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Regarding the National Endowment for the Humanities’ Section 106 Review of the Memphis College of Art Rust Hall Rehabilitation for the National Ornamental Metal Museum.
The National Endowment for the Humanities (NEH) has offered the National Ornamental Metal Museum (Museum), in Memphis, Tennessee, a Challenge Infrastructure and Capacity Building grant (CHA-292077) to extensively renovate Rust Hall, a four-story mid-century modern, to become the new home of the Museum. 
NEH is an independent grant-making agency of the United States government dedicated to supporting research, education, preservation, and public programs in the humanities.  This public notice is issued as part of NEH’s responsibilities under 36 C.F.R. Part 800, the regulations which implement Section 106 of the National Historic Preservation Act (NHPA) of 1966, as amended, 54 U.S.C. 306108.  NEH, a funding agency, is required by regulation to identify and assess the effects of any proposed actions on historic properties.  If any proposed action will have an adverse effect on historic resources, NEH works with the appropriate parties to seek ways to avoid, minimize, or mitigate any adverse effects.  Additionally, the Section 106 regulations require NEH to consider the views of the public on preservation issues when making final decisions that affect historic properties. 
The project involves renovations to Rust Hall, at 1930 Poplar Ave, Memphis, Tennessee 38104-2756.


The Project

The project involves the renovation of Rust Hall, a four-story mid-century modern building that was originally built in two phases - in 1959 and 1967. Two additions were added in the 1970s and 1980s. The current building with additions is approximately 76,000 square feet. The project involves the renovation of the original structure and the demolition of the two additions. Original, historic materials and finishes, such as brick, concrete, and concrete block facades, terrazzo flooring, and steel window frames, will be repaired and retained as much as possible. 

Exterior Modifications 
There will be two changes to the exterior of the building. First, the two additions will be removed. They are not visible from the main entry and therefore do not significantly affect the integrity of the building and its ability to convey its New Formalist Design. The 1980s west addition will be replaced with new construction of a single-story building with a 17,000 square foot footprint. The new addition on the west will have a steel column and beam structure, sawtooth metal roof with clerestory lighting, and a combination of concrete block walls and metal stud framed walls. The 1970s north addition will be replaced with 20 additional parking spaces. 
The second is the widening of the ground level, accessible entrance to meet current codes and accessibility standards. A limited segment of the berm will be removed and the north walkway leading to a non-ADA compliant entrance will be expanded in order to facilitate installation of a new, socially equitable entrance for the non-ambulatory public on the ground floor. The berm could be restored to its original configuration anytime necessary and thereby does not have an adverse impact on the historic structure. 

Interior Modifications 
Many of the current interior walls throughout the building have been reconfigured over time. The ground floor currently consists of a maze of studios, classrooms, offices, and an auditorium. Much of the ground floor will be reconfigured to accommodate new uses. A new entrance foyer and reception area will be in the former non-ADA compliant entrance area. New bathrooms, offices, and other service rooms will be installed. A new service elevator will be installed in the northeast stairwell. The auditorium will be retained in its original state. These changes will have no adverse effect on the ground floor as most of it is secondary space, altered over time, and the most defining elements - the auditorium and a central staircase - will be retained. 
The first floor on the north tower, which housed administrative offices for the College of Art, will be reconfigured for gallery space and a library. The second and third floors, which were used as classrooms, will become open gallery space. A new stairwell extending from the first floor to the third floor will be introduced to improve circulation through the tower and gallery spaces.   The changes will have no adverse effect as the space retains the same perimeters and fenestration. 
The first floor in the south tower, which served the College as the library, will become a store and café. The second and third floors, which served as classrooms, will become an open space with a catering kitchen and bathrooms, and offices. This will have no adverse effect as the space retains the same perimeters, historic stairwells, and fenestration. 

Historic Properties 
Russ Hall is individually eligible for the National Register of Historic Places (NHRP) and is located within the Overton Park Historic District (NHRP #79002475). The building is set on an earthen podium with three floors and a partially submerged basement, the former Memphis College of Art Building (Rust Hall) is a steel frame and reinforced concrete block building. The building has a brown brick veneer walls on the façade (east) and rear (west) elevations and glass and steel curtain wall windows on the north and south elevations. A white, poured concrete, irregular grid, with a paired rectangular shape pattern brise soleil extends to the middle of the third floor on all elevations. This sunscreen is supported by evenly spaced white concrete piers which support the folded plate roof. The folded plate roof covers both wings and extends out to provide a covered walkway on the third floor for accessibility to both wings. The basement level extends further to the north, beyond the footprint of the building, to serve as a first-level plaza; a courtyard within this section provides natural light to the interior of the basement level. The foundation is concealed by a concrete block planter that rises to the first level around the entire building. 
The building was constructed in two phases. The north side, including the ground-level section with courtyard, was constructed in 1959 and the center hall and south section was finally constructed almost a decade later in 1967. The original building is approximately 58,000 square feet. Two additions were added in the 1970s and 1980s. A one-story, concrete block, ground floor addition was added to the north side in 1976, which is approximately 5,500 square feet. In 1986-1987, a similar one story, concrete block annex was added to the rear west ground floor of the building, which is approximately 12,500 square feet. In total, the existing building is about 76,000 gross square feet. There is a parking lot on the north side of the building with 10 parking spaces. 

Section 106 Consultation 
The Museum is also seeking Historic Tax Credits for Rust Hall.  The National Park Services (NPS) conditionally approved the project on December 14, 2023, which required minor modifications of the design to ensure that the renovations met the Secretary of the Interior’s Standard for Rehabilitation.  On May 10, 2024, E. Patrick McIntyre, Jr., Tennessee State Historic Preservation Officer, provided the opinion that the proposed work will have No Adverse Effect upon historic properties, “as long as the conditions for completing the Federal Historic Tax Credit from the National Park Service”. 
After reviewing Section 106 documentation NEH issues a final determination of No Adverse Effect. 

Public Comment 
As required by Section 106, NEH is providing the public with information about this project, as well as an opportunity to comment on any knowledge of, or concerns with, historic properties in the proposed project area, and issues relating to the project’s potential effects on historic properties. Comments may be submitted to the NEH by e-mail to .  The deadline for submitting comments is June 6, 2024. 


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