1. Department of Natural Resources Historic Preservation Division Working Through The S106 Process FY 2015 CDBG Applicant Workshop December 4 th, 2014Meg Richardson

2. Department of Natural Resources Historic Preservation Division To promote the preservation and use of historic places for a better Georgia Our Mission Statement 2

3. Department of Natural Resources Historic Preservation Division National Historic Preservation Act Passed by Congress in 1966 Established a comprehensive program to preserve the historical and cultural foundations of the nation as a living part of community life Created the Advisory Council on Historic Preservation and SHPOs

4. Department of Natural Resources Historic Preservation Division Section 106 of the NHPA Requires federal agencies (or their designated applicants) to consider the effects of their actions on historic properties Triggered by the use of federal funds or requirement of a federal permit or license 36 CFR 800, “Protecting Historic Properties” Must be completed before agency can release funds or issue license or permit Encourages but does not mandate preservation

5. Department of Natural Resources Historic Preservation Division Our Role Advise and assist federal agencies in carrying out S106 responsibilities Provide comments on eligibility and potential effects to historic structures and/or archaeological sites Environmental Review program staff review over 2500 project submittals a year

6. Department of Natural Resources Historic Preservation Division Section 106 Project Types Cell towers Highway/road projects Bank branches Docks Irrigation Lines, Firebreaks Transmission lines Military installations Public housing Pipelines

7. Department of Natural Resources Historic Preservation Division The Process for Completing Section 106 Initiate the process Identify historic properties Assess adverse effects Resolve adverse effects

8. Department of Natural Resources Historic Preservation Division

9. Environmental Review (ER) Form Remember the cold reader I. General Information Clear, detailed information

10. Department of Natural Resources Historic Preservation Division Environmental Review (ER) Form I.G: Contact Information I.H: Map I.I: Previous Reviews II. Area of Potential Effect (APE)

11. Department of Natural Resources Historic Preservation Division ER Form

12. Department of Natural Resources Historic Preservation Division Environmental Review (ER) Form II.C: Photos!!!!!!!! Remember the Cold Reader/Reviewer Only 2 photos per page III. Site Info IV. Building and Structure Information

13. Department of Natural Resources Historic Preservation Division Environmental Review (ER) Form V. Additional Information for Effects Determination Assess Effects

14. Department of Natural Resources Historic Preservation Division Tips for the ER Form Clear, detailed information Color Photos keyed to a map Map of project location and APE Include all of the information you have for the project Historic Structures in the APE does not automatically mean the project cannot be funded

15. Department of Natural Resources Historic Preservation Division Submitted the ER Form, What’s Next? 30 days from receipt of the submittal in our office to review Responses are emailed from hpd-106reply@dnr.state.ga.us Responses: NHPA, NAE, CNAE, and….

16. Department of Natural Resources Historic Preservation Division Adverse Effects (AE) Adverse Effect: found when an undertaking may alter, directly or indirectly, any characteristics of an eligible or listed property that qualify it for inclusion in the NRHP in a manner that would diminish the integrity (location, design, materials, workmanship, feeling, and association)

17. Department of Natural Resources Historic Preservation Division Adverse Effects Physical Destruction or Damage Alteration Inconsistent with SOI Standards Relocation Change in character of the property’s use or setting Introduction of incompatible visual, atmospheric, or audible elements Neglect and Deterioration Transfer, sale, or lease out of federal control without adequate preservation restrictions

18. Department of Natural Resources Historic Preservation Division Adverse Effects Does NOT cancel or stop a project “not the end of the process” Just another step in the S106 process Avoid, Minimize, or Mitigate

19. Department of Natural Resources Historic Preservation Division The Next Steps Can the adverse effect be avoided or minimized? Decide on mitigation measures Notify the ACHP Write the MOA Complete the Stipulations

20. Department of Natural Resources Historic Preservation Division Avoid or Minimize Avoid Adverse Effect –Move undertaking to alternate site –Use alternative, compatible design –Repair instead of replace Minimize Adverse Effect –Alter plans to minimize plans –Utilize Landscaping to reduce visual impacts

21. Department of Natural Resources Historic Preservation Division Mitigate Adverse Effects If avoidance is not possible, the agency consults with HPD, the public and interested parties to identify measures to mitigate the adverse effect Balances loss of historic properties with the public good Creative approaches are encouraged

22. Department of Natural Resources Historic Preservation Division Mitigation Measures Popular Report Exhibit NRHP Nomination Photographic Documentation Archaeological Excavation Historic Resources Survey

23. Department of Natural Resources Historic Preservation Division Notify ACHP Notification of Adverse Effect Letter Provides details of project and asks if they want to participate in resolution of adverse effects HUD contact at ACHP, Jaime Loichinger To Include: Description of the undertaking, specifying fed involvement APE to include photos, maps, and drawings as needed Description of steps taken to ID historic properties Explanation of why the criteria of AE were found applicable, including any conditions or future actions to avoid, minimize or mitigate (i.e.. MOA stips) Copies or summaries of any views from consulting parties (HPD) and public Note working with HPD to develop MOA

24. Department of Natural Resources Historic Preservation Division MOA Memorandum of Agreement Formalizes mitigation measures Assigns duties and responsibilities to the signatories Legally binding Includes: Whereas Clauses- Who? What? Where? Why? Stipulations – Action: what will be done, who is doing it, and when it will be done – Administrative: Dispute Resolution, Performance Monitoring, Sunset, Amendment, Termination Conclusion Signature Blocks

25. Department of Natural Resources Historic Preservation Division Final Points Cold Reader Clear, Color Photos Site Plans and Elevations Adverse Effect is NOT the end, does NOT stop a project Applicant’s Priority vs. HPD’s Priority I’m always around and happy to answer questions.

26. Department of Natural Resources Historic Preservation Division Contact Information Meg Richardson Environmental Review Historian meg.richardson@dnr.state.ga.us (404) 651-6624 254 Washington Street, SW Ground Level Atlanta, GA 30334

27. Department of Natural Resources Historic Preservation Division www.gashpo.org