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Preservation alliance for greater Philadelphia 1616 Walnut Street, Suite 1620

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for greater Philadelphia

1616 Walnut Street, Suite 1620

Philadelphia PA 19103

December 6, 2007

Barbara Franco

Pennsylvania Historical and Museum Commission

Commonwealth Keystone Building

300 North Street

Harrisburg PA 17120
Dear Barbara,
Thank you for providing the Preservation Alliance with copies of the materials submitted to PHMC by the Pennsylvania Convention Center Authority regarding the proposed demolition of the Philadelphia Life Insurance Co. (PLICO) building and its annex. As you know, this is an issue of great importance to the preservation and architectural communities in Philadelphia. The preservation of the PLICO building and annex is important not only for the significance of the buildings, but because they, along with the Liberty Trust building, consist of an ensemble of historic structures that is important to the urban design character of Broad Street and helps to create a transition for the new convention center to the historic character of the area on the north side of City Hall.
For this reason it is appropriate for information regarding these buildings to be available to the public in a manner that allows for comment before PHMC makes a decision to amend the Memorandum of Agreement (MoA). When you provided me with the current reports I did not know if this information was being publicly released to others as well. I have therefore not distributed the information you provided to me, although I have consulted with a number of different parties concerning the information in the reports.
It is the Preservation Alliance’s opinion that these reports do not provide PHMC with sufficient information to justify the demolition of the PLICO building and its annex. We therefore recommend and request that you do not agree to modify the MoA to allow the demolition of these two properties. Our reasons for this recommendation, discussed more fully in the attached memorandum, include:

  • The Convention Center Authority did not really obtain an independent engineering assessment of the buildings. The closes thing to an independent assessment is the I-Tan Yu Associates report, which was limited in its scope.

Page 2

  • The I-Tan Yu report is found the PLICO building to be structurally sound and the steel and joists of the annex to be sound as well. The Convention Center

Authority ignores this report and its findings in stating its case for demolition and relies solely on the August report of Tantala Associates.

  • The letter and reports do not indicate that there was any consultation with the engineers and architects who have worked on this project (CSA Associates, Kelly/ Aiello, and Keast & Hood) and have developed plans for rehabilitation of the buildings based on first-hand knowledge of the buildings as a result of numerous inspections of the buildings over the two years.

  • The $9 million cost estimate to construct a steel frame to support the PLICO facade is not documented in any way and is substantially inconsistent with the $1.2 million cost of erecting a steel frame of virtually the same character and size for the retention of the façade of the Rittenhouse Club.

  • The support of the preservation community in Philadelphia, including the Preservation Alliance, for the demolition the other historic buildings, as well as the support of the Philadelphia Historical Commission for the demolition of the Fire Station, was based on the total preservation agreement reflected in the MoA. Preservation of the PLICO building and its annex were fundamental to the support of the demolition of the other historic buildings.

It is our view that PHMC should consult directly with the engineering and architectural team that has prepared the rehabilitation plans for these two buildings. They are highly qualified professionals, with greater experience in historic preservation than either of the engineering firms the Convention Center Authority has engaged on this matter. If that team felt that the buildings had to be demolished I am confident that they would have reported that to the Authority. The fact that they did not and went ahead and prepared rehabilitation and stabilization plans suggests that they felt that the facades and 20 feet of the buildings specified to be preserved in the MoA can be preserved.

Lastly, let me note that the MoA states that PHMC will consult with the Preservation Alliance along with several other organizations in Philadelphia regarding the use of the $1 million. The Preservation Alliance would not support the idea implied in the Convention Center Authority’s letter that the $1 million mitigation fund be used for these properties. Moreover, we feel that the proposal to add $250,000 to the mitigation fund if demolition is approved is inadequate. Had it been known at the outset that all 18 buildings would be demolished, the Preservation Alliance and other organizations would have sought a mitigation fund of at least $2 million.
Thank you for the opportunity to provide these comments and recommendations.
Page 3


John Andrew Gallery

Executive Director

cc. Wayne Spilove, chair

Joseph Resta, Convention Center Authority

Adrian Fine, National Trust for Historic Preservation

Shawn Evans, co-chair, AIA Historic Preservation Committee

Alan Greenberger, Design Advocacy Group

Submitted by the

Preservation Alliance for Greater Philadelphia

December 6, 2007

Prepared by John Andrew Gallery, Executive Director


These comments are based on the Preservation Alliance’s review of the following items submitted to the Pennsylvania Historical and Museum Commission:

  • Letter from the Convention Center Authority dated November 21, 2007;

  • Two reports from Tantala Associates dated August 8, 2007 and October 8, 2007;

  • A report from I-Tan Yu Associates dated November 9, 2007;

  • A letter from Vitetta dated November 20, 2007.

In preparing these comments we have consulted with a number of individuals familiar with the Philadelphia Life Insurance Co. building and annex.


In September 2007, the Preservation Alliance contacted PHMC and asked that it obtain an independent assessment of the PLICO building and annex. The intention of this request was for PHMC to obtain an assessment of the buildings that re-examined the issues raised and conclusions reached by the Tantala Associates report of August 2007 on which the Convention Center Authority and DGS were basing their decision to demolish the buildings. PHMC made such a request to the Convention Center Authority and DGS. The information presented in the Convention Center Authority’s letter of November 21, 2007 is intended to be a response to that request. The following memorandum discusses the information presented in these reports.


1. The Convention Center Authority letter indicates that the Authority considered using CSA Associates to evaluate the buildings, but decided to select another consultant because “L&I suggested that Hill engage the services of Tantala Associates.” (page 4) Commissioner Robert Solvible of the Dept of L&I indicated to me on December 5, 2007, that he has no knowledge of such a recommendation. It would be highly unusual for the Department of L&I to recommend a specific engineer in a matter where there were L&I violations involved. An individual L&I inspector may have suggested a firm, but it does not appear to us that it is accurate to say that L&I recommended a specific consultant.

This is important because in undertaking its assessment in August 2007—and in all assessments up to the present date—the Convention Center Authority has not consulted with the engineers and architects most familiar with the condition of these buildings—CSA Associates and Kelly/Aiello Architects. Contrary to the statement on page 3 that the Authority did not have “the benefit of structural analysis or detailed assessment of the facades since neither PCCA nor the Commonwealth had ownership or access to the buildings,” it is my understanding that both CSA Associates and Kelly/Aiello Architects had been in the buildings at least two dozen times beginning in 2005 and up through 2007. In fact, it is my understanding that Hill International conducted probes in the buildings in January 2007 at the request of CSA Associates.
CSA Associates and Kelly/Aiello clearly had a need to assess the buildings in order to prepare the rehabilitation plans, which have been completed. It is my understanding that these plans included plans for what would be required to shore the buildings up during demolition and what would be required for rehabilitation. I am led to believe that the total cost for that work was estimated at $2.5 million.
Given what would appear to be extensive knowledge on the part of these consultants there was no sound reason for the Convention Center Authority to go to another consulting firm in July 2007 to get detailed information about the buildings. Moreover, it is my understanding the CSA Associates also consulted with Keast & Hood on these buildings. CSA Associates, Kelly/Aiello, and Keast & Hood are all highly qualified professional firms with considerable experience with historic properties. If there were serious structural problems with these buildings that would preclude compliance with the MoA there is little doubt that these firms would have discovered that and have reported that to the Convention Center Authority. They did not. They proceeded to develop rehabilitation plans based on their first-hand knowledge of the buildings through numerous inspections over several years.
2. The Convention Center Authority did not conduct an independent assessment of the condition of the buildings as requested by PHMC. The authority went back to Tantala Associates for a second opinion. This was inappropriate since the idea of an independent assessment was to get a professional evaluation of the August report prepared by Tantala Associates. The October report by Tantala is irrelevant and adds nothing new. The engagement of I-Tan Yu Associates was an engagement of an independent consultant. However, the scope of I-Tan Yu’s work was narrowly defined and limited to a visual inspection based on what appears to be two walk-throughs of the buildings. Nonetheless, I-Tan Yu’s report is strikingly different from Tantala's, a fact that is totally ignored by the Authority in its letter.
I-Tan Yu concluded that as to the general condition the PLICO building “the building appeared to be structurally sound with no significant visible signs of distress.” This clearly contradicts the Tantala report and supports the apparent conclusions of CSA Associates. The I-Tan Yu report indicates that the steel and joists in the annex building are sound as well. There is no statement in their report that the annex building is structurally unsound or imminently dangerous. The report documents that there are collapses in the roof, but these collapses are in the rear of the building, well beyond the 20 feet depth to be preserved with the façade.
I-Tan Yu’s report suffers from the deficiency noted above that there was no consultation with CSA Associates and Kelly/ Maiello in spite of the fact that the report indicates that I-Tan Yu was provided with copies of the rehabilitation plans. This, as noted before, is a gross oversight of the analysis of these buildings by the Convention Center Authority. .
3. In justifying its recommendation that the buildings be demolished, the Convention Center Authority states (page 7):
“ We now know, however, based on independent engineering reports that Building #3 (including the façade and front bays) is imminently dangerous and has reach the end of its serviceable life,…. With regard to Building #2 we now know that the façade is in relatively sound condition, but the front bays are structurally unsound“.
These statements are not correct. As previously noted the Tantala report does not constitute an independent assessment—its August report is the report that was intended to be assessed by another consultant. Yet all these statements are taken directly from the August 2007 Tantala report and none of these conclusions are found in the I-Tan Yu Associates report. The Convention Center Authority has completely ignored the findings of the I-Tan Yu report (the only independent report it undertook). Moreover, the Department of L&I has repeatedly stated that its inspection in summer 2007 did not suggest that the buildings needed to demolish. And one must assume that neither CSA Associates nor Kelly/Aiello found that the buildings needed to be demolishes since they did not recommend so and proceeded with rehabilitation plans. Therefore, the statement of the Convention Center Authority quoted above is not supported by the facts.
4. The I-Tan Yu report indicates that a steel frame would need to be constructed to protect the façade of the PLICO building during demolition. The report does not indicate that an alternative of interior stabilization was examined as appears to be an approach that CSA Associates thought was feasible. Here again the absence of any evaluation of the CSA plans or engagement of them in this process is an oversight.
The Authority’s letter indicates that the cost for this steel frame is estimated to be $9 million. This figure is not supported by any detailed documentation. This figure is substantially out of line with the cost of creating the steel frame to support the Rittenhouse Club façade. That façade is approximately the same size and had the same issues as the PLICO facade. Information provided by the developer of the 10 Rittenhouse project indicates that the cost of the structure was approximately $1.2 million. While the subway tunnel may be an issue, the primary steel supports could be placed on the east side of the façade where the subway would not be an issue.
5. The Vitetta memorandum draws its conclusions from the engineering reports and not from first-hand inspection of its own. It does not acknowledge the discrepancy between the I-Tan Yu report findings and the Tantala report and consequently it draws conclusions that are not necessarily supported by a full view of the facts. It’s conclusions are also based on the fact that the $9 million cost estimate is accurate, something which seems out of line as previously noted. Had these matters been pointed out to Vitetta it is possible that a different conclusion might have been reached.
Mr. Myers’ statement that “facadectomies” are not generally supported by historic preservationists is true to some degree, but not in all cases. The example he mentions—the Park Avenue properties of Temple University—is a clear indication of this. Mr. Myers himself recommended preservation of those facades, the Preservation Alliance supported that approach and the Historical Commission approved it. Recently, the Historical Commission approved in concept the demolition of two historic buildings with retention of the facades only for a project on Locust Street. The Historical Commission, represented by Dr. Richard Tyler, executive director at the time, reviewed and supported the MoA and the preservation of the facades of the PLICO buildings. Therefore, Mr. Myers conclusion that it would be better to demolish these buildings rather than retain the facades represents a personal point of view and is unsupported by the views and actions of preservation organizations in Philadelphia.


There has been no independent assessment of the overall conditions of the project.

The closest thing to an independent assessment is the I-Tan Yu Associates report, which finds the PLICO building to be structurally sound, the steel and joists of the structure of the annex to be sound.
There is no support for a conclusion that either building is structurally unsound to a degree that would preclude compliance with the MoA.
There has been no consideration of the findings of CSA Associates and Kelly/ Aiello both of who appear to have concluded that the facades and 20 feet could be preserved and rehabilitated.
The cost estimate of $9 million is unsubstantiated and significantly at odds with the actual costs of a similar installation for the Rittenhouse Club.
The preservation community supported the preservation of these facades both for their importance and for the preservation of the character of Broad Street in this area.
Based on these findings, PHMC should not agree to amend the MoA to allow for demolition and should continue to request that the Convention Center Authority and DGS comply with the intent of the MoA with respect to the PLICO building and its annex.

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