07/23/2026
Here is an excellent example of using Section 106 to save a significant historic resource AND have a successful rehabilitation project that continues to serve Oklahoma City today:
The Project: In 1999, Oklahoma City (City) formed the Skirvin Solutions Committee to evaluate options for saving the building. Of particular concern was retaining the building’s use and historic character, which required finding a proponent that would rehabilitate the property and return it to its use as a hotel. When it became clear public involvement was necessary to save the landmark hotel, the City purchased it with Community Development Block Grant funds from the U.S. Department of Housing and Urban Development (HUD).
The 106 Process: Section 106 of the National Historic Preservation Act requires federal agencies to take into account the effects of projects they carry out, fund, or permit on historic properties prior to making final decisions on the projects. The law creating the Community Development Block Grant Program delegates that responsibility to HUD’s grantees, so the City undertook compliance with Section 106. While no plan had been developed at the time of purchase, the City and the Oklahoma State Historic Preservation Officer executed a Memorandum of Agreement (MOA) to establish that any rehabilitation proposal considered by the City would require compliance with the Secretary of the Interior’s Standards for Rehabilitation. The use of the Standards would facilitate use of federal financial tools such as grants and tax credits. Following a Request for Proposals, the City chose Skirvin Partners LLC, which included the Hilton Hotel group, as the developer for the rehabilitation and reuse of the building.
The rehabilitation included masonry restoration; roof replacement; installation of new plumbing, electrical, and HVAC systems; installation of 900 new windows; and complete interior rehabilitation. While original corridors were left in place, guest rooms were reconfigured to retain the building’s historic character. Special attention was given to the retention of other historic spaces and elements, such as the 29 hand-carved Bacchus busts accented with gold leaf, the lobby’s arched wooden entry ways and the 1911 tile floor, art deco tile in the Skirvin’s Park Avenue Grill (dating from the 1920's expansion), and the decorative lobby elevator doors. The rehabilitation also restored the original first and second floor façade and entry canopy, which had been masked by modern stucco. The $56.3 million project had a complex financial package which relied upon federal and state rehabilitation tax credits but also utilized New Markets Tax Credits, a HUD Economic Development Initiative grant, local funding from the Oklahoma City Urban Renewal Authority, proceeds from the sale of the building, and private equity.
Section 106 Success: By using its allotted federal funds to purchase the hotel and support community development, the City used the Section 106 process to guide the successful rehabilitation of the hotel. The project recognized the need for public-private partnerships to leverage federal funds. Neither the City nor a private entity could have completed a project of this scale or magnitude on its own. Together, though, they were able to access multiple sources of funding, making the rehabilitation financially feasible. The Section 106 process facilitated the needed collaboration, consultation, and compromise among the multiple partners. The Skirvin Hilton Hotel project demonstrates that historic preservation works.