What Is Section 106?
The Lead Hazard Reduction Capacity Building Program is funded by the
U.S. Department of Housing and Urban Development (HUD). Because federal
funding is used, every assisted project is subject to review under
Section 106 of the National Historic Preservation Act as part of HUD's
environmental review process.
Section 106 is a federal review process that requires federal agencies
and entities carrying out federally funded programs on their behalf to
consider how a project may affect historic properties before approving
work.
The purpose of the review is to ensure that public health improvements,
such as lead hazard reduction, are carried out while also considering
the preservation of Atlanta's historic buildings, neighborhoods, and
archaeological resources.
Section 106 does not prevent projects from moving forward. Instead, it
helps identify appropriate treatment measures and, when necessary, ways
to avoid, minimize, or mitigate adverse effects to historic properties.
How Does the Section 106 Review Process Work in City of Atlanta?
To streamline the Section 106 review process, the City of Atlanta
entered into a Programmatic Agreement (PA) with the U.S. Department of
Housing and Urban Development (HUD) and the Georgia State Historic
Preservation Office (SHPO) in January 2010.
The PA establishes agreed-upon review procedures that allow the City to
complete many aspects of the Section 106 review internally, while
ensuring compliance with federal historic preservation requirements.
Projects are reviewed in accordance with the PA, and consultation with
the SHPO is conducted when required.
Submission Requirements (for subrecipients/applicants)
To facilitate the Section 106 review process, applicants or
subrecipients should submit sufficient information for the City to
evaluate the proposed undertaking and its potential effects on historic
properties. Depending on the scope of work, the following information
may be required:
1. Required Forms
The following forms must be completed and submitted:
These forms provide the basic project information needed to begin the
Section 106 review.
2. Supporting Documentation
The following supporting documentation may be required, as applicable to
the proposed undertaking.
Existing Conditions
Provide clear, color photographs documenting the existing conditions of
the property, including:
- All exterior elevations
- Streetscape and surrounding context
- Interior areas affected by the proposed work (if applicable)
Photographs should be:
- Clearly labeled
- Dated (if possible)
-
Keyed to a site plan, aerial image, or photo location map indicating
the direction each photograph was taken
3. Lead Hazard Reduction Project Documentation
Provide documentation sufficient for the Preservation Professional to
evaluate the proposed undertaking, as applicable, including:
- Lead inspection or lead risk assessment report
- Proposed lead hazard reduction treatment plan or scope of work
- Construction drawings, plans, or specifications (if available)
-
Product specifications for proposed replacement materials (e.g.,
windows, doors, siding, trim, porches, or other character-defining
features), when applicable
- Architectural renderings, elevations, or details, if available
-
Any additional documentation necessary to evaluate the proposed work
and its potential effects on historic properties
4. Additional Information
The Preservation Professional may request additional information or
documentation as needed to complete the Section 106 review.
Public Participation
Public participation is an important part of the City of Atlanta's
Section 106 review process. The City provides opportunities for the
public to learn about certain HUD-assisted projects and share comments
when appropriate, in accordance with the National Historic Preservation
Act, HUD environmental review requirements (24 CFR Part 58), and the
City's Programmatic Agreement.
The level of public participation depends on the nature of the proposed
project and its potential to affect historic properties. The City will
determine the appropriate public involvement process based on the
project and applicable federal requirements.
Current Public Notices
This page will be updated with projects that are available for
public review and comment. Each notice will include, as applicable:
- Project name and location
- Project description
- Section 106 determination
- Supporting documentation
- Public comment period
- Instructions for submitting comments
Project Description
The undertaking consists of the proposed replacement of all
exterior historic wood siding and decorative cedar shake
shingles within the front gable area to address lead-based paint
contamination and achieve permanent abatement. The proposed
replacement materials include James Hardie HardiePlank fiber
cement lap siding and James Hardie HardieShingle fiber cement
shingle panels designed to replicate the appearance of the
existing historic materials.
During review of the proposed undertaking, several alternative
treatment approaches were considered to avoid or minimize
impacts to historic materials, including encapsulation,
selective replacement, stabilization, and non-abrasive paint
removal methods. The following alternatives were determined not
to be feasible or appropriate:
-
Interim control and encapsulation approaches were determined
not to be feasible due to the long-term monitoring,
maintenance, compliance, staffing, and liability obligations
associated with ongoing lead hazard management.
-
Non-abrasive paint removal methods, including chemical and
wet-method removal to bare substrate, were determined not to
be feasible due to the extent of lead-based paint
contamination across the exterior siding and cedar shake
shingles.
-
Abrasive removal methods such as sanding, grinding, or media
blasting were determined to be inappropriate for the historic
resource because such methods may damage historic wood
surfaces, diminish material integrity, and accelerate
deterioration of historic fabric.
Section 106 Determination
Adverse Effect
Historic Property Involved
The subject property is listed in the National Register of
Historic Places as a contributing resource within the Adair Park
National Register Historic District. The property contributes to
the district under National Register Criterion C as an example
of a Craftsman Bungalow and is therefore considered a historic
property pursuant to the National Historic Preservation Act and
the City-wide Programmatic Agreement.
Adverse Effect
The existing historic wood siding and decorative cedar shake
shingles are original historic materials and character-defining
features of the contributing resource. The current condition of
these materials does not meet the “50% or greater deterioration”
threshold identified in Appendix B of the Programmatic
Agreement, and the proposed treatment approach is not fully
consistent with the preservation guidance outlined in
Preservation Brief 37, which prioritizes retention and
stabilization of historic materials where feasible. Accordingly,
the proposed wholesale replacement of the historic siding and
cedar shake shingles would result in an Adverse Effect due to
the loss of historic materials and workmanship associated with
the contributing resource.
Proposed Mitigation Measures
-
Prior to removal of the existing siding and shingles, the
property shall be photographically documented, including all
primary elevations and representative detail views of the
siding, shingles, trim, and associated architectural features
affected by the undertaking. Documentation shall be retained
within the project record.
-
To the greatest extent feasible, replacement siding and
decorative gable shingles shall be replaced in kind using
compatible wood materials matching the existing historic
materials in profile, dimensions, reveal, orientation,
texture, finish, and overall appearance.
-
All remaining character-defining features, including windows,
window trim, porch elements, decorative trim, fascia, masonry
elements, and other architectural details shall be retained
and protected.
Supporting Documentation
Open the project maps and photographic documentation in a new
tab.
Submit Comments
Members of the public are encouraged to submit comments during the
designated public comment period. Comments received will be
considered as part of the City's Section 106 review process.