Historic preservation fact sheet

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Vermont Community Development Program

Grant Application Section 106 Review

Section 106 Review

Condensed From:

Section 106 Review and You


TOPIC: Community Development Block Grants and Historic Preservation

Vermont State Historic Preservation Office - April 1996

The Agency of Commerce and Community Development has executed a Programmatic Agreement effective as of May 2, 2001 with the State Historic Preservation Officer and the National Advisory Council for the administration of the Vermont Community Development Program to ensure compliance with the Section 106 requirements of the National Historic Preservation Act of 1966.
For assistance in meeting the Section 106 requirements the VCDP has developed a list of pre-qualified professionals and ONLY those individuals may conduct the Section 106 review. (See attached)
1) What is Section 106 Review?

Section 106 of the National Historic Preservation Act is the cornerstone of this country's historic preservation policy. The Section 106 review refers to the federal review process designed to ensure that historic and archeological resources are considered during federal project planning and implementation. The review process is administered by the Advisory Council on Historic Preservation, an independent federal agency. Section 106 requires that every federal agency, or their legal designee such as the Vermont Agency of Commerce and Community Development (ACCD), "take into account" how each of its undertakings may affect an "historic property."

Section 106 review is fully detailed in federal regulation 36 CFR Part 800, the Advisory Council's "Protection of Historic and Cultural Properties."

2) What is an "historic property"?

An historic property is any historic or archeological resource that is listed in or is eligible for listing on the National Register of Historic Places. Generally, buildings must be 50 years old and must retain their important historic features to be eligible for the National Register.

About 9000 buildings in Vermont are currently listed in the National Register, most as part of historic districts. Thousands more are eligible. Identification and evaluation of archeological resources that are eligible for the National Register require several phases of field study since archeological sites are generally not visible on the ground surface.

3) What kind of projects require106 review?

A broad range of federally funded, permitted or licensed activities require review under this law: new construction, rehabilitation and repair projects, demolition, loans, loan guarantees, grants, federal property transfers, permits, and many other types of federal involvement.

Vermont Community Development Program (VCDP) projects, require this review. Whenever a VCDP project affects or may affect an historic property, ACCD, as the federal agency's legal designee, is obligated to seek State Historic Preservation Officer (SHPO) comments.

4) If my VCDP project requires a permit from the Army Corps of Engineers or has other federal funds, is a second, independent Section 106 review required?

No, review only occurs once, but all involved federal agencies consult together; one is designated the lead agency for 106 review. Typically, ACCD is considered the lead federal agency for the VCDP and it coordinates the Section 106 consultation with the Corps of Engineers and other sources of federal monies.

5) If I already have an Act 250 permit and then apply for VCDP funds, is Section 106 review still necessary?

Yes. Section 106 review and Act 250 review are separate and different processes. Satisfying the Act 250 review does not necessarily satisfy the federally mandated Section 106 review, although this is a goal as much as possible. For example, there are cases in which an Act 250 permit is issued without any consideration of historic preservation/archeology concerns. The Section 106 review requires affirmative consideration of project effects on historic properties by ACCD; legally binding documentation of that effect; consultation with the State Historic Preservation Office (SHPO); and, when necessary, consultation with the federal Advisory Council.

6) What kinds of historic preservation issues should I consider when developing or designing my project?

Does the project involve a building that is 50 years old or older? Do you plan to demolish, alter, or rehabilitate this building? If you plan to rehabilitate it, do you plan to hire an architect experienced in historic preservation projects? If your project involves new construction, does the project area have the potential for containing archeological sites or is the project area within an historic district? Are there historic cellar holes or other historic ruins in the project area that may be archeologically significant?

7) How will I know if the building involved in my project is listed on or eligible for inclusion in the National Register of Historic Places?

The SHPO maintains a statewide inventory of historic buildings and structures (currently about 20,000), including a town-by-town record of properties that are listed in the National Register. The inventory files for buildings and structures are open to the public and you are encouraged to use them. Remember, not all buildings have been surveyed.

If your project is located in Rutland or Addison County, the SHPO has published comprehensive listings of these counties' historic buildings and structures: "The Historic Architecture of Rutland County" (1988) and "The Historic Architecture of Addison County" (1992). These publications are available in many town clerk offices, libraries, and bookstores.

  1. If I am rehabilitating a building or structure that is 50 years or older, do I have to meet any particular standards?

Yes, the rehabilitation project must meet the Secretary of the Interior's Standards for Rehabilitation. Copies of the Standards, and related Preservation Briefs on specific topics, are available from the SHPO or your CD Specialist.

9) Are there particular steps I should take to ensure that my rehabilitation project meets preservation standards?

If you plan to rehabilitate a building that is 50 years old or older and listed in or potentially eligible for listing in the National Register of Historic Places, it is recommended that you hire an architect with experience in meeting the Secretary of the Interior's Standards. The architect’s plans will need to reviewed and approved by one of the VCDP Authorized Historic Consultants. (See entry 13, below.)

10) How do I know if the project area has the potential for containing archeological sites?

There are certain obvious environmental characteristics that help predict the likelihood that prehistoric Native American sites may lie within a project area: for example, located on a floodplain or along a major river, stream or lake; contains several small tributaries or ancient stream channels (that now are swales or ravines); situated on terraces above a floodplain or overlooking a valley. It is recommended that you hire a qualified archeological consultant (See attached list of pre-qualified professionals) early on in project planning to assist you in assessing the archeological potential of your project area. Unlike prehistoric Native American sites, historic archeological sites are often visible on the surface. Typical evidence includes cellar holes and foundations.

11) Are there particular steps I should take if my project area appears to be archeologically sensitive?

Early project planning should include consultation with a qualified professional archeologist. (See attached list) She/he can assist you in:

  • identifying the need for archeological studies;

  • preparing a budget estimate for archeological studies for inclusion in the grant application;

  • helping you design a project that avoids the most archeologically sensitive lands and eliminates or minimizes the need for an archeological study.

12) Are the costs of archeological studies eligible VCDP grant costs?

Yes, the costs of necessary archeological studies are eligible project planning costs. However, it is critical that estimated archeological costs be anticipated and included as a line item in your application. If the estimated costs for any necessary archeological assessment or study is not included in the grant agreement, VCDP cannot reimburse you for this project component.

13) How do I locate qualified archeological consultants and are there standards for conducting archeological studies?

The VCDP has developed a list of pre-qualified professionals. ONLY these individuals are authorized to conduct Section 106 reviews for the VCDP. (See attached list)

14) What role does the State Historic Preservation Office Play in Section 106 review?

Under state law, the Division for Historic Preservation, in the Department of Housing and Community Affairs, serves as the State Historic Preservation Office. The head of the Division serves as the State Historic Preservation Officer (SHPO). Under Section 106, federal agencies and their designees, are required to consult with the SHPO at various steps of review. The SHPO also maintains the statewide inventory of historic buildings, structures, and archeological sites and provides technical assistance to communities and others on issues relating to historic preservation. The SHPO also assists ACCD in Section 106 review by providing recommendations that professional archeological/architectural historians be added to the project budget. We strongly recommend:

  • you collect the information from the SHPO prior to submitting your application to adequately budget for any necessary Section 106 review;

  • use the sample memo to enlist input from the SHPO, Division for Historic Preservation, on your specific project. Be sure to include all the pertinent items listed to ensure the SHPO can make a preliminary review, please allow at least 45 days prior to the application deadline for SHPO to comment; or

  • directly contact one of the VCDP authorized professionals to conduct the Section 106 review.

15) What other resources/opportunities exist to improve my project?

If your project involves an historic, income-producing building or structure (see #2, above), it may be eligible for a 20% Rehabilitation Investment Tax Credit (RITC). Under this federal program, 20% of qualified rehabilitation expenditures may be allowed as a credit on investor's federal tax return. (Contact Chris Cochran, at the SHPO, at 802-828-3047). The Vermont Downtown Program also offers various opportunities that may enhance your project (Contact Joss Besse at DHCA 802-828-5212).

16) Do VCDP Planning projects also require Section 106 review?

Planning projects must also take into account the potential impact to historic resources, both architectural and archaeological. It is an excellent opportunity to develop a comprehensive plan that anticipates historic preservation and archeological issues and opportunities. For example, if planning new construction in an archeologically sensitive area, the planning grant should include provision to hire an archaeology consultant to identify the need and cost estimates for a study and help to adequately plan for such study during the project implementation phase. If you are planning to rehabilitate an historic building, including an experienced historic preservation architect in the planning aspect can ensure that potential issues are addressed and resolved early on and that the implementation grant budget is developed accordingly.

Any plans developed with VCDP funds must be reviewed and approved by one of the VCDP Authorized Historic Consultants.

17) Who do I contact for more information?

For copies of 36 CFR Part 800 or a 63 page booklet entitled "Section 106, Step-by-Step," contact the Advisory Council on Historic Preservation, 1100 Pennsylvania Avenue, NW, Suite 809, Washington, DC 20004 (202) 606-8505. (Web site http://www.ACHP.gov )

For specific questions relating to VCDP projects, contact your CD Specialist or Ray Marzbani at the Vermont Department of Housing and Community Affairs, Montpelier (802) 828-5226, or Judith Ehrlich at the SHPO, Montpelier (802) 828-3049.

Exhibit – This memo format must be used to obtain Division for Historic Preservation (DHP) input if the project involves a structure that is 50 years old or older and/or an activity that may cause any disturbance to the ground.

Please send the documentation to the following address:

Judith Ehrlich, Environmental Review Coordinator

Division for Historic Preservation

National Life Building, Drawer 20

Montpelier, VT 05620


TO: Judith Ehrlich, Environmental Review Coordinator

FROM: {Applicant Name}, XXXX Program Year



We, the Town, City, Village of XXX, are currently applying to the Department of Housing and Community Affairs (DHCA) for funding through the Vermont Community Development Program (VCDP) for the upcoming cycle of the XXXX Program Year.

Our project may impact historic/and or achaeological resoures.

In an effort to meet Section 106 requirements and plan for any additional professional review of our projects, we are requesting the Division for Historic Preservation to review specific information about our project prior to completing the application. The application deadline is . We wish to include a statement of this review with our application.

In order to obtain the preliminary comments of the State Historic Preservation Officer (SHPO), we are submitting the following information: Items (a)-(i) if project involves a building or items (a), (d), (e), (f), (j) if project involves ground disturbing activities.

  1. Detailed project description

  2. Photographs of structure(s), prints clearly labeled as to property name and indicating location of all shots.

  3. Interior photographs of all typical significant and non-significant spaces, labeled as to description of view and location.

  4. Photographs of the property’s surroundings and adjacent landscape

  5. Project location map (copy of USGS map preferred)

  6. Site Plans

  7. Building elevations

  8. Methods and materials proposed for repair or replacement

  9. Date of original construction; date(s) of subsequent alterations/additions – brief description of work and materials used

  10. Description of previous land use

Please send response to: Name, Address, Phone#, email.

Thank you for your assistance.
cc: Ray Marzbani, Environmental Officer
802) 828-3049

June 2006 Agency of Commerce and Community Development Page

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