Town Initiates Section 106 Historic Preservation Review for Jones Library Expansion
This photo delineates the 1928 and 1993 parts of the Jones, 1928 dark gray, 1993 (to be demolished in the Jones expansion) light gray] Photo: Chris Wolak. https://chriswolak.com/2021/01/31/library-stop-jones-library-amherst-ma/
Source: amherstma.gov
The Town of Amherst initiated the Section 106 Historic Preservation Review process for the proposed expansion of the Jones Library.
Section 106 Historic Preservation Review
Section 106 of the National Historic Preservation Act of 1966 (NHPA) requires federal agencies to consider the effects on historic properties of projects they carry out, assist, fund, permit, license, or approve throughout the country. If a federal or federally-assisted project has the potential to affect historic properties, a Section 106 review will take place. Section 106 gives the Advisory Council on Historic Preservation (ACHP), consulting parties, and the public the chance to weigh in on these matters before a final decision is made. The four-step process includes consultation to explore measures to avoid, minimize, or mitigate any adverse effects that may be identified to the historic property and reach a Memorandum of Agreement (MOA) which records the resolution measures agreed upon to resolve these adverse effects.
Historic properties are districts, buildings, structures, objects, and sites that are listed or eligible for listing in the National Register of Historic Places (National Register). The Jones Library is listed in the National Register as a contributing building in the Amherst Central Business District, which was listed in 1991.
The Jones Library Building Project requires a Section 106 Review because it will receive a Challenge Infrastructure and Capacity Building grant from the National Endowment for the Humanities (NEH), an Economic Development Initiative grant from the U.S. Department of Housing and Urban Development (HUD), and a hazardous waste removal permit from the Massachusetts Department of Environmental Protection (MassDEP). Several review processes have occurred for the Jones Library rehabilitation over the last approximately 10 years in relation to state funding from the Massachusetts Board of Library Commissioners and an application for the Massachusetts Historic Rehabilitation Tax Credit. However, this process pertains specifically to the federal Section 106 review.
The Town of Amherst, acting through the office of the Town Manager as the Responsible Entity designated by the U.S. Department of Housing and Urban Development (HUD), which is itself the lead Federal Agency, will undertake an environmental review under the National Environmental Policy Act (NEPA), as well as review under related laws, including Section 106. The town, pursuant to 24 CFR §58.4, has assumed the responsibility for environmental review, decision-making, and action that would otherwise apply to HUD under NEPA and other provisions of law that further the purposes of NEPA, as specified in §58.5, including the National Historic Preservation Act.
Proposed Project
The Project proposes the rehabilitation of the Jones Library for continued use as a public library. The Project includes rehabilitation of the Jones Library original building constructed in 1928, removal of the three-story rear addition built in 1993, and new construction of a three-story rear addition. The original building will host a climate-controlled Special Collections storage space, the Special Collections Exhibit space, the town’s Civil War Tablets, a portion of the enlarged Children’s Room, three adult reading rooms, a portion of the adult fiction collection, the entire enlarged ESL department, an accessible Staff Lounge, and the Goodwin Meeting Room, which will now be available for public use. The addition will house an accessible Amherst Meeting Room, an enlarged Woodbury Meeting Room/kitchenette, gender neutral restrooms, the Burnett Art Gallery, an enlarged Special Collections Reading Room, the other half of an enlarged Children’s Room including a Children’s Activities Room, a gathering space for patrons to be able to consume refreshments, the AV collection, a Sensory Room, the other half of the adult fiction collection, the adult nonfiction collection, public Internet terminals, the Reference department, three quiet study rooms, and the new Teen Room which will include a Makerspace. The Project will upgrade the building to meet current library standards, enhancing the library’s role as a community and educational center. It will address costly but critical safety and accessibility concerns, improve and expand children’s and special collections facilities, create dedicated space for ESL and teens, and substantially improve the energy efficiency of the building by eliminating the use of fossil fuels which will result in a Net-Zero-Ready building, and through the purchase of off-site renewable energy, the new building will be Net-Zero.
Invitation to Participate as Consulting Parties
The Town identified the following parties to be invited to participate as consulting parties in the Section 106 process:
- Advisory Council on Historic Preservation
- Massachusetts State Historic Preservation Office (SHPO) / Massachusetts Historical Commission as the appropriate SHPO
- Mashpee Wampanoag Tribe, Wampanoag Tribe of Gay Head (Aquinnah), Stockbridge-Munsee, and Nipmuc as tribal organizations to be consulted regarding the proposed undertaking
- Amherst Historical Commission (AHC) as an appropriate representative of the local government
- Amherst Historical Society as owner of an abutting historic property affected by the Project
- Amherst Historic Preservation Coalition which has requested consulting party status
- Other organizations that have expressed interest in the undertaking.
- Amherst Area Chamber of Commerce
- Amherst Business Improvement District
- Amherst Cinema
- Amherst College Community Engagement
- Amherst Historic Preservation Coalition
- Amherst Historical Society and Museum
- Ancestral Bridges
- Burnett Art Gallery
- Downtown Amherst Foundation
- Downtown Amherst Historic District Committee
- Emily Dickinson Museum
- Eric Carle Museum of Picture Book Art
- Friends of the Jones Library System
- Frost Library, Amherst College
- Hampshire College Community Relations
- Hampshire College Library
- Jones Library
- Literacy Project
- UMass Amherst Department of Architecture
- UMass Amherst Library System
- UMass Amherst University Relations
- Yiddish Book Center
These organizations have been emailed and mailed an invitation letter and have 30 days of receipt of the letter to notify the Town if they choose to be a consulting party to the Section 106 process.
Information on the proposed Project and the Section 106 process, as well as on past local and state reviews, is available on the town website at www.amherstma.gov/3804/Section-106-Historic-Preservation-Review
Any clue as to why this legal review is happening at the end and not much earlier in the process? It’s incredible that this did not happen years and years ago.
The 1928 Jones Library is on both the State and National Registers of Historic Places. Consequently, there are legal restrictions on what changes its Trustees can make to the historic Library building, if federal or state funds help to pay for a project.
Jeff Lee’s handy Illustrated Guide to Adverse Effects to the Historic Jones Library Resulting from the Proposed Demolition-Renovation-Expansion Project [link], shows that the Trustees’ demolition/expansion project would have quite a few “adverse effects” on the historic Library building.
https://www.amherstindy.org/2024/08/23/an-illustrated-guide-to-adverse-effects-to-the-historic-jones-library-resulting-from-the-proposed-demolition-renovation-expansion-project/
To be eligible for grants under the federal and State historic preservation laws, respectively, the Town and Trustees must avoid (federal) or eliminate (State) those “adverse effects,” or else minimize or mitigate them. This is the purpose of the Town’s new process under Section 106 of the National Historic Preservation Law. It can obviously result in modifying this project.
Perhaps this is why both federal and State historic preservation laws require grant recipients to address “adverse effects” early — in fact, “as early as possible in the planning process of any project,” as the Massachusetts Historical Commission puts it. (950 CMR 71.02.)
The Town and Jones Library Trustees failed to do this. Nonetheless, a colloquy last night (22 August) at the Amherst Historical Commission indicated that the Town still intends to go out to bid again next month with this project.
So: 1) Put that demolition/expansion project, with its “adverse effects,” out to bid again; and only then 2) Conduct a Section 106 historical preservation review that will, predictably, result in changes to the project in order to avoid, minimize, or mitigate those very “adverse effects.”
What is wrong with this picture?
Oh Janet, there are so many questions, most of which have been asked though not many answered. For example, why were 2 letters from the state historical commission containing critical information about the Jones Plan, though received by the library director last year, only (unintentionally) disclosed a few months ago?
Just one case of subterfuge by a town department head should prompt an investigation. Surely the good people of the town, no matter their position on the Jones Plan, would agree.
And I forgot to mention that those letters were received prior to votes taken by Town officials and committees regarding the Jones Plan. Hmmm, perhaps therein lies the answer.