JIM TREADWELL LETTERS yreacatcew °
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September 25 , 2002
* Stanley Gee
Division Administrator
U.S.Department
HighwayoAdministrrationon Gl-'',('1 (, j • lj
55 Broadway 10th Floor
Cambridge, MA 02142-1093
Thomas Broderick
Chief Engineer
Massachusetts Highway Department
10 Park Plaza
Boston , MA 02116
Attn: Steven McLaughlin
RE: Salem-Beverly Transportation Project
Bridge Street Bypass Road
Salem, Massachusetts
Dear Mr. Gee and Mr. Broderick:
It is our understanding that the Massachusetts Highway
Department (Department) , in concert with the Federal Highway
Administration (FHWA) , is to prepare, pursuant to Section
106 of our National Historic Preservation Act and the
directive contained in the letter of August 5 , 2002 to
Mr . Gee from Mr . Don L. Klima, Director, Office of Federal
Agency Programs, Advisory Council on Historic Preservation ,
an effect finding respecting the modification to the
proposed alignment of the Bypass Road . We further note that
said finding and supporting documentation is to be provided
to various parties , specified in Mr . Klima ' s letter, that
have expressed an interest in this undertaking.
As your Office proceeds with the effect determination
regarding impact on the historic resources , we would ask
that you give particular attention to thefollowing :
1 .The 75% Design Plan Tbr the re-aligned Bypass indicates
considerable change in the vicinity of the National
Register Eligible Signal Tower , including widening of
road at the existing rotary toward the Tower. Also,
please include in your "finding" consideration of the
impact on this historic property of the failure to go
forward with compliance with Stipulation V of the
Memorandum of Agreement .
2 .The effect which the proposed five lane segment of the
realigned highway ' s construction could have on the
structural integrity of the First Universalist Church,
the introduction of increased levels of traffic and
associated noise, pollution and vibration could have on
this individually listed National Register property
(c. 1808 ) and the effect on the setting of this resource .
r
3 .The effect of the project on the Salem Common National
Register Historic District , particularly the
contributing Jail House and Howard Street Burial Ground
which are immediately adjacent to the re-aligned Bypass
Road and its Bridge Street connection.
4.The effect of the project on the adjacent Bridge Street
Historic District portions of which are contiguous to
the Bypass Road.
We stand ready to meet with representatives of your Offices
for consultation as you proceed to satisfy your historic
preservation review responsibilities and look forward to our
involvement in the review of the effect finding for the
revised Bridge Street Bypass .
You may contact us most directly through James Treadwell at
( 978) 744-6080 if you wish to discuss any matter
specifically set-forth in this letter .
Sincerely,
1",A—
Staley,4fcDermet
ames Treadwell , AICP
IAV�4 All
for Downtown Salem Neighborhood Association
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for First Universalist Church o
cc : Advisory Council on Historic Preservation
Massachusetts Historical Commission
,vSalem Historical Commission
Salem Planning Department
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��Mrms
Salem Historical Commission
ONE SALEM GREEN,SALEM,MASSACHUSETTS 01970
(978)745-9595 EXT.311 FAX(978)740-0404
April 19, 2002
James Treadwell
36 Felt Street
Salem,MA 01970
Dear Mr. Treadwell,
I am in receipt of your letter requesting a copy of all Massachusetts Highway Department
and Massachusetts Historical Commission correspondence that I have in the Salem Historical
Commission files regarding the Salem/Beverly Transportation Project. Administrative staff in
my department have made copies of the correspondence you have requested(91 pages). The
total cost for copying at 25 cents per page is $22.75.
You may pick up the package of copies from the receptionist in my department(120
Washington Street, 3rd floor). Please make your check out to the"City of Salem". If you prefer,
you may mail a check for$26.26 (includes $3.50 for postage)to my office and we will mail the
package of copies to you upon receipt.
Sincere'
J e A. Guy
Clerk of the Commission
1 4/30/02 TUE 14:30 FAr 617 973 8879 MHD-ENVIRONMENTAL 000
36 Felt Street
Salem, MA 01970
April 15, 2002
Stanley Gee
Division Administrator
U.S. Department of Transportation
Federal Highway Administration-Region I
55 Broadway
Cambridge, MA 02142
RE: Bridge Street By-pass
Salem-Beverly Transportation Project
Dear Mr. Gee:
As I 'm sure you are aware, the Massachusetts Highway
Department (MHD) is in the process of approving a change
to the Bridge Street By-pass (By-pass) segment of the Salem-
Beverly Transportation Project. The change involves the
significant realignment of a 2000 foot section of this
By-pass which would connect the new Veterans Memorial Bridge
to downtown Salem.
This Project has been proposed to be planned and implemented
in 6 Phases and, previously, with regard to the review
pursuant to Section 106 of the Historic Preservation Act of
1966, A Memorandum of Agreement (Bit-F-54 (085) was
formulated which included Stipulations relative to three
Phases of this undertaking-Phase V, the By-pass,was
determined to have "no effect" on historic resources. (Re-
fer to Project Reference Map, Figure 3, Supplemental
Environmental Impact Report, EOEA No. 0756, which depicts
Phases of the Project and historic resources) Please note
that the Advisory Council of Historic Preservation, (Council )
concluded that review and comment by the Council of the
no effect findings is not necessary ( See attached letter of
December 26, 1991 to Donald E. Hammer from Don L. Klima) .
The realignment currently being considered will abutt two
Natinal Register properties and the Register-eligible Bridge
Street Historic District. ( See Attached Figure 4.6, State
and National Register and National Register-Eligible
Resources Adjacent to Project (Jefferson at Salem) , Epsilon
Associates) In this regard, the roadway has the potential
to adversely effect the National Register listed First
Universalist Church and the Howard Street Burial Ground, a
contributing element in the Salem Common National Register
District.
To evidence my past interest and involvement with the
historic review process and with the Project, I am including
copy of the letter from George R. Turner, Jr. , P.E. , to me
4/30/02 TUE 14:30 FAX 617 973 8879 HHD-ENVIRONMENTAL 0 003
as an -interested party" of January 29, 1991 and the
Certification of the Project of August 2, 1990, by John
DeVillars, Secretary of Environmental Affairs, recognizing
the need to confer with me by the Highway agency.
To date the MHD as not solicited the involvement of myself
or the general public or interested parties in the on-going
Section 106 process regarding the modification to the
By-pass nor have any meetings been held with regard to the
historic review process.
I would ask that you insure that the HHD include me, as a
citizen with a "demonstrated interest" in this project and
historic preservation, in the Section 106 review of the
change to the subject undertaking.
I may be reached at (978) 744-6080.
Thank you for your consideration of this matter.
Sincerely,
James R. Treadwell , AICP
cc= Don L_ Klima
Cara Metz
Thomas F. Broderick
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f 2 199, 36 Felt Street
SAI&I f�ry���@� Salem, MA 01970
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22 February 1991
Ms. Jane Guy
Salem Historical Commission
Planning Department
City of Salem
One Salem Green
Salem, MA 01970
Dear Ms . Guy:
As discussed, I am therby requesting copy of the Historical
Commission 's comments on the Section 106 Documentation which
was prepared and distributed by the Massachusetts Department
of Public Works (MDPW) in January 1991 . I understand that
your Commission intends to provide such comment to the MDPW
by March 1, 1991 .
I am enclosing herewith co yof m
y comment regarding the extent
of archaeological testing which has been conducted for the
MDPW in connection with its proposed construction of a Bypass
Road along the eastern shore of the North River. I note that,
with regard to this issue of the proposed project ' s impact on
archaeological resources, your Commission has only reviewed and
commented on the "seperate" March Street Bridge project, and
that you anticipate receipt of the final report for your review
in the near future. In this respect, I would ask that you note
the boundary of the report ' s "project area" vis a vis the corridor
to be occupied by the Bypass Road/relocated railroad, the issue
of pre-historic resource potential, the limited amount of sub-
surface testing which occurred beyound the March Street Bridge
project area, and the report ' s conclusion regarding the documen-
tary evidence of early seventeenth century occupation of the
area.
Thank you.
Sincerely,
pJrrtuJJ ��.,
Ja es R. Treadwell, AICP
36 Felt Street
Salem, MA 01970
21 February 1991
Mr . Don Klima
Director, Eastern Office of Project Review
Advisory Council on Historic Preservation
The Old Post Office Building
1100 Pennsylvania Avenue, NW, #809
Washington, D.C. 20004
RF,: Salem-13everly Transportation Project
Dear Mr. Klima:
By letter of August 15, 1990 , Mr. H. Gunther Rudenberg of Beverly
requested that your office investigate the matter of the adequacy
and extent of archaeological testing which was being performed in
the area of the Old Planters ' Settlement in Salem.
Recently copy of the conceptual design plans for the Bridge Street
Bypass Road portion of the subject undertaking have been released
by the Massachusetts Department of Public Works (MDPW) . When these
plans are examined, they indicate that the Bypass Road will be on
grade through the Old Planters ' Settlement site area in a corridor
40 feet wide and about 3300 feet long. In turn, the railroad tracks ,
which will be relocated to the west and toward the banks of the North
River so that the new Road may be accommodated, are also to be located
in a corridor of 40± feet in width and for a distance of about 2000
lineal feet.
I have reviewed the draft of the final Archaeological Investigation
at the Ephrain Skerry House and the March Street Peninsula, 1990,
which has been prepared for the MDPW. I note that, within the
abovecited corridors, the Investigation indicates that one trench
and one test shovel pit (Phase I ) and one test shovel pit (Phase
II ) occurred at the Skerry House lot, that two trenches were in-
vestigated on Lot 24, near March Street, and that three test shovel
pits were dug on a lot at Throndike Street. By contrast, for the
seperate and considerable smaller and simpler March Street Bridge
replacement project, this same Investigation involved extenisve
testing on all lots which would be involved with this undertaking.
Now that the abovecited plans and archaeological investigation are
avialable, and in view of the conclusions concerning the location
of the Old Planters ' Settlement and the integrity of the area set
forth in the Investigation, I would request that the Advisory Council
investigate further the issue of the extent of archaeological testing
within this undertaking ' s area of potential effect.
Thank you-
Sincerely,
___� S �-
James R. Treadwell, AICP
4 , 36 Felt Street
Salem, MA 01970
February 8, 1991
Mr. Anthony J. Fusco
Division Administrator
US Department of Transportation _
Federal Highway Administration - Region I
55 Broadway 10th Floor
Cambridge, MA 02142
Mr. Don L. Klima
Director, Eastern Office of Project Review
Advisory Council on Historic Preservation
The Old Post Office Building
1100 Pennsylvania Avenue, NW, #809
Washington, DC 20004
Ms. Judith B. McDonough
Executive Director
State Historic Preservation Officer
Massachusetts Historical Commission
80 Boylston Street
Boston, MA 02116
RE: Salem-Beverly Transportation Project
(Beverly-Salem Bridge and Bridge Street Bypass)
Dear Sirs and Madame:
I have reviewed the "Documentation Submitted Pursuant to: Section
106 of the National Historic Preservation Act of 1966" which was
forwarded to meas an interested party and on behalf of the Federal
Highway Administration, by letter of January 29, 1991 , from George
R. Turner, Jr. , P.E. , of the Massachusetts Department of Public
Works (MDPW) . Subsequently, I requested and recieved additional
information which included plans and profiles for the Bridge Street
Bypass and for Bridge Street from Boston Street to Flint Street
from James E. Elliott of MDPW. My comments regarding this .documen-
tation are attached to this letter.
Please advise me of your consideration of my views and of your pro-
posed resolution of the historic preservaton issues which they raise
as soon as practicable.
I appreciate being consulted with respect to the subject undertaking
and will anticipate the opportunity to participate further in the
Section 106 process.
Sincerely;
James R. Treadwell, AICP
Attachment
t - 2 -
CC: James Kerisotis, MDPW /
Salem Historical Commission
Beverly Historic District Commission
John Bestgen, FHWA
Eugene Cleckley, FHWA
Robert Crecco, DOT
FEBRUARY 8, 1991
COMMENTS OF JAMES R. TREADWELL, AICP
SECTION 106 DOCUMENTATION (UNDATED) OF THE FEDERAL HIGHWAY ADMINISTRATION
1 . Previous Satisfaction of the Section 106/ The Undertaking.
The evidence of the 1980 "clearance" included 'in the Documen-
tation is the letter of March 27, 1980 , to the Massachusetts Depart-
ment of Public Works (MDPW) which reflects the opinion of the
Massachusetts Historical Commission (MHC) that the Salem-Peabody
Connector Road and the Beverly-Salem Bridge " . . .is unlikely to
affect significant historic or archaeological resources! This
"no effect" opinion is contradicted by the indication made by the
Federal Agency in its Final Environmental Impact Statement of 1981
that the project would, in fact, have a limited affect on the Fish
Flake Hill National Register Historic District, thus requiring
mitigation ( "a clean, simple well. proportioned design" , page 85
of the Final EIS) , and the fact that the Skerry House was proposed
to be relocated (Refer to letter to MDPW by the Salem Historic
Commission( SHC) of September 5, 1975) thus affecting this First
Period House. MHC/FHWA opinion of eligibility of Skerry not presented.
By limiting its assessment to the modifications to the project,
as such was envisioned back in 1980, the impression could be given
that the documentation and process is being used to justify a
previously made decision. In addition, this limitation would pre-
clude the consideration of all reasonable alternatives to the FHWA
proposal which might avoid or mitigate impacts to historic proper-
ties .
2 . Public Participation
It is noted that the Documentation sets'>forth information re-
garding the identification of historic properties and the assess-
ment of effects,and was transmitted to the FHWA by the MDPW on
January 4, 1991 . Please describe the methods used by the Federal
Agency since that date to make the documentation available for
public inspection and of the measures of notification utilized
to solicit the views of the public so that. such can now be properly
considered by the FHWA and other consulting parties (Reference:
Part 800.1( c) ( 2) (iv) , Part 800.4,Part 800. 5(b)). Further in this
regard, and now that comprehensive documentation on resource Iden-
tification and effect has been developed, would it not be appropri-
ate for the Federal Agency to provide an opportunity for members
of the public to receive information and express their views by
conducting a public information meeting for this purpose? (Reference:
800. 5(e) ( 3) . Note: the MDPW did conduct an information meeting on
the project in Salem on July 7, 1991, but this was held before the
FHWA Documentation was available, neither the Agency Official,
the State Historic Preservation Officer, nor the Advisory Council
participated in the July meeting, and the State Agency did not
take the opportunity to address the issue of historic preservation,
project impacts on historic resources, nor explain the Section 106
process from. the dias.
_ 1 _
FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
3 . Consultation with Interested Parties
The Documentation indicates that the MDPW did consult with one
k.: group in Salem (ie, residents of the Federal Street neigh-
borhood) and I understand that the Documentation has been sent to
two interested parties in order to seek .' views of the public/
interested persons . Has the MDPW informed the FHWA of other organ-
izations and individuals that have expressed concern with the effects
of the undertaking on historic properties and have made such known
to the MDPW at the Project Update Meetings-which were conducted
"for informational purposes" by the MDPW until July of 1990 -3or
through comments relative to historic preservation issues made
to Secretary DeVillars in concert with review of the Draft Supple-
mental Environmental Impact Report? Is it appropriate that these
other "interested persons" be notified of the Documentation? (Re-
ference: Part 800.1(c) ( 2) (iv) , Part 800 . 4(d) and Part 800 . 5(b)
4 . Coordination with Other Authorities
By letter of November 24 , 1989, the Advisory Council requested
a copy of the "Environmental Reevaluation" for this project which
was being developed pursuant to the Environmental Impact (NEPA)
Procedures of the Federal Highway Administration. Has this data
been provided to the Advisory Council for consideration in connection
with the Section 106 review? Should not the Reevaluation be includ-
ed as relevant data in the Documentation? Has FHWA made a decision
regarding the validity of the 1975-1981 EIS?
Please describe how the Federal Agency will satisfy Part 800 .14 _
of the Advisory Council 's Regulations in this instance and in rela-
tion to the on-going review of the project 's environmental impacts
and t _er its Reevaluation of the Environmental Impact Statement of
1975-1981. How will the Federal Agency "integrate" the current
historic preservation review with the environmental review process
of NEPA, and "coordinate" the studies needed to comply with the
Section 106 Regulations with studies related to natural and social
aspects of the project ( ie, aspects such as the use of mass transit
and the relocation of the MBTA railroad, floodplain and coastal
zone management, impact on significant public recreation facilities
under .Section 4 ( f) , impacts on wetlands and replication proposals,et.c )?
(Reference: Part 800 .14)
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FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
5. RECONSTRUCTION AND WIDENING OF BRIDGE STREET, BOSTON
STREET TO FLINT STREET.
a. Prior environmental/historic preservation review.
It is my understanding that this proposed improvement
was not an element of the undertaking which was reviewed
by the Federal Agency in 1981 and as described in the
Final Environmental Impact/4( f) Statement. This action
has never been reviewed under the provisions of either
the National Environmental Policy Act or the National
Historic Preservation Act.
Please report on the status of the NEPA review of
this segment of the Transportation Project and indicate
when it will be available to the consulting and inter-
ested parties
b. Blubber Hollow
This property was judged, in June of 1988, to be " . . .
an excellent candidate for an historic/archaeological
district" by Dr. Stephen M. Mrozowski and Leslie Shaw
as reported in "Salem, Massachusetts, An Archaeological
Survey of the City" .
In 1955 and in connection with excavation associated
with construction on the south side of Bridge Street di-
rectly opposite from the area in question, Sylvania Elec-
tric Company reportedly discovered, in tact, whale oil
vats of cypress wood which had_..been associated with the
whaling industry and the North River.
Within this Blubber Hollow area, the subject proposal
would necessitate the excavation of a 40 'by 1500 ' channel
to accommodate the relocation of the existing North River
Canal . As noted above, this element has never been reviewed
under NEPA or Section 106.
In view of the conclusions of the above-cited experts,
and with knowledge of the Sylvania discovery, a thorough
investigation of the subsurface conditions which includes
documentary research and testing should be undertaken for
the areas which will be impacted by this new project ele-
ment.
No data is presented in the Documentation to substanti-
ate the conclusions presented nor to reflect an actual
assessment of the subsurface conditions in this area.
c. The North River Canal
The North River Canal has been identified by the National
Park Service as a significant historic resource and the
portion lined in rough-cut, semi-coursed ashlar and constructed
in 1881 , is actually depicted among "Images Along the Leather
Tour" in the National Park Service ' s 12/89 publication con-
cerning"The Salem Project"
The FHWA has indicated that, since the North River industri-
al area has lost its historic and visual integrity, the Canal
structure is not afforded the protection of the historic laws and
-3-
r
FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
North River Canal (con)
regulations.
In a letter to Commissioner Garvey of September
13, 1989, from Mayor Salvo, while describing the
City ' s preferred alternative for the Transportation
Project based on the City 's conceptual plan as pre-
pared by its transportation consultant, it is noted
that the City prefered an alternative which "Keeps
the existing canal in operation and exposed to view
in recognition of its historical character, attrac-
tive stone wall construction, and interpretive oppor-
opportunities by the National Park Service".
I would ask the the above-cited conflict regarding
the significance of the North River Canal be properly
considered and rectified.
I would further note that the channelization of the
North River during the period from 1881 to 1885 is gen-
erally recognized a a very early, though unsuccessful
attempt regarding the disposal of contaminated waste
and that certain individuals of local significance
might have been associated with this construction pro-
ject. Accordingly, I would ask consideration of the
need to explore the appropriateness of HABS/HAER com-
pliance concerning this property as it would be effected
by the Transportation Project.
6. RECONSTRUCTION AND WIDENING OF BRIDGE STREET, FLINT STREET
TO WASHINGTON STREET
a. Prior environmental/historic preservation review.
In 1981 when the Federal Agency conducted its .
NEPA review and last considered the impact of the
project on historic resources, this portion of the
undertaking represented a mere segment of the Pea-
body-Salem Connector Road. It represented an entirely
new roadway with fully controlled access, a segment
of this four lane, four mile long arterial which
would run through Peabody to Route 128 and connect
central Salem to the Interstate Highway system.
The current proposal '_:.:c,?; would involve a "stand-
alone" type of project which consists of the improve-
ment to existing streets without limited access,
which would extend from Salem ' s core for about three-
quarters of a mile and connect to the above-cited
improvement to the existing Bridge Street and ter-
minate at Boston Street in Salem.
The Federal Agency proposal of 1981 would have
approached no closer than to about 150feet from the
historic properties/residential comm4nity, whereas
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FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
the Bridge Street widening/reconstruction project will
be contiguous to a National Landmark, several National
Register properties, a local historic district and the
residential comm ,�unity, including its elementary school.
Accordingly, the current proposal reflects significant
change from the Connector Road project of 1981and in
actuality represents a different highway design concept
and(entirely new design. The change in alignment/loca-
tion of the project will not lessen the impact on the
numerous historic properties in the area of potential
effect.
It ;would seemireasonable that the. Section 106 and the
NEPA reviews for the new proposal would reflect the
consideration of these issues .
The Documentation does not include the results of the
consideration of a full range of all reasonable alterna-
tives which would avoid or reduce effects on historic
properties or eliminate other adverse impacts to the
environmental which might be associated with this new
proposal .
The Documentation does not present data relative to
the purpose of the project or the need for the improve-
ment -as planned.
b. Pierce-Nichols House-National Landmark
This Landmark is not "well outside the project area"
The property is actually immediately adjacent to the
proposed undertaking, well within area of environmental impact.
No assessment of the visual, atmospheric,audible
changes which can be expected to the Pierce-Nichols
House is included in the Documentation. Also; :.had=.in .
this- regard, the Documentation does not include data
concerning the projected traffic volumnes on Bridge
Street and the increases which can be expected upon
implementation of this proposed undertaking.
c. Dewatering area.
The Documentation does not assess the impact which
this proposed facility could have on the Pierce-Nichols
House, or the_McIntire,Chestnut Street and Federal Street
historic Districts.
d. McIntire District
In terms of the atmospheric (air quality and vibration)
and other changes which would be associated with the
expected increases in traffic volumnes on Bridge Street,
it does not seem reasonable to conclude that a 5 ' -30 '
buffer will cause the proposed widening/reconstruction
not to effect the historic district.
The basis for concluding that a 3 dB decrease in noise
levels will occur at sites 6 and 19 is not presented in
the Documentation (ie, number of vehicles, percent trucks,
effective distance, stop and go traffic, etc)
-5-
FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
e . Court Houses
Traffic volumnes will be increased, the setting will
change as the roadway adjacent to these National Register
is improved to acc(Imodate 5/6 traffic lanes, and these
changes effect the passage of pedestrians from the rail
station/parking area to the court complex. These effects
are not assesselin the Documentation.
7 . BRIDGE STREET BYPASS ROAD
a. Prior environmental/historic preservation reviews .
At the time of the Final Environmental Impact/4 ( f)
Statement in 1981,the undertaking from the Bridge to the
vicinity of Washington Street/Route 114 was a segment of
the Peabody-Salem Connector with a partial interchange
at Route 114 and some=what removed from the Salem core street
system. The 1991 proposal is for a two-travel lane, "stand-
alone" type of project which connects ;•; - the principle
business street in downtown Salem to the Salem-Beverly Bridge.
Its purpose now relates to a traffic bypass for Brige Street
rather than as a connection to Route 128 and the Interstate
from the Bridge.
The proposal previously subject to the Section 106 would
not have had an effect on the Salem Signal Tower structure.
The previous Section 106 did not recognize the significance
of the Old Planters' Settlement site and did not address the
impact of the relocation of the Skerry House.
The current project reflects a significant change with
regard to its purpose and it would not lessen the impact on
historic resources .
The Documentation does not present the results of the
consideration of all reasonable alternatives which would
avoid or mitigate impacts to the Salem Signal Tower or the
Planters Settlement.
-6-
FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
b. Salem Tower
The Documentation indicates that this National Register
eligible property ( ie, criteria A,C &D, per MHC letter of
July 25, 1990 ) is to be relocated. The finding presented
is that this action will not cause an adverse effect to the
Salem Signal Tower.
The recognized .impact on this significant property is re-
lated to a basic and significant change which has been made
to the undertaking since 1981 and is caused by a new project
element ( ie, the construction of an elevated roadway con-
nection to downtown Salem from the limted access roadway
along the North River and the termination of this new highway
at a principle street �in the Salem CBD) .
It is noted that the Tower has been located adjacent to the
railroad tracks and related to the Salem Tunnel entrance and
in the immediate vicinity of the intersection of Washington
and Bridge Street since its construction in 1928.
The Documentation does not indicate that alternatives to
this new highway proposal, which would avoid impacts to the
Signal Tower, were fully considered by the FHWA.
In any event, while the Documentationiticludes a statement
that the Tower will be moved out of the right-of-way of the .
Bridge Street Bypass Road, and that it will be incorporated
into the plan for the proposed MBTA parking facility and in
such a way as to maintain the remaining railroad context,no
"agreement" with the State Historic Preservation Officer or
the Advisory Council is included in the Documentation to in-
sure that the stipulations for a "no adverse effect" finding
will be implemented. In this regard, I would note that there
is no committment to rehabilitate the structure to the
Secretary ' s Standards, theYe is no committment by the Federal
Agency to cause the proper relocation of the property or
to present the standards which will govern this placement of
the structure in the railroad context, that there is no
committment to finance the relocation, maintainance, security,
and rehabilitation of the structure by the Federal Agency or
others .
What is the current status of the proposed parking garage?
What contigency plan conerning relocation of the Tower is
being considered should the Garage not be constructed?
c. Skerry House
The Documentation does not include data relative to the
Section 106 review and determinations with respect to the
Ephrain Skerry House (ca. 1710-1730) formerly located at
22 Conant Street.
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FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
d. Old Planters ' Settlement
It is noted that a final report concerning Archaeological
Investigations at the Ephraim Skerry House and the March Street
Peninsula is not yet complete for inclusion with the Docu-
mentation. MDPW expected to receive this report, which was
to have been revised to reflect the comment of the MHC
and MDPW Archaeologist, by the end of January, 1991 .
It appears that the impact of the undertaking on this
resource is dependent on the rendering of a final opinion
of significance by the MHC and the consideration of said
opinion by the Agency Official. Further, the question of
notification of the public of the report ' s finding pertain-
ing to identification of resources and the ,potential for
effect is apparentlyAto be addressed by the consulting parties .
In any event, it is noted that the proposed Bridge Street
Bypass Road cannot be accommodated in its proposed alignment
without the relocation of the MBTA railroad tracks .and secur-
ity fence towards the west for a distance of about 2000 feet
from the March Street Penninsula to a point well south of
Conant Street. It is noted that the Salem Archaeological
Survey indicates that the North River shoreline has not been
altered significantly nor has the thearea along the shorline
been extensively developed. The Phase I archaeological site
locational survey conducted in connection with the current
Investigation did not occur within the area to be occupied
by the relocation railroad facilities .
Consideration should be given to the need for further
action in the portion of the project area to be occupied
by the relocated railroad to identify pre-historic and
historic resources, particularly in view of the above-cited
reports conclusions regarding pre-historic evidence along
the North River, its conclusionsregard"&The excellent research
potential in the project area_ and the t .-::, possession of ex-
cellent integrity in portions of the area.
8. SALEM-BEVERLY BRIDGE
a. Prior environmental and historic preservation review
Since this aspect of the undertaking was last reviewed
pursuant to NEPA, Section 4( f) and the Historic Preservation
Act, certain basic dimensions of this proposed structure
have been modified by significant degrees with regard to
factors which influence the size, bulk and scale of the
proposed fixed span bridge( ie the height of the bridge
would be increased by about twenty-two percent ( 22%) , the
length by approximately two-thirds, the width by nearly
tenpercent ( 10%) and the grade by twenty percent ( 20%) ) .
Further, since previous Section 106 reviews were concluded,
the National Register, Fish Flake Hill Historic District
_8_
FEBRUARY 8, 1991
COMMENTS OF JAMES TREADWELL
SECTION 106 DOCUMENTATION
has been substantially enlarged and historic properties
which relate to Beverly 's harbor and waterfront 'have been
identified ( ie, Ferry Landing and See-Side Eye Clinic) .
An updated Section 4( f) determination may also be considered
necessary in this instance.
Accordingly, significant changes appear to have occured _ to
the Bridge proposal relative to its environmental impact and
effect on historic properties since the Federal Agency last
made determinations in these regards .
b. The Salem-Beverly Bridge
The Documentation does not contain the data which permits
a conclusion regarding the eligibility of this property for
the National Register of Historic Places.
c. See Side Eye Clinic
The Documentation does not present data with respect to
the property's significance during the twentieth century.
The Beverly Historic District Commission had noted, by
letter of July 24 , 1990, that the building was a " . . .poten-
tially significant 150 year old historic structure. . . " Is
the Commission satisfied that the structure is not of sig-
nificance based on the data in the Documentation?
Has the building been secured by the MDPW to the satis-
faction of the consulting parties to this Section 106 review?
Should the structure be demolished before the NEPA/Section
106/Section 4( f) review is concluded for the Transportation
Project and before the permits for the new Salem-Beverly
Bridge are secured from various federal, state and local
agencies?
d. Ferry Landing
The comments and information provided to the consulting
.parties by the Beverly Historical Society with regard to the
Ferry Landing is noted. It is quite evident that, as an
interested party, The HIstorical SocietyApocess consider-
able knowledge of and concern with historic properties in
the project area.
The Documentation does not contain any data with respect
to subsurface conditions, nor does it reflect extensive and
meaningful ' documentation research of the Ferry Landing site.
e. Fish Flake Hill Historic District
The Documentation does not reflect a very thorough
evaluation of the visual, atmospheric or audible impacts w6mc
the undertaking, as currently designed, would have on the
District or how the proposed Bridge would alter its setting.
-9-
Note:Preliminary onsite inspection.
An onsite inspection related to this Section 106 process
for the Transportation Project was conducted on September
20, 1990 . On September 18, 1990, the public became aware of
the inspection upon seeing a notice from Salem Historical
Commission on the Bulletin Board at Salem City Hall.
Subsequently I inquired about the meeting. I was told that
it was not a public information meeting by the MHC. I was told
by local representatives that the MDPW was of the position that
the inspection/meeting was "too preliminary for the Advisory
Council to attend. " I was also advised that a conscious decision
had been made by those conducting the inspection not to request
the attendence of "interested parties" .
In this case, were these abovecited decisions by the State
Agencies consistent with the FHWA practice under the Advisory
Council Regulations? Will the Advisory Council and "interested
parties" and the public be encouraged to participate in further
meetings ,inspections, etc, which are associated with this project?
-10-
t
CITY OF SALEM, MASSACHUSETTS
PLANNING DEPARTMENT
WILLIAM E.LUSTER � , ONE SALEM QREENffi
,
CITY PLANNER u Irl / - 01970
(508)7458595 EXT
FAX f(0Y
- 4 f q1F
February- 12, 1991
James R. Treadwell , AICPw
36 Felt Street 3' MM(' '
)Ibd��H'Lt�R'bf
Salem, MA 01970
a fy,f;leil
RE: Salem-Beverly Transportation Project
Dear Mr. Treadwell :
Enclosed per your request, please find a copy of^? he Salem
Historical Commission 's letter to Brona Simon regarding the ' cp,
preliminary report of the first phase of the archaeological .'
survey conducted in the March Street Bridge" Area
fr(JGa
I am not able to provide further information as the. , '"
Commission has not yet received the final report of the UMAS
investigation . To the best of my knowledge, the report is
expected any day. It will then be forwarded to, Commission
members for them to review and to comment at an upcomingt fir ;
Commission. meeting.
Thank you for your interest in this project.
Sincerely,
f„
f
ne A. Gu :t{,'' ,r Jia a
Y f t�
lanning Assistant ,: " s"rr
ft
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ONE SALEM GREEN.SiLEwmxSSACxU8ETrSC-1yro
� `6}n745-*59s. EXT. 31 �
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July 13, 1989 ^
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Drona Simon
State Archaeologist and Deputy SUPO
Massachusetts Historical Commission
00 Boylston Street
Boston, M& 01118
'
Dear do. Simon:
The Salem Historical Commission has reviewed the information that you
forwarded to us regarding the first phase of the archeological survey
conducted in the March Street Bridge area.
From the preliminary report, it appears that there is no sign of the
early Planters Settlement, and the Commission, therefore, concurs with your
determinacivn^ It is our understanding that the March Street Bridge
replacement project is considered separate from the Beverly-Salem
Bypass/Route l& project and therefore our concorraoce is limited only to
the March Street Bridge project.
After completion of the archeological work in the remaining ureas, the `
Commission is prepared to review the findings and comment on the impart the
Beverly-Salem Bypass/Route l& project will have on historic elemeurs.
Thank you for your consideration in this mutter.
Re fully,
\
\ ' /\ /'
THE SALEM HISTORICAL COMMISSION
Annie C. Harris
Chairman
J]228
|
�
36 Felt Street
e Salem, MA 01970
July 28, 1990 R E C E I V F D
Mr. Anthony J. Fusco 19QO
Division Administrator
Federal Highway Administration �9 r,,,
10th Floor �aA f9� P 41'C 9 � �o
55 Broadway
Cambridge, MA 02149
RE: Salem-Beverly Transportation Project
Dear Administrator Fusco:
I understand that the archaeological report for the Old Planters '
Settlement in Salem has now been completed by the University of Mass-
achusetts Archaeological Services (UMTS) and will soon be submitted
to your Office by the Massachusetts Department of Public Works. As
a person interested in historic preservation and of the effect of
the subject undertaking on historic resources, I would appreciate
receiving a copy of the above-cited Report as soon as possible so
that I may express my views concerning your efforts to identify
historic properties in accordance with the Section 106 historic
review process .
I had previously requested the opportunity to participate in
the Section 106 process as a "consulting party" as noted in the
letter to Administrator Walsh from Don L. Klima of the Adtisory
Council on Historic Preservation of September 14, 1989. My desire
to actively participate in the consultation process continues, and
I would appreciate your acknowledgement whether my participation
would be agreeable to your Office.
I will very much appreciate your prompt attention to these issues.
Sincerely,
S �
James R. Treadwell, AICP
cc: Don L. Klima
Michael Spratt,NPS
MA SHPO
Annie Harris, SHC
Ann Farnum, Essex Institute
David Goss, House of Seven Gables
h
36 Felt Street
Salem, MA 01970
i
July 25, 1990
Mr. Anthony J. Fusco
� IEWE
Division Administrator
US Department of Transportation J'JLJ � i� '0
Federal Highway Administration
55 Broadway oI
10th Floor `"-
Cambridge, MA 02149
RE: Salem-Beverly Transportation Project (Salem-Beverly Bridge
and Bridge Street Bypass Project: Peabody-Salem Connector) .
Massachusetts Executive Office of Environmental Affairs,
File No. 0756.
Dear Administrator Fusco:
Please let this letter serve as a follow-up to my correspon-
dence to you of July 19, 1990, regarding Section 4(f) requirements
and the William P. Furlong Memorial Park in Salem.
In addition of your consideration of the "constructive taking"
of the Furlong Memorial Park, I would appreciate your agency's
determination regarding the applicability of Section 4( f) in the
instance of the subject project to the following publicly owned
park and significant historic sites:
1. The McIntire (Chestnut Street) National Register Historic
Distirct in Salem, portions of which are adjacent to the Recon-
structed Bridge Street and .in the vicinity of the Dredged Mater-
ial Dewatering Site.
2. The Pierce Nichols House, National Historic Landmark, which
in contiguous of the Reconstructed Bridge Street and the Dredged
Material Dewatering Site in Salem.
3. The Federal Street National Register Historic District in
Salem which is immediately adjacent to the Reconstructed Bridge
Street and opposite the proposed MBTA Parking Facility.
4. The Salem Signal Tower, a property which has been determined
by the Massachusetts Historical Commission (SHPO) to be poten-
tially eligible for listing on the National Register and which
is scheduled to be demolished to accommodate the Bridge Street
Bypass Road.
5. The Fish Flake Hill National Register District in Beverly
which is considered to be within the area of environmental impact
of the proposed Salem-Beverly Bridge and is adjacent to the north-
erm terminus of the Bridge and its system of improved local approach
streets .
6. The See-Side Eye Clinic Building, a 140 +/- year old, water-
front warehouse structure that might be considered by appropriate
local officials to be eligible for National Register listing.
7 . The Ferry Way Park in Beverly, a significant, passive, water-
-2-
front park which was constructed in the 1980s and which relates
to the recently completed Beverly Harbor Fishing Pier. This
park is in very close proximity to the approach structure of
the Bridge and contiguous to the limited access approach road.
Accordingly, the park is subject to visual, noise, air quality,
and accessability impacts from the project. However, and i.
actp1l ity, rather than the subject of a "constructive taking",
a ! tion of the park may be used by the project if, in fact,
t7 levant graphics in the Draft SupplementalEnvironmental
In,p , _ Report are accurate in this regard.
I would note .that. the Impact Report states that this project
will require the use ofproperty which was occupied by the Skerry
House, a First. Period structure which was determined to be eligi-
ble for the National Register and which was demolished by the MDPW
this past Spring. To.' my knowledge, a Section 4(f) analysis was not
undertaken with respect to the Skerry House.
With regard to the historic properties mentioned above, the
MDPW does indicate in the Impact Report that neither the Federal
Highway Administration nor. the Advisory Council and Massachusetts
Historical Commission have yetto'determine. whether. the undertaking
would have an adverse. affect in accordance withi.the Section 106
historic review process.
Thank you for your consideration of the conclusion of the
MDPW, as set forth in the Draft Supplemental Environmental Impact
Report, that the::Salem-Beverly..Transportation Project does not
involve any Section 4(f) properties.
Sincerely,
,S ---�
James R. Treadwell, AICP
cc,: John G. Bestgen, FHWA
Commander, First Coast Guard District
Don L. Klima, Advisory Council
John P. DeVillars, MA EOEA
Jane F. Garvey, MDPW
James O'Connell, MCZM
Valarie Talmage, MHC
Robert Crecco, US DOT
Larry Issacson, FHWA
Annie Harris, SHC 41 --
William Finch, BHDC
36 Felt Street
Salem, MA 01970
July 22 , 1990
Mr. John P. DeVillars, Secretary R E C E I V E D
Executive Office of Environmental Affairs
20th Floor JUL 2 4 1990
100 Cambridge Street
Boston, MA 02202
Attention: MEPA Unit
RE: Salem-Beverly Transportation Project, EDEA 0756
Dear Secretary DeVillars:
With respect to the Draft Supplemental Environmental Impact Report
(DSEIR) for the subject project and the evaluation of the impact on
historic and archaeological resources, I would offer the following
comments.
Archaeological Resources.
1 . The Massachusetts Department of Public Works (MDPW) has not
evaluated the impact of the Salem-Beverly Transportation Project
on Blubber Hollow, a property which is described in "Salem, Mass-
achusetts, An Archaeological Survey of the City", June, 1988, as
" . . .an excellent candidate for an historic/archaeological district" .
Within this potential district the MDPW proposes to undertake ex-
tensive excavation to accommodate the relocated North River Canal
into a new 40 ' x 1500 ' channel. No evidence of an archaeological
investigation of this area of potential effect is presented in the
DSEIR, thus precluding an informed assessment of the impact of the
project on the Blubber Hollow district.
2. With regard to the Old rLanters ' Settlement along the eastern
shore of the North River, the MDPW indicates on page 4-29 of the
DSEIR that " . . .thorough archaeological testing program. . .uncovered
no significant archaeological resources:' This statement appears
to be erroneous since the Preliminary Management Summary Report
(June 21, 1989) discovered both 17th Century and 19th Century
material of significance. In this regard,the Massachusetts His-
torical Commission has concluded that the Skerry site "may poten-
tially contain sinificant information concerning the early his-
torical settlement of the March Street peninsula. . ." and that the
19th Century resource on this site ". . .could be eligible for list-
ing in the National Register° With regard to any more recent test-
ing at the Planters ' Settlement, the MDPW has failed to provide any
information in the DSEIR which would permit an informed assessment
of this issue.
-2-
3 . The Salem Archaeological Survey cited above indicates that the
North River shoreline has not been altered significantly nor has
the area been extensively developed. Accordingly it would be
appropriate for testing at the Old Planters ' Settlement be expnd-
ed to include sites which will be occupied by the relocated rail-
road between the existing tracks and the North River. This will
permit the impact of the project on this archaeological resource
to be more effectively analyzed.
Historic Resources:
1. The Federal Highway Administration (FHWA) and the Advisory
Council on Historic Preservation both define adverse effects on
hsitoric resources as including the introduction of visual, audi-
ble or atmospheric elements that are out of character with the
property or alter its setting. Adverse effect is not limited to
the taking or demolition of properties.
With regard to the Fish Flake Hill, Federal Street and Chestnut
Street National Register Historic Districts and the Pierce-Nichols
House National Landmark, the MDPW does not evaluate the impact of
the project on these properties with respect to the adverse criteria
cited above.
Concerning the Fish Flake Hill Historic District, it is noted
that the Massachusetts Historic Commission (MHC) has requested
data relative- to this criteria in 1989 from the MDPW. This infor-
mation if not included in this DSEIR.
2. The North River Canal is listed by the National Park Service as
a significant historic resource and the Canal is actually depicted
among "Images Along the Leather Tour" in the Park Service's recent
publication for"The Salem Project:
The MDPW indicates that this structure, constructed in 1881/1885,
is not afforded the protection of the historic laws and regulations
since the historic and visual integrity of the North River industri-
al area in Salem is gone.
No information is included in the DSEIR to document the opinion
of the interested historic agencies in this regard, to rectify the
above-cited conflict concerning significance, .or concerning the
possible need for HABS/HAER compliance concerning this facility.
3 . The DSEIR indicates that the Salem Signal Tower has been deter-
mined to be potentially eligible for the National Register. However,
the survey data is not presented in the DSEIR, thus precluding an
informed assessment respecting the characteristics of this property
which qualified it for listing.
The MDPW opines that the Tower is no longer eligible but does
not substantiate this positon with the opinion of any State or
Federal historic agency. In any event the MDPW does not present
any finding relative to feasible means and measures to avoid or
minimize damage to this resource.-
4 . The DSEIR fails to reflect an evaluation of impact of the proposed
project on the 140 year old waterfront building in Beverly which rep-
. . -3-
resents the only remaining 19th Century Building on the harbor
of the size and scale prevalent in this period. No technical
information to permit an informed judgement regarding the signif-
icance of this building or a determination of effect is presented
in this MEPA document by the MDPW.
General:
1 . By letter of February 7, 1990 the Advisory Council did advise
the FHWA on the need to fulfill its compliance responsibilities for
the subject project. By letter of June 26, 1990 the State Historic
Preservation Officer has contacted the FHWA to inquire of recent
changes to the project which would demand consultation. Also, back
in 1988, the Beverly Historic District Commission notified the State
Historian of its opinion that the scale and overall concept of the
Salem-Beverly Bridge would cause an adverse impact on Beverly's
historic resources.
The MDPW has not included this or similar communication in the
DSEIR although such information is of significance to its Deter-
mination of Effect, of importance to the satisfaction of the Section
106 historic review process, the evaluation of impacts on historic
properties, and would assist other agencies and the public in
making an informed judgemnt concerning the impact of this project.
2 . The MDPW indicates that concurrance in the conclusions regarding
the lack of any impact of the Transportation Project on historic
properties is being sought from the FHWa, the MHC and the Advisory
Council . It should be noted that the consultation required to achieve
such concurrance could, in fact, result in a determination that the
project will impact on some of the many historic resources located
in the area. In turn, measures to avoid or minimize impacts might be
necessary for inclusion into a complete assessment of environmental
impact. Accordingly, it might ..be appropriate to finalize the EIR
subsequent to the conclusion of the historic preservation consulta-
tion and concensus by the parties to the determination of the effect
which the Transportation Project will have on historic resources.
Thank you for the opportunity to comment on this project.
Sincerly,
S'
James R. Treadwell, AICP
cc: Don L. Klima
Valarie A. Talmage
Annie Harris
William Finch
Frank A. Bracaglia
36 Felt Street
Salem, MA 01970
August 26, 1989 ?
Ms . Jane F. Garvey, Commissioner ��`
The Commonwealth of Massachusetts
Executive Office of Transportation SEP
� j
and Construction 1989
Department of Public Works
Office of the Commissioner
Ten Park Plaza
Boston, Massachusetts 02116-3973
Ms. Valerie A Talmage, Executive Director
State Historic Preservation Officer
Massachusetts Historical Commission
80 Boylston Street
Boston, Massachusetts o2116
RE: Historic Preservation ( "Section 106" ) Review
Beverly-Salem (Route 1A) Bridge and Bridge Street Bypass
Ladies:
I have reviewed the Preliminary Management Summary Report,
Subsurface Archaeological Testing of Areas 1 and 3, UMAS,
dated June 21, 1989 and the related DPW comment which were
transmitted to me by the letter of Ms. Brona Simon of
August 17, 1989. I have the following comment.
1 . I would re-iterate my request fcr; information regarding
the basis for concluding the extent of the test area and for
a description of the area of the subject project 's potential
effects as set-forth in my letter to you of June 15, 1989
relative to the Summary Report of Area 2 . ' However, lacking
the specific information previously requested but recognizing
the extent of the Planters Settlement as described in secondary
sources such as Perley( 1924 ) and Mrozowski et al ( 1988) and
the considerable area which is to be effected by the Bypass and
related activities such as railroad relocation, it could be
concluded that the extent of the identification effort ( 12
lots ) is inadequate.
2 . I would c®acur with the UMAS recommendation for Phase II site
examination in both the Front and the Back Yards of the Skerry
House Lot in order to gather sufficient information to evaluate
the eligibility of the resources identified for the Register.
The point made by the DPW staff that " . . .this feature[early-
mid 19th Century] does not relate to the purposes for conducting
the archaeological survey. . . " and located in the Skerry House
Back Yard is seen as particularly irrelevant to the intent of
providing protection for all properties of National Register
quality.
-z-
3 . Presuming that the archaelogical features identified at the
Skerry House are potentially eligible for the National Register,
I would anticipate that the MDPW will observe the direction -
and regardingsuch matter as consideration of preservation in
place, securing the comments of the Council and preparing the
Preliminary Case Report, developing a Data Recovery Program,
etc - as set forth in the Executive Director ' s"Principles
in the Treatment of Archeological Properties" .
With the exception of the issue of segmentation of the March
Street element, I am not aware of your consideration of any of
the issues which I raised in my previous letter of comment
of June 15, 1989 nor have I received any of the information
which I requested there-in. While I appreciate the opportunity
to participate in this Section 106 process, I would consider
it to be more in accordance with an active role and of a pro-
ductive nature as envisioned by the Regulations if an acknow-
ledgement of the issues raised were forthcoming and the
issues resolved.
Thank you for providing me with the opportunity to comment.
Sincerely,
James R. Treadwell
cc: Don Klima, ACHP
James Walsh, FHWA
Salem Historic Commission/
JR
36 Felt Street
Salem, MA 01970
June 15, 1989
Ms . Jane F. Garvey
Commissioner
The Commonwealth of Massachusetts
Executive Office of Transportation
and Construction
Department of Public Works
Office of the Commissioner
Ten Park Plaza
Boston, Massachusetts 02116-3973
Ms . Valerie A. Talmage
Executive Director
State Historic Preservation Officer
Massachusetts Historical Commission
80 Boylston Street
Boston, Massachusetts 02116
RE: Historic Preservation ( "Section 106" ) Review
Beverly-Salem (Route 1A) Bridge and Bridge Street Bypass
March Street Bridge
Ladies:
I have reviewed the letter of May 26, 1989 from Mr. Robert
H. Johnson, P.E. , of the Massachusetts Department of Public
Works (MDPW) to the Massachusetts Historical Commission (MHC)
which was transmitted to me with the letter of Ms. Brona Simon
of June 5, 1989 . I subsequently received and have considered
the "Preliminary Management Summary Report, Subsurface Archaeo-
logical Testing of the Beverly Salem Bypass Project, March
Street Bridge Detour (Area 2 ) , Salem, Massachusetts", Univer-
sity of Massachusetts Archaelogical Services, dated May 25,
1989 . Pursuant to the direction provided by the Advisory
Council on Historic Preservation at 36 CFR Part 800 I would
offer the following observations respecting the documentation
cited above:
1. These comments should not be considered as comprehensive
or complete since the following is not avialable for
my consideration:
a. the background research results for the Old Planters
Settlement,
b. a description, graphic and written, of the project
which is being subject to this review ( that is, the
March Street Bridgeproject and/or the March Street
Bridge Detour)
c . a description of the project 's area of environmental
impact and the basis for concluding the environment
which would be affected by the project,
d. the basis for concluding the extent of the location
of the test area in this instance.
-2-
2 . The Preliminary Management Summary Report relates to the
testing of nine lots along March Street inSalem.
The Report concludes that no sites eligible for the
National Register were observed and recommends no further
survey for the "March Street Bridge detour" . I have
no basis for disagreeing with that recommendation.
3. It would appear reasonable and appropriate in this
instance that the "Section 106" documentation include
views of the MHC and determination by the Agency Official
which reflect the results of consideration of the follow-
ing issues:
a. while the March Street Bridge iS? recognized as having
"independent utility", it could be considered to be a
part of the Beverly-Salem Bridge and Bridge Street Bypass
project. I£ this is, in fact, the case, concluding the
historic preservation review for the March Street Bridge
could be construed as segmenting the project, a practice
which is not consistent with NEPA or the Historic Preser-
vation Act Regulations . Environmental and historic preser-
vation review are in process and continuing for the over-
all project.
b. it is noted by Mr. Johnson thatthe final locational
report for the Old Planters Settlement research area
will be forthcoming and that archeaological fieldwork and
historic structures analysis are in process within this
resource area. Would the principles of "Section 106"
or futher deliberation under the guidance of 36 CFR Part
800 be compromised should the historic preservation
review be concluded for a portion of this site at this
time and before conclusion of the review process relative
to the Old Planters Settlement.
4 . Is Section 800 .4(d) of the Regulations regarding providing
documentation to the public when no resource in identified
considered to be applicable to this March Street Bridge
determination?
I would appreciate receiving information alluded to in comment 1
above so that I might supplement these observations, as appropriate,
and will otherwise look forward to an acknowledgement of the
comments which are set-forth herein.
Thank you for requesting my input into the "Section 106" consul-
tation process .
Sincerely,
}
/ Rp Treadwell, AICP
cc: Don Klima, ACHP"
James Walsh, FHWA
Salem Historic Commission
SETTS *mss
C/D
March 6, 1989
James Treadwel l 'fMISS �e�* 2 3 E89
36 Fe
Salem1 tMAtreet 01970 �om"tOnlVealth for ,N
RE: Route IA, Salem - Beverly Bridge
Dear Mr. Treadwell :
Thank you for your letter which was received at this office on February 13,
1989, concerning the Route IA Bridge project in Beverly and Salem. The MHC
recognizes your concerns regarding potential adverse effects of this project
to historic properties.
As you noted in your letter, staff of the Massachusetts Historical Commission
requested a meeting with representatives of the MDPW, Beverly Historic
District Commission, Salem Historical Commission, City of Salem, and other
interested parties in order to address concerns raised concerning the effects
of the Route IA project on significant historic and archaeological
properties. The meeting was held at the office of the MDPW on December 14,
1988. At the meeting, the MHC requested that the MDPW provide additional
information concerning the project, in order to more fully understand the
project's impacts; this information has not yet been received. For further
information, you might wish to contact MDPW Associate Commissioner, Ellen
DiGeronoimo, 10 Park Plaza, Boston, MA 02116.
The MHC appreciates receiving comments from interested parties concerning the
possible project impacts to significant historic and archaeological
properties, through correspondence, meetings and/or a public hearing. Should
the MHC hold further meetings or a hearing on this project, you will be
notified and invited to participate.
Thank you once again for interest. —
Sincerely,
V A.Tc�
Valerie Talmage
State Historic Preservation Officer
Massachusetts Historical Commission
cc: Mass. Department of Public Works
Beverly Historic District Commission
Salem Historical Commission
Salem Planning Department
Advisory Council on Historic Preservation
Federal Highway Administration
Mmrcusetts Historical Commission,Valerie A.Talmage,Executive Director,State Historic Preservation Officer
YY 80 Boylston Street,Boston, Massachusetts 02116 (617) 727-8470
Office of the Secretary of State,Michael J. Connolly,Secretary