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Commission discusses Section 106 reviews and PROTECT grant area for federally funded projects in Kalamazoo
Summary
Members reviewed how Section 106 federal reviews work, discussed the city's PROTECT grant project area (roughly from north Kalamazoo Avenue to Western Michigan University), and cited mitigation examples such as replanting trees after an airport runway proposal.
Commissioners and staff used the Nov. 12 meeting to revisit how Section 106 reviews are carried out for projects using federal funds and to note local projects that may undergo review, including a PROTECT grant–funded area that covers portions of northeast Kalamazoo down toward Western Michigan University.
A presenter summarized Section 106 as a federal-review process that evaluates whether federal funds will have adverse effects on historic resources and noted that the typical outcome of a Section 106 review can be a memorandum of agreement or memorandum of understanding identifying mitigation steps. "The end of a 106 review usually is like an MOA or MOU, a memorandum of agreement or a memorandum of understanding, where we look at what effects are gonna be wrought on historic properties ... and then how are we gonna mitigate those effects?" the presenter said.
Local examples and concerns: speakers pointed to the PROTECT grant project area (a city page and map were referenced) and noted that such projects can be divided into archaeological and above-ground evaluations. One commissioner cited the airport runway-extension review as an example where tree-removal concerns in a neighborhood led to mitigation that required replanting shorter trees.
Representation and consulting parties: attendees asked why the preservation commission had not been consistently included as a consulting party on past Section 106 projects. A presenter said they would look into how consulting parties are selected and whether the commission could play a clearer role in future reviews, including checking the city's CLG (Certified Local Government) status and how that might affect notifications.
What wasn't decided: the commission did not adopt any formal policy changes at the meeting; members asked staff to investigate why the commission has not been included consistently in past consulting-party outreach and to clarify which projects should be routed to the commission for review.
