SECTION 106 REVIEW                                                                         FOR ENERGY PROJECTS:           ...
INTRODUCTION Recent interest in expanding the development and transmission  of energy resources, including renewable ener...
MY PRESENTATION - A VERY BRIEF OVERVIEW OF ISSUES ANDRECOMMENDATIONS REGARDING SECTION 106 REVIEW FOR ENERGYDEVELOPMENT PR...
ADVISORY COUNCIL ON HISTORICPRESERVATION Appointed  membership Responsible for  overseeing the Section  106 review proce...
ACHP ROLES developed and interprets the Section 106 regulations,  “Protection of Historic Properties” (36 CFR 800) provi...
SECTION 106 OF THE NHPAThe head of any Federal agency having direct or indirectjurisdiction over a proposed Federal or fed...
THE SECTION 106 PROCESS       1. INITIATE the process       1. INITIATE the process                                       ...
RECENT INCREASE IN NUMBER AND VISIBILITY OFUNDERTAKINGS RELATED TO ENERGYDEVELOPMENT AND TRANSMISSION desire to reduce de...
FEDERAL ACTIONS AND THE SCOPE OF FEDERALINVOLVEMENT VARIES (SOME EXAMPLES) Permitting/special use on federally managed la...
COMMON ISSUES / COMMON PROBLEMS project timing and Coordination of Section 106  review with the planning process conside...
PROJECT TIMING AND COORDINATION OFSECTION 106 REVIEW WITH THE PLANNINGPROCESS sponsored by private entities, early planni...
OFTEN LARGE LAND AREAS INVOLVEDprojects that cover large areaseffects on large historic properties withindeterminate bou...
RANGE OF HISTORIC PROPERTYTYPES AFFECTED standing structures and historic districts historic/cultural landscapes archae...
NATIVE AMERICAN TRIBALCONSULTATION Need to initiate early in the review process government-to-government consultation t...
STEPS TO IDENTIFY PROPERTIES OF RELIGIOUSAND CULTURAL SIGNIFICANCE TO TRIBES ethnographic / ethnohistoric research resea...
MULTIDISCIPLINARY TEAMS Historical landscape architect Ethnographer, cultural anthropologist Tribal experts (traditiona...
CONFIDENTIALITYThere is frequently a need to maintainconfidentiality regarding information aboutproperties of religious an...
RECOMMENDATIONS TO IMPROVE THEEFFICIENCY AND EFFECTIVENESS OF THESECTION 106 REVIEW PROCESS early consideration of the po...
EARLY CONSIDERATION OF THE POTENTIALFOR EFFECTS TO HISTORIC PROPERTIES pre-selection of areas by potential for effects to...
TRIBAL CONSULTATION - 1 formally contact tribes early in its review  process, establish protocols for exchange  of inform...
TRIBAL CONSULTATION - 2 federal agencies should seriously consider  tribal concerns due deference to views of tribes reg...
TRIBAL CONSULTATION - 3 work to resolve conflicts between concerns  about confidentiality and the need for  transparency ...
ACHP INITIATIVES ANDINTERAGENCY COORDINATION    ACHP / DOI framework for energy projects    CEQ’s Renewable Energy Rapid...
SAMPLE OF RELEVANT GUIDANCE ACHP Resources for Energy Projects  (http://www.achp.gov/docs/ACHPResourcesEnergyH  andout_13...
GUIDANCE SAMPLER - 2 Consultation with Native Hawaiian  Organizations in the Section 106 Review  Process: A Handbook  (ht...
GUIDANCE SAMPLER - 3 ACHP Homepage on Renewable Energy  Development  (www.achp.gov/renewable_energy.html) Reasonable and...
CASE DIGEST ENERGY PROJECTSUMMARIES Renewable Energy park Project at Ewa Field, Winter 2012 Keystone Pipeline, Fall 2007...
CASE DIGEST ENERGY - 2 Medicine Lake Highlands Geothermal, Winter 2008 Glen Canyon Dam Project, Spring 2008 Permian Bas...
ADVISORY COUNCIL ON HISTORIC           PRESERVATION1100 PENNSYLVANIA AVE, N.W., SUITE 809       WASHINGTON, D.C. 20004    ...
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Section 106 Review for Energy Projects: Issues and Recommendations

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John Eddins, Advisory Council on Historic Preservation

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  • Recent interest in expanding the development and transmission of energy resources, with an increasing emphasis on renewable energy, presents a variety of potential impacts to historic properties on and off federal lands. These impacts include the direct effects of large-scale land development associated with solar or wind energy development on many types of historic properties including archaeological sites, historic structures, cultural landscapes, and properties of religious and cultural significance to Indian tribes and Native Hawaiian organizations as well as the introduction of visual intrusions imposed by the construction of wind turbines, transmission lines, and other facilities. While the technologies of energy resource recovery, generation, and transmission vary, the challenges for the management of historic properties and completion of the Section 106 process are largely consistent and include: project timing, consideration of alternatives for project location and implementation, tribal consultation and consultation with other interested parties, and assessing impacts on natural and cultural landscapes.
  • My presentation intended to be a very, very brief overview of recent ACHP experience with and initiatives related to energy development projects.
  • Who we are (As you all know, but by way of context) The Advisory Council on Historic Preservation (ACHP) established in 1966 National Historic Preservation Act (NHPA), is an independent federal agency that promotes the preservation, enhancement, and productive use of our nation's historic resources, and advises the President and Congress on national historic preservation policy.
  • ACHP developed and interprets the Section 106 regulations, “Protection of Historic Properties” (36 CFR 800) We provide guidance and training in the Section 106 process to federal agencies, SHPOs/THPOs, Tribes, Applicants for federal assistance, permit, or authorization, and other stakeholders Informed by the Criteria for Council Involvement in Individual Section 106 Cases, Appendix A of our regulations, the ACHP enters formally into Section 106 consultations conducted by federal agencies in order to (1) facilitate the Section 106 consultation when there are important procedural or policy issues, (2) significant historic properties are affected, or (3) significant tribal issues and concerns We provide comment on federal agency compliance with Section 106 for individual cases, programs, and in general
  • Section 106 of the NHPA establishes the requirement for federal agencies to take into account effects of undertakings on historic properties
  • Federal comply with Section 106 by following the Four step process set forth in the Section 106 regulations (1) Establish undertaking and initiate the Section 106 process (2) Identify historic properties (3) Assess effects to historic properties (4) Consult to resolve adverse effects
  • Over the last several years, the ACHP has noted an increasing number of projects related to energy development and transmission, many of these related to forms of renewable energy. The increase in projects is a response to our national interest in reducing dependency on foreign energy sources and a concern to address causes of global warming and other environmental issues. These projects were submitted by diverse agencies, including the National Park Service, the United States Navy, the Bureau of Land Management, the Department of Energy, the U.S. Army Corps of Engineers, the Federal Energy Regulatory Commission, the Bureau of Ocean Energy Management, USDA-Rural Development, the U.S. Fish and Wildlife Service and the Tennessee Valley Authority. As a result of the often complex nature of these projects and the high priority to advance renewable energy initiatives, the ACHP has participated in the consultation for such projects at a higher-than-average percentage rate. Many of these participation decisions have been the direct result of specific requests from SHPOs and Indian Tribes for ACHP participation. Most of the projects related to renewable energy have been for wind power and, more recently, solar power. However, there also have been a few related to geo-thermal and bio-fuels. Most conventional energy projects we see are for pipelines for transmission of natural gas, a number of oil pipelines crossing our national border, and more recently activities related to exploration and recovery of natural gas by hydrolic fracturing (fracking).
  • The federal involvement in these projects varies. Some examples include: i) Permitting/special use on federally managed lands (1) BOEMRE, (2) BLM, FS, other land managing agencies ii) Construction of pipelines (1) DOS – Presidential Permit for border crossing (2) FERC – Interstate Gas Pipelines iii) Grants (1) DOE (2) RUS iv) Environmental Impacts Corps of Engineers Permits for impacts to waters of US for exploration, recovery, and transmission projects EPA - NPDES vi) Varying scope of federal involvement with the undertaking and how that can affect the Section 106 review (1) Often a small federal handle
  • While the technologies vary, the challenges for the management of historic properties and completion of the Section 106 process are largely consistent and include: project timing, consideration of alternatives for project location and implementation, tribal consultation and consultation with other interested parties, and assessing impacts on natural and cultural landscapes.
  • Project timing and Coordination of Section 106 review with the planning process i) Often such energy projects are sponsored by private entities with early planning and analysis carried out before active federal involvement ii) There are often problems in compiling sufficient information about potential for effects to historic properties early enough to inform site selection to avoid potential effects to significant historic properties iii) After federal involvement is underway, the assignment to applicants / project proponents of responsibilities for initiation of the Section 106 process and compiling information about the presence of historic properties can cause problems for SHPOs/THPOs, tribes and NHOs, and other consulting parties and stakeholders
  • Often large land areas involved i) Such undertakings can cover large areas ii) often have effects on large historic properties with indeterminate boundaries iii) can have effects on historic properties that are distant from the footprint print of the project c) Direct and indirect effects, including visual effects on historic properties farther removed from footprint of the project
  • Range of historic property types affected i) Standing structures ii) Historic districts iii) Historic/cultural landscapes iv) Archaeological sites v) Archaeological districts vi) Traditional cultural properties of assorted types vii) Indigenous cultural landscapes viii) Other properties of religious and cultural significance to federally recognized Indian tribes and Native Hawaiian Organizations (NHO) ix) These can be overlapping categories
  • Federal agencies have an obligation to engage in government-to-government consultation with federally recognized tribes, but often do not energetically coordinate with tribes to achieve a mutually agreed upon definition of gov-to-gov consultation. This can lead to roadblocks in eliciting the concerns of tribes about properties of religious and cultural significance that might be affected by the undertaking. Tribes often are not content to consult directly with project proponents and often do not wish to share with proponents information about historic properties of religious and cultural significance that they wish to be held in confidence. There is no specific guidance on what constitutes a reasonable and good faith effort to identify properties of religious and cultural significance to tribes.
  • The process for compiling information about properties of religious and cultural significance to tribes is not standardized, and can include: (1) Professional ethnographic / ethnohistoric research (2) Research sponsored or carried out by the tribe (3) “TCP” studies (4) Oral history interviews with tribal elders and specialists (5) Field survey by assorted preservation professionals (6) Field survey by representatives of the tribes (7) Tribal monitoring during construction
  • Some of the preservation professionals and tribal specialists that might be involved:
  • Based on our experience with a range of Section 106 cases related to energy projects and the problems encountered by federal agencies, applicants, tribes, and other consulting parties and stakeholders, we have a general set of recommendations to improve the efficiency and effectiveness of the Section 106 review process for all stakeholders across energy project types. First recommendation: EARLY, EARLY, EARLY
  • Early consideration of the potential for effects to historic properties: i) Consideration of the potential for presence of historic properties in the project area and effects on historic properties should be integrated into the earliest stages of project planning ii) This could include the vetting and pre-selection of areas that would be open for potential energy projects in part based on the potential for effects to significant historic properties iii) Agencies should provide guidance to potential applicants for permits or assistance that highlights the need for project proponents to include consideration of effects on historic properties in the earliest stages of project planning iv) Federal agencies should ensure that the Section 106 process is initiated early enough in the project planning and review process so it can realistically affect consideration of alternatives and selection of a preferred alternative project site.
  • Formal Tribal Consultation should begin early and respect the Government-to-Government relationship between the federal government and federally recognized tribes i) The federal agency should formally contact tribes early in its review process, establish protocols for the exchange of information with the tribe and protocols to enable applicant interaction with tribes ii) Federal agencies should acknowledge the “special expertise” of Indian tribes in “assessing the eligibility of historic properties that may possess religious and cultural significance to them.”
  • Federal agencies should give serious consideration to the concerns expressed by the tribes. Due deference should be given to the views of an Indian tribe regarding the impact on historic properties that are integral to the cultural and religious identity of the tribe before deciding to approve an undertaking that will have an adverse effect on such sites.
  • Federal agencies should conscientiously and creatively work to resolve conflicts between tribal concerns about confidentiality and the need for transparency in the Section 106 review process Consultation with tribes should be conducted in settings and conditions that provide for the consideration of confidential information about properties of religious and cultural significance and associated beliefs and practices.
  • Over the past several years, policy makers, politicians, and the public have expressed concerns regarding energy independence, stimulation of job growth and economic recovery, and the development and use of clearer technologies that will benefit the environment and the economy. As a result, the federal government has demonstrated a commitment to expanding the development and transmission of energy resources and to achieve efficiencies in government regulation of energy projects. Interagency efforts are underway to facilitate more efficient project planning and approvals. Following on our experience with the Cape Wind case and in response to the priority of the Administration on moving forward rapidly with renewable energy development and transmission initiatives, the ACHP is actively addressing the implications of renewable energy development and transmission on historic properties through a variety of groups and interagency forums. We have been working with other federal agencies, tribes, project proponents, and other stakeholders to improve the effectiveness and efficiency of the Section 106 review process for energy undertakings and to ensure that federal planning properly addresses preservation interests. A few examples are listed on the slide. More in depth information is available at the ACHP website (http://www.achp.gov/renewable_energy.html) . See additional page of explanatory text
  • Federal Oversight and Assistance for Shale Gas Development and Section 106 (http://www.achp.gov/shale_gas_development.pdf ) An overview of the kinds of federal actions related to shale gas development projects that make such projects “undertakings” subject to Section 106 review. Federal Actions that Qualify Development of Wind Farms as Undertakings Subject to Section 106 (http://www.achp.gov/news_windfarmproject.html) An overview of the kinds of federal actions related to the development and operation of on- and off-shore wind farms that make such projects “undertakings” subject to Section 106 review.
  • ACHP Homepage on Renewable Energy Development (www.achp.gov/renewable_energy.html) The ACHP has developed a dedicated subpage on the ACHP’s homepage on renewable energy development, which includes information, tools, guidance, contacts, and other information Reasonable and Good Faith Identification Standard Guidance (http://www.achp.gov/docs/reasonable_good_faith_identification.pdf) The ACHP developed guidance for Section 106 users on meeting the regulatory requirement that federal agencies make a "reasonable and good faith effort" to identify historic properties as part of the Section 106 process. This question frequently arises when agencies are faced with conducting historic property surveys for large and/or linear project areas associated with renewable energy development and transmission projects .
  • Summaries of a sample of energy project cases that the ACHP has participated in, available in our Case Digests .
  • Section 106 Review for Energy Projects: Issues and Recommendations

    1. 1. SECTION 106 REVIEW FOR ENERGY PROJECTS: ISSUES AND RECOMMENDATIONS John Eddins July 16, 2012 Preservation Combination Conference / TRB ADC50 ADVISORY COUNCIL ON HISTORIC PRESERVATION PRESERVING AMERICA’S HERITAGEPhoto credit: Vito Palmisano courtesy the Michigan Economic Development Corporation
    2. 2. INTRODUCTION Recent interest in expanding the development and transmission of energy resources, including renewable energy, presents a variety of potential impacts to historic properties on and off federal lands. While the energy resource types vary, the challenges for the management of historic properties and completion of the Section 106 process are largely consistent and include: project timing, consideration of alternatives for project location and implementation, tribal consultation and consultation with other interested parties, and assessing impacts on natural and cultural landscapes.08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 2
    3. 3. MY PRESENTATION - A VERY BRIEF OVERVIEW OF ISSUES ANDRECOMMENDATIONS REGARDING SECTION 106 REVIEW FOR ENERGYDEVELOPMENT PROJECTSVISUAL SIMULATION OF CAPE WIND FROM HYANNIS PORT, NEAR KENNEDY COMPOUND 08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 3
    4. 4. ADVISORY COUNCIL ON HISTORICPRESERVATION Appointed membership Responsible for overseeing the Section 106 review process Advises the President and Congress Important role in setting national policy08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 4
    5. 5. ACHP ROLES developed and interprets the Section 106 regulations, “Protection of Historic Properties” (36 CFR 800) provides guidance and training in the Section 106 process formally enters into Section 106 consultations conducted by federal agencies comments on federal agency compliance with Section 106 for individual cases, programs, and in general08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 5
    6. 6. SECTION 106 OF THE NHPAThe head of any Federal agency having direct or indirectjurisdiction over a proposed Federal or federally assistedundertaking in any State and the head of any Federal departmentor independent agency having authority to license any undertakingshall, prior to the approval of the expenditure of any Federal fundson the undertaking or prior to the issuance of any license, as thecase may be, take into account the effect of the undertaking on anydistrict, site, building, structure, or object that is included in oreligible for inclusion in the National Register. The head of any suchFederal agency shall afford the Advisory Council on HistoricPreservation established under Title II of this Act a reasonableopportunity to comment with regard to such undertaking.08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 6
    7. 7. THE SECTION 106 PROCESS 1. INITIATE the process 1. INITIATE the process No undertaking/ potential to cause effects? 2. IDENTIFY historic properties 2. IDENTIFY historic properties No historic properties present/affected? 3. ASSESS adverse effects 3. ASSESS adverse effects No historic properties adversely affected? 4. RESOLVE adverse effects 4. RESOLVE adverse effects Agreement (MOA)/PA) or Council Comment08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 7
    8. 8. RECENT INCREASE IN NUMBER AND VISIBILITY OFUNDERTAKINGS RELATED TO ENERGYDEVELOPMENT AND TRANSMISSION desire to reduce dependency on foreign energy sources concern to address causes of global warming and other environmental issues concern to stimulate job growth and economic recovery both renewable and conventional
    9. 9. FEDERAL ACTIONS AND THE SCOPE OF FEDERALINVOLVEMENT VARIES (SOME EXAMPLES) Permitting/special use on federally managed lands – BOEMRE – BLM, FS, other land managing agencies Construction of pipelines – DOS – Presidential Permit for border crossing – FERC – Interstate Gas Pipelines Grants – DOE – RUS Environmental Impacts – Corps of Engineers Permits (Section 404 of CWA and Section 10 of RHA) – EPA - NPDES08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 9
    10. 10. COMMON ISSUES / COMMON PROBLEMS project timing and Coordination of Section 106 review with the planning process consideration of alternatives for project location and implementation often large land areas involved direct and indirect effects range of historic property types affected Native American Tribal consultation08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 10
    11. 11. PROJECT TIMING AND COORDINATION OFSECTION 106 REVIEW WITH THE PLANNINGPROCESS sponsored by private entities, early planning and analysis carried out before active federal involvement problems in compiling information about potential for effects to historic properties early enough to inform site selection delegation of responsibilities in the Section 106 review to applicants / project proponents08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 11
    12. 12. OFTEN LARGE LAND AREAS INVOLVEDprojects that cover large areaseffects on large historic properties withindeterminate boundarieseffects on historic properties that aredistant from the footprint of the projectdirect and indirect effects08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 12
    13. 13. RANGE OF HISTORIC PROPERTYTYPES AFFECTED standing structures and historic districts historic/cultural landscapes archaeological sites and districts traditional cultural properties indigenous cultural landscapes other properties of religious and cultural significance to tribes and Native Hawaiian Organizations (NHO) these can be overlapping categories08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 13
    14. 14. NATIVE AMERICAN TRIBALCONSULTATION Need to initiate early in the review process government-to-government consultation tribal reluctance to consult directly with project proponents confidentiality issues no specific guidance on what constitutes a reasonable and good faith effort to identify properties of religious and cultural significance to tribes08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 14
    15. 15. STEPS TO IDENTIFY PROPERTIES OF RELIGIOUSAND CULTURAL SIGNIFICANCE TO TRIBES ethnographic / ethnohistoric research research sponsored or carried out by the tribe “TCP” studies oral history interviews with tribal elders and specialists field survey by preservation professionals field survey by representatives of the tribes tribal monitoring during construction08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 15
    16. 16. MULTIDISCIPLINARY TEAMS Historical landscape architect Ethnographer, cultural anthropologist Tribal experts (traditional practitioners, medicine men, basket-material gatherers, etc.) Archaeologist Historian Agricultural/horticultural/forestry specialist08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 16
    17. 17. CONFIDENTIALITYThere is frequently a need to maintainconfidentiality regarding information aboutproperties of religious and cultural significance totribes while gathering the information necessaryfor the Section 106 review and consultation. Attimes, it is difficult to achieve both goalssimultaneously.08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 17
    18. 18. RECOMMENDATIONS TO IMPROVE THEEFFICIENCY AND EFFECTIVENESS OF THESECTION 106 REVIEW PROCESS early consideration of the potential for effects to historic properties in planning process initiate consultation early in planning and review process early tribal consultation, reflecting government- to-government relationship, and sensitive to confidentiality issues08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 18
    19. 19. EARLY CONSIDERATION OF THE POTENTIALFOR EFFECTS TO HISTORIC PROPERTIES pre-selection of areas by potential for effects to significant historic properties guidance that highlights the need to include consideration of effects on historic properties in the earliest stages of project planning ensure Section 106 process is initiated early enough to affect consideration of alternatives08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 19
    20. 20. TRIBAL CONSULTATION - 1 formally contact tribes early in its review process, establish protocols for exchange of information and protocols to enable applicant interaction acknowledge “special expertise” of Indian tribes in assessing eligibility of historic properties of religious and cultural significance08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 20
    21. 21. TRIBAL CONSULTATION - 2 federal agencies should seriously consider tribal concerns due deference to views of tribes regarding effects on historic properties integral to their cultural and religious identity08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 21
    22. 22. TRIBAL CONSULTATION - 3 work to resolve conflicts between concerns about confidentiality and the need for transparency in the Section 106 review process consultation conducted in settings and conditions that provide for the consideration of confidential information08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 22
    23. 23. ACHP INITIATIVES ANDINTERAGENCY COORDINATION ACHP / DOI framework for energy projects CEQ’s Renewable Energy Rapid Response Team on- and off-shore wind energy development forums/agreements Tribal Summit on Renewable Energy Traditional Cultural Landscapes Forum Native American Traditional Cultural Landscapes Action Plan Western Renewable Energy and Historic Preservation Wrkgroup BLM Liaison ACHP Energy Policy Team - Applicant Toolkit being developed08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 23
    24. 24. SAMPLE OF RELEVANT GUIDANCE ACHP Resources for Energy Projects (http://www.achp.gov/docs/ACHPResourcesEnergyH andout_13feb12.pdf) Federal Oversight and Assistance for Shale Gas Development and Section 106 (http://www.achp.gov/shale_gas_development.pdf) Federal Actions that Qualify Development of Wind Farms as Undertakings Subject to Section 106 (http://www.achp.gov/news_windfarmproject.html)08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 24
    25. 25. GUIDANCE SAMPLER - 2 Consultation with Native Hawaiian Organizations in the Section 106 Review Process: A Handbook (http://www.achp.gov/Native%20Hawaiian %20Consultation%20Handbook.pdf) Consultation with Indian Tribes in the Section 106 Process: A Handbook - 2012 (http://www.achp.gov/pdfs/consultation-with- indian-tribes-handbook-june-2012.pdf) 08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 25
    26. 26. GUIDANCE SAMPLER - 3 ACHP Homepage on Renewable Energy Development (www.achp.gov/renewable_energy.html) Reasonable and Good Faith Identification Standard Guidance (http://www.achp.gov/docs/reasonable_good_f aith_identification.pdf)08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 26
    27. 27. CASE DIGEST ENERGY PROJECTSUMMARIES Renewable Energy park Project at Ewa Field, Winter 2012 Keystone Pipeline, Fall 2007 and Spring 2011 White Mountain Wind Energy, Summer 2011 Imperial Valley Solar, Fall 2010 West Tavaputs Full Field Gas and Oil Development, Winter 2010 Yucca Mountain Nuclear Repository, Spring 2009 Nantucket Sound Wind Farm Application, Summer 2009 Lake Powell Power and Water Systems, Fall 200908/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 27
    28. 28. CASE DIGEST ENERGY - 2 Medicine Lake Highlands Geothermal, Winter 2008 Glen Canyon Dam Project, Spring 2008 Permian Basin MOA for Oil and Gas, Summer 2008 Permits for Exploratory Drilling Mount Taylor, Summer 2008 Columbia River Power System, Winter 2007 Custer National Forest Oil and Gas Leasing, Spring 2007 Overland Pass Pipeline, Fall 2007 Coal and Wind Electric Generation Facility at Great Falls/Cascade County, Summer 2006 Find them at http://www.achp.gov/casedigest.html08/06/12 ADVISORY COUNCIL ON HISTORIC PRESERVATION 28
    29. 29. ADVISORY COUNCIL ON HISTORIC PRESERVATION1100 PENNSYLVANIA AVE, N.W., SUITE 809 WASHINGTON, D.C. 20004 www.achp.gov

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