**Addendum**

**Lincoln Highway Special Resource Study**

**and Environmental Assessment**

**April 2005**

This study was available for public review from June to August 2004.
Because the changes to the study were minor, it was not reprinted.
Instead, this addendum was printed to complete the study. Included here
are:

1.  Responses to Comments on the Study

2.  An Errata Sheet

3.  The Finding of No Significant Impact that concludes the
    Environmental Assessment

**[Responses to Comments on the Study]{.underline}**

In January 2004, a mailing was sent to 2500 individuals on the mailing
list for this project, including units of local, state, and federal
government, the membership of the Lincoln Highway Association and others
who had expressed interest throughout the course of the study. This
mailing announced that the study was forthcoming and included a tear-off
postcard recipients could return to request a printed copy of the study.
Upon completion of the production and printing process in mid-June 2004,
copies were mailed to the 500 people who had requested a copy and the
document was posted on the project webpage. Copies of the study were
also sent to members of Congress and the Senate in each Congressional
district crossed by the Lincoln Highway, State Historic Preservation
Offices and Departments of Transportation in the 14 states through which
the highway passes, tribes with traditional connection to land in the
Lincoln Highway corridor and to representatives of the Certified Local
Governments overseeing historic preservation efforts in towns and
counties along the highway.

Comments on the study were due August 13, 2004. This comment period was
longer than the 30-day review period typically allowed for Environmental
Assessments to allow those who might be away from home for an extended
period of time during the summer months to comment. Within this extended
period, 21 comments were received. Two more comments were received late,
for a total of 23 comments.

These letters were sorted into those that offered substantive comments
and those that were non-substantive. Substantive comments are defined as
those that do one or more of the following: (source: The NPS Director's
Order 12, *Conservation Planning, Environmental Impact Analysis, and
Decision Making Handbook*, January 2001)

(a) question, with reasonable basis, the accuracy of information in the
    EIS.

(b) question, with reasonable basis, the adequacy of environmental
    analysis.

(c) present reasonable alternatives other than those presented in the
    EIS.

(d) cause changes or revision in the proposal.

All comments, whether substantive or not, were acknowledged and
considered. Substantive comments are summarized, grouped into themes and
responded to below. Responses to some of the non-substantive comments
are also included in order to clarify points made in the study. All of
the written comments and letters are available for review at the
National Park Service, Midwest Regional Office located in Omaha,
Nebraska.

**Substantive Comments and Responses**

***Comment Theme: Standard of evaluation and degree of integrity***

Some commenters disagreed with the finding that the Lincoln Highway does
not retain a high degree of integrity, suggesting that the standard used
to assess the integrity of the highway should have been the same as the
standard used to assess other "pioneer pathways" such as the Oregon
National Historic Trail, the Mormon Pioneer National Historic Trail, the
Pony Express National Historic Trail, etc.

Commenters:

-   Christopher Plummer, President, Lincoln Highway Association

-   Oral Comments offered at the Annual Meeting of the Lincoln Highway
    Association (June 18, Chester, West Virginia)

Response:

The designation process for National Historic Trails has evolved since
the passage of the National Trails System Act (NTSA) of 1968 to
recognize that virtually all historic trails have been impacted to the
degree that they would not be acceptable under the common definition of
integrity for a National Historic Landmark. Therefore, designation of
National Historic Trails has not required integrity in the same way or
to the same degree as designation of National Historic Landmarks.
However, we do not believe that Congress intended to include automobile
highways in the system of National Historic Trails. While the definition
of \"trail\" in the NTSA does not directly address this issue, section
5b(11) of the Act refers to \"trail segments no longer possible to
travel by trail due to *subsequent* development as motorized
transportation routes.\" \[emphasis added\], which suggests that routes
*originally* developed as motorized routes were not meant to be included
in the trails system.

Never-the-less, the concept of the Lincoln Highway as a National
Historic Trail was considered at a number of stages in the study process
with the understanding that this would require Congress to amend the
NTSA. However, the concept of the Lincoln Highway as a National Historic
Trail never developed into a management alternative because the existing
program for administering trails in the National Park System is not
designed or equipped to handle the competing interests, costs,
jurisdictional complexity, potential states rights issues, and life
safety concerns involved with managing a highway as a National Historic
Trail. It is important to note that there are alternative ways of
preserving, interpreting, and commemorating the Lincoln Highway other
than inclusion in the National Park System, such as the alternatives
described in this study. The preferred alternative described in this
study would benefit the Lincoln Highway in terms of preservation,
commemoration, and interpretation in much the same way as National
Historic Trail designation benefits historic trails.

Evaluating the integrity of long-distance historic highways is a complex
process. There is no special category within either the National Park
System or the National Historic Landmark program that provides a
different standard for evaluating the integrity of roads. Therefore, the
standard of integrity used to evaluate the Lincoln Highway is the same
as the standard used for any National Historic Landmark. It is important
to note that this study's finding that the Lincoln Highway does not
retain a high degree of integrity applies to the highway *as a whole*,
and *not* to every element of it. In fact, the study team did find 1500
resources that contribute to the significance of the Lincoln Highway,
including sections of the road itself, that do retain a high degree of
integrity. Since these resources were identified in a
reconnaissance-level survey conducted with minimal time and funding, it
is likely that a more in-depth survey may identify more than these 1500
resources. (see both Appendix D and response to non-substantive comment
theme: "Resources were overlooked").

***Comment Theme: Evaluation of National Significance***

One commenter felt that the section of the study evaluating the Lincoln
Highway using the criteria of the National Historic Landmark program
(pages 31-36) "stops short of articulating its true significance to
America and the rest of the world." In particular, this comment stressed
that the fact that the Lincoln Highway was a memorial to President
Abraham Lincoln and that it is associated not only with the President
but also with key figures in the early years of the American automobile
industry should have been noted in this evaluation.

Commenter: Craig Harmon, Director, Lincoln Highway National Museum and
Archives

Response:

The study begins Chapter Two, *History of the Lincoln Highway*, with a
note that that the Lincoln Highway was so named in honor of President
Abraham Lincoln and that "the motivations of the men who formed the LHA
were varied and included...the desire to build an appropriate memorial
to the fallen President." In this same chapter, it is noted that "the
Lincoln Highway began as the idea of Carl Fisher, the founder of the
Prest-O-Lite company" and that "visionary leaders in the early
automotive industry, chiefly Henry Joy of Packard Motor Company and
Frank Sieberling of Goodyear Tire and Rubber Company" worked with Fisher
to form the Lincoln Highway Association (both citations are taken from
page 3).

Chapter Four of the study describes the national significance of the
Lincoln Highway according to the criteria for making this determination
outlined in *NPS Management Policies 2001* and further defined by the
National Historic Landmarks (NHL) process. The NHL designation process
requires potential landmarks be assessed using six possible criteria,
which are listed on pages 31 and 32 of the study. While many potential
landmarks could be said to reflect all of the criteria to some degree,
under this process evaluation teams cite the criteria under which the
significance is *best* reflected. The Lincoln Highway study team
considered how all of the NHL criteria applied to the highway and
decided its national significance was ultimately best reflected in
criterion #1 and #5 for the reasons cited in the study.

Note that the errata sheet corrects a sentence in the first column of
page 32 to clarify that the Lincoln Highway's national significance is
not reflected *only* in criteria #1 and #5, but rather *best* reflected
in these criteria.

***Comment Theme: Mapping of the route***

Two commenters felt that important segments of the Lincoln Highway were
not included on the map and therefore erroneously not subject to the
reconnaissance survey. Specifically, one commenter presented research
that the Lincoln Highway was routed through Washington D.C. and Los
Angeles and that its terminus was in Hawaii, not San Francisco. Another
commenter felt that the Lincoln Highway had a secondary routing in the
Chicago area.

Commenters:

-   Craig Harmon, Director, Lincoln Highway National Museum and Archives

-   Arthur W. Olson

Response:

The maps developed for this study were based on the main route of the
Lincoln Highway and major deviations clearly stated in official
documents of the original Lincoln Highway Association, namely the LHA
guides, the notes Gael Hoag made of the marker placement in 1928 and the
official LHA history written in 1935. These documents make it clear
that, while the LHA described and mapped numerous feeder routes, they
thought of the Lincoln Highway as the main trunk of a national system of
highways. It is that main trunk that was the subject of this study.
Despite the extensive experience of study team members and exhaustive
research of historical documents, the team did not find any evidence of
an official LHA effort to sign or fund feeder routes. (See response to
non-substantive comment theme: "Qualifications of the study team").

In order to describe the route on a microscale (for example, specific
streets and section line roads between small towns), we relied on local
experts and deduction based on available routes at the time as defined
by contemporary maps and motor guides since official LHA documents on
this scale are difficult to find.

**Non-substantive Public Comments and Responses**

***Comment Theme: Resources were overlooked.***

Some comments suggested important Lincoln Highway resources were
overlooked in this study, both in the descriptive text and in the
survey. Various reasons were mentioned for why these commenters feel
that resources were overlooked including: ineffective survey logistics,
omission of the mention of specific towns, and undersurveying of dense
urban areas. Two commenters were concerned that if the preferred
alternative were implemented, preservation funding would be limited to
the list of items on the Summary of Reconnaissance Survey in the
Appendix to this study or to properties already listed in the National
Register.

Commenters:

-   Scott Maits, Belmont Community University Partnership (Philadelphia)

-   Byron Anderson, Mayor, Grantsville City, Utah

-   Mella Rothwell Harmon, National Register Coordinator, State of
    Nevada

-   Christine Lewandoski, Deputy Development/Historic Preservation
    Officer, Township of Princeton, New Jersey

-   Arthur W. Olson

Response:

"We appreciate the additional information about Lincoln Highway
resources provided by these commenters. While this study attempts to
give an overview of the role this resource played in American history, a
much more thorough study would be necessary to exhaustively discuss the
Lincoln Highway contributions of every town, city, and region along the
highway. When the information provided by commenters pointed out
overlooked resources contributing to the history of the highway and
included specific identifying elements for resources such as a business
name or street address, the survey was amended to add these resources
(see the errata sheet).

The survey conducted as part of this project was designed to meet the
needs of the study within time and funding limitations. Data was
recorded only on cultural resources that both related to the Lincoln
Highway's period of significance and contributed to that significance
(for example, buildings that offered gas, food, or lodging to travelers;
objects related to the significance of the highway such as markers and
monuments; bridges; road segments; and, associated landscapes). This
survey was reconnaissance level, which is defined under the Secretary of
Interior's preservation terminology as "an examination of all or part of
an area accomplished in sufficient detail to make generalizations about
the types and distribution of historic properties that may be present."
A reconnaissance-level survey of a resource on the scale of the Lincoln
Highway would be an inadequate tool on which to base decisions of which
individual resources to preserve, interpret or commemorate. Please note
that one of the management objectives used to design and evaluate
management alternatives was "continue to identify and evaluate
significant Lincoln Highway resources." (page 49) Including this factor
as an objective for any management alternative makes it clear that,
under any alternative enacted by Congress, it would be important to
further identify and evaluate Lincoln Highway-contributing resources in
order to most effectively concentrate limited preservation funding.

The same reconnaissance level of surveying was undertaken along the
entire length of the Lincoln Highway. As mentioned on page 61 of the
Environmental Assessment for this study, the counties through which the
Lincoln Highway passes are socially and economically diverse. The most
economically-disadvantaged county is primarily rural Juab County, Utah
where per capita income is 52 percent of the US average. The most
diverse counties (where the population is at least 30 percent minority)
include the metropolitan areas on the east and west ends of the highway
(in New York, New Jersey, Pennsylvania, and California) as well as St.
Joseph County, Indiana. In order to ensure that subjectivity in
evaluating resources was kept to a minimum, all the survey work across
the country followed the same methodology and was undertaken by a small
group of experienced cultural resource professionals, either the team
specifically hired for the surveying period or key members of the study
team.

***Comment Theme: Qualifications of the study team***

One commenter felt that "many involved" in the study "did not have a
clear understanding of the Lincoln Highway."

Commenter: Craig Harmon, Director, Lincoln Highway National Museum and
Archives

Response: The study team for this project had extensive experience in
evaluating cultural resources and planning for their preservation.
Collectively, the study team had more than 100 years of experience in
the fields of history, geography, historic architecture, historic
landscape architecture, and planning. In addition to general expertise
in cultural resource preservation and interpretation, this project also
benefited from the in-depth knowledge of the Lincoln Highway that team
members brought to the table. The study team included not only two
members who are charter members of the current LHA, but also an academic
expert on cultural geography in the United States \-- Kevin Patrick,
Professor of Geography at Indiana University of Pennsylvania. Dr.
Patrick completed his doctoral dissertation on the Lincoln Highway in
1995.

**[Errata Sheet]{.underline}**

Inside Front Cover. The captions for cover photos 6 and 7 are reversed.
Photo #6 is of Turtle Creek in Pennsylvania. Photo #7 is of Toll Gate
Rock in Wyoming.

Page 24. The last two sentences in Chapter Two need to be corrected to
read "The opening of the San Francisco-Oakland Bay Bridge in 1939 made
the ferry crossing obsolete, but, until that time, the highway came
ashore at the Ferry Building, then coursed up Market Street and west
over Post and Geary to 36^th^ Avenue. After turning north for a block,
the Lincoln Highway entered Lincoln Park and reached its western
terminus at the Palace of the Legion of Honor, overlooking the Pacific
Ocean.

Page 32. The first sentence of the paragraph in the first column which
reads "The national significance of the Lincoln Highway is reflected in
two of the above criteria, numbers 1 and 5" needs to be corrected to add
the word "best" so that it reads "The national significance of the
Lincoln Highway is best reflected in two of the above criteria, numbers
1 and 5."

[Changes to Appendix C, Lincoln Highway Resources in the National
Register of Historic Places, (page 75)]{.underline}

-   The Louis Joliet Hotel in Joliet, Illinois should be included as an
    individually-listed resource.

-   The Armstrong Hotel in Fort Collins, Colorado should be included as
    an individually-listed resource.

-   The Northern Hotel in Fort Collins, Colorado should be included as a
    district resource.

-   The Hemminger Travel Lodge in Plymouth, Indiana should be included
    as an individually-listed resource.

-   The 10^th^ Avenue Brick Remnant is in Mount Vernon, Iowa (not
    Lisbon).

-   The Mount Vernon Railroad Viaduct is in Mount Vernon, Iowa (not
    Lisbon).

-   The Mount Vernon Visitor Center in Mount Vernon, Iowa is not a
    former gas station. The commenter who pointed this out did not state
    what this building's historic use was, but did stress that the
    building has been moved from its original location, suggesting it
    may not contribute to the Mount Vernon Historic District. This
    comment also applies to the listing of the Mount Vernon Visitor
    Center in Appendix D, Page 88, line 319.

-   Kings Highway in New Jersey should be included as a district
    resource in the corridor between Kingston and Princeton, New Jersey.

-   The Bellevue-Stratford Hotel in Philadelphia, Pennsylvania should be
    included as an individually-listed resource

-   The Broad Street Historic District in Philadelphia, Pennsylvania
    should be included as a district resource

-   The North Broad Street Mansion Historic District in Philadelphia,
    Pennsylvania should be included as a district resource

-   North Broad Street Station, Reading Company in Philadelphia,
    Pennsylvania should be included as an individually-listed resource

There are two Appendices C. The Summary of Reconnaissance Survey Results
beginning on page 78 should be labeled Appendix D.

[Changes to Appendix D, Summary of Reconnaissance Survey Results, pages
78-125]{.underline} (as corrected above. labeled as "Appendix C" in
text)

-   page 92, rows 429 to 432, Column F needs to be corrected to read
    "Between Ashton and Franklin Grove, Illinois"

-   page 84, row 190. The Mountain Empire Hotel's current name is the
    "Armstrong Hotel". The hotel's address is 259 S. College Avenue in
    Fort Collins, Colorado and was constructed in 1922-23, not 1905.

-   page 86, row 244, Twin Towers address is 4010 Johnson Avenue NW

-   page 88, row 321, "Abbey" Creek is misspelled. This should be "Abbe"
    Creek.

-   "Seedling Mile Remnant between Mount Vernon and Cedar Rapids
    (1918/19)" and "Canopied Gas Station, 1560 First Street West, Mount
    Vernon (circa late 1920s)" need to be added to the list of resources
    in Iowa.

-   Page 86, row 244, the name of this resource needs to be changed to
    "Log Cabin Tourist Court/Twin Towers"

-   The Pulaski Skyway (circa 1932) in Jersey City needs to be added to
    the list of resources in New Jersey.

-   Streetcar tracks on Lancaster Avenue and 30^th^ Street Station
    (circa 1934) in Philadelphia need to be added to the list of
    resources in Pennsylvania.

-   The Broad Street Historic District in Philadelphia needs to be added
    to the list of resources in Pennsylvania.

-   The North Broad Street Mansion Historic District in Philadelphia
    needs to be added to the list of resources in Pennsylvania.

-   North Broad Street Station, Reading Company in Philadelphia needs to
    be added to the list of resources in Pennsylvania.

    **Finding of No Significant Impact**

    **Lincoln Highway Special Resource Study/Environmental Assessment**

    **[Introduction and Background]{.underline}**

The National Park Service (NPS) has completed a Special Resource Study
of the Lincoln Highway. In December of 2000, Congress directed the NPS
to evaluate the significance of the Lincoln Highway and to develop
alternatives for preserving, interpreting, and using its remaining
features (Public Law 106-563).

Established in 1913 as the idea of businessmen in the automobile
industry, the Lincoln Highway was one of America's first
transcontinental automobile roads. The highway, which began in New York
City and ended in San Francisco, played an important role in the
development of the automobile's influence on the way of life in 20^th^
century America.

The National Environmental Policy Act (NEPA) (42 U.S.C. § 4379 et seq.),
the Council on Environmental Quality (CEQ) regulations implementing NEPA
(40 CFR 1500-1508), and NPS Director's Order 12 and Handbook
(Conservation Planning, Environmental Impact Analysis, and Decision
Making) direct the NPS to consider the environmental consequences of
proposed federal actions. The NPS has completed an environmental
assessment (EA) that provides an analysis of the environmental
consequences of the management alternatives considered in the Lincoln
Highway Special Resource Study.

**[Preferred Alternative]{.underline}**

Under the preferred alternative, described as "Alternative 1" in the
study, either a new nonprofit organization would be established or the
capabilities of an existing organization would be enhanced in order to
coordinate a program to commemorate, preserve, and interpret the Lincoln
Highway. Congressional legislation would be necessary to implement the
alternative. The NPS would provide financial and technical support for
this organization. The program would include comprehensive planning,
certified interpretive sites, uniform signs, an information
clearinghouse, and the development of a website offering personalized
travel itineraries. A matching grant program to prioritize preservation
efforts would also be part of the program. In addition to providing
financial and technical support, the National Park Service would
encourage the inclusion of Lincoln Highway resources in existing federal
programs that influence preservation and interpretation of historic
roads.

This alternative was identified as the environmentally-preferred
alternative. It did not change after the public draft.

**[Other Alternatives Considered]{.underline}**

Four alternatives were considered \-- the preferred alternative
described in the proposed action and the three other alternatives
described below. The three alternatives described below were not
selected as the preferred alternative because they ranked lower against
the evaluation factors and could be expected to result in fewer
beneficial and more adverse environmental impacts. The seven factors
used to evaluate the benefits of the four alternatives were:

1.  Commemorate and Interpret the National Significance of both the
    Lincoln Highway and its Related Resources

2.  Provide for a Diversity of Lincoln Highway Experiences

3.  Preserve Significant Lincoln Highway Resources

4.  Continue to Identify and Evaluate Significant Lincoln Highway
    Resources

5.  Provide for Private Sector Efforts to Commemorate, Preserve and
    Interpret Lincoln Highway Resources.

6.  Provide for State and Local Government Efforts to Commemorate,
    Preserve and Interpret Lincoln Highway Resources.

7.  Provide for National Coordination Efforts to Commemorate, Preserve
    and Interpret Lincoln Highway Resources.

The topics used to analyze the environmental impacts of the alternatives
were:

1.  Impacts to Historic and Archeological Properties

2.  Wetlands and Floodplains

3.  Energy and Natural Resource Requirements and Conservation Potential

4.  Ecologically Critical Areas, Wild and Scenic Rivers, or Other Unique
    Natural Resources

5.  Air Quality

6.  Visitor Experience

7.  Socially or Economically-Disadvantaged Populations

The second alternative was entitled "Lincoln Highway Touring and
Discovery". Under this alternative, NPS would have proposed to Congress
the passage of legislation to introduce visitors to the Lincoln Highway
by establishing a series of discovery hubs and certified interpretive
sites and encouraging State-based programming and local interpretive
efforts. This alternative included: a set amount of matching funds per
state for the establishment of at least one hub, established in an
existing highway resource, in each Lincoln Highway state; additional
certified interpretive sites throughout each state: and, personal travel
itineraries available to the general public through a website.

The third alternative was entitled "Lincoln Highway Heritage Corridor."
Under this alternative, NPS would have proposed to Congress the passage
of legislation designed to solicit local interest in developing a
coalition that is a collection of multiple geographically defined
segments of the Lincoln Highway and associated resources (at least four
such segments spread out across the country). Within each segment, local
groups (businesses, nonprofit organizations, units of local government)
would take actions to protect, preserve, and promote the role that
segment played in the national Lincoln Highway story. Together, this
coalition would make up one national heritage corridor.

The fourth alternative was the No New Federal Action alternative, as
required by NEPA. Advocates of preserving Lincoln Highway resources
would continue to work within existing programs (for example, the
National Scenic Byway Program, the National Register of Historic Places
Programs, and Transportation Enhancements Program) to commemorate,
preserve, and interpret the Lincoln Highway.

Two other management alternatives were considered, but eliminated from
in-depth study: a national park unit, the "Lincoln Highway National
Historic Site", and a program within the U.S. Department of
Transportation to designate, preserve, and interpret historic roads and
highways that are nationally significant. Under this second alternative,
the Lincoln Highway would have been designated as the first national
historic highway. The designation of a segment of the highway as an
historic site was not studied in-depth because more survey work would
have been necessary to identify the best location for a potential
Lincoln Highway Historic Site. The historic highway program was not
pursued after considerable concern about this alternative was expressed
during public meetings. A third management concept, the Lincoln Highway
as a National Historic Trail, was considered early on in the study
process but never developed into an alternative because the existing
program for managing historic trails in the National Park Service is not
designed or equipped to handle the complexities of managing a highway as
an historic trail.

**[Environmentally Preferred Alternative]{.underline}**

The environmentally preferred alternative is the alternative that will
best promote the national environmental policy expressed in the National
Environmental Policy Act (NEPA) (Section 101 (b)). NPS *Management
Policies 2001* and Director's Order 12 ask that an environmental
assessment identify the environmentally preferred alternative. Expressed
simply, the environmentally preferred alternative is "...the alternative
that causes the least damage to the biological and physical environment;
it also means the alternative which best protects, preserves, and
enhances historic, cultural and natural resources. "

Of the four alternatives thoroughly evaluated and considered, the
preferred alternative and the third alternative best address the goals
of NEPA. These two alternatives do the best job of preserving the
Lincoln Highway both as a finite resource and as an element of our
history and culture. As such, they preserve portions of the resource and
history in trust for future generations and help attain a wide range of
beneficial uses without degradation of the quality of life. In addition,
the preservation of a valuable resource will not come at the expense of
the resources itself or be in conflict with the population or its
standards of living. These alternatives do not fully address the sixth
goal that concerns the reuse and recycling of depletable resources.
However, both the preferred alternative and the third alternative do
strongly encourage adaptive reuse of historic structures and, in doing
so, benefit energy conservation by reusing the embodied energy in these
structures. Moreover, neither of these alternatives requires a great
deal of nonrenewable resources and are not expected to use an
unreasonable amount of recyclable resources, and neither alternative is
wasteful of these resources.

Alternative two would address most of the goals of NEPA but would not be
as successful at achieving those goals. The alternative is not as
focused on the Lincoln Highway as a resource to preserve as the
preferred alternative and alternative three, but is more focused on the
interpretive centers (hubs) and interpretation of the Lincoln Highway
story. Under alternative two, there would be some trade offs between
concentrating preservation efforts on reusing a limited number of
Lincoln Highway resources as new interpretive centers as opposed to less
extensive rehabilitation of more historic structures as would occur
under the other alternatives.

Alternative four would also address to some degree the goals of NEPA but
would be much less successful in meeting those goals than the other
alternatives. Without a focused approach to the Lincoln Highway, there
would be greater opportunity to lose portions of the resource, and
efforts to interpret the resource for the benefit of succeeding
generations would be scattered. Without a single national focus, other
related resources could be lost, or fail to be interpreted for the
benefit of all Americans.

Though the preferred alternative and alternative three are nearly equal
in their ability to meet the national goals, the preferred alternative
is more successful in preserving and interpreting the resource. The
preferred alternative is also considered the environmentally preferred
alternative because the beneficial impacts to overall preservation and
interpretation of the Lincoln Highway outweigh slightly the relatively
minor adverse impacts it may have on economic development factors.
Alternative three may have less adverse impacts to economic development
but is not quite as successful in the preservation and interpretation of
the resource.

**[Criteria to Determine Significance of Environmental
Impact]{.underline}**

If implemented, the preferred alternative would not have a significant
impact on the natural environment, cultural or socioeconomic resources
of the Lincoln Highway Corridor. As noted in the Environmental
Assessment, this study does not propose specific actions at specific
sites. Until sites are selected and the parameters of specific projects
are known, it is not possible to meaningfully analyze the impacts of
*projects*; however none of the impacts that were analyzed in this study
on a *programmatic* level for any of the alternatives were considered to
be significant. The Council on Environmental Quality's regulations for
NEPA (40 CFR § 1508.27), determine "significance" of environmental
impact by examining each of the following ten criteria:

***Impacts that may be both beneficial and adverse.* *A significant
effect may exist even if the Federal agency believes that on balance the
effect will be beneficial. ***None of the projected impacts, based on
existing impacts of similar actions on a smaller scale and discussed
only on a programmatic level, are considered significant. Impacts to the
following are discussed in the Environmental Assessment: Historic and
Archeological Properties; Wetlands and Floodplains; Energy and Natural
Resource Requirements and Conservation Potential; Ecologically Critical
Areas, Wild and Scenic Rivers, or Other Unique Natural Resources; Air
Quality; Visitor Experience; and, Socially or Economically Disadvantaged
Populations. None of these impacts are considered significant. In
addition to the minor and moderate beneficial impacts discussed in the
Environmentally Preferred Alternative section above, there would also be
potentially minor beneficial and negligible adverse impacts to air
quality. Reuse of historic districts can replace sprawl development,
preventing pollution from motor vehicles. However, short duration of
high levels of pollution emitted from touring of classic cars with old
or non-existent emission controls could adversely affect very sensitive
people. The other impacts were rated either negligible or not foreseen.

***The degree to which the proposed action affects public health or
safety.*** There are no known health and safety issues that would result
from this conceptual proposal.

***Unique characteristics of the geographic area such as proximity to
historic or cultural resources, park lands, prime farmland, wetlands,
wild and scenic rivers, or ecologically critical areas.*** If
implemented, the preferred alternative would have both beneficial
moderate, minor, and negligible impacts on these elements of the Lincoln
Highway corridor. None of these impacts are considered significant.

***The degree to which the effects on the quality of the human
environment are likely to be highly controversial.*** The public
responses to this study focused more on the way in which the Lincoln
Highway would be managed (for example, who would be involved and what
kind of attention would be brought to the Lincoln Highway) than on the
effects on the quality of the environment the management alternatives
would have. Those who did comment on environmental impacts mentioned
strong support for preservation of historic resources. Preservation was
a key objective of the study. Of all of the alternatives analyzed, the
preferred alternative would best preserve historic resources. Therefore,
the preferred alternative addresses these commenters' concerns. The
effects the preferred alternative, if implemented, would have on the
quality of the human environment are not highly controversial.

***The degree to which the possible effects on the quality of the human
environment are highly uncertain or involve unique or unknown risks.***
There were no highly uncertain or unique or unknown risks identified.

***The degree to which the action may establish a precedent for future
actions with significant effects or represents a decision in principle
about a future consideration.*** The proposal is modeled after the
current NPS-managed program to preserve and interpret Route 66, which
was legislated in January of 1999 (P.L. #106-45). This proposal builds
on the Route 66 program to add successful elements of both National
Heritage Area programs (for example, management by a non-profit entity,
with NPS technical assistance) and other federal programs (for example,
the National Scenic Byways and National Register of Historic Places
programs). The preferred alternative, if implemented would not establish
a precedent for future action with significant effects or represent a
decision in principle about a future consideration.

***Whether the action is related to other actions with individually
insignificant but cumulatively significant impacts***. Because the same
qualities that lend historic roads integrity, such as narrow alignments
and older, less smooth surfaces, can pose safety concerns with the speed
demands of today's drivers, the integrity of these roads is frequently
eroded as part of road improvement projects. Of the roughly 5,000 miles
that comprise routes of the Lincoln Highway, the reconnaissance survey
conducted for this project found that less than 500 miles of the roadway
itself retains integrity. While the survey located about 1,000 buildings
contributing to the highway's significance with integrity, at least 60
of these buildings appear to be abandoned or neglected. It is likely
that these 60, without further attention, will cease to retain
integrity. Some Lincoln Highway resources benefit from public
preservation and interpretation programs (for example, scenic byway
programs, state heritage corridors, and transportation enhancement
funding). Similarly, some private organizations (notably, the Lincoln
Highway Association) exist to draw attention to the highway. However,
there is no concerted effort to link these programs to preserve,
interpret, and commemorate the Lincoln Highway on a national scale. The
preferred alternative, if implemented, would coordinate these programs
and, in doing so, lend preservation support to cultural resources
contributing to the significance of the Lincoln Highway. While the
preferred alternative would not have a cumulatively significant impact
on the resource, it would lend support to unify the effort to prevent
further loss.

***Degree to which the action may adversely affect districts, sites,
highways, structures, or objects listed on the National Register of
Historic Places or may cause loss or destruction of significant
scientific, cultural, or historical resources.*** One hundred and thirty
seven properties associated with the Lincoln Highway's significance are
listed in the National Register of Historic Places (either individually
or within the boundaries of a listed district). The preferred
alternative, if implemented, would lend support to the preservation of
these resources. State and Tribal Historic Preservation Officers were
consulted about this study and provided valuable information and
support. The alternative would not cause loss or destruction of
scientific, cultural or historical resources.

***Degree to which the action may adversely affect an endangered or
threatened species or its critical habitat.*** There are no foreseen
impacts to endangered or threatened species or critical habitat that
would result from the preferred alternative as it is conceptual and no
site specific projects are described. NEPA compliance would need to be
revisited and the US Fish and Wildlife Service consulted on a
project-by-project basis if the preferred alternative were implemented.

***Whether or not the action threatens a violation of Federal, state, or
local environmental protection law.*** This action violates no federal,
state, or local environmental protection laws.

**[Public Involvement]{.underline}**

Public scoping for this study began in fall 2001. Scoping letters were
sent to members of Congress and the Senate in each Congressional
district crossed by the Lincoln Highway, State Historic Preservation
Offices and Departments of Transportation in the 14 states through which
the highway passes, tribes with traditional connection to land in the
Lincoln Highway corridor and to representatives of the Certified Local
Governments overseeing historic preservation efforts in towns and
counties along the highway. A scoping newsletter was produced in
December 2001, with scoping comments requested by mid-February 2002. The
membership of the Lincoln Highway Association and others interested in
historic road preservation were sent copies of this scoping newsletter.
Press releases were also sent to newsletters in communities along the
Lincoln Highway, resulting in a number of articles on the project. A
comprehensive study website was produced through which the public could
submit comments.

Public scoping helped the study team craft five preliminary
alternatives, which were presented at fourteen public meetings held
across the country at 300-500 mile intervals along the highway. Again,
press releases were issued to help publicize these meetings.
Partnerships with local historic preservation and economic development
offices as well as state chapters of the Lincoln Highway Association
were formed to collaborate on arranging and announcing them. The
meetings were attended by approximately 500 people. The preliminary
alternatives were revised by the team in response to public comment
raised both at these meetings and in writing, resulting in four final
alternatives.

The final study was mailed out in mid-June 2004. The mailing list for
the final study, numbering about 500, included those who had requested
it in response to a postcard mailing a few months earlier. Comments were
due August 13, 2004. This comment period was longer than the 30-day
review period required for an EA to allow those who might be away from
home for an extended period of time during the summer months to comment.
Within this extended period, 21 comments were received. Two more
comments were received late, for a total of 23 comments. Most of these
comments were received from non-profit historic preservation agencies
and members of the general public. One tribe and two state historic
preservation offices submitted non-substantive comments. In general,
comments corrected minor errors in the document and were supportive of
the study's conclusions. There were three substantive comments: the
first challenged the decision not to recommend the Lincoln Highway as a
National Historic Trail, the second asserted that the historic
significance of the highway was understated, and the third questioned
the mapping of the highway. All comments, whether substantive or not,
were acknowledged and considered. However, the recommended alternative
did not change as a result of the comments. A Response to Comments
document was produced for distribution with the final study to respond
to all three substantive comments, as well as to some of the
non-substantive comments in order to clarify points made in the study.
An errata sheet correcting minor factual errors in the study was also
produced for distribution with the final study. Both of these documents
are attached to this FONSI.

**[Conclusion]{.underline}**

This study constitutes the findings required pursuant to the Lincoln
Highway Study Act (P.L. 106-563). Congressional action would be required
to implement the preferred alternative. NPS guidance requires a Special
Resource Study to be accompanied by an Environmental Impact Statement
(EIS) if the resource meets the criteria for inclusion in the National
Park System and if one of the alternatives being considered is
designation as a National Park System unit. Because both of these were
possibilities when this study process started, the original intent was
to issue an EIS. However, the study concluded that the resource does not
meet the criteria for inclusion in the National Park System and,
therefore, did not include designation as a unit as an alternative.
Additionally, should the preferred alternative be implemented, there
would be no significant impacts for the reasons stated here. Therefore,
it has been determined that an EIS is not required for this study.
Implementation of the preferred alternative would not constitute an
impairment of the critical resources and values of any unit of the
National Park System. Since specific projects were not proposed and
specific sites were not selected as part of this study, impacts were
assessed only on a programmatic level. The need for NEPA compliance
would need to be revisited on a project-by-project basis if the
preferred alternative were implemented.

Recommended

[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*signed
1/10/05*\_\_\_\_\_\_]{.underline}

Alan M. Hutchings Date

Midwest Associate Regional Director

Professional Services and Legislation

Approved

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*[signed
1/14/05\_\_\_\_\_]{.underline}*

Ernest Quintana Date

Midwest Regional Director

*[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_signed
1/18/05]{.underline}*

Marie Rust Date

Northeast Regional Director

*[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_signed
3/3/05]{.underline}*\_\_\_

Stephen P. Martin Date

Intermountain Regional Director

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*[signed
2/4/05]{.underline}*\_\_\_\_

Jonathan B. Jarvis Date

Pacific West Regional Director