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Opportunity to Comment on FHWA Program Comment for Post-1945 Bridges

| Apr 10, 2013
At the request of the Federal Highway Administration (FHWA), the Advisory Council on Historic Preservation has issued a Program Comment that will eliminate individual historic review requirements under Section 106 of the National Historic Preservation Act for common post-1945 concrete and steel bridges and culverts (attached).   This new Program Comment applies to effects of undertakings on certain common concrete and steel bridges lacking distinction, not previously listed or determined eligible for listing on the National Register, and not located in or adjacent to historic districts.  It makes no findings regarding the historic significance of the bridges included under its terms, but goes directly to treatment for these types of bridges which in any case are not likely to be preserved in place.  The Program Comment also obligates FHWA to carry out certain programmatic mitigation to address the potential loss of some historic bridges under its terms.
                                                               
The intent of Program Comment is to ensure that more obviously special or unique historic bridges receive the attention they deserve while the project development process is substantially streamlined for common, “cookie-cutter” bridges that are unlikely to be significant for preservation in place.  These bridges were constructed in vast numbers after World War II using standardized plans.  Although there has been little public interest in the preservation of these common bridges and culverts, FHWA was required under Section 106 to consider and document the potential historic significance of any bridge approaching 50 years of age that might be affected by FHWA projects. See http://www.environment.fhwa.dot.gov/histpres/bridges.asp for examples of common bridge types covered by the Program Comment.

You are invited as an interested party to participate in a conference call/meeting to provide recommendations about post-1945 concrete and steel bridges and culverts having exceptional significance.  

Exceptional Significance is defined as:

•    association with an event or individual;
•    being a very early or particularly important example of its type in a State or the nation;
•    having distinctive engineering or architectural features that depart from standard designs; or
•    displaying other elements that were engineered to respond to a unique environmental context.  

The meeting will be held on May 2 at 10:00 AM in Harrisburg, PA.  If you are unable to participate in the conference call/meeting, you are not precluded from providing input.  You may provide input concerning exceptional post-1945 concrete and steel bridges and culverts via email or letter by May 3.

If you wish to provide input about a post-1945 concrete and steel bridges or culvert which you are recommending as exceptional, please provide the following information:

•    County
•    Municipality
•    State Route # or Township # (if known)
•    Road name
•    What the bridge crosses (creek name, railroad, road, etc.)
•    Reason you are recommending the bridge or culvert as exceptional (include which of the four criteria listed above you think it meets and provide a brief explain why)

The agenda for the conference call/meeting is as follows:

•    Introductions/Meeting framework
•    Brief explanation of the Program Comment purpose and procedures (also described below in this email and attached)
•    Collection of input from all participants about recommended exceptional post-1945 concrete and steel bridges and culverts
•    Next steps

The methodology of creating this list was established by FHWA’s Federal Preservation Officer in cooperation with the President’s Advisory Council on Historic Preservation (ACHP).  Because of the framework of the Program Comment, the methodology of creating the list will be explained, but will not be a topic for discussion, at this meeting.  During the meeting we will not discuss or debate the significance of each bridge or make a determination about whether each bridge will or will not be placed on the list of exceptional post-1945 concrete and steel bridges and culverts.  The meeting is for information collection only.

Once we have gathered the input, FHWA will develop a list of exceptional post-1945 concrete and steel bridges and culverts.  This list is not intended to be exhaustive, nor will it necessarily be final.  The intent is to provide a means to exclude obviously exceptional bridges from falling under the Program Comment.  The creation of this list does not preclude consulting parties from providing information about bridges that may be exceptional during consultation for specific projects.  In those cases, it may be determined during the project development process that a bridge is exceptional, and the Program Comment would not apply.  In addition, the adoption of this Program Comment does not mean that FHWA and PennDOT will apply it to every project.  It will be applied on a case-by-case basis when appropriate.

The Program Comment is not a waiver for bridge projects.  It eliminates case-by-case review for bridges and culverts meeting the criteria, while retaining the requirement for FHWA to consider the effects of its actions on any other historic properties affected by a proposed project.
 
The full text of the Program Comment is attached, but it breaks down into several parts.

•    The Program Comment applies to specific types of bridges and culverts built after 1945, including various forms of reinforced concrete slab bridges, reinforced concrete beam and girder bridges, steel multi-beam bridges or multi-girder bridges, and culverts and reinforced concrete boxes (Section V).
•    The Program Comment does NOT apply to bridges that are already listed in or eligible for the National Register of Historic Places or to those located in or adjacent to a historic district (Section IV.A).
•    The Program Comment does NOT apply to arch bridges, truss bridges, bridges with movable spans, suspension bridges, cable-stayed bridges, or covered bridges (Section IV.B).
•    The Program Comment does NOT apply to bridges identified as having exceptional significance for association with a person or event, being a very early or particularly important example of its type in a State or the nation, having distinctive engineering or architectural features that depart from standard designs, or displaying other elements that were engineered to respond to a unique environmental context and included in a list to be developed by each state Division of FHWA (Section IV.C).

The Program Comment never envisioned requiring a survey to complete the listing of exceptional bridges; however, if a state has a survey or management plan it should suffice to identify exceptional bridges, if any, and those already listed in or determined eligible for the National Register.  For those bridges previously listed or determined eligible under the provisions of an existing Programmatic Agreement, this Program Comment will make little difference except to allow bridges not yet under the terms of the PA to forego evaluation in the future as they approach the age to be considered eligible or as the PA is amended to allow the programmatic mitigation provided with the Program Comment to fulfill any further stipulation for coordination and mitigation.

If you are interested in participating either in person or on the phone, you must RSVP by April 22, 2013 to Barbara Shaffer or Deborah Suciu Smith (contact information below) so that we know what size facility we need and can ensure that we have enough lines for the conference call.  When you RSVP, please let us know if you plan to attend in person or call into the conference call.  The meeting will be in Harrisburg.  Once you RSVP, we will provide you with the location or call-in number.

If you are unable to attend, but would like to provide input on exceptional post-1945 concrete and steel bridges and culverts, please send your input by May 3, 2013 at barbara.shaffer@dot.gov or Deborah.suciu.smith@dot.gov or

Barbara J. Shaffer or Deborah Suciu Smith
Planning and Environmental Specialist
Federal Highway Administration
Pennsylvania Division
228 Walnut Street, Room 508
Harrisburg PA 17101-1720

We look forward to your input.

Thank you,
Barbara Shaffer