APPENDIX B4

RESPONSES TO SECTION 106 

CONSULTING PARTY COMMENTS
 B-305 

RESPONSES TO SECTION 106 

CONSULTING PARTY COMMENTS

This Appendix Section B4 provides detailed responses to Section 106 Consulting Party letters, 

presented in the below order: 

 National Trust for Historic Preservation ........................................................................... B-306 

 Civil War Trust ...................................................................................................................... B-313 

 Hanover County Historical Commission .......................................................................... B-315 

 Historic Richmond ................................................................................................................ B-317 

 City of Alexandria – Planning and Zoning ....................................................................... B-324 

Additionally, Appendix E of the Final EIS details the comments and coordination for the Section 

106 process. 

Appendix B4 
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-306 

NATIONAL TRUST FOR HISTORIC PRSubsequent to NTHP’s submittal of commen

November 7, 2017 letter, DRPT met with the meetings as well as corresponded through oadditional data on the Preferred Alternaproperties, Project effect, and development Memorandum of Agreement (Appendix K of submitted a formal reply letter to the final roseffect on July 20, 2018, and the DRPT seconcerns on September 4, 2018. Additional c

received from the NTHP on December correspondence including letters and minutes Appendix E of the Final EIS. 

1. Alternative 6F (Full Service Staples 

Station) has been selected as the Pref6 through Richmond. As defined in EIS, the Preferred Alternative in Area two stations in Richmond, one serviat Main Street Station and a seRichmond at Staples Mill Road. AMain Street Station will provide cresidential, commercial and recRichmond’s Central Business DistShockoe Bottom. Sections 5.13 andiscusses the potential impacts to regMain Street Station, including the afoShockoe Bottom. Chapter 4.3.6 odescribes the infrastructure improMain Street Station in Area 6. investigation of historic records as consultation with numerous agencieand in comments received from the DRPT has reduced the facilities proMain Street Station to the minimum to deliver the service proposed in thincludes a reduction in the design lethe east and west sides of the statioBroad Street, and to the minimum wthe forecasted level of ridership and station. 

(Responses are continued on next page)
 RESPONSES TO SECTION 106 CONSULTING P

NATIONAL TRUST FOR HISTORIC PR

(continued) 

 The provision of a two-station altern

for a distribution of ridership, parkiamong the stations. Therefore, infrastructure required and potentiaMain Street Station. Additionally, proposed construction of a maintenaat the former CSXT Brown Street Yarat Hospital Street to a site near BRichmond (see Section 4.3 and Appeadditional detail) and removed a mthis area. 

Throughout the Project and as highefforts described above, FRA and sensitivity and cultural significance area. The Project, as currently desigknown boundaries of identified archconsulting party feedback, the LumAcre site and the Graveyard for FSlaves, located north of Shockoe Botthe list of historic properties and impacts. FRA determined, and the Project would have no adverse effecFRA and DRPT recognize that unreclikely exist in the general Project vicmade to minimize the limits of distuthe high probability for such unrevaluations of historic properties associated with the antebellum oincluding the slave trade, are being apostbellum sites, buildings, and diThis includes sites 44HE1095, 44HE1of the century warehouses). DRPT conducting full archaeological studiany area where disturbance cannot three above-ground historic propertProject: the Shockoe Valley and TobaMain Street Station, and the Seaboar

(Responses are continued on next page)
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-308 

NATIONAL TRUST FOR HISTORIC PR

(continued) 

Although the Project will result resources, the use of the area and stais consistent with the use of the existrail facilities at this location, thus historic context in the area. Section provides an expanded discussion of Shockoe Bottom area, including comthe Draft EIS related to historic consummary of previous cultural studwork to-date including ongoing worDraft EIS, the avoidance analysis, anRegarding archaeological study odisturbance, however, DRPT haextensively with DHR and ACHP, athat preservation in place is the priora destructive science. As such, generto avoid archaeological deposits wProject implementation, and areas disturbance will not be the subject opart of the identification and evalua106 Draft Memorandum of AgreeAppendix K of the Final EIS, outlininadverse effects, has been developed consulting parties, property ownerand include a roster of tasks to be coaffected resources, such as public research, National Register documdata recovery, and more. This incluShockoe Valley and Tobacco Row Hassociated with the slave trade that to this district, including Lumpkins J
 RESPONSES TO SECTION 106 CONSULTING P

NATIONAL TRUST FOR HISTORIC PR

(continued) 

(Response to comment 1 on pages B-306 thro2. DRPT concurs with the Nation

Preservation’s comment and, as meresponse #1, preservation in placparamount. These resources will be 

construction. 

3. Final EIS Section 5.20 addresses 

impacts, including potential impacfrom the Preferred Alternative. Data consulting parties via email and 

Appendix E of the Final EIS). Basefrom the National Trust and similaexpanded discussion of potential effects on historic resources in ShockSection 3.1 of the Final EIS. 
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-310 

NATIONAL TRUST FOR HISTORIC PR

(continued) 

(Response to comment 3 on previous page) 4. An expanded discussion of poten

Bottom historic properties is includFinal EIS, including an evaluation constructive use under Section 4(f). 

5. DRPT conducted additional review 

area to ensure that the history is knoweffect determinations; as stated Expanded discussion of the Main Bottom area, including details on conducted to date is presented in Faddition, an examination on 4(f) use Chapter 6.5 through 6.7. There aassociated with the DC2RVA PrEvaluation. 
 RESPONSES TO SECTION 106 CONSULTING P

NATIONAL TRUST FOR HISTORIC PR

(continued) 

(Response to comment 5 on previous page) 
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-312 

NATIONAL TRUST FOR HISTORIC PR

(continued) 

(No comments on this page) 
 RESPONSES TO SECTION 106 CONSULTING P

CIVIL WAR TRUS

T

1. DRPT confirms that by selecting a P

generally remains within the existhrough Central Virginia, the Project the character-defining features of thand contributing elements specifical
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-314 

CIVIL WAR TRUST (continued) 

2. DRPT is committed to an open and c

consulting parties, including the American Battlefield Protection ProgWar Trust, during the entire Projefinal design, after incremental imprand funding is established. Modificaproperties and effect determinations upon receipt, followed by additionaon the ensuing results. 

3. DRPT will continue its ongoing dial

parties, including the ABPP anSpotsylvania National Military Park all historic properties are thoroughly design in a manner consistent wiSection 106 of the National Historimeeting with DRPT on Februardetermined that KOCOA analysis is Project Section 106 effects. 
 RESPONSES TO SECTION 106 CONSULTING P

HANOVER COUNTY HISTORIC

AL CO

1. and 2. DRPT conducted addition

archaeological survey, architectural level architectural study along witresearch and contextual reviews, prion the Commonwealth Trecommendation of the Preferred Althe Final EIS presents the resultant ureports. The additional studies includeterminations for all buildings, disand sites within the Project Area of Pcomplied with Section 106 of Preservation Act and studies werCounty and the Department of HInformation on any resource deemeshared with the Hanover County Hverify that character-defining featurelements were included as applicabAlternative 5A (Maintain Two TracPreferred Alternative in Area 5 thro5A provides the railroad and roadwato support the railroad operations pProject. As presented in Section Alternative 5A is expected to affect zdowntown Ashland, as no additionaconstructed within the Town of ACSXT railroad right-of-way througexception to this includes the constrail grade separations where VaughDrive) and Ashcake Road cross the south. There are no historic propertieffects at the Ashcake Road intersecproperty at the Vaughan Road intersection: the Berkleytown Histodetermined, and the DHR concurredan adverse effect and a Section 4Stipulations to mitigate the adverse Section 106 Draft Memorandum of Athe Final EIS). 

(Responses are continued on next page)
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-316 

HANOVER COUNTY HISTORICAL CO

(continued) 

 Outside of Ashland, there are 

properties within Hanover CountyDistrict and the Doswell Depot andetermined that the Project will havSection 4(f) use of both resources, mitigated through the Section 106 p6 of the Final EIS for details. 

3. All consulting parties to the Section 1

Hanover County Historical Commisinformed of all steps in the cultural stipulations set forth in the Section 1Agreement (Appendix K of the Fimeetings. 
 RESPONSES TO SECTION 106 CONSULTING P

HISTORIC RICHMOND (No comments on this page) 
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-318 

HISTORIC RICHMOND (continued) (No comments on this page) 
 RESPONSES TO SECTION 106 CONSULTING P

HISTORIC RICHMOND (continued) 1. The FRA and DRPT understan

significance of the Shockoe BottoLoving’s Produce Company, which 

to the National Register of HistorShockoe Valley and Tobacco Row HProduce Company was included in studies completed by DRPT prior ttaken into consideration to avoid impacts to the resource. The DHresource is not individually eligible fa contributing element to the surroun6F (Full Service - Staples Mill Road/selected as the Preferred AlternaRichmond. As defined in Section Alternative 6F provides full servRichmond, one serving Downtown Station and a second serving suburMill Road. Chapter 4.3.6 of the infrastructure improvements propStation in Area 6. Through review anrecords, consultation with consulting with a vested interest in area hisreceived from the public and Historeduced the facilities proposed for coStation to the minimum infrastructurservice proposed in the DC2RVA reduction in the design length of the west sides of the station to remain sand to the minimum width feasible level of ridership and services proaddition, a multistory parking deck ehas been removed from the plans. station alternative in Richmond allridership, parking and automobile stations. Therefore, this minimizes thand potential impacts associated wit

(Responses are continued on next page)
TIER II FINAL ENVIRONMEN TAL IMPACT STATEMENT 

B-320 

HISTORIC RICHMOND (continued)  Through these efforts, Project impact

the greatest degree possible. The recorded antebellum resources in the resources will be demolished. There three postbellum above-ground hisValley and Tobacco Row Historic Diand Seaboard Air Line Railroad). Ithe-century eligible archaeological siand 44HE1098) may be impacted bAny historic property that is ad

undertaking will be the subject of mDRPT response to comment #2 below 

2. Resources in Shockoe Bottom, al

Memorial Park area, are discussed in the Draft EIS, and within several techEIS Appendix R (cultural resource teFinal EIS Chapters 5 and 6 and Appenhistoric places are taken into consplanning. Additionally, Section 3.1.4 an expanded discussion of the MaiBottom area, including comments anEIS related to historic context, histoprevious cultural studies, a summincluding ongoing work since the isdescription of the avoidance analysstudies. The Section 106 Draft Mem(Appendix K of the Final EIS) outlininadverse effects to six historic properon studies being completed as recommendation on expansions to trecordation of a new district, wouensuing recommendations for thiRichmond beyond the DC2RVA Precognizes the importance of this areworking with the City to define the b

and to work with local interest grhistory of this area as a stipulation surrounding Shockoe Valley and District. 

(Responses are continued on next page)
 RESPONSES TO SECTION 106 CONSULTING P

HISTORIC RICHMOND (continued) 3. The DC2RVA limits of disturbanc

subject of a Phase IA archaeologpredictive model and Phase IB survepreviously recorded sites and recordarea where ground-disturbing act

predictive model and survey report cR of the Draft EIS. The addendu

report can be found in Appendix D minimized the Project footprint to thboth identified and unknown aincluding Lumpkins Jail/Devil’s HGround, among others, such as elparking deck planned for east of Project, as currently designed, doeboundaries of these sites. At the requLumpkins Jail and the Graveyard for Slaves, located just north of Shockothe list of historic properties in the AFinal EIS), and the FRA determined no adverse effect on these resources. and DRPT fully recognize that unreclikely exist in the general Project committed to conducting full archaarea where disturbance cannot be avrecovery efforts are outlined in the (Appendix K of the Final EIS). Rstudies outside of the limits of disthas discussed the issue extensively DHR has concluded that preservatioas archaeology can be a destructive s

 4. Mitigation for adverse effects to 

Tobacco Row Historic District, as ouDraft MOA (Appendix K of the Final will aid in this process. The Historand the City of Richmond, as consulin developing the Section 106 Draft M

5. Comment noted. DRPT would comp

and codes during final design of the improvements are scheduled and fu

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B-322 

HISTORIC RICHMOND (continued) 6. The resource was preliminarily reco

studies associated with the Project iwas the subject of additional invesaddition, the parcel was studied archaeological remains in 2018. architectural report and archaeologiAppendix D of the Final EIS. Upon determined that this building is not the National Register of Historic Placnot listed as a historic property in thbuilding and its landscape were noprocess, and DRPT removed the neeproperty by eliminating planned conarea; refer to Appendix J of the Fin

revised Richmond area turning wye that is part of the Preferred Altsummarized in Section 4.6 of the Fin
 RESPONSES TO SECTION 106 CONSULTING P

HISTORIC RICHMOND (continued) (Response to comment 6 on previous page) 7. Potential construction elements o

Interchange Improvements and VDresources in Shockoe Valley associatwere taken into consideration background data and to assure consresource evaluations. Chapter 3 of tresults of the background review cProject including details on the Shocstreet improvements as they relate to Additionally, the referenced projecindirect and cumulative effects sepotential impacts on land use and hSection 5.20 of the Final EIS. 
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B-324 

CITY OF ALEXANDRIA, DEPARTMENT 

ZONING 

[Note that while the letter from the City of Planning and Zoning is in reference to Sprovided responses in the same format as comments on the Draft EIS.] 1. DRPT has worked with the City of Ale

referenced in this comment. DRPT rethat all resources over 48 years in age wpotential effects (APE) and shared the ras the Virginia Department of Historincludes additional reconnaissance astudies, additional archaeological woresources as requested by the locality, the East Rosemont Historic District. Ahas copies of all the additional 2018 tanalysis and coordination associated weight historic properties within the Pbeen evaluated and coordinated with RF&P Railroad (adverse effect; use); Highway (no adverse effect; de minimiJunior High School (no effect; no uDistrict/Uptown (no adverse effect; nDistrict (no adverse effect; de minimStation (no adverse effect; de minimis National Masonic Memorial (no effect(no adverse effect, no use). Alexandrwith these determinations in a letter d

2. DRPT agrees that the term “Alexand

its historic name and how it is labelenomination. Draft EIS references to are corrected in the errata table for Appendix A of the Final EIS. 

3. DRPT concurs that the Mount Vern

located in Alexandria in addition tCounties. This change has been madeFinal EIS. 

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 RESPONSES TO SECTION 106 CONSULTING P

CITY OF ALEXANDRIA, DEPARTMENT 

ZONING (continued) 

4. Based on the coordination betwe

Alexandria to clarify this issue, DRPGeorge Washington Junior High submitted to the DHR in time completion of the Final EIS. Based on plans in this area, the FRA has deterProject will have no effect on tconcurred with this determination 2018. 

5. DRPT agrees that the term “Uptow

District” matches its National Rereferences to the “Parker Gray Disterrata table for the Draft EIS, which iEIS. 

6. All consulting parties to the Section 1

City, will continue to be informed steps in the cultural resource procesforth in the Section 106 Draft MemorAppendix K of the Final EIS), or Appendix E of the Final EIS for copiecorrespondence.