OG 17-146

HPA number
HPA 17-263

1051-1055 29th Street, NW
United States

D.C. Department of Consumer and Regulatory Affairs
West Heating Plant
Multi-unit residential building and garden
Review Type
Previous Review


Dear Mr. Levy:

In its meeting of 18 May, the Commission of Fine Arts reviewed a concept submission for a new multi-unit residential building and associated landscape at the site of the West Heating Plant at 1051–1055 29th Street, NW, following the review of the project by the Old Georgetown Board at its meeting of 4 May 2017. The Commission did not adopt the recommendation of the Old Georgetown Board to follow a concept of rehabilitation for the property; the Commission approved the concept submission with the following recommendations to be addressed in the further review of the project at the concept phase.

In their discussion, the Commission members acknowledged the broad range of public testimony regarding the project, which proposes to substantially demolish the iconic structure, and they noted the widely varying discourse concerning historic preservation principles. They accepted the structural engineer’s analysis demonstrating the difficulty of preserving the masonry shell of the building, and they expressed regret that a more thorough study of the condition of the West Heating Plant had not been undertaken prior to its disposal by the General Services Administration. However, they supported the concept of preserving the building’s western facade and site walls as a reasonable approach for the redevelopment of the property, and they endorsed a direction of exploring cultural heritage concepts in the design of the new building and landscape.

Recognizing that the project is fundamentally a new building that would reconstruct the volume of the historic structure, the Commission members recommended expressing the monumentality of the building rather than imitating its historic elements and details. While they expressed overall support for the presented concept, they recommended that the design be developed with a more creative and innovative design that would interpret the building’s characteristic features less literally. They noted that an applicable principle of the Secretary of the Interior’s Standards for the Treatment of Historic Properties is to differentiate the character of new construction from actual historic fabric, and they suggested that the 2013 concept submission may be useful in guiding the development of the design.

Regarding the site design of a park to be constructed above a parking garage occupying the heating plant’s former coal yard, the Commission members recommended further development of the proposal. Raising concerns that the proposed landscape design appears banal and suburban in character, they recommended that the design be more strongly informed by the site’s industrial heritage and its history of water, energy, and construction technologies. They emphasized the opportunity for the landscape design to connect more directly with the character of the building and its site—drawing inspiration from 20th-century industry rather than focusing on the 18th-century tobacco trade as presented—and they commented that the elements of the landscape could be more directly informed by this history. In its action to approve the concept design, the Commission requested review of a revised concept submission without an intervening review by the Old Georgetown Board. Please coordinate the next submission with the staff, which is available to assist you.


/s/Thomas E. Luebke, FAIA

Richard H. Levy, Managing Principal
The Levy Group, LLC
1321½ Wisconsin Avenue, NW
Washington, DC 20007

cc: David Adjaye, Adjaye Associates
Nnenna Lynch, The Georgetown Company

Enclosure: Report of the Old Georgetown Board, 11 May 2017


OG 17-146 (HPA 17-263)
1051 29th Street, NW
(Square 1193, Lot 800-804, 45, 46)
Multi-Family Residence
Concept Design: Demolition, Alterations, Site Work
(Reviewed: May, April 2017 – OG17-146; May, Feb 2016 – OG16-107; Jul 2014, Nov 2013 – OG14-012)

REPORT: The applicant, Georgetown 29K Acquisition LLC, proposes the demolition of the West Heating Plant (WHP), save for the rehabilitation of the west elevation that includes the main entrance to the building, as well as retaining portions of the perimeter walls at the base of the building. The construction includes what would be in essence a new building plus alterations to the site, with the construction of a park to the south of the building and a pedestrian walkway along Rock Creek that would lead to a bridge providing a connection to the north side of the C&O Canal. The D.C. zoning administrator has determined that a proposal retaining approximately 32 percent of the building (as with the current proposal, including the site walls) would be sufficient to allow for the reconstruction of the structure at its original height and bulk and preserve its nonconforming status.

1051–1055 29th Street (West Heating Plant, or WHP) is an important Art Moderne-style building that was constructed from 1942 to 1948. It was designed in the early 1940s by William Dewey Foster with the leadership of Gilbert Stanley Underwood of the Public Works Administration, precursor to the GSA. With its heroic massing and abstracted detailing, the building is exemplary of the aspirational public infrastructure of the late-New Deal era and may be considered the best of its kind in Washington. (A full history of the building and site is provided in a staff analysis dated 16 January 2017, presented at the Old Georgetown Board meeting of 4 February 2017.) The General Services Administration disposed of the 1.97-acre property in 2013 with a quitclaim deed signed by the applicant (grantee) that included a Historic and Cultural Preservation Covenant (Section I) providing for the “long-term preservation” of the WHP and requiring any redevelopment to be consistent with local preservation laws and the Secretary of the Interior’s Standards for Rehabilitation (Section I.1).

In 2013 and 2014, the Old Georgetown Board (OGB) considered presentations regarding the structural integrity of the existing building. Structural engineering reports from Robert Silman Associates, the applicant’s consultant, and Wiss-Janney Associates, the peer reviewer, presented similar observations with differing conclusions. In summary, rust-jacking associated with the steel frame within the building’s envelope would have to be treated; in order to retain the exterior brick, the interior terra cotta back-up wall would need to be removed in its entirety. The conclusions varied in terms of the extent of repair (near-total vs. partial) required due to the corrosion. The OGB/CFA forwarded these reports to the State Historic Preservation Officer for the District of Columbia (SHPO).

Over the past several years, the applicant has proposed three different concept designs for the property, all for luxury residential use. Each concept included significant demolition of the historic building, and all three have not been approved by the Old Georgetown Board. The first submission, in 2013, proposed reconstructing the masonry box of the building, but using sliding metal screens where the building’s planar walls exist between the multi-story windows to increase perimeter fenestration. The second submission, in 2016, proposed an entirely new design of stacked horizontal slabs and continuous perimeter balconies. The current proposed design calls for a “reinterpretation” of the original building: a facade clad in brick with perforated areas at the corners, top floor, and penthouse level; a series of new vertical multistory windows on the side elevations, creating 10 on each side at a tighter spacing to replace the existing pattern of 6 on the south elevation and 8 on the north elevation; a wide monumental opening on the east elevation, roughly twice as wide as the existing one; and at the corners, top floor, and penthouse level, perforated brick in operable fold-up panels intended to allow light into the residential units where there is currently solid masonry.

Over the course of its review, the Board advised the applicant to treat the project as a rehabilitation rather than a demolition, in keeping with established preservation law, and in recognition of the WHP being one of the finest remaining industrial buildings in Washington and a superb example of the Art Moderne style. The Board noted the prominence of the site as a gateway structure to the historic district, and as such the need for a carefully conceived design that would respect the robustness and monumentality of the existing structure.

The Board has stated its willingness to consider alterations to the building that would preserve its fundamental character-defining features while allowing for its adaptive reuse. These qualities include the stark massiveness of the building, which is established through the planar treatment of the brick cladding and the ratio of solid to void areas. The Board noted strong concern over the proposed excessive use of the perforated brick, the reordering of the side windows, and the doubling of the opening on the east elevation—all of which would result in the effective erosion of the building’s monumental quality. After repeatedly requesting test-fits of proposed residential units the Board does not feel that the applicant has conclusively demonstrated the incompatibility of the proposed residential use with the historic building itself, and the Board continues to recommend a proposal that rehabilitates the historic WHP.

RECOMMENDATION: Recommend AGAINST concept design that proposes substantial demolition of outstanding and rare example of Art Moderne building designed and erected by federal government from 1942–48, the last industrial building erected in the Georgetown waterfront area. File new concept application for design following historic preservation principles of rehabilitation for the historic structure.