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Commission staff reports sharp rise in Section 106 reviews, flags workload and coordination needs
Summary
Staff told commissioners that potentially historic property reviews for Section 106 nearly tripled compared with last year and that many grant-funded projects are expanding to include building systems, prompting discussion about timing, coordination with adjacent properties and grant administration.
The commission's coordinator reported an increase in Section 106 workload and urged commissioners to expect broader project scopes and more coordination in grant administration.
The coordinator said the number of potentially historic Section 106 reviews rose to 23 this year compared with eight at a similar point last year, and noted that some neighborhoods—particularly Edison—have many properties flagged as potentially historic. "When 1 0 6 kicks in ... those funds won't get released until the reviews are complete," the coordinator said, explaining that federal funds (for example, HUD community development block grants) trigger the review process.
Members asked how the process works when properties fall outside local historic districts but are listed as eligible for the National Register, and the coordinator explained that eligibility can necessitate a 1 0 6 review and sometimes means layered reviews for projects that also require local historic-district approval.
The coordinator also warned that recently funded projects are expanding past traditional preservation work to include building systems and larger scopes, which can affect timelines and require coordination with adjacent property owners and other stakeholders.
Next steps: staff will continue to monitor review workloads, follow up on outstanding GRAMA requests, and work with the grant subcommittee to align timelines and application guidance with the realities of larger project scopes.
