Section 106 of the National Historic Preservation Act requires a review of any Federal project that could potentially impact a historic property. There are four steps in the Section 106 compliance process. This page outlines how to complete Step One of the process. There are similar, separate pages for Step Two, Step Three and Step Four. Be sure to check them out!

STEP ONE: INITIATE THE PROCESS

To complete STEP ONE, answer this question:
IS THIS PROJECT AN UNDERTAKING?

An undertaking is any project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency, including those carried out by or on behalf of a Federal agency; those carried out with Federal assistance; and those requiring a Federal permit, license, or approval. If there is no undertaking, then you don’t have to go any further in the 106 Process.

If there is an undertaking taking place, then determine if it is a type of activity that has the potential to cause effects on historic properties.

No Potential to Cause Effects
Is the undertaking a type of activity that has the potential to cause effects on historic properties, assuming such properties were present? If the answer is no, the agency has no further obligation under Section 106.

Identify SHPO/THPO
The SHPO is your State Historic Preservation Officer and THPO is your Tribal Historic Preservation Officer. If the proposed action is an undertaking that has the potential to effect historic properties, then identify the appropriate SHPO/THPO and initiate consultation with them. To initiate consultation, we recommend you send a letter to SHPO/THPO describing the proposed undertaking. A sample letter can be found here. Go to this website to find your SHPO and this website to find your THPO.

Identify Other Consulting Parties
You must identify other consulting parties and invite them to participate in the process. Such parties may include: Indian tribes and Native Hawaiian organizations, representatives of local governments, applicants for Federal assistance, permits and licenses, and the public.

HELPFUL SITES/LINKS

HELPFUL TERMS

Undertaking: any project, activity, or program funded or under the jurisdiction of a Federal Agency
SHPO: State Historic Preservation Officer
THPO: Tribal Historic Preservation Officer

REAL WORLD SCENARIO

Watch an interview with Jeff Durbin, National Section 106 Compliance Program Manager, as he explains Step One of Section 106: Initiate the Process

Audio Description Video for Step One
Step One Video Transcript

Next Step

Proceed to Step Two of the 106 process.

Write a Review

  1. Prior to the start of this course I never thought how much time folks like the parks Cultural Resource Experts needed to expand on projects such as this one.

Arrow pointing upwards. Click this icon to go back to the top of the page.