Section 106 Historic Preservation Review Underway

Tuesday, October 8, 2024

Historic preservation is a core component of the Jones Library Renovation & Expansion project and has been since the project began. Library and Town leaders are carefully following a complex process for the necessary federal, state, and local regulations which balance program needs and historic preservation.

The Town has initiated the Section 106 Historic Preservation review and consultation process, hosting a key public meeting this Wednesday, 10/9/24 at 12:30 via Zoom.

Explore the substantive details here: https://www.amherstma.gov/3804/Section-106-Historic-Preservation-Review

Attend, learn & speak! The Jones Library Building Committee meets Wednesday, October 9, 2024 at 12:30 on Zoom  The meeting will include:

->A presentation by the Senior Historian from the Public Archaeology Laboratory (PAL) about the Section 106 process & findings;

-> Input by institutions and organizations invited by the Town to consult on measures to mitigate adverse effects to historic properties; and

-> Public comment relevant to the section 106 findings and mitigation options.

Historic Preservation Distinctions

Historic preservation has been a key part of this project since the very beginning.

The Jones Library is part of the Amherst Central Business Historic District, which is on the National Register of Historic Places. Therefore, any changes to the historic look and feel of the building need to be reviewed under the standards of Section 106 of the Federal Historic Preservation Act of 1966.

The historic preservation distinction does not mean we cannot change anything in the original building. It means we need to consider changes to the historic details in light of the overall needs and function of the library.

The Jones is a library, not a museum. This means some internal changes are necessary. The stairwell in the children’s area needs to be removed to make enough space for the demands of our children’s programs. Other changes to walls and doors are necessary to make the building fully accessible for people with disabilities and safer for everyone.

Minimal Interior Changes

Rumors that the renovation will gut the interior of the building are not true. Our architects explored multiple options to find the most cost-effective way to renovate while preserving the historic fabric of the building. The current proposal is to keep the vast majority of the interior woodwork intact, not disturbing the asbestos in the plaster behind.

Chart demonstrating Library processes with the MA Historic Commission
Presentation to the Amherst Historical Commission 8/28/24 Page 18.

MHC Parallel Processes

Massachusetts has its own historic preservation regulations and funding streams. In 2023, once building plans were far enough along to do so, the Library initiated two distinct processes with the MA Historical Commission (MHC):

  • Applications to compete for historic rehabilitation tax credit funding.
  • The Project Notification Form (PNF) initiating the Section 106 historic preservation review.

Both processes cover much of the same information about the building but are distinct from each other. In their presentation to the Amherst Historical Commission, Finegold Alexander Architects shared a chart distinguishing between the two. (see page 18.)

Historic Tax Credits

For tax credits, it is common to apply multiple times and receive feedback from MHC before being approved or denied. Our first two applications received feedback that needed to be addressed in future applications. The April 2024 letter that told us that they found the changes to the building to be too significant to qualify for tax credits. (Incidentally, this denial letter was sent the same day we received the singular high bid for the project.)

Historic Tax Credits are not and were not ever counted in the $39 million secured for the project. Tax credits were listed as pending. After MHC’s April decision, HTCs have been removed from any listing of possible funding.

With this and all pending funding, we continue to operate in good faith.

Section 106 Historic Preservation Review

In October 2023, consultants working with the library submitted the Project Notification Form (PNF) to MA Historic Commission, seeking their Section 106 determination for our federal grants, including National Endowment for the Humanities (NEH) funding.

MHC replied in writing in November. Library staff resubmitted the PNF in February 2024 addressing the issues raised in their letter. At the same time, we submitted more details for the HTC application. And then we waited for the two MHC processes to play out in parallel time.

MHC has taken no further action on the PNF, even as they decided against HTC funding. on the HTC application.

Section 106 consulting process is underway

Town and Library officials remain in regular contact with the federal agencies funding our project to ensure our efforts comply with their requirements. In consultation with the appropriate federal agencies, the Town of Amherst has assumed authority to carry out the Section 106 review.

Following the guidance of subject matter experts from the Public Archaeology Laboratory (PAL), the Town has issued a finding of adverse effect, noting the ways in which project plans will impact the Jones Library, the Strong House, and the Historic District. Details of these findings are documented in the Historic Resources Assessment prepared by the PAL consultant.

Citing the decade of planning during which the Town has considered ways to avoid and/or minimize impacts to historic properties, the Town will next create a Memorandum of Agreement (MOA) detailing mitigation measures for actions that could not be avoided or minimized. Along with inviting public input, the Town has invited two dozen local organizations and institutions to participate in the MOA consulting process. Details, including the list of consulting party organizations, supporting documentation, and links for making public comment are on the Town’s web page:  https://www.amherstma.gov/3804/Section-106-Historic-Preservation-Review

A version of this article ran on the Amherst Current Tuesday, October 8, 2024.
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