APPENDIX E

UPDATED SECTION 106 AND SECTION 4ΈfΉ

COMMENTS & COORDINATION
E-1 

UPDATED SECTION 106 AND SECTION 4(f) 

COMMENTS & COORDINATION

This appendix includes data associated with the coordination of Section 106 of the National 

Historic Preservation Act of 1966 and Section 4(f) of the U.S. Department of Transportation Act 

of 1966 with pertinent federal agencies, state governments, and localities, as well as consulting 

parties and other involved members of the public. Data presented here is reflective of 

coordination efforts that occurred from August 2017, after the publication of the Draft 

Environmental Impact Statement (EIS), through the publication of the Final EIS. For coordination 

that occurred prior to August 2017, see Appendix U of the Draft EIS. 

Section E.1 involves all correspondence associated with Section 106 of the National Historic 

Preservation Act of 1966 and any other cultural resource topics. Cultural resource studies have 

included coordination with agencies since the fall of 2014 to comply with cultural resource and 

environmental legislation. In particular, coordination has involved extensive dialogues with the 

Virginia Department of Historic Resources (DHR, the Virginia State Historic Preservation Office 

[SHPO]), the Advisory Council on Historic Preservation (ACHP), the Virginia Department of Rail 

and Public Transportation (DRPT), the Federal Railroad Administration (FRA), and over 30 

consulting parties spanning the entire corridor. This chapter includes data on correspondence 

with all groups and includes the following documentation in separate PDFs in chronological 

order: 

 Appendix E1: SHPO, ACHP, DRPT, and FRA Meeting Summaries 

 Appendix E2: SHPO Technical Study Correspondence 

 Appendix E3: SHPO Project Effect 

 Appendix E4: SHPO Memorandum of Agreement Correspondence 

 Appendix E5: Consulting Party and Public Invitations, Emails, Letters, and Other 

Correspondence 

 Appendix E6: Consulting Party and Public Meeting Summaries 

Appendix E 
E-2 

Section E.2 includes documentation related to the Section 4(f) process, including parks, 

recreational resources, trails, and wildlife refuges, and historic properties as they relate to Section 

4(f). The following documentation includes separate PDFs in chronological order: 

 Appendix E7: De Minimis Concurrence Letters 

 Appendix E8: Temporary Occupancy Concurrence Letters 

E.1 SECTION 106/OTHER CULTURAL RESOURCE COMMENTS & 

COORDINATION 

DRPT coordinated with numerous federal and state agencies with jurisdiction over resources 

protected under Section 106 and Section 4(f), both before and after the issuance of the Draft EIS 

(see Appendix E1 of the Final EIS). For Section 106, this includes project initiation, definition of 

an area of potential effects (APE), technical studies on above- and below-ground resources (see 

Appendix E2 of this Final EIS for correspondence since the Draft EIS), resource eligibility, 

determinations of effect (see Appendix E3 of the Final EIS), and production of a Section 106 Draft 

Memorandum of Agreement (MOA) to outline measures to mitigate adverse effects, where 

appropriate (see Appendix E4 of the Final EIS for coordination efforts; the Section 106 Draft MOA 

document is Appendix K of the Final EIS). Beyond agencies, extensive coordination with 

consulting parties and others with a vested interest in area history and prehistory has occurred 

since the Project began (see Appendices E5 and E6 of the Final EIS for coordination with 

consulting parties since publication of the Draft EIS). 

For Section 4(f), each historic property—defined as a resource that is eligible for or listed in the 

National Register of Historic Places (NRHP)—was evaluated for Project “use” as defined by Section 

4(f). Where FRA determined that the Project will result in a Section 4(f) use and there are no feasible 

and prudent alternatives, FRA provided individual Section 4(f) evaluations to the U.S. Department 

of Interior (DOI) Office of Environmental Compliance and Policy for review and concurrence. 

E.1.1 Consulting Parties 

While FRA continued to be the primary point of contact for all federally recognized tribes, FRA 

delegated all other state agency and consulting party coordination to DRPT in 2014. As such, 

DRPT sent invitation letters to agencies, local governments, and other stakeholders in the Section 

106 consultation process. FRA sent a letter to the federally recognized tribes along the DC2RVA 

corridor. 

Table E.1-1 provides information on the 50 distributed consulting party invitations. Of these, 23 

elected to participate in the process; the table below lists these groups, along with their response 

dates. For an additional 11 stakeholders, DRPT assumed that they would want to participate and 

has treated them as consulting parties. Although a formal response was not received from these 

11 groups, they have requested participation on similar projects and have shown a noted interest 

in the current undertaking through telephone calls or attendance at associated meetings. These 

11 are noted by “assumed yes” in Table E.1-1. 
E-3 

Table E.1-1: List of Invited Consulting Parties 

Stakeholder Invite Letter Date Response (Date) 

American Battlefield Protection Program (ABPP) January 6, 2015 Assumed Yes 

Marine Corps Base Quantico January 6, 2015 Assumed Yes 

National Park Service—Northeast Regional Office July 11, 2018 Yes (7/11/18) 

National Park Service—Captain John Smith Chesapeake NHT January 6, 2015 Yes (1/22/15) 

National Park Service—Fredericksburg January 6, 2015 Assumed Yes 

National Park Service—GW Memorial Pkwy July 1, 2017 Yes (7/1/2017) 

National Park Service—National Capital Region January 6, 2015 Assumed Yes 

National Park Service—Potomac Heritage National Scenic Trail January 22, 2015 Yes (3/4/2015) 

National Park Service—Richmond January 6, 2015 Yes (1/14/15) 

National Park Service—Washington-Rochambeau NHT January 22, 2015 Assumed Yes 

Alexandria Archaeology January 6, 2015 Yes (1/21/15) 

Arlington County January 6, 2015 Yes (1/14/15) 

Caroline County January 6, 2015 Yes (2/3/15) 

City of Alexandria January 6, 2015 Yes (10/11/17) 

City of Fredericksburg January 6, 2015 Yes (1/12/15) 

City of Richmond January 6, 2015 Yes (1/16/15) 

Hanover County January 6, 2015 Yes (2/3/15) 

Prince William County January 6, 2015 Yes (2/13/15) 

Town of Ashland January 23, 2017 Yes (2/23/17) 

Ashland Museum January 6, 2015 Yes (1/21/15) 

Central Virginia Battlefields Trust (CVBT) January 6, 2015 Yes (1/22/15) 

Civil War (now Battlefield) Preservation Trust (CWT) January 6, 2015 Yes (2/11/15) 

Historic Fredericksburg Foundation, Inc. (HFFI) January 6, 2015 Yes (1/9/15) 

Historic Richmond Foundation January 6, 2015; Resent 

November 13, 2016 Yes (11/28/16) 

Preservation Virginia June 21, 2018 Yes (6/21/18) 

National Trust for Historic Preservation (NTHP) January 6, 2015; Resent 

December 22, 2016 Yes (12/22/16) 

Pamunkey Indian Tribe July 9, 2015; Resent 

April 12, 2017 Assumed Yes 

Chickahominy Indian Tribe February 13, 2018 from 

FRA Assumed Yes 

Eastern Chickahominy Indian Tribe February 13, 2018 from 

FRA Assumed Yes 

Upper Mattaponi Indian Tribe February 13, 2018 from 

FRA Yes (2/23/18) 

Rappahannock Indian Tribe February 13, 2018 from 

FRA Assumed Yes 

Nansemond Indian Tribe February 13, 2018 from 

FRA Assumed Yes 

 Continued – see end of table for notes.
E-4 

Table E.1-1: List of Invited Consulting Parties 

Stakeholder Invite Letter Date Response (Date) 

Monocan Indian Tribe February 13, 2018 from 

FRA Assumed Yes 

Fairfax County January 6, 2015 No Reply 

Henrico County January 6, 2015 No Reply 

Spotsylvania County January 6, 2015 No Reply 

Stafford County January 6, 2015 No Reply 

ACL & SAL RR Historical Society January 6, 2015 No Reply 

Center for Neighborhood Revitalization January 6, 2015 No Reply 

Arlington Historical Society January 6, 2015 No Reply 

Caroline Historical Society January 6, 2015 No Reply 

Chesterfield Historical Society January 6, 2015 No Reply 

Hanover County Historical Society, Inc. January 6, 2015 No Reply 

Henrico County Historical Society January 6, 2015 No Reply 

Historic Alexandria Foundation January 6, 2015 No Reply 

Historic Prince William, Inc. January 6, 2015 No Reply 

Historical Society of Fairfax County, Virginia, Inc. January 6, 2015 No Reply 

Stafford County Historical Society January 6, 2015 No Reply 

Catawba Indian Tribe (based in South Carolina) January 6, 2015 No Reply per FRA protocol for 

Catawba 

Note: 1. The letters to the Native American tribes were sent by FRA. None of the tribes were federally recognized at the time the initial letters 

(dated 1/6/15) were disseminated. They were recognized at a later date (2/13/18), at which time the FRA invited them to participate. 

E.1.2 Meetings 

DRPT has held numerous in-person and telephone-based meetings with DHR, ACHP, consulting 

parties, and other vested individuals and groups. They included a Section 106 kick-off and an 

abundance of follow-up meetings to update participating agencies and parties on the Project 

initiation; determination of APE; cultural resource methodology for the reconnaissance predictive 

model, identification surveys, and evaluation studies; survey results and list of historic properties; 

Project effect on historic properties; stipulations to mitigate adverse effects; and crafting the Section 

106 Draft MOA. Multiple invitations to each meeting and reminders were sent to consulting parties. 

Table E.1-2 highlights the meetings held with these groups. Minutes for meetings held prior to the 

publication of the Draft EIS in September 2017 can be found in Appendix U of the Draft EIS. Minutes 

for meetings held since the publication of the Draft EIS can be found in Appendices E5 and E6. The 

public was invited to the Shockoe area meeting on October 12, 2018 but in general, consulting party 

meetings were limited to that group. Rather, numerous public meetings were held as part of the larger 

NEPA process, and details can be found in Chapter 2 of the Final EIS. The exception to this is within 

Richmond, where a number of vested individuals and groups requested additional data on the 

parameters of the Project and its potential impacts on cultural resources. Meetings were held to 

discuss historic properties in Shockoe Bottom and the Grave Yard for Free People of Color and Slaves 

(44HE1203) near Hospital Street to address specific concerns. Additional data on these meetings can 

be found in the table below. 
E-5 

Table E.1-2: Section 106 and Section 4(f) Cultural Resource Meetings 

Date Attendees Topics 

November 7, 2014 DHR, DRPT Kick-off meeting; discussions on APE, methodology, reporting 

March 19, 2015 VDOT, DRPT Roadway bridges and Section 106 coordination 

February 18, 2016 DHR, DRPT Update on corridor and status of studies 

June 14, 2016 CWT General discussion on results to date; Richmond to Raleigh 

Memorandum of Agreement 

August 10, 2016 DHR, DRPT Preliminary dialogue on historic properties and Project effect 

May 15, 2017 Ashland Museum, Town of Ashland Overview of 106 process and technical studies to date 

June 8, 2017 NPS- Fredericksburg, DRPT Update on technical studies and Project plans 

July 14, 2017 Town of Ashland; Ashland Museum Update on technical studies and Project plans 

July 26, 2017 DHR, DRPT Update on technical studies and Project schedule 

August 14, 2017 NPS—Richmond, DRPT Update on technical studies and Project plans 

October 11, 2017 Hanover County, Town of Ashland, 

Ashland Museum Update on technical studies and Project plans 

October 20, 2017 

Alexandria Archaeology, City of 

Alexandria, Arlington County, NTHP, 

DRPT 

Update on technical studies and Project plans 

October 24, 2017 ACHP, ABPP, CWT, DRPT Update on technical studies and Project plans 

October 27, 2017 

Prince William County, Caroline 

County, City of Fredericksburg, CVBT, 

HFFI, DRPT 

Update on technical studies and Project plans 

October 30, 2017 City of Richmond, Historic Richmond 

Foundation, DRPT Update on technical studies and Project plans 

February 8, 2018 Rose Center/Urban Land Institute, 

DRPT Overview of Project and history of Shockoe Bottom 

February 13, 2018 DHR, DRPT Update on technical studies and Project schedule 

April 4, 2018 DHR, DRPT Discussion of Project limits of disturbance and APE 

June 18, 2018 Town of Ashland, Ashland Museum Historic property list and 106 process 

June 19, 2018 DHR, DRPT Historic properties and Project effect 

June 21, 2018 

CWT, Historic Richmond Foundation, 

Town of Ashland, Ashland Museum, 

Preservation Virginia, DRPT 

Historic properties and Project effect 

June 26, 2018 ABPP, City of Fredericksburg, NPS 

Fredericksburg, DRPT, FRA Historic properties and Project effect 

June 28, 2018 NTHP, Alexandria Archaeology, NPS—

Mount Vernon Parkway, ACHP, DRPT Historic properties and Project effect 

July 2, 2018 DHR, FRA, DRPT Revisit of historic properties and Project effect 

July 16, 2018 Town of Ashland, Ashland Museum Technical reports and Project effect 

July 17, 2018 NPS- Fredericksburg DC2RVA LOD and Jackson’s Shrine 

 Continued.
E-6 

Table E.1-2: Section 106 and Section 4(f) Cultural Resource Meetings 

Date Attendees Topics 

July 17, 2018 Preservation Virginia DC2RVA Project summary and list of historic properties 

July 19, 2018 City of Richmond, DRPT Historic properties and Project effect 

July 24, 2018 DHR Resources in Shockoe Bottom 

July 26, 2018 FRA, DHR, DRPT Resources in Shockoe Bottom 

July 27, 2018 ACHP Resources in Shockoe Bottom 

July 31, 2018 DHR, FRA, DRPT Resources in Shockoe Bottom 

August 3, 2018 DHR Resources in Shockoe Bottom 

August 6, 2018 

DHR, DRPT, VA Secretary of 

Transportation, VA Secretary of 

Natural Resources 

Discussion on historic resources in Shockoe Bottom 

August 29, 2018 City of Richmond, DHR Resources in Shockoe Bottom, City preservation initiatives 

near Main Street Station and future projects 

September 5, 2018 VA Secretary of Transportation, DHR, 

DRPT, City of Richmond Discussion of cultural resources in Shockoe Bottom 

September 10, 2018 NTHP, Preservation Virginia, Sacred 

Ground Project, ACHP, DHR, DRPT 

Discussion of upcoming meeting in Shockoe/Richmond, 

including meeting content and attendees 

October 2, 2018 FRA, DHR, ACHP, DRPT Summary of three October 2018 consulting party meetings, 

Resources in Shockoe Bottom, Next steps in 106 process 

October 2, 2018 DRPT, City of Alexandria List of historic properties, Project effect 

October 4, 2018 

City of Fredericksburg, Prince William 

County, Ashland Museum, Alexandria 

Archaeology, DRPT, FRA 

APE, list of historic properties, Project effects, Section 106 

Draft MOA mitigation 

October 5, 2018 

American Battlefield Trust (Civil War 

Trust), ABPP, Alexandria Archaeology, 

NPS- Mount Vernon Parkway, NPSNational Capital Region 

APE, list of historic properties, Project effects, Section 106 

Draft MOA mitigation 

October 12, 2018 

NTHP, Shockoe Partnership, ACHP, 

Preservation Virginia, City of Richmond, 

Slave Trail Commission, Historic 

Richmond Foundation, Untold RVA, 

DHR, FRA, DRPT, private citizens 

On-site visit at Main Street Station, APE, list of historic 

properties, Project effects, Section 106 Draft MOA mitigation 

October 15, 2018 Historic Richmond Foundation, DRPT Resources in Shockoe Bottom, list of historic properties, 

Project effect, Section 106 Draft MOA mitigation 

October 23, 2018 ACHP, DHR, FRA, DRPT Update on consulting party meetings, list of historic 

properties, Project effect 

October 24, 2018 Ashland Museum, Town of Ashland, 

DRPT 

List of historic properties, Project effect, Section 106 Draft 

MOA mitigation 

November 1, 2018 Preservation Virginia, DRPT Resources in Shockoe Bottom, list of historic properties, 

Project effect, Section 106 Draft MOA mitigation 

November 2, 2018 Elegba Folklore Society, DRPT 

Summary of Project, Resources in Shockoe Bottom, list of 

historic properties, Project effect, Section 106 Draft MOA 

mitigation 

 Continued.
E-7 

Table E.1-2: Section 106 and Section 4(f) Cultural Resource Meetings 

Date Attendees Topics 

November 28, 2018 NTHP, DRPT Discussion on reply sent to NTHP on Historic Properties 

December 2, 2018 

NTHP, Preservation Virginia, Historic 

Richmond Foundation, Elegba Folklore 

Society, City of Richmond, DRPT, FRA, 

ACHP, DHR 

Additional discussion on reply sent to NTHP, historic 

properties in Shockoe Bottom, and effect on historic 

properties 

January 31, 2019 DRPT, DHR Site 44HE1203 (Grave Yard for Free People of Color and 

Slaves) 

February 13, 2019 

Rivanna Archaeology, Historic 

Richmond Foundation, Sacred Ground 

Project, Richmond Archaeology, DRPT, 

DHR, VDOT 

Onsite meeting to discuss site 44HE1203 (Grave Yard for 

Free People of Color and Slaves) 

E.1.3 Correspondence 

Since the Project’s initiation, correspondence has occurred between DRPT and the cultural resource 

agencies, localities, and consulting parties to keep them informed on the progress of the studies, 

resource eligibility, the Project’s effects on historic properties, and Section 106 Draft MOA 

mitigation strategies. DRPT held meetings at milestones or as necessary throughout the Project. In 

particular, meetings and e-mail exchanges with DHR and ACHP have occurred regularly to 

provide information on Project plans. Data on the study results in specific Project areas were also 

sent to consulting parties to garner comments on the Project. The architectural reports were posted 

on the Project’s webpage for general public comment as well. The archaeological reports were only 

distributed to the agencies, localities, and consulting parties due to the sensitivity of site location 

mapping and to meet stipulations set forth in the Archeological Resources Protection Act of 1979. 

Table E.1-3 includes correspondence conducted as part of the process. Note that this table only 

lists formal correspondence and group emails. In addition to this roster, hundreds of one-on-one 

emails were exchanged with consulting parties and the general public to convey additional 

cultural resource data pertaining to the Project. Copies of relevant correspondence prior to 

September 2017 are included in Appendix U of the Draft EIS and post-September 2017 

correspondence can be found in Appendices E1 through E6. 

Table E.1-3: Project Correspondence 

Date Medium Recipient Topic 

September 25-

October 15, 2014 E-mail; Letter DHR, FRA, DRPT Initiation of Section 106 Process 

January 5- 

February 2, 2015 E-mail, Letter DHR, FRA, DRPT Defining Project APE 

June 8, 2015 E-mail VDOT VDOT/DHR PA on Historic Bridges 

June 22, 2015 Letter Civil War Trust, DRPT Receipt of comments on Project 

screening review 

July 30, 2015 E-mail All Consulting Parties, DRPT Distribution of Archaeological 

Predictive Model report for review 

July 17, 2015; 

August 28, 2015 Letter, E-mail DHR Submittal of Archaeological Predictive Model Report; DHR Reply 

 Continued.
E-8 

Table E.1-3: Project Correspondence 

Date Medium Recipient Topic 

August 3- 

September 4, 2015 E-mail 

Arlington County, City of Alexandria, Prince 

William County, City of Fredericksburg, 

DRPT 

Receipt of comments on

Archaeological IA Predictive model 

August 28, 2015 E-mail All Consulting Parties, DRPT Reminder to submit comments on 

Predictive Model Report 

October 20, 2015; 

December 18, 2015 Letters NPS (FSNMP) 

Archaeological Resources Protection Act

(ARPA) permit to dig on federal land 

(Original Segment 7) 

December 9, 2015; 

February 5,2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report (Original Segment 7); DHR 

Reply 

December 15, 2015 Letter DHR Application to conduct archaeology 

on state lands (Original Segment 11) 

March 18-31, 2016 E-mail; Memo DHR 

Discussion of alternative methodology 

for architecture in Original Segment 

18 

April 13- 

April 26, 2016 E-mail David Hamilton (Consulting Party), DHR, DRPT, FRA 

Mr. Hamilton is a private property 

owner along the Ashland Bypass.

Numerous E-mails were exchanged

with Mr. Hamilton regarding his 

concerns, his position as a consulting 

party, and distributing Project data 

May 20, 2016; 

June 8, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report (Original Segment 6); DHR 

reply 

May 31, 2016; 

June 22, 2016 

Letter, 

E-mail DHR 

Submittal of Architectural Phase I 

Report (Original Segment 3); DHR 

reply 

May 31, 2016; 

June 22, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report (Original Segment 4); DHR 

reply 

June 21, 2016; 

June 28, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segments 8-9); DHR reply 

July 6, 2016; 

July 22, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segment 1); DHR reply 

July 6, 2016; 

July 15, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report (Original Segment 2); DHR 

reply 

July 25, 2016; 

August 15, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segments 10-12); DHR reply 

December 21, 2016; 

February 21, 2017 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segment 13); DHR reply 

August 3, 2016; 

August 22, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segment 14); DHR reply 

September 6, 2016; 

October 11, 2016 Letter, E-mail DHR 

Submittal of Archaeological Phase I 

Report 

(Original Segments 1-20); DHR reply 

 Continued.
E-9 

Table E.1-3: Project Correspondence 

Date Medium Recipient Topic 

October 21, 2016; 

November 30, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segments 15, 16, 20); DHR 

reply 

November 14, 2016; 

December 22, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segments 17, 19); DHR reply 

October 21, 2016; 

November 3, 2016 Letter, E-mail DHR 

Submittal of Architectural Phase I 

Report 

(Original Segment 18); DHR reply 

January 20, 2017; 

March 1, 2017 Letter, E-mail DHR Submittal of Architectural Phase I Report (Structures); DHR reply 

January 6, 2017; 

February 3, 2017 Letter, E-mail DHR Submittal of Phase IA Ashland Bypass Report; DHR reply 

January 20, 2017; 

February 3, 2017 Letter, E-mail DHR Submittal of Phase IA Fredericksburg Bypass Report; DHR reply 

February 24, 2017; 

March 24, 2017 E-mail All Consulting Parties 

Distribution of Architectural Reports 

for review; Consulting Party 

comments 

March 28, 2017 E-mail All Consulting Parties Update on technical study distribution 

April 14, 2017; May 

14, 2017 Letter; E-mail All Consulting Parties 

Distribution of All Phase IA and IB 

reports for review; Consulting Party 

comments 

May 17, 2017 E-mail All Consulting Parties Reminder of comment deadline for 

reports 

June 1, 2017 E-mail All Consulting Parties Extension of deadline for comments 

on reports 

September 19, 2017 E-mail All Consulting Parties 

Summary of upcoming Draft EIS 

meetings and offer for on-on-one 

meetings 

October 7, 2017 E-mail All Consulting Parties Reminder of Draft EIS meetings 

November 2, 2017 E-mail All Consulting Parties Distribution of historic map overlays 

showing Shockoe Bottom 

November 21, 2017 Letter; E-mail Professor J.V. Moeser, Secretary of 

Transportation Resources in Shockoe Bottom 

February 7, 2018 E-mail All Consulting Parties Update on LOD and technical studies 

progress 

February 13, 2018 Letter; Email Tribes who received federal status in 2018 

Invitation to participate in Project; 

Updates on Project to date and future 

steps (Tribes were included on all 

subsequent All Consulting Party 

communication) 

May 8, 2018 E-mail All Consulting Parties Update on distribution of LOD and 

Phase II technical reports 

May 14, 2018; 

June 12, 2018 E-mail DHR Submittal of Archaeological LOD 

Expansion Areas Report; DHR reply 

May 17, 2018; 

July 20, 2018 E-mail All Consulting Parties 

Distribution of Archaeological LOD 

Expansion Areas Report for review; 

Consulting Party comments 

 Continued.
E-10 

Table E.1-3: Project Correspondence 

Date Medium Recipient Topic 

May 4, 2018; 

June 11, 2018 E-mail DHR 

Submittal of Architectural LOD 

Expansion Areas Report for review; 

DHR reply 

May 17, 2018; 

July 20, 2018 E-mail All Consulting Parties 

Distribution of Architectural LOD 

Expansion Areas Report for review; 

Consulting Party comments 

March 22, 2018; 

April 25, 2018 E-mail DHR Submittal of Architectural Phase II 

Report A; DHR reply 

April 19, 2018; 

May 1, 2018 E-mail DHR Submittal of Architectural Phase II 

Report B; DHR reply 

May 10, 2018; 

June 12, 2018 E-mail DHR Submittal of Architectural Phase II 

Report C; DHR reply 

May 17, 2018; 

July 20, 2018 E-mail All Consulting Parties 

Distribution of Architectural Phase II 

Reports (A-C) for review; Consulting 

Party comments 

June 13, 2018 E-mail All Consulting Parties Reminder of upcoming series of 

Project meetings 

June 20, 2018; 

June 28, 2018 Letter, E-mail DHR Submittal of Project effects letter; 

DHR reply 

June 20, 2018 E-mail All Consulting Parties 

Update on Project effects and 

reminder of upcoming series of 

Project meetings 

July 9, 2018; 

July 18, 2018 Letter; E-mail DHR Submittal of Addendum Project effects 

letter; DHR reply 

July 9, 2018 E-mail All Consulting Parties Update on Addendum Project Effects 

July 20, 2018 E-mail All Consulting Parties Reminder of deadline for report and 

effects comments 

August 14, 2018 E-mail FRA, DHR, DRPT Framework of Section 106 Draft 

MOA for review 

August 23, 2018 E-mail All Consulting Parties 

Update on Project including receipt of 

comments on reports, APE, and list of 

historic properties 

September 21, 2018 E-mail All Consulting Parties Invitation to three October 

Consulting Party Meetings 

September 21, 2018 E-mail 

Shockoe Bottom Neighborhood Assn; 

Historic Shockoe Partnership; Slave Trail 

Commission; Elegba Folklore Society; Black 

History Museum Virginia 

Untold VA; Virginia African American 

Cultural Resources Task Force; Southern 

Environmental Law Center; Sacred Ground 

Project; Community Unity in Action, 

Richmond Branch NAACP; Wesley 

Memorial United Methodist Church; 

VCU Department African American Studies; 

Richmond Crusade for Voters; First 

Unitarian Universalist Church; 

Sacred Ground Historical Reclamation 

Project; VCU, Building on Sacred Ground 

Invitation to Shockoe Bottom/ 

Richmond Consulting Party Meeting 

October 11, 2018 E-mail All Consulting Parties Reminder of three October 

Consulting Party Meetings 

 Continued.
E-11 

Table E.1-3: Project Correspondence 

Date Medium Recipient Topic 

October 11, 2018 E-mail 

Shockoe Bottom Neighborhood Assn; 

Historic Shockoe Partnership; Slave Trail 

Commission; Elegba Folklore Society; Black 

History Museum Virginia 

Untold VA; Virginia African American 

Cultural Resources Task Force; Southern 

Environmental Law Center; Sacred Ground 

Project; Community Unity in Action, 

Richmond Branch NAACP; Wesley 

Memorial United Methodist Church; 

VCU Department African American Studies; 

Richmond Crusade for Voters; First 

Unitarian Universalist Church; 

Sacred Ground Historical Reclamation 

Project; VCU, Building on Sacred Ground 

Reminder of Shockoe Bottom/ 

Richmond Consulting Party Meeting 

November 13, 2018 Letter; E-mail DRPT, Preservation Virginia, Historic 

Richmond Foundation, DHR, ACHP 

Reply to NTHP, Preservation Virginia, 

and Historic Richmond Foundation on 

July 20, 2018 letters 

November 27, 2018 E-mail All Consulting Parties 

Distribution of updated list of historic 

properties and revised effects; 

Solicitation of additional Section 106 

Draft MOA mitigation ideas 

November 19, 2018; 

January 4, 2019 Letter; E-mail DHR Submittal of Second Addendum Project effects letter; DHR reply 

December 21, 2018 E-mail FRA, DHR, ACHP, Revised Section 106 Draft MOA for 

review 

January 22, 2019 E-mail FRA, DHR, ACHP 

Revised Section 106 Draft MOA for 

review based on DHR feedback 

(received January 16, 2019) 

November 30, 2018; 

January 4, 2019 Letter; E-mail DHR Section 4(f) concurrence letter; DHR reply 

December 21, 2018 E-mail All Consulting Parties Distribution of Section 106 Draft 

MOA for review to Consulting Parties 

January 29, 2019 E-mail All Consulting Parties Extension of deadline for Section 106 

Draft MOA comments 

February 11, 2019 E-mail FRA, DHR, ACHP 

Second revised Section 106 Draft 

MOA for review based on Consulting 

Party feedback 

February 26, 2019 E-mail FRA, DHR, ACHP 

Third revised Section 106 Draft MOA 

for final review based on signatory 

feedback 
E-12 

E.2 SECTION 4(f) COMMENTS & COORDINATION 

Table E.2-1 includes the correspondence subsequent to the publication of the Draft EIS in 

September 2017 related to Section 4(f) for parks, recreation areas, trails, and wildlife and 

waterfowl refuges (this information is also provided in Table 6.8-1 of the Final EIS). Section 4(f) 

correspondence prior to the Draft EIS publication is included in Appendix U of the Draft EIS. 

Table E.2-1: Section 4(f) Correspondence 

Resource Owner Type1 Date Purpose 

Arlington County Response 

Letter September 8, 2017 Expressed concern with de minimis assumption based on Draft EIS impacts 

Virginia Department of Game 

and Inland Fisheries 

Response 

Letter October 12, 2017 Concurrence with temporary occupancy of Mattaponi Wildlife Management Area 

Arlington County Meeting February 2, 2018 Review of Draft EIS comments 

City of Richmond, Department 

of Public Works Letter October 22, 2018 

Provided update of impacts, requested concurrence 

with de minimis use and temporary occupancy of 

Walker’s Creek Retention Basin Park 

City of Richmond, Department 

of Parks, Recreation, and 

Community Facilities 

Letter October 22, 2018 

Provided update of impacts, requested concurrence 

with de minimis use and temporary occupancy of 

Walker’s Creek Retention Basin Park 

Arlington County Department 

of Parks and Recreation Letter October 29, 2018 

Provided update of impacts to Long Bridge Park and 

Mount Vernon Trail, and requested concurrence 

with temporary occupancy for Long Bridge Park 

NPS – George Washington 

Memorial Parkway 

Headquarters 

Letter 

October 29, 2018 

and December 6, 

2018 

Provided update of impacts and requested 

concurrence regarding temporary occupancy of 

George Washington Memorial Parkway and Mount 

Vernon Trail 

City of Alexandria Letter October 29, 2018 

Provided update of impacts and requested 

concurrence with temporary occupancy of Dog Run 

Park at Carlyle, Four Mile Run Trail, Potomac Yard 

Park, Potomac Yard Landbay N., and Rail Park 

NPS – Fredericksburg and 

Spotsylvania National Military 

Park 

Letter October 29, 2018 

Provided update of impacts and requested 

concurrence regarding temporary occupancy of 

Fredericksburg and Spotsylvania National Military 

Park 

Prince William County Parks 

and Recreation Department Letter October 29, 2018 

Provided update of impacts and requested 

concurrence regarding temporary occupancy of 

Veterans Memorial Park 

Henrico County Recreation 

and Parks Letter October 29, 2018 

Provided impacts and requested concurrence 

regarding temporary occupancy of Laurel Recreation 

Area 

Henrico County Recreation 

and Parks 

Response 

Letter October 31, 2018 Concurrence regarding temporary occupancy of Laurel Recreation Area 

Prince William County Parks 

and Recreation Department 

Response 

Letter November 2, 2018 Concurrence regarding temporary occupancy of Veterans Memorial Park 

City of Richmond, Department 

of Public Works 

Response 

Letter 

November 16, 

2018 

Concurrence regarding de minimis use and temporary 

occupancy of Walker’s Creek Retention Basin Park 

NPS – Fredericksburg and 

Spotsylvania National Military 

Park 

Response 

Letter December 7, 2018 

Concurrence regarding temporary occupancy of 

Fredericksburg and Spotsylvania National Military 

Park 

 Continued – see end of table for notes.
E-13 

Table E.2-1: Section 4(f) Correspondence 

Resource Owner Type1 Date Purpose 

NPS – George Washington 

Memorial Parkway 

Headquarters 

Response 

Letter December 12, 2018 

Concurrence regarding temporary occupancy of 

George Washington Memorial Parkway and Mount 

Vernon Trail 

City of Alexandria Response 

Letter December 13, 2018 

Concurrence regarding temporary occupancy of Dog 

Run Park at Carlyle, Four Mile Run Trail, Potomac 

Yard Park, Potomac Yard Landbay N., and Rail Park 

Arlington County Department 

of Parks and Recreation 

Response 

Letter December 18, 2018 Concurrence regarding temporary occupancy of Long Bridge Park 

Notes: 1. “Letter” denotes a letter from DRPT to the resource owner; “Response Letter” denotes a letter from the resource owner to DRPT. 

Appendix E7 includes correspondence related to the de minimis impacts associated with Walker’s 

Creek Retention Basin Park. 

Appendix E8 includes correspondence related to concurrence that the temporary occupancy of 

the following parks does not result in a Section 4(f) use: 

 Long Bridge Park 

 Mount Vernon Trail 

 George Washington Memorial Parkway 

 Dog Run Park at Carlyle 

 Four Mile Run Trail 

 Potomac Yard Park 

 Potomac Yard Landbay N. 

 Rail Park 

 Fredericksburg and Spotsylvania National Military Park 

 Veterans Memorial Park 

 Laurel Recreation Area