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b. Inventory Format

Every property in the corridor study area should be assigned a specific level of historic significance, based on an analysis of the following criteria, as well as other criteria considered appropriate by the State Historic Preservation Agency with regard to the local situation:

As part of this section, the SHPA should attempt to identify areas or neighborhoods within the study area that have a significant number of long-term residents and an established pattern of neighborhood stability. At the same time, areas traditionally populated by transient or short-term residents should also be recorded. Preference in highway location should be given to protecting neighborhoods or areas with established ties and social linkages. Such areas may or may not be delineated by ethnic or other characteristics and should be determined as far as possible by local citizen group participation.

(i) Broad historic values;

(ii) Degree of identification with his

toric personages or historic events;

(iii) Extent of surviving remains;

(iv) Accessiblity and capacity for public

use, enjoyment and education;

The map identifying cultural and associative sites and areas should be approved by the SHPA, certified by the SHPO and forwarded to the state highway department to be included in the public hearing data package.

(v) The role of the historic site in

ongoing or contemplated historic preservation programs.


Existing Patterns, Vistas and Natural Features-The Possible Effect of the Proposed Highway Construction on the Existing Street Layout, Development Patterns, Vistas and Viewpoints or Natural Features Significant to the Community

Lists, with proper documentation, should be prepared with field maps, identify: ing all sites of major historic significance, Priority One, and sites of lesser historic significance, Priority Two. After approval by the SHPA and certification by the SHPO, the lists, documentation and maps should be forwarded to the state highway department for review and inclusion in the data for the highway design public hearing, required under PPM 20-8, 1.14.59.

4. Cultural and Associative Sites - The Cultural

and Associative Importance of All Buildings, Structures and Sites in or Contiguous to the Corridor Area

A map locating and identifying by name all cultural attractions and sites of associative significance should be prepared by the SHPA. This category should include all libraries, schools, museums, art galleries, theaters, hospitals, health clinics, welfare offices, transportation terminals, fraternal organization meeting places and churches or other places of Worship. It is the intent of this section of the Historic and Cultural Sites Inventory to identify all sites concerned with social activity within a study area and to estimate the effect of any highway construction proposal on the existing associative linkages. The activity may be identified with a recurring event or with a major group.

This part of the inventory should begin with a series of comparative studies based on early and present-day street maps, insurance atlases, prints and other visual documents of the corridor and surrounding area. This review will quickly point out the earlier or in some cases the original portions of the community, their patterns of development, including street layout and location of community facilities of the past and today, neighborhood boundaries and general land use patterns. All alternative highway routes within the corridor should be analyzed by the state highway department and the SHPA as to potential effect on these physical patterns of development. Special emphasis should be placed on the visual effect of placing a highway facility in an already established area with important aesthetic and physical characteristics. This section should identify dominant street patterns in a given area, such as the rapid grid of the Vieux Carré, geometric patterns such as Washington, D.C., and curvilinear patterns such as Greenbelt, MD. or Reston, VA. The three dimensional scale of the subareas within the corridor should also be noted, especially if the proposed highway facility may be elevated in some sections. This can be shown on maps by noting the predominant building height, texture (fine, medium or coarse), building coverage, amount of open space around each structure, and height within each area.

wildlife and waterfowl refuge areas should be recorded at this time.

All of the above material-dominant street patterns, development patterns, vistas, viewpoints and entry points, and natural featuresshould be listed, photographed or sketched and mapped by feature, reviewed by the SHPA, certified by the SHPO and forwarded to the state highway department.

Any building, site or group of structures which might become physically or visually isolated because of any proposed highway facility should also be recorded during this part of the Historic and Cultural Sites Inventory. This would include areas which might become "historic islands" (Mobile, Fort Conde) in a sea of 20th-century construction due to the highway proposal, and areas where the potential for rehabilitation and improvement might be af. fected (Bowen's Wharf, Newport). Termed "opportunity areas," such areas might include riverfronts, lakefronts, scenic areas, park lands and potential historic or design districts, especially areas of significance contiguous to existing historic districts (Fox Point/College Hill, Providence and Elysian Fields/Vieux Carré, New Orleans).

6. Preservation Climate-An Analysis of the

Potential Effect of a Proposed Highway
Facility on Preservation or Rehabilitation
Activity and Public Acceptance in the

Existing and potential vistas and viewpoints are important to the identity of a community and should be inventoried as part of this survey. Vista may be defined as a confined, directed view terminating at an important building or scene, while the term viewpoint refers to a broad, overall view of a given area. Vistas and viewpoints of and from significant buildings and areas within and contiguous to the corridor study area should be mapped as part of this phase of the inventory. Whenever possible, the actual view should be photographed and keyed by number and directional arrow on the map. Entry points to the community and its subareas should also be mapped and photographed. Visually important vistas, viewpoints and entry points should be recognized in the highway decision making process, while negative visual elements might be corrected or eliminated by such construction activity.

Areas in the community where significant preservation or rehabilitation activities have occurred in the recent past should be identified during this part of the Historic and Cultural Sites Inventory. Real estate associations, local preservation groups and building inspection departments should be consulted. Real estate agents can provide data regarding real estate value trends for areas that might be influenced by any highway proposal, especially if it affects local initiative for preservation. Interviews with local preservation groups and an analysis of construction and repair permits will identify individual properties and clusters of preservation or rehabilitation projects indicating a concerted effort on the part of individual owners or some organization to reclaim an area. By reviewing building permits for the past five to seven years, any pattern of rehabilitation activity that exists in the community can be mapped. Such areas should be checked in the field to identify additional properties that may have undergone minor rehabilitation that does not require a permit, such as painting and general maintenance. This data should be mapped, reviewed by the SHPA, certified by the SHPO and forwarded to the state highway department.

D. Provisions for Amending The Historic and Cul

tural Sites Inventory

Natural and landscape features that should be recorded include the three dimensional form of the community-flat, bowl-shaped, on a hill, fan-shaped, or linear-especially if this form is susceptible to irreparable change. Of critical importance are ridge lines, which should be protected from overdevelopment of any kind. To protect the natural contour lines and landscape quality of the area, it should be possible to terrace a proposed highway facility below rather than along the ridge. It is important to recognize that "ridge lines," in the form of man-made features, may exist in urban areas. Parks and

The state highway department shall instruct all highway location engineers and other employees, consultants and contractors to record all important buildings, sites or objects discovered during surveying and construction of the proposed highway facility not included in the Historic and Cultural Sites the survey. All sites and objects discovered in the field should be added to the appropriate report and map of the HCSI, and should be clearly identified as being inventoried after all public hearings at the instigation of the state highway department.

E. Final Review of the Historic and Cultural Sites


Inventory. (The state highway department should bear in mind that all properties eligible for listing on the National Register may not yet have been nominated for such listing in spite of the best efforts of those involved in the Register program and those involved in the Historic and Cultural Sites Inventory). The existence of such sites should be noted and descriptions entered in daily field reports, and their location plotted on highway construction maps of the area. Sites beyond the actual right-of-way not listed in the HCSI should also be recorded if they are subject to visual or physical damage due to highway construction activities. The state highway department shall notify the SHPA immediately upon discovering such sites and stop all construction activity. Such a stop work order shall be in effect for a period not to exceed two working days, during which time representatives of the SHPA or their consultants shall be afforded the opportunity to survey the new site. If the site is of significance, the SHPA may request a further delay in construction for up to sixty days to permit recording, photographing, drawing, salvage operations or, in the case of buildings or structures of major significance, moving of the object.

Upon receipt of the reports and maps outlined above, the state highway department should review all the data with representatives of the State Historic Preservation Agency in order to gain complete understanding and familiarity with the contents of each study. All mapped material should be transferred to plastic overlay sheets at a constant scale, with the base map showing the proposed corridor limits. The plastic overlays should be prepared so that any single study or combination of studies can be reviewed at any time. The scale of the maps will be determined by the size of the highway proposal, but in no case should it be less than the seven and one-half minute series of the USGS maps. The map and overlays should be prepared before the design stage public hearing and be made available for review by the interested public.

If the survey team determines that the site is of only minor importance and does not warrant further action, the SHPA may authorize a brief report to the state highway department detailing the findings of


Adams National Historic Site-The Old House of John Adams at Quincy, Massachusetts, commemorates four generations of the distinguished Adams family. The house is not a period piece but one which, from 1788 to 1927, clearly shows the everchanging style and taste of its occupants.


The primary uses of the Historic and Cultural Sites Inventory described in the preceding chapter are two. First, the material gathered as part of the inventory process can serve as an historic preservation input for discussion at the two public hearings required of state highway departments under provisions of the U.S. Department of Transportation Policy and Procedure Memorandum 20-8 (January 14,

1969). An equally important use of the HCSI will be in assisting in the preparation of various statements and reports required under existing Federal legislation, including Section 102(2)(c) of the National Environmental Policy Act of 1969, Section 106 of the National Historic Preservation Act of 1966, Section 4(f) of the DOT Act, Executive Order 11593 and others.


they must be made a part of the process as early in the planning stage as possible.

A. Recommended Improvements to the Public Hear

ing Process

Executive Order 11514 (Nixon, 3-5-70) "places responsibility on all Federal agencies to develop procedures to insure the fullest practicable provision of timely public information and understanding of Federal plans and programs with environmental impact in order to obtain the views of interested parties," and "insures that information regarding existing or potential environmental problems and control methods developed as part of research, development, demonstration, test or evaluation activities is made available to Federal agencies, states, counties, municipalities, institutions and other entities, as applicable."

The most effect device developed to date to meet the requirements of Executive Order 11514 is the public hearing. This formal mechanism affords local officials and interested citizens the opportunity to view and study all available data regarding highway planning, including all alternative proposals to a given project location, and offers a forum for open discussion of the proposed activity.

Existing Federal laws and regulations insist highway department construction activities meet certain requirements, including two open public hearings, one at the "location or corridor state," the second at the "design stage." One purpose of these meetings is to explore ways to avoid or mitigate damage to parks or historic sites or buildings that might be caused by highway department activities. While the letter of the law has been met in most cases, problems and questions regarding the current public hearing process have arisen. Many of the problems can be traced to incomplete presentations on the part of the state highway department officials, especially with regard to alternative proposals. In some instances, this can be traced to the highway department's being supplied with inaccurate or outdated data by local officials and the private citizenry on the highway proposal, or to the fact that preliminary planning has been based on unreliable secondary source materials. In some cases, highway departments have been accused of feeling, out a community's reaction to a specific proposal and by characterizing that proposal as "the preferred route or design" even though the proposal has not been studied for economic and engineering feasibility; this practice has caused criticism that the highway department is "fishing for approval." And, in at least one instance, a state highway department

As in all types of planning activity, it is imperative that highway route selection and design decisions be consistent with local plans, goals and objectives. Since the final responsibility for good highway planning and construction in any given area rests with local officials and the private citizenry, individually or collectively, of that area, they must be given an active role in the decision making process. And, if such groups and officials are to effectively mediate and resolve real potential conflicts at the local level,

has presented completely new alternative on the day of the scheduled public hearing, without affording local officials or citizens the opportunity for review or preparation of rebuttal. In the past, highway department public hearings in some communities have suffered from a lack of candor which must be corrected if effective and responsive highway planning is to take place.

and time, and to the role of the private citizen or local official in the public hearing process. Other problems encountered include the selection of the moderator for the hearing. A third problem grows out of the use of graphics in such presentations.

1. Poor Timing and the Lack of Publicity

Regarding Public Hearings

PPM 20-8 (see Appendix B) states that "both a corridor public hearing and a design public hearing must be held, or an opportunity afforded for those hearings, with respect to each Federal-aid highway project that

In other instances, public hearings have elicited organized group opposition. The state highway departments should involve citizen groups early in the planning process and keep them aware of the progress of planning by informal meetings. Experience has demonstrated that the use of these meetings and similar informal approaches to public involvement provides a better solution to the problem of achieving effective two-way communication. State Action Plans should include procedures sufficient to inform the public and to derive information from the public relevent to the project at a sufficiently early stage to permit maximum consideration and responsiveness.

(1) is on a new location; or

(2) would have a substantially different social,

economic or environmental effect; or

(3) would essentially change the layout or func

tion of connecting roads or streets"

[blocks in formation]

7.a. A State may satisfy the requirements for a public hearing by (1) holding a public hearing, or (2) publishing two notices of opportunity for public hearing and holding a public hearing if any written requests for such a hearing are received.

The State Action Plans required by FHWA PPM 90-4, which is based on the provisions of Section 136(b) of the 1970 Federal-Aid Highway Act, describe the States' approaches to the incorporation of social, economic and environmental considerations in highway planning and development. These Action Plans, prepared by the States for the approval of FHWA, identify the assignments of responsibility for providing information on environmental effects, including historical, to those engaged in highway planning, location and design efforts. The Action Plans identify the method by which such information is taken into account in the decision-making process.

In summary, PPM 20-8 requires the state highway department to advertise the potential for scheduling public hearings at the two public stages in the highway planning process, the location or corridor selection phase, and the final design stage. The corridor hearing will be scheduled to take place before the route of any highway is determined, and the design phase hearing after the route location is approved by the state highway department and the U.S. Department of Transportation.

The Action Plan does not describe the precise procedures for dealing with individual environmental considerations, such as historic preservation, but it does call attention to the applicability of the appropriate legislation and other directives. The Action Plan describes the highway department's in-house interdisciplinary capability of assessing the several environmental factors at each key stage of project development and it identifies the procedures for coordinating with other agencies and interest groups.

The wording of paragraph 7.a. of PPM 20-8 requires the convening of either hearing if any request is made in writing. This means that as few as one such request is sufficient to require a public hearing taking place, and this carefully worded section should be an adequate safeguard to insure such a hearing whenever

potential conflict between highway planning and historic preservation objectives occurs. Both the State

A lack of communication between the highway planner and local officials and citizens is most apparent in three areas. The first problem area is concerned with poor timing of the public hearings and a lack of publicity with regard to the hearing site

*PPM 208 also states that "a single combined corridor and highway design public hearing must be held, or the oppor. tunity for such a hearing afforded, on all other projects before route location approval, except ... resurfacing." widening existing lanes or similar work.

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