The Heritage Foundation of Williamson County, TN has learned that the Middle Eight PUD Subdivision is on the agenda at the Franklin Municipal Planning Commission (FMPC) on Thursday, June 27 for one of its final approvals before moving on to engineering and construction approval. While the public has been led to believe that the fate of Middle Eight was long ago signed, sealed, and delivered, the project’s inclusion on the FMPC agenda proves otherwise. The item report prepared by the planning department for the meeting recommends approval with conditions. The as of yet unmet conditions required by the planning department are detailed in a 16 page document. This means that the city of Franklin still has the opportunity mitigate the untold damage to our historic resources by requiring the standard due diligence of preliminary archaeological survey and adherence to the historic preservation overlay design guidelines.

The Heritage Foundation of Williamson County, TN has submitted the following statement to the Franklin Municipal Planning Commission:

Throughout the public engagement process for the Middle Eight, the Heritage Foundation of Williamson County, TN has been transparent in expressing its deep concerns about the project in its current iteration, from its detrimental impact on the validity of the Historic Preservation Overlay to the loss of one of the few remaining green gateways into Franklin that could contain significant Civil War history. As the project returns to the Franklin Municipal Planning Commission for its final approvals before construction begins, we urge you to consider the dangerous legal precedent that will be set by the approval of the current iteration of the Middle Eight project.

Approval of this project creates a massive loophole in Franklin’s Historic Preservation Ordinance which would allow for any developer to develop any vacant plot within the Historic Preservation Overlay to the density of Middle Eight with little regard to the design guidelines, regardless of whether the project is approved by the Historic Zoning Commission, the Franklin Municipal Planning Commission, and Board of Mayor and Aldermen through litigation. The precedent set by the approval of Middle Eight creates a tidy argument for “equal protection of the law” in land use and zoning decisions if litigation is brought forth against the city by the developer.i While the approval of Middle Eight may have been issued to a developer who is a trusted local known to the community, the precedent set by it has issued a proxy approval to any future developer hoping to capitalize on the allure of historic Franklin.

At this point, the best we can do is to mitigate the vast extent of the harm caused by the Middle Eight. The Heritage Foundation strongly recommends that the Franklin Municipal Planning Commission require the following of the applicant before the project moves forward:

1. Preliminary archaeological survey of the site which can be performed utilizing ground penetrating radar. Archaeological survey is standard due diligence for projects of this size. It is required by law in many states and is a component of best practices industrywide. Private property owners in Williamson County are leading by example on this issue. In 2022, the Heritage Foundation commissioned a ground penetrating radar archaeological survey of 423 South Margin Street, the future location of Franklin Grove, prior to beginning renovation work. In 2019, Dr. Kevin Smith was contracted to perform extensive archaeological survey and research at Old Town using GPR technology which helped guide best practices for the owners to make informed decisions without disturbing the ancient prehistoric site. Considering that the historical significance of the Middle Eight parcel is well known, it would be an egregious oversight to allow this project to move forward without archaeological survey.
2. Reconfiguration of design to be more compatible with historic context. While we understand that the development was designed to complement the more industrial architectural features of the area, the historic district’s design guidelines should still be followed. Building height should be limited to three stories, density should be reduced to preserve accessible greenspace, and overall design of the development (including, but not limited to building materials, cornice heights, window designs, overhangs, and roofing materials) align with the surrounding community.

It is crucial that the Franklin Municipal Planning Commission require these two simple things of the developer before the project progresses. We urge staff and the Commission to add these two items to the list of conditions that have already been requested of the developer in exchange for a recommendation of approval. Nothing is set in stone until building permits have been issued and construction has begun. Franklin is a city that has prided itself on being a leader in historic preservation for over a century. We must make sure that we continue to live up to our reputation.

Sincerely,

Board of Directors
Heritage Foundation of Williamson County, TN

Bari Beasley
President and CEO, Heritage Foundation of Williamson County, TN

Anna Marcum
Senior Director of Preservation, Heritage Foundation of Williamson County, TN

We invite you to join us in voicing your concerns about the Middle Eight by sending an opposition letter via email to planningintake@franklintn.gov before noon, Wednesday, June 26, 2024. See our customizable form letter below to get started. By simply hitting “send” you can be an important part of powerful preservation advocacy that will help to preserve the places, spaces, and stories that contribute to Williamson County’s unique sense of place.