Jones Library’s Section 106 Review Hits a Speed Bump
Photo: National Park Service
While Town officials had previously indicated that the Section 106 historic preservation review for the Jones Library expansion/demolition plan (see also here) would be completed by Nov. 15, the Massachusetts Historical Commission (MHC), which must ultimately approve the review, notified the town last week that more must be done to comply with the process.
Completion of the Section 106 review is crucial to the library project because HUD and NEH cannot release their approximately $2.1 million in grants that they have provisionally awarded to the town until the MHC is satisfied that the project’s adverse effects on the library have been avoided, minimized or mitigated as fully as possible.
On October 2, as part of the Section 106 process, Jones Library Director Sharon Sharry hand delivered to the Massachusetts Historical Commission a letter setting forth the project’s “adverse effects” on the historic library building. The letter read, in part: “The Town has determined that the Project will have an ‘adverse effect’ on historic properties through the physical destruction of part of the Jones Library, alterations to the interior circulation and historic materials, and construction of a rear addition, and changes to the visual setting of the Amherst Central Business Historic District and the Strong House.”
In a letter dated November 1 to Jones Library Project Manager Robert Peirent, Brona Simon, Executive Director of the MHC, concurred with the town’s findings of adverse effects. Simon requested that the town provide to the MHC and other consulting parties an “alternatives analysis” regarding how each of the adverse effects might be addressed. Simon explained that “at a minimum” there should be an alternatives analysis of roof materials, staircases and circulation, woodwork, and the size, scale, and massing of the proposed addition. Simon wrote that she looked forward to consulting with the town to “explore alternatives that would eliminate or minimize the adverse effect of the proposed project.”
In the Consultation Parties Public Meeting on October 9, and elsewhere, the Jones Library Trustees have indicated their intention to “mitigate” these adverse effects by posting photographs of the historic features of the original building. It now appears that the proposed photography display will not be sufficient to discharge the Town’s historic preservation responsibilities under Section 106.
On a procedural matter, in her November 1 letter, Simon also pointed out that as the State Historic Preservation Officer, the MHC did not need to “opt in” to the Section 106 process, as had been suggested by an August 23, 2024 letter from the town requesting that the MHC respond within 30 days about whether they would be participating as a consulting party. Simon also took the town to task for failing to provide the time or place of the October 9 Consulting Parties Meeting, which prevented the MHC representatives from attending . At the October 9 meeting, Rachael Mangum, from the Advisory Council on Historic Preservation, made particular note about the absence of any representatives from the MHC and asked, “Were they invited to today’s meeting and was there a response?” Jones Library Director Sharon Sharry responded, “They’ve been notified but we haven’t heard from them.”
The Town’s webpage for the Jones Library Building Project notes that “The Town is reviewing this letter [from Simon] and is working on development of the alternatives analysis requested by the MHC”. At this point it’s not clear how this will impact the project, its timeline, or budget.
The full text of Simon’s November 1 letter follows.