunteers on their own time; most of them have families and jobs also clamoring for their attention. While people with certain talents are more urgently needed, anyone with a spare hour or two a week can help out. There are a lot of side benefits to volunteering, including gaining museum experience, expanding networks, fellowship with like-minded Phoenicians, and the satisfaction and feeling of accomplishment of helping create the new PTM.
Serve on the Board of Directors. Board members are also volunteers, but with more responsibilities and authority. Each Board member is expected to help ensure the financial success of the museum (in one of various ways) and participate in committee work. But this is where you can make the most impact. There are several openings, and PTM is looking to expand its diversity in terms of age, gender, race, and knowledge.
Building this trolley museum will bring richness to our quality of life in Phoenix in so many ways. If you agree, and really want to see this vision realized, I hope you’ll be able to help in one of the ways outlined here. Together, we can make it happen.
The City of Phoenix was responsible for the destruction of the magnificent Fox Theater in 1975. That event was probably the low point for preservation in a city that appeared hellbent on the destruction of its own identity and heritage. Since then, the City’s attitude toward historic preservation seemed to have improved: an Historic Preservation Office was established; protective overlay zoning was enacted in many historic districts and for landmark buildings; and the Orpheum Theatre was even restored and integrated into the new City Hall. But the impending redevelopment of the American Legion Post No. 1 shows that the City’s commitment to historic preservation is slipping. While they expect private property owners to preserve their historic buildings, they so far have declined to preserve an important landmark that the City itself owns and controls.
Post No. 1 has stood on its site near the five-points intersection at Van Buren and 7th Avenue for precisely 99 years. Unfortunately for the Legion, that corresponds with the end of their 99-year lease, signed in 1920 in the wake of World War I. The city’s Community and Economic Development Department (CED, for short) is in the process of finding a willing developer to buy the site and redevelop it for apartments or condos. They have decided that preservation of Post No. 1 is incompatible with their economic goals, and to date have rebuffed requests to make preservation of the Post building a requirement.
City staff has downplayed the historical importance of the Post building, implying that its value is doubtful. But to be clear: the American Legion Luke/Greenway Post No. 1 is without question a very significant historic site that is eligible to the National Register of Historic Places. That fact has already been evaluated and endorsed by the city’s own Historic Preservation Commission and the State Historic Sites Review Committee. The history of the building has been extensively researched, and was summarized in this prior post. Between its establishment in 1920 and into the 1970s, the Post was a social hub for all Phoenicians and the most important center for veterans’ services and issues in the entire state. Most of these connections have been forgotten, as long-time Phoenicians pass away and new residents flood in from elsewhere. In its present condition, the building would not win any beauty awards, and so most people would not give it a second look. But the whole point and purpose of historic preservation is to preserve those connections and stories it has to tell in tangible form so we can learn from our past.
Instead, the City proposes lip-service preservation. Their current proposal would only require a developer to include an “interpretive feature” or monument that commemorates the history of the American Legion on the site. Clearly, this does not meet the goal of historic preservation, which is to preserve historic places. The place itself will be lost. Only a gravestone would remain.
The place itself will be lost. Only a gravestone would remain.
CED also falsely says that the site can’t be economically redeveloped in a way that complies with historic standards. This claim reveals either a total misunderstanding of those standards and a lack of creative thinking, or is simply misleading. The leadership of the Legion Post on site has been working with a potential developer on a plan that achieves both redevelopment and preservation. That plan proves that it can be done.
Of course, when it comes to others preserving historic buildings, the city bars no holds. The David and Gladys Wright House was privately owned, and the owners proposed to do what was within their legal rights: bulldoze the building for McMansion lots. The city rightly intervened, and with a lot of time and effort costing both the property owners and the city, found an angel to buy and preserve it. More recently, an elderly couple with a small historic home on north Central Avenue filed for demolition. The Historic Preservation Commission has voted to initiate overlay zoning that would delay demolition for a year, while alternatives are found. This zoning action puts a major crimp in the owners’ financial plans, but you know, the city values historic preservation, doesn’t it?
The American Legion Post No. 1 is 100 times more important to the history of Phoenix as a single house on north Central Avenue. It is a one-of-a-kind, irreplaceable resource. If the City of Phoenix can’t commit to preserving the Post, an historic building that they own and control, it loses the high moral ground the next time a major historic building is endangered by redevelopment.
If the City of Phoenix can’t commit to preserving the Post, an historic building that they own and control, it loses the high moral ground the next time a major historic building is endangered by redevelopment.
It’s now up to the City Council. The city needs to walk the talk when it comes to preserving its historic buildings. And if CED will not make preservation of the historic building a condition of redevelopment, then the city’s Historic Preservation Commission, comprised entirely of private citizens, should initiate HP overlay zoning as it has for other, privately-owned buildings.
If you live or work in downtown Phoenix, you’ve probably passed by the American Legion hall at 7th Avenue and Van Buren. You might not notice it if it weren’t for the huge American flag flying overhead, which is hard to miss. It’s a nondescript building, set back from the street behind a field of asphalt parking. You wouldn’t know from looking that the Luke/Greenway Post No. 1 has been the most influential veterans’ organization in the state. It’s one of the three oldest posts in the U.S., established in 1919. For the first fifty years or so, it was involved in every significant veterans’ issue, and it was a center of Phoenix social life.
But it may not be there much longer.
A national movement begets a local landmark
The national movement that resulted in the organization called the American Legion has its roots in World War One. In those days, America’s wars were fought by a cross section of its citizens, driven by feelings of patriotism and unity that today seem a distant memory. The community spirit of support for the returning Doughboys (which, despite their diversity, were of course still mostly young men), who had fought, survived, or died in the first truly mechanized war, was palpable. This support was demonstrated locally by the direct assistance given to the newly chartered Legionnaires by the city of Phoenix providing them with a home.
The story of Phoenix’s Legion home starts in the 1880s, when Vina Brown was one of the landowners on the northwest edge of what was then Phoenix who banded together to make Grand Avenue possible. Her home on Yavapai Street (which would become 7th Avenue), just north of the new Five Points intersection at Van Buren Street, was provided with its own parcel in the new University Addition. By the ‘teens the property and its two-story Mansard-roofed Victorian house had become the home of the William and Georgiana Pickrell family, ostrich farmers. Mr. Pickrell was a charter member of the new Frank Luke Post No. 1 and was among those searching for a permanent meeting place. They had been meeting in various borrowed office spaces around town. Public support for the returning veterans was such that the city stepped in to purchase a home for them. Pickrell sold his home to the city in 1919, which on February 20, 1920 leased it to the post on a 99-year lease for $1 per year.
The fifty years to follow were a time of constant change and growth, reflecting both the development of the small town of Phoenix into a big city and the increase in the ranks of veterans emerging from wartime service. The first floor of the house was first gutted to make a meeting room. Additions followed, for offices, kitchen and other service areas. During the Depression, the Luke post merged with the John C. Greenway post to become the largest, by membership, in Arizona and one of the largest in the country; more additions were made to contain the growing Legion and the auditorium was enlarged to its 2-story height. World War II veterans drove even greater growth in membership. In the 1950s, Post No. 1 became one of the prime social spots in Phoenix, with events held every night of the week and gambling in the back, including slot machines. A major remodel and expansion in 1961 brought Post No. 1 to its present appearance.
Post No. 1 and its members were responsible for many advances in veteran’s services in Arizona, including local support for the GI Bill, securing the Veterans’ Administration Hospital and the Arizona Veterans’ Home, and working to create what was to become the National Veterans’ Cemetery of Arizona. Beyond direct assistance to veterans, the Post also supported programs promoting patriotism and good citizenship, including awards to outstanding grade school students, sponsorship of a Boy Scout troop, and outreach to the homeless. The Ladies Auxiliary supported additional programs for women and children.
The divisive politics that surrounded the war in Vietnam changed how society viewed returning American servicemen. It became harder after the war for veterans to express their pride in doing what was asked of them. It was also the first war that largely exempted the well-to-do from the burdens of service. Locally, the population of Phoenix was spreading out rather than building up and most vets moved to the suburbs, just like everyone else. These factors all contributed to a slow decline in membership at the downtown Post No. 1. Suburban flight and generational changes in leisure activities likewise reduced the use of the post by non-veterans. By the 1980s, the Luke/Greenway Post was largely off the radar of many Phoenicians.
The changes have been profound: the proportion of veterans in the American population has declined from about one-third in 1970 to about one-eighth today. But Post No. 1 has continued to march forward in its mission to assist war veterans while promoting patriotism and citizenship.
The City eyes a prime parcel
Meanwhile, downtown’s fortunes have completely reversed. Beginning in the 1990s people started to return to the central city. The opening of the light rail system and the establishment of ASU’s downtown campus have cemented the comeback.
Suddenly, five-story apartment blocks seem to have sprouted up everywhere around downtown, and every month it seems a new project is announced. The economic and real estate boom that we find ourselves in today coincides with an historical time bomb for the Frank Luke post. Remember that 99-year lease? It’s up.
99-year leases seem like forever. They are commonly assumed to be so – after all, by the time the lease is up, the principals will all be dead. And surely, (the thought goes) the lease will be renewed before it runs out.
Unfortunately, this may not be the case. Downtown development is quite literally at the doorstep of the American Legion. The Alta Fillmore apartment project across the street that opened in 2017 recently was sold at a record per-unit price for Phoenix apartments. City officials and council members have said that the Legion parcel should be redeveloped with as high a density as possible, in the name of economic development. And it’s an eyesore, they say.
The potential is there
It would be tragic if the American Legion Post No. 1 were forced out of their historic home just to make room for another urban apartment block. We need to do a better job of encouraging the kind of development that achieves the city’s economic goals while also preserving and honoring our past, and giving a hand-up to worthy institutions and organizations rather than shutting them out. This should not be an either/or, zero-sum decision – we can, and should, do both.
For the last year, an ad-hoc group of downtown stakeholders has been working on exactly that – how to preserve the history, legacy, and positive community benefits of the Luke-Greenway Post in downtown Phoenix while recognizing the economic expectations of city government. In fact, the potential for an entrepreneurial partnership may be exactly what the Legion needs to help make it relevant in a new era.
The vision that’s being developed for the future of the Post: a veteran’s service campus. Partnering with a for-profit development company leveraging federal tax credits, the revitalized Post could provide 50 or 60 units of transitional housing for homeless or disabled veterans. It could provide space for counseling programs, health care events, and job training. There could be some commercial space for a coffee shop or lunchroom. All of these activities can be accommodated within a rehabilitated Post building and on the underused land around it. Done right, the post could once again become a focal point of community activity and a way to reconnect with our population of service veterans.
The city has not taken an official position on the future of the historic Post No. 1. It’s still possible that the forces of economic development may win out over soft issues such as community-building, historic preservation, and helping our veterans. But with grassroots activists taking up the cause, it won’t be going down without a fight.
Pictured above: The Clinton Campbell House, one of fewer than 50 remaining 19th-century homes in Phoenix, will be demolished to make way for an unspecified future development.
Recently we seem to be losing one historic building after another in Phoenix to the bulldozer for lack of regulatory protections. In a political climate that places a high value on private property rights, unless owners voluntarily protect historic buildings they control little can be done without risking huge legal bills or court judgments. But why does it so often come down to us-versus-them? In a reflection of today’s polarized political climate, the answer may illustrate two radically different worldviews about economics and our responsibilities to society.
There is a familiar pattern to many losses of historic buildings in Phoenix that reads like this: A building’s historical importance is recognized by survey, but it is not legally designated historic because of objections by the property owner. The property is put on the market. It sits with a for-sale sign in front for months, and then years, as one developer after another looks at it, evaluates the development proforma of an adaptive reuse project, and walks away because the high asking price can’t be justified. Just when it seems that the seller is going to have to lower the price, a buyer appears that negotiates a purchase close to what the seller was asking. Soon thereafter, a demolition permit is filed, the community cries out, and another piece of Arizona history disappears.
The three examples that come to mind are the Stewart Motors Studebaker building, the Clinton Campbell House, and just recently, the Melrose Drive-in Liquor building. All three of these illustrate the pattern exactly.
Why were these buildings left unprotected, if they are so worthy? Stewart and Campbell were identified by historic surveys in the 1980s, and the Melrose building was on the developer’s radar from the inception of their project. Someone could have nominated them to the National Register of Historic Places, but the documentation needed can be complex and costly to create, and listing is contingent on the consent of the property owner. In any case, National Register listing provides little to no protection except from a federal government action. Real protections are embodied in Historic Preservation overlays written into the zoning ordinance. But since 2006, when the Private Property Rights Protection Act (a.k.a. Proposition 207) was passed in Arizona, cities are more than reluctant to re-zone anything without owner consent.
It’s important to be clear on this point: although not formally listed or zoned, these buildings are unquestionably historic. Having a detailed write-up and federal recognition doesn’t make a building historic. Being zoned with an HP overlay does not make a building historic. The criteria for evaluating whether a building qualifies as historic have changed little since the 1960s. If it’s generally at least 50 years old, represents an important historical event, person, or architectural pattern, and still looks the same as it did “back then,” it’s historic. It’s what preservationists call “National Register Eligible” and it’s just a fact of a building’s existence.
The demolition of these buildings (or in the case of Stewart Motors, 2/3 of it) may be the result of a purely economic viewpoint on the part of the developers. If demolishing a building and putting something bigger and newer on the site can create more value than rehabilitating the historic building, then some people believe that our laissez-faire economic system says it must happen. It’s not me tearing down that building, it’s Adam Smith’s invisible hand!
But economics is more complex than that. There are other forces at work. In a sales transaction, there is a buyer and there is a seller. Negotiation between the two determines the true value. Because these properties sat on the market for several years, it’s apparent that the seller’s idea of their value exceeded what most buyers found to be a justifiable price. They knew that the community would want the building preserved, and that a rehabilitation project couldn’t be economic at the price being asked.
When a buyer does come along who is willing to pay the higher price, it’s often because he’s willing to go farther than everyone else. Whether through ignorance, malevolence, or indifference, they are taking advantage of the fact that there are no regulations preventing them from “maximizing the value” of the site by removing impediments such as old buildings. And this is where the two worldviews collide.
Do we have a moral obligation to preserve buildings for the good of the community? Morals and ethics are not laws, but they are part of the social contract that we live by. They are the rules of politeness, unselfishness, and humanity that lubricate our interactions with others, creating trust and harmony. In the absence of laws, ethics are the only thing preventing a “tragedy of the commons” effect, a race to the bottom, from occurring. Adherence to the ethical standards of the community is what caused these buildings to stay on the market so long.
In the cases of Stewart Motors and the Clinton Campbell House, either the new owners did not recognize that the buildings were important to the community, or they didn’t care. If the former, they are negligent in not doing the depth of research on the property they should have, and the community was negligent in not making their importance more obvious. But I fear the latter is more likely. In the absence of laws or zoning regulations to halt bad actors, it is up to the community to communicate and enforce the ethical standards we expect people to live up to.
To the development community, I say: please be aware that the set of historic buildings that the community cares about is much larger than the set of buildings that have preservation overlays on them. You should expect resistance to their destruction, even without protections being written into law. The community expects you to do right by our historic buildings because when you are doing development work in an urban context, there needs to be a cooperative process where everyone comes out a winner, as much as is possible.
And to the community, I say: we need to do a much better job of identifying, recognizing, celebrating, and publicizing all our historic building stock, whether or not formally recognized. Without such recognition, it is far too easy for developers to claim ignorance in defense of a development scheme that requires demolition of an historic building to pencil out economically.
Most Valley residents know Grand Avenue as the diagonal street standing out from the metropolitan grid like an arrow pointing to downtown Phoenix. But they may not be as familiar with the most interesting neighborhood in the city, Historic Grand Avenue, the southernmost mile of this fifty-mile road.
Historic Grand hit a low point in the 1980s and 90s, but bounced back through the efforts of hardy artists and entrepreneurs looking for affordable rents and inspiration. That success could now be its downfall, as real estate investors look for the next trendy area to redevelop. Will the hard-fought gains of the last twenty years be lost?
The last few years of changes on Roosevelt Row (known to downtowners as RoRo), a neighborhood with a similar history just a mile away, have amplified this concern. Redevelopment of RoRo kicked into high gear in 2016. Down came many little old buildings and up went five-story, full-block urban residential developments. Rents have risen, driving out small local coffee houses, boutiques, and galleries. It’s a pattern seen over and over in America’s gentrifying urban centers. What can Historic Grand learn from RoRo? And most importantly, is gentrification the inevitable fate of every Bohemian neighborhood, or can we do better?
What’s so special about Historic Grand
Historic Grand is a neighborhood like no other – a rich stew with a flavor that transcends its ingredients. If the object is to save it from predatory development and its side effects, it’s important to understand what it is about Historic Grand that merits saving.
The diagonal of the street itself, forming angled intersections and pie-shaped building lots, is the canvas of the neighborhood. Such a street is a stark contrast in a city of right angles. When you drive on Grand, you know where you are.
Homes and businesses grew within this cockeyed framework over the first seventy years of the 20th Century. In the same block, you will find some historic buildings and some “vintage” buildings – but very few new buildings. As Grand developed, things were constantly churning – buildings being built, others being torn down, some being remodeled – until about 1970, when highway traffic started to be diverted onto the Interstates. Then nothing happened, for a long time.
If location is important, you couldn’t do much better. Grand Avenue’s front door, historically known as Five Points, lies at one corner of the downtown central business district. That provides excellent access to all the services downtown, as well as potential shoppers and clients.
One of the most important qualities of the historic environment is its fine-grained texture. Blocks on Grand average about 500 feet long, but the average building or lot has a frontage of only about 100 feet. From a pedestrian’s perspective, you are encountering something different every 20 seconds or so. Contrast that with typical full-block developments that bore you for two minutes at a brisk walk.
In 2012-13, the “Greening Lower Grand Avenue” plan created Phoenix’s first “complete street” along Historic Grand by reducing traffic lanes to one in each direction and adding bicycle lanes, curbside parking, and raised planters in the street that have been decorated by local artists. While the street looks more inviting and colorful than it did before, this configuration has also slowed and reduced traffic on the street, contributing to walkability. Landscape enhancements to the plan are still being developed.
So the street, the buildings, and the other improvements offer something unique to Phoenix. But what really makes Grand special are the people.
Historic Grand is a model of economic and ethnic diversity. It is home to artists, merchants, beauticians, wholesalers, professionals, brewers, landscapers, musicians, restaurateurs, luthiers, and mechanics, to name a few. Grand together with its adjacent residential areas represent an affordable place to live and work close to downtown. This kind of diversity is important to the life of the city.
Much has been made about the impact arts and artists have on any community or neighborhood. In Historic Grand, art is found not only indoors within the galleries that have made Grand their home, but also in murals, planters, crosswalks, and yarn-bombed trees and street improvements.
It’s the people who make the art. They also make wonderful events. The area pulses on First and Third Fridays and ArtWalk, and hosts a significant crowd during the Grand Avenue Festival in the fall. If you lose the people, you lose these events.
All of the properties along Historic Grand are privately held by a wide variety of owners and investors. These properties can and will be bought and sold, and some buyers may only be interested in the neighborhood assets to the extent that they improve their own property value. Very few buildings have any level of historical protection, and it’s always easier to tear down and build new.
Can this development be controlled, or at least shaped? Can we keep the street welcoming to pedestrians? Can we keep the funky buildings, historic and otherwise? And can we keep rents affordable for homes, art space, and small businesses?
I think we can. I’ll share my ideas in Part 2 of this article.
Robert Graham is President of the Grand Avenue Members Association and the Grand Avenue Rail Project, but the views represented in this article are strictly his own and do not reflect the official position of these organizations.
So you want a 20% tax credit for rehabbing a historic building? You won’t get past square one if you can’t prove your building has historic cred.
In my prior post, “Historic Preservation Tax Credits: Worth the trouble if you know how to get them,” I gave an overview of the federal Historic Preservation Investment Tax Credit (ITC) and when it may be an appropriate tool for enhancing the financial package for a renovation project. In this article I will review the first step in the three-step process by which a project achieves status as a “certified rehabilitation” and becomes eligible for the ITC.
The three steps to certification relate directly to the National Park Service (NPS) Parts 1, 2, and 3 certification forms that are filed to prove that your project qualifies for the ITC. In Part 1, you are establishing that the building you’re working on is historic. Part 2 outlines in detail what work will be performed on the building and how it meets preservation standards. Part 3 documents the finished project and requests certification.
The challenge and the strategy
Getting approval from the Parks Service for your Part 1 filing could be hard or easy, depending on the circumstances around your building. Simply stated, your building must be listed in, or eligible for, the National Register of Historic Places. That may sound onerous, but it’s really not as big a hurdle as you may think.
If you are considering applying for the historic rehabilitation ITC, presumably you either know that your building is listed as historic or you suspect that it might be eligible. I’ll go over three cases: a property that is listed in the National Register of Historic Places, either individually or as part of an historic district; a building that has been determined eligible or likely eligible to the register by a past survey; and the third case, what I would call an “unrecognized” historic building that may be eligible, but that has drifted along under the radar. Each case requires a different approach to getting your Part 1 form approved.
Like most things in life, your best approach is to make sure you have done your homework. Gain a full understanding of the history of your property and how it fits into the larger history of the place. Become an expert on these subjects, and you will have a much easier time convincing others of the historic value of your property.
It’s a good idea to bring your State Historic Preservation Office (SHPO) representative into the process as early as possible and recruit him or her as an advocate for your project. (Arizona SHPO’s page linked here.) They have an interest in seeing that your project get tax credits, because it helps to justify the value of their preservation program politically. Their role in the process is to provide the first line of review, and in effect serve as the field agent for NPS. Your initial discussions are with a SHPO representative. They will review and comment on your form submissions and construction plans, and will be the one forwarding your documents to NPS. Of particular relevance to this article, your SHPO is the best source of guidance about whether or not your building is historic, and an ITC candidate.
National-Register listed buildings
If your building is already listed, then the Part 1 form is a mere formality. All you need to know is the name of the property, the date of listing, and whether it was listed individually or as part of a group (an historic district).
Eligible buildings not yet listed
Because the National Register nomination process costs money and time, many buildings have been identified in the course of local historic surveys as being eligible to the National Register but which have never actually been nominated. In most cases, those surveys include a certain amount of historical background research that provides the context for the recommendation of eligibility. The survey usually says explicitly why a given building is recommended eligible. This initial information is a valuable head start on showing NPS that your building is eligible, but is often not definitive. In most cases, additional research will need to be completed to flesh out the details of the building’s history and the historical context under which it is considered eligible.
In order to claim your tax credits when your project is complete, your building will need to be listed in the National Register, and that will require a nomination form to be prepared. Don’t wait to get this started. The best proof to NPS that your building is historic is to be able to show them the nomination, even if it has not yet been fully reviewed or approved.
The Part 1 form documents the same types of information that would be eventually submitted for National Register listing but in brief, narrative format. It boils the question down to two short statements: a “description of physical appearance” and a “statement of significance.” If the case for eligibility is simple and strong, then just submitting the information gleaned from past studies or surveys can be enough. After the summary information has been submitted, NPS will let you know if they agree with your eligibility claim.
Sometimes NPS does not agree. Don’t take an initial rejection too seriously! In reviewing a Part 1 form they are making a judgment on very little information. Providing them a copy of your full, draft National Register nomination at that point can make a big difference.
There are many buildings around the country that are National Register material (and thus candidates for the ITC) but which have not been recognized or surveyed. Here are some of the categories of buildings that could present hidden opportunities for a rehabilitation project using the ITC.
Newer buildings: 50 years is the usual cutoff age for historic consideration. For this reason, historic surveys don’t normally consider younger buildings, and as time marches on, more and more buildings reach that magic 50 year birthday and need a fresh look. As of 2016, buildings constructed between 1956 and 1966 have only recently been old enough to be considered for their historic value – and many of these have never been evaluated.
Building types that have become rare: The conditions around which buildings are evaluated for historic status can change over time. Ordinary-seeming buildings that are old enough to qualify, but are deemed to lack importance, may be skipped over by historic surveys. Consider the case of just such an unremarkable and common old commercial building that was built in a typical downtown. If the area around it is redeveloped, tearing down so many of its neighbors that it becomes one of the last of its kind … suddenly it becomes a lot more important.
Buildings with reversible alterations: Old buildings are frequently passed over in historic surveys because they no longer represent their original architectural appearance. Some common alterations include “re-facing” a building, filling in door and window openings, or making additions to the front side. By National Register rules, if you can’t see the building’s important architectural features, they can’t contribute to its character and the building is ineligible. But what if you were to remove the covering, or open up those old window openings? That’s a different story. If you can show that enough of the original historic features are present and visible to collectively define the historic appearance of the building, it can regain eligibility.
Flawed or incomplete surveys: Historic surveys aren’t perfect. Sometimes important buildings are passed over for any number of reasons, such as incorrectly identifying the building age, or failing to uncover an important bit of data, such as who the architect was or that it was the home of an important person.
In each of these cases, proving the eligibility of an unrecognized resource will require some research and understanding of how the arcane rules of the National Register are applied. If you are not knowledgeable about the criteria then it can be difficult to tell an eligible building from an ineligible one. Fortunately, your state or local historic preservation office or a qualified preservation consultant can offer guidance.
This was the easy part
In most cases, proving that your building has the qualities necessary to be considered historic is just a matter or proper documentation. You can usually receive approval of your Part 1 form within a month or so from NPS. The real challenges are in formulating your project approach and gaining approval of your Part 2 form in the ITC process, which will be the subject of the next article of this series.
One of the most powerful financial tools in the preservation toolkit is the federal Historic Rehabilitation Investment Tax Credit (ITC). Qualifying a project for an ITC can be difficult, but the reward is recovering 20% of your building improvement costs in the form of income tax credits. This article will give an overview of the rules, benefits and liabilities of attempting a certified rehabilitation. In later articles I will address the process in more detail, and review some of the common pitfalls to watch out for that could derail an otherwise worthy project from being certified.
As a disclaimer, I’m an architect who has been doing preservation projects for 30 years, so I have been around ITCs for some time. But I’m not a CPA and I’m not an attorney; if after reading what I have to say about the ITC you are inspired to do a certified rehabilitation, you’ll need advice from those professionals as well.
The Historic Preservation ITC provides for direct tax credit of 20% of the investment in a certified historic building undergoing a substantial, certified rehabilitation. In essence, if you plow a million dollars into fixing up a building that’s eligible for the National Register of Historic Places, you can recover $200,000 in forgiven taxes – using just this one incentive.
Of course, there are strings attached – and a process that many find to be daunting and incomprehensible. But with a little foresight and the right team, you can cover any increased costs many times over.
What kind or project is eligible? In short, the project must involve a registered historic building that undergoes a “substantial rehabilitation” that conforms to the Secretary of the Interior’s Standards for Rehabilitation. Let’s address each part of those requirements in more detail.
Any income-producing, commercial building that is listed in, or eligible for, the National Register of Historic Places could be a candidate for the ITC. The building doesn’t have to look like much, or even be individually listed; it could just be a contributor to an historic district. Most local governments and the State Historic Preservation Office (SHPO) keep track of what’s already listed and have surveys of places that are eligible, but not listed yet. There are also lots of other buildings around that could be eligible, waiting for someone to come along and do the research and paperwork necessary to get listed. The same governmental entities can usually render an informed opinion if there is any doubt. A good consultant can also advise you with some degree of assurance.
The ITC is intended to encourage re-investment in historic buildings that are currently underutilized. So, to qualify, the project must be a “substantial rehabilitation,” in which the investment in improvements is worth at least as much as the value of the building (not including land) before rehabilitation (technically, the “adjusted basis”). This requirement tends to exclude small projects like tenant improvements and quick fix-and-flips. What they really want to see is a project that is transformational – that reverse years of deterioration and neglect and put the building back into service.
The standards that must be met in order to be named a “certified rehabilitation” are what many developers and their architects find to be hardest to understand. The
Secretary of the Interior’s Standards for Rehabilitation can be thought of as the “ten commandments” of the historic preservation approach. The intended affect of the Standards is to allow certain kinds of changes and updates to be made in order to keep (or return) a building in service, while still protecting the very qualities that make it qualify as an historic building in the first place. If you have an eligible historic building and you follow the standards, it will still be eligible after you have completed the work.
Rehabilitations are certified using a 3-part process that I will cover in more detail in a later article. In the first step, you establish that the building itself is eligible for the program. In the second step, you document what you plan to do, and in the last step you show that you did it. Each of these steps is reviewed by the SHPO (largely advisory) and then by the National Park Service (which actually decides if you have met the bar).
The obvious benefit of a certified rehabilitation is the tax credit itself. That credit can be carried back one year, and best of all, can be carried forward 20 years. And if the ownership entity does not pay enough in income tax to make a 20% credit worthwhile, or doesn’t want to wait that long to recover the funds spent out of pocket, it’s good to know that there is a secondary market for these credits and that they are transferrable. Even nonprofit entities that don’t pay any income tax at all can take advantage of the ITC by partnering with for-profit investors to whom the credits can be assigned.
There is some risk of failure, particularly if your project needs to stick to a tight schedule and you have to proceed with construction before you have received approval from NPS. At a minimum, you will have spent some money on consultants to register the building and to do the paperwork to apply for the credit. You may have compromised the function or size of the project in an attempt to make it “certifiable,” and you may have incurred significant additional construction costs in preserving things that would have been cheaper to replace (or demolish). For these reasons, it’s always best to get your project certified before it is built.
If you have incurred some of these sunk costs and then are denied certification, all is not necessarily lost. If the reasons for NPS denying certification are minor, then it may be worth re-doing the part of the design that they object to. If not, then there is also a back-up plan: the 10% rehabilitation ITC. A 10% credit is available to ANY rehabilitation of a non-residential building constructed before 1936 – the building does not have to be certified historic, and the rehabilitation does not have to be certified by NPS.
Knowledge is power and the risks of embarking on a project using the Historic Rehabilitation ITC can be controlled. Make sure that you fully understand the requirements of the program, and hire an architect and contractor that “get it” and won’t do something that will disqualify the project. If your architect doesn’t have the in-house expertise to get your building listed as historic, apply preservation standards, and guide you through the ITC process, there are preservation consultants who can fill this gap in the team.
In May 2016 Empire angered the downtown community when it initiated demolition of the historic car dealership after their initial plans for a 19 story apartment project (which would have resulted in the demolition of as much as 75% of the building) met with resistance that, in their view, threatened their right to tear the building down at will. The inevitable storm of bad PR caused by the surprise demolition work caused the city of Phoenix to immediately pull out of negotiations with Empire to receive city support for their project.
Finding themselves suddenly cast in the role of Evil Villain Developer, Empire turned a complete one-eighty, firing their zoning attorney and blaming him for the “poor advice” that they accepted when calling in the bulldozers. The developer’s new representatives, the Rose Law Group of Scottsdale, embarked on an apology tour in an attempt to get the project back on track.
In a series of meetings with various groups, lead attorney Jordan Rose assured community leaders that the demolition was all a mistake that wouldn’t be repeated; that CCBG, the architects for the project, were already working on a new, exciting approach that would address all of the community concerns; that the new design would be so fantastic that project opponents would be amazed at the total transformation from the original plan, and would become its biggest supporters; and that the project wouldn’t move forward until it received said community support.
Empire’s hostage-taking approach following the public resistance to its first plan led preservationists to view their later overtures with suspicion. But in the interest of preserving one of the last pair of endangered car dealerships on Central Avenue, many were willing to withhold judgment until the developer shared the new plan.
Rose was informed that the community only wanted one thing: that the Stewart Motor Co. building be preserved.
“Preserved” in the sense that it would remain eligible to the National Register of Historic Places. It’s a plain, simple, cut-and-dried criterion for gauging whether or not the community’s desire has been addressed.
A quick aside about historic preservation
A working knowledge of historic preservation basics is important to evaluating whether or not Empire’s proposal meets the goal of “preserving the building.” How do we decide what’s historic, and what’s not? And how do we define what changes you can make without ruining those historic qualities?
For a building to be considered “historic,” it’s not enough to just be old. It must have two essential qualities: significance and integrity. These are the criteria used by the National Register to decide whether or not a property is worthy of listing.
Significance is pretty easy to understand – it’s the important “story” that the building tells. In the case of Stewart Motor Co., there are actually two areas of significance. First is the building’s part in the history of the Central Avenue “Automobile Row” and as a focus for auto sales. The second is as an important local work of architecture.
Integrity is a little slipperier. Some think of integrity as a measure of how much a property has changed since it was built, but that’s not totally accurate. Technically, it’s the ability of the building to “convey its significance.” So for a building to convey the significance of its architecture, the individual features that were important elements of the original architect’s vision all need to remain, in recognizable condition. And when we’re talking about “vision” and “design,” we are talking about the whole building, not just what some have called “the iconic elements,” and not just facades. In order to convey the building’s significance to the history of this part of Central Avenue, it needs to retain (recognizably) all of the elements that mark it as a full-service auto dealership of the 1940s and 50s – not just the showroom – and enough physical, surrounding context so that people can recognize its place in the larger streetscape.
The Ten Commandments of the preservation world, the “Secretary of the Interior’s Standards for Rehabilitation,” were written to guide designers on what changes could be made and still retain the historical integrity of the building. The purpose of all of this is to identify a clear, unambiguous criterion to maintain pieces of our shared history in a way that they continue to “tell the story.” Because if you can’t tell by looking at a building what it is and how it’s related to our history, then what’s the point? Worse yet, if the building is changed in such a way that throws it completely out of context or implies a different back story, will future residents of our city get a completely wrong idea about our history?
Empire’s June 2016 proposal
In early June, the developer’s architects and attorneys unveiled the much-anticipated revision. While the building addition’s general form, height, scale, and massing are unchanged, it’s apparent that significant time and effort has been paid in the development of details and features aimed at increasing the project’s compatibility with the historic core’s architecture and the project’s place in the south Roosevelt neighborhood.
The biggest and most positive change has been the new commitment to preserving all of the building’s facades along Central Avenue and McKinley Street. However, because the footprint of the new apartment tower is closer to the street than the front of Stewart Motors, the north half of the historic façade ends up as one side of an interior space behind a glass curtain wall.
Another new commitment is a significant investment in local art. The entry would be marked by a flaming Pete Diese steel sculpture (his largest to date). Otherwise-dead areas of the parking garage would be enhanced by huge murals the size of (or perhaps emulating) billboards.
Presentations were made by the development team to a variety of stakeholder groups. A consensus appears to have reached that while “The Stewart” is an improvement from “Circle on Central,” the project still has not addressed the community’s greatest concern for preserving the building, nor has it provided more than lip service to a grab bag of potential mitigating features. The neighborhood group representing the area, the Roosevelt Action Association, summarized this in a July 25 letter to the city. RAA has declared “an impasse,” essentially giving up on talking with Empire because they aren’t listening.
So why, with all these improvements, is the project still unacceptable? Because it does not meet the simple criterion communicated to the developer that the Stewart Motor Co. building be preserved. Instead, it seems to be doing everything except for the one thing that the community requested.
On July 28th the developer’s attorneys issued a rosy response (pun intended) to RAA’s letter, putting a positive spin on each of RAA’s objections. This letter reveals a remarkable disconnect in communication between the sides while shining an interesting light on their future strategy toward achieving a GPLET tax incentive from the city.
The first item RAA discussed with the developer, in RAA’s words “to no avail,” was the “further preservation of the building.” In the response, Rose expresses agreement with this goal but goes on to defend the proposal as it stands – that the new design “preserves the most significant as well as recognizable portions of the building” and using the analysis (but not explicit support) of its paid preservation consultant to provide a fig leaf of legitimacy to a design that would make the building ineligible to historic registers. A Wyoming defective product attorney firm weighed in to say that, not only would the project still demolish at least two thirds of the fabric of the building, the most interesting feature of the new design – the encasement of a portion of the façade behind glass – would radically change the context of the facade and result in “head in a jar” preservation.
That RAA was hoping to be presented with “alternative design solutions” met with similar “agreement” and a non-responsive defense of the current design. I believe that the neighborhood was hoping for more than a skin-deep façade remodel of Circle on Central, and be presented with designs that actually changed the form of the building, but this distinction appears lost on Rose.
RAA members apparently also put funding for historic preservation on the table. This desire is understandable due to the unfortunate lack of funding for the preservation office in the city and state, and the developer has leapt on this item with a commitment “to provide substantial funding to the Historic Preservation Office.” As an element of a development deal, this arrangement appears to be ill-advised, as it sets a couple of bad precedents: 1) that our historic buildings are for sale, and 2) kicking back public subsidies to fund preservation rather than working through the traditional channels is acceptable. (Personally, I believe it was an issue worth discussing in a brainstorming session but should be discarded.)
Rose’s letter puts similar spin on RAA’s ideas to include museum space (RAA: 3,000 square foot historical museum; Rose: museum-quality exhibits, no area commitment) and alternative funding sources (by which RAA probably mean preservation grants and tax incentives and Rose appears to mean GPLET).
Divide and conquer
As reported in the Downtown Devil, the RAA has publicly disavowed the areas of “agreement” implied by Rose’s letter of July 28, but that has not put an end to the campaign to get back into good graces with the city. While city representatives have stated that they don’t intend to restart discussions with the developer at this time, that stance could change if Empire can show support in the community for the project.
It appears that the strategy now is to drive a wedge into the opposition between “preservationists” and “artists.” Compared to Circle on Central, The Stewart is tailor-made to appeal to our local arts community as much as it alienates preservationists. Several in the arts community report being contacted for “one on one” meetings with the development team in order to “get their input” – or perhaps to gauge what it would take to get their support. A similar effort is being mounted to push the “affordable housing” potential of the project, which could splinter off the pro-urban members of the coalition.
A cynic could get the idea that Empire believes that the artists and “urbanistas” can be successfully bought off by purchasing some of their art and throwing in a few below-market units, opening the way for a new run at the city to secure the estimated $15 million in GPLET value for their project. That would be a tragedy for the unity of our downtown community that, if successful, would set the worst precedent of all.