After an undertaking – like bridge removal – is identified, federal agency stakeholders follow these four steps to fulfill Section 106 requirements:

1. Initiate consultation by notifying appropriate consulting parties. Consultation is between the federal agency, the State Historic Preservation Officer (SHPO), and other consulting parties including:  the Advisory Council on Historic Preservation, certified local governments (The Corvallis Historic Resources Commission is a consulting party, PreservationWORKS! is another), and members of the general public with an economic, social or cultural interest in the project. 

2. Identify properties that may be affected by the project – there are several including the Van Buren Bridge – and determine if the property or properties are historic as determined by eligibility or listing in the National Register of Historic Places.  (Yes, they are.)

3. Assess the effects of the undertaking on the resources in consultation with interested parties and establish if they are adverse. (Demolition is the definition of an adverse effect.)

4. Resolve adverse effects by developing and evaluating alternatives that could avoid, minimize, or mitigate these impacts on historic resources.  (This is a substantial issue and ODOT has failed to develop – or consider – alternatives.)

National Environmental Policy Act (NEPA)

Requires federal agencies – or those funded with federal money – to assess whether an action potentially affects the human environment prior to making decisions.  Agencies must evaluate the environmental, social, and economic effects of proposed actions by preparing an Environmental Assessment (EA) or an Environmental Impact Statement (EIS).  Under NEPA, agencies are required to provide opportunities for public review and comment.

Integration of NEPA and Section 106 makes sense because: the historic properties of concern in Section 106 are one type of resource in the human environment considered in NEPA; both processes are triggered by federal funding, permits, licenses, or other approvals and share goals of providing transparency and allowing for public involvement; both processes should be initiated early in project planning when a broad range of alternatives can be considered; and, completion of both processes is needed for agencies to proceed to implement an action or undertaking.

Sec. 101 [42 USC § 4331]

(a) The Congress, recognizing the profound impact of man’s activity on the interrelations of all components of the natural environment, declares that it is the continuing policy of the Federal Government, in cooperation with State and local governments, and other concerned public and private organizations, to use all practicable means and measures to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans.

(b) In order to carry out the policy, it is the continuing responsibility of the Federal Government to use all practicable means, consistent with other essential considerations of national policy, to improve and coordinate Federal plans, functions, programs, and resources to the end that the Nation may —

1. Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations;

2. Assure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing surroundings;

3. Attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences;
   Preserve important historic, cultural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity, and variety of
   individual choice;

4. Achieve a balance between population and resource use which will permit high standards of living and a wide sharing of life’s amenities; and

5. Enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.

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(c) The Congress recognizes that each person should enjoy a healthful environment and that each person has a responsibility to contribute to the preservation and enhancement of the environment.