The Small Cities Community Development Block Grant (CDBG) Program is a federal program that provides funding for housing and community development activities. FloridaCommerce administers the State Program in Florida through the Small Cities CDBG Program. This is a competitive grant program that awards funds to units of local government in small urban and rural areas.
This is not a private matter. Federally funded programs are matters of public concern.
DHR Project File No.: 2023-5606 /311 SW 3rd Street, Stuart, Florida 34994-Housing Rehabilitation FDEO HUD Small Cities CDBG.
“Four months after the City certified the work as complete—stating it was ‘done correctly and in accordance with all requirements’—and disbursed the CDBG taxpayer funds to the contractor, the City hired an engineer. On May 13, 2025, Specialty Engineering Services & Solutions, Inc. deemed the replacement window work to be, to quote their report, ‘poor workmanship bordering on amateurish installation. Harsh and true. This alone warrants complete replacement.’
This article documents the replacement-window installation performed under the City of Stuart’s Small Cities CDBG Housing Rehabilitation Program by contractor Patriot Response Group, under the program management of the City of Stuart and Guardian Community Resource Management, Inc.
It also documents what happened after we—the homeowners, Robert W. Hamilton, Jr. and Olga Hamilton—raised concerns about oversized replacement windows, alterations to our historic building, the permit documents, structural damage, historic-preservation requirements, inspections, payment, and oversight.
Who’s Who
Pinal Gandhi-Savdas — Community Redevelopment Agency (CRA) Executive Director and the City of Stuart CDBG Project Manager, with the authority to act on the City’s behalf with respect to all aspects of the Project.
Antonio Jenkins of Guardian Community Resource Management, Inc. — CDBG Housing Rehabilitation Project Manager and Director of Construction. Guardian CRM, described as a “top-ranked” firm, was contracted by the City of Stuart to manage the CDBG Program. Mr. Jenkins was described as “certified in the latest building codes.”
Patriot Response Group, LLC — the CDBG contractor, CGC-1526178, and one of only two bidders reviewed for the project.
The contractor and Guardian CRM, Inc. were paid from federal funds.
On July 1, 2024, Mr. Jenkins notified us that subcontractor Merrigan Building Group “will be in charge of the window install.”
The City of Stuart’s CDBG Housing Rehabilitation contract with Patriot Response Group states:
“Contractor shall be responsible for the work of all subcontractors.”
— Article 7, Subcontractors
Accordingly, throughout this article, we refer collectively to the CDBG subcontractors performing this work as “the contractor.”
The City’s Agreement With FloridaCommerce
On September 29, 2021, the City of Stuart signed the Small Cities CDBG Subgrant Agreement with what was then the Florida Department of Economic Opportunity, now FloridaCommerce.
Under that Agreement, the City agreed to abide by applicable State and Federal laws, rules, and regulations.
The Subgrant Agreement identifies Pinal Gandhi-Savdas as the Local Government Project Contact.
You can download the Subgrant Agreement fro the Florida Department of Financial Services website: https://facts.fldfs.com/search/ContractDetail.aspx?AgencyId=400000&ContractId=H2443
Residents who frequently attended City meetings may remember us standing before the Stuart City Commission and pleading for help after problems developed with our CDBG Housing Rehabilitation project.
What neither we nor the public knew at the time was that Guardian CRM and the City Administration had possessed an important State Historic Preservation Office letter concerning our property since December 1, 2023.
The December 1, 2023 SHPO Letter
When you watch the video below, please keep in mind, Mr. Jenkins of Guardian Community Resource Management Inc. and the City Administration have had the State Historic Preservation Office letter since December 1st, 2023, stating: “Based on the information provided, 311 SW 3rd Street appears to be potentially eligible for listing in the NRHP under Criteria A: religion (Florida Master Site File Number: MT346). It is the opinion of this office that the proposed rehabilitation should have no adverse effect on historic properties provided the following conditions are met:…”
We, the owners of the historic building, knew nothing about this letter until November 22, 2024, when SHPO provided copies to us.
By then, the City had already released taxpayer funds for destructive replacement-window work.
We—the homeowners and participants in the Small Cities CDBG Program—spent month after month researching the Florida Building Code, statutes, the CDBG agreement, and publicly available documents and records.
The City Administration denied responsibility for supervising the program. We contend that this position contradicts the Subgrant Agreement between FloridaCommerce and the City.
Furthermore, the City Administration and Guardian Community Resource Management intimidated us with threats of liens if we did not release federal funds to the contractor for work we believed was destructive and fraudulent (work that wasn’t even performed).
They also attempted to have us sign documents stating that “the consideration provided and received by all parties was fair, just, and reasonable.”
Documents provided to us contained dates that, in our view, were either negligently recorded or deliberately falsified.
We refused to release the funds because we believed doing so would constitute an improper payment.
We consequently filed a complaint with the FloridaCommerce Office of Inspector General.
The Scope of Work and the Replacement Windows
The City of Stuart CDBG Housing Rehabilitation Scope of Work for our historic building was prepared by the City of Stuart and Guardian CRM, Inc.
By signing the Scope of Work, the contractor acknowledged that it had reviewed and agreed to perform the described work and that rehabilitation work would be performed in accordance with required state historic mandates.
Under the Scope of Work, Patriot Response Group was responsible for the permit application, measurements of the window frames, plans, drawings, ordering the replacement windows, and installation.
The contractor ordered replacement windows measuring approximately 31.5″ × 59.5″.
Those windows were approximately 4 inches larger than our original windows.
They did not fit within the existing rough openings.
Of the 20 replacement windows included in the project, three could not be installed at all because of their size.
First Installation: July 5–7, 2024
The first installation took place from July 5 through July 7, 2024.
We expressed concerns about the oversized replacement windows.
We were told not to worry, to trust the contractor’s “window crew,” and not to interfere with their work. We were told that everything was being performed according to the Florida Building Code and that the contractor had submitted all necessary documents and plans to the City of Stuart Building Department.
Three workers were left at our property without supervision by a licensed window installer. Two did not speak English. They struggled even with installation of the flashing tape intended to waterproof the windows.
To make the oversized windows fit, the contractor removed essential portions of the existing window frames and wall assemblies and altered our exterior load-bearing walls.
The gaps between the installed replacement windows, the damaged frames, and the rough openings measured as much as 1 inch and, in some places, more.
From July 5 through July 7, we had to cover gaps and holes around the windows with painter’s tape to help prevent insects, water, and hot outside air from entering the building.
What the Photographs Show
Photographs taken during the July 5–7 installation document the work.
The contractor cut out the original Dade County pine sill, part of a Dade County pine stud, and portions of the exterior load-bearing wall.
The original approximately 2″ × 4″ sill was replaced with a 3/4″ inferior-grade pressure-treated board.
That board was not screwed or nailed to the studs. It was hanging from the flashing tape beneath the window.
The contractor also removed the original historic 1.5″-thick projecting sills and portions of the framing, and cut approximately 4 inches into the exterior load-bearing wall to accommodate the oversized replacement windows.
One photograph shows a screw penetrating the corner of a replacement window.
All 17 replacement windows that had been installed were incorrectly installed.
On July 9, 2024, the contractor covered them with clear Visqueen.
Reinstallation: July 10–13, 2024
The oversized windows were removed and reinstalled from July 10 through July 13, 2024. During that reinstallation, we contend that additional damage was inflicted on the historic building.
On July 10, the contractor’s construction manager, Jim Nichols, was rude and insulting and threatened to take his crew and leave when we became upset about the damage and questioned the reinstallation of the oversized windows.
We asked the contractor not to further destroy the rough openings or cut farther into the exterior walls.
July 16: We Asked Whether Structural Alterations Had Been Approved
On July 16, 2024, we sent a message to Antonio Jenkins asking whether the contractor had plans and Building Department permission to alter our exterior load-bearing walls.
Mr. Jenkins responded:
“yes.”
Mr. Jenkins was the CDBG Project Manager and Director of Construction and was described as being certified in building codes.
He was also aware of the December 1, 2023 State Historic Preservation Office letter.
After we later examined the building-permit file, we discovered that the permit documents did not contain plans for the structural alterations that had been made to our window rough openings and exterior load-bearing walls.
July 19: We Put the Damage in Writing
On July 19, 2024, we sent an email with photographs to Mr. Jenkins and Mrs. Gandhi-Savdas documenting damage to our historic building, including the cutting of the exterior load-bearing walls.
Mrs. Gandhi-Savdas did not respond to that email.
Neither she nor Mr. Jenkins told us about the December 1, 2023 SHPO letter.
We also stated that we had not been informed in advance that the contractor intended to alter the structure and had never been provided with plans authorizing such work.
The contractor had submitted the building-permit application electronically. The contractor failed to submit the CDBG Scope of Work. That is a critical compliance issue because CDBG funds are strictly tied to specific federal regulations—such as environmental reviews, Davis-Bacon labor compliance, and historic preservation—work cannot legally begin without an approved permit and validated SOW.
Months later, when we asked Mrs. Gandhi-Savdas when the SHPO letter had been provided to or disclosed to the Building Department, she wrote in a December 10, 2024 email:
“Guardian is managing the project, so they are responsible that the contractors’ scope of work is in accordance with the conditions of approval by SHPO or any other agencies.”
What We Found in the Permit File
At our request through the City portal, the Building Department provided us with the replacement-window permit file.
When we examined the documents, we found that the contractor had submitted what we contend was the wrong floor plan.
That plan added an extra room to our dwelling and altered the path of egress.
We also found no plans authorizing alteration of the existing window rough openings, removal of structural elements, or cutting into the exterior load-bearing walls.
We notified the City Administration and the Building Department. We requested reinspections.
The Building Department did not respond to those requests.
City Manager Michael Mortell stated that the City was not responsible for supervising the Program or the contractors.
The Condition of the Windows and Walls After Reinstallation
The photographs documenting the work are important because they allow comparison of the building before and after the CDBG replacement-window project.
North-Facing Window
Photo #1 was taken on November 6, 2022, after we finished insulating the wall.
Photo #2 was taken shortly afterward, after we covered and reinforced the wall with 3/4″ plywood.
Both photographs also show the original 4.5″ exterior trim attached from the outside.
Photo #3 was taken on July 12, 2024, during the replacement-window reinstallation.
When the contractor’s second crew removed the replacement window, the opening revealed that the first crew had cut out critical portions of the rough framing and approximately 4 inches of the exterior load-bearing wall. Cracks were also visible in the wall covering.
This portion of the building was constructed in 1932 by the Stuart Episcopalians as part of an enlargement that gave the former Methodist Church—also known as the Pioneer Church, built in Stuart in 1895—its cross-shaped form.
The oversized and substantially heavier north-facing replacement window was left with no support underneath except for a 0.75″ inferior-grade pressure-treated yellow-pine board screwed to the tops of the cut-off cripples.
Our exterior load-bearing walls were also left with additional cracking after the contractor enlarged the window rough openings to accommodate the oversized replacement windows.
West-Facing Windows
At the west-facing windows, the contractor altered the existing window frames, rough openings, and exterior load-bearing wall to accommodate the oversized windows.
The silicone sealant used by the contractor to fill large gaps and holes after the walls were altered is now falling out in chunks.
The photographs compare our original window with the oversized replacement window and document the resulting condition of the frames and rough openings.
Our original 4.5″-wide Dade County pine and cypress trim was replaced with 3.5″-wide inferior-grade pressure-treated boards, altering the historic exterior appearance of the building.
When we raised this issue with construction manager Jim Nichols, he responded with a smirk:
“I can fix it, but you will not like it.”
The pressure-treated trim boards are cracking and moving.
The non-paintable silicone sealant and stucco patches placed around the windows to cover holes are separating.
During wind-driven rain, the windows leak.
After removing parts of the original frames and the projecting 1.5″-thick sills and altering the exterior load-bearing wall, Patriot Response Group filled holes in the exterior walls with silicone sealant.
The contractor installed the same replacement windows into the same damaged framing twice: first during the July 5–7 installation and again during the July 10–13 reinstallation.
We were not told that the windows were being attached to those damaged studs. We discovered the condition after the beadboard surrounding the windows detached.
The replacement windows were also installed off-center.
As a result, the trim widths differ: approximately 2 inches on one side and 4 inches on the other.
Centering those windows would require additional alteration of the wall and could inflict further damage.
The shoddy wrapping on the windows was also damaged as the oversized windows were forced into the openings during the failed first installation, removed, and then forced into the openings again during reinstallation.
Silicone used to fill gaps between the wall and window sill is falling out in chunks, leaving openings through which one can see.
Shoddy workmanship not only falls apart quickly but also inflicts more damage on the home.
It creates a dangerous domino effect, compromising the structural integrity of our home: moisture – wood rot
Due to what we contend is shoddy and incomplete work, our house is less safe and in substantially worse condition.
We have also been left with the financial burden of repairing the damage.
"The Independent Engineer"
The window reinstallation did not pass a Building Department inspection because of shim and screw placement.
But we had reported a more serious concern: the contractor had altered exterior load-bearing walls and removed structural elements.
Building Department officials told us they could not inspect or comment on work that was not included in the permit.
Two replacement windows had also been attached to studs with obvious damage. The Building Department likewise did not comment on that condition.
Change Order #2
On July 19, 2024, at 10:17 a.m., we sent Mr. Jenkins photographs documenting alterations to the walls and destruction of the existing frames and rough openings.
Mr. Jenkins did not respond.
At that point, we had not yet discovered that the contractor “faked” the roof ridge-vent system installation.
On July 23, 2024, at 3:24 p.m., Dawn Cobb, Guardian CRM, Inc. Admin, brought us Change Order #2. We did not sign it immediately.
Change Order #2 stated:
“In accordance with the Building Department recommendation: The services -Dwelling of an engineer shall be procured and assigned. The engineer shall complete the following site review services:…”
Guardian CRM charged $1,000 to our CDBG account.
Despite that language, we had not been provided with any official written Building Department notes or recommendations arising from the window inspection.
July 24: “If He Had to Respond to the Email in Writing It Would Hurt Us Badly”
On July 24, 2024, at 10:00 a.m., we emailed Mr. Jenkins asking him to respond to our July 19 email before we signed Change Order #2. We have also requested the financial documents on our project: invoiced and a copy of the Change Order #1.
At 10:40 a.m., Mr. Jenkins called us.
The first thing he said was that if he had to respond to the email in writing, it would hurt us badly.
He talked over us while attempting to convince us that he had personally hired the engineer for us and that this was the best option available.
He did not provide the engineer’s name.
At 10:40 a.m., Mr. Jenkins called us.
The first thing he said was that if he had to respond to the email in writing, it would hurt us badly.
He talked over us while attempting to convince us that he had personally hired the engineer for us and that this was the best option available.
He did not provide the engineer’s name.
At 11:02 a.m., we sent Mr. Jenkins the signed Change Order #2 and a PDF containing photographs for the engineer.
Throughout this period, Mr. Jenkins was also aware of the December 1, 2023 State Historic Preservation/SHPO letter but didn’t say a word about this letter to us.
July 25: Questions About the “Independent” Engineer
On July 25, 2024, at 7:36 a.m., we called Mr. Jenkins and again expressed our concerns about the damage caused by the oversized-window installation.
Mr. Jenkins repeatedly assured us that everything had been done according to the Florida Building Code, that plans had been provided to the Building Department, and that written responses from him would not do us any good.
He again declined to provide the engineer’s name, stating that the engineer was independent.
Mr. Jenkins confirmed that the engineer and Dawn Cobb would arrive on July 26 at 10:00 a.m.
He did not tell us that the contractor would also be present.
On July 25, we also sent Mr. Jenkins a phone message with photographs showing that Patriot Response Group had used window silicone sealant to fill holes left in the exterior load-bearing walls after cutting the walls.
Again, Mr. Jenkins did not mention the December 1, 2023 SHPO letter.
July 26: Who Actually Hired the Engineer?
On July 26, 2024, Vance Olvey, the contractor, arrived before the scheduled meeting and met the engineer.
When Mr. Hamilton approached, the contractor was talking with the engineer, who was reviewing documents brought by the contractor.
Mr. Hamilton was concerned and quiet upset that the engineer’s independence had been compromised.
Mr. Hamilton stated that Antonio Jenkins had told us he had hired the independent engineer and that the cost would be paid from our CDBG account.
Vance Olvey then stated that the contractor had hired and paid the engineer.
The engineer stated that he did not feel “independent” anymore and therefore could not perform the inspection.
Dawn Cobb arrived approximately eight minutes late.
Vance Olvey said he was calling Mr. Jenkins while Mrs. Cobb and Robert and Olga Hamilton spoke with the engineer.
The engineer left at approximately 10:13 a.m.
Vance Olvey was still on the phone.
Mr. Olvey took the contractor’s trailer and left at approximately 10:28 a.m. Mrs. Cobb also left.
Mrs. Cobb returned at approximately 11:12 a.m. and told us that she had spoken with the CRA Executive Director and that Patriot Response Group had been removed from our project.
We still do not know the name of the engineer hired by Patriot Response Group.
At the video-recorded August 26, 2024 CRA meeting, Mr. Jenkins—who had previously told us that he had hired the “independent” engineer—could not remember the engineer’s name when asked by a City Commissioner.
On July 26, 2024, we also sent an email to Guardian CRM at 02:23PM.
Mr. Jenkins did not respond to the email and didn’t call us that day.
After July 26, we did not hear from Guardian CRM until a brief response from Mr. Jenkins on August 6 following our August 4 email.
After August 6, we did not hear from him again until his August 15 response to another email from us.
August 15, 2024: Extortion of the Release of Funds Under Threat of a Mechanic’s Lien
In his August 15 email to us, Ms. Gandhi-Savdas, City Manager Mortell, and City Building Department official Louis Hatten, Mr. Jenkins denied our requests for financial records and at the same time wrote:
“The only action being taken at this time is the official dissolution of the agreement between you (The Hamilton’s) and the contractor (Patriot Response Group). This will allow: (1) avoidance of any mechanical liens that the contractor will have a legal right to impose should just due payment not be rendered. Keeping in mind the aforementioned F.S. cure provisions, it should be objectively noted that the windows did not fail the building inspection for size, for type, for framing (material type), or condition, but only for shim/screw placements. It should also be noted that window or other installation does not have to meet any standards other than those required by minimum Florida Building Code.”
The City of Stuart CDBG Project Management then began pressuring us to release federal funds to the contractor for the work and to sign voluntary contract-dissolution documents as though the project had been satisfactorily completed according to the “minimum Florida Building Code.”
On September 5, 2024, City Manager Mortell again denied that the city was responsible for supervising a federally funded program, while also denying our requests for reinspections. Instead, he attempted to coerce us into signing the release of the CDBG funds.
“The City of Stuart does not serve as the contractor or supervisor of the program… the City does not select the program administrators or the contractors,” Mr. Mortell stated in his September 5, 2024 email to us and the City Commissioners
We refused to sign the document. We do not agree with its terms, which state that “all parties acknowledge heretofore… that the consideration provided and received by all is fair, just and reasonable and that no further consideration, compensation or obligation will be due.”
FloridaCommerce and SHPO
The FloridaCommerce Office of Inspector General responded to our complaint on Sep 11, 2024.
On October 18, 2024, FloridaCommerce notified the city regarding our project – the home located at 311 South West 3rd Street. The agency stated that the completed work does not appear to comply with the project’s Site-Specific Environmental Review Conditions. As a result, costs incurred to date may not be eligible for reimbursement with federal funds.
Then, on November 22, 2024, the State Historic Preservation Office (SHPO) sent us a copy of a letter addressed to Mrs. Gandhi-Savdas.
SHPO wrote:
Based on the information provided, the completed work does not conform to the Secretary of the Interior’s Standards for the Treatment of Historic Properties and does not meet the conditions set forth by this office in our 2023 letter.”
This was the first time we learned about the December 1, 2023 SHPO correspondence with the city, which took place well before the roof and window replacement work began. At our request, SHPO provided us with copies of the letters.
However, the correspondence regarding our project actually dates back to October 2023, and we, the homeowners, were kept completely in the dark.
The City released the CDBG Funds to the contractor anyway!
On November 7, 2024, City of Stuart CRA Executive Director Pinal Gandhi-Savdas signed the release of funds together with Guardian Community Resource Management, Inc. and Patriot Response Group.
The CDBG document stating that the “Contract Voluntarily Dissolved” does not bear the homeowners’ signatures. Instead, the homeowners’ signature field contains only a date, which appears above the signature of City CRA Director Pinal Gandhi-Savdas.
The 2023 CDBG Scope of Work for our project included the replacement of twenty windows. However, the contractor, Patriot Response Group, replaced only seventeen of those twenty windows.
The City refused to cite the contractor for the destructive installation of oversized replacement windows that altered the structural integrity of our historic building’s exterior load-bearing walls without structural plans or engineering drawings. Instead, the City certified the replacement-window portion of the project as 85% complete—the exact percentage represented by seventeen of the twenty contracted windows.
On November 8, 2024, Executive Administrative Assistant and CRA Specialist Jordan Pinkston, CRA Director Gandhi-Savdas, and City Manager Michael Mortell requested payment to Patriot Response Group from CDBG Fund #105.
In total, the City of Stuart released $51,490 in taxpayer funds, including a $2,500 CDBG Change Order No. 1 document bearing the homeowner’s forged signature, as well as $5,000 for the structural engineer retained by the City.
After paying the contractor, Patriot Response Group, City Manager Mortell wrote to us on December 27, 2024:
“it is more likely that the house should be razed…”
On March 27, 2025, FloridaCommerce sent us an email stating:
“the City requests that a structural engineer of your choosing evaluate the property to determine whether any additional work is needed.” The City requested at least three engineers’ bids. We provided the City with the engineers’ bids, and the City hired Specialty Engineering Services & Solutions, Inc.
On May 13, 2025, Specialty Engineering Services & Solutions, Inc. issued its report:
“When something interferes or breaks the specific original load path, the affected load will find a new path. This new path may not be one that is favorable to the longevity of the building. This is why what may be seen as a simple piece of wood is actually more important than it appears. Normally a Trimmer stud would perform this task. In this building some of those Trimmer studs have been removed or cut.
In all cases where the windows were replaced, specifically the concerning the bucking and shim work, is considered poor workmanship bordering on amateurish installation. Harsh and true.
This alone warrants complete replacement… In this case its 24”, these windows being wider than the originals , @ 34”, means the installers may have cut through the load bearing King and Trimmer studs… As mentioned above, all of the windows need to be removed and replaced with windows that are sized according to the original design. The framing at each window that requires it should be restored and / or reframed using specified and appropriate methods and materials for a building designated as historical.”
As of today, we are left with a $57,330 CDBG Subordinate Mortgage for an incomplete project and damages inflicted on our historic home by Patriot Response Group.
The City now wants us to sign another set of CDBG documents for additional funds to pay another contractor to remedy the shoddy, destructive, and fraudulent work for which the City has already paid Patriot Response Group, thereby adding another CDBG mortgage on top of the existing one without addressing the mismanagement or the altered and falsified records.
What the CDBG Agreement Says About Oversight
The Agreement provides:
(2) Incorporation of Laws, Rules, Regulations, and Policies
“The Recipient agrees to abide by all applicable State and Federal laws, rules, and regulations, including but not necessarily limited to, the Federal laws and regulations set forth at 24 C.F.R. Part 570 Subpart I (except that the Recipient does not assume DEO’s responsibilities described at § 570.604 and the Recipient does not assume DEO’s responsibility for initiating the review process under the provisions of 24 CFR part 58); and chapter 73C-23, Florida Administrative Code (F.A.C.), Effective: May 27, 2018.”
(8) Monitoring
“(a) The Recipient shall monitor its performance under this Agreement, including the performance of any subrecipients, subcontractors and/or consultants who are paid from funds provided under this Agreement, to ensure that the project activities are being accomplished within the specified time periods included in Attachment C – Activity Work Plan and that other performance goals are being achieved.”
Attachment E – Category Specific Conditions: Housing Rehabilitation
“6. Rehabilitation of all housing units funded in part or in full with CDBG funds must be in compliance with the current Florida Building Code – Existing Buildings, as well as local building codes and local maintenance codes. If housing units must be replaced, construction of new units must be in full compliance with current Florida Building Code.”
Florida Administrative Code provisions governing grant administration also provide:
73C-23.0051 Grant Administration and Project Implementation
(4) Procurement. (a) Procurement Policy.
“Each subgrant Recipient (City) shall adopt and follow a local CDBG Procurement Policy that complies with the provisions of 2 CFR 200.317 – 200.326.”
Federal procurement standards further state:
2 CFR § 200.318 — General Procurement Standards
“(b) Oversight of contractors. Recipients (State) and subrecipients (City) must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.”
The City was also required to comply with historic-preservation requirements under the National Historic Preservation Act of 1966, as amended; the procedures in 36 C.F.R. Part 800; the Secretary of the Interior’s Standards for Rehabilitation codified at 36 C.F.R. Part 67; and the Guidelines for Rehabilitating Historic Buildings.