1 Zoo to Paoli Electrification Transmission Line MOA

MEMORANDUM OF AGREEMENT

AMONG

THE FEDERAL RAILROAD ADMINISTRATION,

THE NATIONAL RAILROAD PASSENGER CORPORATION,

THE RAILROAD MUSEUM OF PENNSYLVANIA, SOUTHEASTERN PENNSYLVANIA 

TRANSPORTATION AUTHORITY, AND THE

PENNSYLVANIA STATE HISTORIC PRESERVATION OFFICE

REGARDING THE AMTRAK ZOO TO PAOLI ELECTRIFICATION

TRANSMISSION LINE PROJECT

IN PHILADELPHIA, MONTGOMERY, DELAWARE, AND

CHESTER COUNTIES, PENNSYLVANIA

WHEREAS, the National Railroad Passenger Corporation (Amtrak) proposes the Amtrak 

Zoo to Paoli Electrification Transmission Line Project (Project) to modernize and upgrade the 

electrification system on a 20-mile section of Amtrak’s Keystone Corridor between the Philadelphia 

Zoo Substation (Zoo Substation) in Philadelphia and the Paoli Substation in Paoli, extending through 

portions of Philadelphia, Montgomery, Delaware, and Chester Counties, Pennsylvania; and

WHEREAS, Amtrak has determined that implementation of the Project requires upgrades or 

replacement of the 80- to-100-year-old system elements with approximately 325 new catenary 

structures, transmission lines, signal power lines, and replacement of the existing 100-year-old Bryn 

Mawr Substation; and

WHEREAS, the Federal Railroad Administration (FRA) provided funding for design and 

review of the Project pursuant to the National Environmental Policy Act (42 U.S.C. § 4321 et. seq.)

(NEPA), and anticipates providing financial assistance for construction of the Project; and

WHEREAS the Project would be an “Undertaking” under Section 106 of the National

Historic Preservation Act, as amended (54 U.S.C. § 306108) (Section 106) if FRA provides 

financial assistance for construction of the Project; and

WHEREAS, FRA, and Amtrak on behalf of FRA, has consulted with the Pennsylvania 

Historical and Museum Commission, which acts as the State Historic Preservation Office (PA 

SHPO), pursuant to authority provided by the Advisory Council on Historic Preservation (ACHP) 

regulations implementing Section 106 (36 CFR Part 800), including participating in the consultation

process; and

WHEREAS, in a letter dated February 9, 2012, FRA and Amtrak invited 41 organizations,

institutions, governmental agencies, elected officials, and individuals to participate as Consulting

Parties for the purposes of Section 106, including the resolution of adverse effects of the Project, and

the following Consulting Parties actively participated in consultation:

Preservation Alliance for Greater Philadelphia

Delaware Valley Association of Rail Passengers, Inc.

Haverford Township Historical Commission

Lower Merion Township Historic Architectural Review Board

Radnor Township Historic Architectural Review Board

National Railway Historical Society, Philadelphia Chapter, Inc.

Haverford Station Historic District Neighborhood Coalition 

Railroad Museum of Pennsylvania; and 
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WHEREAS, in a letter dated August 26, 2015, FRA invited potentially interested Native 

American Tribes to consult and sought comments from the following Tribes for the purposes of 

complying with Section 106 and the requirements of government-to-government consultation:

Absentee-Shawnee Tribe of Oklahoma; Delaware Nation; Delaware Tribe of Indians; Eastern 

Shawnee Tribe of Oklahoma; Onondaga Nation; St. Regis Mohawk Tribe; Shawnee Tribe; and the 

Stockbridge-Munsee Band of the Mohican Nation of Wisconsin; and only the Delaware Tribe 

provided comments; and

WHEREAS, the Railroad Museum of Pennsylvania (RRMPA) and Southeastern 

Pennsylvania Transportation Authority (SEPTA), the latter of which is the lessee of the Bryn Mawr 

Station from Amtrak pursuant to that certain Lease Agreement between National Railroad Passenger 

Corporation and Southeastern Pennsylvania Transportation Authority dated January 1, 1987, as 

amended, participated in the consultation and have been invited to be Signatories to this 

Memorandum of Agreement (MOA) because they will be responsible for executing portions of the 

mitigation stipulations herein; and FRA, Amtrak, and PA SHPO are also Signatories to this MOA;

and

WHEREAS,FRA is the lead federal agency for the Project under NEPA and is preparing an 

Environmental Assessment for the Project, and under 36 C.F.R. § 800.8 FRA has coordinated the 

Section 106 and NEPA processes; and

WHEREAS, FRA and Amtrak have established the Area of Potential Effects (APE), as 

defined in 36 CFR § 800.16(d), to include the segment of the right-of-way (roughly 100 feet in 

width) from its point of departure from Amtrak’s Zoo Substation in Philadelphia, Pennsylvania, to 

Paoli Substation, in Paoli (Tredyffrin and Willistown Townships), Pennsylvania, for a distance of 

approximately 20 miles, as described and shown in the report entitled Historic Resources 

Study/Determination of Eligibility, Zoo to Paoli Electrification Transmission Line Project, Chester, 

Delaware, Montgomery, and Philadelphia Counties, Pennsylvania, E.R. #2012-0005-42 dated 

February 2015, and PA SHPO concurred with Amtrak’s efforts to identify historic properties within 

this APE on April 24, 2015; and

WHEREAS, FRA and Amtrak have identified 27 historic properties in the APE, and the PA 

SHPO concurred with this identification on March 16, 2015, and April 24, 2015; and

WHEREAS, one of the identified historic properties in the APE is the Pennsylvania Railroad

Main Line (Philadelphia to Harrisburg) (Key No. 105675), which was determined eligible for listing 

in the National Register of Historic Places (NRHP) by the PA SHPO on September 14, 1993, and 

again on November 16, 2007; and

WHEREAS, the existing catenary structures and the Bryn Mawr Substation building are 

Contributing Resources to the NRHP-eligible Pennsylvania Railroad Main Line (Philadelphia to 

Harrisburg); and

WHEREAS, through consultation, FRA determined that the Project will have an Adverse 

Effect on one historic property within the APE, namely, the Pennsylvania Railroad Main Line 

(Philadelphia to Harrisburg), because of the removal of the existing catenary structures and the Bryn 

Mawr Substation building, as discussed in the Determination of Effects Report, dated August 2015; 

and the same report describes the no adverse and no effect findings regarding other historic 

properties in the APE; and the PA SHPO concurred with these findings on October 8, 2015; and

WHEREAS, through consultation, FRA determined that revisions to the design of certain 
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catenary structures associated with the Project would have no additional adverse effects on historic 

properties, as discussed in an Addendum to the Determination of Effects Report, dated June 2016, 

and the PA SHPO concurred with this finding on July 19, 2016; and

WHEREAS, FRA and Amtrak have explored options to avoid the adverse effect to the 

Pennsylvania Railroad Main Line and concluded that such options are not practicable, as discussed 

in the August 2015 Determination of Effects Report; and

WHEREAS, all actions necessary to implement the Project will occur in areas disturbed by 

previous construction, as documented in the Phase IA Geomorphology/Archaeology Reconnaissance 

Survey Report dated December 2012 and in a subsequent letter to PA SHPO dated December 22, 

2015; and FRA determined and PA SHPO concurred on January 25, 2013 and January 7, 2016, 

respectively, that no archaeological investigations are necessary for the Project; and

WHEREAS, FRA and Amtrak conducted public involvement meetings from 2012 through 

2015, which included meetings with public officials, general public meetings, and meetings with the 

Section 106 Consulting Parties; and

WHEREAS, FRA received a request for additional information from the Delaware Tribe of 

Indians in a letter dated October 2, 2015 and FRA submitted the requested information on December 

22, 2015, which included a copy of the Phase IA Geomorphology/Archaeology Reconnaissance 

Survey Report, the Unanticipated Discoveries Plan, and mapping showing the proposed footprint 

and construction entrance at the Bryn Mawr Substation; and no other tribes provided comments or 

requested additional information regarding the Project; and

WHEREAS, on June 21, 2016 FRA notified the ACHP of the determination of adverse effect

in accordance with 36 CFR § 800.6(a)(l), and in a letter dated June 27, 2016, the ACHP declined to

participate in the consultation process;

NOW, THEREFORE, FRA, Amtrak, RRMPA, PA SHPO, and SEPTA, only to the extent 

these stipulations are applicable to SEPTA, (each, a Signatory and together the Signatories) agree

that the Project, if it becomes an Undertaking, will be implemented in accordance with the following

stipulations in order to minimize impacts and mitigate adverse effects on historic properties, and that

these stipulations will govern the Undertaking and all of its parts until this MOA expires or it is

terminated.

STIPULATIONS

FRA will ensure that the following measures are carried out:

I. Applicability 

A. This MOA would apply to FRA’s Undertaking and would only bind FRA if FRA 

provides financial assistance for the construction of the Project.

B. This MOA may apply should another Federal agency have an Undertaking as part 

of the Project; that agency may agree to comply with the terms of this MOA and 

become a Signatory to fulfill its Section 106 responsibilities as provided for in 

Stipulation V.E.
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II. Professional Qualification Standards

Amtrak will ensure that all historic preservation and documentation work carried out

pursuant to this MOA will be done by or under the direct supervision of a qualified 

professional or qualified professionals in the discipline of architectural history who meet[s] 

the relevant standards outlined in the Secretary of the Interior's Professional Qualification 

Standards for Architectural Historians (48 FR 44738-9).

III. Minimization Measures

A. As a result of consultation, Amtrak has decreased the proposed catenary structure 

heights to the extent feasible without adversely impacting railroad safety and 

operations.

B. Amtrak commits to a tree trimming program to facilitate Project construction in lieu 

of removing multiple trees. Selected trees may be removed within Amtrak’s right-ofway. Trimming will adhere to the program outlined in tree trimming plans dated 

March 17, 2016, and appended to this MOA as Attachment 1.

C. Amtrak commits to the placement of new catenary structures as near as practicable

to the existing structures, and that existing catenary structures will be removed, to 

minimize visual effects. 

D. Amtrak commits to avoiding physical impacts to the following historic train stations 

located along the Project corridor: Overbrook, Merion, Wynnewood, Haverford, 

Villanova, Radnor, Wayne, and Stafford.

IV. Mitigation Measures

A. Documentation

1. Amtrak will record the existing Bryn Mawr Substation and related catenary 

system to Historic American Engineering Record (HAER) Documentation 

Level II, as outlined in the publication, Secretary of the Interior’s Standards 

and Guidelines for Architectural and Engineering Documentation: 

HABS/HAER Standards, available at 

http://www.nps.gov/hdp/standards/standards.pdf. Documentation Level II

includes a narrative with the history and description of the resource, archival 

photographs, and copies of selected existing historic drawings. Amtrak’s

current existing conditions drawings may be supplemented with new 

measured drawings, to the extent that it is necessary to sufficiently document 

the resources. The documentation will describe the design of the existing Bryn 

Mawr Substation as well as the design of the catenary system in the Project 

APE, including all four types of catenary structures present along the railroad 

right-of-way. Amtrak will consult with PA SHPO to determine the extent of 

the documentation (e.g., format and length of narrative, quantity of 
5 Zoo to Paoli Electrification Transmission Line MOA

photographs, and extent of documentation using historic or new measured 

drawings) prior to beginning the work. Prior to beginning field 

documentation, Amtrak will consult with RRMPA to use its collections and 

expertise as described in Stipulation IV.A.2. Amtrak will provide the draft 

documentation to PA SHPO for review and comment as described in

Stipulation V.B. Amtrak will complete the agreed-upon photographic 

documentation prior to beginning demolition activities. Amtrak will deposit 

the final documentation of the existing Bryn Mawr Substation and related 

catenary system at RRMPA, the State Museum of Pennsylvania, and the 

Lower Merion Historical Society. 

2. RRMPA will provide Amtrak with access to its collections and technical 

expertise to inform the content of the documentation effort described in 

Stipulation IV.A.1, including important views or details to capture in 

photographs and drawings. RRMPA may, at its discretion, provide historic 

images or drawings to Amtrak for inclusion in the documentation package.

B. Interpretation

1. Interpretive Signage - Amtrak will provide an interpretive sign inside the Bryn 

Mawr Station building that focuses on the history of the Pennsylvania 

Railroad Main Line, with particular attention to the importance of the 

electrification of the route. Amtrak will submit the draft content of the sign to 

PA SHPO, SEPTA, and Lower Merion Township Historic Architectural 

Review Board for review and comment as described in Stipulation V.B. 

Amtrak will address any comments received as described in Stipulation V.B., 

and circulate the revised draft sign content to the aforementioned parties for 

review and comment. Once the content of the sign is agreed upon and 

finalized, Amtrak will provide it in electronic PDF format to FRA, PA SHPO, 

SEPTA, and Lower Merion Township. Amtrak will install the agreed-upon

sign in the Bryn Mawr Station in a specific location that is agreed upon by 

SEPTA, and Amtrak will be responsible for the maintenance of the sign, and

the replacement or repair of the sign should it be damaged for any reason or 

vandalized after installation for a period of five years after Project 

construction is complete. SEPTA has no responsibility for sign maintenance 

or replacement.

2. Equipment Donation - Amtrak will donate materials and elements of the 

catenary system that Amtrak or its contractors remove from the existing Bryn 

Mawr Substation to RRMPA for use in their upcoming new exhibits about the 

history of railroad electrification or for other exhibits, or to achieve other 

preservation purposes, as RRMPA may determine at its discretion. To the 

extent available, and at its discretion, Amtrak may also donate other materials, 

such as a pantograph, hangers, insulators, signage, and digital photographs for 

use in RRMPA exhibits. Acceptance of materials will be at the discretion of 

the RRMPA. RRMPA will appropriately credit all photographs and other 
6 Zoo to Paoli Electrification Transmission Line MOA

donations provided by Amtrak. The donation of documents, photographs, and 

other corporate records will be governed by Amtrak’s Records Management 

and other applicable policies. Amtrak will accompany RRMPA staff on a tour 

of the existing Bryn Mawr Substation prior to demolition so that RRMPA can 

identify materials it would like to receive as donations. Amtrak will make 

items available and RRMPA will retrieve them from the existing Bryn Mawr 

Substation property at its own expense. Because the construction schedule 

for the Project is uncertain, Amtrak will work with RRMPA and FRA to 

coordinate the timing of Project activities and donations for exhibits to the 

extent possible. All donated materials will be provided to RRMPA on an “asis, where-is” basis. Prior to removal of any materials, RRMPA will provide 

Amtrak with a full release from all claims, suits, damages, costs, etc. for the 

donated materials.

3. Conservation Allowance - Once the nature and extent of donated materials is 

determined as set forth in Stipulation IV.B.2 above, FRA, Amtrak, RRMPA, 

and PA SHPO will consult to determine an appropriate one-time financial 

contribution from Amtrak to RRMPA dedicated to the conservation of 

donated materials. 

4. Oral History Opportunity - Amtrak will make reasonable efforts to identify 

and provide to RRMPA contact information for current or former Amtrak 

Electric Traction Department employees who are willing to participate in oral 

history interviews. RRMPA will provide to Amtrak a description of the oral 

history process and proposed discussion topics for Amtrak to share with 

potential interviewees so that they can make an informed decision about their 

participation in an interview. Amtrak does not guarantee the participation of 

any current or former employee in the interviews. Amtrak retains the right to 

screen contents of the interviews intended for public access to ensure that 

sensitive security and operations information is not shared with the public. 

RRMPA will deposit transcripts and other relevant documentation of the 

interviews, subject to Amtrak security approval, at RRMPA, the PA State 

Archives, and Amtrak.

C. Design 

1. Amtrak will replace the existing Bryn Mawr Substation building with two 

new substation buildings. Amtrak will design the exterior of these two new 

buildings with buff brick walls consistent with the brick of the existing Bryn 

Mawr Substation building. The design will be consistent with the materials, 

color, and texture of the existing Bryn Mawr Substation building, but will not 

mimic the historic building to make it clear that the new buildings are nonhistoric and do not create a false sense of history. Amtrak will submit the 

proposed design to PA SHPO for review and comment as described in

Stipulation V.B. Design documents will be shared at 30%, 60%, and 90% 

design. 
7 Zoo to Paoli Electrification Transmission Line MOA

2. Amtrak will incorporate the “Bryn Mawr Substation” sign currently on the 

existing Bryn Mawr Substation building into a new retaining wall or other 

landscape feature adjacent to the new Bryn Mawr Substation site. Amtrak will 

submit its proposed conceptual design to PA SHPO and the Lower Merion 

Township Historic Architectural Review Board for review and comment, and 

Amtrak will address any comments received, as described in Stipulation V.B.

3. Amtrak will offer the bricks from the existing Bryn Mawr Substation building 

for salvage upon removal of the building. Amtrak will notify Consulting 

Parties and the public when the bricks will be available and will take requests 

for the materials. Amtrak will not deliver the brick, but will make it available 

for pick-up for a specified, reasonable period of time. Amtrak cannot 

guarantee the amount or number of salvageable bricks. Amtrak will provide 

all materials for salvage on an “as-is, where-is” basis, and will make no 

warranty as to condition, suitability, serviceability, or degree of 

contamination for any intended subsequent use. Amtrak will prepare and 

deliver a written receipt to that effect to every recipient for their review and 

signature, and the receipts will become a part of the official Project record. 

Recipients will sign a release indemnifying Amtrak and Signatories of this 

Agreement against any and all claims arising from the acquisition and use of 

salvaged materials. At the end of the retention period, Amtrak may sell or 

dispose of the remaining unused materials in accordance with applicable 

statutes and regulations.

V. General Provisions

A. Effective Date

This MOA will be effective as of the date of obligation of Federal financial assistance 

to construct the improvements and upgrades required for the Project following 

execution of this MOA by all Signatories.

B. Document Review

Unless otherwise stated in the stipulations, the Signatories and Consulting Parties, 

where applicable, will provide comments on the documents they review as set forth 

below:

1. The Signatories and Consulting Parties specified in each item under 

Stipulation IV above will have up to thirty (30) calendar days from the date 

of receipt to review and provide written comments to Amtrak on documents 

stipulated in this MOA.

2. Amtrak will ensure any written comments received within the timeframe are 

considered and incorporated, as appropriate, into the documentation.

3. If the specified Signatories and Consulting Parties do not submit written 

comments to Amtrak within thirty (30) calendar days of receipt of any 

document, it is understood the non-responding parties have no comments on 

the submittal.
8 Zoo to Paoli Electrification Transmission Line MOA

4. If the Signatories and Consulting Parties object to or recommend extensive 

revisions to submissions stipulated in the MOA, Amtrak will work 

expeditiously to respond to the recommendations and resolve disputes.

5. If Amtrak cannot resolve a dispute, and if further consultation is deemed 

unproductive by any party, the parties will adhere to the dispute resolution 

procedures detailed under Stipulation V.G. 

6. The Signatories and Consulting Parties acknowledge the timeframes set forth 

in this MOA will be the maximum allowed under normal circumstances. In 

exigent circumstances (e.g., concerns over construction suspensions or 

delays), all parties agree to expedite their respective document review and 

dispute resolution obligations.

C. Project Changes

If Amtrak proposes changes to the Project that may result in additional or new effects 

on historic properties, Amtrak will notify FRA and the PA SHPO of such changes. 

Before Amtrak takes any action that may result in additional or new effects on historic 

properties, Amtrak, FRA and PA SHPO will consult to determine the appropriate 

course of action. 

D. Amendment

Any Signatory to this MOA may request that it be amended. The amendment will 

be effective on the date a copy signed by all of the Signatories is filed with the ACHP.

E. Use of this MOA by Other Federal Agencies

In the event that a Federal agency other than FRA is considering financial assistance, 

permits, licenses, or approvals for the Project, such Federal agency may become a 

Signatory to this MOA as a means of complying with Section 106. To become a 

Signatory to this MOA, the agency official must provide written notice to the 

Signatories that the agency agrees to the terms of the MOA, specifying the extent of 

the agency’s intent to participate in the MOA, and identifying the lead Federal agency 

for the Undertaking. The participation of the agency is subject to approval by the 

Signatories, who must respond to the written notice within 30 days or the approval 

will be considered implicit. Any other modifications to the MOA will be considered 

in accordance with Stipulation V.D.

F. Termination

If any Signatory to this MOA determines that its terms will not or cannot be carried 

out, that Signatory will immediately consult with the other Signatories to attempt to 

develop an Amendment per Stipulation V.D. If within thirty (30) days (or another 

time period agreed to by all Signatories) an amendment cannot be reached, any 

Signatory may terminate the MOA upon written notification to the other 

Signatories.
9 Zoo to Paoli Electrification Transmission Line MOA

Once the MOA is terminated, and prior to work continuing or initiating on the 

Undertaking, FRA must either (a) execute an MOA pursuant to 36 CFR § 800.6 or 

(b) request, take into account, and respond to the comments of the ACHP under 36 

CFR § 800.7. FRA will notify the Signatories as to the course of action it will 

pursue.

G. Dispute Resolution

Should any Signatory to this MOA object at any time to any actions proposed or the 

manner in which the terms of this MOA are implemented by providing written notice 

of such objection to FRA, FRA will consult with the Signatory to resolve the 

objection. If FRA determines that the objection cannot be resolved, FRA will: 

1. Forward all documentation relevant to the dispute, including the FRA’s 

proposed resolution, to the ACHP and request that the ACHP provide FRA 

with its advice on the resolution of the objection within thirty (30) calendar 

days of receiving the documentation. FRA will prepare a written response to 

the objection, which will constitute the FRA’s decision regarding the 

objection, that takes into account any timely advice or comments regarding 

the dispute from the ACHP and the Signatories and provide the ACHP and

Signatories with a copy of this written response. FRA will then proceed 

according to its decision. 

2. If the ACHP does not provide its advice regarding the dispute within the thirty 

(30) calendar day time period, FRA may make a decision on the dispute and 

proceed accordingly. FRA will document this decision in a written response 

to the objection that takes into account any timely comments regarding the 

dispute from the Signatories and provide the ACHP and Signatories with a 

copy of such written response. 

3. The Signatories remain responsible for carrying out all other actions subject 

to the terms of this MOA that are not the subject of the dispute.

H. Duration

This MOA will be valid for five (5) years following the Effective Date, or when the

Signatories have agreed to terminate the MOA, whichever comes first. If the terms

of this MOA have not been implemented within five years of its Effective Date, this

MOA will be considered null and void. In such event, FRA or Amtrak will notify the

other Signatories to this Agreement, and if FRA chooses to continue with the

Undertaking, will reinitiate review ofthe Undertaking in accordance with 36CFR Part 

800. Prior to such time, FRA may consult with the other Signatories to reconsider the 

terms of the MOA and amend it in accordance with Stipulation V.D above.

I. Monitoring and Reporting

Each year following the Effective Date of this MOA until it expires or is terminated, 
10 Zoo to Paoli Electrification Transmission Line MOA

Amtrak will provide all Signatories to this MOA a summary report detailing work 

undertaken pursuant to its terms. Such report will include any scheduling changes 

proposed, any problems encountered, and any disputes and objections received in 

FRA’s efforts to carry out the terms of this MOA. 

J. Unanticipated Discoveries Plan

In consultation with FRA, Amtrak has developed an Unanticipated Discoveries Plan

for human and non-human archaeological resources in the event that any

unanticipated archaeological resources are encountered during construction of the

Project. The Unanticipated Discoveries Plan is appended to this MOA as Attachment 

2. In the event of the Unanticipated Discovery of human or non-human

archaeological resources, Amtrak will cease work in the affected area and implement 

the Unanticipated Discoveries Plan. 

EXECUTION of this MOA, and implementation of its terms, evidences that FRA, Amtrak, and 

PA SHPO have taken into account the effects of the Project on historic properties, and that FRA

and Amtrak have satisfied their responsibilities under Section 106 of the Act and implementing

regulations codified in 36 CFR Part 800 with regard to a future Undertaking. 





ATTACHMENT 1:

TREE TRIMMING PLANS
PAOLI STATION

PAOLI

SUBSTATION

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DAYLESFORD

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BERWYN STATION

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DEVON

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STRAFFORD STATION

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ST. DAVIDS STATION

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RADNOR STATION

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VILLANOVA STATION

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ROSEMONT

STATION

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BRYN MAWR

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BRYN MAWR STATION

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ATTACHMENT 2:

UNANTICIPATED DISCOVERIES PLAN
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UNANTICIPATED DISCOVERIES PLAN

AMTRAK’S PHILADELPHIA ZOO SUBSTATION TO PAOLI 

SUBSTATION ON THE PENNSYLVANIA MAIN LINE RAILROAD 

ELECTRIFICATION TRANSMISSION LINE PROJECT

Chester, Delaware, Montgomery, and Philadelphia Counties,

Pennsylvania

National Railroad Passenger Corporation (Amtrak)

60 Massachusetts Avenue, N.E.

Washington, D.C. 20002

PART 1 - GENERAL

This document is prepared pursuant to the requirements of a Memorandum of Agreement 

(MOA) among the Federal Railroad Administration (FRA), the Pennsylvania State Historic 

Preservation Office (PA SHPO), the National Railroad Passenger Corporation (Amtrak), the 

Southeastern Pennsylvania Transportation Authority (SEPTA), and the Railroad Museum of 

Pennsylvania (RRMPA).

This document provides the procedure to be followed in the event human or non-human 

archaeological resources are encountered during construction of the project.

This document pertains to the work of the Contractor, the Contractor’s subcontractors, the 

Contractor’s material suppliers, the Contractor’s equipment suppliers, and all individuals and 

companies associated with the Contractor’s performance of the project (hereafter collectively 

referred to as Contractor). Contacts for Amtrak, the Contractor, and other appropriate parties will 

be provided prior to construction.

This document shall remain in force until the formal completion of the project, or the termination 

of the MOA, whichever comes first.

PART 2 – IDENTIFICATION OF RESOURCES

The following are considered examples of potential archaeological resources to be included in 

this Unanticipated Discoveries Plan (Plan):

- Human skeletal remains, including individual bones, groups of bones, bone fragments,

dental fragments, etc.

- Articles of clothing, including cloth, leather, shoe leather, buckles, buttons, etc.

- Personal items, including rings, jewelry, beads, toys, coins, gun parts, funerary items, etc.

- Household and kitchen items, including intact or broken pieces of ceramics, glass and 

metal containers, cutlery, butchered bones and oyster shells, tobacco pipe remnants, etc.
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- Architectural items, including window glass, nails, bricks, shaped building stones, etc.

- Possible prehistoric objects, including chipped stone tools (i.e, projectile points, drills, 

etc.), ceramics, groundstone, lithic debitage, animal bone, personal adornment items, etc.

- Areas of darkened soil that suggest possible cultural features, such as firepits, garbage 

pits, privies, foundations, postholes, etc.

- Unusual objects not identified herein that suggest human occupation.

It is possible any combination of these resources may be found during earthwork operations at 

locations where drilling occurs for pole footings, temporary fences, gates, signs and other 

appurtenances, and at locations where soil is disturbed, removed, relocated, or displaced along 

the right-of-way, such as at access points, staging areas, and the Bryn Mawr Substation 

construction location. The Contractor’s supervisory personnel present during hours of 

construction should be provided with minimal training in the identification of archaeological 

resources. 

PART 3 – PROCEDURE FOR IDENTIFYING UNANTICIPATED DISCOVERIES

1. If one or more of the potential archaeological resources (listed above) are 

encountered by the Contractor during earthwork operation, stop work in the vicinity 

of the resource immediately and notify the Amtrak Project Manager (to be named 

prior to construction). Do not resume work in the vicinity of the resource until 

specifically directed by the Amtrak Project Manager. The Contractor will ensure that 

any discoveries are protected from destruction, looting, and vandalism during stopwork episodes while a determination is made as to the importance of a find.

2. The Amtrak Project Manager will notify the Project’s Environmental Consultant 

(including a Secretary of the Interior [SOI]-qualified archaeologist and the Project 

Manager), who, in consultation with the Amtrak Project Manager, will determine if it 

is necessary to conduct a field visit to inspect the encountered potential 

archaeological resource.

a. Should the Amtrak Project Manager and the Project’s Environmental 

Consultant conclude it is not necessary to investigate the encountered 

potential archaeological resource any further, the Amtrak Project Manager 

will authorize work in the area to resume.

b. Should the Amtrak Project Manager and the Project’s Environmental 

Consultant conclude it is necessary to further investigate the encountered 

potential archaeological resource, the SOI-qualified archaeologist with the 

Project’s Environmental Consultant will conduct a field visit within 24 hours.

3. Should the field visit indicate the encountered materials are not potential

archaeological resources, the Project’s SOI-qualified archaeologist will notify the 

Amtrak Project Manager, who will authorize work in the area to resume.
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4. Should the field visit confirm the encountered materials are potential archaeological 

resources, the Project’s SOI-qualified archaeologist will inform the Amtrak Project 

Manager and then notify:

- the PA SHPO (Douglas McLearen, Chief, Archaeology and Protection, 

Bureau for Historic Preservation at 717.772.0925), and

- FRA (Laura Shick, Federal Preservation Officer at 202.366.0340).

a. FRA will determine if it is appropriate to notify Native American groups to 

invite consultation and review of any discovered potential pre-contact human 

remains. Per PA SHPO guidelines for the treatment of human remains, work 

will stop and the coroner and SHPO will be notified. 

b. FRA, in consultation with Native American tribe(s), will determine the 

appropriate treatment of the discovered potential pre-contact human remains 

and associated funerary objects. The Project’s SOI-qualified archaeologist 

will notify the PA SHPO and Amtrak’s Project Manager of the treatment.

- The treatment of all encountered pre-contact human remains and 

associated funerary objects will be subject to the regulations promulgated 

in the Native American Graves Protection and Repatriation Act 

(NAGPRA), 25 U.S.C. 3001 et.seq.

- The treatment of all encountered archaeological resources will be subject 

to the regulations stipulated in the Guidelines for Archaeological 

Investigations by the PA SHPO.

c. Amtrak’s Project Manager will notify the Contractor of any required 

modifications to the project timetable or aspects of the contract.

d. FRA will notify the Project’s Environmental Consultant when work in the 

area of the potential archaeological resource may resume. The Project’s 

Environmental Consultant will notify the Amtrak Project Manager, who in 

turn will notify the Contractor.

- End of Document -