THE FOUR STEP SECTION 106 PROCESS: STEP ONE TENNESSEE STATE HISTORIC PRESERVATION OFFICE REVIEW AND COMPLIANCE SECTION All reproduction rights reserved.

THE FOUR STEP SECTION 106 PROCESS: STEP ONE TENNESSEE STATE HISTORIC PRESERVATION OFFICE REVIEW AND COMPLIANCE SECTION All reproduction rights reserved

What follows is a presentation text in PowerPoint format. It is being presented that way because the staff of the Tennessee State Historic Preservation Office’s Review and Compliance Section believes you will be able to absorb more of the message of the presentation in this format than if it were presented as a printed text. As such, this presentation lacks much of the “punch” of a normal PowerPoint presentation. But since we are not there to narrate all the needed information for you, this is the best way to transmit the information you need to complete Section 106 review swiftly and successfully.

INTRODUCTION

Initiate Section 106 Review Step One

All Federal agencies and applicants for Federal assistance that propose projects, programs, and activities that might affect Historic Properties in Tennessee must complete this step.

It is the Federal Agency Official alone that begins the Section 106 review process (800.3). The Agency Official ultimately decides whether the project, program, or activity is an undertaking as defined in the Regulation (36 CFR 800.3(a) and 800.9(a)) that has the potential to cause effects to Historic Properties (36 CFR 800.5). The Agency Official, however, does not make these decisions in a vacuum.

The 36 CFR 800 Regulation directs each Federal agency to base these decisions upon the outcome of consultation. The agency first must refer to the strict statutory and regulatory definitions of an undertaking found at 36 CFR 800. Then, the agency must rely upon its own regulations, system-wide best practices, and standard operating procedures to refine that definition. Then the agency must consult with the appropriate SHPO and other Consulting Parties to inform the final decision.

QUESTIONS YOU SHOULD ANSWER BEFORE BEGINNING STEP ONE

Questions: Is the project under review an "Undertaking" as defined in the National Historic Preservation Act and in the 36 CFR 800 Regulation? Is the project under review an "Undertaking" as defined in the National Historic Preservation Act and in the 36 CFR 800 Regulation? What is the Federal agency's mission as demonstrated in the purpose and need of the project under review? What is the Federal agency's mission as demonstrated in the purpose and need of the project under review? Step One: Initiate The Section 106 Process Step One: Initiate The Section 106 Process :

What is the project’s possible Area of Potential Effects as defined in the Act and in the 36 CFR 800 Regulation? What is the project’s possible Area of Potential Effects as defined in the Act and in the 36 CFR 800 Regulation? What is the size and nature of the undertaking as defined in the 36 CFR Part 800 Regulation? What is the size and nature of the undertaking as defined in the 36 CFR Part 800 Regulation? What is the appropriate degree of Federal involvement in the Section 106 process as defined in the 36 CFR 800 Regulation? What is the appropriate degree of Federal involvement in the Section 106 process as defined in the 36 CFR 800 Regulation?. Questions:

What is the likelihood of identifying Historic Properties within the Area of Potential Effects? What is the likelihood of identifying Historic Properties within the Area of Potential Effects? What is the nature and extent of potential effects to Historic Properties as defined in the Criteria of Adverse Effect codified at 36 CFR 800.5? What is the nature and extent of potential effects to Historic Properties as defined in the Criteria of Adverse Effect codified at 36 CFR 800.5? Who is the appropriate State Historic Preservation Officer/Tribal Historic Preservation Officer as defined at 36 CFR 800.2? Who is the appropriate State Historic Preservation Officer/Tribal Historic Preservation Officer as defined at 36 CFR 800.2?. Questions:

How do you plan to involve the public? How do you plan to involve the public? Who are the other likely Consulting Parties? Who are the other likely Consulting Parties? Do you plan to meld the Section 106 review process into the National Environmental Policy Act process, a previously executed Programmatic Agreement, or other counterpart process reviewed and approved by the ACHP? Do you plan to meld the Section 106 review process into the National Environmental Policy Act process, a previously executed Programmatic Agreement, or other counterpart process reviewed and approved by the ACHP?. Questions:

What is the appropriate degree of Federal involvement as defined in the Regulation? Things to Keep In Mind: The agency official should plan consultations appropriate to the SCALE of the undertaking and the SCOPE of Federal involvement and coordinated with other requirements of other statutes, as applicable, such as the National Environmental Policy Act, the Native American Graves Protection and Repatriation Act, the American Indian Religious Freedom Act, the Archeological Resources Protection Act, and agency-specific legislation.

WHAT IS MEANT BY SECTION 106 “SCALE” AND “SCOPE”?

Section 106 “Scale” and “Scope” is comparable to NEPA “Context” and “Intensity”

Things to Keep In Mind: 40 CFR 1508.27 requires agency official considerations of both context and intensity: (a) Context. This means that the significance of an action must be analyzed in several contexts such as society as a whole (human, national), the affected region, the affected interests, and the locality. Significance varies with the setting of the proposed action. For instance, in the case of a site- specific action, significance would usually depend upon the effects in the locale rather than in the world as a whole. Both short- and long-term effects are relevant.

Here, context involves the close relationship between the proposed project and known or as-yet-unknown historic properties. Things to Keep In Mind:

40 CFR 1508.27 requires agency official considerations of both context and intensity: (b) Intensity. This refers to the severity of impact. Responsible officials must bear in mind that more than one agency may make decisions about partial aspects of a major action. The following issues should be considered in evaluating intensity: Things to Keep In Mind:

Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial. Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial. The degree to which the proposed action affects public health or safety. The degree to which the proposed action affects public health or safety. Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. Things to Keep In Mind:

The degree to which the effects on the quality of the human environment are likely to be highly controversial. The degree to which the effects on the quality of the human environment are likely to be highly controversial. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration. Things to Keep In Mind:

Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources. Things to Keep In Mind:

The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment. Things to Keep In Mind:

40 CFR 1508.27 requires agency official considerations of both context and intensity: Intensity also refers to the level of direct and indirect impact of the project upon historic properties. Things to Keep In Mind:

Summing Up: All this means is that different types of Federal undertaking demand different levels of Federal Agency Official effort in fulfilling the requirements of Section 106 review.

These varying levels of effort may include: initial review requests to the Tennessee SHPO and other Consulting Parties, site visits, the preparation of cultural resources survey reports, and formal Public Meetings and Consulting Parties Meetings. Summing Up:

STEP ONE SECTION 106 CHECKLIST

Check the appropriate line (Yes, No) as you complete each specific task.

1.Establish Whether the Project is an Undertaking: Remember! Undertakings are defined in the Section 106 Regulation (800.3(a) and 800.9(a) and 800.16(y)).

Sec. 800.3 Initiation of the Section 106 process. (a) ESTABLISH UNDERTAKING. The agency official shall determine whether the proposed Federal action is an undertaking as defined in 36 CFR 800.16(y) and, if so, whether it is a type of activity that has the potential to cause effects on historic properties (800.3(a) and 800.9(a) (a) ESTABLISH UNDERTAKING. The agency official shall determine whether the proposed Federal action is an undertaking as defined in 36 CFR 800.16(y) and, if so, whether it is a type of activity that has the potential to cause effects on historic properties (800.3(a) and 800.9(a)

PARSING THE REGULATORY DEFINITION OF AN UNDERTAKING(CHECK ALL THAT APPLY)

project, activity, or program________, project, activity, or program________, Federally funded in whole or in part________; or, Federally funded in whole or in part________; or, under the direct or indirect jurisdiction of a Federal agency________, under the direct or indirect jurisdiction of a Federal agency________, including those carried out by or on behalf of a Federal agency; or________ including those carried out by or on behalf of a Federal agency; or________ those carried out with Federal financial assistance; or________ those carried out with Federal financial assistance; or________ those requiring a Federal permit, license or approval; or________ those requiring a Federal permit, license or approval; or________ those subject to State or local regulation administered pursuant to a delegation or approval by a Federal agency_________. those subject to State or local regulation administered pursuant to a delegation or approval by a Federal agency_________.. 36 CFR 800.16(y)

that might cause an effect to a property ELIGIBLE FOR LISTING IN OR LISTED IN the National Register of Historic Places. Yes_________ No_________ 36 CFR 800.3(a)

This rather broad definition is the consequence of the most recent amendment to the NHPA (1992). At that time, Congress wanted to make plain that it intended for the definition of undertaking to cover most everything the Federal government did that might affect historic properties. Undertaking

More recent federal litigation has restricted this definition in some areas involving federal pass throughs to state governments of authority to issue certain environmental permits. Overall, however, this broad definition of an undertaking has stood the test of time. Remember that Federal undertakings have both direct and indirect effects upon historic properties. Undertaking

If more than one state is involved in an undertaking, the involved State Historic Preservation Offices may decide to choose a lead State Historic Preservation Officer to act on its behalf in the Section 106 process, including taking actions that would conclude the Section 106 process. Undertaking

If more than one federal agency is involved in an undertaking, some or all of the agencies may choose a lead federal agency and a lead agency official who acts on their behalf, discharging their collective responsibilities under Section 106. Those federal agencies that do not choose a lead federal agency remain individually responsible for their compliance. Undertaking

CAVEAT

Section 214 of NHPA states, “The ACHP, with the concurrence of the Secretary [of the Interior], shall promulgate regulations or guidelines, as appropriate, under which Federal programs or undertakings may be EXEMPTED from any or all of the requirements of this Act when such exemption is determined to be consistent with purposes of NHPA, taking into consideration the magnitude of the exempted undertaking or program and the likelihood of impairment of historic properties.

Section 214 of NHPA, therefore, allows for a CATEGORICAL NO HISTORIC PROPERTIES AFFECTED determination either from the ACHP, or, by inference, from a particular SHPO, when deemed appropriate.

TWO POSSIBILE FEDERAL AGENCY FINDINGS

1) No Undertaking The agency official decides that the project under review does not meet the definition of an undertaking. If this is the case, the agency official has completed Section 106 review, but may be called upon by the ACHP to justify the “no undertaking” decision later.

2) Undertaking The agency official decides that the project under review meets the definition of an undertaking. The agency official then informs the Tennessee State Historic Preservation Office, begins consultation, assembles a slate of additional Consulting Parties, informs the Public, and proceeds to Step Two.

2) Undertaking The Tennessee State Historic Preservation Office may suggest added consulting parties and consult with the agency official on proper ways for the interests of the Public to be included in Section 106 review.

2) Undertaking Since a correct determination about whether a Federal activity is an “undertaking” is critical to successful Section 106 review, test your decision again and again.

2) Undertaking What are some specific questions to ask yourself when making a determination about whether a Federal activity is an “undertaking”?

Does your project, program, or activity involve Federal funding, licensing, permitting or other type of approval or assistance? Yes_________ No_________ Don’t know_________

Does it have the potential to alter any eligibility-defining characteristic of a Historic Property that qualifies that Historic Property for eligibility in the National Register of Historic Places now or in the future? Yes_________ No_________ Don’t know_________

WHAT ARE SOME ELIGIBILITY- DEFINING CHARACTERISTICS?

Some Eligibility-defining Characteristic Architectural features such as windows, doors, rooflines, exterior materials, interior architectural features such as mantles, moldings, etc. Architectural features such as windows, doors, rooflines, exterior materials, interior architectural features such as mantles, moldings, etc. Setting Setting Viewshed Viewshed Previously undisturbed archaeology Previously undisturbed archaeology

Reality Check: If the answer to both questions is “Yes,” your activity is an undertaking. Proceed to the next question.

Firewall: If the answer to either question is “No,” You have no undertaking. Your project is not subject to Section 106 review. But you had better make real sure of this.

Firewall: 1) No undertaking/No potential to cause effects If the Agency Official determines that there is no undertaking as defined in Section 800.16(y), or there is an undertaking but it is not a type of activity that has the potential to cause effects on historic properties, there are no further obligations under Section 106 or the Council’s regulations. Agencies are strongly advised to keep appropriate records of such findings in case questions are raised by members of the public or other parties at a later date* *Advisory Council on Historic Preservation Working with Section 106, User’s Guide

Reality Check: If the answer is “Don’t know,” or, you determine that you have completed the Section 106 process successfully because your project is not an undertaking, answer the following three even more specific questions to ensure you have made the correct decision.

Questions: I. Does your project involve FEDERAL FUNDING, OR LICENSING, PERMITTING OR OTHER KINDS OF APPROVING either by a Federal agency or applicant for Federal assistance of any of the following:

Questions: Any new construction, including preservation, rehabilitation, reconstruction, or restoration directly or indirectly associated with the project Yes_________ No_________

*Secretary of the Interior's Standards for Treatment of Historic Properties PRESERVATION IS DEFINED as the act or process of applying measures necessary to sustain the existing form, integrity, and materials of an historic property. Work, including preliminary measures to protect and stabilize the property, generally focuses upon the ongoing maintenance and repair of historic materials and features rather than extensive replacement and new construction. New exterior additions are not within the scope of this treatment; however, the limited and sensitive upgrading of technical, electrical, and plumbing systems and other code-required work to make properties functional is appropriate within a preservation project.*

*Secretary of the Interior's Standards for Treatment of Historic Properties REHABILITATION IS DEFINED as the act or process of returning a property to a state of utility and of making possible a compatible use for a property through repair, alterations, and additions which makes possible an efficient contemporary use while preserving those portions or features which convey its historical, cultural, or architectural values.*

*Secretary of the Interior's Standards for Treatment of Historic Properties RESTORATION IS DEFINED AS the act or process of accurately depicting the form, features, and character of a property as it appeared at a particular period of time by means of the removal of features from other periods in its history and reconstruction of missing features from the restoration period. The limited and sensitive upgrading of mechanical, electrical, and plumbing systems and other code-required work to make properties functional is appropriate within a restoration project.*

*Secretary of the Interior's Standards for Treatment of Historic Properties RECONSTRUCTION IS DEFINED AS the act or process of depicting, by means of new construction, the form, features, and detailing of a non- surviving site, landscape, building, structure, or object for the purpose of replicating its appearance at a specific period of time and in its historic location.*

Questions: Any partial or complete demolition of any structure, including abandonment directly or indirectly associated with the project Yes_________ No_________

Questions: Any modification of any structure directly or indirectly associated with the project Yes_________ No_________

Any relocation of any structure directly or indirectly associated with the project Yes_________ No_________ Questions:

Any ground-covering activity such as a landfill, aeration field, spoil, staging area, biomat, fill into wetlands, trail, streambank or shoreline restoration, barrow, staging area, dock, pier, ramp, float, or riprap directly or indirectly associated with the project Yes_________ No_________ Questions:

Any wind farm, solar voltaic panel, pipeline, transmission line, fuel storage facility, industrial plant, inter-modal facility, or terminal directly or indirectly associated with the project Any wind farm, solar voltaic panel, pipeline, transmission line, fuel storage facility, industrial plant, inter-modal facility, or terminal directly or indirectly associated with the project Yes_________ No_________ Questions:

Any natural resources conservation activity such as a farm pond, watershed rehabilitation, plowing, streambank relocation, or forestry preservation directly or indirectly associated with the project Yes_________ No_________ Questions:

Any planting or removal of vegetation, including reforestation, controlled burn, or tree, root, and brush removal directly or indirectly associated with the project Yes_________ No_________ Questions:

Any reclamation program such as superfund, brownfield reclamation, mining reclamation, or forest reclamation directly or indirectly associated with the project Yes_________ No_________ Questions:

Any transfer or lease of any Federal property, including structures, out of Federal ownership or from one Federal agency to another directly or indirectly associated with the project Yes_________ No_________ Questions:

Any mortgage guarantee or any other similar type of Federal financial support to applicants directly or indirectly associated with the project Yes_________ No_________ Questions:

Any purposeful and deliberate Federal agency neglect of any structure under its jurisdiction or control that has been determined National Register eligible directly or indirectly associated with the project Yes_________ No_________ Questions:

Any survey-related data recovery of any significant archaeological Historic Property that is not Archaeological Resources Protection Act permitted directly or indirectly associated with the project Yes_________ No_________ Questions:

Any survey-related data recovery of any significant archaeological Historic Property directly or indirectly associated with the project that is Archaeological Resources Protection Act permitted, but that has a collateral element that may affect an historic property Yes_________ No_________ Questions:

Any data recovery of any archaeological resource directly or indirectly associated with the project that is significant for reasons other than purely research (National Register Criterion “D”) value (that is, significant for reasons of religious or cultural or historical association) Yes_________ No_________ Questions:

Removal of any significant archaeological resources directly or indirectly associated with the project that contain human remains or directly associated funerary objects Yes_________ No_________ Questions:

Neglect of any Federally owned or controlled land surface that contains or has the likelihood to contain significant archaeological resources directly or indirectly associated with the project through such actions as the knowing sanction of stream bank erosion, wind erosion, rain erosion, or other preventable natural force Yes_________ No_________ Yes_________ No_________ Questions:

Reality check: If you checked “Yes” to any of the preceding types of activities, then your project really is an undertaking subject to Section 106 review. Therefore...

Reality check: …proceed to the next Step One numbered question.

2. Does the activity have the potential to cause an EFFECT to an Historic Property? Yes_________ No_________ Questions:

“EFFECT” means alteration to the characteristics of an historic property qualifying it for inclusion in or eligibility for the National Register. This is different from “Adverse Effect,” which means alteration to the characteristics of an historic property qualifying it for inclusion in or eligibility for the National Register in a manner that jeopardizes its future eligibility.

Whether you checked “Yes” or “No”as a response to any previous question, you still must coordinate with other required reviews, laws, and regulations.

COORDINATE WITH OTHER REVIEWS. The agency official should coordinate the steps of the Section 106 process, as appropriate, with the overall planning schedule for the undertaking and with any reviews required under other authorities such as the National Environmental Policy Act, the Native American Graves Protection and Repatriation Act, the American Indian Religious Freedom Act, the Archeological Resources Protection Act, and agency-specific legislation, such as section 4(f) of the Department of Transportation Act. Where consistent with the procedures in this subpart, the agency official may use information developed for other reviews under Federal, State, or tribal law to meet the requirements of Section 106. COORDINATE WITH OTHER REVIEWS. The agency official should coordinate the steps of the Section 106 process, as appropriate, with the overall planning schedule for the undertaking and with any reviews required under other authorities such as the National Environmental Policy Act, the Native American Graves Protection and Repatriation Act, the American Indian Religious Freedom Act, the Archeological Resources Protection Act, and agency-specific legislation, such as section 4(f) of the Department of Transportation Act. Where consistent with the procedures in this subpart, the agency official may use information developed for other reviews under Federal, State, or tribal law to meet the requirements of Section 106.

3. Is the activity subject to the stipulations of an existing Section 106 Programmatic Agreement (PA)? Yes_________ No_________ Questions:

Reality check: If you checked “Yes” to the PA question, then once you record how the project complies with the terms of the PA, Section 106 review is complete and you are in compliance. To remain in compliance, you must implement the project in accordance with the PA.

If you checked “No” to all of the preceding questions, then your project IS NOT AN UNDERTAKING and you have successfully completed Section 106 review. THIS IS HIGHLY UNLIKELY… Reality check:

…It is therefore best to seek concurrence with the Tennessee State Historic Preservation Office before assuming you have no undertaking. Reality check:

How do you do that?

Submit a formal project description identifying the Federal agency, and a location map, and current photographic documentation to the Tennessee State Historic Preservation Office. Joseph Y. Garrison, PhD, Review and Compliance Coordinator, Tennessee Historical Commission, 2941 Lebanon Road, Nashville, Tennessee, 37243-0442 Joseph Y. Garrison, PhD, Review and Compliance Coordinator, Tennessee Historical Commission, 2941 Lebanon Road, Nashville, Tennessee, 37243-0442 Reality check:

Firewall: If the Tennessee State Historic Preservation Office does not respond within a reasonable amount of time (at least 30 days), you may then presume your project is not an undertaking subject to Section 106 review.

IF AT THE END OF THIS PROCESS YOU ARE CERTAIN THAT YOUR PROJECT, PROGRAM, OR ACTIVITY HAS NO POTENTIAL TO CAUSE EFFECTS TO HISTORIC PROPERTIES…

1) No potential to cause effects. If the undertaking is a type of activity that does not have the potential to cause effects on historic properties, assuming such historic properties were present, the agency official has no further obligations under Section 106. 1) No potential to cause effects. If the undertaking is a type of activity that does not have the potential to cause effects on historic properties, assuming such historic properties were present, the agency official has no further obligations under Section 106. 36CFR800.3

If you have determined that your project is, in fact, 2) an undertaking, MUCH MORE LIKELY, and, therefore, subject to Section 106 review… what do you do? Firewall:

INITIATE CONSULTATION WITH THE APPROPRIATE SHPO

IDENTIFY THE APPROPRIATE SHPO. As part of its initial planning, the agency official shall determine the appropriate SHPO or SHPOs to be involved in the Section 106 process. The agency official shall also determine whether the undertaking may occur on or affect historic properties on any tribal lands and, if so, whether a THPO has assumed the duties of the SHPO. The agency official shall then initiate consultation with the appropriate officer or officers.

2. Identify the appropriate State Historic Preservation Office and notify it that you have begun the Section 106 review process; (800.16(f), 800.3(c), 800.3(f), 800.3(f)(1) and 800.3(f)(2)), or Tribal Historic Preservation Office ( IF THE UNDERTAKING IS PROPOSED EXCLUSIVELY ON TRIBAL LAND ).

WHY DO FEDERAL AGENCIES NOT INITIATE CONSULTATION WITH THPOs IN TENNESSEE?

BECAUSE THERE ARE NO FEDERALLY- DESIGNATED TRIBAL LANDS LOCATED IN TENNESSEE

DOES THIS MEAN THAT YOU DO NOT HAVE TO CONSULT WITH INDIAN TRIBES?

NO! THERE ARE MANY TRIBES THAT PLACE RELIGIOUS AND CULTURAL VALUE UPON CERTAIN SITES LOCATED IN TENNESSEE.

YOU MUST CONSULT WITH THE AUTHORIZED REPRESENTATIVES OF THESE TRIBES (WHO MAY OR MAY NOT BE THPOs). THEY WILL ASSIST YOU IN TAKING SITES OF SPECIAL SIGNIFICANCE TO THEM INTO ACCOUNT.

HOW DO YOU IDENTIFY THE APPROPRIATE SHPO?

IDENTIFY THE APPROPRIATE SHPO AND TRIBAL REPRESENTATIVE IDENTIFY THE APPROPRIATE SHPO AND TRIBAL REPRESENTATIVE You can find SHPO/TRIBAL REPRESENTATIVE contact information at ACHP.gov and at the Tennessee Historical Commission Website.

IN TENNESSEE, THE APPROPRIATE SHPO IS THE TENNESSEE HISTORICAL COMMISSION/STATE HISTORIC PRESERVATION OFFICE

INITIAL CONSULTATION WITH THE SHPO: WHAT ARE THE OPTIONS?

Federal agencies may choose between two methods of conducting initial consultation with the Tennessee SHPO. Initial Consultation With the SHPO:

Initial Consultation With the SHPO: Method One As part of its initial planning, the agency official shall determine for her/himself the appropriate SHPO to be involved in the Section 106 process.

Initial Consultation With the SHPO: Method Two The agency official may authorize an applicant or group of applicants to initiate consultation with the SHPO and others, but remains legally responsible for all findings and determinations charged to the agency official. The agency official shall notify the SHPO when an applicant or group of applicants is so authorized.

Initial Consultation With the SHPO: Method Two A Federal agency may authorize all applicants in a specific program pursuant to this section by providing notice to all SHPOs. Federal agencies that provide authorizations to applicants remain responsible for their government-to-government relationships with Indian tribes.

In other words…

1.) It may begin consultation – by a Federal agency direct consultation request - begin consultation. (Land- holding, building-holding agencies; some funding agencies; some permitting agencies) Consultation:

2.) It may also begin the process indirectly through a review request submitted by a duly certified applicant for Federal funds, licenses, or permits. (Grant applicants, assistance applicants, permit applicants, license applicants, approval applicants) Consultation:

Questions: How do you choose to initiate consultation with the Tennessee SHPO for this undertaking? Directly_____ Indirectly_____

Initial Review Documentation : Either way, you or your applicant should submit as much of the following information as you can accumulate to the Tennessee State Historic Preservation Officer to initiate Section 106 review. Prepare the following basic documentation:

INITIAL REVIEW: WHAT IS THE BASIC DOCUMENTATION CHECKLIST?

Questions: A cover letter on AGENCY OR APPLICANT contact information letterhead requesting Section 106 review of EACH SEPARATE SPECIFIC PROJECT OR ACTIVITY (the Tennessee SHPO prefers multiple projects within the same undertaking grouped by county). The Review Request letter should contain the following: Yes_________ No_________ I

A CAPTION HEADING CONTAINING…

The name or initials of EACH Federal agency funding, licensing, permitting, or approving the undertaking Yes_________ No_________ Questions:

The name of the Federal undertaking. Yes_________ No_________ Questions:

The appropriate municipal designator or legal description (STREET ADDRESS, CITY, COUNTY) of the undertaking. If a property such as a vacant lot or rural property does not have an address, then enter its street name, lot number, or other legal location. If the project is located in an unincorporated area, so indicate that. Yes_________ No_________ Questions:

Appropriate “Agency Official” (800.2) contact information (address, telephone, email, etc.), and if applicable, the name, address, telephone number, and email address of the applicant for Federal funding, licensing, permitting, or approval. Yes_________ No_________ Questions:

The applicable statute or regulation, license, or permit authorizing the Federal action. Yes_________ No_________ Questions:

If applicable, a copy of the formal Federal agency authorization to initiate consultation as the applicant for Federal funding, licensing, permitting, or approval. Yes_________ No_________ Questions:

The size of the undertaking in acres. Yes_________ No_________ Questions:

The size, terrain, and present land uses of the proposed Area of Potential Effects ((APE) (36CFR800.16)), as well as that of adjacent land. Yes_________ No_________ Questions:

The type and level of Federal involvement: Funding, Licensing, Permitting, Approving. Yes_________ No_________ Questions:

A project narrative that describes the undertaking in enough detail to enable a cold reader unfamiliar with the scope of the undertaking or its location to gain a full understanding of the undertaking and all of its elements and their potential to affect directly and indirectly any Historic Properties within the proposed Area of Potential Effects Yes_________ No_________

The project narrative should begin with a ONE PARAGRAPH ABSTRACT, and should BRIEFLY specify the underlying purpose and need to which the agency is responding in proposing the undertaking. Yes_________ No_________ Questions:

The project narrative should specify the Project Type: Road/Highway Construction or Improvements, Demolition, Rehabilitation, Addition to Existing Building/Structure, New Construction, Utilities/Infrastructure, Other Ground Disturbance, etc..* Yes_________ No_________ *Georgia Historic Preservation Division Environmental Review Form Questions:

The project narrative should make note of and describe any Historic Properties (both architectural and archaeological) previously identified plus any potential Historic Properties located within the proposed Area of Potential Effects that might be affected directly and indirectly. Yes_________ No_________ Questions:

LIST YOUR SUGGESTED CONSULTING PARTIES IN YOUR INITIAL TENNESSEE SHPO REVIEW REQUEST

(f) IDENTIFY OTHER CONSULTING PARTIES. In consultation with the SHPO, the agency official shall identify any other parties entitled to be consulting parties and invite them to participate as such in the Section 106 process. The agency official may invite others to participate as consulting parties as the Section 106 process moves forward

Consultation: A preliminary list of Consulting Parties that the agency or applicant has recommended to participate in consultation relative to the undertaking. Yes_________ No_________

Remember! Consulting Parties include: State Historic Preservation Officers Tribal Historic Preservation Offices ON TRIBAL LANDS Tribes and Native Hawaiian organizations OFF TRIBAL LANDS Representatives of local governments Applicants for Federal assistance Property owners Groups and individuals with standing Consultation:

A Current List of Federally Recognized Tribes http://www.tn.gov/environment/hist/pdf/appexd.pdf Consulting Archaeologists Working In Tennessee http://www.tn.gov/environment/hist/pdf/archaeol.pdf Tennessee Division of Archaeology http://www.tn.gov/environment/arch/ Tennessee County Historians http://tn.gov/tsla/history/misc/historians.htm Tennessee Certified Local Government Contacts http://www.tn.gov/environment/hist/pdf/clg_list.pdf

Remember! CONSULTING PARTIES do not usually include: The Advisory Council on Historic Preservation (may be specifically invited to participate or it may request to participate subject to Appendix “A” of the 36 CFR Part 800 regulation) People or groups that do not have standing The Public. Consultation:

THE QUAD MAP

PROVIDE THE TENNESSEE SHPO WITH AN 8 ½” X 11” TRUE-TO-SCALE COPY OF A 1- 24000 SCALE USGS 7 ½ MINUTE SERIES TOPOGRAPHIC MAP SECTION…

…WITH THE UNDERTAKING’S APE CLEARLY BOUNDED ON IT AND INDICATING ALL ITS CONSTITUENT PARTS

THE TENNESSEE SHPO SITE FILE MAPS ARE 1-24000 SCALE USGS 7 ½ MINUTE SERIES 1-24000 SCALE USGS 7 ½ MINUTE SERIES

Questions: A USGS 7 1/2 minute series (1 TO 24,000 scale) topographic quadrant map ( NOT MapQuest, TopoZone, Google, or Yahoo Maps) clearly indicating the boundary of the undertaking, the location of all undertaking elements, and the undertaking’s suggested Area of Potential Effects (800.4). Yes_________ No_________

WHAT IS A U. S. GEOLOGICAL SURVEY 7 1/2 MINUTE SERIES/1 TO 24,000 SCALE TOPOGRAPHIC MAP AND WHY IS IT IMPORTANT TO USE THIS KIND OF MAP WHEN PREPARING A DOCUMENT TO SEND TO THE SHPO AND OTHER CONSULTING PARTIES? WHAT IS A U. S. GEOLOGICAL SURVEY 7 1/2 MINUTE SERIES/1 TO 24,000 SCALE TOPOGRAPHIC MAP AND WHY IS IT IMPORTANT TO USE THIS KIND OF MAP WHEN PREPARING A DOCUMENT TO SEND TO THE SHPO AND OTHER CONSULTING PARTIES?

The United States Department of the Interior, Geological Survey (USGS) – sometimes with the help of other agencies - prepares and issues topographic maps that record the land area of the United States. They are referred to as 7 1/2 minute series maps because they document seven and one half minutes of latitude and longitude. These maps are also referred to as 1:24000 scale maps. 7 1/2 MINUTE SERIES/1 TO 24,000 SCALE TOPOGRAPHIC MAP

These maps accurately show landforms, contour intervals, watercourses, geographical boundaries, and manmade features such as buildings, roads, railroads, et cetera. Most cultural resources site surveys use USGS 7 ½ minute quadrant topographic maps to locate their findings. Most State Historic Preservation Officers and Tribal Historic Preservation Officers use these types of maps as well to record the locations of properties that have been previously surveyed for National Register eligibility. That means that this type of map is the industry standard. 7 1/2 MINUTE SERIES/1 TO 24,000 SCALE TOPOGRAPHIC MAP

USGS 7.5 minute topographic maps may be ordered, downloaded or printed from the Internet at the following locations: Tennessee State Division of Geology, or Tennessee State Division of Geology, or The United States Geological Survey website [free] The United States Geological Survey website [free] 7 1/2 MINUTE SERIES/1 TO 24,000 SCALE TOPOGRAPHIC MAP

THE UNDERTAKING’S AREA OF POTENTIAL EFFECTS What are you documenting on this topographic map?

Area of Potential Effects: Area of potential effects means the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist.

MORE INITIAL SHPO REVIEW REQUEST DOCUMENTATION

Questions: Other suitably scaled maps or site plans as necessary to depict the extent of the undertaking and its locational relationship to its surroundings and environment. Yes_________ No_________

AND…

Questions: Original, current GROUND LEVEL/NOT AERIAL high resolution, color, digital photographs of the undertaking’s Area of Potential Effects. Yes_________ No_________

“The photography should document not only the project area, but also any adjacent properties that are within the APE If the APE includes buildings or structures, please include clear views of each. All photography should be keyed to a site map and project plans (as applicable). Photographs should be individually numbered, and corresponding numbers should be placed on the map or site plan, showing location and direction of view. Should your project entail the alteration of existing historic structures, please provide photographs of existing conditions of sites, buildings and interior areas to be impacted.”* *Georgia Historic Preservation Division Environmental Review Form

Original chemical or digital photographs of the undertaking’s proposed Area of Potential Effects must be numbered and clearly keyed to one of the above maps or site plans (“Tennessee State Historic Preservation Office, Review and Compliance Section, Photographic Policy Standards and Guidelines:Initial Request, 2011”*). ______ *Excerpted from “National Register Photo Policy Factsheet” Office of the Keeper of the National Register of Historic Places, 2008

Federal agencies and applicants for Federal assistance must provide photographic documentation to accompany their Section 106 review requests. This photographic documentation must comply with the following Policy Standards and Guidelines. 1. Buildings, structures, and objects: a. Submit photographs showing the principal facades and the setting in which the property is located. Additions, alterations, intrusions, and dependencies should appear in the photographs. b. Include views of interiors, outbuildings, landscaping, or unusual features if they contribute to the significance of the property.

2. Historic and archeological sites: a. Submit photographs showing the condition of the site and any above- ground or surface features and disturbances. b. If relevant to the evaluation of significance, include drawings or photographs illustrating artifacts that have been removed from the site. c. At least one photograph must show the physical environment and topography of the site.

3. Architectural and Historic Districts (key all photographs to the sketch map for the district): a. Submit photographs showing major building types and styles, pivotal buildings and structures, and representative noncontributing resources. b. Streetscapes and landscapes are recommended. Aerial views may also be useful. Views of significant topographic features and spatial elements should also be submitted. c. Views of individual buildings are not necessary if streetscape views clearly illustrate the significant historical and architectural qualities of the district.

4. Archeological Districts: a. Submit photographs of the principal sites and site types within the district following the guidelines for archaeological sites (see above). 5. Selecting a Digital Camera: Six megapixel or greater digital SLR camera 6. Taking the Picture: Tag Image File format (TIFF) or RAW format images. Six megapixels or greater (2000 x 3000 pixel image) at 300 dpi

7. Printing the Images: a. No more than two images per 8 ½” X 11” page b. Manufacturer recommended ink for photograph printing - some examples: 1. Epson UltraChrome K3 2. Kodak No. 10 Pigmented Inks 3. HP Vivera Pigment Inks 4. Epson Claria “Hi-Definition Inks” 5. Epson DuraBrite Ultra Pigmented Inks 6. HP Vivera 95 dye-based inks

8. Examples of acceptable photo label – place below photograph: a. Name of Property: b. Street Address: c. City or Vicinity: d. County: e. State: f. Date of Photograph:

AND…

Questions: Any available information including DATES OF CONSTRUCTION of buildings either inside the undertaking footprint or within view or sound of the undertaking (Area of Potential Effects) (NOT THE DATES WHEN NEW CONSTRUCTION WILL BEGIN). Yes_________ No_________

AND…

Questions: Any required forms specified by a particular Federal agency such as FCC Form-620 and FDIC “Request for Cultural Resources Review”. Yes_________ No_________

AND…

Questions: A request for any data or information from the Tennessee SHPO concerning known Historic Properties located within the undertaking’s Area of Potential Effects. Yes_________ No_________

NPS Focus allows you to search the National Register Information System; a database of over 85,000 historic buildings, districts, sites, structures and objects listed on the National Register of Historic Places. The information is downloadable in a variety of formats, including simplified versions of the data. http://nrhp.focus.nps.gov/natreg/docs/Download.html

Reality Check: The Tennessee State Historic Preservation Office requires this level of documentation at minimum for initial project review. So, do not proceed until you have answered all the preceding questions “Yes.”

FORMALLY IDENTIFY OTHER CONSULTING PARTIES

The Tennessee State Historic Preservation Office is required under the 36 CFR 800 Regulation to respond to a Federal agency’s direct consultation request or a duly certified applicant’s review request within thirty days. The agency and State Historic Preservation Office then should consult together to identify other appropriate Consulting Parties (800.16(f), 800.3(c), 800.3(f), 800.3(f)(1) and 800.3(f)(2)). The Federal agency should invite all agreed- upon Consulting Parties to participate in the consultation process. The Federal agency should take the views of all Consulting Parties into account. Consultation with all Consulting Parties runs through the entire Section 106 review process.

Consultation: 3. You must now confirm your selection of other Consulting Parties with the help of the Tennessee State Historic Preservation Officer: You and the Tennessee SHPO consult together to identify ALL appropriate Consulting Parties, if any, (800.16(f), 800.3(c), 800.3(f), 800.3(f)(1) and 800.3(f)(2)).

4. You must also consider at this point; if, what types, and how some project-related locational information should be made to remain confidential. This is particularly true of archaeological sites identified during the initial review process. MORE ABOUT CONFIDENTIALITY CONCERNS LATER Consultation:

MORE ABOUT IDENTIFYING OTHER CONSULTING PARTIES: 36 CFR 800.2

(1) Involve local governments and applicants. The agency official shall invite any local governments or applicants that are entitled to be consulting parties under Sec. 800.2(c). Yes_________ No_________ Consultation:

(2) Involving Indian tribes. The agency official shall make a reasonable and good faith effort to identify any Indian tribes that might attach religious and cultural significance to historic properties in the area of potential effects and invite them to be consulting parties. Such Indian tribe that requests in writing to be a consulting party shall be one Yes_________ No_________ Consultation:

(3) Requests to be consulting parties. The agency official shall consider all written requests of individuals and organizations to participate as consulting parties and, in consultation with the SHPO, determine which should be consulting parties Yes_________ No_________ Consultation:

Questions: 36 CFR Part 800.2 lists Consulting Parties as: Additional State Historic Preservation Offices (Undertakings in multiple states). _____ Additional Tribal Historic Preservation Officers on tribal lands. _____ Additional Indian tribes and Native Hawaiian organizations that retain cultural and religious interests off tribal lands. _____

Additional Representatives of local governments. _____ Additional Applicants for Federal assistance, permits, licenses and other approvals. _____ Additional Federal agencies_____ Questions:

Certain additional individuals and organizations such as affected property owners with a demonstrated interest in the undertaking may participate as Consulting Parties due to the nature of their legal or economic relation to the undertaking or affected properties, or their concern with the undertaking's effects on Historic Properties. _____ Questions:

In rare instances, the Advisory Council on Historic Preservation may participate if invited or if it desires to participate under 36 CFR 800 Appendix “A”. _____ Questions:

Reality Check: Remember, consultation with all Consulting Parties runs through the entire Section 106 review process. Do not proceed until all of the preceding questions are answered “Yes.”

AS YOU ARE CONSULTING WITH THE SHPO AND IDENTIFIED CONSULTING PARTIES, WHAT ELSE SHOULD YOU DO?

Possible, not required: Are you planning to coordination Section 106 review with other Federal environmental reviews? Yes_________ No_________ Questions:

Possible, not required: Are you planning to develop a common set of project documents that satisfies the stated documentation needs of all pertinent review authorities including the State Historic Preservation Office? Yes_________ No_________ Questions:

EXPEDITING CONSULTATION WITH THE SHPO AND OTHER CONSULTING PARTIES

Consultation: (g) EXPEDITING CONSULTATION. A consultation by the agency official with the SHPO and other consulting parties may address multiple steps in Secs. 800.3 through 800.6 where the agency official and the SHPO agree it is appropriate as long as the consulting parties and the public have an adequate opportunity to express their views as provided in Sec. 800.2(d). (g) EXPEDITING CONSULTATION. A consultation by the agency official with the SHPO and other consulting parties may address multiple steps in Secs. 800.3 through 800.6 where the agency official and the SHPO agree it is appropriate as long as the consulting parties and the public have an adequate opportunity to express their views as provided in Sec. 800.2(d).

WHILE YOU ARE CONSULTING WITH THE SHPO, WHAT ELSE SHOULD YOU BE DOING?

PLAN TO INVOLVE THE PUBLIC

(e) PLAN TO INVOLVE THE PUBLIC. In consultation with the SHPO, the agency official shall plan for involving the public in the Section 106 process. The agency official shall identify the appropriate points for seeking public input and for notifying the public of proposed actions, consistent with 36 CFR 800.

The Federal agency involves the public in the Section 106 process (800.3(e), 800.2(d)(1) and 800.11(c)). As is the case with Consulting Parties, the Federal agency should consult with the State Historic Preservation Officer respecting a method for involving the public. This method should demonstrate a good faith attempt to take the public’s views on preservation issues into account.

In arriving at this method, the Federal agency should consider: · The nature and complexity of the undertaking · The nature and complexity of its potential effects upon Historic Properties · The amount and nature of likely public interest · Concerns relative to the confidentiality of information produced because of the consultation, identification, evaluation, and protection process.

The Regulation expects the Federal agency to offer basic information to the public throughout the process relative to: · The existence of Historic Properties within the undertaking’s Area of Potential Effects (but not necessarily their exact location) · The general nature of the potential for project effect upon these Historic Properties

Certainly and within reason, the Federal agency may use its existing procedures for informing the public based upon Federal law, regulation, policy document, or the particular agency’s unique corporate culture. Such procedures should be consistent with proper identification of Historic Properties within the project’s Area of Potential Effects and evaluation of project effect. Remember, consultation with the public runs through the entire Section 106 process. The Regulation allows the public on its own to offer its views on the boundary of an Area of Potential Effects, the National Register eligibility of properties within it and the effect of the undertaking upon them (800.2(d)(2) and 800.2(d)(3)) to the State Historic Preservation Office, other Consulting Parties, and the Council, even without a Federal agency invitation to do so.

You are nearing completion of Step One.

PRACTICE SCENARIO

1. Read the Scenario 2. Answer the Questions 3. Check Your Answers

The Huey County Highway Department plans to use funds from the Federal Emergency Management Agency to repair the 1945 concrete, wood, and steel bridge over the Frog Suck River. The bridge was severely damaged by the “Sho’nuff Flood” (Flood# 714) that crested the river last May. The County plans to replace broken, bent, or washed away decking, rails, and I- beam underpinnings and do extensive re-grading and re- paving of the approaches on both sides of the river. The County has hired the engineering firm of Dewey, Swim ‘n’ Lake (DS&W) to facilitate completion of environmental review, including Section 106 review. DS&W has contacted the Grace State Historic Preservation Office to begin Section 106 consultation, and has submitted preliminary documentation to the Mudpuppy Tribe of Indians as well.

Please take pen and paper and answer the following questions based upon the information you have and your understanding of Step One. Please take pen and paper and answer the following questions based upon the information you have and your understanding of Step One. Is the project under review an "Undertaking" as defined in the Act and in the Regulation? What is the Federal agency's mission as demonstrated in the project under review? What is the project’s possible Area of Potential Effects as defined in the Act and in the Regulation? What is the size and nature of the undertaking as defined in the 36 CFR Part 800 Regulation? What is the appropriate degree of Federal involvement as defined in the Regulation? What is the appropriate degree of Federal involvement as defined in the Regulation?

What is the likelihood of finding Historic Properties within the Area of Potential Effects? What is the nature and extent of potential effects to Historic Properties as defined in the Criteria of Adverse Effect? Who is the appropriate State Historic Preservation Officer/Tribal Historic Preservation Officer? How do you plan to involve the public? Who are the other likely Consulting Parties?

ANSWERS

Is the project under review an "Undertaking" as defined in the Act and in the Regulation? YES! FEDERALLY FUNDED IN WHOLE OR PARTFEDERALLY FUNDED IN WHOLE OR PART POSSIBLE NEED FOR FEDERAL PERMITSPOSSIBLE NEED FOR FEDERAL PERMITS MIGHT AFFECT HISTORIC PROPERTIES – BRIDGE - APPROACHESMIGHT AFFECT HISTORIC PROPERTIES – BRIDGE - APPROACHES

What is the Federal agency's mission as demonstrated in the project under review? REPAIR OR REPLACE PUBLIC INFRASTRUCTURE DAMAGED OR DESTROYED BY NATURAL DISASTERS.

What is the project’s possible Area of Potential Effects as defined in the Act and in the Regulation? THE BRIDGE STRUCTURE AND APPROACHES

What is the size and nature of the undertaking as defined in the 36 CFR Part 800 Regulation? BRIDGE RECONSTRUCTION AND REPAIRBRIDGE RECONSTRUCTION AND REPAIR GROUND DISTURBENCE ASSOCIATED WITH APPROPAH WORKGROUND DISTURBENCE ASSOCIATED WITH APPROPAH WORK RE-PAVING APPROACHESRE-PAVING APPROACHES

What is the appropriate degree of Federal involvement as defined in the Regulation? What is the appropriate degree of Federal involvement as defined in the Regulation? MODERATE - FEDERAL FUNDING PASS THROUGH TO COUNTY APPLICANT, WHO, THROUGH DS&l, IS MOVING THROUGH SECTION 106 REVIEW

What is the likelihood of finding Historic Properties within the Area of Potential Effects? MODERATE THE BRIDGE MAY BE NATIONAL REGISTER ELIGIBLETHE BRIDGE MAY BE NATIONAL REGISTER ELIGIBLE THERE MAY BE ARCHAEOLOGICAL RESOURCES WITHIN THE APPROACHESTHERE MAY BE ARCHAEOLOGICAL RESOURCES WITHIN THE APPROACHES

What is the nature and extent of potential effects to Historic Properties as defined in the Criteria of Adverse Effect? HIGH – REPAIRING THE BRIDGE MAY CAUSE OUT OF CHARACTER CONSTRUCTION ELEMENTS TO BE PLACED UPON ITHIGH – REPAIRING THE BRIDGE MAY CAUSE OUT OF CHARACTER CONSTRUCTION ELEMENTS TO BE PLACED UPON IT APPROACH WORK MAY DISTURB ARCHAEOLOGICAL RESOURCESAPPROACH WORK MAY DISTURB ARCHAEOLOGICAL RESOURCES

Who is the appropriate State Historic Preservation Officer/Tribal Historic Preservation Officer? THE STATE OF GRACE SHPOTHE STATE OF GRACE SHPO AUTHORIZED REPRESENTATIVE OF THE MUDPUPPY TRIBEAUTHORIZED REPRESENTATIVE OF THE MUDPUPPY TRIBE

How do you plan to involve the public? PUBLIC NOTICE IN LOCAL NEWSPAPERPUBLIC NOTICE IN LOCAL NEWSPAPER POSSIBLE PUBLIC MEETING IF NECESSARYPOSSIBLE PUBLIC MEETING IF NECESSARY

Who are the other likely Consulting Parties? HUEY COUNTY EXECUTIVEHUEY COUNTY EXECUTIVE U. S. ARMY CORPS OF ENGINEERSU. S. ARMY CORPS OF ENGINEERS HUEY COUNTY HISTORIANHUEY COUNTY HISTORIAN

EVERY FEDERAL AGENCY AND APPLICANT FOR FEDERAL ASSISTANCE MUST COMPLETE STEP ONE. Full Stop:

Everyone goes on to the next step.* *UNLESS YOU HAVE NO UNDERTAKING

END OF STEP ONE

THE FOUR STEP SECTION 106 PROCESS: STEP ONE TENNESSEE STATE HISTORIC PRESERVATION OFFICE REVIEW AND COMPLIANCE SECTION All reproduction rights reserved.

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THE FOUR STEP SECTION 106 PROCESS: STEP ONE TENNESSEE STATE HISTORIC PRESERVATION OFFICE REVIEW AND COMPLIANCE SECTION All reproduction rights reserved.

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