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State Section 106 Programmatic Agreement

PROGRAMMATIC AGREEMENT
AMONG THE FEDERAL HIGHWAY ADMINISTRATION,
THE ADVISORY COUNCIL ON HISTORIC PRESERVATION,
THE STATE OF NEW HAMPSHIRE STATE HISTORIC PRESERVATION OFFICE,
AND THE STATE OF NEW HAMPSHIRE DEPARTMENT OF TRANSPORTATION
REGARDING IMPLEMENTATION OF
CERTAIN TRANSPORTATION UNDERTAKINGS IN NEW HAMPSHIRE

WHEREAS, the Federal Highway Administration (FHWA) proposes to administer its Federal-aid Highway Program (herein after referred to as, “Program”) in New Hampshire, authorized by 23 U.S.C. 101 et seq., through the New Hampshire Department of Transportation (NHDOT) (23 U.S.C. 315); and

WHEREAS, FHWA has determined that certain types of transportation projects (undertakings) may have an effect upon properties included in or eligible for inclusion in the National Register of Historic Places (herein after referred to as “the National Register”); and has consulted with the Advisory Council on Historic Preservation (ACHP) and the New Hampshire State Historic Preservation Officer (SHPO) pursuant to 36 CFR 800.14(b) implementing Section 106 of the National Historic Preservation Act (NHPA) (16 U.S.C. 470f) (hereinafter referred to as “Section 106”); and

WHEREAS, NHDOT participated in consultation and has been invited to be a signatory party to this Programmatic Agreement (hereinafter referred to as, “this Agreement”); and

WHEREAS, pursuant to 36 CFR 800.16(1)(l), historic properties are defined as prehistoric and historic archaeological sites, buildings, bridges, structures, districts, and objects, included in or eligible for listing in the National Register; and

WHEREAS, any undertaking involving tribal lands (as defined in 36 CFR 800.16(x)), or any undertaking that may affect a property identified by a federally recognized Indian Tribe with ancestral homelands in New Hampshire as possessing traditional religious and cultural significance, shall not be governed by this Agreement, but shall be reviewed by FHWA in consultation with appropriate Federally recognized Indian Tribes, in accordance with 36 CFR Part 800; and

WHEREAS, 36 CFR Part 800 encourages Federal Agencies to efficiently fulfill their obligations under Section 106 through the development and implementation of cooperative programmatic agreements; and

WHEREAS, the US Department of Transportation encourages streamlining the environmental review processes in the Moving Ahead for Progress in the 21st Century Act (hereinafter referred to as “MAP-21”) Section 1305; and

WHEREAS, FHWA and NHDOT are committed to the design of transportation systems that: (1) achieve a safe and efficient function in the State of New Hampshire; (2) avoid, minimize, and mitigate adverse effects on historic properties; and (3) respond to the needs of New Hampshire’s citizens and communities, including strategies that enhance the preservation of historic properties; and

WHEREAS, NHDOT Bureau of Environment (NHDOT-BOE) employs a staff of cultural resources specialists and consultants who meet the Secretary of Interior’s Professional Qualification Standards in 36 CFR Part 61 in the fields of archaeology, and architectural history to carry out its cultural resource programs and responsibilities; and

WHEREAS, this Agreement sets forth the process by which FHWA, with the assistance of NHDOT-BOE, will meet its responsibilities under Section 106 and the implementing regulations set forth in 36 CFR Part 800. For purposes of this Agreement, the definitions for terms appearing in 36 CFR 800.16(a) through (y) inclusive shall be employed whenever applicable.

NOW, THEREFORE, FHWA, ACHP, SHPO, and NHDOT hereby agree that the review of undertakings within the Program in New Hampshire shall be administered according to the following stipulations in order to satisfy FHWA’s Section 106 responsibilities as implemented by 36 CFR Part 800 and to integrate historic resource protection responsibilities with its other responsibilities under Federal and State statutes, regulations, and policies.

STIPULATIONS

FHWA, with the assistance of NHDOT-BOE, shall ensure that the following measures are carried out:

I. Purpose and Applicability

This Agreement sets forth the process by which FHWA will meet its responsibilities under Section 106 of the NHPA, with the assistance of NHDOT-BOE, for certain undertakings in the Program. This Agreement establishes the basis for NHDOT’s internal review of individual undertakings, the review of Local Public Agency (LPA) undertakings, and how NHDOT-BOE and LPA sponsors will notify and coordinate with the SHPO and FHWA.

This Agreement only applies to undertakings that have a demonstrated history of typically resulting in Section 106 findings of “No Potential to Cause Effects,” or “No Historic Properties Affected,” as outlined in Appendices A and B of this Agreement, and as defined in 36 CFR 800.3(a)(1), and 36 CFR 800.4(d)(1). Undertakings that do not conform to Appendices A and B shall follow the procedures in 36 CFR Part 800.

At any time, NHDOT-BOE can choose to process an undertaking by following the procedures in 36 CFR Part 800 rather than by following the procedures in this Agreement. For reasons such as known controversy, SHPO, ACHP, or FHWA may also request that NHDOT-BOE process an undertaking by following the procedures in 36 CFR Part 800.

II. Responsibilities of FHWA and NHDOT

For undertakings listed in Appendices A and B, FHWA authorizes NHDOT-BOE to conduct all consultation with the New Hampshire SHPO and other consulting parties on its behalf, including determining Area of Potential Effect (APE), determinations of No Potential to Cause Effects, and No Historic Properties Affected, and applicability to this Agreement. This is exclusive of FHWA’s consultation with federally recognized tribes. FHWA shall remain ultimately responsible for all findings and determinations and shall take the lead in any consultation with the ACHP for undertakings with active ACHP participation (36 CFR 800.6(b)(2)), and those involving the Secretary of the Interior.

Should the NHDOT-BOE, through its Cultural Resources Program, not be able to execute its internal review for an undertaking qualifying for use of this Agreement as outlined under Stipulation VI, that undertaking shall undergo the Section 106 review process outlined in 36 CFR 800.3-800.7.

III. Professional Qualifications, Staffing, and Resources

NHDOT-BOE shall continue to employ, at a minimum, an archaeologist and an architectural historian to direct consultants who conduct Section 106 work, and to provide review and quality control on all Section 106 work. NHDOT-BOE Cultural Resources Program staff and consultants who conduct Section 106 work shall meet the Secretary of the Interior’s Professional Qualifications Standards in 36 CFR Part 61. In the event of a temporary absence of the employed archaeologist or the architectural historian, NHDOTBOE, FHWA, and SHPO shall closely coordinate to determine requirements needed to continue to meet the stipulations of this Agreement. In the event of a prolonged absence of the employed archaeologist or the architectural historian, or should NHDOT no longer employ either the archaeologist or the architectural historian, all undertakings previously covered by this Agreement shall follow the Section 106 review process outlined in 36 CFR 800.3-800.7.

NHDOT-BOE shall have sufficient financial resources and administrative support to efficiently operate under this agreement, and maintain databases and other tools necessary to implement the stipulations of this Agreement.

IV. Monitoring

NHDOT-BOE, FHWA, and SHPO shall meet annually in each of the first three (3) years after the date this Agreement takes effect, and every five (5) years thereafter, to evaluate the agencies’ joint functioning under this Agreement. Prior to any such meetings, the ACHP shall be notified and may participate at its discretion. Prior to the annual evaluations, and in each and every year while operating under this Agreement, NHDOT-BOE shall submit a report of the current activities under this Agreement to FHWA, SHPO, and ACHP. This report shall include, but is not limited to:

  1. A table identifying all undertakings processed under this Agreement, specifying project names, state and federal numbers, towns, any other pertinent information, and all findings pursuant to 36 CFR Part 800 that were processed by NHDOT-BOE for the year under review, and
  2. A narrative description summarizing accomplishments, trends, concerns, resource needs, recommendations, etc., regarding any aspect of this Agreement.

V. Undertakings with No Potential to Cause Effects

  1. Undertaking Types

    The signatories to this Agreement agree that the types of undertakings listed in Appendix A, by their nature typically have “No Potential to Cause Effects” (36 CFR 800.3(a)(1)), and by definition, qualify for use of this Agreement. The NHDOT-BOE can add undertaking types to Appendix A upon written authorization by all parties to this Agreement.

  2. Notification and Coordination

    For undertakings that conform to the types listed in Appendix A, the Project Manager/Environmental Manager, or LPA sponsor shall submit a hard copy of a completed Appendix A Certification Form to the NHDOT-BOE Cultural Resources Program for review. The NHDOT-BOE Cultural Resources Program shall determine whether an undertaking conforms with the types of undertakings listed in Appendix A, and shall make a finding that an undertaking has either No Potential to Cause Effects, or does not conform to Appendix A. The NHDOT-BOE Cultural Resources Program shall maintain such documentation in its files. The NHDOT-BOE Cultural Resources Program shall notify the SHPO of its use of the documentation on specific undertakings in an annual report to the signatories of this Agreement, as specified in Stipulation IV.

    If the NHDOT-BOE Cultural Resources Program makes a finding, based on a review of an Appendix A Certification Form, that an undertaking does not conform to the types listed in Appendix A, the undertaking shall be reviewed for its applicability to the types of undertakings listed in Appendix B (undertakings with minimal potential to cause effects), pursuant to Stipulation VI of this Agreement, or through the Section 106 review process outlined in 36 CFR 800.3-800.7.

VI. Undertakings with Minimal Potential to Cause Effects

  1. NHDOT Internal Review

    For all undertaking types listed in Appendix B, the NHDOT-BOE Cultural Resources Program shall employ a multidisciplinary approach, involving the Project Manager, Environmental Manager, engineers, and other staff, as appropriate, to initiate consultation and identify historic properties that may be affected by an undertaking in accordance with the procedural requirements of 36 CFR 800.2, 36 CFR 800.3 and 36 CFR 800.4, following its internal review process as outlined below:

    1. Initiate the Section 106 process in accordance with the procedures in 36 CFR 800.3, including establishing whether there is an undertaking, coordinating with other reviews, planning to involve the public, and identifying and inviting other consulting parties, as appropriate;
    2. Coordinate with the public through any/all of the following methods. Appendix E provides a list of typical consulting parties to consider:
      1. Sending initial contact letters to local historic commissions, other governmental entities with jurisdiction, regional planning commissions, and other potential consulting parties in accordance with CFR 800.2(c), 800.3(f) and 800.4(d);
      2. Presenting findings and soliciting input at public officials meetings, public informational meetings, and/or public hearings, as appropriate;
      3. Coordinating directly with abutting property owners through meetings, electronic communication, and telephone communication; and/or
      4. On site meetings with concerned property owners.
    3. Assess potential impacts, including archaeological and aboveground sensitivity potential, to determine the applicability of an undertaking to the types listed in Appendix B. The Project Manager/Environmental Manager shall submit to the NHDOT-BOE Cultural Resources Program information required for the NHDOT-BOE Cultural Resources Program to complete its assessment, including an Appendix B Certification Form, topographical maps, photographs, design plans, and as-built plans (if available). In addition, if an undertaking’s applicability to Appendix B cannot be made without additional review and information, the NHDOT-BOE Cultural Resources Program may require a “Request for Project Review by the New Hampshire Division of Historical Resources for Transportation Projects” form (Transportation RPR) to be submitted.
    4. Determine whether archaeological or aboveground surveys are needed, utilizing rationale that include, but are not limited to, the following:
      1. The potential for the undertaking to directly or indirectly impact the integrity of a potential historic property,
      2. Compromises to the physical integrity of a property more than 50 years old that could render it ineligible for the National Register,
      3. The degree of recent development and overall change within the APE,
      4. The density of potential historic properties in the area of the undertaking,
      5. Modifications to the undertaking that can be made to avoid impacts to potential historic properties,
      6. The potential archaeological sensitivity within the APE,
      7. A review of existing information on historic properties within the APE, and
      8. Information from consulting parties and others with knowledge of, or concerns with, historic properties within the APE.
    5. Initiate archaeological and/or aboveground field surveys, as warranted, for any property that may be affected by an undertaking, and that may be eligible for listing in the National Register, as outlined below;
      1. Archaeological Surveys
        1. Phase IA archaeological reviews shall be conducted by the NHDOT-BOE 36 CFR 61 qualified archaeologist or consulting archaeologist(s) in conformance with the Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation: Identification (1983, as revised in the 48 FR 44716), and the DOT Archaeological Standards and Guidelines;
        2. Studies beyond phase IA archaeological reviews, as recommended by the NHDOT Archaeological Standards and Guidelines, and the determination of National Register eligibility of archaeological sites shall follow the regular Section 106 process pursuant to Stipulation VI.D.
      2. Aboveground Surveys
        1. Aboveground reviews shall be conducted by the NHDOT-BOE 36 CFR 61 qualified architectural historian or consulting architectural historian(s) in conformance with the Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation: Identification and Evaluation (1983, as revised in the 48 FR 44716), and SHPO guidelines;
        2. As warranted, individual inventory or area forms shall be prepared in accordance with SHPO guidelines for properties in the APE in order to determine National Register eligibility.

    NHDOT-BOE may address multiple steps simultaneously.

  2. Review of LPA Undertakings

    For all the types of undertakings listed in Appendix B, LPA sponsors shall employ a multidisciplinary approach to initiate consultation and identify historic properties that may be affected by an undertaking in accordance with the procedural requirements of 36 CFR 800.3 and 36 CFR 800.4, following the process outlined below:

    1. Initiate the Section 106 process in accordance with the procedures in 36 CFR 800.3, including establishing whether there is an undertaking, coordinating with other reviews, planning to involve the public, and identifying and inviting other consulting parties, as appropriate;
    2. Coordinate with the public through any/all of the following methods. Appendix E provides a list of typical consulting parties to consider:
      1. Sending initial contact letters to local historic commissions, other government entities with jurisdiction, regional planning commissions, and other potential consulting parties in accordance with CFR 800.2(c), 800.3(f) and 800.4(d);
      2. Presenting findings and soliciting input at public officials meetings, public informational meetings, and public hearings;
      3. Coordinating directly with abutting property owners through meetings, electronic communication, and telephone communication; and/or
      4. On site meetings with concerned property owners.
    3. Prepare and submit a hard copy of a completed Appendix B Certification Form, along with two original copies of a Transportation RPR, with required attachments, to the NHDOT-BOE Cultural Resources Program staff.
    4. NHDOT-BOE Cultural Resources Program shall:
      1. Assess potential impacts of the undertaking, including archaeological and aboveground sensitivity potential, to determine the applicability of an undertaking to the types listed in Appendix B.
      2. Determine whether archaeological or aboveground surveys are needed, utilizing rationale that include, but are not limited to, the following:
        1. The potential for the undertaking to directly or indirectly impact the integrity of a potential historic property,
        2. Compromises to the physical integrity of a property more than 50 years old that could render it ineligible for the National Register,
        3. The degree of recent development and overall change within the APE,
        4. The density of potential historic properties in the area of the undertaking,
        5. Modifications to the undertaking that can be made to avoid impacts to potential historic properties,
        6. The potential archaeological sensitivity within the APE,
        7. A review of existing information on historic properties within the APE, and
        8. Information from consulting parties and others with knowledge of, or concerns with, historic properties within the APE.
      3. Direct the LPA sponsor to initiate archaeological and/or aboveground field surveys, as warranted, for any property that may be affected by an undertaking, and that may be eligible for listing in the National Register, as outlined below;
        1. Archaeological Surveys
          1. Phase IA archaeological reviews shall be conducted by a 36 CFR 61 qualified archaeologist or consulting archaeologist(s) in conformance with the Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation: Identification (1983, as revised in the 48 FR 44716), and the DOT Archaeological Standards and Guidelines;
          2. Studies beyond phase IA archaeological reviews, as recommended by the DOT Archaeological Standards and Guidelines, and the determination of National Register eligibility of archaeological sites shall follow the regular Section 106 process pursuant to Stipulation VI.D.
        2. Aboveground Surveys
          1. Aboveground reviews shall be conducted by a 36 CFR 61 qualified architectural historian or consulting architectural historian(s) in conformance with the Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation: Identification and Evaluation (1983, as revised in the 48 FR 44716), and SHPO guidelines;
          2. As warranted, individual inventory or area forms shall be prepared in accordance with SHPO guidelines for properties in the APE in order to determine National Register eligibility.

    LPA sponsors may address multiple steps simultaneously.

  3. Results of Identification and Evaluation
    1. Eligibility Findings for Aboveground Resources

      Eligibility findings for the National Register shall be conducted by FHWA and SHPO via the review process in place at the time of the undertaking, and in accordance with 36 CFR 800.4.

    2. Archaeological Report Reviews and Eligibility Findings

      Review of archaeological reports and eligibility findings for archaeological sites shall be conducted by FHWA and SHPO via the review process in place at the time of the undertaking, and in accordance with 36 CFR 800.4.

    3. Effects Findings

      For undertakings that conform to the types listed in Appendix B, the NHDOT-BOE Cultural Resources Program shall make a finding that the undertaking results in No Potential to Cause Effects, or No Historic Properties Affected, as appropriate, on the Appendix B Certification Form, and maintain documentation in its files. The NHDOT-BOE Cultural Resources Program shall notify the SHPO of its use of the documentation on specific undertakings in an annual report to the signatories of this Agreement, as specified in Stipulation IV.

      If a NHDOT-BOE Cultural Resources Program review under Stipulation VI determines that an undertaking may affect (either adversely or not adversely) National Register listed or eligible properties, and thereby does not conform to the types of undertakings listed in Appendix B, the NHDOT-BOE Cultural Resources Program shall utilize the Appendix B Certification Form to notify the NHDOT Project Manager and/or the LPA Project Manager in writing that the undertaking does not qualify for use of this Agreement, and the Section 106 review process outlined in 36 CFR 800.3-800.7 shall be utilized.

      All documents submitted by the NHDOT-BOE Cultural Resources Program to SHPO for review under this Agreement shall include the SHPO Review and Compliance number, if known, as well as a statement that the information is being submitted pursuant to a review under this Agreement.

  4. Notification and Coordination with FHWA and with the New Hampshire SHPO

    For any undertaking that includes, within the APE, National Register listed or eligible properties that the NHDOT-BOE Cultural Resources Program determines may be affected (either adversely or not adversely) by the undertaking, as defined by criteria set forth in 36 CFR 800.5(a) and outlined in Stipulation VI, the NHDOT-BOE Cultural Resources Program shall forward copies of the Appendix B Certification Form, Transportation RPR with required attachments, as well as all other relevant documentation to FHWA and SHPO, and the Section 106 review process outlined in 36 CFR 800.3-800.7 shall be utilized.

VII. Changes to the Scope of an Undertaking

Changes, or anticipated changes, to the design and/or scope of an undertaking that are made after signature of either an Appendix A Certification Form, or Appendix B Certification Form shall be coordinated with the NHDOT-BOE Cultural Resources Program. The NHDOT-BOE Cultural Resources Program staff shall be provided with sufficient information and time to allow for a complete reassessment of the modified undertaking. As appropriate, the NHDOT-BOE Cultural Resources Program shall evaluate the following and alert the project sponsor as to whether:

  1. The undertaking continues to conform to the types listed in either Appendix A or Appendix B,
  2. The undertaking continues to be able to be processed under this Agreement, and/or
  3. Additional or revised certification forms are required for a complete and thorough reassessment.

VIII. Review of NHDOT Projects under New Hampshire State Law

State-funded projects that are not part of the Program are not subject to the terms of this Agreement. NHDOT-BOE and New Hampshire SHPO will assess whether developing a Memorandum of Agreement (MOA) addressing review requirements of state-funded NHDOT projects would be appropriate to pursue. To the extent feasible, the MOA would follow the procedures established in this Agreement.

IX. Emergency Situations

This Agreement prescribes review processes for two classes of emergency situations as allowed in 36 CFR 800.12. The first class exists when (1) an undertaking is responding to a disaster or emergency declared by the President of the United States or Governor of the State of New Hampshire, or that is responding to immediate threats to life or property, and (2) corrective measures are initiated within 30 days after the disaster or emergency has been formally declared. Reviews in these emergency situations shall utilize the review process described in Stipulation VI, but with a shortened timeframe for participation by the SHPO, and consulting parties as time permits. Written notification of the emergency action being considered shall be provided to the SHPO, and any consulting parties. The notice shall be clearly identified as an emergency notification, and shall include a brief description of the significance of the resource(s) involved, the nature and anticipated effect of the emergency action on the resource(s), and the anticipated timeframe available for comment. The ACHP may be invited to participate in the review at the request of a consulting party, or any signatory, or invited signatory to this Agreement.

The second class of emergencies, as defined by immediate rescue and salvage operations conducted to preserve life or property such as necessitated by natural disaster or other catastrophic event, are exempt from the provisions of Section 106 and this Programmatic Agreement.

X. Post-Review and Unanticipated Discoveries

If a plan for subsequent discoveries is not in place, and there is an inadvertent discovery of a historic property or human remains during construction of undertakings inclusive of Appendix A and B projects, NHDOT or the LPA sponsor, as appropriate, shall stop construction in the immediate vicinity of the discovery, notify appropriate authorities, and follow the procedures outlined in 36 CFR 800.13. If the discovery involves human remains, NHDOT or the LPA project sponsor, as appropriate, shall follow the procedures established in Stipulation XI of this Agreement.

XI. Treatment of Human Remains

If previously unidentified human remains are discovered during construction, that portion of the undertaking shall stop immediately. The area shall be protected and NHDOT or the LPA sponsor, as appropriate, shall immediately consult with the New Hampshire State Police, FHWA, NHDOT-BOE Cultural Resources Program, SHPO, the State Archaeologist, and the State Medical Examiner. Once notified, FHWA shall immediately consult with any federally recognized Indian Tribe or tribes that may ascribe traditional cultural and religious significance to the remains. Native American human remains discovered on Federal or tribal lands shall be treated in accordance with the Native American Graves Protection and Repatriation Act (P.L. 101-106). Any human remains discovered on non-federal lands shall be treated in accordance with NH RSA 227-C:8-a through 8-g.

XII. Amendment

Any party to this Agreement may request that it be amended, whereupon the parties shall consult to consider such amendment.

XIII. Termination

Any party to this Agreement may terminate it by providing 30 calendar days notice in writing to the other parties explaining the reason for termination, provided that the parties consult during the period prior to termination to seek agreement on amendments and other actions that would avoid termination. In the event of termination, the FHWA shall comply with the Section 106 review process in 36 CFR 800.3-800.7 with regard to individual properties covered by this Agreement.

XIV. Dispute Resolution

Should any signatory or invited signatory to this Agreement object at any time to any actions proposed or the manner in which the terms of this Agreement are implemented, FHWA shall consult with the objecting party(ies) to resolve the objection. If FHWA determines that such objection(s) cannot be resolved, FHWA will:

  1. Forward all documentation relevant to the dispute to ACHP in accordance with 36 CFR 800.2(b)(2). Upon receipt of adequate documentation ACHP shall review and advise FHWA on the resolution of the objection within thirty (30) days. Any comments provided by ACHP, and all comments from the parties to the Agreement, will be taken into account by FHWA in reaching a final decision regarding the dispute.
  2. If ACHP does not provide comments regarding the dispute within thirty (30) days after receipt of adequate documentation, FHWA may render a decision regarding the dispute. In reaching the decision, FHWA will take into account all comments regarding the dispute from the parties to the Agreement.
  3. FHWA’s responsibilities to carry out all other actions subject to the terms of this Agreement that are not the subject of the dispute remain unchanged. FHWA will notify all parties of its decision in writing before implementing that portion of the undertaking subject to dispute under this stipulation. FHWA’s decision will be final.

XV. Duration

This Agreement shall remain in effect for a period of three (3) years after the date it takes effect, unless it is terminated prior to that time pursuant to Stipulation XIII of this Agreement. This Agreement shall be reviewed by all parties on an annual basis for modification or termination in accordance with Stipulation IV. If no changes are proposed and no party objects within the first three (3) year term, the term of the Agreement shall be extended automatically for another five (5) years without re-execution.

XVI. Definitions

Terms used in this Agreement are defined in Appendix C.

XVII. Signatures

Execution and implementation of this Agreement evidences that FHWA has satisfied its Section 106 responsibilities for all Program undertakings covered by this Agreement, and has afforded the ACHP an opportunity to comment.

The parties hereby acknowledge and reaffirm their commitment to perform all duties set forth in this Agreement.

Patrick A. Bauer, New Hampshire Division Administrator, Federal Highway Administration
Date: 10-15-14

Christopher D. Clement, Senior Commissioner, New Hampshire Department of Transportation
Date: 10/6/14

Elizabeth H. Muzzey, State Historic Preservation Officer, New Hampshire Division of Historical Resources
Date: 10/7/14

John M. Fowler, Executive Director, Advisory Council on Historic Preservation
Date: 11/26/14