September 26, 2001

Missouri Advisory Council on Historic Preservation
Historic Preservation Program
P.O. Box 176
Jefferson City, MO 65102

Re: Forest Park Southeast Historic District

Dear Advisory Council Members:

   I write to you on behalf of the Forest Park Southeast Community Council to oppose the nomination of Forest Park Southeast Historic District because, as the Council sees it, the application of historic tax credits in the neighborhood will discriminate economically and racially against a majority of the neighborhood's residents.

   In 1999, the Council had 40 members and attempted to represent the whole neighborhood. Some members were "at-large" while other members represented geographic areas, service providers, businesses, or clergy. (The composition of the Council changed over time because some members agreed to make the Council dysfunctional by depriving it of a quorum; details may be found by going to the neighborhood web site set out in the letterhead.)

   The Council adopted a draft plan that had an equalized approach to physical improvement of the neighborhood, namely the simultaneous improvement of all buildings in each of four selected blocks (one block in each quadrant). Upon completion of the first blocks, new blocks would be selected. This equalized approach grew, in part, from a perception of longstanding favoritism for one quadrant of the neighborhood where, generally, all the higher-income families lived.

   The draft plan adopted certain principles including (quoting page 3): 1. Reinforce and revitalize Forest Park Southeast as a traditional, mixed-income St. Louis neighborhood . . . ; 2. Provide a variety of housing types and prices ranging from subsidized rental to home ownership along the continuum from low-income to market- rate; . . . and 9. Ensure that residents have an effective leadership role in guiding both the development of the design of their neighborhood and the implementation of the plan.

   Approval of the pending nomination will contribute to the disappearance of the equalized improvement and the plan's stated principles into the bait and switch of business as usual, which is epitomized by the Park East project that motivates the nomination. The Park East project, undertaken by the Forest Park Southeast Housing Corporation, bought out one landlord, acquiring scattered sites, primarily in the long-favored quadrant of the neighborhood. Worse yet, it appears that Park East and other redevelopment tends to displace low-income FPSE residents.

   We realize that historic tax credits are available to any property owner. The practice is that most of the credits go to multi-million dollar projects. Working homeowners cannot cope with the professional services required to plan and carry out a program-compliant rehabilitation. Often they will not be able to afford or even obtain the new debt of half the basis of their property. Even if Park East is not the only applicant for benefits under this nomination, it will soak up almost all of the benefits ever applied for in the district.

   Already general economic conditions result in evictions and homelessness for neighborhood residents. Park East's implementation has already caused more. The project's pledge of units for families whose income is 60% or less of the Area Median Income is little solace, given that over 50% of the households have annual incomes of less than $15,000. These families may be eligible for the new, improved units, but they will not be able to afford them.

   The Park East developers say they are "working closely" with Urban Strategies to assist tenants in locating alternatives. It turns out that "working closely" was no more than an unspecified "offer to help." The Park East developers say relocation benefits are not required because there is no government funding. Aren't tax credits real public money? We are also concerned about the "vigorous screening" of new tenants that the Housing Corporation says it will use. Credit and police histories are common for our residents. The screening will make them former residents, disproportionately by race because of law enforcement history.

   We realize that natural economic trends will change the economic mix of the neighborhood. Redevelopment should not accelerate the trend. Rather it should slow the trend by supporting present residents. We wish there was a way to condition the granting of the historic credits -- which come from the tax dollars of all of us -- for the further advantage of the more affluent residents the Park East project seeks to attract.

   After all, poor people deserve the opportunity to stop being poor. But as the Council perceives the way historic credits will work in the neighborhood, they will not help a majority of our neighbors and will actually burden them with continued pressure to move out without moving up.

   In short, the very "success" of projects such as Park East will guarantee the failure of the objective of maintaining a traditional, mixed-income neighborhood.

Sincerely yours,

Bob Babione, President