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America’s 11 Most Endangered Historic Places and Section 106

Annually, the National Trust for Historic Preservation publishes America’s 11 Most Endangered Historic Places List which highlights places across America that are “threatened by neglect, insufficient funds, inappropriate development, or insensitive public policy.” Visit the list here.

The America’s 11 Most Endangered Historic Places List often includes properties that may be impacted by federal actions that are subject to review under Section 106 of the National Historic Preservation Act. Read about Section 106.  Section 106 requires federal agencies to consider the effects on historic properties of any project carried out by them or that receives federal financial assistance, permits, or approvals, and provide the ACHP an opportunity to comment on these projects prior to making a final decision.

These projects highlight the challenges two federal agencies face as they work to accomplish their missions and also consider the effects their actions may have on historic properties through the Section 106 process.

Department of Veterans Affairs: Northwestern Branch of the National Home for Disabled Volunteer Soldiers Historic District (NHDVS) – Clement J. Zablocki VA Medical Center
 Milwaukee, Wisconsin

The Department of Veterans Affairs (VA) is required to consider how its projects might impact historically significant properties. These projects might include new construction, rehabilitation of existing buildings, and implementing master plans that address a medical facility’s long term development. Currently the ACHP is working with the VA, Wisconsin State Historic Preservation Office, National Trust for Historic Preservation, and other consulting parties to determine ways in which the VA can address the immediate stabilization of Old Main (Building 2) and Ward Memorial Hall (Building 41) and the long term consideration of all the historic properties located in the National Home for Disabled Volunteer Soldiers historic district. While consulting parties have expressed concern over the pace of repairs, the VA recently indicated in a Section 106 consultation meeting that it has allocated funds to make these repairs and plans to initiate Section 106 consultation in order to address them in the near future.  

The VA has also initiated Section 106 consultation to address the proposed construction of Community Living Centers (CLC) within Milwaukee’s Clement J. Zablocki VA Medical Center and is considering ways to avoid, minimize, and mitigate the effects that undertaking may have on the historically significant landscape and buildings located within the Northwestern Branch of the National Home for Disabled Volunteer Soldiers. The ACHP has encouraged the VA to develop a comprehensive plan that will balance future construction projects with the need to consider preserving this historic district. Additionally, the historic district has now been designated as a National Historic Landmark (NHL).

National Park Service: Chaco Culture National Historical Park
New Mexico

As with other parts of the country, the Greater Chaco Landscape in the Four Corners area of the Southwest is facing strong pressure for energy development. The Bureau of Land Management (BLM), a government agency mandated to allow multiple uses of the lands it manages, often receives proposals for energy development and regularly puts oil and gas leases up for sale within this area.

In October 2009, the BLM withdrew eight parcels of land covering over 10,000 acres from an oil and gas lease sale based on a formal protest letter from the Hopi Tribe. The tribe’s concern was that with some parcels less than three miles from the northern boundary of Chaco Culture National Historical Park, there may have been adverse effects to the views from the mesas of Chaco Canyon. Through the Section 106 process, which takes place to address adverse effects that may occur when energy developers propose a plan of development based on purchased leases, individuals and organizations with a demonstrated interest in the undertaking can express their views. The BLM also consults with local tribes to protect their heritage through government-to-government consultation and the Section 106 process, while still making lands available for activities such as mineral extraction, energy development, and recreation.

Given the unique interests in this area, the BLM is working on developing a comprehensive long-term policy to balance energy extraction with the need to manage for the future this important archaeological and cultural landscape, which includes UNESCO World Heritage Sites, so that it does not need to respond to leasing on a parcel-by-parcel approach.

The ACHP encourages anyone who is interested in being involved in these Section 106 reviews to contact the federal agency responsible for conducting them to determine how they may participate.

Updated July 8, 2011

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